GRI 406: Non-discrimination·Disclosure GRI 406-1
Incidents of discrimination and corrective actions taken
Guía práctica para preparar esta divulgación. Use esta ficha para identificar la información a preparar, verificar afirmaciones y organizar la evidencia de soporte. Para los requisitos exactos, consulte siempre la fuente oficial de Global Reporting Initiative.
Estatus legal
GRI 406: Non-discrimination 2016 remains the applicable published GRI Topic Standard and is effective for reports or other materials published on or after 1 July 2018.
Pasaporte publicado
Última revisión el 2026-08-03
Revisado por
Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
Material formativo de LRA · No emitido ni avalado por Global Reporting Initiative
Norma
GRI 406: Non-discrimination
Disclosure GRI 406-1 · 2016
Última revisión
2026-08-03
Material formativo de LRA · No emitido ni avalado por Global Reporting Initiative
Foco de la divulgación
This disclosure requires the organization to report the total number of incidents of discrimination during the reporting period.
It also requires the organization to report the status of those incidents and actions taken, with reference to:
incidents reviewed by the organization;
remediation plans being implemented;
remediation plans implemented, with results reviewed through routine internal management review processes; and
incidents no longer subject to action.
The incident population includes relevant formal complaints, legal actions and identified instances of non-compliance involving internal or external stakeholders across the organization’s operations.
A formally registered complaint can be counted even if it is later not substantiated. The disclosure should therefore not be limited to confirmed cases.
The information can be reported in aggregate. The organization is not required to publish confidential case-level details.
Policies, commitments, grievance mechanisms and preventive measures are reported through Disclosure 3-3 where non-discrimination is a material topic. They do not replace the quantitative and status information required by GRI 406-1.
Este material formativo de LRA apoya la preparación de la divulgación. Para los requisitos exactos, consulte siempre la fuente oficial de Global Reporting Initiative.
Antes de empezar
Antes de empezar
Una breve lista de comprobación antes de preparar esta divulgación: marque cada punto a medida que lo resuelva.
Preparación
Información clave que preparar
| Campo de preparación | Qué recopilar | Pista de evidencia | Responsable |
|---|---|---|---|
| Incident population and sources | Formal complaints, legal actions and identified instances of non-compliance involving internal and external stakeholders. | HR, Ethics, Legal, Compliance, grievance, customer and supplier complaint registers. | Ethics / Compliance / Legal / HR |
| Total incidents | Total number of incidents of discrimination during the reporting period. | Reconciled master incident register and counting methodology. | Disclosure coordinator |
| Incidents reviewed | Incidents reviewed through the organization’s formal process. | Investigation records and review status. | Case owner |
| Remediation being implemented | Incidents for which remediation plans remain in progress. | Remediation plans, action owners and implementation records. | Case owner / Compliance |
| Remediation implemented and reviewed | Incidents for which remediation was completed and results reviewed through routine management processes. | Completed plans and management-review evidence. | Compliance / Management |
| No longer subject to action | Resolved, completed, withdrawn or other incidents requiring no further action. | Closure records and documented closure basis. | Case owner |
| Scope and classification mapping | Stakeholder type, discrimination ground, reporting period and mapping from local labels. | Methodology and case-taxonomy mapping. | Sustainability Reporting / Legal |
| Privacy and omissions | Aggregation, confidentiality and any reason for omission. | Privacy assessment and GRI content-index documentation. | Legal / Privacy |
Cómo prepararlo
Solicitar los datos
Request the disclosure evidence
Traduzca la divulgación a una pregunta de negocio interna y adáptela después al lenguaje propio de su organización.
Please provide the discrimination-incident register for [reporting period]. Include incidents registered or identified through: HR and employee-relations channels; Ethics or speak-up systems; Legal and regulatory records; grievance mechanisms; audits or formal monitoring programmes; customer, supplier or business-partner complaint channels; and other applicable formal procedures. For each record, provide: anonymized incident ID; date registered or identified; stakeholder type; internal case classification; discrimination ground; source system; review status; remediation status; whether implemented remediation has been reviewed; whether the incident is no longer subject to action; and any linked duplicate record. Please also provide the reconciled total for the reporting period.
Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.
Solicitud mejor
Please provide the discrimination-incident register for [reporting period]. Include incidents registered or identified through: HR and employee-relations channels; Ethics or speak-up systems; Legal and regulatory records; grievance mechanisms; audits or formal monitoring programmes; customer, supplier or business-partner complaint channels; and other applicable formal procedures. For each record, provide: anonymized incident ID; date registered or identified; stakeholder type; internal case classification; discrimination ground; source system; review status; remediation status; whether implemented remediation has been reviewed; whether the incident is no longer subject to action; and any linked duplicate record. Please also provide the reconciled total for the reporting period.
Redacte su divulgación
Notas que convierten los datos en una divulgación
Plantillas formativas de LRA: adáptelas a su organización y consulte la fuente oficial antes de la aprobación.
Nota metodológica
Incidents include formal legal actions, registered complaints and instances of non-compliance identified through established procedures. The total covers relevant incidents involving internal and external stakeholders across the organization’s reporting scope.
Nota de contexto
Keep mandatory GRI Requirements, GRI recommendations and additional LRA preparation controls clearly distinguished. Apply a GRI 1 reason for omission where required information cannot be reported.
Centro de descargas
Herramientas y formularios de preparación
Herramientas profesionales de preparación para GRI 406-1 — gratuitas con la membresía de LRA Community. Regístrese una vez (es gratis) y se desbloquean todas las descargas, junto con la Biblioteca de divulgaciones, las plantillas y el asistente de IA de LRA.
Preparación para el aseguramiento
Para cada afirmación, compruebe la evidencia
| Afirmación | Riesgos | Evidencia que comprobar |
|---|---|---|
| We included formal complaints, legal actions and identified instances of non-compliance that meet the GRI incident definition. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The incident population includes relevant internal and external stakeholders. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Relevant HR, Ethics, Compliance, Legal, grievance and external-stakeholder complaint systems were reconciled. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| We did not limit the total to confirmed or substantiated cases. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| We removed duplicate records concerning the same incident. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The current-period total is separated from incidents originating in prior periods. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The published total reconciles to the master incident register. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| We mapped incident status and actions to the four references specified by GRI 406-1. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The disclosure identifies incidents reviewed by the organization. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The disclosure identifies remediation plans being implemented. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The disclosure identifies implemented remediation whose results were reviewed through routine management processes. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The disclosure identifies incidents no longer subject to action. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Internal labels such as open, closed and substantiated were not used as substitutes without mapping. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Zero incidents are explicitly reported where applicable. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Incident counts are reported as whole numbers and are not rounded or estimated. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The disclosure does not reveal information that could identify affected persons. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Any required information that cannot be reported is addressed through the applicable GRI reason for omission. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The status cut-off and reporting period are documented and consistently applied. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
Paquete de evidencia que preparar
Carencias habituales en los informes
Ejemplos
Ejemplos ilustrativos
Sintéticos, redactados por LRA: no proceden del informe de ninguna empresa ni del texto de ninguna norma.
Illustrative synthetic example — Retail and distribution
During 2025, the organization recorded three incidents of discrimination through its formal complaint channels.
All three incidents were reviewed.
Remediation plans were being implemented for one incident.
Remediation plans had been implemented and their results reviewed for one incident.
One incident was no longer subject to action after the complaint was withdrawn and no further organizational action was required.
The information is presented in aggregate to protect confidentiality.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Construction and engineering
Five incidents of discrimination were registered during the reporting period, including four involving workers and one involving a contractor.
All five incidents were reviewed. Remediation was being implemented for two incidents, remediation had been implemented and reviewed for two incidents, and one incident was no longer subject to action.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Zero incidents
No incidents of discrimination were registered or identified through the organization’s formal processes during 2025. Accordingly, the four incident-status and remediation categories were not applicable.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative treatment — complaint not substantiated
A formally registered complaint was included in the incident total even though the investigation did not substantiate the allegation. The incident was reported as reviewed and no longer subject to action.
Scenarios to work through
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Informes de empresas
Cómo informan las empresas sobre GRI 406-1 en la práctica
Ejemplos de práctica de reporte completa y parcial. Son análisis basados en evidencia, no plantillas exactas para copiar.
CRH reports 23 instances of discrimination in 2024. It states that all were fully investigated and that policies and training were reinforced where necessary, with disciplinary action taken where appropriate.
This provides:
the total number of incidents;
aggregate evidence that the incidents were reviewed; and
a general description of actions taken.
However, the disclosure does not clearly map the 23 incidents to:
remediation plans being implemented;
remediation plans implemented with results reviewed; and
incidents no longer subject to action.
Classify the disclosure as substantial but partial practice.
Remove all discussion of forced labour, product labelling and supplier commodity assessments because these matters do not support GRI 406-1.
The relevant information appears directly in CRH’s GRI Index on report page 103.
JD Logistics’ 2025 ESG Report states that it had no incidents of employment discrimination during the reporting period.
This provides a zero figure for employment-related incidents. Where the report’s formal processes identified no incidents, the four status and remediation categories are not applicable.
The report also describes general human-rights remediation mechanisms, including possible apologies, position adjustments, termination and clawback of incentives. These are general procedures and should not be presented as corrective actions taken in response to actual 2025 discrimination incidents.
The principal remaining review point is scope: employment discrimination does not clearly demonstrate whether relevant incidents involving applicants, customers, suppliers or other external stakeholders were also included.
Classify the disclosure as partial because the reported zero is narrower than the full internal-and-external-stakeholder compilation requirement unless broader scope is evidenced elsewhere.
JD Logistics’ report expressly reports zero employment-discrimination incidents and separately describes its general remediation mechanisms.
Marfrig’s 2024 Integrated Report provides relevant information across more than one section.
Page 103 reports:
ten discrimination cases in Brazil;
one discrimination case in Uruguay;
corrective measures assessed and applied where complaints were substantiated; and
annual compliance training used to reduce the risk of recurrence.
Page 33 separately reports 20 combined incidents of harassment or discrimination in North America.
The report therefore contains substantial relevant information, but it does not clearly provide one consolidated GRI 406-1 total across all operations. The North American combined category also needs to be mapped to the GRI discrimination definition before it can be added to the total.
The report does not clearly map the incidents to all four required status and action references. A statement that corrective measures were applied in substantiated cases does not explain:
how many incidents were reviewed;
how many had remediation being implemented;
how many had implemented remediation with results reviewed; or
how many were no longer subject to action.
Classify the disclosure as substantial partial practice rather than presenting 20 incidents as the complete GRI total.
Marfrig’s GRI Index points Disclosure 406-1 to page 103, while page 33 contains additional regional complaint-channel data.
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GRI
GRI 406-1
dentro de GRI 406: Non-discrimination
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Profundizar · GRI 406-1
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This guide covers the incident total and the four status and action references required by Disclosure 406-1.
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