Disclosure focus
This disclosure asks an organisation to explain the main actions it is taking to prevent, detect, address and improve business conduct issues. In practice, that means describing the measures in place, how they are implemented, and what parts of the organisation they cover, rather than only listing policies or commitments.
The practical focus is on whether those actions are embedded across the business and value chain, or limited to a few flagship sites or functions. Report the scope, the type of action, and where it applies, so a reader can see how consistently the organisation is managing business conduct in day-to-day operations.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show G1-2 sub-elements (LRA working checklist)
Put the measures into practice.
Keep track of the measures over time.
Set out steps to stop issues before they arise.
State whether ESG factors were used.
Show what share of the relevant scope was covered.
Describe any supplier engagement programmes.
Set out the results of those programmes.
Identify which suppliers were included.
Report the number of training hours delivered.
State whether training was provided.
Explain how the selection was made.
Record the actions taken in response.
Note any breaches found.
Describe any disciplinary steps applied.
Set out the process used to investigate.
Name the roles that were targeted.
Show the percentage of those roles covered by training.
Describe the systems used to monitor.
Set out the procedures that have been defined.
How to prepare it
1Set the reporting boundary first. Decide which parts of the business, which activities, and which people or suppliers are in scope for this disclosure, so every later entry is drawn from the same population.
2Agree the definitions before you start counting or writing. Confirm what your team will treat as an implemented action, a prevention measure, a monitoring activity, a selection basis, training, an engagement programme, a procedure, an investigation, a breach, a follow-up action, and a disciplinary response.
3Gather the source records that support each item. Pull together the internal notes, registers, training logs, supplier records, monitoring outputs, investigation files, and any other working papers that show what was done and by whom.
4Prepare the figures and narrative in the format needed for each datapoint. Record the yes/no fields, the percentage fields, and the descriptive text fields separately, and make sure the numbers and wording match the same reporting period and scope.
5Explain any exclusions, changes, or gaps in a clear audit trail. If a group, activity, supplier set, or role was left out, or if the method changed from the prior period, note what changed and why so the reported picture can be understood.
6Check the draft against the official source before sign-off. Confirm that every required item is covered, the wording still reflects the underlying requirement, and the final submission is consistent with the current ESRS source text.
Request the data
Request the business conduct actions log and supporting evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What actions, controls and follow-up activity has the organisation put in place to prevent, monitor and address business conduct issues, and what supporting records show how these were applied in practice?
Use the organisation’s own names for policies, controls, training, monitoring, investigations and disciplinary steps first, then map them to the disclosure. Keep the request in business language that the owner already uses internally, and check the source material before sign-off.
Weak request
Please provide the ESRS G1-2 actions, prevention measures, monitoring actions, ESG criteria used, training coverage, engagement programmes, procedures, monitoring systems, investigation processes, breaches identified, actions taken and disciplinary measures.
Why it fails: This is too close to framework wording and bundles many labels without telling the owner what internal records to pull. It does not ask for the organisation’s own terms, source systems, boundary or evidence trail, so the response is likely to be incomplete or hard to map.
Better request
Please send the conduct actions log and the supporting records for [period] from your team’s normal systems. Include the steps already in place to prevent issues, the checks or reviews used to spot problems, any training or supplier engagement activity, and any case outcomes or follow-up actions. Use your own internal labels first, then we will map them to the reporting categories.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
State how the organisation defined the relevant scope, what it counted as an action, training, engagement, procedure, monitoring step, or investigation step, and how it determined the basis for any percentages or selections reported.
Context note
Explain what the figures show about how the organisation manages the issue in practice, including the extent of implementation, the reach of training, the scale of supplier engagement, and whether the control framework is in place.
Fluctuation statement
If any figures changed materially, note whether that was driven by a wider rollout of controls, a change in the number of people or suppliers covered, a revised selection approach, or a shift in the amount of activity recorded.
Content index entry
G1-2 Actions (Business Conduct) — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for G1-2 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.
Free · Community members
Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
A percentage is stated without the underlying counts (numerator and denominator).The denominator — what the figure is a share of — is not explained.Partial scope is reported as if it were complete coverage.One-off activities are counted as if they were ongoing programmes.Boundary or period changes that move the figure are not flagged.Exclusions from the reported scope are not listed or explained.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The team asks a policy, training, or investigations lead for figures that sit with the business unit actually running the action, so the answer comes from the wrong place.
Framework language instead of local terms
People ask for data using disclosure labels rather than the organisation’s own names for controls, programmes, and case handling, which leads to mismatched responses.
Scope not pinned down
The collector does not state which entities, functions, or locations are in scope, so different teams send data for different parts of the business.
Wrong time basis
The request does not fix the reporting period or cut-off point, so some teams report current status while others send figures from a different date range.
Mixed counting basis
One source counts people, another counts sessions or events, and the numbers are merged without saying which basis was used.
Source labels stripped out
Original system tags, case IDs, course names, or programme titles are removed during collation, making it hard to trace each figure back to its source.
Separate groups merged
Data for different staff groups, supplier groups, or action types is combined even though it should stay separate for later reporting.
Evidence details missing
The pack contains the number or narrative but not the supporting file name, date, owner, or version, so the figure cannot be checked later.
No review trail
The draft is circulated without a named reviewer or sign-off record, so nobody can show who checked the data before it moved forward.
Where judgement is often needed
Acquisitions and disposals during the year
Decide whether to include only the business units you controlled at the reporting date or to also bring in sold or newly bought operations for part-year activity, and explain the cut-off used.
Different local meanings for the same conduct topic
Where country teams use different internal labels or legal definitions for the same behaviour, map them to one group-wide description and say how you reconciled the local wording.
Teams close to the boundary of scope
Set out whether shared-service staff, temporary workers, contractors, or other near-boundary roles are counted in the action narrative, and state the rule used to include or exclude them.
Choosing the timing basis for actions and training
Be clear whether the figures and descriptions reflect what happened by period end, by approval date, or by completion date, and keep that basis consistent across the card.
Measured figures versus management estimates
If complete records are not available, use a reasonable estimate only where needed, label it as such, and explain the source and method behind the estimate.
Rounding and small-number presentation
Apply one rounding approach across the disclosure, and if rounding changes a small count or percentage in a noticeable way, explain the effect so the reader can reconcile the numbers.
Aggregating sensitive people data
When privacy rules prevent showing a small team, a country, or a role group separately, combine the data into a broader bucket and say that the split has been suppressed for confidentiality.
Selecting which actions to describe
If several initiatives exist, choose the ones that best represent the main steps taken on conduct, prevention, monitoring, training, supplier engagement, and follow-up, and explain the selection rule.
Counting coverage across mixed populations
For percentages and training hours, define the denominator up front so it is clear whether you counted all relevant staff, only those in target roles, or only people who actually received the session.
Reporting outcomes and follow-up measures
Separate the action itself from the result it produced, and if the same issue led to both a corrective step and a disciplinary step, describe each one distinctly rather than blending them together.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Consumer goods manufacturing
We are using this synthetic example to show how our group could describe its approach to business conduct oversight. - We have put in place a supplier code, a gifts-and-hospitality rule, and a third-party due-diligence check; we also run periodic reviews to spot issues early and track whether the controls are working. - For supplier screening, we do use environmental, social and governance factors, applying a risk-based scoring method that gives extra weight to higher-spend and higher-risk categories; we also provide anti-bribery and conduct training to 1,260 of 1,500 relevant staff (84%), totalling 2,520 hours. - Our supplier outreach covered 180 of 240 active suppliers (75%); the programme led to 34 corrective plans, 12 supplier exits, and no confirmed cases of repeat non-compliance at year end. - We have defined escalation steps, a case-tracking system, and a formal review route for allegations, with monthly monitoring by compliance and internal audit.
Synthetic illustration only; figures and processes are invented for training purposes and are internally consistent.
Illustrative (synthetic) example — Commercial property services
This is a synthetic example showing how our group could explain its business conduct controls in plain language. - We introduced a tenant-and-vendor integrity policy, a conflicts register, and spot checks on higher-risk relationships; these are supported by routine monitoring so we can see whether the controls are being followed. - We do use environmental, social and governance factors when choosing service partners, using a weighted review that favours suppliers with stronger labour, safety, and ethics records; we trained 420 of 500 relevant colleagues (84%), for 1,050 hours in total. - Our engagement work reached 96 of 120 suppliers (80%) and produced 19 remediation plans, 7 contract renewals with conditions, and 4 supplier removals after unresolved issues. - We have set out reporting steps, a monitoring platform, and an investigation workflow for concerns, with quarterly oversight by compliance and risk teams.
Synthetic illustration only; figures and processes are invented for training purposes and are internally consistent.
How companies report G1-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
EssilorLuxottica Société anonyme
Healthcare Providers, Services and Technology · France · 2024
EssilorLuxottica's 2024 Sustainability Report provides covered evidence of implementing anti-bribery and corruption programmes, including training on business conduct and anti-bribery measures, with a target of 85% completion (pp. 137, 140, 142, 143). The report also references a SpeakUp reporting system related to ethics and anti-corruption (p.140). However, disclosures on measures for preventing trafficking in human beings are unclear, with only related context found without a clear statement (p.30), and several other narrative items and percentage values relevant to the disclosure are not found in the report.
EDP, S.A.
Electric Utilities / IPP / Energy Traders · Portugal · 2025
EDP, S.A.'s 2025 Integrated Annual Report provides some relevant information on business conduct and related party transactions aimed at preventing conflicts of interest, notably on page 245. The report also references anti-corruption and anti-bribery measures, including certification under ISO 37001 and a Compliance Specific Program, with mentions on pages 187, 193, and 585. However, clear and detailed disclosures specifically addressing prevention and detection of corruption and bribery are unclear or missing, with only partial context found on pages 547, 548, and 128, and no quotable evidence for key narrative or percentage datapoints elsewhere in the report.
Terna S.p.A.
Electric Utilities / IPP / Energy Traders · Italy · 2025
Terna S.p.A.'s 2025 Annual Report provides partial supporting context on risk mitigation measures related to business conduct and supplier relationship management, mentioning prevention efforts involving employees and contractors (p.339). The report references the adoption of a comprehensive system for corporate culture and business conduct policies (p.352) and notes the company’s ISO 37001 certification for anti-corruption management since 2017 (p.364). However, no clear headline values, detailed narratives, or percentage data specifically addressing the disclosure were found, leaving the overall methodological and quantitative aspects unclear.
✓ LRA AI Assistant · Human-in-the-loop
Ask Study Studio AI assistant about this disclosure
Get practical answers for your reporting context. Your first two answers are free — join LRA Community for free to continue without a limit.
TryHow do I prepare G1-2?What data do I need to collect?Where can I see a real-report example?What mistakes should I avoid?
2 free answers
Check your understanding
Scenarios to work through
A preparer is drafting the year-end note on business conduct actions. The company has rolled out a new anti-bribery process, a supplier engagement programme, and a whistleblowing review workflow, but the draft only says 'we improved controls' without naming what was done.
QHow should the preparer decide what to include so the note is useful and complete?
Reveal model answer →Hide answer ↑The note should spell out the concrete steps taken, grouped in plain language: what was put in place to prevent issues, what was done to watch for problems, and what action was taken after issues were found. A vague statement about improvement is not enough on its own because the reader needs to see the actual measures, not just the intention.
Why this matters · Describe the real actions taken, not a general claim that things got better.
A company used a mix of ethics, sustainability and supplier-risk factors to choose which staff and suppliers received extra conduct training. The draft report says the selection was based on 'relevant criteria' but does not explain how the group was chosen.
QWhat should the preparer check before finalising the training disclosure?
Reveal model answer →Hide answer ↑The preparer should make clear whether the organisation used business, environmental or social factors to decide who was included, and then explain the method used to pick the people or suppliers covered. If the selection was not based on those kinds of factors, that should also be clear. The point is to show the logic behind the choice, not just the fact that training happened.
Why this matters · Explain the basis for selecting the training group, not only the training itself.
A procurement team ran a supplier conduct programme for 180 suppliers. The draft says 180 suppliers were contacted, but it does not say what changed as a result, and the only training figure available is that 144 staff attended a session out of 160 in scope.
QHow should the preparer handle the outcome and coverage details?
Reveal model answer →Hide answer ↑The preparer should report the result of the supplier programme in practical terms, such as what issues were raised, what commitments were made, or what follow-up actions were agreed. For training, the coverage figure should be based on the relevant group in scope, so 144 out of 160 would be 90%, and the narrative should also state the hours delivered if that is part of the disclosure. The key is to connect the activity to its outcome and to present the coverage consistently.
Why this matters · Pair the activity with its result, and calculate coverage from the correct in-scope group.
A compliance team has a hotline, a case-tracking tool and a disciplinary process for conduct breaches. During the year, 12 breaches were confirmed, 9 led to retraining, and 3 led to formal sanctions, but the draft only mentions the hotline and omits the follow-up steps.
QWhat decision should the preparer make about the way the response process is described?
Reveal model answer →Hide answer ↑The preparer should describe the procedures used to monitor for breaches, how cases are investigated, and what happens after a breach is confirmed. The report should also distinguish between the number of breaches found, the corrective steps taken, and any disciplinary action, rather than blending them into one general statement. That gives a clearer picture of how the organisation responds when conduct problems arise.
Why this matters · Separate detection, investigation and response so the reader can see the full process.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
What should I gather first to prepare disclosure G1-2 on business conduct for this page?+−
Start with the page’s plain-language explainer and the step-by-step preparation section, then work through the listed datapoints. The page is designed to help you turn those inputs into a draft disclosure rather than to act as an official standard.
Which data points does the G1-2 page say I need for the disclosure?+−
The page lists the main datapoints to prepare, including actions taken, prevention and monitoring measures, ESG criteria used, training data, supplier engagement, defined procedures, breaches found, corrective actions and disciplinary outcomes. Use that list as your collection checklist before drafting.
How do I decide the scope for G1-2 business conduct data on this page?+−
Use the page’s preparation guidance and the datapoints that refer to coverage, such as training coverage, suppliers in scope and target roles. The page is meant to help you define what is included in your own reporting set before you draft the narrative and table.
Who should own the G1-2 data collection and sign-off process?+−
The page is aimed at sustainability and ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can evidence the datapoints and explain the methodology. The workbook and evidence-pack sections are there to help those owners coordinate the draft and support review.
What evidence pack do I need to make G1-2 assurance-ready?+−
The page includes an evidence pack with five items to support assurance readiness, alongside six assurance claims to verify. Use those materials to assemble proof for the claims, the data points and the way the disclosure was prepared.
What are the common mistakes on the G1-2 page that I should avoid?+−
The page has a section on common reporting gaps and mistakes, so it is intended to help you spot missing data, weak scope choices and unsupported claims before finalising the disclosure. It also points you back to the evidence pack and workbook so you can check the draft against your source material.
How do I use the Prep & Assurance workbook for G1-2?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format to help you organise the disclosure inputs and assurance checks. Use it with the page’s datapoint list, assurance claims and evidence-pack guidance to build a more complete draft.
What is the printable Library Card for G1-2 used for?+−
The Download Centre also includes a printable Library Card in .pdf format, which is there as a quick reference while you prepare the disclosure. It sits alongside the workbook and the page guidance so you can keep the key points to hand during drafting and review.
Can I use the synthetic example disclosure on the G1-2 page as a template?+−
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table where relevant, to show how the information can be turned into a draft. Treat them as examples only and make sure your own figures and wording stay internally consistent.
How does the G1-2 page help me turn raw data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. That makes it easier to convert your collected datapoints into a structured draft rather than starting from a blank page.
More questions this page can help with
What does the G1-2 business conduct page cover in plain language?Which G1-2 datapoints are about training and coverage?Which G1-2 datapoints relate to supplier engagement and supplier scope?What should be included in the G1-2 evidence pack for assurance?How do I check the six assurance claims on the G1-2 page?What are the most common reporting gaps for G1-2 business conduct disclosures?How do I use the G1-2 workbook and Library Card together?Are there example tables or narrative starters for G1-2?How do I write a draft content-index line for G1-2?What should an assurance reviewer look for in a G1-2 draft?Does the G1-2 page provide real company report examples I can compare against?Can I use the G1-2 page to map to ESRS or IFRS requirements?
How this library is built
312 published reports indexed
63171 pages with page-level citations
272 practitioner guides
Free · LRA Community
Get your G1-2 tools — free
Your preparation tools are free for LRA Community members and students. Register once (it's free) and your download starts right away — plus the Disclosure Library, templates and the LRA AI-assistant.
✓
You're in — your download is starting
Your file is downloading now. Your Community Cabinet — with the Disclosure Library, templates and the LRA AI-assistant — is ready too.
Open your Cabinet →