Disclosure focus
This disclosure asks an organisation to report the numbers that show how it manages corruption and bribery risks in practice. The focus is on measurable information, such as how many relevant incidents, allegations, investigations, training completions, or other tracked events there are, so readers can see whether the organisation’s anti-corruption controls are active and being used, not just described in policy documents.
In practical terms, the reporting should cover the organisation’s full relevant footprint, not only a few well-controlled or flagship locations, unless the scope is clearly explained. The key question is whether the figures reflect the parts of the business where corruption and bribery risk actually exists, including operations, subsidiaries, and other relevant activities, so users can judge the breadth and consistency of the organisation’s approach.
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 G1-4 sub-elements (LRA working checklist)
Count how many convictions were recorded.
Count how many sanctions were imposed.
Add up the total fines in euros.
How to prepare it
1Set the reporting boundary first: decide which parts of the business, subsidiaries, and relevant reporting period are in scope for this disclosure, so the figures and narrative are built from the right population.
2Agree what each metric will count before you start collecting data: define how you will treat convictions, sanctions, and monetary penalties, and make sure the same approach is used consistently across the scope.
3Gather the underlying records from the source systems and case files: keep the documents that support the count of convictions, the count of sanctions, and the total amount of fines in euros.
4Compile the reported values in the required form: provide the two counts as numbers and the fine total as a euro amount, using one consistent basis across the disclosure.
5Record any exclusions, adjustments, or changes in method: explain what was left out, what changed from the prior period, and why the reported figures differ from earlier submissions if that applies.
6Check the draft against the official source and internal records: confirm the numbers tie back to the evidence, the scope is complete, and the final wording matches the underlying requirement without adding anything extra.
Request the data
Request the corruption case metrics from Legal / Secretariat
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How many corruption or bribery cases in the period ended in a conviction, a sanction, or a financial penalty, and what was the total amount of fines in euros?
Use your organisation’s own case-handling terms first, then map them to the reporting fields. For example, if you track matters as investigations, enforcement actions, settlements, or court outcomes, keep those labels in the request and ask the owner to translate them into the reporting view before sign-off. This is a training template only; adapt it to your organisation and check the source disclosure before sign-off.
Weak request
Please provide the ESRS G1-4 corruption and bribery metrics for the period, including convictions, sanctions and fines, in line with the disclosure.
Why it fails: It uses framework language instead of the organisation’s own case terms, does not say which register or system to pull from, and leaves the counting basis and currency treatment unclear. That makes it hard for the owner to know what to extract and how to map it.
Better request
Please provide the [period] case outcome data from your [legal case tracker / compliance register] for the [boundary]. We need the number of matters that ended in a conviction, the number that ended in a sanction, and the total fines in euros. Please keep your normal case labels in the extract and add a short mapping note so we can translate them into the reporting view.
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 each figure was counted, what was included in the totals, and the reporting period and scope used to compile the three measures.
Context note
Explain what the counts and euro total indicate about enforcement activity in the period, and whether the monetary amount reflects a small number of large cases or many smaller ones.
Fluctuation statement
If the figures moved materially, describe the main drivers, such as changes in case volume, case severity, timing of decisions, or one-off events that affected the totals.
Content index entry
G1-4 Corruption & Bribery Metrics — [location / page] / [notes]
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Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
Units are missing or inconsistent across the figures.The reporting scope or boundary for the numbers is unclear.Estimates are not distinguished from measured values.Parts of the total are double-counted or omitted.Restatements of prior-period figures are not disclosed.The calculation method or data source is not documented.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
Sending the request to a team that only sees part of the case file means the count is built from incomplete records.
Framework words, not business terms
Asking for the figures in disclosure language instead of the organisation’s own case labels makes people pull the wrong dataset or miss relevant entries.
Unclear boundary
Not stating which entities, sites, or case types sit inside the scope leads to some records being left out and others being counted twice.
Wrong time basis
Using a different reporting window from the one used in the source records produces totals that do not match the period being reported.
Mixed counting method
Combining case counts, people counts, and monetary amounts in one extraction step creates numbers that cannot be reconciled back to the source.
Source labels lost
Copying the figures without keeping the original case IDs, file names, or ledger tags makes it impossible to trace each number back to its origin.
Populations merged
Putting convictions, penalties, and fine amounts into one undifferentiated list hides which figure belongs to which measure.
No evidence trail
Collecting the numbers without the supporting extract date, owner, and approval record leaves no audit trail for later review.
No sign-off record
Failing to capture who checked the figures and when means the final set cannot be shown as reviewed before it is used.
Where judgement is often needed
What counts as a case in the reporting perimeter after a buy or sell transaction
Decide whether to include outcomes linked to businesses added or removed during the year, explain the cut-off date used, and make clear if prior-period figures were restated or left as reported.
How to handle local legal labels that do not line up neatly across countries
Use one internal rule for classifying court outcomes, penalties and monetary penalties across jurisdictions, then disclose any country-by-country mapping or simplification you used so readers can see how unlike labels were made comparable.
Whether to include people or entities close to the boundary of control
Set out whether you counted matters involving joint ventures, contractors, agents or other connected parties, and explain the practical test used to decide when a case sits inside or outside the group’s own figures.
Choosing the date basis for the annual count
State whether you used the date of the final decision, the date the matter was recorded, or another consistent point in time, and keep that basis the same for convictions, penalties and fines.
Using actual records versus estimates where the file is incomplete
If some cases are still being confirmed, explain whether you relied on measured amounts, management estimates or later adjustments, and identify which figures are provisional and which are final.
Rounding and presentation of small numbers
Explain the rounding rule applied to counts and euro amounts, especially where a small number of cases or a low total fine could change materially after rounding, and keep the method consistent across the table.
Protecting personal data when the case list is very small
Where naming or splitting the data would risk identifying individuals, aggregate the figures to a safer level and say that privacy protection affected the way the numbers were grouped.
Deciding whether one matter can lead to more than one metric entry
Clarify your rule for cases that end in both a conviction and a penalty, or in several penalties from the same matter, so users can see whether the counts and euro total reflect each outcome separately or only once.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Consumer goods
: during the reporting period, we recorded 3 convictions and 5 sanctions linked to business conduct matters, with total fines of €420,000. This example is internally consistent and shown for training purposes only.
Shows how to present the count of convictions, the count of sanctions, and the combined monetary amount of fines in a concise quantitative note.
Illustrative (synthetic) example — Industrial manufacturing
: in our group, the period included 1 conviction and 2 sanctions, and the related fines came to €75,000. The figures below are illustrative, internally consistent, and provided for practitioner training.
Shows the same three data points for a different reporter and sector, using a separate synthetic fact pattern.
How companies report G1-4 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Covivio
Real Estate · France · 2025
Covivio’s 2025 Sustainability Report states that the company had zero convictions and zero fines related to violations of anti-corruption and anti-bribery laws, as noted on page 184. The report also references governance measures under the Sapin 2 law and mentions a review of corruption and influence peddling processes conducted in 2024 (pp. 179, 183). However, no specific numeric data or further details on anti-corruption policies or outcomes beyond these points were found in the report.
Continental AG
Tires · Germany · 2025
Continental AG's 2025 Annual Report provides a numeric value indicating zero convictions for corruption and bribery, as well as zero fines for violations of anti-corruption laws, reported on page 208. The report also references management approaches and metrics related to prevention and detection of corruption and bribery on pages 205–207 and 214. However, no additional numeric data or detailed findings on anti-corruption measures or outcomes were found elsewhere in the report.
Sanoma Oyj
Education Services · Finland · 2025
Sanoma Oyj's 2025 Annual Report includes a statement on its zero tolerance policy towards bribery and corruption (p.131) and mentions confirmed incidents of corruption or bribery (p.135). The report also references fines related to violations of anti-corruption and anti-bribery laws (p.84). However, no specific numeric values or detailed quantitative data on these incidents or fines are provided in the report.
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Scenarios to work through
A group’s legal team confirms that one overseas subsidiary was convicted in the reporting year for a bribery-related offence, and a separate regulator issued a financial penalty in the same year for a different anti-corruption breach. The finance team is preparing the year-end disclosure and has to decide how to count each outcome.
QHow should the team treat the conviction and the penalty when completing the corruption-and-bribery metrics for the year?
Reveal model answer →Hide answer ↑Count the court conviction as one conviction and the regulator’s penalty as one sanction, because they are different outcome types and each is tallied separately. If the same case led to both a conviction and a sanction, each outcome would still be counted in its own line, but the team should avoid double-counting the same outcome within a single metric. The figures should reflect the reporting period only and be supported by the underlying case records.
Why this matters · Separate legal outcomes by type, and count each outcome once in the correct metric.
A preparer has two matters on file: one ended with a conviction and a fine, while the other ended with a warning letter and no court case. The draft note currently lists both matters under the same heading because both relate to bribery concerns.
QShould both matters be rolled into one figure, or should they be split across the different data points?
Reveal model answer →Hide answer ↑They should be split. The conviction belongs in the conviction count, the warning letter is not a conviction, and only a true sanction should feed the sanctions count. The fine from the convicted case is included in the monetary total only if it is a fine linked to the relevant anti-corruption outcome being reported, and the team should keep the mapping clear so each number matches the right category.
Why this matters · Use the nature of the outcome, not the topic of the case, to place each item in the right count.
During consolidation, one business unit reports a bribery conviction in local currency and another reports a sanction with no monetary amount attached. The group reporting team is unsure whether to leave the euro total blank until all subsidiaries have replied.
QWhat should the team do if there is a conviction or sanction but no fine amount is available for one of the cases?
Reveal model answer →Hide answer ↑The team should still report the counts for convictions and sanctions based on the confirmed outcomes, but only include a euro amount where there is an actual fine to total. If a case produced a sanction without a fine, it contributes to the sanctions count but not to the euro figure. The monetary line should be the sum of the fines that are known and relevant, converted and presented consistently in euros.
Why this matters · Counts and money totals are related but not identical; a case can affect one line without affecting the other.
A sustainability analyst finds an internal spreadsheet showing three bribery-related court outcomes, but one was overturned before the reporting date and another was still under appeal at year-end. The draft disclosure currently includes all three because they were all mentioned in incident logs.
QWhich outcomes should be included in the year-end metrics, and why?
Reveal model answer →Hide answer ↑Only outcomes that are confirmed for the reporting period should be included in the counts and the fine total. An overturned matter should not stay in the tally, and an unresolved appeal should not be treated as a final conviction or final sanction unless the reporting basis used by the organisation clearly supports that treatment. The analyst should rely on the final case status at the reporting date and keep the evidence trail clear.
Why this matters · Base the disclosure on the final status at the reporting date, not on early incident logs or provisional labels.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
For G1-4, what data do I need to collect before I start drafting the disclosure?+−
The page says to prepare three datapoints: conviction count, sanction count and total fines amount. Use the step-by-step preparation section to turn those into a draft and keep the evidence pack ready for review.
How should I define the scope for G1-4 business conduct data on this page?+−
Use the page’s plain-language explainer and preparation steps to decide what sits in scope before you collect figures. The page does not set a formal scope rule, so you need to apply the guidance consistently and document your approach.
Who should own the G1-4 conviction, sanction and fines data in my organisation?+−
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source, check and explain the figures. The workbook is there to help assign and track those responsibilities.
What evidence should I keep to make a G1-4 disclosure assurance-ready?+−
The page includes an evidence pack with five items and five assurance claims to verify, each framed around claim, risk and evidence. Use those together so you can show where each number came from and how it was checked.
What are the five assurance claims on the G1-4 page and how do I use them?+−
The page says there are five claims to verify, each linked to a risk and evidence point. In practice, use them as a checklist to test whether the disclosure is complete, accurate and supported before it goes into a report.
What are the common mistakes to avoid when reporting G1-4?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot issues before drafting. Use that section to check for missing datapoints, weak evidence or inconsistent treatment across the disclosure.
How do I use the G1-4 workbook download to prepare the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, track evidence and support the step-by-step preparation process.
What is the printable Library Card PDF for G1-4 used for?+−
The Download Centre includes a printable Library Card in PDF format. It is there as a practical reference alongside the workbook, so you can keep the key preparation and assurance points to hand while drafting.
Can I use the synthetic example on the G1-4 page to draft my own disclosure?+−
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table, to show how the disclosure can be presented. Treat it as a format guide only and make sure your own numbers and narrative match your actual evidence.
How do I turn G1-4 data into a draft narrative and content-index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line. Use those prompts to turn the prepared figures into a clear draft, then check it against the evidence pack and assurance claims.
More questions this page can help with
G1-4 conviction count, sanction count and total fines amount: what should I gather first?How do I build an evidence pack for G1-4 business conduct disclosure?What should I check before sending a G1-4 disclosure for assurance review?How do I use the step-by-step how to prepare section for G1-4?What does the G1-4 plain-language explainer help me decide?How do I avoid common reporting gaps in G1-4?What is included in the G1-4 Prep & Assurance workbook download?How do the synthetic illustrative examples on G1-4 show the disclosure format?Where can I find real company report examples for G1-4?How do I use the G1-4 content-index line in a draft report?What should an ESG manager ask a data owner for when preparing G1-4?How do I use the assurance claims, risks and evidence on the G1-4 page together?
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