Disclosure focus
This disclosure asks an organisation to explain how it engages with the people in its own workforce and how those people can raise concerns or complaints. In practice, the report should show whether workers have accessible ways to speak up, whether those channels are available in the places and parts of the business where people actually work, and how the organisation responds when issues are raised.
The practical focus is on coverage and effectiveness, not just the existence of a policy. An organisation should describe whether its approach reaches all relevant workers across operations, sites and employment arrangements, or only selected locations, and how it makes the process usable in day-to-day work. The emphasis is on whether workers can use the mechanism safely and whether the organisation learns from what it receives.
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 S3-2 sub-elements (LRA working checklist)
Describe the routes used to engage people or groups.
Set out the ways engagement is carried out.
Identify whether women, migrants, and disabled people are included.
Explain how the consultation is run.
Show how affected people helped shape the engagement design.
State whether free, prior and informed consent was used.
Make the process easy to access and use.
List the channels that people can use.
Track the key measures used to monitor it.
Confirm whether a grievance or feedback route exists.
Report the share of matters resolved.
Report how long replies usually take.
State how many cases were handled.
Describe the approach used to put things right.
How to prepare it
1Set the reporting boundary first. Decide which parts of the business, sites, operations, and value chain activity are in scope for this disclosure, so the later evidence and wording all relate to the same population.
2Map the people and contact routes you need to describe. Identify the worker groups covered by the datapoints, then list the ways they can engage with the organisation and the methods used to do so.
3Check whether free, prior and informed consent applies, and if so, record the consultation trail. Note how the process was run and how workers or their representatives were involved in shaping the engagement design.
4Gather the operational records behind the disclosure. Pull together the channels available, whether the mechanism exists, how accessible it is, and the measures used to track performance, including the indicators for resolution and response timing.
5Prepare the narrative on follow-up and outcomes. Explain the approach used to address issues raised, and summarise the cases that were handled during the reporting period.
6Before finalising, reconcile the draft against the source material. Confirm that any exclusions, scope changes, or wording choices are explained, and check that each required item is supported by the official source and the underlying evidence.
Request the data
Request the site engagement and issue-handling evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How do we show that affected local people and other relevant groups were engaged, and that concerns were handled through accessible channels with follow-up and remedy where needed?
Use your organisation’s own terms first, then map them to the reporting labels. For example, if you call these ‘community contacts’, ‘site feedback routes’, ‘hotline cases’ or ‘issue logs’, keep that language in the request and in the return pack; only translate into the reporting wording at the end. Check the source material before sign-off.
Weak request
Please provide the ESRS S3-2 engagement and grievance mechanism disclosures for the year, including stakeholder engagement, FPIC, accessibility, KPIs, remediation and cases addressed.
Why it fails: This uses framework language that many operational teams do not use day to day, so the owner may not know which records to pull. It also bundles too many concepts without saying which internal systems, site boundaries, or local terms to use, making the response harder to verify and map.
Better request
Please send the site/community contact routes, the groups you have identified for tailored engagement, the ways you engaged them, any consent process used, the way people helped shape the engagement plan, the concern-reporting routes, accessibility features, the case-handling measures you track, the remedy approach, and example cases for [period] and [sites in scope]. Use your own team language first, then add a short mapping note and attach the source files.
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
Explain the basis used to define the affected groups, the engagement channels and methods counted, how consent and consultation were assessed, what was treated as an available access route, and how performance measures and case handling were compiled.
Context note
Set out what the figures show about how the organisation engaged with affected people, how easy it was to raise issues, how quickly matters were handled, and how many cases were taken through to resolution or other remedy.
Fluctuation statement
If any figures moved materially, link the change to shifts in outreach, access, participation in design, case volumes, or the speed and success of handling, and note any operational or process changes that may have influenced the result.
Content index entry
S3-2 Engagement & Grievance Mechanisms — [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
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The team asks the wrong business owner, so the answer comes from a function that does not run the channel, case handling, or follow-up process.
Framework terms only
The request is written in reporting language instead of the organisation’s own operational terms, and the source team cannot map it to their day-to-day records.
Scope left vague
No one defines which sites, teams, worker groups, or service lines are in scope, so different people collect different populations.
Wrong time basis
The data pull uses a different period or cut-off from the one used elsewhere, which makes the figures impossible to compare cleanly.
Mixed counting rules
One source counts cases, another counts people, and the pack merges them without separating the basis used for each figure.
Source labels lost
Original system names, case IDs, or spreadsheet tabs are stripped out, so the reviewer cannot trace each figure back to its first record.
Populations merged
Groups that should stay separate, such as different worker categories or user groups, are combined into one total and the detail is lost.
Weak evidence trail
The pack has the numbers but not the supporting metadata, so dates, extract logic, and file versions cannot be checked later.
No approval record
The final dataset is circulated without a sign-off trail, so nobody can show who checked it or when the figures were cleared.
Where judgement is often needed
Which sites and teams count after a buy-in or sale
State the cut-off date you used for adding or removing locations, and explain whether the channels, complaints and follow-up cases from the changed perimeter were included on a full-period or partial-period basis.
How to handle country-specific labels for the same worker group
If local records use different labels for the same people, explain the mapping you applied and keep the group split consistent so readers can see who was counted in each category.
People just outside the formal workforce boundary
Say whether contractors, agency staff, seasonal workers or other near-boundary groups were included in the channel and complaint counts, and explain the rule used to decide any borderline cases.
Choosing the timing basis for activity and case counts
Disclose whether you used opening, closing or average headcount, and whether engagement and grievance figures reflect events recorded when they happened or when they were closed.
Using estimates where records are incomplete
If some locations could not provide complete logs, identify which figures were estimated, describe the method used, and separate estimated values from directly recorded ones where that helps interpretation.
Rounding small numbers in low-volume populations
Explain the rounding rule applied and make sure the published totals still reconcile to the underlying counts, especially where a small number of cases could be masked by rounding.
Protecting identity in small groups or rare case types
Where a tiny population or a rare issue could reveal who was involved, combine categories or widen the grouping enough to protect privacy while still showing the substance of the channel or case data.
Deciding whether a channel is truly available to the intended people
Clarify any limits on language, location, shift pattern, device access or disability support, and explain if a route was counted as available only for some parts of the workforce or community.
Counting a case as resolved or still open
Set out the rule you used for closure, note any cases carried over from earlier periods, and explain how reopened or partially handled matters were treated in the reported figures.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
We run regular two-way contact with affected people through site meetings, worker representatives, a multilingual hotline and community drop-ins; in this period we focused on women, migrant workers and disabled people, and used interviews, small-group discussions and anonymous feedback forms to shape the process. For land-related matters, we used a consent-led approach where relevant, held prior discussions with the people concerned, and involved them in designing how the engagement would work; our grievance route was open by phone, web and in person, with 96% of 25 cases closed, 92% of them accessible through the channels we provide, and an average first reply within 3 working days. Where harm was identified, we used direct remedy, service restoration or compensation, and during the period we handled 25 cases in total.
Synthetic illustration for practitioner review only; figures are internally consistent and not based on a real reporter.
Illustrative (synthetic) example — Renewable energy
We kept dialogue open through project briefings, local liaison sessions, a worker forum and a dedicated email line; the groups we paid particular attention to were women, migrant contractors and disabled people, and we used one-to-one conversations, facilitated workshops and written submissions to gather views. For a project affecting customary land, we applied a consent-based process where needed, consulted before key decisions, and invited community members into the design of the engagement plan; our concern-handling route offered email, phone and an online form, was available in plain language and accessible formats, and closed 18 of 20 matters in the period, with 90% resolved and an average reply time of 2 working days. When issues arose, we used apology, corrective action, reinstatement or payment as appropriate, and we dealt with 20 cases overall.
Synthetic illustration for practitioner review only; figures are internally consistent and not based on a real reporter.
How companies report S3-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Globalvia
Ground Transportation — Highways and Railtracks · Spain · 2025
Globalvia’s 2025 Sustainability Report includes a covered datapoint on processes to remediate negative impacts and channels for affected communities to raise concerns, explicitly mentioned on page 109. There is related but unclear information on resolution times and investigations on page 88, though it does not clearly disclose the full remediation process. Numerous other narrative items related to this disclosure are not found or unclear in the report, indicating limited detailed coverage beyond the mentioned pages.
Saipem SpA
Oil and Gas · Italy · 2025
Saipem SpA's 2025 Consolidated Sustainability Statement provides some data related to socio-economic development, education, vocational training, and health promotion (p.172), as well as metrics on training and skills development, health and safety, compensation, and incidents (p.3). There is also mention of corporate culture, business conduct policies, supplier relationships, and anti-corruption measures (p.3). However, no clear or quotable evidence directly addressing the specific disclosure was found, and the methodology or narrative details remain unclear or missing.
Aena S.M.E., S.A.
Air Transportation — Airport Services · Spain · 2025
Aena S.M.E., S.A.'s 2025 Sustainability report includes a covered datapoint on page 240 describing channels for affected communities to raise concerns and processes for remediating negative impacts. Additional references to engagement with affected communities and remediation processes appear on pages 70 and 184, indicating some narrative coverage of these topics. However, multiple narrative items related to this disclosure are not found or remain unclear elsewhere in the report, suggesting limited or incomplete information on methodology and detailed processes beyond these mentions.
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Scenarios to work through
A preparer is drafting the section on how the organisation speaks with affected people. They have one general staff hotline, plus a separate route used by migrant workers through a local support group, and they are unsure whether to mention both.
QHow should they decide what to include about the ways people can raise issues and the groups that were identified as needing different routes?
Reveal model answer →Hide answer ↑They should describe the actual ways the organisation engages with affected people, and name the groups it has identified where different access or outreach is needed, such as women, migrants or disabled people if those are the groups relevant in this case. The write-up should reflect the real channels and the real groups considered, rather than using a generic statement that everything is covered in one way.
Why this matters · Report the real engagement routes and the groups that need tailored access, not a one-size-fits-all summary.
A site expansion may affect an Indigenous community, and the project team held meetings, shared translated materials, and allowed time for the community to discuss the plan internally before responding. The preparer is unsure whether to describe this as a simple consultation note or as a more specific consent-related process.
QWhat should they check before deciding how to present the engagement process for this case?
Reveal model answer →Hide answer ↑They should first check whether the situation involved a free, prior and informed consent process and, if so, state that clearly in a yes/no way and then explain how the consultation was carried out. They should also describe how the engagement was designed with participation from the people involved, so the account shows both the process used and the role of the affected group in shaping it.
Why this matters · Where consent-based engagement applies, say so plainly and explain both the consultation steps and how people helped shape the process.
The organisation has a complaints route through a phone line, a web form and an in-person desk at one facility, but workers in another location say the web form is hard to use because of poor connectivity and low literacy. The preparer is deciding whether the section can simply list the channels or whether it needs more detail.
QWhat should they include about the grievance route and its accessibility?
Reveal model answer →Hide answer ↑They should describe the channels that are available, confirm whether there is a grievance route in place, and explain how access works in practice for the people who need it. If some groups face barriers, the explanation should make clear what adjustments or support are in place so the route is genuinely usable, not just available on paper.
Why this matters · A grievance route should be described as both present and usable, with accessibility explained in practical terms.
The complaints log shows 40 cases opened in the period, 28 closed, and 12 still open at period end. Of the 28 closed cases, 20 were resolved through corrective action and 8 were closed because the issue was outside scope; the average first response time was 5 days. The preparer is unsure how much of this belongs in the disclosure.
QHow should they decide what to say about performance, closure outcomes and follow-up action?
Reveal model answer →Hide answer ↑They should include the key measures they use to track the route, such as how many cases were resolved, how quickly people first heard back, and any other relevant indicators they rely on. They should also explain the approach used to put things right and describe the kinds of cases that were dealt with, making sure the numbers are internally consistent: 40 opened, 28 closed, 12 still open, with 20 of the closed cases resolved through corrective action and 8 closed for another reason.
Why this matters · Use consistent case data to show how the route performs, how quickly it responds, and how issues are remedied.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I prepare the S3-2 Affected Communities disclosure using this page step by step?+−
Use the page’s plain-language explainer, then work through the step-by-step preparation section to identify the datapoints, scope, and evidence you need. It is designed to help you move from raw information to a draft disclosure, not to replace your own judgement or review.
What datapoints do I need to collect for S3-2 Affected Communities?+−
The page lists the datapoints to prepare, including engagement routes, affected groups, engagement approach, FPIC status, consultation process, design participation, grievance routes and system, access conditions, grievance metrics, case closure rate, complaint turnaround, remedy approach, and remediated cases. Use that list as your collection checklist before drafting.
How should I define the scope for S3-2 Affected Communities in practice?+−
The page helps you set scope and methodology through its preparation steps and datapoint list, so you can decide which affected groups, engagement routes, and grievance processes are in scope. Keep the scope consistent with the evidence you can actually support in the workbook and evidence pack.
Who should own the S3-2 Affected Communities data collection and sign-off?+−
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source the datapoints and evidence. Use the workbook to assign tasks and make sure the final draft is reviewed by the right internal owners.
What evidence pack do I need to make S3-2 Affected Communities assurance-ready?+−
The page includes an evidence pack with five items to support assurance readiness. Use it to assemble the documents and records that back up the datapoints, claims, and narrative before you finalise the disclosure.
What are the six assurance claims I should verify for S3-2 Affected Communities?+−
The page says there are six assurance claims to verify, each with a claim, risk, and evidence prompt. Use those prompts to test whether your draft is supported and whether the underlying records are complete and consistent.
What are the common reporting mistakes on the S3-2 Affected Communities page?+−
The page lists common reporting gaps and mistakes to help you avoid weak or incomplete disclosures. Use that section as a pre-submission check, especially if your draft is missing evidence, unclear on scope, or not aligned to the datapoints listed on the page.
How do I use the Prep & Assurance workbook for S3-2 Affected Communities?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format to help you organise the disclosure work. Use it to track datapoints, ownership, evidence, and draft outputs in one place before you prepare the final narrative.
How do I turn the S3-2 Affected Communities data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters, and a content-index line. Use those tools to turn your collected data and evidence into a structured draft that is easier to review and refine.
Are there example disclosures for S3-2 Affected Communities I can learn from?+−
Yes. The page includes synthetic illustrative example disclosures, including a quantitative table, so you can see how the information might be presented in practice. Treat them as examples only and keep your own figures internally consistent.
More questions this page can help with
S3-2 Affected Communities checklist for engagement routes, grievance routes and remedy dataS3-2 Affected Communities evidence pack items for assurance reviewHow to use the S3-2 Affected Communities workbook and printable Library CardS3-2 Affected Communities common mistakes to avoid before submissionS3-2 Affected Communities draft narrative starters and content-index lineS3-2 Affected Communities synthetic example disclosure tableWhat should be in scope for S3-2 Affected Communities data collection?How do I assign ownership for S3-2 Affected Communities reporting?How do I check S3-2 Affected Communities assurance claims against evidence?Where can I find real company report examples for S3-2 Affected Communities?
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