Disclosure focus
This disclosure asks an organisation to explain how its policy commitments are built into day-to-day management, rather than simply listing policies on paper. In practice, the report should show whether commitments are translated into internal rules, procedures, responsibilities, training, controls, and decision-making processes, so that they can actually be applied across the organisation.
The practical focus is on coverage and consistency: readers should be able to see whether the approach applies across the whole organisation and its relevant operations, or only in selected areas such as flagship sites or head office. It is useful to describe where the commitments are embedded, where they are not yet fully in place, and any differences in implementation between parts of the business.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI 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 GRI 2-24 sub-elements (LRA working checklist)
Set out how responsibility for carrying out each responsible-business commitment is assigned across the organisation, from one level to another, and across its activities and external relationships.
Explain how those commitments are put into practice through the organisation’s dealings with suppliers, partners and other business relationships.
Show how the commitments are built into business strategy, day-to-day policies and operating procedures.
Set out the training the organisation gives people so they can apply the commitments in practice.
How to prepare it
1Map the policy commitments you are reporting on, then set the reporting boundary so it is clear which parts of the organisation and which business links are in scope for the disclosure.
2For each commitment, decide what counts as evidence of it being built into day-to-day practice: governance responsibilities, internal strategy and policy documents, operating procedures, use with business partners, and staff training materials.
3Gather source material that shows how the commitments are applied in practice across the business and through external relationships, including records that show who is responsible at different levels and where training has been delivered.
4Draft the disclosure in a way that covers each commitment separately and explains the practical embedding approach, rather than giving only a high-level policy statement.
5Note any exclusions, partial coverage, or changes in approach from the prior period, and make sure these are explained clearly enough for a reader to understand what is and is not included.
6Check the final wording against the official source to confirm you have covered every required point, used the right scope, and not added or omitted anything material.
Request the data
Request the policy-embedding evidence pack
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How do our policy commitments get turned into day-to-day practice across the business, our operating rules, our external relationships, and staff training?
Use your organisation’s own terms first, then map them to the disclosure. For example, ask for the board paper, policy rollout note, supplier code, operating procedure, or training record that your teams actually use, rather than using framework language in the request.
Weak request
Please provide the GRI 2-24 evidence showing how policy commitments are embedded throughout activities and business relationships, including allocation of responsibility, integration into strategies, policies and procedures, implementation through business relationships, and training.
Why it fails: It uses framework wording that many internal owners will not recognise, so it is harder to route, collect, and answer. It also bundles several ideas into one abstract ask, which makes it difficult to pull the right records from different teams and systems.
Better request
Please send the records that show how our policy commitments are put into practice: who owns them, where they sit in our internal rules and operating processes, how we apply them with suppliers and other partners, and what training staff receive. Include the document title, owner, version, date, and source system for each item.
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
This disclosure can be based on the organisation’s current policy framework, showing how responsible business commitments are assigned, built into internal processes, applied in external relationships and supported by training, with terms defined consistently across the reporting period.
Context note
The figures and descriptions show how far the organisation has moved from policy statements to practical implementation, indicating whether responsibility, systems and training are in place to support day-to-day delivery.
Fluctuation statement
Any change from the prior period can be explained by updates to governance roles, policy revisions, wider rollout of procedures, changes in partner engagement or expanded training coverage.
Content index entry
GRI 2-24 Embedding policy commitments — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for GRI 2-24 — 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.
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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
Asking the wrong owner
The request goes to a policy team or ESG lead who cannot explain how the commitments are actually carried out across the business, so the evidence comes back as theory rather than day-to-day practice.
Using framework language instead of the organisation’s own terms
People are asked to answer in disclosure jargon, which produces wording that does not match how the business names its roles, processes, or controls.
Leaving the scope unclear
The data pull does not say which parts of the business, which activities, or which external relationships are in scope, so teams send partial or inconsistent material.
Mixing different time bases
One team sends current-year material while another sends older training or policy records, so the pack no longer reflects the same reporting period.
Combining unlike counts
Training attendance, policy roll-out, and relationship coverage are merged into one total even though they are different measures and should be kept separate.
Dropping the source labels
The original file names, version marks, or system references are stripped out, making it hard to trace each item back to the record it came from.
Pulling together populations that should stay separate
Internal teams, contractors, and external partners are bundled into one dataset even where the organisation needs to explain them separately.
Missing the evidence trail
The pack contains the data but not the supporting notes, owner details, or approval history, so no one can show how the figures or statements were checked before use.
Where judgement is often needed
Group changes after a buy-in or sale
State whether the description covers the reporting period as a whole or only the parts you controlled, and explain how you handled newly added or removed operations and relationships.
Different local meanings for the same policy
If the same commitment is translated or adapted differently in separate countries, explain which version you used and how you treated any local wording that changes the practical meaning.
Units close to the boundary of scope
Explain how you decided whether small sites, joint ventures, agents, or other near-boundary parts of the business were included, and note any exclusions that could affect the picture.
Choosing the level where responsibility sits
Describe whether accountability is set at board, executive, regional, site, or team level, and make clear how you resolved overlaps where more than one layer shares the task.
Policies versus day-to-day procedures
If a commitment is reflected in strategy, a policy, a work instruction, or all three, explain which layers you counted and how you avoided double counting the same control.
Using estimates where records are incomplete
Where you do not have direct evidence for every location or relationship, say what was measured, what was estimated, and the basis used so readers can judge the reliability.
Training coverage and timing
Clarify whether training numbers cover everyone who was eligible, everyone who attended, or only those trained in the period, and explain how refresher or induction sessions were treated.
Aggregating sensitive information
If privacy or confidentiality means you cannot show detail for a small group, explain the aggregation rule you used and how it may hide differences across teams, countries, or partners.
Rounding and presentation choices
If figures or counts are rounded, state the rounding basis and check that totals still make sense after rounding, especially where small changes could alter the interpretation.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — food processing
*Synthetic illustration only.* We set out our responsible-business commitments in our code, supplier rules, and operating procedures, then assign delivery from the board through executive leads to site managers and procurement teams so each level knows its role. We also build the commitments into our strategy reviews, purchasing controls, and day-to-day work instructions, and we use them in contracts and supplier reviews so our business partners are expected to follow the same approach. - Training is part of rollout: in the year, 1,240 employees completed the core module and 186 managers completed the deeper implementation session, out of 1,426 employees in scope, so 87% and 13% respectively; all 312 new starters received induction on the commitments within their first month.
Illustrative only; shows how a reporter might explain where responsibility sits, how commitments are built into management systems, how they are carried into supplier and other business relationships, and how staff are trained to apply them.
Illustrative (synthetic) example — commercial property services
*Synthetic illustration only.* Our policy commitments are translated into our group plan, local operating rules, and service-delivery procedures, with the board, regional leadership, and contract teams each holding defined duties for putting them into practice. We also require key partners to meet the same expectations through onboarding, contract clauses, and performance checks, and we refresh training so people understand how to apply the commitments in their roles. - During the year, 540 of 600 employees completed the general refresher and 60 of 600 completed role-specific workshops, giving 90% and 10%; in addition, 48 of 48 contract managers finished the partner-oversight course, and 96 of 120 site supervisors attended the practical implementation briefing, giving 40% and 80% respectively.
Illustrative only; shows a second plausible way to describe governance, integration into internal systems, use with external partners, and training coverage.
Company reports
How companies report GRI 2-24
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Interconexión Eléctrica S.A. E.S.P.
Electric Utilities / IPP / Energy Traders · Colombia · 2024
Interconexión Eléctrica S.A. E.S.P.'s ISA Integrated Management Report 2024 includes coverage of human rights, referencing the Declaration of Human Rights and business on page 140, and addresses aspects of workforce diversity such as gender, generations, knowledge, experience, skills, and academic training on page 133. However, the report does not provide quotable evidence for narrative items (a-ii) and (a-iii), indicating gaps in those specific areas. Overall, while some elements related to rights and workforce composition are documented, other narrative components remain unaddressed in the report.
Oberoi Realty Limited
Real Estate · India · 2025
Oberoi Realty Limited’s ESG Report FY 2024-25 includes a covered narrative item (a-i) on page 20, referencing codes and policies, indicating some disclosure of governance or policy frameworks. The report also mentions a publicly available Environmental Sustainability Policy on page 67, reflecting the company’s focus on responsible growth and sustainability across its operations and value chain. However, several narrative items (a-ii, a-iii, a-iv) are not found in the report, suggesting gaps or lack of explicit information on those specific aspects.
Agnico Eagle Mines
Mining — Rare Minerals / Precious Metals / Gems · Canada · 2025
Agnico Eagle Mines’ 2025 Sustainability Report includes a leadership message affirming the company’s ongoing commitment to responsible mining (p.24). The report provides partial information on TSM performance and scores across multiple sites, offering supporting context but no headline values (p.106). However, several narrative items related to specific disclosures are not found or lack quotable evidence in the report.
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Check your understanding
Scenarios to work through
A group has a responsible business conduct policy, but the draft report only says the board approved it last year. The sustainability team has separate notes showing who owns implementation, but nothing yet on how the policy is built into strategy, procedures, supplier work, or staff training.
QWhat extra narrative do you need to add so the disclosure shows how the policy is actually carried through the business?
Reveal model answer →Hide answer ↑Add a plain explanation of four things: who is accountable at each level of the organisation for putting the policy into practice; how the policy is built into strategy, operating rules and day-to-day procedures; how it is applied through dealings with suppliers, agents or other partners; and what training people receive to help them carry it out. If any part is not yet in place, say so clearly rather than implying it is.
Why this matters · The disclosure is about practical embedding, not just policy approval or publication.
A preparer has drafted a section saying the company expects ethical conduct from suppliers and distributors, and that contracts include a clause on this. However, the report does not explain whether internal teams use the same commitments in planning, controls and procedures, or who inside the business is responsible for delivery.
QCan this be presented as a full account of how the commitments are embedded, or is something still missing?
Reveal model answer →Hide answer ↑Something is still missing. The narrative needs to show both sides: how the commitments are used inside the organisation and how they are put into practice with business partners. It should also make clear how responsibility is spread across the organisation, rather than stopping at a contract clause for third parties.
Why this matters · Embedding covers internal management as well as external relationships.
The HR team has run one induction session on the conduct policy for new starters, and the report mentions that training. But the policy also affects procurement, operations and sales, and those teams have different procedures and decision rights that are not described anywhere in the draft.
QHow should you decide whether the training description is enough for this disclosure?
Reveal model answer →Hide answer ↑It is not enough on its own. The report should explain the training that supports implementation, but it also needs to show how the commitments are built into the organisation’s wider way of working, including strategy, procedures and responsibility at different levels. A single induction session does not by itself show that the policy is embedded throughout the business.
Why this matters · Training is one part of embedding, but it does not replace the wider implementation story.
A company has a group-wide policy on responsible business conduct, and local managers in three countries adapt procedures to fit local operations. The draft report says the policy exists, but it does not explain how the group keeps the same commitments in place across those locations or how it works through local partners.
QWhat should the preparer explain to show the policy is embedded across the business rather than sitting at head office only?
Reveal model answer →Hide answer ↑Explain how the commitments are carried through the whole organisation and its relationships: how head office and local teams share responsibility, how the policy is reflected in local operating rules and procedures, and how it is put into practice with partners in each market. The point is to show the policy is active in the business, not just stored centrally.
Why this matters · The report should show the policy working across the organisation and through its business relationships.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Organizational details → Guide ✓Nomination and selection of the highest governance body → Guide ✓Chair of the highest governance body → Guide ✓Role of the highest governance body in overseeing the management of impacts → Guide ✓Delegation of responsibility for managing impacts → Guide ✓Role of the highest governance body in sustainability reporting → Guide ✓Show all 29 related disclosures →
FAQ
Questions this page answers
For GRI 2-24, what data do I need to gather before I start drafting the disclosure?+−
The page says to prepare four datapoints: responsibility allocation, strategy and process integration, business relationship delivery, and implementation training. Use those as the starting point for your data request list and evidence pack.
How do I use the step-by-step 'how to prepare' section for GRI 2-24?+−
Use it as a working sequence to move from understanding the disclosure to collecting the right inputs, checking the scope, and turning the information into a draft. It is designed as practitioner guidance rather than a formal standard.
Who should own the GRI 2-24 disclosure data in practice?+−
The page points to responsibility allocation as a key datapoint, so ownership should be assigned clearly before drafting starts. In practice, that usually means identifying the person or team responsible for each input and keeping that traceable in the evidence pack.
What should I include in the evidence pack for GRI 2-24 assurance readiness?+−
The page says there is an evidence pack with five items to support assurance readiness. Use it to keep the core documents and records together so a reviewer can trace the reported information back to source material.
What are the four assurance claims I need to verify for GRI 2-24?+−
The page includes four assurance claims to check, each with a claim, risk and evidence prompt. Use those prompts to test whether the disclosure is supported, complete and consistent before it goes to review.
What are the common reporting gaps or mistakes on the GRI 2-24 page?+−
The page lists common reporting gaps and mistakes to help you spot weak points before submission. Use that section as a pre-check against missing data, unclear scope, or unsupported statements.
How can I turn the GRI 2-24 data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters and a GRI content-index line. That gives you a practical way to move from raw inputs to a first draft without starting from a blank page.
Can I use the synthetic illustrative example on the GRI 2-24 page as a template?+−
Yes, but only as an example of how the disclosure might look. The page says the example is synthetic, so you should adapt the structure and numbers to your own data and keep any quantitative table internally consistent.
What does the GRI 2-24 workbook download help me do?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the preparation steps, track evidence, and support assurance readiness alongside the printable Library Card PDF.
How do I use the 'From company reports' table on the GRI 2-24 page?+−
It links to real published reports at the pages where the topic is disclosed, so you can see how others have presented similar information. Use it for practical reference, not as a substitute for your own reporting approach.
More questions this page can help with
GRI 2-24 disclosure checklist: what should I collect for responsibility allocation, strategy integration, business relationship delivery and training?How do I build an assurance-ready evidence pack for GRI 2-24?What are the most common mistakes people make when drafting GRI 2-24?How should I assign ownership for the GRI 2-24 disclosure across HR, ESG and operations?How do I use the GRI 2-24 Prep & Assurance workbook to track evidence and drafting?What should a first draft of GRI 2-24 look like using the page's narrative starters?How do I check whether my GRI 2-24 disclosure is supported by evidence?Can I use the synthetic example table on the GRI 2-24 page to structure my own data table?Where on the GRI 2-24 page do I find the content-index line for the draft?How do I avoid overclaiming in a GRI 2-24 disclosure when the evidence is incomplete?What is the best way to use the plain-language explainer before drafting GRI 2-24?Does the GRI 2-24 page give me a direct ESRS or IFRS mapping?
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