Disclosure focus
This disclosure asks an organisation to explain whether it has a formal approach for managing occupational health and safety across its activities, and how far that approach reaches. In practice, the report should make clear if the system applies to all operations, selected business units, specific sites, or only part of the workforce, and should describe the main features of that approach in a way that shows how health and safety is managed rather than just stated as a policy.
The practical focus is on coverage and consistency: readers should be able to see where the management system applies, where it does not, and whether it is embedded across the organisation or concentrated in a few flagship locations. The disclosure is therefore less about describing isolated initiatives and more about showing the scope, structure, and operational reach of the organisation’s health and safety management arrangements.
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 403-1 sub-elements (LRA working checklist)
Set out which workers, tasks and sites fall within the health and safety system.
If any workers, tasks or sites are left out, explain whether that is the case and why.
For staff and any other workers whose work or workplace the organisation controls, state whether a health and safety system is in place.
Say whether the system follows recognised risk-management or management-system guidance.
Say whether the system exists because the law requires it.
List the legal requirements relied on.
List the guidance or standards relied on.
How to prepare it
1Set the boundary first: decide which employees and which non-employee workers fall within the system because their work, their workplace, or both are under the organisation’s control.
2Confirm the basis for the system: note whether it exists because a law or regulation requires it, or because you have used a recognised risk or management framework to put it in place.
3Gather the supporting records: keep the legal provisions relied on, or the named standards or guidance used, so the basis for implementation can be shown clearly.
4Describe the coverage in plain terms: state which worker groups, activities, and sites are included in the health and safety system.
5Record any gaps openly: explain whether any workers, activities, or locations are left out, and give the reason for each exclusion.
6Check the final wording against the source material and your evidence pack, so the reported scope, basis, and exclusions match the underlying records and no item has been missed.
Request the data
Request the OHS system evidence from EHS / Operations
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What parts of our workforce and sites are covered by the current health and safety management approach, and what sits outside it?
Use your organisation’s own labels first, then map them to the reporting disclosure. For example, talk about your safety programme, site controls, incident process, or local H&S arrangements if that is how the business describes them internally.
Weak request
Please provide the GRI 403-1 information for the OHS management system, including whether it is implemented, the basis for implementation, and the scope and exclusions.
Why it fails: This uses reporting jargon and leaves the owner guessing which internal records to pull. It does not say what people, sites, activities, or source systems to use, so the response may be incomplete or inconsistent.
Better request
Please send the current safety programme details for [period]: which workers, activities, and sites are covered; which are not covered; why any gaps exist; and whether the programme sits in place because of a legal duty, a recognised framework, or both. Include the internal record name, owner, and latest review date.
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 defines the people, activities and sites included in the health and safety system, and note whether the system exists because of a legal duty or because it follows recognised risk or management guidance.
Context note
Explain what the figures mean in practice by describing the parts of the workforce, work and locations that are covered, and whether any exclusions are limited or material.
Fluctuation statement
If coverage changed from the prior period, explain whether that was due to a new legal requirement, adoption of a recognised framework, or a change in the scope of people, activities or sites included.
Content index entry
GRI 403-1 Occupational health and safety management system — [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
Chasing the health and safety team alone can miss the person who holds the system decision, the legal basis, or the scope note in the business.
Framework language only
Asking people in disclosure terms instead of the organisation’s own labels can produce answers that do not match how the system is actually described internally.
No boundary set
Collecting a yes/no answer without first fixing which staff, contractors, activities, and sites are in scope leads to a statement that cannot be tied to a clear coverage boundary.
Wrong period basis
Pulling the answer from a different reporting cut-off or a later policy version can make the data reflect the wrong time point for the reporting year.
Mixed counting basis
Combining employee records with non-employee worker records, or mixing site-level and group-level counts, can blur populations that should stay separate in the source data.
Source labels lost
Copying figures or notes into a new file without keeping the original document names, version marks, or system tags makes it hard to trace where each answer came from.
Coverage gaps hidden
Rolling covered and not-covered workers or sites into one total can hide the parts of the operation that need a separate explanation for exclusion.
No evidence trail
Saving the final answer without the supporting file, date, owner, and approval record leaves no clear path for review before sign-off.
Where judgement is often needed
Newly bought or sold sites during the reporting period
Decide whether to include sites and teams from acquisitions or disposals from the date control starts or ends, and explain the cut-off used so readers can see why the covered group changed.
Different local safety rules across countries
Where country rules differ, map each location to the local rule set used and say whether you applied the strictest local approach, a country-by-country approach, or another consistent basis.
Contractors, agency staff, and other non-employees at controlled workplaces
Set out which non-employees are treated as in scope when their work or workplace is under your control, and explain any groups left out because control is not clear or is shared.
Shared sites and mixed-control operations
For joint ventures, leased premises, and multi-occupier sites, explain how you decided whether the workplace is controlled enough to sit inside the system and note any partial coverage.
Head office policy versus site-level practice
If the system exists on paper but is only partly rolled out in practice, describe the parts that are live, the parts still being implemented, and the basis for saying the system is in place.
Using recognised frameworks versus internal arrangements
If you rely on a legal duty, an external framework, or your own internal process, state which basis applies at each location and list the laws, standards, or guidance you used.
Estimating coverage where records are incomplete
When headcount, site lists, or worker categories are not fully measured, use a transparent estimate, say how it was built, and identify the period and source data behind it.
Rounding and aggregation for privacy or practicality
If you combine small groups or round figures to avoid identifying individuals or to keep the disclosure readable, explain the aggregation rule and make sure the totals still reconcile.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food manufacturing
We have put in place a workplace health and safety system for our own staff and for agency workers whose day-to-day tasks and sites we control. It is in place because local law requires it, and it is also aligned with recognised management approaches used in our sector. - The legal basis we rely on is the UK Health and Safety at Work etc. Act 1974, the Management of Health and Safety at Work Regulations 1999, and the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013. - The framework we use is built around ISO 45001 and our internal risk-control procedures. - It covers 1,240 employees and 310 non-employee workers across 6 production sites and 2 distribution depots; that is 100% of employees and 100% of controlled non-employees in scope. - We exclude 18 remote sales contractors because their work is not directed by us and their workplaces are not under our control.
Synthetic illustration only. Shows how to state whether a health and safety system exists, why it exists, what it is based on, who and what it covers, and any exclusions, using plain language and internally consistent figures.
Illustrative (synthetic) example — Logistics and warehousing
Our company runs a health and safety system for employees and for labour-hire staff working under our direction at our depots and transport hubs. We use it because the law expects it, and we also follow recognised risk-management practice. - The legal requirements we meet include the Health and Safety at Work etc. Act 1974, the Workplace (Health, Safety and Welfare) Regulations 1992, and the Control of Substances Hazardous to Health Regulations 2002. - The guidance and standards we work to include ISO 45001 and HSE’s HSG65 approach. - The system applies to 860 employees and 140 agency workers at 4 warehouses, 1 cross-dock site, and 1 vehicle-maintenance yard; that is 100% of employees and 100% of controlled agency workers. - We do not include 22 self-employed delivery drivers because their routes and work locations are set by their own businesses rather than by us.
Synthetic illustration only. Shows a second plausible reporter with different wording, different legal references, and a different coverage pattern, while keeping the disclosure complete and numerically consistent.
Company reports
How companies report GRI 403-1
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
ASE Technology Holding Co., Ltd.
Semiconductors · Taiwan · 2024
ASE Technology Holding Co., Ltd.'s 2024 CSR Report includes some coverage of occupational health and safety, with a specific reference to this topic on page 254 and related social data in an appendix (p.254, p.262). The report also mentions legal compliance and internal audits in the context of risk management on page 68, and discusses information security management systems on page 48. However, there is no clear or comprehensive narrative specifically detailing occupational health and safety measures or outcomes, and some expected narrative elements are either missing or unclear.
Mega Financial Holding Co., Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
Mega Financial Holding Co., Ltd.’s 2024 Sustainability Report provides coverage on occupational health and safety, including data on workers covered by occupational health and safety measures linked to business relationships (p.193) and references to an occupational health and safety management system and committee (pp.156, 158). The report also mentions a 100% legal compliance training rate in 2024 (p.56) and outlines risk management implementation (p.48). However, there is no clear or quotable evidence regarding certain narrative items or methodology, leaving some aspects unclear or not found in the report.
London Luton Airport Operations Ltd.
Air Transportation — Airport Services · United Kingdom · 2024
London Luton Airport Operations Ltd.'s Sustainability Report 2024 covers several aspects of occupational health and safety, including management systems and hazard identification, with relevant information found on pages 71 to 74. The report also addresses economic performance and material topics management on pages 14 and 70, and provides some details on activities and workforce on pages 66 and 67. However, there is no clear evidence regarding freedom of association, collective bargaining agreements, or child labour disclosures, as indicated by missing or unclear datapoints and the absence of relevant information in the report.
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Check your understanding
Scenarios to work through
A manufacturer has one safety framework for its own staff, but contractors on the warehouse site follow a separate site rulebook. The reporting team is unsure whether to describe this as one system or two, and whether both groups sit inside the scope.
QHow should the preparer decide what to say about whether a safety management system is in place for the people and workplaces the business controls?
Reveal model answer →Hide answer ↑They should state plainly whether such a system has been put in place for employees and for non-employee workers whose work or workplace the organisation controls. If the answer is yes, they then need to explain the basis for that system, such as legal duties or recognised management approaches, and make clear which workers, activities and sites are included. If some contractors are managed under a different arrangement, that needs to be reflected in the scope explanation rather than assumed to be covered.
Why this matters · The disclosure is about the actual reach of the safety system, not just the existence of a policy.
A logistics group says its safety approach was built to meet local law in three countries. The draft report names the countries but does not say which legal duties shaped the system or whether those duties were the reason it was set up.
QWhat should the preparer check before describing the legal basis for the system?
Reveal model answer →Hide answer ↑They should confirm whether the system was put in place because of legal obligations, and if so, list the specific legal requirements that drove it. Naming the countries alone is not enough, because the report needs the actual requirements that informed the system, not just the jurisdictions where the business operates.
Why this matters · If law is the basis, the report should identify the relevant duties, not only the places where they apply.
A services company uses a health and safety framework adapted from a well-known risk standard, but only for office staff. Field technicians and temporary workers are managed through separate local procedures, and the team is unsure whether to mention the standard and the exclusions together.
QHow should the preparer handle a system that is based on recognised guidance but does not cover everyone or every site?
Reveal model answer →Hide answer ↑They should say whether the system draws on recognised risk or management guidance, and name the guidance used. They should also describe which workers, activities and workplaces are covered, then explain any people, tasks or locations left out and why they are excluded. The fact that the system is based on recognised guidance does not remove the need to be clear about its boundaries.
Why this matters · A recognised framework can support the system, but the report still needs a clear boundary and any exclusions.
A retailer has one safety system for stores and distribution centres, but head office staff are not included because they work remotely and are covered by a separate wellbeing process. The draft wording says only that the system covers “operational sites” and gives no reason for the omission.
QWhat should the preparer do about workers or workplaces that are left out of the described system?
Reveal model answer →Hide answer ↑They should explain whether any workers, activities or workplaces are outside the system, and if so, why. A vague label such as “operational sites” is not enough if it hides a real exclusion, because the reader needs to understand the full scope and the reason for any gap.
Why this matters · Any exclusion should be stated with a reason, so the scope is transparent.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Work-related ill health → Guide ✓Hazard identification, risk assessment, and incident investigation → Guide ✓Occupational health services → Guide ✓Worker participation, consultation, and communication on occupational health and safety → Guide ✓Worker training on occupational health and safety → Guide ✓Promotion of worker health → Guide ✓Show all 9 related disclosures →
FAQ
Questions this page answers
What do I need to gather before drafting GRI 403-1 Occupational Health and Safety on this page?+−
Start with the datapoints listed on the page: system coverage statement, legal basis, legal requirements list, standards basis, frameworks used, system coverage scope, and any exclusions with reasons. The page also has a step-by-step preparation section to help you turn those inputs into a draft.
How do I decide the scope for GRI 403-1 Occupational Health and Safety using this page?+−
Use the page’s system coverage scope and exclusions fields to define what is in and out of scope, and record the reasons for any exclusions. The page is set up to help you explain the coverage clearly rather than assume a one-size-fits-all approach.
What evidence should I keep for GRI 403-1 Occupational Health and Safety in case of assurance?+−
The page includes an evidence pack with five items and six assurance claims to verify, each framed around claim, risk and evidence. Use those to build a file that shows how the disclosure was prepared and what supports each statement.
What are the common mistakes to avoid when preparing GRI 403-1 Occupational Health and Safety?+−
The page lists common reporting gaps and mistakes so you can check for missing scope detail, weak explanations, or unsupported statements before you finalise the disclosure. It is designed as a practical review aid rather than a compliance checklist.
How can I use the Prep & Assurance workbook for GRI 403-1 Occupational Health and Safety?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format that you can use to capture the required datapoints and organise assurance evidence. The page also offers a printable Library Card in PDF if you want a lighter reference copy.
What should the draft output for GRI 403-1 Occupational Health and Safety include?+−
The page gives draft-output support through visualisation ideas, narrative starters, and a GRI content-index line. That helps you turn the prepared data into a report-ready draft without starting from a blank page.
Can I use the synthetic example on the GRI 403-1 Occupational Health and Safety page as a template?+−
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table, to show how the disclosure can be presented. Treat it as a worked example only and make sure your own figures and wording match your actual data.
How do I link GRI 403-1 Occupational Health and Safety to ESRS S1 without double work?+−
The page notes ESRS S1 (Own Workforce) as the closest correspondence, so you can reuse the same underlying data where it is relevant. It does not say the requirements are identical, so you still need to check the disclosure wording and presentation separately.
Who should own the data for GRI 403-1 Occupational Health and Safety in my organisation?+−
The page is written for sustainability and ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with whoever can explain the system coverage, legal basis, and evidence behind the disclosure. Use the preparation section and workbook to make responsibilities clear internally.
Where can I find real company examples for GRI 403-1 Occupational Health and Safety?+−
The page has a 'From company reports' table that links to real published reports where the topic is disclosed. That can help you see how others have handled the topic, while still building your own disclosure from your own data.
More questions this page can help with
GRI 403-1 Occupational Health and Safety workbook download and how to use itGRI 403-1 Occupational Health and Safety evidence pack what to includeGRI 403-1 Occupational Health and Safety common mistakes and reporting gapsGRI 403-1 Occupational Health and Safety system coverage statement exampleGRI 403-1 Occupational Health and Safety legal basis and legal requirements listGRI 403-1 Occupational Health and Safety standards basis for systemGRI 403-1 Occupational Health and Safety exclusions and reasons how to writeGRI 403-1 Occupational Health and Safety draft narrative startersGRI 403-1 Occupational Health and Safety content index line exampleGRI 403-1 Occupational Health and Safety assurance claims to verifyGRI 403-1 Occupational Health and Safety from company reports tableGRI 403-1 Occupational Health and Safety ESRS S1 data reuse
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