Disclosure focus
This disclosure asks an organisation to report whether it has had any incidents of discrimination during the reporting period, and what it did in response. The emphasis is on the actual cases that occurred, not just on having a policy in place. It is about showing the extent of the issue and the follow-up action taken to address it.
In practice, the reporting focus should cover the organisation’s full operations, not only a few well-managed or high-profile sites. The useful question is whether incidents are being identified and handled consistently wherever the organisation operates, and whether corrective actions are being applied in a way that helps prevent repeat issues.
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 406-1 sub-elements (LRA working checklist)
Track the current position of each incident and the steps taken in response.
Count all discrimination incidents that occurred during the reporting period.
How to prepare it
1Set the reporting boundary first: decide which parts of the business, sites, teams, and time period are in scope for the count, so the figures and narrative cover the same reporting period throughout.
2Agree the counting rule for what you will treat as a discrimination incident, and use that rule consistently before you start collecting cases, so the total is built on one clear basis.
3Gather the underlying records for each case, such as case logs, investigation notes, HR files, grievance records, or other internal evidence that supports both the number and the case status.
4Compile the output in two parts: one numeric total for incidents during the period, and one short narrative on where each case stands and what action has been taken.
5Record any exclusions, restatements, or methodology changes, including why a case was left out or reclassified, so the reported total can be traced back to the source material.
6Check the final disclosure against the official source and your internal records to confirm the count, the case status summary, and the supporting evidence all align before sign-off.
Request the data
Request discrimination case log and outcome summary
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How many discrimination cases were logged in the period, and what happened to each one?
Use your organisation’s own case-handling language first, then map it to this disclosure. For example, if your team talks about grievances, conduct cases, speak-up reports, investigations, or employee relations matters, use those terms in the request and only translate them into the reporting label at the end. Keep the ask focused on the case log, the outcome, and any follow-up action.
Weak request
Please provide the GRI 406-1 data for discrimination incidents and corrective actions.
Why it fails: This uses framework language only, so the owner has to guess which internal records to search, how to count cases, and what level of detail is needed. It also does not specify the period, boundary, source system, or the status/action information needed to complete the disclosure.
Better request
Please pull the discrimination-related case log from [system] for [period], covering [boundary]. I need the total number of cases recorded, plus each case’s current status and any follow-up action taken. Please use your internal case labels, note the counting method, and flag any late updates or exclusions.
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 you counted each discrimination-related case, including the basis used to decide whether an event was included and how you grouped the case outcomes and follow-up steps.
Context note
Explain what the total case count and the case-status split indicate about the organisation’s experience of discrimination and how far each matter has progressed.
Fluctuation statement
If the figures moved materially from the prior period, describe the main operational or reporting reasons for the change and whether it reflects more cases, different handling, or both.
Content index entry
GRI 406-1 Incidents of discrimination and corrective actions taken — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for GRI 406-1 — 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
Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps
Mistakes to avoid when collecting the data
Wrong case owner
The data request goes to the wrong team, so the count is chased through HR, legal, and line management instead of the function that actually logs discrimination cases.
Framework language only
People ask for the information using disclosure jargon rather than the organisation’s own case labels, so the source team cannot map the request to their records.
Scope left vague
No one agrees which parts of the business, worker groups, or locations are in scope, so different teams pull different sets of cases.
Period basis mixed up
The team uses a different timing basis for the case count than for the status update, so the figures do not relate to the same reporting window.
Counting rules not aligned
One person counts every complaint while another counts only confirmed cases, which produces a total that cannot be reconciled back to one method.
Source labels stripped out
The original case references and status tags are removed during collection, so the team cannot trace each figure back to the underlying record.
Separate groups merged
Cases from different worker populations or business areas are combined even though they should be tracked separately, which hides the real pattern.
Evidence details missing
The file contains numbers but not the supporting dates, record IDs, or document links, so the team cannot show where the data came from.
No approval trail
The final dataset is circulated without a named reviewer or sign-off record, so nobody can show who checked the figures before they were used.
Where judgement is often needed
Group-wide count after a business change
Decide whether to include incidents from sites or teams added or removed during the period, and explain the cut-off used so the total matches the organisation’s reporting boundary for that year.
Different local meanings of unfair treatment
Where country rules or internal policies use different labels for similar conduct, map them to one organisation-wide view for counting and say how you translated local cases into that single tally.
Cases at the edge of the reporting scope
Set out whether you include matters involving contractors, agency staff, former workers, applicants or other non-employees if they sit near your operational boundary, and describe the rule applied.
One event, several people affected
Choose whether a single episode affecting multiple individuals is counted as one incident or several, apply that approach consistently, and explain it in the narrative.
Open cases at period end
State whether you count only matters closed by the reporting date or also unresolved cases identified before that date, and make clear how the status note reflects any live follow-up.
Internal records versus estimates
If complete case files are not available, use a documented estimate only where necessary, explain the method used, and flag any limits on confidence in the figure or status summary.
Privacy limits on detail
When naming the nature of the case or the action taken could identify people, group the information to protect privacy while still showing the overall status and response pattern.
Rounding and small numbers
Agree a rounding rule for the incident total and apply it consistently, making sure the rounded figure does not misstate the underlying count and that the status description still aligns with the number reported.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Retail and distribution
*Synthetic example only.* During the year, we recorded **3** discrimination complaints across our workforce. - **2** matters were closed by the reporting date after review and corrective action, including manager retraining and a policy reminder. - **1** matter was still open at year-end and had been escalated for further investigation and follow-up with the people involved.
This example shows a simple narrative way to report the count of discrimination-related complaints and then explain what happened to each case by period end, including the actions taken.
Illustrative (synthetic) example — Construction and engineering
*Synthetic example only.* We identified **5** discrimination-related incidents during the reporting period. - **4** had been resolved before the year closed, with outcomes ranging from mediation to disciplinary action and refresher training. - **1** remained under review at the reporting date, with interim safeguards in place while the investigation continued.
This example illustrates how to pair the total number of incidents with a short status update and a plain-language summary of the response for each outcome.
Company reports
How companies report GRI 406-1
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
CRH plc
Construction Materials · Ireland · 2024
CRH plc’s 2024 Sustainability Performance Report provides specific data on incidents of discrimination, reporting a total of 23 instances along with corrective actions taken (p.103). The report also includes narrative details on supplier assessment approaches at the commodity level (p.104). However, information on incidents of forced or compulsory labour is noted as incomplete and monitored locally (p.103), and there are no recorded incidents of non-compliance concerning product and service information and labeling (p.104).
JD Logistics
Air Freight Transportation and Logistics · China · 2025
JD Logistics’ 2025 ESG Report provides specific data on incidents of discrimination and the corrective actions taken, as detailed on page 110, alongside information on incidents of corruption and related responses found on page 108. The report also references measures for waste prevention and employee turnover, indicating some coverage of environmental and employment issues (pp.109-110). However, the report does not clearly present comprehensive details on the outcomes or effectiveness of these actions, leaving some aspects of the disclosure unclear.
Marfrig Global Foods S.A.
Food Production — Animal Source · Brazil · 2024
Marfrig Global Foods S.A.'s Integrated Report 2024 provides detailed numeric data on various incidents, including 14 reports of misconduct or inappropriate behavior, 12 internal policy violations, and 20 incidents of harassment or discrimination (p.33). The report also references incidents of discrimination and corrective actions taken, linking to further details on pages 103 and 127, and mentions investigations concluding within 90 days, with possible extensions depending on complexity (pp.33-34, 127). However, the report is unclear on the full scope of corrective measures or outcomes related to these incidents, and some references to non-compliance and supplier evaluations are noted without explicit connection to the disclosure focus (pp.128-130).
✓ LRA AI Assistant · Human-in-the-loop
Ask Study Studio AI assistant about this disclosure
Get a practical answer for your reporting context. Your first answer is free — create a free account to continue the conversation.
TryHow do I prepare GRI 406-1?What data do I need to collect?Where can I see a real-report example?What mistakes should I avoid?
1 free answer
Check your understanding
Scenarios to work through
During the year, two employees raised separate complaints about unfair treatment linked to protected characteristics. One case was upheld and the person responsible was moved off people-management duties; the other was not upheld after review.
QHow should you count these matters for the disclosure, and what should you include about each one?
Reveal model answer →Hide answer ↑Count both matters as incidents for the period, because they were discrimination complaints that were handled as separate cases. Then give a short status update for each one, such as whether it was upheld or not upheld, and note the action taken in the upheld case.
Why this matters · Report the number of discrimination cases in the period, then explain what happened to each case and what was done about it.
A worker reported discriminatory remarks in March, but the investigation was still open at year-end. By the time the report is drafted, the case has not yet been closed and no final outcome is available.
QDo you leave this out until the case is finished, or include it now?
Reveal model answer →Hide answer ↑Include it in the period count if it arose during the reporting year, even though it is still open. In the status note, say that the review is ongoing and describe any interim steps already taken, without pretending there is a final outcome.
Why this matters · An open case can still belong in the year’s total if it happened in that year; the status note should reflect that it is still being handled.
A contractor working on site alleged discrimination by a line manager. The investigation found the complaint was not substantiated, but the manager still received refresher training on respectful conduct and the complaint process was updated.
QWhat should the narrative say about the case and the follow-up action?
Reveal model answer →Hide answer ↑Record the incident in the count if it is part of the reporting period’s discrimination cases, then describe the outcome as not substantiated and explain the follow-up action that was still taken, such as training or process changes. The status note should show both the result and the response.
Why this matters · The status section should cover both the case outcome and any corrective or preventive steps, even when the allegation is not upheld.
Three discrimination complaints were logged in the year. One was resolved through mediation, one led to dismissal of the employee involved, and one was withdrawn before investigation ended.
QHow do you present the total and the case-by-case status so the disclosure is complete?
Reveal model answer →Hide answer ↑State the total as three incidents for the year, because there were three separate complaints. Then summarise each case’s status in plain language: one resolved through mediation, one ended with dismissal, and one was withdrawn before the investigation finished.
Why this matters · The total is a simple count of incidents, while the narrative should briefly show the outcome or current state of each one.
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 a draft GRI 406-1 disclosure using the page’s step-by-step guidance?+−
Use the plain-language explainer, the datapoints to prepare, and the step-by-step ‘how to prepare’ section to shape the draft. The page also gives narrative starters and a GRI content-index line you can adapt into your own reporting pack.
What data do I need to collect for GRI 406-1 on non-discrimination?+−
The page says to prepare two datapoints: discrimination incident count, and case status and response. It also includes a synthetic illustrative table you can use as a model for how to organise the figures before drafting.
How should I define the scope and methodology for the GRI 406-1 data on this page?+−
The page is set up to help you work through scope and method using the step-by-step preparation section and the workbook. It does not add extra rules here, so you should use the page materials to document how you counted incidents and how you tracked case status and response.
Who should own the GRI 406-1 non-discrimination disclosure in practice?+−
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership can sit with whichever of those teams holds the underlying case data. The workbook and evidence-pack sections are there to help the owner coordinate inputs and keep the draft supportable.
What should I include in an evidence pack for GRI 406-1 assurance readiness?+−
The page includes an evidence pack with five items for assurance readiness, plus five assurance claims to verify with claim, risk and evidence. Use those materials to assemble support for the incident count, case status, and response before the draft is reviewed.
What are the common mistakes people make when reporting GRI 406-1?+−
The page lists common reporting gaps and mistakes to watch for, so it is useful as a pre-submission check. In practice, use it to spot missing data, weak explanations, or unsupported claims before you finalise the disclosure.
How do I use the Prep & Assurance workbook for GRI 406-1?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is designed to support preparation and assurance readiness. Use it alongside the page’s step-by-step guidance, evidence pack, and draft-output section to move from raw data to a reviewable draft.
What can I take from the synthetic example disclosure for GRI 406-1?+−
The page includes synthetic illustrative example disclosures, including a quantitative table, to show how the disclosure can be presented. Treat it as a formatting and drafting aid only, and make sure any numbers in your own draft are internally consistent.
Can I reuse my GRI 406-1 data for ESRS S1 (Own Workforce)?+−
The page says ESRS S1 (Own Workforce) is the closest correspondence, so the same underlying data may be reusable. It does not say the requirements are identical, so you would still need to check how each framework wants the information presented.
What should the final draft output for GRI 406-1 include on this page?+−
The draft-output section points you to visualisation ideas, narrative starters, and a GRI content-index line. That gives you a practical starting point for turning the prepared data into a disclosure draft.
More questions this page can help with
GRI 406-1 non-discrimination: what datapoints should I prepare before drafting?GRI 406-1 non-discrimination: how do I build an assurance-ready evidence pack?GRI 406-1 non-discrimination: what are the common reporting gaps to check for?GRI 406-1 non-discrimination: how do I use the workbook and printable library card?GRI 406-1 non-discrimination: what does the synthetic example disclosure show?GRI 406-1 non-discrimination: how do I turn the page into a draft disclosure?GRI 406-1 non-discrimination: who should own the data and sign-off?GRI 406-1 non-discrimination: what should I verify before assurance review?GRI 406-1 non-discrimination: how does the page help with scope and methodology?GRI 406-1 non-discrimination: can I map the data to ESRS S1 (Own Workforce)?
Free · LRA Community
Get your GRI 406-1 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 →