Disclosure focus
This disclosure asks an organisation to explain where, in its own activities and in its supply chain, workers may face a higher risk that their right to join together, choose representatives and bargain collectively is not fully protected. The focus is not on saying the organisation supports these rights in principle, but on identifying the parts of the business and the supplier base where the risk is present and describing them clearly.
In practice, the emphasis is on coverage across the whole organisation rather than only highlighting a few well-known sites. A useful response should show which operations and which suppliers are included in the assessment, where the risk is concentrated, and whether the organisation has looked beyond flagship locations to less visible 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 407-1 sub-elements (LRA working checklist)
Set out the steps you took during the reporting period to help workers use their right to join together and bargain collectively.
Identify the parts of your own operations where those worker rights could be breached or are especially exposed to risk, whether because of the kind of activity or the countries/areas involved.
Identify the suppliers where those worker rights could be breached or are especially exposed to risk, whether because of the supplier type or the countries/areas involved.
How to prepare it
1Set the reporting boundary first: decide which parts of the business and which supplier groups you will assess, and which countries or locations you will treat as higher risk for worker voice and bargaining rights.
2Agree the screening rules you will use to flag risk, so the same approach is applied to each operation and supplier and the basis for inclusion is clear.
3Gather the supporting material for each flagged area, such as internal assessments, supplier checks, site reviews, audit notes, grievance records, or other records that show why the area was identified.
4Prepare the disclosure content in two parts: list the operations and suppliers that meet your risk screen, then summarise the actions taken during the year to support those rights.
5Record any exclusions, scope changes, or changes in how you identified risk, so readers can see what was left out and whether the current year is directly comparable with prior reporting.
6Check the final draft against the official source and your evidence pack to confirm the named areas, the reported actions, and the scope treatment all match the underlying records.
Request the data
Request the supplier and site risk evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which parts of our own operations and supplier base may need to be flagged because worker voice or bargaining arrangements could be constrained, and what actions did we take in the period to support those rights?
Use your organisation’s own labels first, then map them to the reporting wording. For example, ask for your high-risk sites, business units, vendor groups, countries, labour channels, or contract types rather than using framework terms in the request itself.
Weak request
Please provide the GRI 407-1 evidence for operations and suppliers at risk and the measures taken to support freedom of association and collective bargaining.
Why it fails: It uses framework language only, so the owner has to translate the ask before they can respond. It also does not say which internal lists, systems, or labels to pull from, or what period and evidence trail to include.
Better request
Please send the current list of sites, business units, supplier groups, or sourcing channels you have flagged because worker voice or bargaining arrangements could be constrained, plus any actions taken in [period] to support worker representation or bargaining. Use your own internal names, the source system or file, the reason each item was flagged, and the 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
Explain how the organisation decided which operations and suppliers to flag as higher risk, including the basis used to define the risk screen and how the reporting boundary was set.
Context note
Set out what the figures mean in practice by linking the flagged operations and suppliers to the organisation’s exposure to possible restrictions on workers’ ability to organise and bargain collectively, and summarise the support measures taken in the period.
Fluctuation statement
If the number or spread of flagged sites or suppliers changed materially, describe the main drivers, such as changes in the business footprint, supplier mix, or the scope of the risk review, and note any corresponding change in support actions.
Content index entry
GRI 407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk — [location / page] / [notes]
Download Centre
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, wrong language
The request goes to the wrong team, or it is framed in framework terms instead of the business labels people actually use, so the source data never gets pulled from the right place.
Scope left vague
No one pins down which sites, countries, service lines, or supplier groups are in scope, so different teams send different populations that cannot be reconciled.
Risk screen not defined first
The team starts collecting names before agreeing what counts as a higher-risk operation or supplier, so the list reflects guesswork rather than a consistent screen.
Period basis is mixed up
Some contributors use the reporting year while others use a different cut-off date or snapshot, which makes the final population inconsistent.
Counting rules are not aligned
One source counts legal entities, another counts sites or contracts, and the numbers are merged as if they were the same basis.
Source labels get stripped out
The original tags, site names, country codes, or supplier identifiers are lost during consolidation, so the evidence cannot be traced back to the first record.
Separate populations are merged
Operations and suppliers are blended into one list too early, which hides where the risk sits and makes later checking much harder.
Evidence trail is incomplete
The file contains names but not the supporting notes, dates, or document references, so no one can show how the data was assembled or reviewed.
No sign-off record
The draft is circulated without a named reviewer or approval trail, so there is no clear record of who checked the figures and when.
Where judgement is often needed
Set the reporting boundary after acquisitions and disposals
Use the same cut-off date and consolidation basis as the rest of the report, then explain any newly added or removed sites or suppliers and whether they were assessed for risk in the period they were in scope.
Choose one country-risk basis and apply it consistently
If local law, labour practice or operating conditions point in different directions, document the rule you used to flag a location or supplier as higher risk and keep that rule stable across the year unless you explain the change.
Decide how to treat mixed-risk operations
Where only part of a site, business line or contract sits in a higher-risk setting, state whether you classify the whole item or only the exposed part, and describe the logic behind that split.
Handle suppliers at the edge of the supply chain
Be clear whether you include direct suppliers only or also lower-tier sources where you have enough visibility, and explain any exclusions where the link to the supplier is too indirect or the evidence is too weak.
Separate measured evidence from informed judgement
If you do not have a full site-by-site or supplier-by-supplier review, say which entries are confirmed by records and which are based on a reasoned estimate, together with the basis used for that estimate.
Fix the timing of the assessment window
State whether the list reflects conditions at period end, an average across the year, or events during the year, and make sure the timing matches the measures you describe for the same period.
Use a privacy-safe level of detail
When naming locations, supplier groups or worker populations could expose individuals or sensitive relationships, aggregate the information to a safe level and explain the level of grouping you used.
Round counts without changing the picture
If you present numbers of sites, suppliers or actions, round them in a way that does not distort the result, and note the rounding approach where it could affect interpretation.
Explain how you treat temporary or contingent labour
If agency staff, contractors or other non-permanent workers are part of the relevant workforce, say whether they are included in the assessment and why they are or are not treated as in scope.
Describe the measures taken in plain operational terms
For the period’s actions, distinguish between policy updates, training, grievance routes, supplier engagement and remediation, and explain which of these were actually carried out rather than planned.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Apparel manufacturing
*Synthetic illustration only.* During the year, we reviewed our own sites and key third-party factories to identify where employee representation and bargaining arrangements could be constrained, and we prioritised follow-up in higher-risk countries and labour-intensive production lines. - Our review covered 14 owned or controlled operations; 5 were flagged as higher risk because of location or operating model, and 2 of those were in the highest-risk category. - We also screened 38 direct suppliers; 11 were treated as higher risk, including 4 in higher-risk countries and 3 labour brokers used for temporary staffing. - To support worker voice, we updated supplier contracts, trained 126 managers and procurement staff, opened 7 worker-feedback channels, and carried out 19 follow-up assessments with corrective actions where needed.
This example shows how to describe where worker representation may be weaker, both in the company’s own activities and across its supply chain, and then summarise the practical steps taken during the period to strengthen worker voice.
Illustrative (synthetic) example — Food processing and distribution
*Synthetic illustration only.* We mapped our facilities and sourcing base to spot places where staff may find it harder to organise or bargain collectively, then focused our attention on regions with weaker labour protections and on outsourced logistics and seasonal labour providers. - Of 9 company-run sites, 3 were identified as higher risk because of geography or operating profile. - Of 52 suppliers assessed, 8 were identified as higher risk; this included 5 agricultural suppliers and 2 logistics providers operating in higher-risk locations. - In response, we refreshed our supplier code, ran 11 site briefings, completed 6 worker-engagement sessions, and escalated 4 cases for remediation planning with suppliers.
This example illustrates a concise narrative that separates the company’s own operations from supplier relationships, identifies where the risk is concentrated, and then lists the main actions taken to support employee and worker representation during the reporting period.
Company reports
How companies report GRI 407-1
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Cogna Educação S.A.
Education Services · Brazil · 2024
Cogna Educação S.A.’s 2024 Relato Integrado report provides evidence of collective bargaining coverage, noting operations and suppliers where the right to freedom of association and collective bargaining applies (p.160), and states that all employees are covered by collective bargaining or employment agreements (p.138). The report also mentions screening of new suppliers for environmental criteria (p.150) and includes workforce demographic data by employee category and ethnicity (p.145). However, details on remediation plans or specific supplier risk assessments for forced labor are less clear, with only a brief mention of suppliers at risk (p.149) and no explicit remediation actions reported.
London Luton Airport Operations Ltd.
Air Transportation — Airport Services · United Kingdom · 2024
London Luton Airport Operations Ltd.'s Sustainability Report 2024 includes coverage of collective bargaining and child labour risks, referencing GRI 407 and 408 standards on page 71. The report also provides supply chain data, including the number of suppliers and total spend, on page 49. However, details on the progress of community relationship reviews and certain land-use actions remain unclear or not started as of 2024 (p.64-65), and while collective bargaining agreements are mentioned, the extent of their implementation is not fully detailed (p.70).
China Airlines, Ltd.
Air Transportation — Airlines · Taiwan · 2024
China Airlines' 2024 Sustainability Report provides coverage on human rights issues, including collective bargaining risks and child labor concerns, with specific references on page 184 to operations and suppliers where these risks may be significant. The report also details procurement practices related to irreplaceable suppliers and their cumulative annual procurement amounts on page 74. However, the report does not clearly specify quantitative data or detailed outcomes related to these human rights risks, leaving some aspects of the disclosure unclear.
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Check your understanding
Scenarios to work through
A manufacturer runs one plant in a country where employee representation is tightly controlled, and another site in a region where labour disputes have recently led to restrictions on worker organising. The reporting team has a list of both sites, but no formal risk note yet.
QShould these sites be included in the narrative, and what basis should be used to decide that?
Reveal model answer →Hide answer ↑Yes. The team should include any site where workers’ ability to organise or bargain collectively could be undermined because of the kind of operation or because of the country or area where it sits. The judgement should be based on a documented risk review, not on whether a problem has already happened.
Why this matters · List the places where the risk is present or plausible, using a clear risk-based assessment tied to the operation and location.
A group buys packaging from a small supplier in a jurisdiction with weak labour protections, but the supplier has not reported any union-related complaints. The procurement lead argues that, because there is no known incident, the supplier should be left out.
QHow should the preparer decide whether to name that supplier in the disclosure?
Reveal model answer →Hide answer ↑The supplier can still belong in the disclosure if its type of business, or the country or area it operates in, means workers’ association or bargaining rights may be at risk. The absence of a complaint does not remove the need to assess and report the risk where it exists.
Why this matters · The test is potential exposure to risk, not only confirmed incidents or grievances.
During the year, a company introduced a supplier code, trained site managers in high-risk locations, and added a worker-voice channel for two factories. The sustainability team is unsure whether these actions belong in the same disclosure as the risk list.
QWhat should be reported about these actions, and how should they be framed?
Reveal model answer →Hide answer ↑They should be reported as the steps taken during the year to support workers’ ability to join together and bargain collectively. The description should focus on what was done in the period, using plain language that links each action to support for those rights.
Why this matters · Alongside the risk list, explain the practical steps taken in the year to support the relevant worker rights.
A retailer has 18 direct suppliers and 42 indirect suppliers. After review, it identifies 3 direct suppliers and 5 indirect suppliers as higher risk because of their locations and labour conditions. The draft report currently mentions only the direct suppliers.
QWhat should the preparer check before finalising the disclosure?
Reveal model answer →Hide answer ↑The preparer should make sure the disclosure covers suppliers at risk wherever they sit in the supply chain, not only direct ones. If indirect suppliers are part of the assessed risk set, they should be included in the narrative in a way that is clear and internally consistent with the review carried out.
Why this matters · Cover all assessed suppliers at risk, and keep the reporting aligned with the scope of the risk review.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
For GRI 407-1, what data do I need to collect before I start drafting the disclosure?+−
The page says to prepare three datapoints: at-risk operations, at-risk suppliers, and support measures taken. Use those as the core inputs before you draft the narrative or table.
How do I scope GRI 407-1 so I do not overstate or understate the disclosure?+−
Use the page’s step-by-step preparation guidance and keep the scope tied to the three datapoints it highlights. The page also flags common reporting gaps, which is useful for checking that your scope is consistent and complete.
Who should own the GRI 407-1 data collection in practice?+−
The page is designed for ESG, HR and data owners, so ownership should sit with the team that can confirm the underlying operational and supplier information and the support measures taken. The workbook can help you assign tasks and track what is still needed.
What evidence should I keep to make a GRI 407-1 disclosure assurance-ready?+−
The page includes an evidence pack with five items and five assurance claims to verify, each framed around a claim, risk and evidence. Use those to build a file that shows where the numbers and narrative came from.
What are the most common mistakes people make when reporting GRI 407-1?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot issues before you finalise the draft. In practice, use that section to check whether the disclosure is missing one of the three datapoints or is not supported by evidence.
How should I use the GRI 407-1 workbook download to prepare the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the preparation steps, capture the datapoints, and assemble the assurance evidence pack.
What is the printable GRI 407-1 Library Card for, and when should I use it?+−
The page says the Download Centre includes a printable Library Card in .pdf format. It is a practical companion for keeping the disclosure requirements, preparation steps and evidence checks in one place while you work.
Can I use the synthetic example on the GRI 407-1 page as a template for my own disclosure?+−
Yes, but only as an illustrative guide. The example is synthetic and the quantitative table is there to show how the disclosure might be presented, not to replace your own company data.
How do I turn my GRI 407-1 data into a draft narrative and table?+−
The page includes draft-output support with visualisation ideas, narrative starters and a GRI content-index line. Use those to turn the prepared datapoints into a first draft, then check it against the evidence pack and common gaps.
What should I include in the GRI 407-1 evidence pack before assurance review?+−
The page says the evidence pack has five items and is designed for assurance readiness. Build it around the source records for at-risk operations, at-risk suppliers and support measures taken, plus anything needed to support the claims you are making.
More questions this page can help with
GRI 407-1 freedom of association and collective bargaining: what are the three datapoints I need to gather?How do I use the step-by-step preparation section for GRI 407-1?What does the GRI 407-1 assurance checklist cover?What goes into the GRI 407-1 evidence pack?How do I avoid common reporting gaps in a GRI 407-1 disclosure?How do I write the draft output for GRI 407-1 using the page’s narrative starters?Where can I download the GRI 407-1 workbook and library card?Is the GRI 407-1 example disclosure on the page real company data?How do I build a GRI 407-1 content index line from the page?Who should be responsible for GRI 407-1 in an ESG reporting process?How do I check whether my GRI 407-1 disclosure is ready for assurance?Does the GRI 407-1 page provide an ESRS or IFRS mapping?
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