Disclosure focus
This disclosure asks an organisation to report the corruption incidents it has confirmed during the reporting period, and what it did in response. The emphasis is on actual, verified cases rather than allegations or untested concerns, so the report should distinguish confirmed incidents from broader ethics or whistleblowing activity.
In practice, the focus is on giving a clear picture of where confirmed incidents occurred across the organisation and what follow-up action was taken. That means looking beyond flagship sites or headquarters and considering the full scope of operations, so readers can see whether incidents were isolated or part of a wider pattern, and whether the response was disciplinary, remedial, preventive, or a combination of these.
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 205-3 sub-elements (LRA working checklist)
Describe what the confirmed corruption cases involved.
Set out any public court or legal actions about corruption involving the organisation or its staff during the period, and explain how each ended.
State how many confirmed corruption cases led to employees being dismissed or otherwise disciplined.
Give the total count of confirmed corruption cases.
State how many confirmed cases led to ending or not renewing contracts with business partners because of corruption-related breaches.
How to prepare it
1Set the reporting boundary first: decide which parts of the organisation and which period you will include, then use that same scope consistently for every figure and case note you prepare.
2Agree your counting rules before you start compiling data. Define what you will treat as a confirmed corruption incident, how you will classify the incident type, and how you will separate employee discipline, contract action, and legal cases so the same event is not counted in more than one place unless your source records clearly support that treatment.
3Gather the underlying records from the teams that hold them. Typical sources include investigation files, HR action records, supplier or customer contract decisions, and legal or compliance logs that show the incident, the response taken, and the outcome.
4Build the disclosure from the evidence. Prepare the total count of confirmed incidents, a short description of what those incidents involved, the number of cases leading to dismissal or other discipline, the number of contract terminations or non-renewals linked to corruption-related breaches, and a narrative on public legal cases and their results.
5Record any exclusions, restatements, or changes in method. If a case is left out, reclassified, or moved between periods, note why and make the treatment clear so readers can follow the basis of the numbers and narrative.
6Check the draft against the official source and the supporting files. Confirm that every required item is covered, the totals match the evidence, the wording is consistent with the records, and any assumptions or judgments are documented for review.
Request the data
Request the corruption case log and outcomes
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What confirmed corruption matters were recorded in the period, and what action was taken in each case?
Use your organisation’s own terms first, then map them to the reporting fields. For example, ask for the ethics case log, investigations register, disciplinary outcomes, contract exit records, and litigation tracker if those are the names used internally. Keep the request in business language and check the source material before sign-off.
Weak request
Please provide the GRI 205-3 data for confirmed incidents of corruption, including the number of incidents, disciplinary actions, contract terminations, and legal cases.
Why it fails: This uses framework wording only, so the owner has to translate the request before they can act. It does not say which internal records to pull, what period to cover, which boundary to use, or how to show the evidence. It also bundles several measures without telling the team how to identify the underlying cases.
Better request
Please send the ethics/investigations case log for [reporting period] covering confirmed corruption matters in [organisation boundary], plus the related outcomes. For each case, include the internal reference, date confirmed, your usual case label, a short summary, whether any employee was disciplined or dismissed, whether any partner contract was ended or not renewed, and whether any public legal case was brought and how it ended. Please attach the source extract or link and note any gaps.
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 defined a confirmed corruption case, how you counted each incident, and whether the figures cover the whole reporting period and all relevant parts of the organisation and its business relationships.
Context note
Explain what the figures indicate about the scale and character of corruption-related issues, including whether any cases led to staff sanctions, contract changes, or public legal action.
Fluctuation statement
If the numbers moved materially from the prior period, note whether that was driven by a small number of larger cases, improved detection, changes in reporting practice, or a genuine shift in underlying conduct.
Content index entry
GRI 205-3 Confirmed incidents of corruption and actions taken — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for GRI 205-3 — 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
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 owner
The request goes to the wrong team, so the count is built from the wrong case files instead of the people who hold the investigation, HR, legal, or contract records.
Framework terms only
The data call uses disclosure language rather than the organisation’s own case labels, so local teams cannot map their records to the request without guesswork.
Scope not fixed
No one states which parts of the business, subsidiaries, or joint arrangements are in scope, so some incidents are included twice while others are missed.
Period basis drift
The team mixes cases opened in one year with cases closed in another, so the figures do not match the reporting window used for the rest of the pack.
Counting rule mix-up
One extract counts every allegation while another counts only substantiated cases, so the totals for incidents and follow-up actions are not built on the same basis.
Source labels lost
Original case references, status tags, and outcome notes are stripped out during consolidation, making it impossible to trace each number back to the underlying record.
Populations merged
Employee discipline, supplier contract action, and legal case data are rolled into one file without separation, so the different measures cannot be checked independently.
Evidence trail missing
The spreadsheet is saved without the supporting documents, timestamps, and reviewer sign-off, so no one can show how the figures were assembled or approved.
Where judgement is often needed
Set the cut-off date for counting cases
Choose one reporting cut-off and apply it consistently so each confirmed case is counted in only one period, then explain that basis if it differs from how internal case logs are dated.
Decide how to treat newly acquired or sold parts of the business
State whether incidents from businesses added or removed during the year are included only for the time they were under your control, and explain any change in the population covered compared with last year.
Use one working definition where local rules differ
If countries or business units label misconduct differently, map those local labels to a single group-wide interpretation for this disclosure and say how you aligned the figures across locations.
Be clear on borderline people and entities
Explain whether cases involving contractors, agency staff, joint-venture staff, or other close third parties are included in your counts, and keep the same inclusion rule across all measures.
Separate confirmed cases from allegations or open reviews
Count only matters that have been established as corruption under your chosen internal process, and describe how you handled cases that were still under review at period end.
Link the action count to the same incident basis
Make sure dismissals, discipline, contract endings, and non-renewals are counted only where they relate to a confirmed corruption case, and state if one case led to more than one action.
Decide how to present legal matters with privacy limits
Where naming cases or outcomes could breach confidentiality or data-protection rules, aggregate the description so the nature and result are still understandable without identifying individuals unnecessarily.
Round numbers without changing the story
If you round the incident counts, use one rounding rule throughout and note it so readers can see that small totals or zero values have not been distorted.
Choose whether to use measured counts or estimates for late data
If some locations report late or incomplete case data, explain whether you used direct counts, a documented estimate, or a later true-up, and keep the method consistent from one year to the next.
Describe the outcome of public court matters at the same level of detail
For public cases brought against the organisation or its people, state the final status or result in plain language and explain any unresolved matters separately from closed ones.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — utilities
We recorded 4 confirmed corruption incidents in the year, all involving improper gifts or hospitality; 2 led to dismissal or formal discipline, and 1 business contract was ended after a partner breach. There were no public court cases brought against us or our staff during the period.
Synthetic illustration only. Shows how to report the count of confirmed corruption matters, the broad nature of those matters, the number of staff sanctions, the number of partner-contract terminations, and whether any public legal cases arose and how they ended.
Illustrative (synthetic) example — food manufacturing
We confirmed 3 corruption incidents, made up of 2 procurement-related bribery cases and 1 facilitation-payment case; 1 employee was dismissed, and 2 supplier agreements were not renewed. No public legal proceedings were filed against the company or its employees in the reporting year.
Synthetic illustration only. Shows a second plausible reporting pattern with a different mix of incident types, while still covering the incident count, the nature of the cases, staff consequences, partner-contract outcomes, and the presence or absence of public legal action.
Company reports
How companies report GRI 205-3
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Mega Financial Holding Co., Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
Mega Financial Holding Co., Ltd.'s 2024 Sustainability Report provides numeric data on work-related injuries and fatalities, reporting 56 to 73 injuries and zero to one fatality in different years (p.191). The report also includes figures related to new employee hires, turnover, and benefits under GRI 401 Employment standards (p.195), as well as data on communication and training about anti-corruption policies (p.193). However, no narrative explanations or qualitative descriptions related to these disclosures were found in the report.
Globalvia
Ground Transportation — Highways and Railtracks · Spain · 2025
Globalvia's 2025 Sustainability Report provides clear numeric evidence that there were no confirmed cases of corruption or bribery in 2025 (p.107). The report also details measures taken to prevent corruption and bribery, including processes to remediate negative impacts and channels for affected communities to raise concerns (p.107). However, while some supporting context on compliance policies is present (p.85), there is no comprehensive narrative or headline statement explicitly summarising anti-corruption efforts, and no quotable narrative item was found elsewhere in the report.
Hankook Tire & Technology
Tires · South Korea · 2025
Hankook Tire & Technology’s ESG Report 2024-25 provides numeric data on anti-corruption policies and training, with specific references to communication and confirmed incidents on pages 27-28 and 79. The report also includes figures related to employees and workforce characteristics on page 73, and details about the business model and stakeholder interests on pages 11-12, 16, and 31. However, there is no quotable narrative evidence found in the report for certain disclosure items, indicating gaps in descriptive or contextual information.
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Check your understanding
Scenarios to work through
During the year, an internal investigation confirms one bribery case involving a procurement manager and two separate supplier-side kickback cases. The HR file shows the manager was dismissed, one supplier contract was ended, and the other was allowed to run to term.
QHow should you decide what to count and describe for this disclosure, and what action details belong in the narrative?
Reveal model answer →Hide answer ↑Count the confirmed cases as three in total, because each substantiated incident is included. Describe the nature of each case in plain business terms, then separately record the employee dismissal and the contract termination. Do not add the supplier contract that simply expired unless it was not renewed because of the corruption issue.
Why this matters · Use confirmed findings as the basis for the count, and separate the type of incident from the response taken.
A whistleblowing review finds that a sales employee offered a payment to speed up a permit, but the allegation against a regional director is not substantiated. The employee is disciplined, and the permit application is withdrawn before any contract is signed.
QWhich events belong in the disclosure, and how should you avoid overstating the case?
Reveal model answer →Hide answer ↑Include only the substantiated employee case in the incident count and in the description of the nature of the incident. Record the discipline if it was a confirmed corruption case. Leave out the unproven allegation against the director and do not treat the withdrawn permit application as a contract termination, because no business partner agreement was ended or left unrenewed for this reason.
Why this matters · Only substantiated corruption matters go into the disclosure, and related business outcomes must match what actually happened.
The legal team reports that a public court case was filed against the company and one employee over alleged bribery. By year-end, the case is still open, with no judgment and no settlement, while a separate internal case has already been confirmed and led to dismissal.
QDo you include the open court case, and if so, what should you say about its outcome?
Reveal model answer →Hide answer ↑Yes, include the public case because it was brought during the reporting period. State that it is still ongoing and give the current status rather than a final result. Keep it separate from the confirmed internal case, which can be counted and linked to the dismissal action.
Why this matters · Public legal proceedings are reported for the period they arise in, even if they have not finished by year-end.
Two confirmed corruption incidents led to employee discipline, and one of those incidents also caused a distributor agreement to be ended early. A third confirmed incident involved a consultant, but the contract was not renewed for commercial reasons unrelated to the misconduct.
QHow do you avoid double counting and make sure the contract-related figure is accurate?
Reveal model answer →Hide answer ↑Count the two employee discipline outcomes once each under the employee-action figure. Count only the distributor agreement that was ended because of the corruption issue under the business-partner figure. Do not include the consultant contract, because the non-renewal was not due to the confirmed corruption matter.
Why this matters · Each count should match the specific outcome it measures, and the reason for ending or not renewing a contract must be corruption-related.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
What data do I need to collect for GRI 205-3 Anti-corruption before I start drafting the disclosure?+−
The page says to prepare five datapoints: confirmed corruption count, corruption incident types, disciplinary corruption cases, partner contract terminations, and corruption legal cases. Use those as your starting data list before you draft anything.
How should I set the scope and methodology for GRI 205-3 Anti-corruption in practice?+−
Use the page’s step-by-step preparation section to define what you are counting, where the data comes from, and how you will treat each datapoint consistently. The page is designed to help you turn that into a draft, so keep the method clear enough for review and assurance.
Who should own the GRI 205-3 Anti-corruption 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, check, and evidence the five datapoints. The workbook and evidence pack are there to help you coordinate that handover.
What evidence should I keep for GRI 205-3 Anti-corruption to make the disclosure assurance-ready?+−
The page includes an evidence pack with five items for assurance readiness, plus five assurance claims to verify using claim, risk, and evidence. Use those materials to build a file that shows how each datapoint was prepared and checked.
What are the five assurance claims on the GRI 205-3 Anti-corruption page and how do I use them?+−
The page says there are five assurance claims to verify, each framed around claim, risk, and evidence. Use them as a checklist to test whether your draft is supported by the underlying records before review.
What are the common reporting gaps or mistakes on the GRI 205-3 Anti-corruption page?+−
The page includes a section on common reporting gaps and mistakes so you can spot issues before finalising the disclosure. Use it as a pre-submission check against your draft, data table, and evidence pack.
How do I use the GRI 205-3 Anti-corruption workbook and printable Library Card?+−
The Download Centre provides a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf. Use the workbook to organise the data, checks, and evidence, and the Library Card as a quick reference while drafting.
Can I use the synthetic example on the GRI 205-3 Anti-corruption page as a template for my own disclosure?+−
Yes, but only as a synthetic illustration. The page includes example disclosures and a quantitative table to show how the data can be presented, so use it as a formatting guide rather than copying the numbers.
How do I turn the GRI 205-3 Anti-corruption data into a draft narrative and content index line?+−
The page has a draft-output section with visualisation ideas, narrative starters, and a GRI content-index line. Use those prompts to convert your verified datapoints into a short narrative and a clean index reference.
How can I use the GRI 205-3 Anti-corruption page for cross-framework reporting with ESRS G1 Business Conduct?+−
The page notes ESRS G1 as the closest correspondence, so you can reuse the same underlying data where relevant. Treat it as a practical cross-reference, not as a statement that the reporting requirements are identical.
More questions this page can help with
GRI 205-3 Anti-corruption: what counts as the confirmed corruption count for this page?GRI 205-3 Anti-corruption: how do I classify corruption incident types for reporting?GRI 205-3 Anti-corruption: what should I include in disciplinary corruption cases?GRI 205-3 Anti-corruption: when should partner contract terminations be counted?GRI 205-3 Anti-corruption: what qualifies as a corruption legal case in the workbook?GRI 205-3 Anti-corruption: how do I build an evidence pack from the five datapoints?GRI 205-3 Anti-corruption: what should I check before I send the draft for assurance review?GRI 205-3 Anti-corruption: how do I use the step-by-step preparation section to complete the disclosure?GRI 205-3 Anti-corruption: what does the synthetic example disclosure show me about formatting the table?GRI 205-3 Anti-corruption: what narrative starters are available on the page for the draft output?GRI 205-3 Anti-corruption: where do I find the printable Library Card and what is it for?GRI 205-3 Anti-corruption: how do I avoid the common reporting gaps listed on the page?
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