GRI 403: Occupational Health and Safety 2018 · Topic Standard · Cross-sectoral
Disclosure GRI 403-3
Occupational health services
Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.
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Reviewed by
Dr Ross Kurinko · GRI Certified Trainer
To prepare this disclosure
2 datapoints ↓
5 claims to verify ↓
5 evidence areas ↓
3 report examples ↓
Disclosure focus
This disclosure asks an organisation to explain how it provides occupational health services for workers and how far those services reach across the business. In practice, the report should make clear whether health support is available only at certain sites or is arranged more broadly across operations, and what form that support takes.
The practical focus is on coverage and access, not just the existence of a service. A useful explanation would show which parts of the workforce can use the service, whether arrangements differ by location or type of operation, and any important gaps or limitations in provision.
* 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
| Datapoint | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Occupational health role | Describe what the occupational health service does for employees and for non-employee workers whose work or workplace the organisation controls, focusing on how it helps spot hazards and reduce risk. | Service scope or terms of reference, provider contract, health and safety procedures, and any internal description of service activities. | Health and Safety |
| Service quality and access | Explain the steps used to keep these health services fit for purpose and how workers are able to use them in practice. | Service quality checks, provider review records, worker access instructions, referral routes, booking arrangements, and communication materials. | Health and Safety |
Show GRI 403-3 sub-elements (LRA working checklist)
- Set out how the organisation keeps these services reliable and makes it easy for workers to use them.
- For employees and other workers whose job or workplace the organisation controls, describe how occupational health services help spot and remove hazards and reduce risk.
LRA working checklist - paraphrased; see official source
How to prepare
- Set the reporting boundary first: decide which people groups are in scope, covering employees and any non-employees whose job or work location is under the organisation’s control.
- Define the service content in plain terms: describe what the occupational health function actually does to spot hazards and reduce or remove risks for those in scope.
- Gather support for the description: collect internal records, procedures, service descriptions, contracts, or other evidence that shows the service exists and what it covers.
- Prepare the quality-and-access explanation: set out how the organisation checks the service is fit for purpose and how workers can use it in practice.
- Record any exclusions or changes clearly: note where the scope, service model, or access arrangements differ from prior reporting periods, and explain the reason for the change.
- Check the draft against the source material before publishing: confirm the wording matches the underlying requirement, the evidence supports each statement, and nothing material has been left out or added.
Request the occupational health service evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How do our workplace health services help spot and reduce work-related hazards and risks, and how do we make sure people can use them and that the service is fit for purpose?
Use your organisation’s own terms first, then map them to this disclosure. For example, you may talk about workplace health, medical support, clinic provision, or employee wellbeing services rather than using framework language. Keep the request aligned to how your teams actually describe the service, the people covered, and the controls around access and quality.
Weak request
Please provide the GRI 403-3 evidence for occupational health services.
Why it fails: This uses framework wording only, so the owner may not recognise what to pull together. It does not say which internal service, which people, which sites, or what kind of records are needed, so the response is likely to be incomplete or inconsistent.
Better request
Please send the evidence for our workplace health / medical support service for [reporting period] covering [sites/business units]. I need a plain-language description of what the service does to help spot and reduce workplace hazards and risks for [people covered], plus how we check the service is working well and how workers can use it. Include the source record, owner, and any site-specific differences.
Formal email template
Subject: Request for workplace health service evidence for [reporting period]\n\nHi [name/team],\n\nI’m pulling together the sustainability reporting pack for [reporting period] and need your help with the evidence for our workplace health service. Please share the information below for [boundary / sites / business units].\n\nCould you provide:\n- A short description of what the service does to help identify and reduce workplace hazards and risks for [people covered]\n- An explanation of how we check the service is working well and how we keep it up to standard\n- An explanation of how workers can access the service, including any routes, eligibility rules, booking steps, or site-specific arrangements\n- Any supporting documents or links that show the current process, provider oversight, or service controls\n\nPlease include the period covered, the source of the information, and the owner of the record. If there are different arrangements by site or business unit, please separate them clearly.\n\nPlease adapt this to your organisation’s own language and check the source material before sign-off.\n\nThanks,\n[preparer name]
Short Teams / Slack version
Hi [name/team] — could you send over the workplace health / medical support evidence for [reporting period] for [sites/business units]? I need: what the service does to spot and reduce workplace risks, how we check service quality, and how people access it. Please include the source record and any site differences. Please adapt this to your organisation’s own language and check the source material before sign-off. Thanks, [preparer name]
Industry examples
Manufacturing
Context. A plant uses an on-site nurse, an external occupational physician, and a contractor health screening provider.
Adapted request. Please provide the evidence for the plant health service for [reporting period] covering [site name]. I need a short description of how the service supports hazard spotting and risk reduction for employees and contractors working under our control, how provider quality is checked, and how workers book or access support.
Example response. The site health service includes pre-placement checks, return-to-work reviews, and referral support for noise, manual handling, and exposure concerns. Quality is reviewed through quarterly provider meetings, KPI tracking, and annual contract review. Workers can access the service by self-referral, supervisor referral, or booking through the site portal.
Corporate offices / professional services
Context. An office-based organisation uses an external employee health provider and a central wellbeing portal.
Adapted request. Please provide the evidence for the workplace health support service for [reporting period] covering office staff and other workers at controlled office locations. I need a plain description of what the service does, how we check provider quality, and how people access it through the portal or referral routes.
Example response. The service offers health advice, ergonomic referrals, and support for stress-related concerns. Quality is monitored through service reviews, response-time reporting, and contract oversight. Access is via the wellbeing portal, manager referral, or direct booking with the provider.
The full request pack — response form, data table, evidence metadata and sign-off — is in the Download Centre.
Draft your disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
This disclosure is based on the organisation’s own description of the occupational health support it provides to employees and to other workers under its control, including how those services help spot and reduce workplace risks and how service quality and access are managed.
Context note
The figures and descriptions show how the organisation uses occupational health support as part of its wider approach to keeping people safe and reducing harm at work, rather than as a standalone medical benefit.
Fluctuation statement
If the service model, coverage or access arrangements changed during the period, the reporter can explain whether that reflects a new provider setup, a change in site coverage, or a revised way of reaching workers.
Content index entry
GRI 403-3 Occupational health services — [location / page] / [notes]
Download Centre
Professional preparation tools and forms for GRI 403-3. Each download includes a concise “How to use” guide.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| I prepared the coverage figure using the organisation’s own records and a clearly defined population, so the disclosed number reflects the intended group and period. | The assurer may find the population, time period, or inclusion rules were changed late, applied inconsistently, or not documented, which would make the figure unreliable. | Population definition note; reporting boundary memo; source extracts used to build the figure; version history showing any scope changes; reconciliation between source totals and the published number. |
| I separated the disclosed operations into the relevant groups before calculating the figure, and I kept a record of the inclusion and exclusion decisions we made. | The assurer may question whether some sites, teams, contractors, or locations were left out without a consistent basis, or whether the same rule was not applied across the full set. | Inclusion/exclusion log; site or entity list used for the calculation; decision papers for borderline cases; mapping of each source record to the final population; sign-off on the final scope. |
| I checked the underlying data for completeness and obvious errors before publication, and I resolved any gaps or anomalies before the figure was finalised. | The assurer may identify missing records, duplicate entries, broken links between systems, or unexplained adjustments that could affect the published result. | Data validation checks; exception reports; query log and responses; duplicate or missing-record review; final data extract with control totals; evidence of corrections made before sign-off. |
| I kept evidence showing how the figure was built, including the source files, working papers, and the review trail that supports the final number. | The assurer may find that the calculation cannot be traced from source data to the published figure, or that key support is missing, unsigned, or not retained. | Calculation workbook or system output; source documents; audit trail or change log; reviewer comments and approvals; retention record for the supporting pack. |
| Before release, I had the draft checked by the relevant owners and I confirmed that the wording matched the underlying records and the agreed method. | The assurer may see that the final text was not reviewed against the evidence, that the method was not approved, or that the published wording overstates what the records support. | Pre-publication review checklist; approval emails or workflow sign-off; draft-to-final comparison; method note; evidence that the published wording was checked against the source pack. |
Evidence pack to prepare
- The governing policy or written commitment behind this disclosure
- A methodology / definition note setting out how the disclosure was scoped and prepared
- Source-system exports the figures or facts were drawn from
- The internal approval / sign-off record for the disclosure before publication
- Minutes or records evidencing the relevant engagement or consultation
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.
Mistakes to avoid when collecting the data
- Wrong owner
Chasing HR alone misses the people who run workplace health support, so the data request lands with someone who cannot describe the service in operational terms.
- Framework language only
Asking for the answer in disclosure wording instead of the organisation’s own service names makes teams search the wrong records and return vague text.
- Scope left vague
Not pinning down which employees and which other workers under the organisation’s control are in scope leads to an incomplete or over-broad data pull.
- Wrong time basis
Pulling figures or descriptions from a different reporting period, or from a later service setup, gives a picture that does not match the period being reported.
- Mixed counting basis
Combining headcount, visits, referrals, and service locations in one request without separating the basis of each measure produces data that cannot be checked back cleanly.
- Source labels lost
Copying information out of local logs or provider reports without keeping the original field names, codes, or document titles makes it hard to trace where each fact came from.
- Populations merged
Putting employees and other controlled workers into one undivided dataset hides whether access and service coverage differ between the two groups.
- Evidence trail missing
Collecting the narrative but not the supporting notes, file dates, and approver names leaves no clear path to show how the answer was assembled and checked.
Where judgement is often needed
- Acquisitions and disposals during the year
Decide whether to include a site or workforce only from the date control starts or until control ends, and explain the cut-off used so the service description matches the period actually under your control.
- Different country meanings for the same service
Where local practice uses different labels or scopes for workplace health support, map them to one internal definition and disclose that mapping so readers can see what sits behind the reported service description.
- People on the boundary of your controlled workforce
Set out whether you include agency staff, contractors, or other non-employees only when their work or workplace is under your control, and explain any exclusions where control is not clear.
- Choosing the population basis
State whether the description covers the whole workforce in scope or only the parts where health support is actually arranged, and explain the basis so users can understand any gaps.
- Timing of the description
If the service model changed during the year, choose whether to describe the year-end setup, the average position, or the main arrangement in place for most of the period, and explain that timing choice.
- Measured information versus management estimate
When direct records are incomplete, use a clearly identified estimate only if it is the best available basis, and say where figures are counted, inferred, or rounded so the reader can judge reliability.
- Combining sites to protect privacy
If headcount or service-use detail is too small to show safely at site level, group locations or teams before reporting and explain the aggregation rule so individuals cannot be identified.
- Rounding and small-number effects
Apply one rounding approach consistently across the disclosure, and note where rounding changes the apparent total or hides a very small number so the presentation is not misleading.
- Shared services across several entities
If one health service supports more than one legal entity or business unit, explain how you split or allocated the coverage so the reported description reflects the part under your reporting boundary.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Manufacturing · synthetic · written by LRA
Illustrative only: this example shows how to describe the service’s practical role in finding and reducing health risks, and how quality and access arrangements can be explained for both employees and controlled-site non-employees.
We run an occupational health service for both our employees and contractor staff working on our sites, and it focuses on spotting workplace health risks early and helping remove or reduce them.
- The service carries out pre-placement and periodic health checks, reviews exposure patterns, supports return-to-work planning, and feeds findings into site risk reviews and corrective actions.
- We keep the service quality high through clinician qualifications, service-level checks, case review meetings, and periodic audits, and we make access straightforward through on-site clinics, booked appointments, a confidential referral route, and information shared in induction and shift briefings.
- Synthetic illustration only: in the year, 420 employees and 180 contractor workers were covered; 510 used the service at least once, and 96% of those users said access was easy.
Logistics · synthetic · written by LRA
Illustrative only: this example shows a different sectoral context while still covering the service’s hazard-finding role and the arrangements used to keep the service reliable and easy to reach.
Our health support team serves employees and agency drivers working under our control, with a practical remit of identifying likely work-related harm, advising on controls, and helping cut exposure before it becomes an incident.
- Its work includes health surveillance for noise and manual-handling exposure, fitness-for-task checks, advice on workstation and route planning, and follow-up on trends so that hazards are removed or reduced where possible.
- We assure service quality through named clinical oversight, documented procedures, response-time monitoring, and annual review of provider performance, while access is supported by mobile clinics, a confidential phone line, translated guidance, and manager training so workers know how to use it.
- Synthetic illustration only: 260 employees and 140 agency drivers were covered; 330 workers accessed the service during the year, and 94% of users were able to reach it without delay.
Draft output & visualisation ideas
How to turn the collected data into a draft disclosure. Suggested visuals and a GRI content-index line generated from this disclosure's datapoints.
Suggested visuals
- Occupational health service roles — table: A simple matrix of the service activities in place and the specific hazard-spotting or risk-reduction purpose each one serves for staff and other covered workers.
- Access routes to support — bar: A comparison of the main ways workers can reach occupational health support, such as on-site, referral-based or remote access, to show how availability is organised.
- Quality assurance checks — stacked bar: A breakdown of the steps used to keep the service reliable, for example review, oversight and follow-up, showing how quality is maintained across the service.
- Worker groups covered — donut: The share of occupational health support aimed at employees versus other workers whose place or work is under the organisation’s control.
- Service coverage by location — map: Where occupational health support is available across sites or operating areas, highlighting any differences in access by place.
From a number to a disclosure
What separates a figure from a disclosure.
Basic
We use workplace health support for staff and other controlled-site workers to spot and reduce hazards.
Better
We use workplace health support for staff and other controlled-site workers to spot and reduce hazards, and we keep service quality and access under review through set checks and referral routes.
Best
We used workplace health support for staff and other controlled-site workers across all sites this year to spot and reduce hazards; we checked quality through scheduled reviews and worker feedback, and we improved access by extending clinic hours, which increased use after a shift-pattern change.
Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 403-3 — these are report practice, not exact disclosure examples.
| Company | Sector · Country | Year | Match | Page | Report | Assurance | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
 |
Oberoi Realty Limited | Real Estate · India | 2025 | Partial | p. 107 →p. 109 →p. 128 → | ESG Report FY 2024-25 → | EY | |||||||||
Evidence in Oberoi Realty Limited’s reportWhat the report shows Oberoi Realty Limited’s ESG Report FY 2024-25 provides coverage on occupational health and safety, including references to hazard identification and risk assessment on page 128. The report also details that 25,000 workers were enabled to access benefits under at least one Building and Other Construction Workers (BoCW) scheme, as noted on page 114. However, the report does not clearly specify comprehensive data on occupational health services or detailed outcomes of these initiatives, leaving some aspects of worker health and safety measures unclear.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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SCB X Public Company Limited | Banks / Diverse Financials / Insurance · Thailand | 2024 | Exact | p. 121 →p. 122 →p. 129 → | 2024 Sustainability Report → | EY | |||||||||
Evidence in SCB X Public Company Limited’s reportWhat the report shows SCB X Public Company Limited’s 2024 Sustainability Report provides detailed coverage of occupational health and safety, including references to occupational health services, worker training, and promotion of worker health on pages 129 and 97. The report also highlights support provided to over 1.3 million individuals and 30,000 enterprises, indicating a broad social impact (p.53). However, the report does not clearly address issues related to illegal labor or employee freedom of association, and the extent of non-employee workers is noted but not elaborated upon (p.102, p.125).
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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Nan Pao Resins Chemical Co., Ltd. | Chemicals · Taiwan | 2024 | Exact | p. 128 →p. 116 →p. 26 → | NANPAO Sustainability Report 2024 → | Ernst & Young; BSI; EY; KPMG | |||||||||
Evidence in Nan Pao Resins Chemical Co., Ltd.’s reportWhat the report shows Nan Pao Resins Chemical Co., Ltd.'s 2024 sustainability report provides coverage on occupational health and safety, including promotion of worker health and work-related injuries, with specific references on page 128 and related data on pages 109, 114, and 115. The report also addresses employee engagement and benefits, noting efforts to ensure employee views are heard and flexible compensation is provided (p.105). However, detailed quantitative data or comprehensive metrics on training or injury rates are not clearly presented, and the extent of coverage on emergency response and cybersecurity training is mentioned but not elaborated with specific figures (p.19, p.46).
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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Check your understanding
A manufacturing site uses an in-house nurse clinic for employees and a contractor health provider for agency staff working under the site’s control. The draft note says the clinic offers first aid and return-to-work support, but it does not explain how those services help spot workplace hazards or reduce exposure.What should the preparer check before finalising the disclosure?
Model answer. They should make sure the description covers what the health service does for both employees and non-employees whose work or workplace is controlled by the organisation, and that it links those activities to finding hazards and cutting risk. A note that only lists clinic activities is not enough if it does not show that connection.
Why this matters. Describe the service’s role in hazard spotting and risk reduction, not just the fact that a clinic exists.
A logistics business outsources its occupational health support to a third-party provider. The provider is available by phone and at a nearby clinic, but the draft disclosure only says the service exists and does not explain how workers can actually use it.What decision does the preparer need to make about the access part of the disclosure?
Model answer. They should add a plain explanation of how workers are able to reach the service in practice, such as the channels, locations, or arrangements that make use possible. The point is to show access, not merely to name the provider.
Why this matters. Show the practical route to the service, not just that a provider has been appointed.
A construction group has a shared occupational health arrangement for site employees and subcontracted workers on controlled sites. The draft says the service is “high quality” because it is run by qualified staff, but it gives no detail on how the organisation checks service quality or keeps standards consistent.What should the preparer look for before accepting that the quality explanation is adequate?
Model answer. They should confirm there is a clear explanation of the checks, oversight, or controls used to keep the service dependable and fit for purpose. A bare claim of quality, without showing how quality is maintained, is too thin for the disclosure.
Why this matters. Quality needs an explanation of the controls behind it, not a label.
A food-processing company has occupational health support for employees, but agency workers on the same controlled production line are told to use their own GP. The draft disclosure mentions only the employee clinic and omits the agency workers entirely.How should the preparer judge whether the disclosure is complete?
Model answer. They should include the workers who are not employees but whose work or workplace is controlled by the organisation, if the service covers them or if access is arranged for them. Leaving that group out would miss part of the population covered by the disclosure.
Why this matters. Cover all workers in scope, including non-employees working under the organisation’s control.
Analyse this disclosure across real reports
See how companies actually report GRI 403-3 — drawn from their own published reports, with the exact pages, and an LRA AI-assistant that works through it with you. Available to LRA Community members and to students throughout their platform access.
Related framework references
How this disclosure maps across the major reporting frameworks.
→
ESRSRelated
ESRS S1
Own Workforce — closest topical match (post-Omnibus ESRS catalogue).
→
IFRSNo equivalent
—
No direct IFRS S1/S2 topical equivalent.
Related & explore
Occupational health and safety management… Guide ✓Work-related ill health Guide ✓Hazard identification, risk assessment, a… Guide ✓Worker participation, consultation, and c… Guide ✓Worker training on occupational health an… Guide ✓Promotion of worker health Guide ✓Prevention and mitigation of occupational… Guide ✓Workers covered by an occupational health… Guide ✓Work-related injuries Guide ✓
Questions this page answers
For GRI 403-3, what data do I need to prepare before I start drafting the disclosure?
The page says to prepare two datapoints: the occupational health role and service quality and access. Use those as your starting fields before you build the narrative or table. ↑ section
How should I scope GRI 403-3 so the disclosure is usable for assurance later?
Use the page’s step-by-step preparation section to define the scope early, then keep the same scope through data collection, evidence gathering and drafting. That makes it easier to show how the figures and narrative were built. ↑ section
Who should own the GRI 403-3 data collection in practice?
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the person or team that can explain the occupational health role and service quality and access data. The key is to assign a clear owner before you start the workbook and evidence pack. ↑ section
What evidence pack do I need to make GRI 403-3 assurance-ready?
The page includes an evidence pack with five items for assurance readiness. Use that pack to support the claim, the risk, and the evidence you will show to a reviewer. ↑ section
What are the five assurance claims I should check for GRI 403-3?
The page says there are five assurance claims to verify, each with a claim, risk and evidence. Use those checks to test whether your draft is supported and whether anything is missing before sign-off. ↑ section
What are the common mistakes people make when reporting GRI 403-3?
The page lists common reporting gaps and mistakes, so it is designed to help you spot weak scope, missing evidence or unclear drafting. Review that section before you finalise the disclosure. ↑ section
How do I use the Prep & Assurance workbook for GRI 403-3?
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to work through preparation, evidence and assurance checks in one place before you draft the disclosure. ↑ section
What can I use the printable Library Card PDF for on GRI 403-3?
The Download Centre also includes a printable Library Card in PDF format. It is a practical companion for keeping the disclosure notes, evidence prompts and draft points together while you work. ↑ section
Is there an example of a GRI 403-3 disclosure I can copy into my draft?
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table where relevant. Treat them as examples of how to present the information, not as a template to copy without checking your own data. ↑ section
How do I turn my GRI 403-3 data into a draft disclosure and content index line?
The page has a draft-output section with visualisation ideas, narrative starters and a GRI content-index line. Use those to turn your prepared data into a first draft and then check it against your evidence pack. ↑ section
Can I reuse my GRI 403-3 data for ESRS S1 (Own Workforce)?
The page says ESRS S1 (Own Workforce) is the closest correspondence, so the data may be reusable across both. Do not assume the reporting needs are identical; use the page to align the underlying data and then check the other framework separately. ↑ section
More questions this page can help with
- GRI 403-3 occupational health and safety disclosure: what should I collect first?
- GRI 403-3 how to define the occupational health role for reporting
- GRI 403-3 service quality and access data: what counts as usable evidence?
- GRI 403-3 assurance evidence pack checklist
- GRI 403-3 claim risk evidence review questions
- GRI 403-3 common reporting mistakes and gaps
- GRI 403-3 workbook download how to use it
- GRI 403-3 printable library card PDF download
- GRI 403-3 synthetic example disclosure table
- GRI 403-3 draft narrative starters and content index line
- GRI 403-3 who should own the disclosure data
- GRI 403-3 ESRS S1 own workforce data reuse
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Sources, status and disclaimer
This LRA assistance tool is designed for educational and internal data-collection purposes. It is not an official interpretation of the GRI Standards, IFRS Sustainability Disclosure Standards or EU CSRD/ESRS requirements. When applying these frameworks in professional practice, users should consult and double-check the official standards, guidance and applicable regulatory sources.
