ESRS 2: General Disclosures·Disclosure Requirement GDR-P
Policies Adopted to Manage Material Sustainability Matters
Guida pratica per preparare questa informativa. Usa questa scheda per individuare le informazioni da predisporre, verificare le affermazioni e organizzare le evidenze a supporto. Per i requisiti esatti, fai sempre riferimento alla fonte ufficiale European Commission.
Passaporto pubblicato
Revisione in attesaStandard
ESRS 2: General Disclosures
Disclosure Requirement GDR-P · 2026-5010-final
Ultima revisione
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Materiale didattico LRA · Non emesso né approvato da European Commission
Focus dell’informativa
This disclosure asks an organisation to explain the policies it has put in place to manage the sustainability matters it has identified as material. In practice, that means setting out the main policy commitments, what they are meant to achieve, and which material topics they cover, rather than just naming a policy document. The focus is on showing that the organisation has a clear policy basis for managing its material impacts, risks and opportunities.
The practical question is how far those policies apply and how they are used across the business. An organisation should make clear whether the policies cover the whole group, specific business units, regions or operations, and whether they apply consistently or only in certain areas. If coverage is limited, the organisation should explain the scope and any important exclusions so readers can understand the real extent of implementation.
Questo materiale didattico LRA supporta la preparazione dell’informativa. Per i requisiti esatti, fai sempre riferimento alla fonte ufficiale European Commission.
Prima di iniziare
Prima di iniziare
Una breve checklist prima di preparare questa informativa: spunta ogni voce man mano che la definisci.
Preparazione
Informazioni chiave da preparare
| Campo da preparare | Cosa rilevare | Suggerimento sull’evidenza | Responsabile |
|---|---|---|---|
| Policy title | Record the exact title used for the policy in the organisation’s current documents. | Approved policy register, intranet policy page, or signed policy document. | Policy owner / Legal / Compliance |
| Policy purpose and scope | Summarise the main aims and the core points the policy is meant to achieve or cover. | Policy text, board paper, or internal guidance note that sets out the policy’s purpose and main provisions. | Policy owner / Sustainability / Compliance |
| Linked impact topic | State the impact, risk or opportunity area that this policy is intended to address. | Policy rationale, risk register, or sustainability issue mapping that links the policy to the relevant topic. | Policy owner / Risk / Sustainability |
| Policy changes this year | Capture any changes made to the policy during the reporting period, including updates, rewrites, or removals. | Version history, tracked changes, approval papers, or change log for the period. | Policy owner / Legal / Compliance |
| Policy coverage limits | Describe which parts of the business, activities, locations, or entities the policy applies to, and any explicit exclusions. | Policy scope statement, applicability matrix, or group policy framework showing inclusions and exclusions. | Policy owner / Legal / Compliance |
| External standards used | List any outside standards, codes, or frameworks the policy says it relies on or follows. | Policy references section, annexes, or linked standards register. | Policy owner / Compliance / Technical owner |
| Social input considered | Capture how relevant stakeholder views were taken into account when setting policy on social matters. | Consultation notes, engagement summaries, employee or community feedback logs, and policy approval papers. | Sustainability / Social impact / Stakeholder engagement |
| Human rights policy flag | Confirm whether the organisation has a policy specifically covering human rights. | Policy inventory, approved policy list, or governance attestation showing yes/no status. | Legal / Compliance / Sustainability |
| Covered stakeholder groups | Identify which groups the human rights policy applies to or is intended to protect. | Policy text, scope statement, or stakeholder coverage matrix. | Policy owner / Human rights / Sustainability |
| Human rights standards cited | List the human rights-related standards, principles, or codes the policy refers to. | Policy references, annexes, or compliance library showing the cited standards. | Policy owner / Legal / Compliance |
Come prepararla
Richiedi i dati
Request the policy register and supporting evidence
Traduci l’informativa in una domanda di business interna, poi adattala al linguaggio della tua organizzazione.
Which current policies, scope notes and related references do we need to evidence how the organisation manages its material sustainability topics?
Use your organisation’s own policy, governance and issue-management terms first, then map them to the reporting fields. Keep the request in the language the policy owner, legal team or company secretariat already uses, rather than framework labels.
Richiesta debole
Please provide the ESRS 2:GDR-P policy disclosures, including the policy name, contents, related IRO, changes, scope, third-party standards, stakeholder consideration, and human rights policy details.
Perché non funziona: It uses framework language that many internal owners will not recognise, and it bundles several reporting labels without saying what practical evidence is needed. That makes it harder to answer quickly and increases the chance of incomplete or mismatched evidence.
Richiesta migliore
Please send the current policy documents and a short table showing: the policy title, what it is meant to cover, which sustainability topic or issue it supports, what changed during the period, where it applies and any exclusions, any external principles or codes named, and for people-related topics which stakeholder groups were considered. If there is a human rights policy, include the policy itself and the groups it covers. Use your own internal terms first, then we will map them to the reporting pack.
Modello di e-mail formale
Subject: Request for policy evidence for [reporting period] Dear [name/team], We are preparing the sustainability reporting pack and need your help to collect the current policy evidence for [reporting period]. Please share the latest versions and any supporting records for the policies you own or maintain, together with the details below. For each policy, please provide: - policy title and current version - short summary of what it covers and the main aims - which sustainability topic(s), issue(s) or commitment(s) it is linked to - any changes made during the period - the parts of the business, entities or activities it covers, and any exclusions - any external principles, codes or standards named in the policy - for people-related topics, any stakeholder groups considered when the policy was set or updated - approval or sign-off evidence, where available - source link or document reference Please use your own internal wording first, then we will map it to the reporting fields. If there are multiple policies, please send them in a simple table. A possible LRA training template is attached below. Please adapt this to your organisation and check the official source before sign-off. Kind regards, [preparer name] [team] [contact details]
Versione breve per Teams / Slack
Hi [name/team] — could you send the latest policy list and supporting evidence for [reporting period]? Please include the policy name, version, what it covers, any changes this year, scope/exclusions, linked sustainability topics, any external references named, and any approval record. Use your own internal terms first; we’ll map them later. A possible LRA training template is attached — please adapt to your organisation and check the official source before sign-off. Thanks, [name]
Esempi di settore
Manufacturing
Contesto. The business has site-level environmental procedures, a group code of conduct, and a supplier policy managed by Legal and Operations.
Richiesta adattata. Please share the current group policies and site procedures that set out how we manage our main sustainability topics, including the policy name, what each one covers, any changes this year, which plants or entities it applies to, any exclusions, and any external codes or standards named. For people-related topics, include any worker or community input used when the policy was updated.
Esempio di risposta. A table listing the Code of Conduct, Environmental Policy and Supplier Standards, with version numbers, approval dates, scope across all sites except one acquired plant, a note that the supplier policy was updated in Q3, and references to an external labour code and a responsible sourcing standard.
Financial services
Contesto. The business has conduct, lending, customer treatment and human rights policies owned by Legal, Risk and Compliance.
Richiesta adattata. Please provide the current policy set that explains how we manage our material sustainability topics, including the policy title, summary of coverage, any changes during the year, business lines or entities in scope, exclusions, and any external principles or codes referenced. If there is a human rights policy, include the groups it covers and any standards named in it.
Esempio di risposta. A table covering the Conduct Policy, Responsible Lending Policy and Human Rights Policy, with current versions, board approval dates, scope across retail and corporate banking, an exclusion for a discontinued product line, and references to an external human rights framework and a customer fairness code.
Redigi la tua informativa
Note che trasformano i dati in un’informativa
Modelli formativi LRA: adattali alla tua organizzazione e verifica la fonte ufficiale prima dell’approvazione.
Nota metodologica
State how the policy information was compiled, including how each policy was named, how its purpose and related issue were identified, what counted as a change in the period, how scope limits and exclusions were treated, and which outside standards were noted.
Nota di contesto
Explain what the policy set shows about how the organisation manages its material impacts, risks and opportunities, including whether it has a formal human rights policy, which groups it considers, and whether it relies on external standards to shape its approach.
Dichiarazione sulle variazioni
If the policy set changed during the period, explain whether that was due to new issues, revised priorities, updated external references, or a broader change in coverage, and note any shifts in the groups or topics the organisation now addresses.
Voce dell’indice dei contenuti
GDR-P Policies Adopted to Manage Material Sustainability Matters — [location / page] / [notes]Centro download
Strumenti e moduli per la preparazione
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Preparazione all’assurance
Per ogni affermazione, verifica le evidenze
| Affermazione | Rischio | Evidenze da verificare |
|---|---|---|
| We prepared the coverage figure using the same basis across the period and checked that the policy summary matches the version approved for reporting. | The assurer may find the figure or summary was built on an inconsistent basis, or that the reported wording does not match the approved policy document. | Approved policy register; version history; reporting pack showing the basis used; sign-off records linking the published wording to the approved source. |
| We included the main policy points for the human rights policy and kept the description aligned to the current approved text. | The assurer may probe whether the human rights policy was described fully and accurately, or whether key elements were omitted or outdated. | Current human rights policy; board or management approval evidence; cross-reference table from policy clauses to the published disclosure; review notes confirming completeness. |
| We mapped each policy statement to the relevant business areas before publication so the disclosed coverage reflects the intended scope. | The assurer may question whether the disclosure overstates or understates what the policy actually covers. | Scope mapping or coverage matrix; policy inventory; internal review comments; evidence of sign-off by the policy owner and reporting team. |
| Where a policy changed during the year, we updated the disclosure to reflect the revised position and retained evidence of what changed. | The assurer may test whether changes were missed, misdated, or described in a way that does not match the actual revision history. | Change log; tracked revisions; approval dates; comparison between prior and current versions; meeting minutes or email approvals for the update. |
| We checked the stated scope and any exclusions against the underlying policy wording, including the parts of the business and locations it is meant to cover. | The assurer may challenge whether exclusions were described too broadly or too narrowly, or whether the geography and operational coverage are unsupported. | Policy scope section; exclusion list; entity and location mapping; legal entity or operational boundary schedule; internal review sign-off. |
| We reviewed whether the policy applies to relevant stakeholder groups and used the same group definitions consistently in the disclosure. | The assurer may ask whether affected groups were left out, grouped too loosely, or described in a way that is not supported by the policy. | Stakeholder mapping; policy wording on covered groups; consultation notes; internal consistency check between stakeholder register and disclosure text. |
Pacchetto di evidenze da preparare
Lacune ricorrenti nella rendicontazione
Lacune ricorrenti
Errori da evitare nella raccolta dei dati
Dove serve spesso un giudizio professionale
Esempi
Esempi illustrativi
Sintetici, scritti da LRA: non provengono dal report di un’azienda né dal testo di uno standard.
We set out our policy on responsible sourcing and worker treatment, which aims to reduce labour-rights and supply-chain harm linked to our operations and key suppliers. During the period, we tightened supplier screening, widened the policy to cover two additional raw-material categories, and kept the same exclusions for minor office services and short-term contractors; we also note that our approach draws on recognised external frameworks and that we considered employee and community views when shaping the parts touching social issues.
- The policy applies across our owned sites and tier-1 suppliers, with the exclusions above.
- It refers to the recognised human-rights due-diligence expectations and the recognised responsible-business guidance.
- We also maintain a separate human-rights policy covering employees, agency workers, direct suppliers, and local communities, with the same external references.
This example shows how a reporter can describe the policy in plain language, identify the main issue it is meant to address, note what changed in the year, explain where it applies and what is left out, and name the outside frameworks used. It also shows a separate human-rights policy and the groups it covers.
Our climate-transition and community-impact policy explains how we manage transition-related disruption, local engagement, and fair treatment in project delivery. In the year, we added a requirement for contractor grievance logging, narrowed one legacy exemption for emergency works, and kept the policy focused on our generation assets, grid projects, and major contractors rather than small administrative services; the policy also cites external frameworks and reflects feedback from residents and workforce representatives on the social side.
- The policy covers our generation assets, grid projects, and major contractors, but not small administrative services.
- It draws on the ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy and the recognised human-rights due-diligence expectations.
- We have a separate human-rights policy for employees, contractors, affected communities, and customers, with those same references.
This example demonstrates a different sector using the same disclosure points in a distinct way. It shows how to describe the policy’s purpose, the issue it relates to, changes made during the period, the boundaries and exclusions, the external references, and the stakeholder input used for social matters.
Report aziendali
Come le aziende rendicontano GDR-P nella pratica
Esempi di prassi di rendicontazione completa e parziale. Sono analisi basate sulle evidenze, non modelli da copiare.
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Scenari da affrontare
A group policy on labour and community impacts was updated mid-year after a supplier audit found gaps in grievance handling. The draft report mentions the revised policy title and says it applies to direct operations, but it does not explain what changed or whether any sites were left out.
The sustainability team has a human rights policy that covers employees, agency workers and contractors, and it also refers to a supplier code based on an external labour standard. The draft report lists the policy and the external standard, but it does not say which stakeholder groups are covered or how the outside framework is being used.
A company has one policy for climate transition and another for community relations. The climate policy was unchanged this year, but the community policy was rewritten after stakeholder feedback. The draft report describes both policies in the same way and does not distinguish which one was shaped by stakeholder views.
A preparer is compiling the policy section and has a list of internal policies, but one of them is only a short statement with no objectives, no link to a material issue, and no mention of any outside standard. Another policy is a fuller document that includes all of those points. The team is unsure whether the short statement can be listed on its own.
Riferimenti al framework
Requisiti ESRS pertinenti e informative correlate
Riferimenti disponibili al framework e informative vicine utili alla preparazione di questo requisito.
ESRS
GDR-P
all’interno di ESRS 2: General Disclosures
Correlati ed esplora
Altro in ESRS 2 → Sfoglia il catalogo completo → Home della Biblioteca delle informative → Cerca in tutte le informative →
FAQ
Domande a cui risponde questa pagina
Start with the page’s datapoints to prepare: policy title, purpose and scope, linked impact topic, policy changes this year, coverage limits, external standards used, social input considered, human rights policy flag, covered stakeholder groups, and human rights standards cited. The page also gives a step-by-step preparation flow, so you can turn those inputs into a first draft rather than starting from a blank page.
Use it as a working checklist to move from scoping to drafting: identify the policy, confirm what it covers and excludes, gather supporting inputs, and then write the disclosure. The page is designed to help a practitioner prepare the disclosure in a structured way, not just describe it.
The page points you to policy-level inputs such as title, purpose, scope, changes this year, coverage limits, and the stakeholder and human rights information used to shape the policy. That makes it useful for assigning specific data owners to each field before drafting.
Use the page’s scope-related datapoints to state what the policy covers and where it stops, including any coverage limits. The common gaps section is there to help you avoid vague wording or implying broader coverage than your evidence supports.
The page includes an evidence pack with five items for assurance readiness, so you can assemble support for the policy details, the inputs used, and the draft disclosure. It is meant to help you build a reviewer-friendly file rather than rely on narrative alone.
The page lists six assurance claims to check, each framed around a claim, the related risk, and the evidence needed. Use those claims to test whether the disclosure is supported, complete, and consistent before it goes to review.
The page has a common reporting gaps and mistakes section that you can use as a pre-submission check. It is intended to help you spot missing scope detail, weak evidence, or other avoidable drafting issues before the disclosure is finalised.
Use the draft-output section to move from collected data to a usable draft, including narrative starters, a content-index line, and visualisation ideas. The page also includes synthetic illustrative examples, which can help you see how the data points fit together in practice.
Yes, but only as a pattern for structure and completeness, not as a template to copy. The examples are explicitly synthetic and the quantitative table is there to show how the data can be presented consistently.
The Download Centre provides a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise the preparation and evidence checks, and the card as a quick reference while drafting or reviewing.
It links to real published reports at the pages where the topic is disclosed, so you can see how companies have presented similar information in practice. It is a reference aid for drafting and review, not a statement of required wording.
Altre domande in cui questa pagina può aiutare
Approfondisci · GDR-P
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