Disclosure focus
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.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG 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 GDR-P sub-elements (LRA working checklist)
Note any material changes made during the reporting period.
Summarise the main aims and contents of the policy.
State the policy’s title.
Link the policy to the relevant impact, risk or opportunity.
Set out what the policy covers and what it leaves out.
For social topics, explain how stakeholder views were taken into account.
List any external standards the policy refers to.
Confirm whether a human rights policy exists.
List the standards that are relevant to the policy.
Identify which stakeholder groups the policy applies to.
How to prepare it
1Start by listing every policy or commitment you need to report, then decide which one is being described in each entry. Keep the wording consistent with the actual document name so the label in the report matches the source material.
2For each policy, write down the main points it covers and the aim it is meant to achieve. Use plain business language so a reviewer can see what the policy is for and what it is intended to change.
3Identify the impact, risk or opportunity that the policy is meant to address, and link the policy to that issue in a clear way. If the policy is about human rights, also note which groups it applies to.
4Check whether the policy changed during the reporting period, and capture those changes in a short, factual note. If the policy refers to outside standards or other frameworks, record those references as part of the same entry.
5Define the boundary of the policy carefully: state what is included, what is left out, and why any exclusions apply. For social topics, also note whether stakeholder input was used when shaping the policy.
6Before finalising, compare your draft against the official source and confirm that each required item is present, accurate and complete. Make sure the final text reflects the source exactly in substance, even though the wording is in your own words.
Request the data
Request the policy register and supporting evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
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.
Weak request
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.
Why it fails: 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.
Better request
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.
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 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.
Context note
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.
Fluctuation statement
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.
Content index entry
GDR-P Policies Adopted to Manage Material Sustainability Matters — [location / page] / [notes]
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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
The request goes to a policy team or sustainability lead when the facts sit with the business owner who actually runs the process and can confirm the current wording.
Framework language first
People ask for answers in disclosure terms instead of the organisation’s own policy names, topic labels, and internal wording, so the source team cannot map the data cleanly.
No clear boundary
The team collects policy information without fixing which entities, sites, functions, or excluded parts are in scope, so the final set mixes covered and uncovered areas.
Wrong timing basis
The data pull uses the wrong reporting window or a later approval date, so the record does not match the period being reported.
Mixed counting basis
Different teams count policies, topics, or references using different rules, which makes the totals and lists impossible to compare or reconcile.
Source labels lost
The original file names, version tags, or document titles are stripped out during collection, so nobody can trace each answer back to the exact source used.
Populations merged
Separate groups that should stay distinct, such as different stakeholder sets or different policy types, are combined into one list and the detail is no longer usable.
Missing evidence trail
The collector saves the answer but not the supporting note, extract, or approval record, so there is no audit trail showing where the information came from.
No sign-off record
The draft data is passed on without a named reviewer and date, so there is no clear proof that the business owner checked it before it moved forward.
Where judgement is often needed
What counts as a policy when the same topic is covered in several documents
Choose a clear rule for whether you describe one umbrella policy or several linked documents, and explain the basis so readers can see how the named policy, its main aims and the related issue are connected.
How to handle policy wording that differs by country or business line
If local rules or operating practices lead to different wording in different places, state the versioning approach and explain which wording you have used for the report and why it best reflects the group-wide position.
Whether to include parts of the workforce or value chain that sit near the boundary
Set out the inclusion rule for people or activities that are close to the reporting boundary, then explain any exclusions so readers can see who is covered and who is not.
How to describe changes made during the period
If a policy was updated, merged, retired or replaced during the year, describe the nature of the change and the timing, and make clear whether the current wording or the earlier version is being presented.
How to treat acquisitions, disposals and other boundary shifts
When the group perimeter changes, explain whether the policy description follows the current structure or the prior one, and disclose any material additions or removals that affect the scope statement.
Whether a third-party code or framework is being adopted in full or only in part
If you refer to an external standard, say whether it is used as a full reference point or only for selected parts, and identify any material departures in plain language.
How to decide which stakeholder views are reflected for social topics
Explain which groups were considered, how their input was used, and where the policy reflects those views only in part, so the reader can see the practical basis for the social coverage.
How to present human-rights coverage across different groups
State which worker or community groups are covered by the human-rights policy and explain any gaps, especially where one policy applies to some groups but not others.
How to deal with estimates, rounding and privacy limits in the narrative
Where exact detail cannot be shown because of estimation, rounding or confidentiality, say so and explain the method used, keeping the description consistent with the underlying records and the level of aggregation chosen.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
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.
Illustrative (synthetic) example — Utilities
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.
How companies report GDR-P in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Sanoma Oyj
Education Services · Finland · 2025
Sanoma Oyj’s 2025 Annual Report includes a Human Rights Policy outlining sustainability-related principles and core commitments, as described on page 92. Additional supporting context about the policy’s scope, accountability, and stakeholder consideration is partially provided on page 118, though no specific headline values are given. However, several expected datapoints related to this disclosure are not found elsewhere in the report, indicating gaps in detailed reporting.
Amadeus IT Group, S.A.
Hotels, Restaurants, Leisure, Tourism Services · Spain · 2025
Amadeus IT Group’s 2025 Non-Financial Report includes a sustainability policy and a human rights policy described on page 115, indicating coverage of governance and policy frameworks related to human rights. The report also references measures to promote equal treatment and opportunities between women and men, though this disclosure is unclear and lacks detail (p.214). Several specific datapoints related to human rights incidents, complaints, and severe impacts, as well as other governance disclosures, are not found or not clearly addressed in the report.
Grifols, S.A.
Pharmaceuticals / Biotech / Life Sciences · Spain · 2024
Grifols, S.A.'s 2024 Integrated and Sustainability Annual Report provides partial coverage of its human rights policies, listing several relevant policies such as the Human Rights Policy and Risk Control and Management Policy on page 190. The report also references human rights due diligence processes initiated since 2022 to identify and manage risks across its value chain (p.136), and mentions human rights impacts and related strategy content on pages 153, 195-196, and 235. However, the report lacks clear, quotable disclosures for many specific datapoints, with several key elements not found or only unclearly addressed, such as detailed objectives, strategies, and headline values related to the disclosure (p.229 is unclear, and multiple datapoints have no evidence).
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Scenarios to work through
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.
QShould you add a plain explanation of the policy’s main aims, the material issue it addresses, what changed during the year, and any parts of the business or value chain that are outside its scope?
Reveal model answer →Hide answer ↑Yes. For this disclosure, the reader should be able to see the policy name, the main points it is meant to achieve, which material impact, risk or opportunity it relates to, whether it was changed during the period, and where it does not apply. If there are exclusions, they should be stated clearly rather than implied.
Why this matters · Give enough context for a user to understand what the policy covers, why it exists, and where it does not reach.
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.
QDo you need to spell out the groups covered by the policy and identify any outside framework it draws on?
Reveal model answer →Hide answer ↑Yes. Where the policy is about human rights, the report should make clear which people or groups are within its scope, and it should name any outside standard or framework that the policy relies on. The point is to show who the policy is meant to protect and what reference points shaped it.
Why this matters · For human rights topics, be explicit about the people covered and any external framework used as a reference.
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.
QHow should you handle the social policy so the report shows whether stakeholder views were taken into account?
Reveal model answer →Hide answer ↑You should identify, for the social topic, whether and how stakeholder views informed the policy. If a policy was shaped by engagement with affected groups, that should be made visible in the narrative rather than buried in general wording. The climate policy does not need the same treatment unless the same point is relevant there too.
Why this matters · When the topic is social, show whether stakeholder input influenced the policy.
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.
QCan a policy be presented without explaining its purpose, its link to the relevant material matter, and any external standard it references?
Reveal model answer →Hide answer ↑No. A bare title is not enough for this disclosure. The report should let the reader understand what the policy is called, what it is trying to do, which material matter it addresses, and whether it draws on any outside standard. If the policy is very short, the narrative still needs to explain those points in plain language.
Why this matters · A policy entry needs substance, not just a label.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
General Basis for Preparation of Sustainability Statements → Guide ✓Disclosures in Relation to Specific Circumstances → Guide ✓Actions and Resources in Relation to Material Sustainability Matters →Metrics in Relation to Material Sustainability Matters → Guide ✓Targets in Relation to Material Sustainability Matters → Guide ✓Role of the Administrative, Management and Supervisory Bodies → Guide ✓Show all 14 related disclosures →
FAQ
Questions this page answers
GDR-P (ESRS 2: General Disclosures) — what should I gather before drafting the disclosure?+−
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.
How do I use the step-by-step 'how to prepare' section for GDR-P?+−
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.
What data owner inputs do I need for the GDR-P policy disclosure?+−
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.
How do I define the scope and coverage limits for GDR-P without over-claiming?+−
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.
What evidence should go into the GDR-P assurance pack?+−
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.
Which GDR-P assurance claims should I verify before sign-off?+−
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.
What are the most common mistakes in GDR-P reporting?+−
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.
How do I turn the GDR-P data into a draft disclosure?+−
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.
Can I use the synthetic illustrative example disclosures to model my own GDR-P wording?+−
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.
Where do I find the GDR-P workbook and printable card, and how should I use them?+−
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.
How can the 'From company reports' table help with GDR-P drafting?+−
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.
More questions this page can help with
GDR-P ESRS 2 General Disclosures: what should be in the policy title, purpose and scope fields?How do I capture policy changes this year for GDR-P in a way an assurance reviewer can follow?What does 'linked impact topic' mean in the GDR-P disclosure page workflow?How should I record external standards used in the GDR-P policy disclosure?What social input considered evidence is useful for GDR-P?How do I flag whether a human rights policy exists in GDR-P?Which stakeholder groups should be listed in the GDR-P disclosure?What human rights standards cited information should I collect for GDR-P?How do I use the GDR-P evidence pack to prepare for assurance?What should I check in the GDR-P common gaps section before publishing?How do the GDR-P visualisation ideas and narrative starters help build a draft?Where can I find real company report examples for GDR-P topic disclosure?
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