Disclosure focus
This disclosure asks an organisation to explain whether it has policies that set out how it manages impacts, risks and opportunities affecting its own workforce. In practice, the report should make clear what policy coverage exists, what topics it covers, and whether those policies apply across the whole workforce or only to certain groups, locations or business units.
The practical focus is on completeness and consistency: readers should be able to see if the organisation has a joined-up approach for employees and other workers in its own operations, rather than a policy that exists only on paper or only at flagship sites. It is also useful to show where policies differ by geography, contract type or role, and how the organisation ensures they are actually applied in day-to-day management.
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 S1-1 sub-elements (LRA working checklist)
State whether child labour is present or not.
State whether forced labour is present or not.
State whether trafficking is present or not.
Set out the aims of the policy.
Give the policy’s title.
Specify whether it applies to employees, non-employees, or both.
Identify which workforce groups are included.
How to prepare it
1Start by identifying the policy you will report on and give it the exact internal name used in your records. Make sure you are clear whether it applies to employees, non-employees, or both, and note which parts of the workforce it is meant to cover.
2Set out the policy’s purpose in plain business language. Keep the focus on what the policy is intended to achieve, and make sure the stated aim matches the version approved or used by the business.
3Check the three labour-risk topics separately and record a simple yes or no for each one: forced labour, child labour, and trafficking. Use the same basis for each check so the answers are comparable and easy to trace.
4Gather the source material that supports each entry before you draft the disclosure. That should include the policy text, the scope statement, and any internal records that show which workforce groups are included in the coverage.
5Assemble the final disclosure so the policy name, coverage, workforce segments, and objectives all line up with one another. If the policy applies only to certain groups, make that clear in the wording rather than leaving the reader to infer it.
6Before filing, compare your draft against the official source and your internal records to confirm nothing has been missed or overstated. If you have excluded any group or changed the wording from the source documents, document that clearly so the basis of the disclosure is transparent.
Request the data
Request the workforce policy details
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which people policy applies to our workforce, and what does it cover?
Use your organisation’s own policy names and people-team language first, then map them to the disclosure fields. Do not ask for the framework labels in the first instance; ask for the internal policy record, the groups it covers, and the stated aims. Check the source material before sign-off.
Weak request
Please provide the ESRS S1:S1-1 policy disclosures for own workforce, including the policy name, scope, workforce segments, objectives, and whether it covers forced labour, child labour, and trafficking.
Why it fails: This uses framework language first, which can slow down the response and create translation errors. It also does not point the owner to the internal policy record, the usual document name, or the business groups they actually manage.
Better request
Please send the current people policy record for our workforce: the policy title and version, who it applies to, which worker groups and business areas it covers, its main aims, and whether it addresses forced labour, child labour, and trafficking. Include the document location and review date. We will map your internal terms to the reporting fields afterwards.
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
We based this draft on the organisation’s named policy, the worker groups it is meant to cover, the workforce segments included, and the stated aims, using the collected yes/no flags for the three labour-related risk topics.
Context note
These figures show the organisation’s formal coverage of labour-related risks and which parts of the workforce the policy is intended to reach, rather than evidence of incidents or outcomes.
Fluctuation statement
If the coverage or stated aims changed from the prior period, the reporter can explain that the shift reflects a revised policy scope, a broader or narrower set of worker groups, or updated objectives.
Content index entry
S1-1 Policies (Own Workforce) — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for S1-1 — 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
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 asked
The team chases the policy owner in the wrong function, instead of the people who actually keep the staff policy register and can confirm the current version.
Framework language used too early
The request goes out in ESRS-style wording, so the business cannot map it to its own policy names, workforce groups, or internal labels.
Scope not pinned down
No one states whether the policy applies to employees only or also to other workers, so the data pull mixes the wrong populations.
Coverage groups blurred together
Different staff segments are merged into one answer even though the source records them separately, which hides where the policy really applies.
Wrong time basis used
The collector asks for the position at the wrong date or period, so the answer reflects an out-of-date policy set rather than the reporting cut-off.
Counting basis mixed up
One source counts policies by document, another by topic or business unit, and the final extract combines them without aligning the basis first.
Source labels lost
The original file names, register codes, or system tags are dropped during extraction, making it impossible to trace each answer back to the underlying record.
Evidence trail incomplete
The pack is assembled without the supporting note, version history, and sign-off record, so nobody can show who checked the data and when.
Where judgement is often needed
Defining the policy name when several documents cover the same topic
Use one clear label for the main rule-set you rely on, and if related documents sit alongside it, explain how you grouped them so readers can tell what sits inside the same policy family.
Deciding who counts as part of the workforce scope
State whether you include only direct staff or also people working for you through other arrangements, and explain any cut-off used for groups that sit near the boundary.
Handling different country terms for the same worker group
Where local employment labels do not map neatly across locations, describe the practical rule you used to place each group into your chosen categories and note any exceptions.
Setting the coverage line after a buy-in or sale
If the reporting perimeter changed during the period, explain from which date the new or removed teams were brought into or taken out of the policy coverage view.
Choosing which parts of the workforce are covered by each topic
For each subject area, spell out which employee groups and other workers are included, and make clear when a topic applies only to some segments rather than everyone.
Describing aims in a way that matches how the business actually manages people risks
Link each stated aim to the practical people-risk or conduct issue it is meant to address, and avoid broad wording that does not show what the policy is trying to change.
Using estimates where the underlying records are incomplete
If you cannot trace every group directly from source records, say which figures were estimated, what basis was used, and how you kept the approach consistent across the report.
Rounding and small-number presentation
Explain the rounding rule you applied and make sure any totals still reconcile after rounding, especially where small groups could otherwise be hidden or overstated.
Protecting privacy when the workforce is too small to show in detail
Where a breakdown could identify individuals, combine categories or suppress detail as needed, and say that the presentation was adjusted to avoid exposing personal information.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
We maintain a modern slavery and labour-rights policy that applies to our own staff and to contractors, agency workers and other business partners in our supply chain. It covers production, warehousing, logistics and procurement teams, and its aim is to prevent exploitative recruitment, protect younger workers and strengthen oversight of high-risk sourcing. - In the reporting period, we did not identify any forced labour, child labour or trafficking cases in our operations or value chain. - The policy is applied across employees and non-employees, with coverage for permanent staff, temporary workers, agency labour, transport providers and key suppliers.
This synthetic example shows how to describe the policy, who it applies to, which parts of the workforce it reaches, and the three labour-exploitation flags in a concise narrative form.
Illustrative (synthetic) example — Technology services
Our code on fair work and responsible sourcing sets the rules for our own people and for selected external workers who support software delivery, data operations and facilities management. It is designed to reduce the risk of coercive recruitment, stop under-age work and trafficking, and improve checks on labour practices in higher-risk service contracts. - During the period, we recorded no confirmed instances of forced labour, child labour or trafficking. - The coverage extends to employees and non-employees, including full-time staff, fixed-term staff, contractors, outsourced support teams and on-site service providers.
This synthetic example uses a different sector and wording while still covering the policy title, who is in scope, which worker groups are included, the policy aims, and the three yes/no labour-risk indicators.
How companies report S1-1 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Fluidra, S.A.
Electrical Equipment and Machinery · Spain · 2025
Fluidra’s 2025 Integrated Annual Report provides partial coverage of policies related to child labour and forced labour, noting a zero-tolerance stance and referencing related policies on page 214. The report includes some contextual information on actions addressing material impacts on the workforce (p.299), but does not clearly disclose specific headline values or detailed effectiveness measures. Several expected datapoints, such as explicit disclosures on workforce-related indicators, are not found or remain unclear in the report.
Aena S.M.E., S.A.
Air Transportation — Airport Services · Spain · 2025
Aena S.M.E., S.A.'s 2025 Sustainability report provides some related context on occupational diseases disaggregated by gender but does not clearly disclose this information (p.310). The report references general disclosures related to employment, abolition of forced labour, and employment contract types, with page citations indicating some coverage of social dialogue and preventive policies (pp.196, 309, 311). However, no clear or quotable evidence was found specifically addressing the disclosure in question, indicating notable gaps or unclear presentation of this datapoint.
Banco de Sabadell, S.A.
Banks / Diverse Financials / Insurance · Spain · 2024
Banco de Sabadell’s 2024 Consolidated Non-Financial Disclosures and Sustainability Disclosures Report provides a detailed breakdown of its workforce by country, sex, age, and professional category on page 330. The report also references policies related to its own workforce and grievance handling mechanisms on page 334. However, no quotable evidence was found regarding other narrative items or specific disclosures beyond these datapoints.
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Check your understanding
Scenarios to work through
A group HR lead is drafting the people policy summary for the annual report. The document covers permanent staff and agency workers, but the draft title only mentions employees, and the team has not yet checked whether the wording matches the actual policy scope.
QShould the policy name and scope be described in a way that matches the real document, including whether it applies only to employees or also to other workers?
Reveal model answer →Hide answer ↑Yes. The summary should use the policy’s actual name and make clear who it covers, using plain language that reflects whether it applies just to employees or also to non-employee workers. If the organisation has different workforce groups covered, those groups should be identified rather than implied.
Why this matters · Use the real policy title and describe the people it covers accurately, not loosely.
A preparer has one internal code of conduct for all staff, but separate contractor rules sit in a procurement folder. They are unsure whether the disclosure should mention only the staff code or also the contractor rules when describing the workforce covered.
QWhen setting out the workforce segments covered, should the preparer include every relevant group that the policy actually reaches?
Reveal model answer →Hide answer ↑Yes. The description should reflect all workforce segments that the policy reaches in practice, not just the most obvious employee group. If the same policy or linked policies also apply to contractors or other non-employees, that coverage should be made visible in the narrative.
Why this matters · Describe the full reach of the policy across workforce groups, not only the main employee population.
The sustainability team has a draft policy that bans forced labour and child labour, but the section on trafficking is still being reviewed by legal. The team wonders whether they can leave trafficking out for now and add it later if the wording is finalised before publication.
QCan the preparer omit one of the three labour-abuse topics from the disclosure until the wording is finalised?
Reveal model answer →Hide answer ↑No. The disclosure should show whether the policy addresses each of the three topics separately: forced labour, child labour and trafficking. If one topic is not yet covered, that gap should be reflected honestly rather than filled in as if it were already included.
Why this matters · Treat each labour-abuse topic as a separate check and report the current position honestly.
A company has a broad human rights policy for its own workforce, but the report draft only says it promotes fair treatment and safe working conditions. The team has not yet stated what the policy is trying to achieve for workers or how it links to the labour-abuse topics.
QShould the objectives section explain what the policy is intended to achieve for the workforce, in practical terms?
Reveal model answer →Hide answer ↑Yes. The objectives should be stated in a way that shows what the policy is meant to do for the organisation’s own workers, such as preventing abuse, setting expectations for treatment, and supporting the relevant labour protections. The explanation should be specific enough to show the policy’s purpose, not just a general statement of values.
Why this matters · Explain the policy’s practical purpose for workers, not just its broad principles.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I use the S1-1 page to draft an own workforce disclosure from scratch?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints. The page also gives draft-output prompts, so you can turn the collected information into a first-pass narrative and content line.
What data do I need to collect for S1-1 own workforce before I start writing?+−
The page says to prepare the forced labour, child labour and trafficking flags, plus the policy title, policy coverage group, covered workforce groups and policy aims. Use those items as your minimum data set before drafting.
How should I define the scope for the S1-1 own workforce disclosure on this page?+−
Use the page’s coverage fields to set scope in practice: policy coverage group and covered workforce groups. That helps you show which parts of the workforce the policy applies to before you draft the disclosure.
Who should own the S1-1 own workforce data collection and sign-off process?+−
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can confirm the policy details and workforce coverage. The workbook and evidence pack are there to support that handover and review.
What evidence should I keep to make the S1-1 disclosure assurance-ready?+−
The page includes six assurance claims to verify and an evidence pack with five items for assurance readiness. Use those to build a file that links each claim to the supporting source material before review.
What are the common mistakes to avoid when preparing S1-1 own workforce reporting?+−
The page has a section on common reporting gaps and mistakes, so use that as a pre-submission check. It is especially useful for spotting missing datapoints, unclear scope, or weak evidence before you finalise the draft.
How do I use the Prep & Assurance workbook for S1-1?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the required datapoints, track the assurance claims and evidence, and move from raw inputs to a draft disclosure.
What is the printable Library Card for S1-1 and when should I use it?+−
The Download Centre also includes a printable Library Card in .pdf format. It is useful as a quick reference while you gather data, check the preparation steps, and review the draft output.
Does the S1-1 page include an example disclosure I can copy into my draft?+−
Yes, it includes synthetic illustrative example disclosures, including a quantitative table. Treat them as examples of structure and presentation only, and make sure any real draft stays consistent with your own data.
How can I turn the S1-1 data into a draft narrative and content index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line. Use those prompts to convert the prepared datapoints into a clear first draft and a simple index reference.
More questions this page can help with
S1-1 own workforce: what are the minimum datapoints I should gather before drafting?S1-1 own workforce: how do I map policy coverage group and covered workforce groups in practice?S1-1 own workforce: what should go into the evidence pack for assurance?S1-1 own workforce: how do I use the step-by-step preparation section efficiently?S1-1 own workforce: what are the six assurance claims and how do I verify them?S1-1 own workforce: what are the most common reporting gaps to check before sign-off?S1-1 own workforce: how do I use the workbook to track data, evidence and draft text?S1-1 own workforce: how should I use the synthetic example disclosure without copying it?S1-1 own workforce: where do I find the narrative starters and content-index line guidance?S1-1 own workforce: can the page help an assurance reviewer test the draft against source evidence?S1-1 own workforce: what does the plain-language explainer help me understand before I collect data?S1-1 own workforce: how do I use the company reports table for practical benchmarking?
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