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
＋ 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.
How to prepare it
1Set 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.
2Define 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.
3Gather support for the description: collect internal records, procedures, service descriptions, contracts, or other evidence that shows the service exists and what it covers.
4Prepare 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.
5Record 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.
6Check 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 data
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.
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
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
Preparation tools & forms
Professional preparation tools for GRI 403-3 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
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
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.
Illustrative (synthetic) example — Manufacturing
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.
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.
Illustrative (synthetic) example — Logistics
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.
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.
Company reports
How companies report GRI 403-3
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Oberoi Realty Limited
Real Estate · India · 2025
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.
SCB X Public Company Limited
Banks / Diverse Financials / Insurance · Thailand · 2024
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).
Nan Pao Resins Chemical Co., Ltd.
Chemicals · Taiwan · 2024
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).
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Check your understanding
Scenarios to work through
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.
QWhat should the preparer check before finalising the disclosure?
Reveal model answer →Hide 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.
QWhat decision does the preparer need to make about the access part of the disclosure?
Reveal model answer →Hide 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.
QWhat should the preparer look for before accepting that the quality explanation is adequate?
Reveal model answer →Hide 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.
QHow should the preparer judge whether the disclosure is complete?
Reveal model answer →Hide 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.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Occupational health and safety management system → Guide ✓Work-related ill health → Guide ✓Hazard identification, risk assessment, and incident investigation → Guide ✓Worker participation, consultation, and communication on occupational health and safety → Guide ✓Worker training on occupational health and safety → Guide ✓Promotion of worker health → Guide ✓Show all 9 related disclosures →
FAQ
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 reportingGRI 403-3 service quality and access data: what counts as usable evidence?GRI 403-3 assurance evidence pack checklistGRI 403-3 claim risk evidence review questionsGRI 403-3 common reporting mistakes and gapsGRI 403-3 workbook download how to use itGRI 403-3 printable library card PDF downloadGRI 403-3 synthetic example disclosure tableGRI 403-3 draft narrative starters and content index lineGRI 403-3 who should own the disclosure dataGRI 403-3 ESRS S1 own workforce data reuse
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