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GRI 403: Occupational Health and Safety · 2018
Disclosure GRI 403-4

Worker participation, consultation, and communication on occupational health and safety

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.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain how workers are involved in occupational health and safety matters in practice. It is about the channels used for participation, consultation and communication, and whether workers can raise concerns, share views, and receive information on health and safety issues in a meaningful way.

The practical focus is on how far these arrangements apply across the organisation, not just at a few well-managed sites. A useful report should show whether the approach covers all operations, including different locations, worker groups and employment arrangements, and where there are gaps or differences in coverage.

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
Worker input process How employees and other people whose work or workplace is under the organisation’s control are involved in shaping, running and reviewing the health and safety system; include the main participation and consultation routes used. Meeting notes, consultation records, worker forum terms of reference, policy/process documents, and examples of feedback being used in system reviews. Health and safety / HR
Safety information access How workers are given access to, and kept informed about, health and safety information that is relevant to their roles and workplaces; capture the channels, timing and any role-based tailoring. Induction materials, intranet pages, toolbox talk records, noticeboard screenshots, training logs, and communication plans. Health and safety / Internal communications
Joint safety committee Whether there is a formal committee made up of management and worker representatives for health and safety oversight. Committee charter, terms of reference, governance register, and meeting calendar. Health and safety / Governance
Committee remit and cadence What the committee is responsible for, how often it meets, and what decisions it can make or influence. Terms of reference, minutes, action logs, and governance approval documents. Health and safety / Governance
Unrepresented workers Whether any workers are outside the coverage of the formal health and safety committees. Committee membership lists, workforce coverage mapping, site/shift rosters, and representation arrangements. Health and safety / HR
No-representation reason If any workers are not covered by the committees, explain why that gap exists in practice. Coverage mapping, local consultation arrangements, union or representative agreements, and management explanations for excluded groups. Health and safety / HR
＋ Show GRI 403-4 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: identify the people covered, including employees and any non-employees whose work or workplace the organisation controls, so the disclosure matches the intended population.
2Map the two required process areas in plain language: how workers are involved in shaping, running and checking the health and safety system, and how they are given access to and told about relevant health and safety information.
3Check whether formal shared health and safety committees exist, and if they do, gather a clear summary of what they do, how often they meet, and how much decision-making power they have.
4Confirm whether any workers are outside committee coverage; if so, prepare a short explanation of who is not covered and why that is the case.
5Collect the supporting records and statements that back each part of the answer, then assemble the final text and any yes/no responses so they are consistent with the evidence.
6Review the draft against the official source to make sure every required point is covered, any exclusions or changes are explained, and nothing has been added, omitted or overstated.
Request the data

Request the worker safety consultation evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

How do people who work for us, and other workers under our site or work control, take part in safety discussions, get safety information, and are any groups left out of the formal safety forum?

Use your organisation’s own names first for the safety forum, worker reps, toolbox talks, noticeboards, apps, site briefings, and escalation routes; then map those terms to the reporting disclosure. Keep the request in your internal language rather than using framework labels.

Weak request

Please provide the GRI 403-4 evidence showing worker participation, consultation, communication, joint committees, and any unrepresented workers.

Why it fails: It uses framework language that many operational teams will not recognise, and it bundles several asks without saying what internal records to pull. It also does not tell the owner how to describe the forum in their own terms or what scope, period, or source to include.

Better request

Please send the records that show how workers at [sites/functions] are involved in safety discussions, how safety updates reach them, whether you use a joint safety forum or another route, and whether any worker groups are outside that coverage. Include the meeting notes, briefing logs, or screenshots, plus the period, scope, and your internal name for each route.

Formal email template
Subject: Request for safety consultation and communication evidence for [reporting period]

Hi [name/team],

I’m pulling together the sustainability reporting pack and need your help with the safety consultation and communication evidence for [reporting period].

Please send, in your own operational terms where possible:
- the name and purpose of the worker safety forum(s) or other consultation route(s)
- how workers take part in safety discussions and review of safety arrangements
- how safety information is shared with workers and other workers under our control
- whether any worker groups are not covered by the forum(s), and why
- the forum responsibilities, how often it meets, and what decisions it can make or influence
- any supporting records you think best evidence this, such as minutes, action trackers, briefing logs, or screenshots

Please include the scope covered, the period covered, and the source of each item. If it is easier, you can return this in the table format below.

This is a training template only; please adapt it to your organisation’s own language and check the source disclosure before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name] — could you share the safety forum / briefing evidence for [period]? I need: how workers feed into safety decisions, how safety info is shared, whether any groups aren’t covered, and any minutes/logs/screenshots. Please use your own site terms and include scope + source. Thanks.
Industry examples
Manufacturing

Context. A plant with day and night shifts, agency staff, and contractor maintenance teams.

Adapted request. Please share the plant safety committee records for [period], plus shift briefing logs and contractor safety update records. I need to see how operators, maintenance staff, agency workers, and contractors feed into safety decisions, how updates are shared, and whether any shift or worker group is not covered. Use the plant’s own names for the committee and briefing routes.

Example response. The plant safety forum meets monthly, reviews incident trends and action closure, and can recommend controls to the site manager. Day and night shifts are covered through supervisor briefings and noticeboard updates. Agency workers receive the same induction pack and weekly safety alerts. Contractors are covered through permit briefings. Night shift agency workers are not on the forum directly; they are represented through shift supervisors and the contractor coordinator.

Logistics / Warehousing

Context. A distribution network with multiple depots, drivers, and third-party warehouse operatives.

Adapted request. Please provide depot-level evidence for [period] showing how drivers, pickers, and third-party operatives are consulted on safety, how route and depot safety updates are communicated, and whether any worker group is outside the depot forum. Include the depot’s own forum name, minutes, action log, and communication examples.

Example response. Each depot has a safety huddle and a monthly depot forum chaired by the operations manager. Drivers raise route risks through daily start-of-shift briefings; warehouse operatives use a QR feedback form and noticeboards. Safety alerts are sent by SMS and app message. Third-party operatives are included in site briefings, but some agency drivers are not on the monthly forum because they are managed by a separate transport provider; their issues are escalated through the transport lead.

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

Define which worker groups are included, explain how the organisation identified participation and consultation arrangements, and state the basis used to decide whether a committee exists, who it covers, and what counts as representation.

Context note

These figures show how far workers are involved in safety management, how information reaches them, and whether formal committee structures are used to support consultation and oversight.

Fluctuation statement

If the pattern has changed since the previous period, note whether this reflects changes in workforce coverage, committee coverage, meeting cadence, or the way participation and communication arrangements are organised.

Content index entry
GRI 403-4 Worker participation, consultation, and communication on occupational health and safety — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for GRI 403-4 — 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.

Free · Community members
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧
Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
I have documented how workers were involved when we designed, rolled out and reviewed the health-and-safety system, including people whose job or work location we control.The assurer will check whether the statement is backed by real participation arrangements rather than a general assertion, and whether the coverage of workers is complete and correctly defined.Minutes from consultation meetings, worker feedback records, participation plans, role descriptions, site-level engagement logs, and a documented boundary showing which workers were included and why.
I can show the route we used to make health-and-safety information available to workers and how we kept it communicated in practice.The assurer will probe whether the communication process actually operated, whether the information was accessible to the intended audience, and whether the claim is supported by evidence rather than policy wording alone.Training materials, noticeboard or intranet screenshots, toolbox-talk records, induction packs, translated or adapted materials where relevant, distribution logs, and evidence of updates when information changed.
We have confirmed whether formal shared safety committees are in place and recorded that position consistently across the disclosed operations.The assurer will test whether the existence or non-existence of committees is accurate for the reporting boundary and whether any exceptions or site differences have been missed.Committee registers, organisational charts, site lists, governance documents, local H&S arrangements, and a reconciliation showing which locations or teams have a committee and which do not.
Where committees exist, I have set out what they do, how often they meet, and what decisions they can make.The assurer will look for unsupported or overstated descriptions of committee powers, unclear meeting cadence, or a mismatch between the narrative and the underlying terms of reference.Terms of reference, meeting calendars, agendas, minutes, action trackers, delegated authority documents, and any policy setting out the committee’s remit and limits.
I have identified any workers who are outside committee representation and explained that position in the disclosure.The assurer will check whether the statement about unrepresented workers is complete, whether the affected groups are correctly identified, and whether the explanation matches the actual arrangement.Coverage mapping by site, contract type or worker group, committee membership lists, workforce population data, and a documented review showing which workers are not covered by representation.
Where some workers are not covered, I have recorded the reason for that gap and kept support for the explanation on file.The assurer will test whether the reason given is specific, credible and consistent with the organisation’s structure and worker representation arrangements, rather than a generic justification.Internal notes explaining the gap, legal or operational rationale if used, correspondence with site leaders or worker representatives, workforce structure records, and review evidence showing the explanation was checked before publication.

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 the safety team in framework language instead of the business owner who runs the worker forums, notice channels, or committee records.
Scope left vague
The team starts collecting data without pinning down which employees and which non-employee workers at controlled sites are in scope.
Boundary not set
People mix together workers from sites, contractors, and business units that should be tracked separately, so the final dataset no longer matches the organisation’s actual coverage.
Wrong time basis
The data pull uses a different reporting period or meeting cycle from the one used elsewhere, so the figures and descriptions do not line up.
Counting basis mixed up
Headcounts, attendance, and committee coverage are combined in one file without stating the basis for each measure, which makes the numbers impossible to compare.
Source labels lost
Original file names, register codes, meeting references, or channel names are stripped out, so nobody can trace each entry back to the source record.
Separate groups merged
Workers who have a committee route and workers who do not are rolled into one population, which hides who is covered and who is not.
Evidence trail missing
The pack contains the summary but not the supporting notes, dates, or sign-off history, so the reviewer cannot see who confirmed the data and when.

Where judgement is often needed

Setting the reporting boundary after a buy-in or sale
Decide whether to include sites and teams only once they are under your control for the period being reported, and explain any cut-off date or partial-period treatment used.
Using local job titles versus one group-wide people map
Where countries use different labels for staff, contractors, agency labour, or other on-site workers, map them to a single internal classification and state the rule you used so readers can see who is in scope.
Including people whose workplace is controlled but whose employer is not
Make a clear call on whether on-site non-employees are covered by the participation and information channels you describe, and note any groups excluded because the organisation does not control their work or workplace.
Treating remote, mobile, and hybrid workers
If people work away from a fixed site, explain how they can join consultation, raise issues, and receive safety updates, or say why a different route is used for them.
Counting joint safety forums that differ by country
If some locations use formal committees and others use works councils, local forums, or other worker forums, describe each model in plain terms and explain how you judged it to be equivalent for this disclosure.
Describing committee powers where practice varies
State whether the forum only shares views, shapes plans, or can block decisions, and be explicit if authority differs by site, country, or business unit.
Choosing the basis for saying who is not covered by a committee
If some workers are outside the committee structure, explain whether that is because of headcount, location, contract type, shift pattern, or another operational reason, and keep the explanation consistent with your internal records.
Using estimates where records are incomplete
If you cannot trace every worker to a consultation route or information channel, use a documented estimate only where necessary, say how it was built, and note any rounding or aggregation that affects the result.
Balancing detail with privacy in small teams
When a site or team is so small that naming the exact arrangement could identify individuals, aggregate the description enough to protect privacy while still showing how workers are involved and informed.
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Food processing

*Synthetic illustration only.* We involve both employees and agency staff whose day-to-day work or worksite we direct in shaping, running, and reviewing our health and safety arrangements through toolbox talks, site walkabouts, incident reviews, and annual policy refreshes. Safety notices, risk assessments, training materials, and incident learnings are shared through shift briefings, noticeboards, the intranet, and supervisor cascades; we also have a formal worker-management safety committee that meets every month, reviews trends and corrective actions, and can require follow-up from site leaders, while 18 of 120 workers are not covered because they are remote office staff with no routine site exposure and are instead represented through local line-management forums.

This example shows how a reporter can describe worker involvement, information-sharing, committee arrangements, and any gaps in representation without using standard wording.

Illustrative (synthetic) example — Logistics and warehousing

*Synthetic illustration only.* Our employees and contracted warehouse operatives who work under our site controls help shape the safety system through pre-shift huddles, joint inspections, near-miss reporting, and post-incident reviews, and they are consulted again when we test changes or check whether controls are working. We share safety rules, hazard alerts, training packs, and emergency instructions through handheld devices, induction sessions, posters, and team briefings; a joint safety panel made up of managers and worker representatives meets every six weeks, tracks actions, and can agree local changes, but 24 of 200 workers are outside the panel because they are night-shift transport coordinators based off-site and are covered instead through direct supervisor consultation.

This example demonstrates a second plausible reporting style with different worker groups, communication channels, committee cadence, authority, and a stated reason for non-representation.

Company reports

How companies report GRI 403-4

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

O-Bank Co., Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
Open report →
O-Bank Co., Ltd.'s 2024 Sustainability Report provides coverage on occupational health and safety, including worker training and the extent of workers covered by an occupational health and safety management system, as noted on pages 26 and 309. The report also references governance responsibilities related to these issues on page 193, though without specific headline values. However, some narrative items lack clear or quotable evidence, indicating partial or missing data in certain areas.
Sands China Ltd.
Hotels, Restaurants, Leisure, Tourism Services · Macao · 2025
Open report →
Sands China Ltd.'s 2025 ESG Report provides coverage on occupational health and safety, reporting zero health fatalities and detailing cases of work-related ill health over recent years, with 98% of team members covered by occupational safety and health management systems (p.40). The report also references Sustainable Development Goal 8, highlighting commitments to decent work and economic growth, including support for micro-, small-, and medium-sized enterprises (p.50). However, the report offers only partial context on governance and business conduct without headline values (p.4), and several narrative items related to the disclosure are not found or lack quotable evidence.
CRH plc
Construction Materials · Ireland · 2024
Open report →
CRH plc’s 2024 Sustainability Performance Report provides evidence of active employee engagement through an annual survey, with results indicating a high level of engagement across its businesses (p.63). The report also details occupational health services and worker participation, consultation, and communication on occupational health and safety, referencing specific pages for further information (p.102). However, some narrative items related to this disclosure are not found or unclear in the report, with no quotable evidence available on several aspects.
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Check your understanding

Scenarios to work through

A UK logistics business has a safety forum for warehouse staff, but its agency pickers and cleaners work on the same site under the company’s day-to-day control. The reporting lead is deciding whether those non-employee workers should be covered in the description of how people are involved in shaping, running, and reviewing the safety system.

QShould the write-up include both employees and those other workers whose tasks or workplace the business controls, and explain how they take part in the safety system’s design, delivery, and review?
Reveal model answer →

A manufacturing site sends monthly safety alerts by email, but many shop-floor workers do not have regular computer access. The preparer is deciding whether the disclosure can simply mention the email system or whether it needs to explain how people actually receive and can use the information.

QWhat level of detail should be given about access to and sharing of health and safety information with workers?
Reveal model answer →

A distribution centre has a joint safety committee made up of managers and worker representatives, meeting every six weeks. The reporting team is unsure whether it is enough to say the committee exists, or whether they also need to explain what it does and how much authority it has.

QIf a joint management-worker safety committee is in place, what else should be explained about it?
Reveal model answer →

A company has safety committees at its main sites, but several remote field technicians work alone and are not part of any committee structure. The preparer is deciding whether to leave that gap unmentioned because the technicians can still raise issues through their line manager.

QHow should the disclosure handle workers who are not covered by the committee arrangement?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 403-4
within GRI 403: Occupational Health and Safety
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

What do I need to gather before drafting GRI 403-4 Occupational Health and Safety on this page?+
How should I set the scope and method for GRI 403-4 Occupational Health and Safety using this page?+
Who should own the data for GRI 403-4 Occupational Health and Safety in practice?+
What evidence should I put in the pack for GRI 403-4 Occupational Health and Safety?+
How do I use the six assurance claims on the GRI 403-4 page?+
What are the common reporting mistakes on GRI 403-4 Occupational Health and Safety that this page warns about?+
How can I turn the GRI 403-4 data into a draft disclosure?+
Can I use the synthetic example on the GRI 403-4 page as a template for my own disclosure?+
What should I check in the workbook and printable card downloads for GRI 403-4 Occupational Health and Safety?+
How can the 'From company reports' table help me with GRI 403-4 Occupational Health and Safety?+
Is the GRI 403-4 page useful if I need to align data with ESRS S1 (Own Workforce)?+
More questions this page can help with
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