Kern van de disclosure
In practical terms, the reporting should cover the organisation’s full relevant footprint, not only a few well-controlled or flagship locations, unless the scope is clearly explained. The key question is whether the figures reflect the parts of the business where corruption and bribery risk actually exists, including operations, subsidiaries, and other relevant activities, so users can judge the breadth and consistency of the organisation’s approach.
Dit educatieve materiaal van LRA ondersteunt het opstellen van de disclosure. Raadpleeg voor de exacte vereisten altijd de officiële European Commission-bron.
Voorbereiden
Wat te verzamelen vóór het opstellen
Vink elk veld af zodra het bewijs binnen is. Eigenaren zijn de teams die de bronbestanden doorgaans beheren.
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Conviction count
Legal / ComplianceRecord the total number of convictions that fall within the reporting scope for the period.
Bewijs Court records, legal case logs, compliance register, or a legal affairs summary that reconciles to the final count.
Let op Count pulled from a case log that includes matters outside the reporting period or excludes convictions already closed in the legal tracker.
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Sanction count
Legal / ComplianceCapture the total number of sanctions that apply to the reporting scope for the period.
Bewijs Regulatory notices, enforcement tracker, compliance register, or a legal affairs summary that ties to the reported total.
Let op Sanctions are counted from a source list that mixes warnings, investigations, and final sanctions, so the category definition does not match the reported total.
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Total fines amount
Finance / LegalCapture the full euro amount of fines that belong in scope for the period, using the same basis across all included items.
Bewijs Penalty notices, finance/legal schedule, or an enforcement summary that reconciles to the euro total reported.
Let op Fine amounts are taken from a source schedule that mixes currencies or periods, so the total does not reconcile to the underlying penalty notices.
Voordat u begint
- Have you fixed which corruption or bribery cases sit inside this count, and which sit outside it, before you total the figures?
- Will the numbers be taken for the same reporting period as the rest of your report, and from one clear cut-off date?
- Can each figure be traced back to a named source record, such as a case log, legal notice, or finance entry?
- Have you agreed what counts as a conviction, a sanction, and a fine in your organisation’s own records, so the counts are built on one consistent basis?
- If fines are included, have you confirmed the amount is recorded in euros and that you are using the full total for the period you chose?
Hoe u dit voorbereidt
De gegevens opvragen
Request the corruption case metrics from Legal / Secretariat
Vertaal de disclosure naar een interne bedrijfsvraag — en pas die daarna aan op het taalgebruik van uw organisatie.
How many corruption or bribery cases in the period ended in a conviction, a sanction, or a financial penalty, and what was the total amount of fines in euros?
Use your organisation’s own case-handling terms first, then map them to the reporting fields. For example, if you track matters as investigations, enforcement actions, settlements, or court outcomes, keep those labels in the request and ask the owner to translate them into the reporting view before sign-off. This is a training template only; adapt it to your organisation and check the source disclosure before sign-off.
Zwak verzoek
Please provide the ESRS G1-4 corruption and bribery metrics for the period, including convictions, sanctions and fines, in line with the disclosure.
Waarom dit misgaat: It uses framework language instead of the organisation’s own case terms, does not say which register or system to pull from, and leaves the counting basis and currency treatment unclear. That makes it hard for the owner to know what to extract and how to map it.
Beter verzoek
Please provide the [period] case outcome data from your [legal case tracker / compliance register] for the [boundary]. We need the number of matters that ended in a conviction, the number that ended in a sanction, and the total fines in euros. Please keep your normal case labels in the extract and add a short mapping note so we can translate them into the reporting view.
Sjabloon voor een formele e-mail
Subject: Data request for corruption case outcomes and fines Dear [name/team], Please could you provide the case outcome data for [reporting period] for the [group/boundary]? We need the figures for matters that ended in a conviction, a sanction, or a fine, together with the total fine amount in euros. Please use your normal case labels in the first instance, and include a short mapping note so we can translate them into the reporting view. If any items sit outside your main register, please note where they came from. Could you return the data in the table below, plus the supporting evidence list, by [date]? Many thanks, [preparer name] [role] Training note: this is a possible LRA template only. Adapt it to your organisation and check the source disclosure before sign-off.
Korte versie voor Teams / Slack
Hi [name] — could you send over the [period] corruption/bribery case outcomes for [boundary]? We need counts for convictions, sanctions, and the total fines in euros. Please use your usual case labels and add a quick mapping note so we can translate them for reporting. Thanks — [name]
Sectorvoorbeelden
Financial services
Context. The organisation tracks enforcement matters, regulatory actions, and court outcomes in a central compliance log.
Aangepast verzoek. Please pull the [period] enforcement and court outcome data from the compliance log for [boundary]. We need counts for matters that ended in a conviction, a regulatory sanction, and the total fines in euros. Please keep the internal labels used in the log and add a mapping note for any items that need translation.
Voorbeeldantwoord. Returned table includes case ID, internal matter type, outcome date, jurisdiction, outcome label, conviction flag, sanction flag, fine amount in original currency, EUR equivalent, and source document reference.
Construction / infrastructure
Context. The organisation records legal claims and regulator actions in a project risk register and a legal matters tracker.
Aangepast verzoek. Please share the [period] legal matters extract from the project risk register and legal tracker for [boundary]. We need the number of cases that finished with a conviction, the number that ended with a sanction, and the total fines in euros. Please use the project/legal labels you already track and note how each item maps to the reporting view.
Voorbeeldantwoord. Returned table includes matter ID, project name, internal label, final outcome, decision date, authority/court, count status, fine amount, currency, EUR amount, and evidence reference.
Stel uw disclosure op
Notities die gegevens tot een disclosure maken
LRA-trainingssjablonen — pas ze aan op uw organisatie en controleer de officiële bron vóór goedkeuring.
Methodenotitie
State how each figure was counted, what was included in the totals, and the reporting period and scope used to compile the three measures.
Contextnotitie
Explain what the counts and euro total indicate about enforcement activity in the period, and whether the monetary amount reflects a small number of large cases or many smaller ones.
Toelichting op schommelingen
If the figures moved materially, describe the main drivers, such as changes in case volume, case severity, timing of decisions, or one-off events that affected the totals.
Vermelding in de inhoudsindex
G1-4 Corruption & Bribery Metrics — [location / page] / [notes]Downloadcentrum
Hulpmiddelen en formulieren voor de voorbereiding
Download voorbereidingstools voor G1-4 gedurende 24 uur met gratis toegang na e-mailverificatie. Links naar bronrapporten blijven openbaar.
Controleren
Controleer bij elke bewering het bewijs
We separated out the number of court findings and regulatory penalties linked to bribery or corruption matters for the period, using a clear cut-off date and a single counting rule.
Risico The assurer will check whether the two categories were kept distinct, whether the period boundary was applied consistently, and whether the counting method could double-count the same case.
Te controleren bewijs Case log or incident register; legal/compliance tracker; period-end extraction showing the cut-off date; documented counting methodology; reconciliation from source cases to the published totals.
We included only matters that met our internal definition of a bribery or corruption breach, and we applied that definition consistently across all business units before aggregating the figures.
Risico The assurer will probe whether the inclusion criteria were applied consistently, whether any borderline cases were excluded or included without justification, and whether the scope was complete.
Te controleren bewijs Written inclusion criteria; review notes for borderline cases; business-unit submissions; consolidation workbook; sign-off showing the same rule set was used across the group.
We based the published numbers on source records held by legal, compliance, and finance, and we checked that each reported item could be traced back to supporting documentation.
Risico The assurer will look for traceability from the published figure to underlying records and will test whether the source files are complete, authentic, and aligned to the final output.
Te controleren bewijs Underlying notices, judgments, settlement letters, or penalty records; finance postings where relevant; traceability schedule; document index; evidence of file retention and version control.
Before publication, we reviewed the draft figures against the underlying case files and resolved any mismatches between local records and the consolidated disclosure.
Risico The assurer will assess whether pre-publication checks were performed, whether discrepancies were investigated, and whether the final numbers reflect the corrected source data.
Te controleren bewijs Draft-to-final comparison; review checklist; discrepancy log and resolution notes; approval emails or sign-off memo; evidence of corrections made before release.
Where a matter involved more than one outcome, we recorded each outcome separately and checked that the total amount reported for monetary penalties matched the supporting finance records.
Risico The assurer will test whether outcomes were classified consistently, whether the monetary total is complete, and whether the amount agrees to the accounting or payment evidence.
Te controleren bewijs Matter-by-matter schedule; penalty calculation support; payment confirmations or ledger extracts; reconciliation to finance records; reviewer sign-off on the final total.
Voor te bereiden bewijsdossier
Veelvoorkomende hiaten in de rapportage
- Units are missing or inconsistent across the figures.
- The reporting scope or boundary for the numbers is unclear.
- Estimates are not distinguished from measured values.
- Parts of the total are double-counted or omitted.
- Restatements of prior-period figures are not disclosed.
- The calculation method or data source is not documented.
Waar concepten misgaan
Fouten om te vermijden en waar een oordeel nodig is
De linkerkolom toont wat opstellers fout doen bij het verzamelen; de rechter waar u een oordeel moet vellen en toelichten.
Fouten om te vermijden
- Wrong ownerSending the request to a team that only sees part of the case file means the count is built from incomplete records.
- Framework words, not business termsAsking for the figures in disclosure language instead of the organisation’s own case labels makes people pull the wrong dataset or miss relevant entries.
- Unclear boundaryNot stating which entities, sites, or case types sit inside the scope leads to some records being left out and others being counted twice.
- Wrong time basisUsing a different reporting window from the one used in the source records produces totals that do not match the period being reported.
- Mixed counting methodCombining case counts, people counts, and monetary amounts in one extraction step creates numbers that cannot be reconciled back to the source.
- Source labels lostCopying the figures without keeping the original case IDs, file names, or ledger tags makes it impossible to trace each number back to its origin.
- Populations mergedPutting convictions, penalties, and fine amounts into one undifferentiated list hides which figure belongs to which measure.
- No evidence trailCollecting the numbers without the supporting extract date, owner, and approval record leaves no audit trail for later review.
- No sign-off recordFailing to capture who checked the figures and when means the final set cannot be shown as reviewed before it is used.
Oordeel vereist
- What counts as a case in the reporting perimeter after a buy or sell transactionDecide whether to include outcomes linked to businesses added or removed during the year, explain the cut-off date used, and make clear if prior-period figures were restated or left as reported.
- How to handle local legal labels that do not line up neatly across countriesUse one internal rule for classifying court outcomes, penalties and monetary penalties across jurisdictions, then disclose any country-by-country mapping or simplification you used so readers can see how unlike labels were made comparable.
- Whether to include people or entities close to the boundary of controlSet out whether you counted matters involving joint ventures, contractors, agents or other connected parties, and explain the practical test used to decide when a case sits inside or outside the group’s own figures.
- Choosing the date basis for the annual countState whether you used the date of the final decision, the date the matter was recorded, or another consistent point in time, and keep that basis the same for convictions, penalties and fines.
- Using actual records versus estimates where the file is incompleteIf some cases are still being confirmed, explain whether you relied on measured amounts, management estimates or later adjustments, and identify which figures are provisional and which are final.
- Rounding and presentation of small numbersExplain the rounding rule applied to counts and euro amounts, especially where a small number of cases or a low total fine could change materially after rounding, and keep the method consistent across the table.
- Protecting personal data when the case list is very smallWhere naming or splitting the data would risk identifying individuals, aggregate the figures to a safer level and say that privacy protection affected the way the numbers were grouped.
- Deciding whether one matter can lead to more than one metric entryClarify your rule for cases that end in both a conviction and a penalty, or in several penalties from the same matter, so users can see whether the counts and euro total reflect each outcome separately or only once.
Voorbeelden
Hoe het op de pagina leest
Synthetisch, geschreven door LRA — niet afkomstig uit een bedrijfsrapport en geen tekst uit een standaard.
during the reporting period, we recorded 3 convictions and 5 sanctions linked to business conduct matters, with total fines of €420,000. This example is internally consistent and shown for training purposes only.
Illustrative conduct outcomes for the period (count / €)
| Measure | Count |
|---|---|
| Convictions | 3 |
| Sanctions | 5 |
Shows how to present the count of convictions, the count of sanctions, and the combined monetary amount of fines in a concise quantitative note.
in our group, the period included 1 conviction and 2 sanctions, and the related fines came to €75,000. The figures below are illustrative, internally consistent, and provided for practitioner training.
Illustrative conduct outcomes for the period (count / €)
| Measure | Count |
|---|---|
| Convictions | 1 |
| Sanctions | 2 |
Shows the same three data points for a different reporter and sector, using a separate synthetic fact pattern.
Kwaliteitsladder
- Basis
We recorded 2 convictions, 3 sanctions and €150,000 in fines.
- Beter
We recorded 2 convictions, 3 sanctions and €150,000 in fines across our group this year, based on closed cases.
- Best
We recorded 2 convictions, 3 sanctions and €150,000 in fines across our group this year, based on closed cases; the total was higher than last year because two legacy matters were resolved during the period.
Toets uw begrip
Scenario’s om door te werken
A group’s legal team confirms that one overseas subsidiary was convicted in the reporting year for a bribery-related offence, and a separate regulator issued a financial penalty in the same year for a different anti-corruption breach. The finance team is preparing the year-end disclosure and has to decide how to count each outcome.
A preparer has two matters on file: one ended with a conviction and a fine, while the other ended with a warning letter and no court case. The draft note currently lists both matters under the same heading because both relate to bribery concerns.
During consolidation, one business unit reports a bribery conviction in local currency and another reports a sanction with no monetary amount attached. The group reporting team is unsure whether to leave the euro total blank until all subsidiaries have replied.
A sustainability analyst finds an internal spreadsheet showing three bribery-related court outcomes, but one was overturned before the reporting date and another was still under appeal at year-end. The draft disclosure currently includes all three because they were all mentioned in incident logs.
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Ontvang praktische antwoorden die passen bij uw rapportagecontext.
Controleer je tekst
Plak één of twee alinea’s. Het fragment wordt alleen voor deze controle gebruikt en niet in uw gesprek opgeslagen.
De vergelijking gebruikt voorbeelden op deze kaart, niet hun prevalentie in het rapportcorpus.
Advies, geen assurance
Verwijzingen naar het raamwerk
Relevante ESRS-vereisten en verwante disclosures
ESRS
G1-4
binnen ESRS G1: Business Conduct
Guides that settle this question
Gerelateerd & verkennen
Meer in ESRS G1 →Volledige catalogus bekijken →Zoeken in alle disclosures →
FAQ
Vragen die deze pagina beantwoordt
The page says to prepare three datapoints: conviction count, sanction count and total fines amount. Use the step-by-step preparation section to turn those into a draft and keep the evidence pack ready for review.
Use the page’s plain-language explainer and preparation steps to decide what sits in scope before you collect figures. The page does not set a formal scope rule, so you need to apply the guidance consistently and document your approach.
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source, check and explain the figures. The workbook is there to help assign and track those responsibilities.
The page includes an evidence pack with five items and five assurance claims to verify, each framed around claim, risk and evidence. Use those together so you can show where each number came from and how it was checked.
The page says there are five claims to verify, each linked to a risk and evidence point. In practice, use them as a checklist to test whether the disclosure is complete, accurate and supported before it goes into a report.
The page lists common reporting gaps and mistakes, so it is meant to help you spot issues before drafting. Use that section to check for missing datapoints, weak evidence or inconsistent treatment across the disclosure.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, track evidence and support the step-by-step preparation process.
The Download Centre includes a printable Library Card in PDF format. It is there as a practical reference alongside the workbook, so you can keep the key preparation and assurance points to hand while drafting.
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table, to show how the disclosure can be presented. Treat it as a format guide only and make sure your own numbers and narrative match your actual evidence.
The draft-output section gives visualisation ideas, narrative starters and a content-index line. Use those prompts to turn the prepared figures into a clear draft, then check it against the evidence pack and assurance claims.
Meer vragen waarbij deze pagina helpt