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GRI Training Partner GRI 2 · General Disclosures · Disclosure GRI 2-8

Workers who are not employees

GRI 2-8 · mandatory · metrics + narrative

Disclosure 2-8 requires the total number of workers who are not employees and whose work is controlled by the organisation. Payroll status is not the test. First determine whether the individual lacks an employment relationship with the reporting organisation under national law or practice; then determine whether the organisation controls the work.

Kern van de disclosure

Control of work means that the organisation directs the work performed or controls the means or methods used to perform it. Control can be exercised solely by the organisation or shared with another organisation, such as a supplier, customer, employment agency, contractor or joint-venture partner. Explain how the control assessment was made.

The disclosure covers all qualifying workers performing work for the entities included in sustainability reporting under Disclosure 2-2. Start with those entities, remove employees reported under Disclosure 2-7, assess control for the remaining workers and remove duplicates across agency, procurement, access and timesheet systems.

Agency workers, apprentices, contractors, home workers, interns, self-employed persons, subcontractors and volunteers are possible examples, not automatic classifications. Labels such as temporary, seasonal, casual or outsourced do not determine employee status or control. Supplier personnel are outside the total when the organisation controls only the service outcome and not their work, means or methods.

Report the total number and describe the most common worker types, their contractual relationship with the organisation and the work they perform. State whether relationships are direct or indirect through a third party and identify the type of third party. A general description is sufficient; a quantitative breakdown by worker type is optional additional transparency.

Describe whether the total is headcount, FTE or another measure and whether it represents period end, an average or another timing basis. Do not add incomparable units without conversion or clear explanation. If exact figures are not available, the organisation can report to the nearest ten, or to the nearest hundred where the number is greater than 1,000, and must explain the estimation method and its limitations.

Describe significant fluctuations during and between reporting periods and report the threshold used to determine significance. If none occurred, a brief direct statement is sufficient. Explaining drivers such as seasonality, major projects or outsourcing changes is useful context but not a separate requirement.

If all workers performing work for the organisation are employees and there are no workers who are not employees, a brief statement confirming this is sufficient.

Reasons for omission are permitted for Disclosure 2-8. An informal exclusion note or a claim that a group is not material is insufficient. Identify the unmet requirement and use a permitted reason—Not applicable, Legal prohibitions, Confidentiality constraints, or Information unavailable / incomplete—with the explanation required by GRI 1 in the content index.

The five datapoints below are an LRA operational decomposition of the three requirements in Disclosure 2-8. They are not five separate GRI requirements.

Dit educatieve materiaal van LRA ondersteunt het opstellen van de disclosure. Raadpleeg voor de exacte vereisten altijd de officiële GRI-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.

  • Total, common worker types and contractual relationships

    HR / Procurement / Operations

    Report the total number of workers who are not employees and whose work is controlled by the organisation. Describe the most common worker types and whether each relationship is direct or indirect through an identified type of third party, such as an employment agency, contractor or subcontractor. If exact figures are not available, the organisation can report to the nearest ten, or to the nearest hundred where the number is greater than 1,000, and must explain the estimation method and its limitations.

    Bewijs GRI 2-2 entity list, GRI 2-7 employee population, employment-status and control assessments, agency rosters, contractor registers and unique-worker reconciliation.

    Let op People are included because they are off payroll, agency, temporary, seasonal, contracted or on site without testing both employment relationship and control of work.

  • Work performed by the most common worker types

    HR / Procurement / Operations

    Describe the work performed by the most common types of workers included in the total. A general description is sufficient; a numerical split by worker type is optional additional information, not a separate GRI requirement.

    Bewijs Statements of work, role descriptions, supplier agreements, operational manager attestations and the approved worker-type mapping.

    Let op Contract labels replace the description of actual work, or an optional numerical split is presented as mandatory while contractual relationships remain unexplained.

  • Counting methodology

    HR / Procurement / Operations

    State whether the total is reported in headcount, FTE or another measure, explain assumptions and estimates, and ensure different units are not added into one total without conversion or explanation.

    Bewijs Approved counting methodology, source extracts, duplicate-removal logic, FTE calculation and estimation method where used.

    Let op Headcount, FTE and unique annual persons are mechanically added, or an estimate is reported without its method and limitations.

  • Timing methodology

    HR / Procurement / Operations

    State whether the total is measured at period end, as an average across the reporting period or using another approach. Apply the basis consistently or identify and explain differences.

    Bewijs Dated rosters, access records, monthly snapshots, averaging calculation and methodology approval.

    Let op Period-end, average and anyone-active-during-the-year populations are combined as though directly comparable.

  • Significant fluctuations

    HR / Procurement / Operations

    Describe significant fluctuations during and between reporting periods, report the threshold used to determine significance and, where useful, explain principal drivers. State directly if none occurred.

    Bewijs Approved threshold, monthly worker trend, project and supplier changes, acquisitions/disposals and a reconciliation of movement drivers.

    Let op The disclosure uses an undefined material-change test, omits the threshold or leaves significant movements unexplained and unreconciled.

Voordat u begint

  • Have you started from every entity included under GRI 2-2 and removed confirmed GRI 2-7 employees?
  • Has employment status been assessed under national law or practice rather than payroll or supplier labels?
  • For each possible group, have you tested both direction of work and control of means or methods, including shared control?
  • Are independent supplier personnel excluded only after a documented control assessment?
  • Can direct and indirect contractual relationships, third-party types and actual work performed be described?
  • Have agency, procurement, access and timesheet records been deduplicated into one comparable total?
  • Are counting, timing, estimates, significant-fluctuation threshold and any reasons for omission documented?
  • If exact figures are not available, will the organisation report to the nearest ten, or to the nearest hundred where the number is greater than 1,000, and explain the estimation method and its limitations?
  • If all workers are employees, can the organisation support the brief no-workers statement?
+ Subelementen van GRI 2-8 tonen (LRA-werkchecklist)

Hoe u dit voorbereidt

Start with every GRI 2-2 reporting entity and reconcile all people performing work to the GRI 2-7 employee population.
For remaining people, assess the employment relationship under national law or practice. Do not classify from payroll, temporary, seasonal, casual, agency, contractor or outsourced labels alone.
Assess whether the organisation directs the work or controls the means or methods, solely or jointly. Retain evidence and exclude independent supplier workers where only the service outcome is controlled.
Describe the most common included worker types, their direct or indirect contractual relationships, the relevant third-party types and the work performed. Treat a numerical split by type as optional.
Reconcile agency, procurement, access, timesheet and project records, remove duplicates and calculate one comparable total in headcount, FTE or another explained unit.
Document period-end, average or other timing, and explain any estimate to the GRI rounding level together with assumptions and limitations.
Set and disclose the significant-fluctuation threshold, analyse movements and state directly when none occurred. If all workers are employees, use the brief statement permitted by GRI Guidance.
Report zero or the truthful no-workers statement where applicable. For an unmet requirement, use a permitted reason for omission and the required GRI content-index explanation rather than an informal exclusion.

De gegevens opvragen

Identify workers who are not employees and assess control of work

Vertaal de disclosure naar een interne bedrijfsvraag — en pas die daarna aan op het taalgebruik van uw organisatie.

Across the GRI 2-2 entities, which people are not employees, whose work does the organisation direct or whose means or methods does it control, and how should the resulting population, relationships, work, methods and fluctuations be reported?

Do not request a generic list of contractors or non-payroll people. Ask separately about employment relationship, direct or indirect contractual relationship, the third party, direction of work, control of means or methods, shared control and actual work performed.

Zwak verzoek

Please send all non-payroll and contractor numbers.

Waarom dit misgaat: It treats payroll and contract labels as classification rules and does not test employment relationship, control of work, duplicates, contractual relationship, work performed or methodology.

Beter verzoek

For every GRI 2-2 entity, identify non-employees and document whether the organisation directs their work or controls its means or methods, including shared control. Reconcile the qualifying population in one unit and describe relationships, work, methods and fluctuations.

Sjabloon voor een formele e-mail
Subject: GRI 2-8 worker population and control assessment for [period]

Dear [name/team],

For every entity reported under GRI 2-2, please provide records of individuals performing work who are not included in the confirmed GRI 2-7 employee population. For each common group, identify the employment status, direct or indirect contractual relationship, relevant third-party type, work performed, who directs the work, who controls the means or methods, and whether control is shared.

Please also provide the source systems, duplicate-removal logic, total in a consistent unit, headcount/FTE method, period-end/average basis, estimates, significant-fluctuation threshold and movement analysis. Do not classify people solely as contractor, temporary, seasonal, casual, agency or outsourced.

Many thanks,
[preparer name]
Korte versie voor Teams / Slack
Please provide the GRI 2-8 assessment for all GRI 2-2 entities: non-employee status, direction or control of means/methods, direct/indirect relationship and third party, work performed, reconciled total, methodology and significant fluctuations.

Sectorvoorbeelden

Construction

Context. Agency labour, subcontractors and self-employed trades on project sites.

Aangepast verzoek. For each worker group, identify the legal employer, who sequences and directs work, who sets work methods and equipment, whether control is shared, the direct or indirect relationship and the work performed.

Voorbeeldantwoord. The project team returns a control matrix; independent subcontractor teams controlling their own methods are separated from workers whose work methods the organisation controls.

Retail and logistics

Context. Warehouse support from agencies and logistics providers.

Aangepast verzoek. Separate temporary employees under GRI 2-7 from agency warehouse workers and provider employees. For non-employees, document direction, control of means or methods, third party and counting basis.

Voorbeeldantwoord. Agency workers under shared operational control enter GRI 2-8; independent logistics-provider personnel remain outside after documented assessment.

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 the GRI 2-2 entity scope, GRI 2-7 employee comparator, employment-status and control tests, duplicate-removal rules, unit, timing and any estimate.

Contextnotitie

Describe common worker types, direct or indirect relationships, third-party types and work performed; explain why possible categories are included or excluded under the control test.

Toelichting op schommelingen

State the significant-fluctuation threshold and qualifying changes, or state directly that none occurred. Keep optional driver explanations distinct from the three formal requirements.

Vermelding in de inhoudsindex

GRI 2-8 Workers who are not employees — [location/page]. For any unmet requirement: [requirement] — [permitted reason for omission] — [required explanation].

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Controleren

Controleer bij elke bewering het bewijs

  • The reporting population covers all entities included under GRI 2-2.

    Risico A reporting entity or controlled worker population is missing.

    Te controleren bewijs GRI 2-2 entity list and entity-to-worker-source reconciliation.

  • Employees and workers who are not employees are distinguished correctly.

    Risico An employee is excluded from GRI 2-7 or double-counted in GRI 2-8.

    Te controleren bewijs GRI 2-7 employee extract and employment-status assessment.

  • Employment relationship is assessed under national law or practice.

    Risico Payroll or supplier labels are used as the legal-status test.

    Te controleren bewijs Country legal assessment and HR/Legal approval.

  • Control of work is documented for each common worker type.

    Risico Day-to-day direction is treated as the only control criterion.

    Te controleren bewijs Control matrix covering direction and control of means or methods, including shared control.

  • Independent supplier workers are not included solely because they are on site.

    Risico Worksite presence is confused with control of work.

    Te controleren bewijs Supplier agreements, statements of work and operational control assessment.

  • The total reconciles to source systems.

    Risico The reported number cannot be traced to rosters, access systems or procurement records.

    Te controleren bewijs Source extracts and total reconciliation.

  • Duplicates across worker sources are removed.

    Risico The same person appears in agency rosters, access records and supplier files.

    Te controleren bewijs Unique-worker matching rules and duplicate exception log.

  • The most common worker types, relationships and work performed are described.

    Risico A total is reported without the required general description.

    Te controleren bewijs Approved worker-type and work-performed narrative.

  • Direct and indirect relationships and relevant third parties are identified.

    Risico A generic supplier relationship obscures how workers are engaged.

    Te controleren bewijs Contracts, agency agreements and third-party mapping.

  • Counting and timing methodologies are stated.

    Risico Headcount/FTE or period-end/average is unclear or inconsistent.

    Te controleren bewijs Approved methodology and dated calculation.

  • Estimates are identified and explained.

    Risico An estimate is treated as exact or rejected despite unavailable exact data.

    Te controleren bewijs Estimation method, sources, assumptions and limitations.

  • Significant fluctuations use a documented threshold.

    Risico Changes are selected through an undefined materiality judgement.

    Te controleren bewijs Approved threshold and movement analysis.

  • A direct statement is made when no significant fluctuations occurred.

    Risico Silence is mistaken for a no-fluctuation statement.

    Te controleren bewijs Approved disclosure and trend analysis.

  • Any unmet requirement uses a permitted reason for omission.

    Risico A worker group is excluded as immaterial or through an informal methodology note.

    Te controleren bewijs GRI content index and required omission explanation.

Voor te bereiden bewijsdossier

Veelvoorkomende hiaten in de rapportage

  • ‘Non-payroll workers’ is used as the GRI 2-8 population even though payroll does not determine the employment relationship.
  • All contractors are automatically included, or all outsourced workers are automatically excluded, without a control assessment.
  • Agency workers are labelled temporary employees without checking which organisation is the employer.
  • Seasonal or casual status is treated as proof that a person is not an employee.
  • Control is tested only through day-to-day instructions, ignoring control over the means or methods of work and shared control.
  • The disclosure does not explain how control of work was determined.
  • Direct and indirect contractual relationships or the relevant third-party type are not described.
  • Headcount, FTE and unique annual persons are added into a total with no common unit or explanation.
  • A period-end figure is presented without explaining major seasonal variation.
  • An estimate is rejected or presented without the estimation method and limitations.
  • ‘Material changes’ is used instead of significant fluctuations and no threshold is reported.
  • There is no direct statement when all workers are employees or when no significant fluctuations occurred.
  • An exclusion is recorded only as an internal methodology choice instead of a formal reason for omission.

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

  • ‘Non-payroll workers’ is used as the GRI 2-8 population even though payroll does not determine the employment relationship‘Non-payroll workers’ is used as the GRI 2-8 population even though payroll does not determine the employment relationship.
  • All contractors are automatically included, or all outsourced workers are automatically excluded, without a control assessmentAll contractors are automatically included, or all outsourced workers are automatically excluded, without a control assessment.
  • Agency workers are labelled temporary employees without checking which organisation is the employerAgency workers are labelled temporary employees without checking which organisation is the employer.
  • Seasonal or casual status is treated as proof that a person is not an employeeSeasonal or casual status is treated as proof that a person is not an employee.
+ Nog 4 tonen

Oordeel vereist

  • Supplier personnel on sitePresence is not enough. Determine whether the organisation controls their work, means or methods rather than only the contracted service outcome.
  • Temporary and seasonal workersFirst determine whether they are employees under GRI 2-7, agency workers potentially under GRI 2-8, or independent provider personnel.
  • Shared controlDocument how control is divided with an agency, contractor, customer, supplier or joint-venture partner.
  • Different source unitsDo not add headcount, FTE and unique annual persons without conversion; explain separate measures or use a reason for omission where required.
+ Nog 2 tonen

Voorbeelden

Hoe het op de pagina leest

Synthetisch, geschreven door LRA — niet afkomstig uit een bedrijfsrapport en geen tekst uit een standaard.

Illustrative (synthetic) example — controlled workers who are not employees

Across the GRI 2-2 reporting entities, the organisation identified people without an employment relationship and assessed whether it directed their work or controlled the means or methods used. The total is average monthly headcount for 2025. The numerical split by type is optional additional information.

Optional worker-type detail supporting a required total of 180 (workers)

Worker typeRelationshipControl basisWork performedAverage headcount
Agency cleanersIndirect — cleaning agencyShared control of methods and shiftsCleaning and hygiene80
Security personnelIndirect — security contractorShared control of site proceduresAccess control and security40
Self-employed techniciansDirect service contractsOrganisation specifies installation methodsEquipment installation20
Site logistics workersIndirect — logistics contractorOrganisation controls sequencing and methodsInternal materials movement40

Agency cleaners and security personnel are included because work methods, site procedures and scheduling are controlled jointly with service providers. Self-employed technicians are directly engaged and follow organisation-specified installation methods. Equipment-supplier technicians performing standard maintenance under the supplier’s own methods are excluded. The threshold is 20% or 25 workers; no significant fluctuation occurred.

Illustrative (synthetic) example — all workers are employees

After reconciling all GRI 2-2 reporting entities to the GRI 2-7 employee population and assessing external service providers, the organisation concluded that all workers performing work for it are employees. It therefore reports: ‘All workers performing work for the organisation are employees. The organisation has no workers who are not employees and whose work it controls.’

Workers who are not employees and whose work is controlled (workers)

Reported measureHeadcountMethod
Total0Control assessment across all GRI 2-2 entities

External consultancy firms control their own teams and methods; the organisation controls only the service outcomes. The conclusion and control assessment are retained as evidence. A brief truthful no-workers statement is sufficient under GRI Guidance.

Kwaliteitsladder

  • Basis

    We used 180 contractors in 2025.

  • Beter

    We had an average monthly headcount of 180 workers who were not employees and whose work we controlled in 2025.

  • Best

    Across all GRI 2-2 entities, we assessed employment relationship and control of work, reported an average monthly headcount of 180, described the common direct and third-party worker types and work performed, documented duplicate removal and estimates, and applied the stated significant-fluctuation threshold.

Toets uw begrip

Scenario’s om door te werken

Agency cleaners and security-provider personnel work on site.

VAre they automatically in GRI 2-8?
Modelantwoord tonen →

Warehouse pickers are reported in headcount and specialist technicians in FTE.

VCan the values be added?
Modelantwoord tonen →

Period-end headcount is 90, but monthly numbers ranged from 60 to 140.

VWhat should be disclosed?
Modelantwoord tonen →

Workers rose from 200 to 280 after a new engineering project.

VWhat needs checking?
Modelantwoord tonen →

Echte rapporten

How 3 companies report it

Voorbeelden van volledige en gedeeltelijke rapportagepraktijk. Dit zijn op bewijs gebaseerde analyses, geen sjablonen om over te nemen.

Echte gepubliceerde rapporten

Interconexión Eléctrica S.A. E.S.P.

Partial

Electric Utilities / IPP / Energy Traders · Colombia · 2024 · p.132 ↗

Interconexión Eléctrica S.A. E.S.P.'s 2024 Integrated Management Report partially covers the disclosure on total and common worker types and contractual relationships by referencing an Additional Information annex for verification, without providing direct data in the main report (p.132). The report clearly states the counting methodology as full-time equivalent units (p.132), but the timing methodology is unclear, with no specification of period-end or average timing (p.132). Notably, information on significant fluctuations is not found, as the company indicates that comparable and traceable data are unavailable for this aspect (p.132).

REN - Redes Energéticas Nacionais, SGPS, S.A.

Partial

Water Utilities · Portugal · 2025 · p.647 ↗

REN's 2025 Integrated Report partially discloses the total number of full-time equivalent (FTE) workers other than employees, reporting 1,511 FTEs (p.647). However, the report omits details on common worker types, contractual relationships, the type of work performed, the wider consolidation methodology, timing methodology, and any significant fluctuations, citing that this information is unavailable or incomplete as it is managed by hiring departments (p.647). Thus, while the total FTE figure is provided, key contextual and methodological details are missing.

ASE Technology Holding Co., Ltd.

Strong

Semiconductors · Taiwan · 2024 · p.253 ↗

ASE Technology Holding Co., Ltd.'s 2024 CSR Report provides a headcount of 26,964 non-employee workers, detailing common types such as engineering contractors, equipment maintenance, IT contractors, cleaning, janitorial, catering, and convenience-store services, with data broken down by region (p.253). The report explains that these workers are engaged through third-party contractors and notes that the counting methodology is site-dependent, using either workers present at year-end or those who worked during the year (p.253). However, the timing methodology varies across subsidiaries and sites, and while an increase in engineering contractors is noted, the report does not confirm a specific threshold for significant fluctuations (p.253).
VeldInterconexión Eléctrica S.A. E.S.P.REN - Redes Energéticas Nacionais, SGPS, S.A.ASE Technology Holding Co., Ltd.
Total, common worker types and contractual relationshipsGedeeltelijkGedeeltelijkNiet gevonden
Work performed by the most common worker typesGedeeltelijkNiet gevondenNiet gevonden
Counting methodologyNiet gevondenGedeeltelijkNiet gevonden
Timing methodologyGedeeltelijkNiet gevondenGedeeltelijk
Significant fluctuationsNiet gevondenNiet gevondenGedeeltelijk

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Probeer Hoe bereid ik GRI 2-8 voor? Welke gegevens moet ik verzamelen? Waar kan ik een voorbeeld uit een echt rapport zien? Welke fouten moet ik vermijden?

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binnen GRI 2: General Disclosures

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FAQ

Vragen die deze pagina beantwoordt

Who belongs in GRI 2-8?+
Does off-payroll status determine the population?+
How is control of work determined?+
Are agency, contractor or outsourced workers automatically included?+
Must we publish a numerical split by worker type?+
What should we report if all workers are employees?+
Can we report an estimate?+
How should different counting methods be handled?+
How do we report significant fluctuations?+
Can a group be excluded because it is not material?+
Hoe deze bibliotheek is opgebouwd 1.211 gepubliceerde rapporten geïndexeerd 315.012 pagina’s met verwijzingen op paginaniveau 272 gepubliceerde kaarten in de actieve catalogus
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