ESRS S1-1 Workforce Policies
ESRS S1-1 requires companies to disclose their policies addressing material impacts on their own workforce — covering human rights, working conditions, and equal treatment. The policy disclosure is the foundation of the entire ESRS S1 section — it sets out the commitments that all subsequent metrics and management approach disclosures are measured against.
ESRS S1-1 requires companies to disclose their policies addressing material impacts on their own workforce — covering human rights, working conditions, and equal treatment. ESRS S1-1 requires disclosure of the policies in place to manage material impacts on the own workforce — covering:.
What ESRS S1-1 requires
ESRS S1-1 requires disclosure of the policies in place to manage material impacts on the own workforce — covering:
Policy content: The topics covered by workforce policies — human rights, health and safety, fair pay, anti-discrimination, freedom of association, working time, data privacy, and any other material working condition topics. Each policy's scope, the standards it references, and the commitments it makes.
Policy coverage: Whether the policies cover all employees globally, specific geographies, or specific employee categories. Where coverage is partial — for example, a policy applying only in certain countries — explain the rationale and the approach to extending coverage.
Board approval and governance: Whether workforce policies have been approved at board or senior governance level. ESRS S1-1 does not explicitly require board approval but it is expected for the most material human rights and working condition commitments. CSDDD Article 5 requires board-approved due diligence policy — for companies subject to both, the S1-1 policy disclosure should confirm board-level endorsement.
International framework alignment: Which international standards are referenced — ILO Core Conventions (on child labour, forced labour, freedom of association, non-discrimination), UN Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights (UNGPs), and OECD Guidelines for Multinational Enterprises.
Annual review: Whether policies are reviewed annually and updated when material changes occur in the company's operations, regulatory environment, or stakeholder expectations.
Core policies to disclose under ESRS S1-1
Most large companies have multiple policies covering different aspects of the own workforce — S1-1 requires disclosure of the most material ones, not necessarily every HR policy in existence.
Human rights policy: A commitment to respect internationally recognised human rights in all operations. Should reference the UNGPs, ILO Core Conventions, and UDHR. Should cover: the scope of commitment (own operations and value chain); governance accountability (board endorsement, senior management responsibility); grievance mechanisms for rights violations; and annual review process.
Code of conduct / business ethics: Employee conduct standards covering: anti-corruption and bribery; conflicts of interest; accurate record-keeping; anti-harassment and respectful workplace; and reporting obligations. Should be signed by all employees on joining and refreshed periodically.
Health and safety policy: Board-approved commitment to worker safety — zero fatality aspiration; compliance with applicable H&S law; H&S management system framework; worker consultation on H&S; and accountability structure. Should cover both employees and supervised workers.
Equal opportunities and anti-discrimination policy: Commitment to fair treatment regardless of protected characteristics; specific procedures for discrimination complaints; positive action commitments where applicable; and board-level diversity and inclusion targets.
Freedom of association policy: Recognition of workers' rights to form and join trade unions and to bargain collectively — even in countries where these rights are legally restricted. The policy commitment goes beyond legal compliance to affirm the principle globally.
Policy quality vs policy quantity
A common S1-1 disclosure error is listing many policies without evidence that they are genuinely implemented and effective. Assurers and sophisticated investors distinguish between paper policies and operational commitments.
Indicators of genuine policy implementation: Annual training completion data on policy content; accessible versions in all relevant languages; regular board and management review with documented outcomes; integration into procurement and supplier qualification criteria; connection to disciplinary procedures for violations; and external stakeholder engagement confirming awareness.
Indicators of paper policies: Policies that have not been updated in multiple years; policies available only in the headquarters language for a multinational workforce; no training data associated with the policy; no governance mechanism for reviewing compliance; and no connection between the policy and the grievance or incident management process.
For the qualitative S1-1 narrative: describe not just which policies exist but how they are operationalised. A single paragraph on the human rights policy backed by training completion data, board approval minutes, and a UNGP alignment assessment is stronger than listing 15 policies with no implementation evidence.
Policy gaps and remediation: Where the S1-1 review reveals gaps — topics not covered by any policy, outdated policies, or policies not extended to all jurisdictions — disclose the gap and the planned remediation. A committed plan to address a disclosed gap is better received than a gap that is not acknowledged.
Frequently asked questions
Do we need separate policies for each S1 topic or can one code of conduct cover everything?
Both approaches are valid. A comprehensive code of conduct or business ethics policy can cover multiple S1 topics — anti-discrimination, anti-harassment, H&S commitment, freedom of association. For topics requiring detailed technical content (H&S management, data privacy, anti-corruption), separate dedicated policies typically provide more appropriate depth. Disclose the approach and ensure all material topics are substantively covered regardless of whether one or many documents are used.
How specific do S1-1 policy disclosures need to be?
Sufficient specificity to allow stakeholders to assess the quality of commitments — not so specific that legally sensitive content or operational details are inadvertently disclosed. Describe the topics covered, the standards referenced, the scope of application, and the governance accountability. You do not need to reproduce the full policy text in the sustainability report — provide a summary and reference where the full policy can be accessed (typically on the company website).
Our workforce is covered by industry-level CBAs that set many employment standards — how do we disclose S1-1?
Reference the collective agreements as the primary source of employment standards for covered workers — these are the binding commitments. Disclose any company-level policies that supplement the CBA (additional H&S commitments, enhanced anti-discrimination provisions, supplementary human rights policy). Clarify which aspects of the workforce are covered by CBA and which by company policy.