GRI 405 Diversity & Equal Opportunity
GRI 405 covers diversity of governance bodies and employees — gender, age group, and other diversity indicators. Combined with GRI 406 (non-discrimination), it forms the core of GRI social diversity reporting. It maps directly to ESRS S1 workforce composition requirements.
GRI 405 covers diversity of governance bodies and employees — gender, age group, and other diversity indicators. 405-1 Diversity of governance bodies and employees: Percentage of individuals in governance bodies by gender, age group (under 30, 30–50, over 50), and other diversity indicators (minority groups, vulnerable groups) where relevant and legally permissible.
The two GRI 405 disclosures
405-1 Diversity of governance bodies and employees: Percentage of individuals in governance bodies by gender, age group (under 30, 30–50, over 50), and other diversity indicators (minority groups, vulnerable groups) where relevant and legally permissible.
For employees: same breakdown by gender and age group, split by employee category (senior management, middle management etc.).
405-2 Ratio of basic salary and remuneration of women to men: Ratio by employee category at significant locations of operation. This is the gender pay gap — expressed as a ratio (e.g. 0.92 means women earn 92% of what men earn at the same level).
GRI 405 vs ESRS S1 diversity requirements
ESRS S1-6 requires headcount by gender and by country — partially satisfying GRI 405-1 governance body data requires separate collection.
ESRS S1-12 requires the gender pay gap — the unadjusted gap between average male and female remuneration. This corresponds to GRI 405-2 but uses a different calculation method: ESRS S1-12 uses average remuneration, GRI 405-2 uses basic salary ratio by category.
Both metrics are required if you report both frameworks. They measure slightly different things — GRI 405-2 is category-adjusted (within-grade comparison) while ESRS S1-12 is unadjusted (whole workforce average). Both are important for understanding different dimensions of pay equity.
Legal constraints on diversity data collection
Collecting diversity data beyond gender and age can face legal restrictions in some jurisdictions. In Germany, France, and several other EU countries, collecting ethnic origin or disability data from employees is restricted without explicit consent and legitimate purpose.
GRI 405 acknowledges this — the standard allows organisations to report 'where legally permissible'. If you cannot collect certain diversity data due to local law, disclose this constraint in your methodology note.
For global companies: adopt a consistent minimum data set (gender, age group) collected everywhere, and supplement with additional indicators in jurisdictions where collection is permitted.
Frequently asked questions
Does GRI 405-2 require equal pay analysis or just the raw gap?
GRI 405-2 requires the ratio of basic salary by employee category — this is a within-category comparison that partially controls for role level. It does not require a full equal pay audit (which would control for all factors). The ESRS S1-12 unadjusted gap and GRI 405-2 category ratio together provide a more complete picture.
How do we handle non-binary gender categories in GRI 405?
GRI 405 uses binary male/female categories in the disclosure format but notes that organisations may disclose additional gender categories where relevant. Report your non-binary or prefer-not-to-say headcount separately and explain your approach in the methodology note.
What governance bodies does GRI 405-1 cover?
The highest governance body (board of directors or equivalent) and any committees with sustainability oversight. For companies with supervisory and management boards (common in Germany and Netherlands), both boards should be covered.