GRI 406 Non-Discrimination
GRI 406 requires disclosure of incidents of discrimination and the corrective actions taken. It is one of the shorter GRI topic standards but covers a high-risk area — incidents of discrimination attract regulatory scrutiny and reputational damage disproportionate to their frequency.
GRI 406 requires disclosure of incidents of discrimination and the corrective actions taken. 406-1 Incidents of discrimination and corrective actions taken: Total number of incidents of discrimination during the reporting period; status of each incident — under review, remediation plans implemented, remediation completed and results reviewed.
What GRI 406-1 requires
406-1 Incidents of discrimination and corrective actions taken: Total number of incidents of discrimination during the reporting period; status of each incident — under review, remediation plans implemented, remediation completed and results reviewed.
Discrimination grounds covered: race, colour, sex, religion, political opinion, national extraction, social origin, age, disability, sexual orientation, gender identity, and any other protected characteristic under applicable law.
The disclosure requires both the count of incidents AND their status. Reporting only a number without status is insufficient. Assurers will check that internal HR and legal records support the disclosed count.
Sources of discrimination incident data
Formal HR grievance logs: Complaints filed through formal HR channels that allege discrimination. These are the most common primary source.
Legal proceedings: Employment tribunal claims, EEOC charges (US), or equivalent regulatory filings — these are matters of public record in some jurisdictions.
Whistleblower reports: Anonymous reports through internal ethics hotlines that allege discriminatory conduct.
Exit interviews: Employees citing discriminatory treatment as a reason for leaving — may not result in a formal complaint but represent a material data point.
For GRI 406, only formally recorded incidents with investigation status are typically included in the count. Define your incident scope clearly in the methodology.
Reporting zero incidents — the credibility question
Many companies report zero discrimination incidents. This is credible only if: you have accessible reporting mechanisms; employees are aware of them; incidents are properly investigated; and your workforce size is consistent with low incident counts.
A large company with thousands of employees reporting zero discrimination incidents over multiple years will attract assurer scrutiny. The absence of formal complaints is not the same as the absence of discrimination.
Best practice: disclose the number of formal complaints AND contextualise with data on grievance channel awareness, usage rates, and outcome trends. This demonstrates a functioning speak-up culture rather than suppressed reporting.
Frequently asked questions
Do we include incidents involving contractors in GRI 406-1?
GRI 406 covers employees. Discrimination incidents involving contractors in your value chain are covered by GRI 414 (Supplier Social Assessment) or ESRS S2 (workers in the value chain), not GRI 406.
What if a discrimination incident is subject to legal confidentiality?
Disclose the number of incidents and their status category without identifying details. Confidentiality of individual cases does not prevent aggregate disclosure. If all incidents are sub judice, note this in the status column.
How does GRI 406 relate to ESRS S1?
ESRS S1 does not have a direct equivalent to GRI 406-1 incident count. ESRS S1 covers working conditions and equal treatment qualitatively through policies and targets. Some assurers map GRI 406-1 data to ESRS S1 as supplementary evidence of workplace culture.