GRI Workforce Disclosure Strategy
GRI workforce disclosures span multiple standards — GRI 401 (employment), GRI 403 (health and safety), GRI 404 (training), GRI 405 (diversity), GRI 406 (non-discrimination), and GRI 407 (freedom of association). Building an integrated workforce disclosure strategy that satisfies all relevant standards — and aligns with ESRS S1 — is more efficient than addressing each standard separately.
GRI workforce disclosures span multiple standards — GRI 401 (employment), GRI 403 (health and safety), GRI 404 (training), GRI 405 (diversity), GRI 406 (non-discrimination), and GRI 407 (freedom of association). GRI workforce disclosures are spread across six Topic Standards — but the underlying data comes from one or two primary systems (HRIS and H&S management).
Integrating GRI workforce standards — the efficiency approach
GRI workforce disclosures are spread across six Topic Standards — but the underlying data comes from one or two primary systems (HRIS and H&S management). Building an integrated workforce data architecture that serves all six standards simultaneously is significantly more efficient than addressing each separately.
Headcount data (GRI 401 → ESRS S1-6): Total employees by employment type (full-time, part-time), employment contract (permanent, temporary), and gender. Also: new hires (by age, gender, region) and departures (by age, gender, region) for turnover calculation.
H&S data (GRI 403 → ESRS S1-14): Fatalities, recordable injuries, lost time injuries, lost days, work-related illness — separately for employees and supervised workers.
Training data (GRI 404 → ESRS S1-13): Average training hours per employee per year; percentage of employees receiving performance reviews; skills development programme descriptions.
Diversity data (GRI 405 → ESRS S1-6, S1-12): Headcount breakdown by gender and age group by employee category; gender pay gap (ratio of average male to female remuneration by employee category).
Grievance data (GRI 406 → ESRS S1-17): Confirmed discrimination incidents and status; H&S grievances where relevant.
Collective bargaining (GRI 407 → ESRS S1-5): Percentage of employees covered by collective bargaining agreements; operations at risk of violations of freedom of association rights.
For CSRD companies also using GRI: your ESRS S1 data collection covers all six GRI workforce standards with minor additions (GRI-specific breakdowns or formats). Collect ESRS S1 data first and extract GRI disclosures from the same dataset.
GRI 407 Freedom of Association — the often-omitted standard
GRI 407 (Freedom of Association and Collective Bargaining 2016) is one of the most commonly omitted GRI workforce standards — either because companies believe it is not material or because they have not assessed operations for risk.
What GRI 407-1 requires: Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk; measures taken by the organisation to support these rights.
Why it is material: Freedom of association — the right of workers to form and join trade unions — is a fundamental ILO Core Convention right. It is restricted in many countries where global supply chains operate, including China, Vietnam, and several other major manufacturing economies. Companies sourcing from these regions have operations at risk under GRI 407.
For companies with EU-based operations only: freedom of association rights are protected by law across the EU. For own-operations-only assessment, GRI 407 may have low materiality. But for companies with supply chains in high-risk geographies — which includes most large manufacturers and retailers — 407-1 requires disclosure of supply chain operations at risk.
Mapping to ESRS S1 and S2: GRI 407 freedom of association connects to ESRS S1-5 (collective bargaining coverage for own workforce) and ESRS S2-1 (policies for value chain workers including freedom of association commitments). Collect ESRS S1-5 collective bargaining data — it directly satisfies GRI 407-1 for own workforce. Supplement with supply chain freedom of association assessment for GRI 407-1 value chain coverage.
Consistent definitions across GRI workforce standards
The most common GRI workforce reporting error is inconsistent definitions across standards — using 'employees' in GRI 401 to mean FTE, 'employees' in GRI 403 to mean headcount, and 'employees' in GRI 405 to mean something else entirely. This creates internal inconsistencies that assurers flag and sophisticated readers notice.
Define once, apply consistently: Before beginning data collection, define: employee (employment contract holder); full-time equivalent (FTE) vs headcount; supervised worker (for GRI 403); gender categories; employee categories (management, professional, administrative, production — or your specific categorisation); and region definitions (for geographic breakdowns).
Document definitions in the methodology note: Publish your definitions in the sustainability report's methodology or basis for preparation section. This allows readers to understand your counting approach and enables meaningful comparison with peer companies that may use different definitions.
For ESRS S1 alignment: ESRS S1 requires disclosure of the definition of employee, FTE methodology, and the basis for non-employee worker counting. Build your ESRS S1 methodology note first — then apply the same definitions to all GRI workforce standards. Consistent definitions across both frameworks prevents the most common workforce data quality problem.
Frequently asked questions
Do we need to report all six GRI workforce standards?
Only for material topics. GRI 3 materiality determines which topics require disclosure. For most companies with significant workforces, GRI 401 (employment), GRI 403 (H&S), and GRI 404 (training) will be material. GRI 405 (diversity) is typically material for large companies. GRI 406 (non-discrimination) and GRI 407 (freedom of association) materiality depends on sector and geography of operations.
We have a complex contingent workforce — how do we handle GRI reporting?
GRI 401 covers direct employees (employment contracts). GRI 403 covers employees AND supervised workers (contractors under your supervision). GRI 407 covers own operations and supply chain. Define your categories clearly — which worker types are employees, which are supervised workers, which are independent contractors. Apply these definitions consistently across all workforce standards and document them in your methodology note.
How do we handle workforce data across acquisitions completed mid-year?
Acquired entities are typically included in the consolidated workforce disclosure from the date of acquisition. Disclose the acquisition date and its impact on year-on-year comparability — for example, note that headcount increased by X% due to Acquisition Y completed in Month Z. For H&S metrics where TRIR is rate-based, use weighted average hours worked including the acquired entity from acquisition date.