17. The undertaking shall describe the key actions and resources used to manage its material positive and negative impacts, risks and opportunities related to workers in the value chain in accordance with ESRS 2 GDR-A.

18. In relation to material negative impacts on workers in the value chain, the undertaking shall describe:

19. For the sub-topics assessed as material for this Standard, subject to the relevant privacy regulation, the undertaking shall disclose human rights incidents connected to workers in the value chain identified in the reporting period.

AR 4 for para. 18 (Key actions)
The actions taken by the undertaking differ depending on its connection to the impact and how it has identified the actions as appropriate for addressing material impacts.
This disclosure requirement also applies to key actions to provide, cooperate in, or enable remediation in cases of actual negative impacts. Key actions to prevent, mitigate, bring to an end, minimise or remediate impacts include the use of different types of leverage or collective actions taken through multi-stakeholder or industry initiatives.

AR 5 for para. 18 (Climate transition)
The undertaking shall present its actions in a way that allows an understanding of the connections that exist between different topics, in accordance with Chapters 3.3 and 9.1 of ESRS 1 General Requirements. This applies to measures taken to mitigate negative impacts on its workers in the value chain that arise from the transition to a low-carbon and climate-resilient economy. For example, innovation and restructuring can lead to mine closures or increased mining of minerals needed for the transition to a sustainable economy. Conversely, positive impacts may arise from initiatives such as updating purchasing practices or training supply chain workers. Other examples include current and/or expected external developments that influence dependencies that are sources of just transition risks.

AR 6 for para. 19 (Human rights incidents)
The human rights incidents in scope for this disclosure are those that relate to not respecting internationally recognised human rights as defined in Directive (EU) 2022/2464 (CSRD), Art. 29b (2) (b) (iii). These incidents are understood as the substantiated instances registered by the undertaking of:

For the purpose of this disclosure, only substantiated and verified instances are to be reported. An instance is substantiated when it is evidenced by objective, factual and verifiable information. An instance is verified when a Court, the OECD or an administrative authority has made a formal finding that the instance occurred. Not all ongoing judicial or non-judicial proceedings, and not all other instances registered by the undertaking, are necessarily substantiated instances.

AR 7 for para. 19 (Human rights incidents)
When applying the filter of information materiality (paragraph 23 of ESRS 1 General Requirements) to the information about incidents referred to under paragraph 19, the undertaking's assessment is primarily based on the severity of the impacts on its workers in the value chain.

AR 8 for para. 19 (Human rights incidents)
The undertaking is not expected to disclose a list of each human rights incident, and may aggregate the information provided, such as by relevant types of incidents and/or workers in the value chain affected.

AR 9 for para. 19 (Cross-referencing)
If the undertaking considers that changes in human rights incidents are relevant for understanding the effectiveness and availability of channels to raise concerns or needs, including grievance mechanisms, it may cross-reference paragraph 19 and paragraph 15.
The way the undertaking has addressed or is addressing human rights incidents may be cross-referenced to information disclosed in accordance with paragraph 18.