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S1-1 - Policies relating to the organization's workforce

Updated over 5 months ago

ESRS Standard

17 The entity shall disclose its policies for managing its material impacts on its own workforce/own workers and the associated material risks and opportunities.

18 The objective of this disclosure requirement is to provide an understanding of the extent to which the entity has policies in place to address the identification, assessment, management and/or improvement of material impacts specifically on the entity's workforce, as well as policies that cover material impacts, risks and opportunities associated with the entity's workforce.

19. the disclosures required by paragraph 17 shall include information on the policies the company applies to manage its Own workforce/own workers' Impact materiality, Risks and Opportunities in accordance with the ESRS 2 MDR-P Approaches to managing Material Sustainability Aspects. In addition, the company indicates whether these policies cover specific groups within its workforce or its entire workforce.

20 The company describes its human rights policy commitments (96) relevant to its own workforce/own workers, including processes and mechanisms for monitoring compliance with the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises (97). In its disclosures, it focuses on the aspects that are material to, and its general approach to, the following:

  • (a) respect for human rights, including labor rights, of the company's workforce,

  • b) the inclusion of people from the company's own workforce; and

  • c) Actions to address and/or enable remediation of human rights impacts.

21 The company shall indicate whether and to what extent its policies in relation to its own workforce/own workers are in line with relevant internationally recognized instruments, including the United Nations Guiding Principles on Business and Human Rights (98).

For application requirements, see AR 12

22 The company indicates whether its policies regarding its own workforce/own workers explicitly address human trafficking (99), Forced labour and Child labour.

23 The company shall indicate whether it has a policy or management system for the prevention of occupational accidents (100).

24. the company shall indicate the following:

  • (a) whether it has specific policies aimed at eliminating Discrimination (including Harassment), promoting Equal opportunities and other ways to promote diversity and inclusion,

  • (b) whether the following grounds of Discrimination are explicitly covered by the policies: Race and ethnic origin, color, gender, sexual orientation, gender identity, disability, age, religion, political opinion, national origin or social origin, and other forms of discrimination covered by EU and national law,

  • (c) whether the company has specific policy commitments on inclusion or affirmative action for people from groups that are particularly vulnerable in its own workforce, and if so, what these commitments are; and

  • d) whether and how these policies are implemented through specific procedures to ensure that Discrimination is prevented, mitigated and addressed as soon as it is identified and to promote diversity and inclusion in general.

For application requirements see AR 15 - AR 16


Application Requirements (AR)

AR 10 The company shall consider whether explanations of material changes to policies adopted during the reporting year (e.g. new expectations for foreign subsidiaries, new or additional approaches to due diligence and remediation) provide contextual information to Users and may provide such explanations. This includes policies and commitments by the company to avoid or mitigate the Risks and negative Impacts on individuals in its workforce related to the reduction of carbon emissions and the transition to greener and climate neutral operations, and to create Opportunities for the company's workforce, for example through job creation and upskilling, including explicit commitments to a 'just transition'.

AR 11 The policy may take the form of a stand-alone policy related to the company's workforce or may be included in a broader document such as a code of ethics or a general sustainability policy that the company has already stated as part of another ESRS. In these cases, the company shall provide a specific cross-reference to indicate the aspects of the Policy that meet the requirements of this disclosure requirement.

AR 12 In disclosing the consistency of its policy with the United Nations Guiding Principles on Business and Human Rights, the company shall consider that the Guiding Principles refer to the International Bill of Human Rights, which consists of the Universal Declaration of Human Rights and its two implementing covenants, and the International Labor Organization's Declaration on Fundamental Rights and Principles at Work and its underlying core conventions, and may report on consistency with these underlying standards.

AR 13. in explaining how externally focused policies are incorporated, the company may consider, for example, internal policies on responsible sourcing and alignment with other policies relevant to the company's workforce, such as those related to Forced labour. With respect to the company's codes of conduct towards Suppliers, the company shall indicate whether they contain provisions that address worker safety, precarious employment (i.e. workers on short-term or temporary contracts, workers employed through third parties, subcontracted to third parties or informal workers), human trafficking, Forced labour or Child labour, and whether these provisions are fully compliant with applicable ILO standards.

AR 14 The company may explain the ways in which it communicates its Policy to the individuals, groups of individuals or companies to whom they are relevant, either because they are expected to implement it (e.g. company employees, contractors and suppliers) or because they have a direct interest in its implementation (e.g. individuals in the company's workforce, investors). It may specify means and channels of communication (e.g. flyers, newsletters, dedicated websites, social media, face-to-face interactions, Workers' representatives) to ensure that the Policy is accessible and that the different audiences understand its Impacts. The company can also explain how it identifies and removes potential barriers to dissemination, e.g. by translating it into relevant languages or using graphical representations.

AR 15 Discrimination in employment and occupation occurs when a person is treated differently or less favorably because of characteristics unrelated to merit or the inherent requirements of the job. These characteristics are generally defined in national legislation. In addition to the grounds set out in the disclosure requirement, the company must consider other grounds of discrimination that are prohibited under national law.

AR 16 Discrimination can occur in a wide range of work-related activities. This includes access to employment, certain occupations, training and career guidance, and social benefits. Discrimination may also occur in relation to terms and conditions of employment, e.g. recruitment, Pay, working and rest periods, paid leave, maternity protection, protection against dismissal, work assignments, performance appraisal and development, training opportunities, promotion prospects, health and safety at work, termination of employment. The company may consider these specific areas when disclosing its policies and underlying procedures as part of the relevant disclosure requirement.

AR 17 The company may disclose whether it has implemented the following:

  • (a) Policies and procedures in which qualifications, skills and experience form the basis for recruitment, placement, training and promotion at all levels, while recognizing that some individuals may find it more difficult to acquire such qualifications, skills and experience,

  • b) Establishing responsibilities at management level for Equal treatment and Equal opportunities in recruitment, clear company-wide policies and procedures to guide equal employment practices and linking promotion opportunities to desired performance in this area,

  • c) Employee training onanti-discrimination policies and practices, with a particular focus on middle and senior management, to raise awareness and provide solution strategies to prevent and address systemic and incidental discrimination,

  • d) Making adjustments to the physical environment to ensure the health and safety of workers, customers and other visitors with disabilities,

  • e) assessing whether there is a risk that job requirements have been defined in a way that would systematically disadvantage certain groups,

  • f) Updating records of recruitment, training and promotions that provide a transparent overview of Employee Opportunities and advancement within the organization,

  • g) Establishing procedures for handling complaints, challenges and appeals for employees (particularly in relation to negotiations and collective agreements) where Discrimination has been identified, taking into account formal structures and informal cultural aspects that may prevent employees from raising concerns and complaints; and

  • h) implementing programs to promote access to skills development.


Examples from Installation A.2

This Installation is one of the application requirements for the ESRS S1-1 Policies related to the organization's workforce and is an integral part of the ESRS S1 Organization's workforce. It has the same binding force as the other parts of this standard and supports the application of the ESRS S1-1 Social and Human Rights Disclosures with examples of disclosures.

Social and human rights issues and examples of policies:

  • Safe employment
    No dismissals, limiting the renewal of fixed-term contracts, provision of social security by the employer if there is a lack of state benefits

  • Working hours
    Limitation of Overtime, long and split shifts, night and weekend work, adequate lead time for scheduling

  • Adequate wages
    Policy to ensure that all own workers receive an adequate wage

  • Social dialogue/existence of works councils/workers' rights to information, consultation and co-determination
    Promotion of institutions for Social dialogue, regular information and consultation of Workers' representatives, consultation prior to final decisions on employment-related issues

  • Freedom of association/collective bargaining including the quota of workers covered by collective agreements
    Non-interference in the formation and recruitment of trade unions (including trade union access to companies), negotiations conducted in good faith, reasonable time off for Workers' representatives to perform their duties, facilities and protection against dismissal for Workers' representatives, no discrimination between trade union members and Workers' representatives

  • Work-life balance
    Ability to take time off work for family reasons, flexible working hours, access to daycare facilities for all employees

  • Health and safety
    Coverage of all company employees through a health and safety management system

  • Gender equality and equal Wage for equal work
    Policy on gender equality and equal Wage for equal work

  • Further training and skills development
    Policy to improve the skills and career prospects of employees

  • Employment and inclusion of Persons with disabilities
    Policy on accessible workplaces for Persons with disabilities

  • Actions against violence and Harassment in the workplace
    Policy on zero tolerance of violence and Harassment in the workplace

  • Diversity
    Inclusion policy (for ethnic diversity or minorities) and positive actions

  • Child labour
    Policy to identify places where Child labour occurs, identify places where young employees are exposed to hazardous work and prevent the risk of exposure

  • Forced labour
    Policy to identify places where Forced labour occurs and reduce the risk of exposure to forced labour


Examples from past practice

Examples serve only as an indication of how a disclosure requirement has been reported by other companies to date. Audited ESRS reports are not yet available. There is no guarantee of accuracy and completeness.

S1-1 - Strategies related to labor

Policy on human rights and labor standards

The Policy emphasizes our commitment to meeting and, where possible, exceeding all applicable social and ethical obligations. We fully support all internationally recognized human rights and the principles set out in the Universal Declaration of Human Rights (UDHR), the United Nations Global Compact (UNGC), the OECD Guidelines and the Declaration on Fundamental Principles and Rights at Work (ILO). We attach great importance to the satisfaction and well-being of our employees and pay attention to compliance with norms and standards. Responsibility for implementing this policy lies with the Vice President Corporate Human Resources.

Global recruitment guidelines

Our global recruitment policy outlines the process for approving positions and the Materiality rules and roles for working together to recruit or transfer employees and make informed, fair and unbiased hiring decisions. This applies to both full-time and part-time positions as well as trainees and special projects. The policy covers recruitment approval, search, selection, decision-making processes, documentation standards, the offer and onboarding phases. It also defines the responsibilities of the local HR department, managers, the central HR department, HR directors and HR business partners. Responsibility for implementing this policy lies with the Director Corporate Recruitment/HR Employee Branding.

Remuneration Policy

This policy sets out the fundamental principles and remuneration strategy of our company with the Targets of attracting qualified employees, being recognized as an employer of choice and promoting long-term retention while ensuring fair Pay both internally and externally. This is based on a job evaluation carried out according to a recognized method. The guideline regulates the basic salary, local remuneration elements, short-term variable remuneration, additional benefits, annual salary reviews, unscheduled increases and performance-related bonuses. All areas and sites of the company are obliged to structure remuneration in accordance with this guideline.

Base Salary Policy

These guidelines have been developed to establish the administrative standards necessary to ensure that the base salary of all employees is set at a competitive, internally equitable and performance-oriented level. They apply to all classified positions worldwide to the extent that they are consistent with national labor laws and regulations. The guidelines cover aspects such as salary adjustment analyses, compensation administration principles, types of salary increases, decision-making processes, promotions, transfers and demotions. The Senior Director Corporate Compensation & Benefits is responsible for the implementation of these guidelines.

Training and Development Policy

This policy provides an overview of the Training and Development processes to ensure that the company is well prepared for future growth through the development of key competencies and skills of its employees. It describes the approach to identifying and defining knowledge that is important for the long-term competitiveness of the company and sets out how competencies are defined and developed in strategic areas. This approach applies to all employees. The policy covers topics such as performance and development reviews, competency frameworks, competency assessments, individual development plans and the process of budgeting for training. Responsibility for implementing this policy lies with the relevant manager in the HR Development department.

Modern Slavery Act Transparency Statement

This statement is made in accordance with the requirements of the Modern Slavery Act 2025 and provides an annual overview of the actions the company has taken to combat modern slavery. It refers to a number of internal documents, including the Human Rights and Labor Standards Policy, the Supplier Code of Conduct and the Global Code of Conduct. The declaration reaffirms support for the principles of the Universal Declaration of Human Rights (UDHR), the United Nations Global Compact, the OECD Guidelines for Multinational Enterprises and the fundamental labor principles for the protection of workers' rights as defined in the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work.

Policy on equality, diversity and inclusion

The Policy reaffirms our commitment to inspiring, promoting, integrating and developing our employees in order to secure our competitive advantage together. We are committed to offering equal opportunities to all employees, regardless of gender, marital status, ethnicity, skin color, origin, disability, sexual orientation, religion or belief, age or other characteristics. Our aim is to create a working environment that promotes diversity and inclusion, respects and values differences so that all employees feel recognized and integrated and can develop their full potential. We are committed to promoting equality, fairness and respect for all employees and applicants and are committed to a working environment free from unlawful discrimination. At the same time, we combat and prevent all forms of discrimination. In addition, we support the principles of the UN Global Compact and actively contribute to achieving the UN Sustainable Development Targets by promoting equality, diversity and inclusion in the workforce. Employees are encouraged to report violations of this policy, with multiple confidential reporting channels available, including a whistleblowing system. Responsibility for implementing this policy lies with the relevant manager in Human Resources.

Procedure for remediation of Child labour

This procedure serves as a guide for dealing with cases of Child labour and describes actions that can be taken by managers to ensure that the safety and rights of children are upheld and their welfare is always paramount. The company expects that no child labour is used in the manufacture of its products. The procedure is designed to ensure compliance with the International Labor Organization (ILO) conventions on Child labour. It applies to all workers, regardless of their status, who are employed directly or indirectly, as well as to cases of child trafficking or sale for labor. All internal recruitment processes are expected to ensure that no child labour is used. The company is also committed to protecting the rights of young employees. All sites are required to implement effective age verification procedures and to keep the relevant documents for all employees. This procedure applies to all applicants, employees and interns at all sites worldwide. The respective local and national laws are taken into account during implementation.

Respect and protection of human rights

We promote a culture of safety and a sustainable working environment for the benefit of our employees, local communities and our business partners. It is crucial for us to comply with and, where possible, exceed all applicable social and ethical obligations. As part of the UN Global Compact, we are committed to upholding human rights, respecting employees' rights, protecting the environment, supporting fair competition and fighting Corruption.

As part of a program to promote human rights, we have identified the rights relevant to our company and developed actions to promote them. The resulting analysis serves as a basis for developing targeted plans and actions on material human rights. In order to meet our due diligence obligations, we monitor compliance with laws, human rights principles and environmental standards not only within the company, but also with our partners and in the supply chain. Respect for human rights is essential for us and is based on international standards such as those of the International Labor Organization (ILO).

This article has been machine translated. In case of errors, please contact [email protected].

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