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S1-3 - Procedures for improving negative impacts and channels through which the organization's workforce can raise concerns

Updated over 5 months ago

ESRS Standard

30 The company shall describe the procedures it has in place to ameliorate or participate in the amelioration of adverse impacts on individuals in its workforce associated with the company, and the channels available for individuals in its workforce to raise concerns and have them reviewed.

31 The purpose of this disclosure requirement is to provide an understanding of the formal means by which the company's workforce can directly communicate their concerns and needs to the company and/or by which the company supports the availability of such channels (e.g. Grievance mechanisms) in the workplace, and how follow-up is conducted with affected individuals on the issues raised and on the effectiveness of these channels.

32 The company shall describe the procedures in place to address the aspects referred to in paragraph 2 of the Targets section by providing the following information:

  • (a) its general approach and procedures for taking or participating in remedial action where it has caused or contributed to material adverse impacts on individuals in its workforce, including whether and to what extent the company assesses each remedial action to be effective,

  • b) any specific channels through which the company's workers can express their concerns or needs directly to the company and have them reviewed, including whether these channels have been established by the company itself or through participation in third party mechanisms,

  • (c) whether the company has a procedure for handling grievances related to employee concerns (101); and

  • (d) the procedures by which the company supports the availability of such channels in the workplace of its workers; and

  • (e) how issues raised and addressed are tracked and monitored and how the effectiveness of the channels is ensured, including through the involvement of stakeholders who are intended as target users.

For application requirements, see AR 28 - AR 29

33 The company discloses whether and how it determines that its workers are aware of and trust these structures or procedures to communicate and have their concerns or needs addressed. In addition, the company indicates whether it has policies in place to protect individuals against retaliation who use them, including Workers' representatives. If such information has been disclosed under ESRS G1-1 , the company may refer to this information.

For application requirements, see AR 31 - AR 32

34 If the company cannot provide the above required information because it has not established a channel for communicating concerns and/or does not support the availability of such a channel at the workplace of its workers, it must indicate this. It may indicate a timeframe within which it intends to implement such a channel.


Application Requirements (AR)

AR 27 In fulfilling the requirements of the ESRS S1-3 disclosure requirement, the company may be guided by the content of the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct, which focuses on remediation and Grievance mechanisms.

AR 28 Channels through which concerns or needs can be raised include Grievance mechanisms, hotlines, trade unions (where workers are unionized), works councils, dialogue processes or other means through which the company's workforce or Workers ' representatives can raise concerns or needs about Impacts that the company is expected to address. This may include channels provided directly by the company as well as channels provided by other companies where the company's workforce is employed, in addition to other mechanisms that a company may use to gain insight into the management of impacts on its workforce, such as compliance audits. If the company relies solely on information about the existence of such channels provided through its Business relationships to fulfill this requirement, it may so indicate.

AR 29 Third party mechanisms may include those operated by government, NGOs, industry associations and other collaborative initiatives. The company may indicate whether these are accessible to the entirety of its workforce (or to Workers' representatives or, in their absence, persons or organizations acting on their behalf or who otherwise have knowledge of the adverse impacts ).

AR 30 The company shall consider, in relation to any Impact materiality, whether and how potentially affected individuals in its workforce and their Workers' representatives have access to channels at the level of the company where they are employed or with which they have a contract for the provision of work. Relevant channels may include hotlines, trade unions (where workers are unionized), works councils or other Grievance mechanisms operated by the company or a third party.

AR 31 If the company explains how it is aware that individuals in its workforce know and trust these channels, the company can provide relevant and reliable data on the effectiveness of these channels from the perspective of the individuals concerned. Examples of sources of information include surveys of individuals in the company's workforce who have used such channels and their satisfaction with the process and outcomes.

AR 32 In describing the effectiveness of the channels through which the company's workforce and Workers ' representatives may raise concerns, the company may be guided by the following questions based on the "Effectiveness Criteria for Non-Discriminatory Grievance Mechanisms" as set out in the United Nations Guiding Principles on Business and Human Rights (in particular Principle 31). The following considerations can be applied to individual channels or to a collective system of channels:

  • (a) Are the channels legitimized by ensuring adequate accountability for fair conduct and building trust among stakeholders?

  • b) Are the channels known and accessible to Stakeholders?

  • c) Do the channels have clear and known procedures with expected timelines?

  • d) Do the channels ensure adequate access by stakeholders to sources of information, advice and expertise?

  • e) Do the channels provide transparency by making sufficient information available to complainants and, where appropriate, respond to a public interest?

  • f) Do the outcomes achieved through the channels comply with internationally recognized human rights?

  • g) Does the company draw lessons from the channels that support continuous learning both in terms of improving the channels and preventing future impacts?

  • h) Does the company focus on dialog with complainants as a means to find mutually agreeable solutions, rather than unilaterally determining the outcome?


Examples from past practice

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

S1-3 - Complaints channels

Regular feedback sessions provide our employees with a valuable opportunity to openly share their ideas, concerns and suggestions for improvement. We promote a corporate culture in which all employees are encouraged to speak up about problematic business practices and misconduct. To support this process, we have introduced a whistleblowing tool that acts as an early warning system and enables employees to report serious misconduct - such as unethical, illegal or corrupt behavior - at an early stage. In addition, we regularly inform our employees through e-learning modules, internal guidelines and updates about the existing reporting procedures and show them how to use them effectively in the event of a case.

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

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