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S1-4 - Actions taken to address material impacts and approaches to managing material risks and exploiting material opportunities

Updated over 5 months ago

ESRS Standard

35 The entity shall disclose its actions with respect to managing material negative and positive impacts, managing material risks and taking advantage of material opportunities relating to the entity's workforce, and the effectiveness of those actions.

36 This disclosure requirement has two Targets:

The first is to provide an understanding of all actions and initiatives the company is taking to

  • a) works to prevent, mitigate and improve significant negative impacts on its own workforce; and/or

  • b) seeks to ensure material positive impacts on its own workforce.

The second is to provide an understanding of how the company manages Material risks and takes advantage of Material opportunities related to the company's workforce.

37 The company provides a summary description of the action plans and resources related to the management of its material impacts, risks and opportunities for the company's workforce in accordance with ESRS 2 MDR-A Actionsand resources related to sustainability aspects.

38 With regard to the material impacts related to its own workforce/own workers, the company explains the following:

  • (a) what actions have been taken, are planned or are underway to prevent or mitigate any significant negative impacts on the company's labor force,

  • b) whether and how it has taken actions to remedy or enable the remedy of any actual material impact,

  • (c) any additional actions or initiatives it has in place primarily to achieve positive impacts on the company's workforce; and

  • d) how it tracks and evaluates the effectiveness of these actions and initiatives in achieving results for the organization's workforce.

See also Application Requirements AR 34, AR 36 - AR 39

39 In relation to paragraph 36, the company describes the processes it uses to determine what actions are necessary and appropriate to respond to specific actual or potential negative impacts on the company's workforce.

See also application requirements AR 40 - AR 42

40 With regard to Material risks and Opportunities, the company describes:

  • (a) what actions are planned or have been taken to mitigate material risks to the organization arising from its impacts and Dependencies related to the organization's workforce, and how it tracks effectiveness in practice; and

  • b) what actions are planned or have been taken to take advantage of material opportunities for the organization related to its workforce.

See also application requirements AR 44 - AR 45

41 The company discloses whether and how it ensures that its own practices do not have or contribute to material adverse impacts on the company's workforce/own workers, including, where applicable, its practices related to procurement, sales and data use. This may include an indication of the approach taken to address tensions between avoiding or mitigating material adverse impacts and other business pressures.

42 When providing the information required by paragraph 40, the company shall, when assessing the effectiveness of an action by setting a target, take into account the ESRS 2 MDR-T Tracking the effectiveness of policies and actions through targets.

43 The company shall specify the resources allocated to the management of its Impact materiality, providing information that enables Users to understand how Impact materiality is managed.

See also Application Requirements AR 48


Application Requirements (AR)

AR 33. it may take some time to understand the adverse impacts and how the organization may be associated with them through its own workforce/own workers, and to identify and put into practice appropriate responses. Therefore, the company may indicate the following:

  • (a) its general and specific approaches to addressing significant negative Impacts,

  • b) its initiatives to contribute to additional material positive impacts,

  • c) how far it has progressed with its efforts during the reporting period, and

  • d) its targets for continuous improvement.

AR 34 The appropriate actions may vary depending on whether the company causes or contributes to significant impacts, or whether it is involved because the impacts are directly linked to its activities, products or services through a business relationship.

AR 35. as material adverse impacts on the company's workforce during the reporting period may also be associated with companies or activities outside its direct control, the company may indicate whether and how it intends to use its business relationships leverage to address these impacts. This may include the use of business leverage (e.g., enforcing contractual requirements within business relationships or using incentives), other forms of leverage within the business relationship (e.g., offering training or capacity building on workers' rights to companies with which the company has a business relationship), or collaboration with peer companies or other stakeholders (e.g., responsible hiring initiatives or ensuring Adequate wage).

AR 36 If the company discloses its participation in an industry or multi-stakeholder initiative as part of its actions to address material negative impacts, it may also disclose how the relevant material impacts will be addressed as part of the initiative and its own participation. Under ESRS S1-5, it may report on the relevant Targets of the initiative and progress towards achieving them.

AR 37 When disclosing whether and how the company considers the actual and potential impacts on its workforce when making decisions to terminate Business relationships, and whether and how it seeks to ameliorate any negative impacts of termination, the company may provide examples.

AR 38. procedures for tracking the effectiveness of Actions may include internal or external audits or reviews, legal proceedings and/or related court rulings, impact assessments, measurement systems, stakeholder feedback, Grievance mechanisms, external performance ratings and benchmarks.

AR 39 Reporting on effectiveness should enable an understanding of the linkages between the actions taken by the company and the effective management of impacts. Additional information that the company may provide includes data demonstrating a reduction in the number of Incidents identified.

AR 40. with respect to initiatives or practices whose primary objective is to have a positive impact on individuals in the company's workforce based on their needs, and progress in implementing such initiatives or practices, the company may provide the following:

  • (a) information on whether and how individuals in the company's workforce and Workers' representatives are involved in decisions about the design and implementation of such programs or practices; and

  • b) information about the intended or achieved positive results of these programs or practices for the company's workforce.

AR 41 The company may explain whether these initiatives are also designed to support the achievement of one or more of the Sustainable Development Targets. For example, a company that is committed to Sustainable Development Goal 8 to "promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all" could actively work to eliminate forced or compulsory labor or promote higher productivity in operations in developing countries through technological improvements and training of local workers, which may benefit both the individuals in the company's workforce affected by the actions and their local communities.

AR 42. in reporting the intended or achieved positive results of its actions for the company's workforce, distinguish between evidence that specific activities have taken place (e.g., that a certain number of individuals have received financial literacy training ) and evidence of actual results for the individuals affected (e.g., that a certain number of individuals report that they are better able to manage their Wage and household money).

AR 43. if the company has taken actions to mitigate the negative impacts of the transition to a greener, climate-neutral economy on its own workforce/own workers, such as training and retraining, employment guarantees, and in the case of downscaling or mass layoffs, actions such as career counseling, coaching, in-company placements, and early retirement plans, the company discloses these actions. Actions to comply with applicable regulations are also included. The company may highlight current and/or anticipated external developments that influence whether Dependencies become Risks. This includes consideration of the impacts that may result from the transition to more environmentally friendly and climate-neutral activities.

AR 44. in disclosing the material risks and opportunities related to its impacts or dependencies on the organization's workforce, the organization may consider the following:

  • (a) Risks related to the company's impacts on its workforce may include reputational or legal consequences if individuals in the company's workforce are found to be subject to Forced labour or Child labour.

  • b) Risks related to the company's Dependencies on its labor force may include disruption to business operations if significant employee turnover or lack of skills/training jeopardizes the company's operations.

  • c) Opportunities related to the company's Own workforce/own workers impacts may include market differentiation and greater customer attraction due to ensuring adequate wages and conditions for Non-employees.

AR 45. when explaining whether Dependencies become Risks, the entity shall consider external developments.

AR 46. when disclosing policies, actions, resources and targets related to the management of Material risks and Opportunities, the entity may cross-reference its disclosures on policies, actions, resources and targets related to these Impacts in cases where Risks and Opportunities arise from Material Impacts.

AR 47 The entity shall consider whether and how its process(es) for managing material risks related to its Own workforce/own workers are integrated into its existing risk management process(es).

AR 48. in disclosing the resources allocated to managing material impacts, the company may explain which internal functions are involved in managing impacts and the types of actions it takes to address negative impacts and drive positive impacts.


Examples from Installation A.3

Application Requirements for ESRS S1-4 - Taking Actions Related to Material Impacts on the Company's Employees and Approaches to Managing Material Risks and Capitalizing on Material Opportunities Related to the Company's Workforce and the Effectiveness of Those Actions

This Installation is an integral part of ESRS S1 Company Workforce and has the same binding force as the other parts of this standard. It supports the application of the ESRS S1-4 disclosure requirements on social and human rights issues with examples of disclosures:

Social and human rights issues

  • Secure employment
    Offering permanent contracts to employees with fixed-term contracts, implementing plans for social protection where there is a lack of state benefits

  • Working hours
    Rotation of shift work, extension of advance planning, reduction of excessive Overtime

  • Adequate wages
    Negotiating fair wages within the framework of collective agreements, checking whether employment agencies pay a fair wage

  • Social dialogue/existence of works councils/workers' rights to information, consultation and co-determination
    Expand the sustainability aspects dealt with in social dialogue, increase the number of meetings, increase funding for works councils

  • Freedom of association/collective bargaining including the quota of workers covered by collective agreements
    Expand the sustainability aspects covered by Collective bargaining, increase funding for Workers' representatives

  • Work-life balance
    Extending the right to time off work for family reasons and flexible working time arrangements, expanding the range of daycare options

  • Health and safety
    Increased training in the areas of health and safety, investment in safer equipment

  • Gender equality and equal Wage for equal work
    Targeted recruitment and promotion of women, reducing the pay gap by negotiating collective agreements

  • Training and skills development
    Qualification tests, further training to close skills gaps

  • Employment and inclusion of Persons with disabilities
    Actions to increase accessibility

  • Actions against violence and Harassment in the workplace
    Improve Grievance mechanisms, tighten sanctions for violence and Harassment, provide further training on prevention for managers

  • Diversity
    Further training on diversity and inclusion (including ethnic aspects), targeted recruitment of underrepresented groups

  • Child labour
    Actions on age verification, partnerships with organizations to eliminate child labour, actions against the worst forms of child labour

  • Forced labour
    Actions to ensure free consent to employment without threat of penalty, contracts in understandable language, freedom to leave employment without penalty, disciplinary measures should not include an obligation to work, free consent to Overtime, freedom of movement (including leaving employment), fair treatment of migrant workers, monitoring of employment agencies


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.

S1-4 - Actions to protect employees

ISO occupational health and safety management system

All production sites are certified in accordance with the ISO occupational health and safety management system. This management system for health and safety in the workplace serves to identify, control and reduce Risks. It is based on the principle of continuous improvement (Plan-Do-Check-Act) and supports the assessment of hazards in all areas of the company. Targets for minimizing Material risks are defined on the basis of feedback from relevant stakeholders. The risk assessment at the production sites includes the analysis of site-specific activities. Potential damage is identified, hazards evaluated, preventive actions defined and potential for improvement sought. Regular reviews ensure the effectiveness of the controls. Assessments are adjusted in the event of changes or following Incidents.

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

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