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S1-17 - Incidents, complaints and serious impacts related to human rights

Updated over 5 months ago

ESRS Standard

100 The company shall disclose the number of Work-related incidents and/or grievances and severe human rights impacts within its workforce and any related fines, sanctions or compensation for the reporting period.

101 The purpose of this disclosure requirement is to provide an understanding of the extent to which Work-related incidents and severe impacts related to human rights affect the company's workforce.

102. the information referred to in paragraph 100 shall include, subject to relevant data protection provisions, Work-related incidents of Discrimination based on sex, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation or other relevant forms of discrimination affecting internal and/or external stakeholders throughout the reporting period. This includes cases of Harassment as a specific form of Discrimination.

103 The company shall disclose the following:

  • (a) the total number of cases of Discrimination, including Harassment, reported during the reporting period(99).

  • (b) the number of complaints filed through channels through which workers of the enterprise can raise concerns (including Grievance mechanisms) and, where applicable, with the OECD National Contact Points for Multinational Enterprises in relation to the issues referred to in paragraph 2 of this Standard, excluding those already reported under subparagraph (a),

  • c) the total amount of material fines, sanctions and damages related to the Incidents and complaints described above and a reconciliation of the reported amounts of fines, sanctions and damages to the most meaningful amount reported in the financial statements; and

  • d) where applicable, background information necessary to understand the data and how it was compiled.

104 The company discloses the following information on identified incidents of severe human rights impacts (e.g., forced labour, human trafficking or child labour):

  • (a) the number of serious human rights incidents related to the company's labor force during the reporting period, including how many were in violation of the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises. If no such Incidents have occurred, the company indicates this(100) and

  • b) the total amount of fines, sanctions and damages related to the Incidents described in point (a) and a reconciliation of the monetary amounts to the most meaningful amount disclosed in the financial statements.


Application Requirements (AR)

AR 103 In addition to the information required by paragraphs 103 and 104, the entity may disclose the status of Incidents and/or Complaints and Actions taken in relation to the following:

  • (a) Incidents reviewed by the company,

  • (b) corrective action plans that are being implemented,

  • (c) corrective action plans that have been implemented, the results of which have been verified through routine internal management review procedures; and

  • d) Incidents that are no longer subject to Actions.

AR 104 When compiling the information described in AR 103, the company shall consider the following:

  • (a) An Incident is no longer subject to Actions if it is resolved, the case is closed, or the entity does not require further Actions. For example, an Incident requiring no further actions may include cases that are withdrawn or where the underlying circumstances that led to the Incident no longer exist,

  • b) Remedial action is targeted at the alleged Harassment perpetrator and the alleged victim. Remedies with respect to the victim may include offering to pay the victim's costs for counseling sessions, offering the victim some time off with pay, or offering to restore sick/vacation days if the victim has incurred costs as a result of the Harassment (e.g., use of sick or vacation days), and

  • c) Remedial action with respect to the harasser may include giving the person a verbal and/or written warning, requiring anti-harassment counseling or sending the person to an appropriate seminar, and requiring attendance at Harassment and Prevention Training. A leave of absence without continued pay may also be an option. If the harasser has been disciplined in the past but does not cease his or her harassment, more severe discipline may be necessary.

AR 105. serious human rights incidents include lawsuits, formal complaints through the company's or third parties' grievance procedures, serious allegations in public reports or in the media, provided they are related to the company's workforce and the incidents are not disputed by the company, and any other serious Impacts of which the company is aware.

AR 106 In addition to the information required by paragraph 104, the company may report the number of serious incidents related to human rights in which the company has played a role in ensuring remedy for those affected during the reporting period.


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.

S1-17 - Incidents, complaints and severe human rights impacts

No grievances were reported in 2023, an increase of 0% compared to 2022. Of the cases reported, none were classified as justified, meaning that no disciplinary action or remedial measures were required.

Of the complaints received, 0% related to Discrimination or Harassment and again none were confirmed as valid. Nevertheless, we ensure that our actions and processes are continuously improved to address such issues appropriately.

The number of cases reported via our whistleblower system is listed in section G1-1. No serious human rights violations, such as forced labour, human trafficking or child labour, were identified in 2023.

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

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