ESRS G1 Business Conduct Disclosures
Overview
Draft and validate ESRS G1 topical disclosures for a CSRD sustainability statement: G1-1 business conduct policies and corporate culture, G1-2 supplier relationships, G1-3 corruption and bribery prevention/detection, G1-4 confirmed incidents, G1-5 political influence and lobbying, and G1-6 payment practices. The skill consumes DMA and ESRS 2 outputs, keeps business-conduct scope separate from S2/S4 social-topic disclosures, and produces evidence-linked IRO-2 hand-off rows.
What It Covers
- Business-conduct policies, corporate culture, whistleblower protection, and animal welfare where relevant.
- Supplier relationship management, SME payment safeguards, and fair dealing.
- Corruption and bribery risk assessment, controls, training, detection, investigations, and confirmed incidents.
- Political influence, lobbying activities, political contributions, register IDs, policy-alignment controls, and recent public-administration appointment checks.
- Payment practices: average payment days, standard terms, percentage paid within terms, late-payment proceedings, methodology, source systems, and evidence.
Example Conversation
You: Our DMA says ESRS G1 is material for anti-bribery, supplier payment practices, and lobbying. We have a code of conduct, ABC risk assessment, whistleblower dashboard, AP ageing report, and EU Transparency Register entry. Can you draft the G1 pack?
Agent: I’ll read the DMA material-topic decision, IRO register, governance log, datapoint index, baselines, contacts, and evidence index first. Then I’ll draft G1-1 through G1-6, keep supplier-worker labour issues out of scope for S2, and mark any missing incident, lobbying, or payment metrics with evidence placeholders.
You: Make sure payment practices and lobbying are assurance-ready.
Agent: I’ll add a G1-6 payment practices table with average payment days, standard terms, percentage paid within terms, late-payment proceedings, SME scope, methodology, source system, owner, and evidence references. For G1-5, I’ll include register IDs, spend categories, trade associations, senior accountability, policy-alignment controls, and the recent public-administration appointment check.
Sample Output Excerpt
The excerpt below illustrates the level of traceability expected in a G1 topical pack.
G1-5 — Political influence and lobbying activities
Materiality basis. The DMA identified G1-IRO-004 as a material risk because inconsistent lobbying positions could undermine the undertaking’s stated climate and anti-corruption commitments. The relevant ESRS 2 IRO-2 row is ESRS-G1-G1-5, owner: Public Affairs, evidence: EV-G1-PA-004.
Governance and accountability. The General Counsel approves lobbying positions before engagement with EU or national policymakers. The Audit & Risk Committee receives a semi-annual public-affairs report covering themes, spend, trade-association positions, and alignment with the Code of Conduct and Anti-Bribery & Corruption Policy.
Activities and registers. The undertaking is listed in the EU Transparency Register under ID [PENDING: register ID]. FY2025 lobbying themes were product safety harmonisation, supplier payment reform, and sustainability reporting proportionality. Direct lobbying spend was [PENDING: finance extract]; trade-association membership fees with lobbying components are tracked in output/esrs-g1-lobbying-register.csv.
Recent public-administration appointment check. Legal confirmed on [PENDING: date] that no member of the administrative, management, or supervisory bodies held a comparable public-administration position in the previous two years, or the exception list is documented in EV-G1-PA-006.
G1-6 — Payment practices
| Supplier category | Standard terms | Average payment days | Paid within standard terms | Legal proceedings | Evidence |
|---|---|---|---|---|---|
| EU SME suppliers | 45 days | 39 days | 92% | 0 outstanding | EV-G1-AP-001 |
Methodology: Accounts Payable calculated days from invoice receipt date to payment date for third-party supplier invoices in the consolidated reporting perimeter, excluding intercompany invoices and formally disputed invoices. Source system: [PENDING: AP system].
Extension Tools
validate_esrs_g1_business_conduct validates an ESRS G1 artefact after drafting or revision. It supports:
- Full G1 packs covering G1-1 through G1-6.
- Non-materiality statements tied to the DMA decision-log.
- G1-1 policy registers.
- G1-2 supplier relationship sections.
- G1-3 anti-corruption sections.
- G1-4 incident registers.
- G1-5 lobbying registers.
- G1-6 payment practices tables.
The validator checks materiality gating, source-of-truth reconciliation, whistleblower protection, animal-welfare relevance or N/A rationale, anti-corruption controls, confirmed-incident evidence, lobbying register IDs and policy-alignment controls, recent public-administration appointment checks, payment metrics, evidence references, IRO-2 hand-off rows, and sibling-scope leakage into S2, S4, or EU Taxonomy work.
Getting Started
- Start from a
csrd-esrs-programworkspace with the DMA and ESRS 2 foundation skills installed. - Confirm G1 materiality in
program/material-topics.mdand the relevant IROs inprogram/iro-register.csv. - Gather the code of conduct, whistleblower procedure, anti-bribery risk assessment, gifts/hospitality register, incident log, supplier payment data, public-affairs register, trade-association list, and evidence references.
- Ask the skill to draft the main G1 pack or a focused register such as payment practices or lobbying.
- Run
validate_esrs_g1_business_conductand resolve any missing evidence, payment metric, incident, lobbying, or scope-boundary findings before assurance review.