Version and legal reference: Delegated Regulation (EU) 2026/1563 of 3 July 2026 (OJ L 2026/1563 of 21.9.2026)
ESRS G1 – BUSINESS CONDUCT
Table of contents10 entries
TABLE OF CONTENTS
Impact, risk and opportunity management
Disclosure Requirement G1-1 – Policies related to business conduct
Disclosure Requirement G1-2 – Actions related to business conduct
Disclosure Requirement G1-3 – Targets related to business conduct
Disclosure Requirement G1-4 – Metrics related to corruption or bribery
Disclosure Requirement G1-5 – Metrics related to political influence, including lobbying activities
Disclosure Requirement G1-6 – Metrics related to payment practices
Objective
1. The objective of this Standard is to set out Disclosure Requirements (DRs) related to business conduct, particularly with respect to the sub-topics specified in paragraph 5 of this Standard. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.
2. The sustainability statement shall provide information in relation to ESRS G1 Business Conduct if this topic relates to material impacts, risks and opportunities. Such information shall cover the reporting areas listed in paragraph 5 of ESRS 1 General Requirements.
3. The DRs in this Standard complement the provisions in ESRS 2 General Disclosures, which require the undertaking to disclose information about topics related to material impacts, risks and opportunities, in particular:
ESRS 2 SBM 3 Interaction of material impacts risks and opportunities with strategy and business model, and financial effects; and
ESRS 2 IRO 2 Material impacts, risks and opportunities and disclosure requirements included in the sustainability statement.
4. In this Standard, each DR is introduced by a disclosure objective, except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant disclosures.
5. This Standard sets out DRs with respect to the following sub-topics:
corporate culture, including anti-corruption and anti-bribery, the protection of whistleblowers and animal welfare;
the management of relationships with suppliers, including payment practices, especially late payment to small and medium-sized undertakings (SMEs); and
political influence, including lobbying activities.
Disclosure Requirements
Impact, risk and opportunity management
Disclosure Requirement G1-1 – Policies related to business conduct
6. The undertaking shall disclose its business conduct policies in accordance with the provisions of ESRS 2 GDR-P.
7. In addition to the information required by ESRS 2 GDR-P, the undertaking shall disclose:
whether or not it has anti-corruption and anti-bribery policies consistent with the United Nations Convention against Corruption (This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts as set out by indicator #15 in Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Lack of anti-corruption and anti-bribery policies’).94);
whether or not it has policies on the protection of whistle-blowers (This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts as set out by indicator #6 in Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Insufficient whistleblower protection’).95); and
the functions or roles within the undertaking that are most at risk in respect of corruption or bribery.
APPLICATION REQUIREMENTS – ARs
AR 1 for para. 6 (corruption or bribery – definition) For purposes of this Standard, the undertaking shall apply the ESRS definition of corruption and bribery (see ESRS Glossary), which is generic, to overcome the differing definitions found in local laws or in laws applicable in the jurisdiction of the parent company and to ensure comparability across reporting undertakings.
AR 2 for para. 7(b) (whistleblowers) Undertakings that are subject to legal requirements under national law transposing Directive (EU) 2019/1937, or to equivalent legal requirements with regard to the protection of whistleblowers, can comply with the disclosure specified in paragraph 6(b) by stating that they are subject to those legal requirements.
AR 3 for para. 7(c) (corruption or bribery) When disclosing information under paragraph 7(c), ‘functions or roles most at risk’ means those functions or roles deemed to be most at risk of corruption or bribery as a result of their tasks and responsibilities within the undertaking, such as those operating in high-risk countries or interacting with public authorities and governments.
Disclosure Requirement G1-2 – Actions related to business conduct
8. The undertaking shall disclose its actions related to business conduct in accordance with the provisions of ESRS 2 GDR-A.
9. In addition to the information required by ESRS 2 GDR-A, the undertaking shall disclose information about the following actions:
the management of relationships with suppliers, including:
if the undertaking takes into account sustainability performance in the selection of its suppliers, how this is done;
training on sustainability provided to the procurement team, if any; and
engagement with suppliers for the improvement of their sustainability performance; and
the undertaking’s procedures to prevent, detect, investigate and respond to allegations or incidents related to corruption or bribery, including:
anti-corruption and anti-bribery training given to functions or roles most at risk within the undertaking, including members of the administrative, management and supervisory bodies; and
any actions taken to address breaches in procedures and standards of anti-corruption and anti-bribery (This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts, as set out in in indicator #16 of Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Cases of insufficient action taken to address breaches of standards of anti-corruption and anti-bribery’).96).
APPLICATION REQUIREMENTS – ARs
AR 4 for para. 9(a) (relationships with suppliers) In presenting the information in accordance with paragraph 9(a), the undertaking may consider cross-referring to the information about the existence of a supplier code of conduct in accordance with ESRS S2 Workers in the Value Chain, paragraph 11.
Metrics and Targets
Disclosure Requirement G1-3 – Targets related to business conduct
10. The undertaking shall disclose its business conduct targets in accordance with the provisions of ESRS 2 GDR-T.
Disclosure Requirement G1-4 – Metrics related to corruption or bribery
11. The objective of this DR is to enable transparency on the convictions and sanctions, including fines, related to corruption or bribery during the reporting period and the related outcomes.
12. The undertaking shall disclose the number of convictions and sanctions, including the total amount of fines, for violation of anti-corruption and anti-bribery laws (This information supports the information needs of: financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts, as set out in indicator #17 of Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Number of convictions and amount of fines for violation of anti-corruption and anti-bribery laws’); and benchmark administrators to disclose ESG factors subject to Commission Delegated Regulation (EU) 2020/1816 as set out by indicator ‘Numbers of convictions and amount of fines for violations of anti-corruption and anti-bribery laws’ in Sections 1 and 2 of Annex II.97) during the reporting period.
APPLICATION REQUIREMENTS – ARs
AR 5 for para. 12 (corruption or bribery – convictions and sanctions) Convictions for the violation of anti-corruption and anti-bribery laws refer to final decisions issued by a criminal court against an individual or undertaking in respect of a criminal offence related to corruption or bribery, where these court decisions are entered in the criminal record of the convicting European Union Member State or, if outside the EU, in the equivalent register or record of the jurisdiction concerned.
Sanctions for the violation of anti-corruption and anti-bribery laws refer to final decisions issued by administrative or regulatory authorities against an individual or undertaking in respect of corruption or bribery.
AR 6 for para. 12 (corruption or bribery – fines) Fines issued for the violation of anti-corruption and anti-bribery laws refer to mandatory monetary penalties resulting from violations of anti-corruption and anti-bribery laws imposed by a court, administrative or regulatory authority, which are paid to a public treasury, and which are recognised in the undertaking’s financial statements during the reporting period.
Disclosure Requirement G1-5 – Metrics related to political influence, including lobbying activities
13. The objective of this DR is to enable an understanding of the undertaking’s activities and commitments related to exerting its political influence through political contributions and lobbying activities.
14. The undertaking shall disclose the total monetary value of financial and in-kind political contributions made directly and indirectly by the undertaking during the reporting period, disaggregated by country or geographical area where relevant, as well as the type of recipient/beneficiary.
15. The undertaking shall disclose the main issues covered by its lobbying activities and the main positions taken, including explanations of how its lobbying activities interact with its material impacts, risks, and opportunities.
16. The undertaking shall disclose information about the appointment of any members of the administrative, management, and supervisory bodies during the current reporting period who held a comparable position in public administration (including regulators) in the two preceding years.
APPLICATION REQUIREMENTS – ARs
AR 7 for para. 14 (political contributions) For purposes of this Standard, ‘political contribution’ means financial or in-kind support provided directly to political parties, their elected representatives or persons seeking political office. Financial contributions can include donations, loans, sponsorships, advance payments for services, or the purchase of tickets for fundraising events, and other similar practices. In-kind contributions can include advertising, use of facilities, design and printing, donation of equipment, provision of board membership, employment or consultancy work for elected politicians or candidates for office.
AR 8 for para. 14 (indirect political contribution) For purposes of this Standard, ‘indirect political contribution’ refers to those political contributions made through an intermediary organisation such as a lobbyist or charity, or support given to an organisation such as a think tank or trade association linked to or supporting particular political parties or causes.
AR 9 for para. 16 (political influence) When determining ‘comparable position’ in this Standard, the undertaking shall factor in the level of responsibility and scope of the activities undertaken.
Disclosure Requirement G1-6 – Metrics related to payment practices
17. The objective of this DR is to enable an understanding of standard payment terms and of the undertaking’s performance with regard to payment, especially late payment to SMEs.
18. The undertaking shall disclose:
a description of the undertaking’s standard payment terms in number of days by main category of suppliers, specifying those that apply to SMEs if they are different from those applied to other suppliers;
the percentage of its payments aligned with these standard terms; and
the number of legal proceedings currently outstanding for late payments.
APPLICATION REQUIREMENTS – ARs
AR 10 for para. 18(b) (payment practices) If late payment to SMEs is a material topic for the undertaking, paragraph 11 of ESRS 1 General Requirements applies; therefore, the undertaking shall provide an entity-specific metric, if material.’
Footnotes
(94) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts as set out by indicator #15 in Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Lack of anti-corruption and anti-bribery policies’).
(95) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts as set out by indicator #6 in Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Insufficient whistleblower protection’).
(96) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts, as set out in in indicator #16 of Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Cases of insufficient action taken to address breaches of standards of anti-corruption and anti-bribery’).
(97) This information supports the information needs of: financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts, as set out in indicator #17 of Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Number of convictions and amount of fines for violation of anti-corruption and anti-bribery laws’); and benchmark administrators to disclose ESG factors subject to Commission Delegated Regulation (EU) 2020/1816 as set out by indicator ‘Numbers of convictions and amount of fines for violations of anti-corruption and anti-bribery laws’ in Sections 1 and 2 of Annex II.