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Sustainability / ESG

ESRS G1 Business Conduct

ESRS G1 is the topical CSRD standard for governance and business conduct; it governs disclosures on business ethics, anti-corruption and anti-bribery, political engagement, and supplier and payment practices.

ESRS G1 (Governance, Business Conduct) is the only topical governance standard within the European Sustainability Reporting Standards (ESRS), adopted under the Corporate Sustainability Reporting Directive (CSRD) through Delegated Regulation (EU) 2023/2772. While the environmental and social standards cover E and S topics, G1 consolidates disclosures on how a company steers its business activities ethically. The standard requires transparency on corporate culture, the policies and processes for business ethics, the prevention of corruption and bribery, political engagement including lobbying, and the management of supplier relationships.The specific disclosure requirements are organised into G1-1 through G1-6: G1-1 covers business conduct policies and corporate culture, G1-2 the management of supplier relationships, G1-3 the prevention and detection of corruption and bribery, G1-4 confirmed incidents of corruption or bribery, G1-5 political influence and lobbying activities, and G1-6 payment practices, particularly towards small and medium-sized enterprises. The scope of reporting depends on the materiality assessment: the full set of G1 data points must be disclosed only where business conduct is assessed as material under the double materiality principle.For compliance officers, ESRS G1 dovetails closely with existing obligations under the German Supply Chain Due Diligence Act (LkSG), anti-corruption rules, and whistleblower protection. Many organisations can draw on their existing compliance management systems, codes of conduct, and whistleblowing procedures as a data foundation. The challenge lies in translating qualitative descriptions into auditable disclosures compatible with the ESRS data points, since the sustainability statement is subject to external assurance, initially at a limited assurance level.

Legal Basis

ESRS G1 (Annex I to Delegated Regulation (EU) 2023/2772 under the CSRD, Directive (EU) 2022/2464); disclosure requirements G1-1 to G1-6

Practical Example

A reporting machinery group assesses business conduct as material in its double materiality analysis. For G1-1 the compliance department documents the group-wide code of conduct and anti-corruption policy, for G1-3 it records the number of trained employees and the whistleblowing system, and for G1-4 it reports that no confirmed corruption case occurred during the reporting year. For G1-6 it analyses average payment terms towards SME suppliers from the ERP system and concludes that shortening these terms is necessary to meet the standard credibly.

FAQ

ESRS G1 comprises disclosure requirements G1-1 to G1-6. They cover business conduct policies and corporate culture, the management of supplier relationships, the prevention of corruption and bribery, confirmed corruption incidents, political influence and lobbying, and payment practices towards SMEs.
The scope depends on the double materiality assessment. The full set of G1 data points must be reported only where business conduct is identified as a material topic. Otherwise a reasoned explanation of why the topic is not material is sufficient.
ESRS G1 requires disclosures on supplier relationships and business conduct that overlap substantively with the obligations of the German LkSG. Companies can use existing LkSG processes, codes of conduct, and risk analyses as a data foundation for G1 reporting.

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