Practitioner's Guide to ESRS S2

Michelle Horsfield

25 years: Sustainable Finance

In this video, Michelle explores ESRS S2, she explains why it’s no longer enough for companies to report only on their direct employees, and how S2 expands the lens to include suppliers, contractors, and others affected by business operations. She walks us through the core disclosure requirements, from policies and remediation to risk management and target setting, all grounded in global human rights frameworks like the UNGPs and OECD Guidelines.

Regulation and Initiatives

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Practitioner's Guide to ESRS S2

13 mins 42 secs

Key learning objectives:

Understand the scope and intent of ESRS S2 regarding value chain workers
Identify the human rights and labour frameworks underpinning the standard
Understand the S2 requirements for disclosure on risks, impacts, and remediation
Understand how businesses are expected to use metrics and targets to manage human rights impacts across their value chain

Overview:

ESRS S2 focuses on how companies affect workers across their value chain, even those they don’t directly employ. It builds on established frameworks like the UN Guiding Principles and OECD Guidelines, requiring firms to disclose their policies, processes, risks, and actions related to human rights and labour practices. Companies must show how they engage with suppliers, track and remediate negative impacts, and set targets for improvement. The standard pushes businesses to acknowledge and manage their broader social responsibilities with transparency and accountability.

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Summary

Why does ESRS S2 focus on workers in the value chain?

ESRS S2 recognises that businesses often rely on thousands of external workers, such as suppliers and contractors, who may be impacted by poor working conditions or human rights violations. These workers might not be on the company’s payroll, but they’re essential to its operations. By addressing this broader responsibility, ESRS S2 ensures that companies can’t outsource risk or turn a blind eye to harm deeper in their supply chains.

What frameworks support ESRS S2?

The standard is rooted in established global frameworks, including the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the ILO Declaration on Fundamental Principles and Rights at Work. These frameworks collectively promote dignity, equality, safety, freedom from forced or child labour, and collective bargaining rights. Rather than reinventing the wheel, ESRS S2 aligns with these well-accepted human rights and labour standards to ensure consistency and credibility.

What must companies disclose under ESRS S2?

Companies must outline their policies (S2-1), describe how they engage with value chain workers (S2-2), and explain their processes for remediation (S2-3) and action (S2-4). They also need to report on how they identify risks and integrate worker perspectives. S2-5 requires the use of measurable, time-bound targets to address material negative impacts. Altogether, these disclosures create a picture of how seriously a business takes its social responsibilities across the value chain.

How does ESRS S2 define 'value chain workers'?

Value chain workers are any individuals affected by a company’s operations, regardless of formal employment status. This includes upstream suppliers like raw material producers, and downstream users like processors or distributors. The key factor is whether the company’s activities materially impact them. This definition broadens corporate accountability and makes it harder to ignore harm occurring outside of direct employment relationships.

What kind of metrics and targets are required?

Companies are expected to set time-bound, outcome-oriented targets to reduce negative impacts on value chain workers. This includes tracking the effectiveness of their actions and demonstrating real progress over time. For example, they might report on the number of supplier audits or improvements in working conditions. These metrics help external stakeholders, especially investors, assess how committed a company is to ethical and responsible business practices.

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Michelle Horsfield

Michelle Horsfield, an environmental scientist with a climate change specialisation, transitioned into the financial sector four years ago to apply her knowledge to the largest reallocation of capital in history, as the economy moves towards a lower carbon future.

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