Templates and records · Sustainability · Clause ESRS G1
ESRS G1 business conduct indicators
The governance figures report readers look at most closely: how long the company takes to pay, what corruption incidents it has had and how it prevents them.
In one sentence
Business conduct indicators cover, for ESRS G1, payment practices —in particular late payment to small and medium-sized enterprises—, the fight against corruption and bribery, training and cases handled through the whistleblowing channel, and they are mandatory when business conduct turns out to be material in the double materiality assessment.
- Where the standard requires it
- Sustainability · Clause ESRS G1 Standards are cited by name: ESRS 1 (general requirements), E1 (climate change), S1 (own workforce), G1 (business conduct). Delegated Regulation (EU) 2026/1563 simplified them for financial years starting on or after 1 January 2027; for 2026 companies may choose the previous version or the new one.
- Type of information
- Mandatory document Mandatory for companies subject to the CSRD when business conduct is material (ESRS G1)
- Who fills it in
- Finance and regulatory compliance Finance provides the payment period; compliance, the cases and the training
- When
- At financial year end The payment period is best tracked every quarter
- How long it is kept
- At least while the report can be reviewed Neither the directive nor the ESRS set a period for working papers; it is wise to keep them with the management report for the year and those for the comparative year.
What the standard requires
What Sustainability demands and what it leaves to your judgement
Standard G1 deals with corporate culture, whistleblower protection, supplier relationships, including payment practices and in particular late payment to SMEs, and the fight against corruption and bribery.
For the payment period, the figure must come from supplier accounts using a documented method. For corruption, it comes from whistleblowing channel case files and from judicial or administrative proceedings, without disclosing personal data.
It is a topic under heavy public scrutiny: a payment period figure that does not match the one in the annual accounts is a guaranteed finding.
Structure
Fields the template should include
- Average supplier payment period and calculation method
- Percentage of payments outside the legal term, with particular attention to SMEs
- Legal proceedings outstanding for late payment
- Confirmed cases of corruption or bribery and action taken
- Convictions and fines for corruption, if any
- Anti-corruption training: groups covered and percentage
- Reports received through the whistleblowing channel, by type
Example
Example: 2025 indicators for the food group (fictitious group)
Company, people and figures are fictitious: the example only shows what a properly completed record looks like.
| Field | Content |
|---|---|
| Average payment period | 52 days · same method as the figure in the notes to the annual accounts |
| Late payments to SMEs | 9 % of the amount · main cause: invoices with goods-receipt discrepancies |
| Corruption | No confirmed cases · two reports investigated and closed |
| Training | 96 % of staff in purchasing and sales roles trained in anti-corruption |
| Whistleblowing channel | 18 reports · 7 on harassment or treatment, 5 on conflicts of interest, 6 other |
| Action | Plan to bring the payment period for SMEs down to 45 days in 2026 |
At the audit
Mistakes auditors commonly flag
- The payment period in the report does not match the one in the annual accounts.
- «No cases of corruption» is reported without explaining how this was checked.
- Whistleblowing channel data indirectly identify individuals.
- Training is measured in total hours rather than coverage of at-risk groups.
In Kimobox
How this record is kept in Kimobox
- 1The Kimobox whistleblowing channel is also used for ESG matters, with restricted intake and a traceable case file.
- 2The governance structure is kept as a controlled document.
- 3Each employee’s training is recorded in their digital file.
- 4Governance indicators are consolidated on the dashboard with exportable evidence.
Frequently asked questions
What people ask us before getting started
What counts as late payment to SMEs?
Paying suppliers that are small and medium-sized enterprises later than the legal or agreed term. Standard G1 highlights it because that is where delay does the most harm.
Do reports received have to be published?
Aggregated data and how reports are handled are disclosed, never identifiable cases. Protecting whistleblowers is part of what the standard itself asks you to explain.
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Sources
Where each figure comes from
References to the official text in force. If a standard is revised, this page is updated and the review date says so.
- Delegated Regulation (EU) 2026/1563 amending Delegated Regulation (EU) 2023/2772 to simplify the sustainability reporting standards EUR-Lex · OJ of 21 September 2026; applicable to financial years from 1 January 2027
- Delegated Regulation (EU) 2023/2772, European Sustainability Reporting Standards (ESRS) EUR-Lex · 31 July 2023
- Directive (EU) 2022/2464 on corporate sustainability reporting (CSRD) EUR-Lex · 14 December 2022