Boundary, restatement and the people who are not on the payroll
TransCargo Group reports on a calendar year. In June 2025 it acquired 100% of Nordic Haul, a regional carrier contributing 18% of group revenue and 600 employees from the acquisition date. It also holds a 40% interest in a joint venture, Baltic Terminals, which is not consolidated and employs 250 staff. Group payroll at 31 December 2025 shows 3,400 employees; in addition, 1,200 drivers work exclusively for TransCargo through three staffing agencies, driving company-branded vehicles on schedules set by TransCargo. The 2023 and 2024 reports presented revenue, headcount and safety data without Nordic Haul. Finance wants 2025 reported on the same basis as before 'so the trend is not distorted', and HR asks whether the agency drivers belong in the employee headcount.
1. Which disclosures govern the boundary, and should prior-year figures be restated?
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2-2 Entities included in the sustainability reporting requires the list of entities covered and the basis for inclusion; Nordic Haul is inside the boundary from June 2025, and Baltic Terminals must be described as an equity-accounted interest that is not consolidated, with the nature of the relationship (2-6). 2-4 Restatements of information requires disclosure of any restated figure and the reason.
GRI does not compel restatement for an acquisition, but it does compel a defensible decision, because comparability is a reporting principle. A 600-person, 18%-of-revenue addition sitting in 2025 totals only, next to unadjusted 2023–24 figures, would be read as organic growth. Two defensible routes: (a) restate the comparative to include Nordic Haul for the full period and explain under 2-4; or (b) leave prior figures and present the pro-forma effect of the acquisition alongside the 2025 numbers. What is not defensible is Finance's preference - reporting a changed entity on a changed basis and telling the reader nothing. Disclose which route was taken, the reason, and the size of the effect.
2. How should the 3,400 employees, 1,200 agency drivers and 250 JV staff be reported?
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Separately, and never summed into one 'workforce' figure.
- 2-7 Employees: 3,400 at 31 December 2025, broken down by gender and region, and by permanent/temporary contract and full-time/part-time type. State whether the number is headcount or full-time equivalent; if FTE, disclose the basis.
- 2-8 Workers who are not employees: 1,200 agency drivers, with the basis of measurement, the type of work, and the operational reality - company-branded vehicles, company schedules, day-to-day supervision by TransCargo. Significant fluctuations during the period should be described.
- JV staff: the 250 Baltic Terminals employees are not TransCargo employees and are not consolidated, so they stay out of 2-7. Whether they are within the reporting boundary depends on whether TransCargo causes or contributes to impacts there through a business relationship - describe under 2-6 and assess under GRI 3.
The judgement being tested: 2-8 exists because a non-employee workforce can exceed the payroll in exposure to safety and labour risk while being invisible in 2-7.
3. Which material topics should the agency-driver arrangement trigger, and how does 3-3 apply?
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The arrangement is a business relationship through which TransCargo can cause or contribute to impacts, so it feeds the GRI 3 assessment rather than staying an HR footnote. Likely topics: 403 Occupational Health and Safety (driving hours, fatigue, vehicle condition, accident rates for non-employees), 406 Non-discrimination and 409 Forced or Compulsory Labor (recruitment fees, debt bondage in agency chains), 414 Supplier Social Assessment (screening and monitoring of the three agencies), and 401 Employment where security of work is at stake.
For each topic confirmed as material, 3-3 requires more than a policy citation: the commitments and how they are embedded, the specific actions taken (e.g. contractual safety clauses, hours monitoring, joint accident investigation), goals and targets, responsibility and resources, the grievance mechanism available to agency drivers (2-26), and how effectiveness is tracked (audit results, incident trends, remediation outcomes - 2-25).