4.01 The 2025 Strategic Report no longer gives the number of employees of each sex
UK Company A · a UK-listed medical technology group · Compliance or disclosure gap
In brief
A quoted company's strategic report must show, at the year end, the number of directors, senior managers and employees of each sex. The 2025 report states [n] employees but nowhere splits them by sex; the 2024 report did ([n] employees, [n]% male, [n]% female). The Board and senior-manager figures appear only in the governance section, which is outside the pages the directors define as the Strategic Report, and the senior-manager figure is given only as percentages.
The evidence, as filed
Further pages withheld to protect the company’s identity (five): Annual Report 2024, page 62; Annual Report 2025, page 130; Annual Report 2025, page 131; Annual Report 2025, page 73; Annual Report 2025, page 62. Their wording or layout could lead back to the company even with names and figures masked; the evidence list below records what each page shows.
Names, figures, dates, logos and any wording that could be searched back to the company are boxed out in grey; the point is highlighted in yellow.
What the report shows, and what the rule requires
| What the annual report shows | What the rule requires |
|---|---|
| What the annual report shows 2025 Strategic Report (pages IFC-96): [n] employees, no split by sex anywhere in the Annual Report. Senior managers ([n]; Female [n]%, Male 66%) and Board (Men 9, Women 5) appear only on pages 130-131 of the governance section; the strategic report's index points to the Board figures only. | What the rule requires Within the Strategic Report, or by a clear and specific cross-reference from it: the number of persons of each sex who were (i) directors of the parent company, (ii) senior managers including directors of subsidiary undertakings, and (iii) employees, at [date], as given in the 2024 report. |
What we checked: Whole 2025 report searched for the employee split; the 2024 report's equivalent page read; the Strategic Report page range taken from the directors' statement.
The rule
Companies Act 2006 s.414C(8)(c)
Version relied on: Companies Act 2006, revised text on legislation.gov.uk as in force for the financial year reviewed
In the case of a quoted company the strategic report must include ... a breakdown showing at the end of the financial year ... the number of persons of each sex who were employees of the company.
Companies Act 2006 s.414C(10)(b)
Version relied on: Companies Act 2006, revised text on legislation.gov.uk as in force for the financial year reviewed
the breakdown required by subsection (8)(c)(ii) must include the number of persons of each sex who were the directors of the undertakings included in the consolidation.
FRC Guidance on the Strategic Report (2022) para 3.17
Version relied on: FRC Guidance on the Strategic Report, July 2014, revised July 2018 and June 2022 (non-mandatory guidance)
Where information satisfying a disclosure requirement that applies to the strategic report is presented outside of that component, cross-referencing must be used in order for the disclosure requirement to be met.
Why it applies here: the employee limb of the breakdown has dropped out of the 2025 report altogether, a departure from the company's own practice; the senior-manager limb is outside the Strategic Report without a cross-reference and is stated as percentages, not as numbers of persons.
Why it matters
- The 2025 Strategic Report does not contain an item the Act requires of every quoted company, and readers lose the comparison the company gave last year.
- The Strategic Report is one of the parts the FRC's Corporate Reporting Review covers.
The 2025 Strategic Report does not contain an item the Act requires of every quoted company, and readers lose the year-on-year comparison the company gave last year.
Exposure
An omission of this kind is typically raised by the FRC's Corporate Reporting Review by letter, with an undertaking to restore the disclosure in the next report; it does not of itself require revision of the 2025 report.
Our workings
the Statement of Directors' responsibilities says the Strategic Report comprises pages IFC-96. Within that range the only workforce total is [n] employees on the At a glance page, with no split by sex; the people and inclusion pages (59-63) describe inclusion groups and programmes but give no gender numbers. The senior-manager breakdown ([n]; [n]% female, 66% male, including subsidiary directors) and the Board numbers (9 men, 5 women) appear on pages 130-131 of the Nomination & Governance Committee Report. The non-financial and sustainability information index inside the Strategic Report cross-refers to 'Board diversity [n]' but not to the senior-manager or employee data. Last year, page 62 of the 2024 Strategic Report gave all three: [n] total employees ([n]% male, [n]% female), together with the senior-manager and Board splits.
No computation is needed to establish the omission.
| Required item (s.414C(8)(c), ([n])) | Where in the 2025 report | Inside Strategic Report (IFC-96)? | Status |
|---|---|---|---|
| (i) Directors of the parent company by sex | Page [n] table: Men 9, Women 5; page 99 percentages | No - governance section; index cross-refers to page 99 | Partial |
| (ii) Senior managers incl. subsidiary directors by sex | Page [n]: [n]; Female [n]%, Male 66% | No - and no cross-reference | Partial (percentages, outside) |
| (iii) Employees by sex | Nowhere; page 2 gives [n] employees only | No | Absent |
Management’s best defence, and our reply
Management would say the Board and senior-manager splits are in the same Annual Report (pages 99-131), that numbers can be derived from the percentages, and that full workforce gender data is published in the separate Sustainability Report. They may add that the strategic report index cross-refers to the Board diversity page. However, the Act requires numbers of persons in the strategic report itself or by a specific cross-reference, the index points only to the Board page, and no page of the 2025 Annual Report gives the employee split at all; a separate Sustainability Report is not part of the strategic report. The 2024 report gave the employee split (a stated total of [n] with the percentage of each sex) on its people page inside the Strategic Report, so the gap is a departure from the company's own practice.
The fix
- Restore the breakdown in the Strategic Report people pages: 'At [date]: Board - X men, Y women; senior managers (including directors of subsidiary undertakings) - X men, Y women; all employees - X men, Y women', or cross-refer specifically to where each sits.
Where: Strategic Report, Our people (pages 59 to 63): new paragraph
Proposed wording
At [date]: Board: 9 men, 5 women; senior managers, including directors of subsidiary undertakings: [x] men, [y] women ([n] in total); all employees: [x] men, [y] women ([n] in total).
Evidence relied on
| # | What it shows | Type | Where |
|---|---|---|---|
| 1 | The directors define the Strategic Report as pages IFC-96 | Document | Annual Report 2025, page 198 |
| 2 | The only workforce total in the Strategic Report, with no split by sex | Document | Annual Report 2025, page 2 |
| 3 | Senior-manager split given as percentages, in the governance section (page 130), outside the Strategic Report | Document | Annual Report 2025, page 130 |
| 4 | Board numbers by sex given in the governance section table (page 131) | Document | Annual Report 2025, page 131 |
| 5 | The strategic report's information index cross-refers to Board diversity only, not to senior-manager or employee data | Document | Annual Report 2025, page 73 |
Absence check
- Document
- Annual Report 2025
- Where it would appear
- A Culture of Inclusion
- What is missing
- the number of employees of each sex at [date] (and the senior-manager numbers by sex), which the 2024 report gave on its equivalent page
- Pages looked at
- p.1-96 (Strategic Report), 61-65 (Building our Way to Win), 131-135 (Nomination & Governance Committee Report)
- Result
- 'female'/'Male' hit p.99, [n] (Board and senior-manager figures in the governance section), p.180 (an incentive measure on female people leaders), p.252 ([product] use in female patients) and p.257 (pension longevity); 'gender' hit p.5 (Board ambition), [n] (index entries), [n] (UK gender pay gap percentages only); 'headcount' hit p.33 and [n] (restructuring and pay peer group). None gives the number of employees of each sex. 'Total employees' and 'each sex' have no hits.
Prepared by Pramanex from the company’s published annual reports, without the company’s involvement, to show how an annual report review reads. The company is not named, and nothing on this page is a statement about any identifiable company. Observations are not an audit, review or other assurance engagement, and not legal advice. A regulator-style question is a question, not a conclusion.
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