Background Material on

Business Responsibility and

Sustainability Reporting

The Institute of Chartered Accountants of India

(Set up by an Act of Parliament)
New Delhi
CONTENTS
Module 1: Introductory Session
1.1. Need for Sustainability Reporting ..................................................................................................................... 1
1.2. Global Trends in Corporate Sustainability Reporting........................................................................................ 3
1.3. Sustainable Development ................................................................................................................................ 7
1.4. UNITED Nations Sustainable Development Goals (UNSDG) 2030............................................................... 11
1.5 National Guidelines on Responsible Business Conduct, 2018 (NGRBC) ....................................................... 22
1.6 Detailed Analysis of SDGs and NGRBC Linkage ........................................................................................... 30
1.7. MCA’s Committee recommendation on Business Responsibility and Sustainability Reporting (BRSR) ......... 37
1.8. Fiduciary Duties of Directors towards Company’s stakeholders, community and environmental protection -
Section 166 of Companies Act, 2013 .................................................................................................................... 39

Module 2: MCA BRSR Disclosures

2.1 Nine Principles of NGRBC ............................................................................................................................................... 45
2.2 Report of the Committee on Business Responsibility Reporting ...................................................................................... 58
2.3 Comparison of BRR Disclosures and BRSR disclosures ................................................................................................. 77

Module 3: MCA BRSR Disclosures

3.1. INTRODUCTION............................................................................................................................................ 80
3.2. Aspects related to quality and utility of disclosures ........................................................................................ 80
3.3. Guidance Note for Business Responsibility & Sustainability Reporting Format (Comprehensive) ................. 83
3.4. Business Responsibility & Sustainability Reporting Format Lite…………………………………………………121
3.5. Guidance Note on Business Responsibility & Sustainability Reporting Format Lite…………………………...128

Module 4: BRSR vs. Global Frameworks

4.1. Overview of GRI and IR Frameworks (Global) ............................................................................................. 136
4.2. Integrated Reporting Framework……………………………………………………………………………………147
4.3. Mapping of BRSR with GRI and IR Frameworks .......................................................................................... 151
4.4. Mapping of GRI and IR Frameworks……………………………………………………………………………….174
4.5. Sustainable Finance………………………………………………………………………………………………….175

Module 5: Assurance Aspects

5.1 Assurance of Corporate Sustainability Report ............................................................................................... 183
5.2 Assurance Framework .................................................................................................................................. 184
5.3 Assurance Standards for Limited/ Reasonable Assurance ........................................................................... 185
5.4 Role of accountants in helping corporates prepare and promote use of high-quality comparable, reliable, and
relevant BRR disclosures .................................................................................................................................... 193
MODULE ONE: INTRODUCTION
1.1.NEED FOR SUSTAINABILITY REPORTING

1.1.1. BACKGROUND

The industrial revolution in Europe resulted in the widespread exploitation of natural resources such as timber and minerals,
and vegetation removal for new settlements in the conquered colonies. The mechanization and high consumption also
resulted in higher level of pollution. The environmental concerns from the resource exploitation gave rise to the concept of
sustaining life on earth. The International Union for the Conservation of Nature (ICUN) published a World Conservation
Strategy in 1980 that introduced the term “Sustainable Development” and referred to it as a global priority. Subsequently,
the report “Our Common Future (commonly known as Brundtland Report)” was released by the United Nations World
Commission on Environment and Development in 1987that gave the popular definition of Sustainable Development.

Sustainable Development

Sustainable development is the development that meets the needs of the present without compromising the ability of future
generations to meet their own needs. It contains within it two key concepts:

 The concept of ‘needs’, in particular, the essential needs of the world’s poor, to which overriding priority should be
given; and
 The idea of limitations imposed by the state of technology and social organization on the environment’s ability to
meet present and future needs.

Sustainability

The concept is related to meeting the human development goals while conserving and protecting the nature, environment,
and social ecosystem on which the economy and society depend. The extraction or usage of the resources to meet the
present human needs should simultaneously ensure that the availability of these resources for future generations to meet
their own needs is not compromised.

Sustainability Reporting

 Traditionally, the organisations considered that economic growth and socio-environmental parameters are
mutually exclusive, and hence, economic growth was the only thing that organisations used to disclose. The
chemical manufacturing companies started publishing environmental reports in the 1980s as a means of image
building, and the tobacco processing industries followed suit in an attempt to attract investment. This disclosure of
corporate information developed into non-financial reporting such as Sustainability Reporting in the last 20 years
as a means of demonstrating accountability and transparency to the stakeholders.
 As per the definition of the Global Reporting Initiative (GRI), Sustainability Reporting is an overview of a
company’s economic, environmental, and social impacts, caused by its everyday activities”. This is not merely
presenting the data collected, but an approach to drive an organization’s commitment to sustainability, and
demonstrate it to the interested parties in a transparent manner. It is intended to assist the organisations to
assess, measure, analyse and present their performance in economic, social, environmental, and governance
parameters, with an objective of setting challenging targets and goals. In the current scenario, the major investing
institutions across the world review the non-financial data in order to take decisions on investment in any new
venture.

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  The organizations now cannot make claims about their sustainable performance without providing credible and
measurable information in a world of powerful social media that has the ability to verify or cross-check with little
effort. The companies are now required to be more transparent about the risks and opportunities they come
across considering the potential impacts on the environment and society from their existence.

1.1.2. PURPOSE AND OBJECTIVE

The specific purpose and objectives for sustainability reporting vary across organisations, but in a broad sense, it intends to
provide trust to the interested parties to a business, such as financial and capital providers, customers, regulatory bodies,
vendors and subcontractors, employees, the population affected by the operation of the organisation, civil societies, and the
general public.

The objectives of sustainability reporting are:

 Customers Satisfaction and retention - People are more likely to purchase products and services from
organisations that are perceived to be responsible for the prevention of pollution, conservation of natural
resources, and give back to the community. Such goodwill and reputations are built by organisations through
years of hard work. The Sustainability Report is one of the effective ways of demonstrating how the organisation is
committed and sensitive to environmental and social issues. With more and more customers now caring about
being environmentally and socially responsible, the sustainable reports are very important in attracting them.
 Gain a Competitive Advantage – Being transparent about the operations, supply chain, sourcing can differentiate
an organisation among the many companies offering similar products or services in today’s competitive market.
Many organisations have set policies to select environmentally and socially responsible organisations as their
supplier, subcontractor, or service provider. An organisation with credible reporting about how sustainable they are
will be able to attract investments from major players in the market.
 Provides accountability - The sustainability report requires the organisation to create genuine goals and targets
that make the organisation accountable for the promises related to the environment, society, and governance. The
specific goals that are relevant to the organisation’s business with clear measurable indicators are much more
likely to be achieved. This will be important when venturing out for financial assistance from banks and investors,
technological tie-ups with other organisations, etc.
 Employee Satisfaction and Retention - The employees take pride in working for environmentally and socially
responsible companies than others that focus purely on economic growth. When the employees have confidence
in their management, they will have higher levels of satisfaction and engagement with the work they perform.
Moreover, they get a chance to play their part in the sustainable initiatives, such as conserving power, water, or
paper, and having their actions listed in the report provides them a feeling of belonging and participation. The
listings such as “companies that are good to work for” are being published by third-party assessment agencies as
well. These higher levels of employee satisfaction can attract competent resources and retain existing resources.
 Provide specific information instead of Greenwashing - The organisations commonly use generic terms and labels
to create a positive image and branding. The terms and labels such as “organic”, “natural”, or “eco-friendly” are
widely used by the organisations and when not backed up, are considered as “Greenwashing”. However,
sustainability reports provide specific information with measurable indicators. E.., “The initiatives offset
Greenhouse gas emission of 100,000 tons of Carbon dioxide every year” is more specific than “Eco-friendly”.
 Demonstrate Progress - Sustainability reports generally make the sustainable efforts tangible to the reader. It is a
way to create the image by showcasing how the organisation is progressing in various parameters and criteria.
Such organisations always will command investor confidence. The interested parties will be able to review how the
company has grown in the previous periods and make a judgment as they often do with financial reports. .

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1.2 GLOBAL TRENDS IN CORPORATE SUSTAINABILITY REPORTING

1.2.1. FRAMEWORKS AND INSTRUMENTS

There are varieties of international and local frameworks used by organisations across the globe for their corporate
sustainability reporting. Only a few of them cover a wider comprehensive scope spanning all the material issues, whereas
some of them operate in specific sectors, or on a single issue. There are 20 countries that have ten or more reporting
frameworks in their country, with the United Kingdom having the maximum with 21 of them. The United Nations Sustainable
Development Goals (UNSDG) is a key driver to most of the sustainability reporting frameworks. There are 15 reporting
frameworks in India, of which 12 are mandatory.

As per Carrot and Sticks report (https://www.carrotsandsticks.net/), out of 84 major economies by GDP, there are 614
sustainability reporting instruments, of which 350 are mandatory, and the rest 264 are voluntary. There has been a
considerable increase in the number of such frameworks since 2006, when there were only 65. The mandatory reporting
requirements are mostly associated with the public sector or government-run companies, large corporations, multi-national
business conglomerates, and listed companies in the stock exchanges. Furthermore, sector-specific and thematic reporting
provisions are also becoming more common.

Source: Carrots and Sticks 2020: Sustainability Reporting Policy: Global trends in disclosure as the ESG agenda
goes mainstream

The major providers of sustainability reporting instruments that are used across different countries are:

 Global Reporting Initiative (GRI)'s Sustainability Reporting Standards

 International Federation of Accountants (IFAC)’s ISAE 3000
 The Organisation for Economic Co-operation and Development (OECD Guidelines for Multinational Enterprises)
 The United Nations Global Compact (the Communication on Progress)
 The International Organization for Standardization (ISO 26000, International Standard for social responsibility)

The most widely used framework in the world is the Global Reporting Initiative (GRI) Sustainability Reporting Standards
having 93% of the world’s largest 250 corporations report on their sustainability performance through GRI. It is used in over
100 countries to report sustainability. This independent international organization, is based in Amsterdam, the Netherlands.

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and has operational hubs in Brazil, China, Colombia, India, South Africa, and the United States. The GRI Sustainability
Reporting Standards are developed with true multi-stakeholder contributions, and rooted in the public interest.

Additionally, GRI is also one of the conveners with the International Integrated Reporting Council (IIRC) a global coalition of
regulators, investors, companies, standard setters, the accounting profession, and NGOs to promote communication about
“value creation” as the next step in the evolution of corporate reporting, known as Integrated Reporting. The mission is to
establish integrated reporting in private and public sectors as a business practice and envisions that the capital allocation
and corporate behaviour are in line with economic growth and sustainable development.

1.2.2. REPORTING

The practice of reporting has now gone up in all the regions and sectors across the globe with 78% of the world’s largest
companies including financial and non-financial data in their annual reports:

 67% of the G250 companies (the world’s largest 250 companies in terms of revenue as per 2016 Fortune 500
ranking list) now perform Assurance of their corporate responsibility data
 The Assurance of Corporate Responsibility CR data is steadily increasing in the case of N100 (top 100
companies in terms of revenue from each of the 49 countries).
 The increase in reporting can be attributed to a combined and integrated pressure from the new regulatory
framework, stock exchange requirements, and investor expectations.

Source: https://assets.kpmg/content/dam/kpmg/xx/pdf/2017/10/kpmg-survey-of-corporate-responsibility-reporting-2017.pdf

 Regions - From a region-based perspective:

o maximum reporting is in the Americas with 83%, mainly due to a high surge in reporting from 57% to
90% in Mexico from regulatory pressure.

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 o Asia Pacific and Europe are close with 78% and 77% of corporate reporting respectively.
o The reporting from Eastern Europe is only 65% that reduces the reporting score of Europe below
Americas.
o The Middle East and Africa are lowest with just 52% reporting. There are nine countries with a 90% or
above reporting rate.
o The United Kingdom, Japan, and India have a reporting rate of 99%, followed by Malaysia, France,
Denmark, USA, and Mexico
 Industry Sectors - Every industry sector now has a sustainability reporting rate of at least 60%. The sectors that
generally lag behind in the reporting such as Healthcare, Transport & Leisure, Industrials, Manufacturing & Metals
and Retail have started their reporting on sustainability.
o The most notable increase in reporting is in Healthcare and Chemicals sectors with an 8% and 6%
growth respectively.
o As it used to be in the previous years, the high impact sectors such as Oil & Gas, Utilities and Mining
have the highest reporting rate among the sectors.

 Integrated Reports - The organisations that produce an “Integrated Report” also have increased steadily with
major improvements seen in Japan, Brazil, Spain, and Mexico. 90 of the South African companies disclose their
sustainability reports as an Integrated report and are first in that category followed by Japan with 42 companies
generating Integrated reports

1.2.3. CLIMATE CHANGE AND CARBON EMISSIONS IN THE REPORTS

Climate Change effect due to the emission of greenhouse gases (GHG) from human activity have been a topic of discussion
and matter of concern in the last two decades in every environment-related forum. The use of fossil fuels for power and
removal of vegetation has been under scrutiny in almost every part of the world. The review of climate change risks in the
sustainability reports has increased over time with organisations reporting the extent of GHG emissions from their operations
and the action plans to bring it down. The regulatory framework of emission reduction along with incentives from emission
trading also has resulted in many organisations quantifying and reporting this data to the public. The Financial Stability
Board considers Climate change as a risk to the stability of the global financial system resulting in the Task Force on
Climate-related Financial Disclosures (TCFD) made of makers and users of financial data to recommend how companies
should disclose the financial risks of climate change

Among the G250 organisations:

 67% of them have identified and formulated targets in their annual reports to reduce their carbon emissions;
however, most of them do not link their emission targets with the national emission goals or the UN initiatives such
as the Paris Agreement.
 Only 48% of the G250 and 28% of the N100 acknowledge climate change as a financial risk in their reports.
 Among the G250 organisation, the location plays a role in their decision to treat climate change as a financial risk,
with only France, Germany, and the United Kingdom had the majority of their G250 companies doing so. France is
on rank 1 with 90% of the G250 companies based in France took climate change as a financial risk.
 Only five countries have the majority of their top 100 organisations acknowledge climate change as a financial risk
in their annual financial reports.
 Taiwan tops the list with 88 companies, followed by France with 76, South Africa with 61, the USA with 53, and
Canada with 52.

From a sector-based view, among the G250 companies:

 67% of the Retail organisations took up climate change in their financial risk, whereas this sector lags in the N100
sample. This may be due to the global retail majors’ experience and knowledge of operating extensive supply
chain systems across continents are providing them better insights into the risks.

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  The Oil & Gas sector irrespective of G250 and the N100 sample has acknowledged climate risk in their reports as
the fossil fuel industry is always under the scanner.
 Financial services companies have lower acknowledgment in both G250 and N100 samples.

1.2.4. U.N. SUSTAINABLE DEVELOPMENT GOALS AND REPORTING

The 17 sustainable goals set by the United Nations for 2030 cover all issues relating to poverty, environment, society,
culture, human rights, and economic growth. Each of these 17 goals has specific goals (total 169) to be achieved in 15
years’ time. Most of the nations have made regulatory framework and guidelines to meet these goals of sustainability and
has resulted in the organisations having elements of them in their annual corporate reporting.

 So far, 43% of the G250 and 39% of the N100 have linked their reporting to UN Sustainable Development Goals.
 Among the G250 companies, the organisations based in Europe lead the way with 83% organisations in Germany
and 63% in France have aligned their corporate reporting to UNSDG.
 Among the sectors, more than half of the companies in Utilities, Automotive, retail, and Telecommunications have
aligned the CR data with UNSDG.
 The sectors Oil & Gas, Manufacturing. and Financial services fare poorly in this parameter.
 European companies do more of SDG inclusion in the N100 sample too with 60% of Swedish companies, and
58% of Portuguese companies having their corporate reporting data in line with the UNSDG.

1.2.5. HUMAN RIGHTS AND REPORTING

With vulnerable communities and displaced people in several regions across the globe, there is a need to have corporations
be responsible for human rights abuses in the areas that they operate. The Guiding Principles on Business and Human
Rights from the UN establish the responsibility of businesses to respect human rights, avoid infringing them, and remedy
any negative human rights impacts they are involved with. The highlights of the survey by KMPG in 2017 about global
reporting is as below: A whopping 90% of the G250 companies and 73% of the N100 have identified human rights as an
issue in their reporting.

 But, only 62% of the organisations in both the samples of G250 and N100 have reported in their sustainability
reports about having a policy on human rights.
 Additionally, only around one-third of the organisations that acknowledged human rights are referring to the
Guiding Principles from the UN.
 The organisations based in Western European countries acknowledge human rights as a business concern with
79% of them doing it.
 In Eastern Europe, it is significantly low with only 61% of companies. This is low for companies from North
America and the Middle East & Africa with 65% and 68% respectively.
 The top ten countries where more organisations take up human rights issues are located in Western Europe, Latin
America, and the Asia Pacific. India, the UK, and Japan lead in this criterion with 95%, 85% and 83% of their
organisations respectively acknowledging the human rights as a business issue.
 All three of these countries have regulatory frameworks relating to disclosure of human rights, either mandating or
encouraging.
 The Mining industry acknowledges the human rights issue the most in their reporting with 88% for the N100
sample and 100% in the G250 sample; mining projects having to deal with local communities in the remotest of
places may be the reason why they treat this parameter with great importance.
 The Financial service industry has the lowest with just 66% of them considering the human rights issues in their
corporate reporting.

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1.3. SUSTAINABLE DEVELOPMENT

1.3.1. ORIGIN AND HISTORY

The consumption of natural resources for human needs have been happening since the beginning of civilization. The
economic prosperity in ancient age was met by agriculture and the production of necessary goods such as clothing and
pottery. These activities required the clearing of trees and changing topography for land and usage of resources such as
water. Fossil fuels such as coal and firewood became necessary for production when the new techniques of production were
invented. Later, when the population grew and more urban areas developed, the fight to control the resources started
between communities.

Industrial Revolution

The manual production of goods was found not adequate to meet the demand and this gave rise to the industrial production
in Europe that became a revolution that changed the trade and commerce significantly, and gave rise to new economic
powers, mostly the naval powers of Europe who established colonies in the new regions they reached. The industrial
revolution required natural resources in enormous quantity causing widespread destruction of nature to extract them, such
as clearing forests for land and timber, and mining for minerals. The refining of petroleum to make different kinds of efficient
fuels and the invention of machinery and automobiles that uses the new fuel intensified the fossil fuel combustion.

The extensive use of fossil fuels resulted in the emission of harmful gases into the atmosphere and the higher levels of
industrial activity polluted the water bodies, land, and air through the emission of effluent, smoke, and other hazardous
waste. There were serious thoughts on how the life on earth can be sustained for future generations if the destruction of
environment and the extraction of natural resources continue in current manner. This environmental destruction gradually
became a concern for most communities in the twentieth century asking industries to reduce the contamination of water
bodies and air and reduce the removal of trees.

The World Conservation Strategy was released in 1980 by the International Union for the Conservation of Nature (ICUN)
that used the term “Sustainable Development” and referred it as a global priority. Later in 1987, the Brundtland Report
published by the United Nations World Commission on Environment and Development had the definition of sustainable
development that is popular and widely accepted across the world. It talks about meeting the present day needs without
compromising the ability of future generations to meet their needs. It had two concepts of prioritizing the essential needs of
the poor and limitation to conserve the ability of environment to provide the resources.

1.3.2. CONCEPT OF SUSTAINABILITY

1. Triple Bottom Line - People, Planet and Profit

The word Sustainability refers to the ability to exist continuously or the ability to sustain life. As per conventional thoughts
and wisdom, economic progress and environmental conservation were mutually exclusive things and thought to be not
considered together. But later the introduction of the concept of sustainability revolutionized the way how business is
performed. In the initial stages, there were three components that are interdependent, namely economic development,
social development, and environmental protection.

"What use is a sawmill without a forest?"- Ecological economist Herman Daly

The concept revolved around having economic progress and social development without compromising the environment
and these are known as the triple bottom line of any business. The main importance of the Triple Bottom Line and other

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subsequent efforts is about shifting the focus from the binary of economy and the environment when relating to progress.
The creative and proactive ways of approaching decisions to minimize the unfavorable effects, and brings stability among
the elements of economic growth, environment, political justice, and cultural vibrancy moves towards sustainable
development.

2. Circles of sustainability and the fourth dimension of sustainability

In a recent approach aimed mostly towards a sustainable urban life, the Circles of Sustainability revolves around four
domains instead of three; they are economic, ecological, political, and cultural sustainability. The representation is a circle
divided into four quadrants for each of the four domains and hence the name. The major change from the triple bottom line
concept is that the domain “Social” is removed and is now considered as a wider field that cuts across all the four domains.
The four domains are not just some parts that join to form sustainability, but are segments that are relevant to channelize
the efforts to create a sustainable society.

An example of circles of sustainability

Each of these four domains has 7 sub-elements as under:

 Ecology -The ‘ecological’ is defined as the practices, discourses, and material expressions that occur across the
intersection between the social and the natural realms, including the important dimension of human engagement
with and within nature, ranging from the built-environment to the ‘wilderness’. The 7 sub elements are Materials
and Energy, Water and Air, Flora and Fauna, Habitat and Settlements, Built-Form and Transport, Embodiment
and Sustenance and Emission and Waste.
 Economics - The ‘economics’ is defined as a social domain that emphasizes the practices, discourses, and
material expressions associated with the production, use, and management of resources. The seven elements of
Economics are Production and Resourcing, Exchange and Transfer, Accounting and Regulation, Consumption
and Use, Labour and Welfare, Technology and Infrastructure, and Wealth and Distribution.
 Politics - The ‘political’ is defined as a social domain that emphasizes practices and meanings associated with
basic issues of social power as they pertain to the organization, authorization, legitimation and regulation of a
social life held-in-common. The seven elements of Politics are Organization and Governance, Law and Justice,
Communication and Critique, Representation and Negotiation, Security and Accord, Dialogue and Reconciliation,
and Ethics and Accountability.

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  Culture - The ‘cultural’ is defined as a social domain that emphasizes the practices, discourses, and material
expressions, which, over time, express the continuities and discontinuities of social meaning of a life held-in-
common. The seven elements of Culture are Identity and Engagement, Creativity and Recreation, Memory and
Projection, Beliefs and Ideas, Gender and Generations, Enquiry and Learning, and Wellbeing and Health.

When the sustainable goals were formulated by the United Nations as an improvement to the Millennium Development
Goals, sustainability was modeled around five elements that interact with each other. These concepts were taken from
different schools of thought of a sustainable future and can be expressed as the five Ps of sustainability- People, Planet,
Prosperity, Peace, and Partnerships. This new concept revolves around identifying the ways several challenges interact and
affect one another to understand these interdependencies, to arrive at the root causes of these problems, and formulate a
long-term solution.

The need for peace for economic growth is a concept accepted from the initial stages of modern-day civilization. The wars
and conflicts have always made trade and commerce challenging and the regions that lacked a peaceful environment
always suffered hindrance to their economic prosperity. However, this was never addressed effectively in the earlier
concepts of sustainable development or the way corporate organisations planned their strategies. The responsible
organisations merely avoided the conflict zones for their operations as a solution to this issue and never addressed the
indirect impacts of their operations that added to the conflict.

The new inclusion of mutually beneficial partnerships between communities and regions as an integral part of sustainability
additional to Peace changed the way sustainability is looked at. This came out of the realization that when the communities
work in isolation, it is impossible to address the challenges we face as inhabitants of the same Planet. E.g. Climate Change
is a problem everyone faces irrespective of the reasons aggravating it. The greenhouse gas emissions by the traditionally
industrial nations affect every community irrespective of their contribution to GHG emissions. Hence, the solution has to be
arrived at by working in partnerships by transfer of technology, capacity building, or financial and commercial support.

1.3.3. CORPORATE SOCIAL RESPONSIBILITY (CSR)

The word Corporate Social Responsibility (CSR) is a type of self-regulating measure by the large organisations with the
objective of meeting social goals in the communities they operate. It is often aimed to build reputation and brand image and
is used along with Sustainability, and at many times interchangeably, when referring to what is expected of an organization,
and the way they perform their disclosure through reporting. Even though they are generally voluntary, more and more
countries are making them mandatory in some form or the other through legislative frameworks. Some countries even have
a mandatory expenditure prescribed for CSR activities.

World Business Council for Sustainable Development defines CSR as, "the continuing commitment by business to behave
ethically and contribute to economic development while improving the quality of life of the workforce and their families as
well as of the local community and society at large". In general, it refers to conducting business in a way to meet or exceed
the expectations of society in terms of ethical, legal, commercial parameters are concerned. The concept of sustainability is
an integral part of CSR.

CORPORATE PHILANTHROPY VS. CSR

There is a general misunderstanding that CSR is the same as Corporate Philanthropy, and hence giving away for charity is
often misconstrued as the only CSR activity a corporate organisation needs to engage in. Although philanthropy may be a
part of the CSR strategies of a business, there is much more to CSR than simply philanthropic gestures, and charitable
initiatives.

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 Involvement of the Organisation - The major difference is the involvement of the organisation. It is quite common for
the philanthropists to support a cause from a distance without having any direct involvement in them apart from
following up about their contributions and the impact it made. The act of charity is completely external to the
organisation with the decision-makers giving away money like they pay their taxes. But CSR aims at an overall
sustainable way of operating, limiting themselves to not only benefitting the nature and community, but also benefitting
the business through increased customer focus, and employee satisfaction.
 Change in Business Practice - Charity donations and other related philanthropic work done by an organisation do not
call for a change in the ways of operation or practice. However, for a socially responsible organisation, it may have to
change its core activities, often taking a higher financial burden affecting their profits. E.g., ethical sourcing could result
in the organisations completely change their supply chain.
 Continuity and effort - Corporate Philanthropy may be a one-time activity, or something that happens once in 6 months
or a year, and does not require additional efforts. But CSR is an ongoing continuous activity from the organisation that
requires effort from the whole organisation. For CSR to work well, the organisation should have well laid down and
communicated strategies and policies in place, that are understood by the employees with clarity on what their roles
are towards their fulfillment. CSR address other issues that affect the environment, consumers, human rights, supply-
chain sustainability, and transparency for the greater good of the world at large
 Return on the efforts - The corporate philanthropy results only in the goodwill to the organisation and building an image
of benevolence among the beneficiaries. It does not in any manner lessen the risks the organisation faces. But in the
case of CSR, the organisation aims to attract funding, keep the investors and customers satisfied, improve employee
retention and engagement, and get into successful partnerships. The aim is to have a long-term successful operation
by considering all the potential risks that the business may have, and devising action plans to counter those risks.
 Public Perception - The act of charity does not improve the perception of the organisation by the public. In many cases,
it hampers the image by making people think that the organisation managed the social and environmental issues by
paying up as if in a compensation program. An organisation that exploits the workers with lower pay or companies that
use child labour will still have the same bad image even if they donate to do charity. But, in case of CSR, the
organisation addresses the issues due to them, with actions, and hence will have a better image among the people.

1.3.4. EXAMPLES OF CORPORATE SOCIAL RESPONSIBILITY INITIATIVES

I. Textile manufacturers using recycled plastic bottles and other polymer-based wastes as r raw material to reduce
their material footprint, and source only from ethical cotton farms. This also helps in reducing the carbon emissions
of polyester processing. E.g.- Nike, Adidas
II. Soft drink bottling plant taking efforts to conserve water (rainwater harvesting, recycling, etc.) and give back to the
aquifer, to account for the water they have taken out to make the soft drink. E.g.- Pepsi, Coca Cola
III. An energy-intensive enterprise setting up wind farms or solar plants to harvest and source the required power for
its operations and / or reduction of consumption to reduce the usage. E.g.- Google, Johnson & Johnson, Cochin
International Airport, Walt Disney Corporation,
IV. FMCG Companies using delivery trucks using alternate fuels to reduce carbon emissions from the enormous
number of running trucks. This required investment in new supply chain and technology. E.g.- Coca Cola
V. Factories in remote areas setting up free education and training unit for specific programs for the local community
so that they can find work in the organisation later. This helps the organisation in remote locations to get
employees who will work for a long time without attrition. E.g.- Aditya Aluminum
VI. Contract farming encouragement in terms of subsidies and technology transfer for the local people near dairy
plants, poultry processing units, sugar mills, paper mills, plywood mills, etc. This ensures jobs and livelihood for
the local people and raw material for the organisation. E.g.- Milma, Amul, ITC
VII. Community-based eco-tourism initiatives in areas of vulnerable and indigenous people help the local population to
preserve their culture, ensure livelihood and the organisation is able to perform business without troubling the
environment. E.g.- Lampi marine national Park in Myanmar

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VIII. The pharmaceutical manufacturers taking responsibility for the addition and side effects that arise out of the use of
their drugs, and arrange awareness programs. They also may subsidize the medicines for refugees and in
emergency situations. E.g - Pfizer
IX. Organisations providing extended paid leaves to their employees for better work-life balance, such as those given
for parental leaves. E.g - Netflix
X. Metro Train network employing transgender people in their ticket booths, checking stations, and offices providing
them a chance of having a livelihood and life with dignity. E.g.- Kochi Metro Rail Corporation

1.4. UNITED NATIONS SUSTAINABLE DEVELOPMENT GOALS (UNSDG) 2030

1.4.1. BACKGROUND AND HISTORY

The Sustainable Development Goals (SDG) were adopted by the United Nations (UN) in 2015 as a call for action by all the
192 member states in a global partnership for peace and prosperity for the people and environment, in a long-term
perspective. It was made based on the understanding that the strategies to improve economic growth, education, health,
and equality should be made together with the preservation of the environment and tackling climate change.

The formulation of these SDGs was the output of years of work by the member counties and the UN, including the UN
Department of Economic and Social Affairs. In the Earth summit 1992 in Rio de Janeiro, Brazil, a plan of action to build a
global partnership for sustainable development was adopted. In the 2000 New York summit, the Millennium Declaration was
made elaborating eight Millennium Development Goals (MDGs) as:

1. to eradicate extreme poverty and hunger;

2. to achieve universal primary education;
3. to promote gender equality and empower women;
4. to reduce child mortality;
5. to improve maternal health;
6. to combat HIV/AIDS, malaria, and other diseases;
7. to ensure environmental sustainability; and
8. to develop a global partnership for development.

In the 2002 Earth summit in Johannesburg, South Africa, the Johannesburg Declaration on Sustainable Development and
the Plan of Implementation was adopted reaffirming the global community's commitments to poverty eradication, and to the
environment, by including more emphasis on multilateral partnerships.

In the 2012 Earth summit again in Rio de Janeiro, adopted "The Future We Want" to kick start a process for the formulation
of a set of Sustainable Development Goals - SDGs to build upon the eight MDGs that are ending their timeline in 2015. A
thirty-member Open Working Group was set up in 2013 to generate a proposal on the sustainable development goals that
resulted in the current 17 SDGs in 2015 after several consultations and discussions.

2015 was the year for many other major global agreements in sustainability such as the Paris agreement on Climate
Change, Addis Ababa Action Agenda on financing for development, Sendai Framework for Disaster Risk Reduction. Now,
the annual High-level Political Forum on Sustainable Development serves as the central UN platform for the follow-up and
review of the SDGs.

1.4.2. OBJECTIVE

The objective of the SDGs is to develop a sustained and inclusive Economic Growth, Social inclusion, and environmental
protection, and to do so in partnership and peace. In comparison with the vertical nature of the MDGs that covered the
Social and Health goals, the SDGs go beyond them to cover the economy, justice, and environment as well in a horizontal
manner. It aims at thinking creatively on the sustainability challenges of today, making the right partnerships, and taking the
right actions.

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The MDGs that ended in 2015 resulted in a reduction in poverty by more than half compared to 1990, far more children
attending primary schools, and more people getting access to clean water and essential medicines. However, still, around
800 Million people live in extreme poverty and hence the importance of further goals for a sustainable world.

The Indian subcontinent and the Sub-Saharan Africa had little progress in comparison with the rest of the world in these
goals. It did very less improvements to certain groups such as the disabled, indigenous communities, rural people, and
women. Hence inclusive sustainability goals became necessary to bring prosperity to everyone. And this human prosperity
should go hand in hand with protecting the planet. There are four underlying principles for the SDGs; universal, sustainable,
leave no one behind, and participation.

1.4.3. STRUCTURE AND FOCUS AREA

There is a total of 17 Sustainable Development Goals (SDGs) and 169 indicators with a targeted timeline of 2030 that cover
diverse topics from ending poverty to making partnerships, and are formed with 5 key areas of focus to leave no one and no
country behind.

The five Ps of SDGs are

1. People
2. Planet
3. Prosperity
4. Peace
5. Partnership

The SDGs are not mere items or checklists, but a holistic approach to understanding and tackling problems faced in today’s
world. It focuses on identifying how several challenges connect with, impact upon each other, and comprehending these
interdependencies helps in identifying the root causes to work out a long-term solution.

Sustainable development is usually viewed through three core elements of economic growth, social inclusion, and
environmental protection. They are not separate boxes, but, are connected and have many things in common. SDG also
include Partnerships and Peace to these three dimensions. Partnerships strengthen the power of all stakeholders in the
group and Peace brings stability and justice to the core elements. The SDGs also look at the whole planet as one. Every
country and community face different challenges and the group shares the responsibility and ownership to address these
challenges as a single entity collectively.

The Division for Sustainable Development Goals (DSDG) in the United Nations Department of Economic and Social Affairs
(UNDESA) provides substantive support and capacity-building for the SDGs and their related thematic issues, including
water, energy, climate, oceans, urbanization, transport, science and technology, the Global Sustainable Development
Report (GSDR), partnerships and Small Island Developing States. DSDG plays a key role in the evaluation of UN system-
wide implementation of the 2030 Agenda and on advocacy and outreach activities relating to the SDGs.

The goals 1 to 5 primarily focus on People, 6 to 15 focus on Planet and Prosperity, 16 on Peace, and 17 on Partnerships.
However, many of these are interlinked and hence the elements of all five Ps can be found in the sustainable goals. For
Example the Goal to end Poverty is primarily focused on People, but the indicators for the goal link to Prosperity, Peace,
and Partnerships. Similarly, all the 17 goals can be seen to be cross related to all the five elements of sustainability.

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1.4.4. THE 17 SUSTAINABLE DEVELOPMENT GOALS (SDGS)

Focus on People

1. End poverty in all its forms everywhere (GOAL 1: No Poverty)

2. End hunger, achieve food security. improved nutrition, and promote sustainable agriculture (GOAL 2: Zero
Hunger)

3. Ensure healthy lives and promote well-being for all at all ages (GOAL 3: Good Health and Well-being)

4. Ensure inclusive and equitable quality education and promote lifelong learning opportunities for all (GOAL 4:
Quality Education)

5. Achieve gender equality and empower all women and girls (GOAL 5: Gender Equality)

Focus on Planet and Prosperity

6. Ensure availability, sustainable management of water and sanitation for all (GOAL 6: Clean Water and
Sanitation)

7. Ensure access to affordable, reliable, and sustainable. and modern energy for all (GOAL 7: Affordable and
Clean Energy)

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8. Promote sustained, inclusive. and sustainable economic growth, full and productive employment and decent
work for all (GOAL 8: Decent Work and Economic Growth)

9. Build resilient infrastructure, promote inclusive, sustainable industrialization, and foster innovation (GOAL 9:
Industry, Innovation and Infrastructure)

10. Reduce inequality within and among countries (GOAL 10: Reduced Inequality)

11. Make cities and human settlements inclusive, safe, resilient, and sustainable (GOAL 11: Sustainable Cities
and Communities)

12. Ensure sustainable consumption and production patterns (GOAL 12: Responsible Consumption and
Production)

13. Take urgent action to combat climate change and its impacts (GOAL 13: Climate Action)

14. Conserve and sustainably use the oceans, seas, and marine resources for sustainable development (GOAL
14: Life Below Water)

15. Protect, restore, and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat
desertification, halt and reverse land degradation. and halt biodiversity loss (GOAL 15: Life on Land)

Focus on Peace

16. Promote peaceful and inclusive societies for sustainable development, provide access to justice for all, and
build effective, accountable. and inclusive institutions at all levels (GOAL 16: Peace and Justice Strong
Institutions)

Focus on Partnerships

17. Strengthen the means of implementation and revitalize the global partnership for sustainable development
(GOAL 17: Partnerships to achieve the Goal)

GOAL 1 - NO POVERTY

The survival of human beings in this world is fully dependent on their economy; however, the economy is not in a balanced
structure across the globe. Certain facts identified by the United Nations regarding poverty across the globe are shocking.

 According to the estimates of the United Nations as of 2015, 10 percent of the world’s population lived on less than
$1.90 a day.
 The world’s largest increase in extreme poverty was identified in the Southern Asia and sub-Saharan Africa region
and a further increase in poverty is expected.
 Although extreme poverty as in 2019 has come down to 7.1 percent from 14.3 percent, the estimate for extreme
poverty for the year 2030 is going to be 6 percent of the global population.
 Considering the economic downfall across the globe due to various pandemic threats, extreme poverty is expected
to remain in the ratio of one out of five children.
 Further, it is expected that the negative effects of poverty and deprivation in the early years have ramifications that
can last a lifetime.
 Out of the world’s population as of 2016, nearly 4 million people did not benefit from any form of social protection.

Goal 1 comprises of five targets with indicators to measure the progress. The targets and indicators are provided in the
annexure. Based on the targets, the following actions are required to be taken:

 Eradication of extreme poverty by creating policy frameworks at national, regional, and international levels.

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  Supporting organization by providing guidelines for creating pro-poor and gender-sensitive development strategies
and thereby accelerating the investment in poverty eradication.
 A strong system has to be developed mainly in rural areas for social protection and mainly, the measures should
cover the poor and vulnerable.
 Bringing up equal rights to economic resources, by means of mobilizing resources from a variety of sources and to
enhance development co-operation between developed and developing countries.
 Bringing flexibility in economic policies to help the poor and those in vulnerable situations and reduce their
exposure and vulnerability to climate-related extreme events and other economic, social, and environmental
shocks and disasters.
 Least developed countries to be kept on top priority, providing support in all dimensions to develop and implement
policies and frameworks to end poverty.

GOAL 2 - ZERO HUNGER

Food is the topmost priority among the basic needs of human beings in this world, but there is no equality in the availability
of food for all human beings across the globe. Out of the world’s population, 8.9 percent of the people are still starving for
food. The increase in hunger is the range of 10 million people per annum.

A total of 381 million undernourished populations are found in Asia and this stands as the major population among the other
regions of the world. Next to Asia, Africa has an undernourished population of 250 million. While comparing other parts of
the world, the number of undernourished is growing faster in Asia and Africa.

The goal comprises of five targets with indicators to measure the progress. The targets and indicators are provided in the
annexure. Based on these targets, the following actions to be taken to achieve the goal:

 Fixing a scale to identify the people living with a very poor economy and struggling for survival in a vulnerable
situation. Based on the identification bring an end to hunger and undernourishment.
 Due to malnutrition 21.3 percent of the children under 5 are affected by stunting and 6.9% percent of the children
under 5 are affected by wasting. This can be eradicated by making supporting the local food market with timely
information about various fluctuations in the derivatives market, mainly food price volatility.
 Increasing the productivity of agriculture and income of small-scale food producers by providing support in
agriculture research and sharing knowledge about advanced technology.
 Improvisation in the trading of agriculture products by removing the restriction in trading in the world agriculture
market.
 Encouraging the usage of diversified seed and plant banks identified based on the genetically proven species of
seeds and plants grown across the globe.

GOAL 3 - GOOD HEALTH AND WELL BEING

Although the world is progressing well in the reduction of child death, still the Sub-Saharan Africa and Southern Asia regions
are struggling to decrease child death. Out of the birth of five children, four children are still losing their lives. Based on the
estimation of the available information, as in 2018, 6.2 million children and adolescents under the age of 15 years died
mainly from preventable causes. In 2017, approximately 810 women died every day from preventable causes related to
pregnancy and childbirth.

Goal 3 has nine targets. The goal aims at bringing good health and wellbeing through development in research and
production of vaccines and medicines for communicable and non-communicable diseases that mainly affect developing
countries. It targets -

1. Global Maternal Mortality reduction.

2. Bringing an end to the death of newborns and children less than 5 years of age.
3. Complete eradication of AIDS, tuberculosis, malaria, and neglected tropical diseases and combat hepatitis, water-
borne diseases and other communicable diseases.
4. Reduction in premature mortality from non-communicable diseases.
5. Prevention of usage of substances like drugs and alcohol.
6. Bringing down the number of deaths due to road accidents.

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 7. Ensuring access for sexual and reproductive health care services for the entire world.
8. Achieving universal health coverage, including financial risk protection.
9. Reduction in the number of death and illness due to air and water pollution, soil, and contamination created by
hazardous chemicals.

Based on the targets, the following actions are to be taken to achieve the goal:

 Reduction in global maternal mortality by bringing development in training and retention of the health workforce in
developing countries.
 Controlling the usage of drugs by the implementation of global framework fitting to all the countries.

GOAL 4 - QUALITY EDUCATION

In the current scenario, education remains an inaccessible right for millions of children around the world. More than 72
million children of primary education age are not in school and 759 million adults are illiterate and do not have the
awareness necessary to improve both their living conditions and those of their children. Out of the total population, 617
million youth worldwide lack basic mathematics and literacy skills.

The goal comprises of seven targets with indicators to measure the progress. The targets and indicators are provided in the
annexure. Goal 4 targets -

 Quality and Equal education for girls and boys.

 Providing preprimary education for girls and boys to get them prepared for primary education.
 Access to all women and men for affordable and quality technical education.
 Increasing the number of youths and adults with technical and vocational qualifications.
 Eliminating gender inequality in education.
 Improvement of literacy and numeracy of adults.
 Ensuring an increase in the percentage of men and women acquiring knowledge and skill through education.

Based on the targets, the following actions are to be taken to achieve the goal:

 Providing quality and equal education for all girls and boys by conducting awareness programs and engaging local
people in such programs.
 Improving gender-equal education by upgrading educational facilities and creating a safe environment for both
girls and boys.
 Increasing the number of women and men with technical qualifications by providing scholarships.
 Ensuring technical qualification to all the youths and adults in by providing education at an affordable cost.
 Increasing the number of qualified teachers so that most of the men and women will get access to minimum
education.

GOAL 5 - ACHIEVE GENDER EQUALITY AND EMPOWER ALL WOMEN AND GIRLS

Even though we have come a long way in women’s empowerment and gender equality, the gender-related issues and
practices are deeply rooted and are still very prevalent in society irrespective of economic advancement. UN Women was
established in 2010 with the objective to address these challenges.

The goal covers the ending of discrimination, violence against women, and providing equal opportunity and rights to
leadership, resources, and practical legal framework for gender equality. The targets and indicators are provided in the
annexure. The summary is to:

1. End all forms of discrimination against all women and girls everywhere.
2. Eliminate all forms of violence against all women and girls.
3. Eliminate forced marriage and female genital mutilation.
4. Recognize and value unpaid care and domestic work.
5. Participation and equal opportunities for leadership for women.

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6. Access to sexual and reproductive health and reproductive rights.
7. Equal rights to economic resources for women.
8. Use of information and communications technology.
9. Enforceable legislation for the promotion of gender equality.

GOAL 6 - ENSURE AVAILABILITY AND SUSTAINABLE MANAGEMENT OF WATER AND

SANITATION FOR ALL

Access to clean water for cooking and drinking, with improved toilet facilities are important aspects of sanitation and public
health. The developing countries across South East Asia and Africa have lower levels of access to these parameters. Only
71% of the total population use improved or clean water resources and just 45% use improved sanitation facilities, 673
million persons still defecate in open.

The goal aim at improving sanitation and access to improved water for all communities across the globe, reduce water
pollution, improve water consumption efficiency, protect water-related ecosystems, and capacity building to help developing
countries. The targets and indicators are provided in the annexure.

The summary is given below:

1. Access to safe and affordable drinking water to everyone.

2. Adequate and equitable sanitation and hygiene for all.
3. Improve water quality by reducing pollution.
4. Increase water-use efficiency and address water scarcity.
5. Protect and restore water-related ecosystems.
6. Capacity-building support to developing countries in water- and sanitation.
7. Strengthen the participation of local communities.

GOAL 7- ENSURE ACCESS TO AFFORDABLE, RELIABLE, SUSTAINABLE AND MODERN ENERGY

for ALL

Even though the access to electricity and energy efficiency has been increasing across the globe, there are still millions who
lack electrification and clean fuel for cooking and lighting. The areas that are deficient in reliable and sustainable power and
energy are Latin America, Sub-Saharan Africa and South-East Asia. The goal comprises of five targets with indicators to
measure the progress. The targets and indicators are provided in the annexure.

The summary is given below:

1. Universal access to affordable, reliable, and modern energy services.

2. Increase the share of renewable energy in the global energy mix.
3. Double the global rate of improvement in energy efficiency.
4. Share the technology and research related to renewable energy, efficiency and cleaner fuel, and to promote
investment.
5. Modern and sustainable energy services for all in developing countries, especially the least developed countries, small
islands, developing States, and land-locked developing countries.

The global electrification rate rose, from 83% to 90% by 2018 giving power to most people of Latin America and South East
Asia. The power deficient areas are mostly in the Sub-Saharan Africa with 548 million people who make up 53% of the total
population. The access to clean fuels and technologies increased from 60% to 63% by 2018; however, the number of
people without clean fuel access has increased in sub Saharan Africa due to population growth.

The share of renewable energy in the total consumed electricity only increased from 16.3% to 17.3% in 2017. Global
primary energy intensity (the energy used per unit of GDP) improved only by 2.2% every year from 5.2% to 5 % in 2017. The
financial assistance to renewable energy in developing countries reached $21.4 Billion in 2017 with a 13% growth from
2016. 46% of the investments were in hydropower followed by 19% in Solar and 7% in geothermal projects.

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GOAL 8 - PROMOTE SUSTAINED, INCLUSIVE AND SUSTAINABLE ECONOMIC GROWTH, FULL
AND PRODUCTIVE EMPLOYMENT AND DECENT WORK FOR ALL

The goal aims at economic productivity though the development of micro, mini and small enterprises and better resource
consumption. It targets employment for all the working population regardless of sex, and disabilities to have an inclusive
economy. The goal also covers the safe work environment, labor rights, tourism, and access to financial assistance. The
targets and indicators are provided in the annexure. The summary is:

1. Sustain per capita economic growth.

2. Economic productivity from technology, diversification, and innovation.
3. Growth of micro, small, and medium-sized enterprises.
4. Resource efficiency in consumption and production.
5. Full and productive employment and decent work for all.
6. Eradicate forced labour, modern slavery. and human trafficking.
7. Protect labour rights. and promote safe and secure working environments.
8. Sustainable tourism that creates jobs and promotes local culture and products.
9. Expand access to banking, insurance and financial services for all.
10. Trade support for developing countries, in particular, least developed countries.
11. Develop and operationalize a global strategy for youth employment.

GOAL 9 - BUILD RESILIENT INFRASTRUCTURE, PROMOTE INCLUSIVE AND SUSTAINABLE

INDUSTRIALIZATION AND FOSTER INNOVATION

The goal is about inclusive industrialization focusing the developing countries, especially the least developed island nations,
and land-locked countries. The goal covers the support in transportation infrastructure, infrastructure development for
efficiency, access to finance, information, technology, and research for industries. The targets and indicators are provided
in the annexure.

The summary is:

1. Develop sustainable transport infrastructure.

2. Raise industry's share of employment.
3. Access to financial assistance for small-scale industries.
4. Upgrade infrastructure for resource efficiency.
5. Scientific research in industrial sectors.
6. International financial support to least developed countries.
7. Technology development in developing countries.
8. Access to information technology in the least developed countries.

The industrial growth rate has been slow and with the global pandemic in 2020, the industrial sector along with
transportation is the worst affected. In the case of the least developed countries, the share of industries in the GDP
increased marginally from 10% to 12.4% in 2019. 14% of the global workforce is employed in manufacturing with South East
Asia having 18% and Sub-Saharan Africa having just 6%. The greenhouse gas emissions from industries increased
gradually in 2017; however, the emissions are far lower than those of 2000 levels.

GOAL 10 - REDUCE INEQUALITY WITHIN AND AMONG COUNTRIES

The goal is aimed at providing all the countries equal opportunity irrespective of their status of development or financial
powers. This includes special treatment to the least developed nations, safe migration of people, wage equality, assistance
to the bottom poor, and investment in the least developed nations. The targets and indicators are provided in the annexure.
The summary is:

1. Income growth of the bottom 40 percent of the population.

2. Social, economic, and political inclusion of all.
3. Equal opportunity, reduce discrimination, and inequalities of outcome.
4. Equality in wages.

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5. Representation and voice for developing countries in decision-making.
6. Orderly, safe, regular, and responsible migration and mobility of people.
7. Special and differential treatment for developing countries.
8. Foreign direct investment to the least developed nations.
9. Reduce transaction costs of migrant remittances.

The income of the bottom 40% of the population increased in 73 of the 90 countries during the period 2012-17. However,
these bottom 40% received less than 25% of the overall income when the top 10% received more than 20% of the income.
As far as discrimination is concerned, one in five people from 31 countries for the period 2014-19, personally experienced
discrimination on at least one ground of discrimination prohibited by international human rights law.

GOAL 11 - MAKE CITIES AND HUMAN SETTLEMENTS INCLUSIVE, SAFE, RESILIENT, AND
SUSTAINABLE

The growth of population and rapid urbanization has given rise to slums, unsafe and inadequate infrastructure, and pollution
of air and water in most cities. The issue is worse in the developing countries having cities with huge population. The total
slum dwellers in 2018 crossed 1 billion accounting for 24% of the urban population. As assessed from a pool of 610 cities
spread in 95 countries, convenient access to public transport is available only to half of the urban population.

The goal is about having more cities and human settlements with safe and affordable housing and transportation,
sustainable urbanization with control over pollution and waste management, preparedness towards disasters and
adaptability to climate change, and safe public spaces for all. The targets and indicators are provided in the annexure.

The summary is given below:

1. Adequate, safe, and affordable housing.

2. Safe, affordable, accessible, and sustainable transport systems for all.
3. Inclusive and sustainable urbanization.
4. Protect and safeguard the world's cultural and natural heritage.
5. Reduce the number of deaths and the number of people affected by natural disasters.
6. Air quality, municipal and other waste management in cities.
7. Safe, inclusive, accessible, green and public spaces for all.
8. Social and environmental links between urban, semi-urban and rural areas.
9. Resource efficiency, resilience to disasters, and climate change.
10. Support least developed countries for sustainable buildings.

GOAL 12 - ENSURE SUSTAINABLE CONSUMPTION AND PRODUCTION PATTERNS

The economy that depends on the consumption and production uses natural resources that put pressure on the
environment. The per capita material consumption increased from 10.8 metric tons in 2010 to 11.7 metric tons in 2017,
showing an upward trend in all regions, except North America and Africa. North America and Europe has a domestic
material consumption of 40% above the global average. The global material foot print per capita is rising steadily over the
years to 85.9 billion metric tons in 2017 from 73.2 billion metric tons in 2010. The material footprint in 2000 was less than
half of the value in 2017.

The goal aim at responsible and sustainable consumption of material by efficient methods and reduction of wastage by
reuse and recycling. This includes the food waste at retail and consumer levels, doing away with ineffective fossil fuel
subsidies, community based sustainable tourism, transfer of technology and research know how to the developing countries
to employ efficient methods of consumption. The targets and indicators are provided in the annexure.

The summary is given below:

1. 10‑Year Framework on Sustainable Consumption and Production Patterns.

2. Efficient use of natural resources.
3. Reduce global food waste at the retail and consumer levels.

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4. Reduce waste generation through prevention, reduction, recycling, and reuse.
5. Companies to adopt sustainable practices and report them.
6. Sustainable public procurement.
7. Information and awareness for sustainable development.
8. Support developing countries with technology.
9. Sustainable tourism that creates jobs and promotes local culture and products.
10. Rationalize inefficient fossil-fuel subsidies that encourage wasteful consumption.

GOAL 13 - TAKE URGENT ACTION TO COMBAT CLIMATE CHANGE AND ITS IMPACTS

The hazard arising out of climate change and natural disasters is a challenge faced by all the countries regardless of their
contribution to the exploitation of natural resources. The least developing countries and small island states have been the
most vulnerable areas to the effects of climate change, all the while having not being a party to exploitation of natural
resources to a large extent. The global temperatures have been rising continuously for years and there is change in rainfall
patterns causing widespread natural disasters such as heavy flood and landslides. The goal aims at strengthening our
resilience to fighting climate change, climate-based hazards, and natural disasters, making policies in every nation to help
this cause, help the least developed nations, island states to address these challenges. The targets and indicators are
provided in the annexure.

The summary is given below:

1. Resilience and adaptability to climate-related hazards and natural disasters.

2. Climate Change in National Policies.
3. Education, awareness, and training on climate change.
4. Fund for fighting climate change in the least developed countries.
5. Climate change-related planning and management in the least developed countries.

GOAL 14 - CONSERVE AND SUSTAINABLY USE THE OCEANS, SEAS AND MARINE RESOURCES
FOR SUSTAINABLE DEVELOPMENT

Marine pollution, exploitation of marine resources, destruction of corals and other marine habitats, and overfishing has been
rampant across the globe, putting pressure on our oceans. The large-scale exploitation has also affected the livelihood of
small artisanal fishers across nations. The subsidies to fisheries also play a part in this over exploitation. The goal aims at
controlling marine pollution, protecting marine ecosystems and coastal areas, regulating overfishing, and developing
research and technology in developing sustainable use of ocean resources. The targets and indicators are provided in the
annexure.

The summary is given below:

1. Prevent and reduce marine pollution.

2. Protect the marine and coastal ecosystems.
3. Address the impacts of ocean acidification.
4. Regulate harvesting and end overfishing.
5. Conserve coastal and marine areas.
6. Prohibit fisheries subsidies that cause overfishing.
7. Sustainable fisheries in small island States.
8. Develop research and transfer marine technology.
9. Access for small-scale fishers to marine resources and markets.
10. International law for sustainable use of oceans and its resources.

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GOAL 15 - PROTECT, RESTORE AND PROMOTE SUSTAINABLE USE OF TERRESTRIAL
ECOSYSTEMS, SUSTAINABLY MANAGE FORESTS, COMBAT DESERTIFICATION, AND HALT
AND REVERSE LAND DEGRADATION AND HALT BIODIVERSITY LOSS

The exploitation of our forest resources, terrestrial biodiversity, and freshwater biodiversity has been rampant across
countries, leading to many species of flora and fauna going extinct, or critically endangered. The goal aims at sustainable
usage of the forest resources, freshwater biodiversity, protecting the endangered and vulnerable species of animals and
plants, and ending poaching and trafficking of these species. The targets and indicators are provided in the annexure.

The summary is given below:

1. Sustainable use of terrestrial and inland freshwater ecosystems.

2. Sustainable use of forest resources, halt deforestation, & restore degraded forests.
3. Combat desertification, restore degraded land and soil.
4. Conservation of mountain ecosystems.
5. Prevent degradation of natural habitats.
6. Fair and equitable sharing of benefits from genetic resources.
7. End poaching and trafficking of protected species.
8. Reduce the impact of invasive alien species on land and water ecosystems.
9. Biodiversity values into national and local planning.
10. Global participation to end poaching and sustainable forest management.

GOAL 16 - PEACE, JUSTICE AND STRONG INSTITUTIONS

The growth of any country is measured using various parameters like GDP, changes in stock exchange pricesetc. However,
there is no fixed parameter in any country to measure the progress of peace and justice. To maintain peace, certain
countries have stringent norms whereas some countries are not following such practices. There are no common criteria
available in the entire world to bring equality in justice. About $1.26 trillion US dollars are getting wasted due to corruption,
bribery, theft and tax evasion. Out of the 73 percent childbirth under age of 5, only 46 have got registered in the Sub-
Saharan Africa region. It is seen that the communities that are vulnerable across the regions always face unequal treatment
from the regulators, and are prone to violence and injustice in every walks of their life. Based on the observation, it was
identified that judiciary and police are the institutions really affected by corruption. To overcome these hassles, the United
Nation has set sustainable development goal which consist of twelve targets along with specificindicators.

Based on the targets, the actions to be taken to achieve the goal are summarized below:

 Strengthening relevant national institutions to make sure that all people have equal access to justice.
 Reducing illegal flow of arms and wealth.
 Providing legal identification to all.
 Ensuring access to information for the public and protecting fundamental freedoms.
 Eradication of violence against children by building strong institutions through international cooperation.

GOAL 17 - STRENGTHEN THE MEANS OF IMPLEMENTATION AND REVITALIZE THE GLOBAL

PARTNERSHIP FOR SUSTAINABLE DEVELOPMENT

A stronger commitment to partnership and cooperation is needed to achieve the SDGs. Attaining the Goals will require
coherent policies, an enabling environment for sustainable development at all levels and by all actors, and a reinvigorated
Global Partnership for Sustainable Development. Partnerships and Goals refer to the need for cross-sector and cross-
country collaboration in pursuit of all the goals by the year 2030. It is a call for countries to align policies. It is a vision for
improved and more equitable trade, as well as coordinated investment initiatives to promote sustainable development
across borders. It is about strengthening and streamlining cooperation between nation-states, both developed and
developing, using the SDGs as a shared framework, and a shared vision for defining that collaborative way forward.

SDG 17 for the partnerships has 19 targets and their indicators are categorized as 5 in finance, 3 in technology, 1 in
capacity building, 3 in trade and the rest 7 in systemic issues. The targets broadly aim at:

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 Strengthening domestic resource mobilization in developing countries.
 Attaining debt sustainability in developing countries.
 Transfer of technology in banking, communication, etc. to developing countries.
 Duty free access to the markets for the least developed countries.

1.5 NATIONAL GUIDELINES ON RESPONSIBLE BUSINESS CONDUCT, 2018 (NGRBC)

1.5.1 BACKGROUND

There was no India specific corporate framework, either voluntary or mandatory, relating to sustainable development till
2011, when the Ministry of Corporate Affairs (MCA) released the National Voluntary Guidelines (NVG).

 NVG is a set of guidelines to the Indian business enterprises to operate considering their responsibilities related to
economy, environment and society.
 It is based on the triple bottom-line principle of sustainability, and is appropriate for organisations of every size,
sector and management, and is specific to the Indian context.
 It had nine elements namely Ethics, transparency and accountability, Product life-cycle sustainability, Employee
well-being, Stakeholder engagement, Human rights, Environment, Policy advocacy, Inclusive growth and equitable
development, and Value to customers and consumers.
 The NVG also had a guidance to implement use of its four concepts of leadership, integration, engagement, and
reporting.
 It also had supplementary annexures that laid out the business case for taking up the guidelines, the related
regulatory frameworks and legislation.
 It had a separate section for the Micro, Small, and Medium Enterprises (MSMEs), about the methods of
application.
 The Securities and Exchange Board of India (SEBI) mandated that the organisations release an annual report on
their Business Responsibility in line with the NVGs.

There were many mechanisms and guidelines that were released by the international and national bodies that urged the
Indian authorities to revise and align the NVGs such as:

 The UN Guiding Principles for Business and Human Rights (UNGPs) 2011
 Annual Business Responsibility Reports (ABRRs)
 Section 135 of Companies’ Act 2013
 The UN Sustainable Development Goals (UNSDGs) 2015
 Paris Agreement on Climate Change (2015)
 Core Conventions 138 and 182 on Child Labour by the International Labour Organization (ILO)

This revision of the NVGs started off after the UNSDGs were released in 2015 and finally resulted in a new principle for
sustainable reporting in the Indian context, called the National Guidelines on Responsible Business Conduct (NGRBC). This
new mechanism is to be used by all organisations operating in India, irrespective of their size and scale of operation, sector
of engagement, structure, or location. This is also applicable to foreign multinational companies that operate in India. In
addition to following these guidelines, the organisations are also expected to encourage and support their suppliers,
vendors, distributors, partners, and other collaborators to follow them.

1.5.2. STRUCTURE

There are two chapters and a set of annexures in the structure of the NGRBC.

 The first chapter is the introduction that gives the context, background, and development of the NGRBC guidelines
and the drivers of formulation.
 The second chapter describes the core elements and principles of NGRBC.

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  Even though the principles have been revised or updated, their explanation as in NVGs is retained in NGRBC.
 There is a total of nine principles as in the case of NVGs, and for each principle, the connected Core elements
provide for their operationalization.
 There are eight annexures in the document to the nine principles.

Introduction Principles 8
and and Core Annexures
Elements

1.5.3. CONTENT OF NGRBC- 9 PRINCIPLES & CORE ELEMENTS

A set of requirements are provided with each Principle, and they are essential to meet the essence of the corresponding
Principle. The principles are all related, complement each other, non-divisible, and the expectation from the organisation is
that they take up the requirements and principles holistically. India being a confluence of several diverse communities and
cultures, the context of every organisation may be very different to another. When the organisations have these principles
implemented, they are required to approach them with sensitivity with regard to social features such as caste, race,
ethnicity, gender, age, religion, and class so as not to trigger a feeling of marginalization or discrimination.

PRINCIPLE 1 - BUSINESSES SHOULD CONDUCT AND GOVERN THEMSELVES WITH

INTEGRITY, AND IN A MANNER THAT IS ETHICAL, TRANSPARENT, AND ACCOUNTABLE.

The first principle is about the governance structure of the organisation. It should be based on ethical ways of doing
business with integrity and accountability. It is based on the organisation’s need to be truthful and transparent to its
stakeholders, and make all information ,about the decisions taken on matters that affect them, accessible to them. This also
emphasizes that the structure of governance is in line with the UN Sustainable Goal 16 for Peace, Justice, and Strong
Institutions. The core elements of the principle are all about the way governance structure is to be made.

The governing structure of the organisation should:

 Formulate a system of policies and procedures that promote the principle, and prevent misuse by effective actions
 Make sure that the principles of the guideline are made available, communicated, trained, and implemented in every
function and operation of the organisation.
 Encourage the implementation of this principle in the overall value chain of the business.
 Transparently report and make available the information to all the stakeholders and affected parties. This information
should cover the strategies, policies, procedures, practices, financial and non-financial performance, such as pollution,
resource usage, affected environment and communities.
 Comply with all the legal and statutory requirements and obligations, facilitate fair competition, and treat stakeholders
with equality and justice.
 Deal strictly with third parties that violate or dilute the principle.
 Have a system that identifies and avoids all kinds of conflicts of interests among the stakeholders
 Have a system that prevents illegal and unfair practices and ensures actions against violations.
 Ensure timely payment of all taxes, levies, and duties relating to the business.

PRINCIPLE 2 - BUSINESSES SHOULD PROVIDE GOODS AND SERVICES IN A MANNER THAT IS

SUSTAINABLE AND SAFE.

The second principle is related to the UN Sustainable Goal 12 for production and consumption of resources. It focuses on
protecting earth’s natural resources by responsible consumption, efficient production creating value adding products with
reduced impacts to the environment and society throughout the product life cycle from concept to disposal. The core idea is
to have circularity in the operations to have material sustainability in the whole value chain and to

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 Encourage resource-efficient and low carbon-emitting methods and technologies for the design and manufacture of
products and services, lowering environmental and social impacts.
 Provide adequate and accurate information to the stakeholders about the impacts to the environment and society due
to the product or service throughout the lifecycle from concept to disposal. This can be done though product labeling,
company websites, advertisements, and promotional programs.
 Make efforts to take back the waste generated such as the used packaging or the spent consumables, reuse or
recycle, or dispose them without affecting the environment or people.

PRINCIPLE 3 - BUSINESSES SHOULD RESPECT AND PROMOTE THE WELL-BEING OF ALL

EMPLOYEES, INCLUDING THOSE IN THEIR VALUE CHAINS.

 The equity, dignity, and quality of life for the employees are the crux of this Principle and are related to the UN SDG 8
for Decent Work and Economic Growth. This covers all the people in the complete value chain, addressing all kinds of
discrimination and encouraging diversity. The quality of life encompasses the whole family of the employee. There are
ten core elements to the principle that covers both the organization and the entities in its value chain. Both entities must
comply with the regulatory and statutory requirements, and further:Provide equal opportunity to all the employees
during recruitment, promotions, appraisals, and exit from the organisation
 Encourage collective bargaining, unions and associations, and have appropriate systems for grievance redressal
 Prevent child labour and slave labour in all forms
 Support work life balance for all employees
 Provide timely wages and payments with transparency in all kinds of calculations, that meets the fair wage for decent
living
 Provide a safe and hygienic place of work with provisions for gender specific requirements
 Provide required training and skill up gradation for the employees with access to learning opportunities
 Prevent violence, harassment, and bullying in the workplace.

PRINCIPLE 4 - BUSINESSES SHOULD RESPECT THE INTERESTS OF AND BE RESPONSIVE TO

ALL ITS STAKEHOLDERS.

The principle focuses on the fact that there are other stakeholders apart from investors, clients, and employees, and the
organisation has a responsibility towards the public at large, as the operations impact the natural resources, natural habitats,
water bodies, communities etc. Organisation has to take into account the expectations of all the interested parties to their
business, both external and internal, and specifically to the affected vulnerable groups and communities. They have to
reduce the adverse effects to any stakeholder from their products or services in any part of the life cycle. The core elements
cover:

 Organisations should have system to disclose the impacts from their operations transparently to stakeholders
 Organisation should identify their stakeholders, both external and internal, determine the expectations of these
interested parties, and devise their strategies accordingly to address them.
 The benefits of the business should be passed on to the affected parties and the organisation is responsible to resolve
any conflicts and grievances related to their operation with the affected parties with fair and just compensations and
alternate arrangements.

PRINCIPLE 5 - BUSINESSES SHOULD RESPECT AND PROMOTE HUMAN RIGHTS.

The Principle is driven by the Constitution of India and the International Bill of Rights, and is based on the duty of the nation
to safeguard, protect, and hold up the human rights. The principle is based on the concept that the human rights are
inherent to every human being, is non-negotiable, and not to be diluted in any manner for the sake of business. UN Guiding
Principles on Business and Human Rights also consider the human rights as a responsibility of the business concerns and
requires them to be responsible for any violation, and take adequate steps to make sure that no human rights abuse
happens because of their business operation. There are five core elements to this Principle as below:

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 The governing structure of the business should make sure that the human rights requirements in the Constitution of
India and other laws prevailing in India along with the International Bill of Rights is communicated to its employees and
collaborators, and if there is any potential for human rights impact, there should be relevant authority to handle them.
 The governing system of the organisation should have policies, structure and procedure to identify and mitigate any
possible human rights violations from its operation.
 The organisation should adequately address mitigation of the human rights issues arising out of their operations and
have effective corrective actions to avoid recurrence.
 Have promotional programs and drives across the value chain to educate the employees and raise awareness about
the human rights violations and how it can happen from their operations.
 Effective grievance redressal mechanisms in place for all the affected groups and communities to raise their concerns
to the organisation.

PRINCIPLE 6 - BUSINESSES SHOULD RESPECT AND MAKE EFFORTS TO PROTECT AND

RESTORE THE ENVIRONMENT.

The Principle is aligned to the UN SDG 11 for Sustainable Cities and Communities, SDG 13 for Climate Action, SDG 14 for
Life below water, and SDG 15 for Life above land. This is based on the fact that our responsibility to protect the nature and
environment is an integral prerequisite for sustainable economic growth, and for the well-being of society. The issues of
environment are interconnected from local levels to regional levels, and can adversely affect a number of stakeholders via
destroying the natural biodiversity of our planet through issues like pollution, resource depletion, climate change, habitat loss
and poor quality of life.

The principle urges the organisations to explore and identify the potential environmental impacts arising out of their
operations and supply chain, and to address them with adequate mitigating measures. It also encourages the organisations
to find ways of operating by causing fewer impacts to the environment from a precautionary approach to the issues. There
are six core elements linked to this principle as below:

 Systems to have identification of environmental impacts, and suitably reviewing them to formulate adequate mitigating
mechanisms in the whole value chain. The review to have extra focus on environmentally fragile and protected areas, if
applicable.
 The organisations should explore ways of reducing the consumption of natural resources such as fossil fuels, water,
electricity, and different raw materials used such as metals, minerals, and forest products.
 The organisations should have measurable performance indicators for environmental issues such as energy, fuels, air,
water, land use, pollution, waste generation, and materials.
 The organisations should have a climate change mitigation program in line with the requirements of the national legal
framework and the international treaties such as the Paris Agreement.
 The organisations should look at the best practices of reuse, reduce, recycle, and recovery of the resources and
materials, and encourage and motivate their stakeholders including the people in their value chain.
 Improve the performance of the organisations with respect to the environment by creative, efficient, and less carbon
intensive technologies and solutions, resulting in lower resource footprint and lesser material consumption

PRINCIPLE 7 - BUSINESSES, WHEN ENGAGING IN INFLUENCING PUBLIC AND REGULATORY

POLICY, SHOULD DO SO IN A MANNER THAT IS RESPONSIBLE AND TRANSPARENT.

The Principle is based on the understanding that national and international legal frameworks have a very important effect on
the businesses that operate within that area, and decide their growth prospects in a significant manner. The principle does
not forbid the organisation to work with government for policy formulations, but reiterates that the organisation has a
responsibility to be transparent. The core elements include:

 The organisation should have a system of having complete public disclosure when in an advocacy role consistent with
the NGRBC.
 The Industry associations and trade and commerce groups should be used to take up policy advocacy to the
Government, especially in matters that affect the policies that relate to the organisation.
 Businesses should ensure that its policy advocacy positions promote fair competition and respect for human rights.

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PRINCIPLE 8 - BUSINESSES SHOULD PROMOTE INCLUSIVE GROWTH AND EQUITABLE
DEVELOPMENT.

The Principle is guided by Section 135 of the Companies Act, 2013 that calls for a specific focus on disadvantaged,
vulnerable, and marginalized communities. The principle is also in line with the UN SDG 17 for Partnerships for
sustainability. The large sections of the under privileged population in India face economic and social challenges which is
detrimental to the inclusive growth in the country. The principle revolves around the concept that the economic prosperity,
inclusive growth, and equitable development are related to each other. The core elements to this principle are as below:

 The organisation should have systems in place to identify and address impacts to the social, cultural, and economic
aspects of the people. This includes business created issues like land acquisition and use and construction activities for
new facilities.
 The organisation should make efforts to bringing up creative products, technologies, and business concerns that help
the marginalized communities to have well-being and a better quality of life.
 Organisations when designing their CSR activities, should review the local and regional development priorities to help
the marginalized groups and communities.
 The organisation should take care to ensure that business induced displacement or relocation of communities does not
happen, and in unavoidable cases, should make sure to have mutually agreed, participative, and informed negotiations
to provide fair compensation to the affected people.
 All forms of intellectual property and traditional knowledge should get the deserved respect from the organisation, and
efforts should be made to ensure that benefits derived from their knowledge are shared equitably.

PRINCIPLE 9 - BUSINESSES SHOULD ENGAGE WITH AND PROVIDE VALUE TO THEIR

CONSUMERS IN A RESPONSIBLE MANNER.

This Principle is related to the concept that the primary purpose of the business enterprise is to create wealth by producing
quality products, or delivering services to the targeted customer, and keeping them satisfied to mutually benefit both the
parties. The principle comprehends that the customer has a freedom of choice of the products and services, and hence the
organisations will put their efforts to provide quality at affordable and reasonable process, that are easy to use and dispose
of. It also aligns with the UN SDG-12 for responsible consumption and production, when is expects the business
organisations to educate, make information available to the customers about the impacts of excessive usage of the products
to their well-being, and to the society or the planet. There are eight core elements for this principle as below:

 Organisations should put in their efforts to reduce the negative impacts of their products and services on consumers,
natural environment and society at large.
 When conceptualizing, designing, and marketing their products, the organisation should not, in any manner, prevent
the freedom of choice and fair competition.
 The organisation should transparently and accurately disclose all kinds of adverse impacts to the user, planet, society,
on the biodiversity from their products. This may be done by labeling, marketing, or by providing information on their
social media platforms.
 When handling customer data, the right to privacy of the customer needs to be maintained.
 Organisations should inform the consumers on the safe and responsible ways of usage, reuse, recycling, and disposal
of their products, and ways to eliminate over-consumption.
 When advertising about their products, the organisations should ensure that misleading and confusing information is
not exposed to the consumers about their products or its usage.
 Business enterprises should make available transparent and accessible grievance redressal and feedback
management system for their consumers to raise their voices or to seek clarifications
 Organisations, when in the business of providing essential goods and services (e.g. Utilities), should enable universal
access, including to those whose services have been discontinued for any reason, in a non-discriminatory and
responsible manner.

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1.5.4 CONTENT OF NGRBC - ANNEXURES

ANNEXURE 1- GUIDANCE ON ADOPTION OF NGRBC

The term “adoption” refers to having the nine NGRBC principles in line with the organizations strategy and policies, and not
as a separate additional standalone system. The principles should become the integral part of the overall behaviour of the
company. This will need some enablers or prerequisites such as:

 Commitment from the top management for the adoption of the nine principles
 Engagement from the employees of the organisation
 Continuous relation with the stakeholders
 Transparent public disclosures by the organisation

The adoption of NGRBC is to be done in four continuous steps as in any management system. The steps are as under:

1. Prioritize the core elements - As a start, identify the context of the organisation, the mission and vision, and
determine the sustainability issues that are more significant through a risk assessment. This review should cover
the legal, regulatory, and statutory requirements that apply to the organisation.
2. Review and develop policies - Review the current set of policies, strategies, procedures, and standard practices in
the organisation with respect to the core elements prioritized (step 1 above) and change them if required. If there
is any major change to the policy, get approval from the top management.

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 3. Determine Ambition - The organisation should decide up to what level they want to take up the initiatives. The
guidelines provide two levels of Essential (basic minimum thing to be done) and Leadership (challenging and
additional things). This is provided elaborately in Annexure 3. The core elements identified have to be cascaded to
the value chain of the business as well.
4. Set targets - Select suitable indicators for each of the core elements and select an appropriate target value to be
achieved for each indicator. E.g. if the element is about reducing the electricity consumption, the indicator can be
the %age or the units of electricity reduced, and the target can be 20% of current value, or 200,000 units per year.

ANNEXURE 2 - GUIDANCE FOR MICRO, SMALL AND MEDIUM ENTERPRISES

The Micro, Small and Medium Enterprises (MSME) are the lifeline of the economy that provide jobs to the poorer section of
the society and hence an important element. However, the resources for adoption of the NGRBC guidelines are limited
compared to big corporate organisations. Adoption of sustainable and ethical practices can give them entry to bigger and
wider markets, and hence is a business case too.

This guideline annexure is a simplified form shown in the previous guidelines for large organisations for a two-stage process.
The first one being identification of the core elements relevant to them. This should cover the mission and vision of the
management, legal requirements that apply to them, and the customer requirements they have in the respective core
element. The MSMEs may set their ambition level to the essential depending on their resources, and set measurable
indicators and targets for each of the core elements.

ANNEXURE 3 - BUSINESS RESPONSIBILITY REPORTING FRAMEWORK (BRRF)

This is a format for reporting the corporate responsibility of the organisation. It is made as three sections A, B and C.
Section A has general information related to the organisation, its product or services, financial and ownership details.
Section B has a list of all the policies, procedures, and strategies against each of the nine principles as a matrix. There is a
total of 18 questions, of which 1 to 5 are about the policies, 6 to 10 are on governance, leadership and oversight, 11 to 14 on
stakeholder engagement, and 15 to 18 on communications. Section C contains the principle wise indicators and targets
segregated as two columns of Essential and Leadership that the organisation needs to choose.

Section A
General information about products, financials, ownership etc.

Section B
Policies - 1 to 5
Governance & Leadership - 6 to 10
Stakeholder engagement - 11 to 14
Communications- 15 to 18

Section C
Performance Indicators -28Essential and Leadership
ANNEXURE 4 - SDGS MAPPED AGAINST THE NGRBC PRINCIPLES

17 SDGs mapped to the related NGRBC principles as a matrix.

SDG NGRBC Principle SDG NGRBC Principle SDG NGRBC Principle

SDG-1 P3, P4, P8 SDG-7 P2, P6, P7 SDG-13 P2, P6, P7, P8

SDG-2 P2, P6, P7, P8, P9 SDG-8 P2, P3, P5, P8 SDG-14 P2, P6, P7, P8, P9

SDG-3 P3, P6, P8 SDG-9 P3, P4, P8 SDG-15 P2, P6, P7, P8, P9

SDG-4 P3, P8, P9 SDG-10 P2, P6, P7 SDG-16 P1, P3, P4, P5, P8

SDG-5 P3, P4, P5, P8 SDG-11 P3, P4, P7, P8 SDG-17 P1, P7, P8

SDG-6 P2, P6, P8 SDG-12 P2, P6, P9

ANNEXURE 5 - BUSINESS CASE MATRIX

It is a matrix on which the nine NGRBC principles are mapped against six business benefits as given below. The matrix
shows the potential benefits that can be achieved against each of the principle:

1. Revenue growth and market access

2. Cost savings and productivity
3. Access to capital
4. Risk management / license to operate
5. Human capital
6. Brand value / reputation

ANNEXURE 6 - GUIDANCE FOR BUSINESSES ON USING THE BRRF AS A SELF-ASSESSMENT

TOOL

The alignment to the nine principles of NGRBC can be checked using the Business Responsibility Reporting Framework
(BRRF) provided in the Annexure 3. The sections B and C when filled up can be assessed using this self-assessment tool.

Section High (20) Medium (15) Low (10) Other (5)

Q 1 complete, Q
1,5,7,8 and 10 5 OR 7 OR Q 8 Q 1 and five of
B All Complete
complete and seven of the others complete
others complete

All Essential and All Essential Some but not all

C All Complete
Leadership Complete complete Essential complete

Overall Above 180 150 to 180 120 to 150 Below 120

ANNEXURE 7- INDIAN LAWS AND PRINCIPLES (INDICATIVE)

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The annexure 7 shows a matrix of the nine principles of NGRBC with some of the major laws that an organisation has to
comply with when operating in India. This mapping is suggestive/indicative and the organisations have to map using the
laws that are relevant in their sector and operations.

ANNEXURE 8 - RESOURCES

The Annexure 8 of the document give the resources referred to draft the document NGRBC principles and segregated them
as national and International origin (15 national and 23 international resources are listed in the Annexure 8)

1.6 DETAILED ANALYSIS OF SDGS AND NGRBC LINKAGE

The commitment to the 17 Sustainable Development Goals set by the UN in 2015 to be achieved in 2030led to the revision
of National Voluntary Guidelines (NVGs) which are updated to the NGRBC. After the NGRBC was released, the Securities
and Exchanges Board of India (SEBI) in November 2019, made the Business Responsibility Report (BRR) mandatory for the
top 1,000 listed companies which is in line with the nine principles of the NGRBC. The nine NGRBC principles are made in
line with the 17 sustainable goals and the mapping between the two is provided in the Annexure 4 of the NGRBC to show
what principles are related to each of the 17 goals. The expectations from the organisations to contribute towards the UN
sustainable development goals are given.

UN SDG NGRBC

Sustainability for all Expectation from Indian Corporate

U.N. SUSTAINABLE GOAL 1 - END POVERTY IN ALL ITS FORMS EVERYWHERE

The SDG-1 aims at eradicating poverty throughout the world, provide equal opportunity to the economic resources, and to
end the climate risk exposure to the poor, by making policies and frameworks, along with strong partnerships and
cooperation. There are a total of 7 indicators covering them. A significant number of the world’s poor live in India and hence
eradication of the extreme poverty, ensuring them equal access to economic resources is an enormous challenge that India
is facing. The NGRBC principles that are designed for SDG 1 are Principles 3, 4 and 8.

 Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value
Chains - Providing decent and fair living wages to the employees in the organisation.
 Principle 4: Businesses should respect the interests of, and be responsive to all its stakeholders - Passing on the
benefits from the business to the marginalized communities.
 Principle 8: Businesses should promote inclusive growth and equitable development - Section 135 of the Companies
Act, 2013 calls for a specific focus on disadvantaged, vulnerable, and marginalized communities.

U.N. SUSTAINABLE GOAL 2 - END HUNGER, ACHIEVE FOOD SECURITY AND IMPROVED
NUTRITION AND PROMOTE SUSTAINABLE AGRICULTURE

The SDG-2 aims at ending hunger, providing nutritious food, and increasing agricultural production, while keeping the
diversity of the seeds and species in mind. There are a total of 8 indicators covering the goal. India being an agricultural
country with a huge rural population that is facing malnutrition and poverty, there is a lot for India to achieve. The NGRBC
principles that are related to the Goal are the Principles 2,6,7,8, and 9.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe - Safe products to
the customer.

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 Principle 6: Businesses should respect and make efforts to protect and restore the environment - Conservation of the
nature and environment.
 Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent - The organisations in an advocacy role to policymaking should have public good as their
focal point, and do so transparently.
 Principle 8: Businesses should promote inclusive growth and equitable development - Providing for the disadvantaged,
vulnerable communities as prescribed by Section 135 of the Companies Act, 2013.
 Principle 9: Businesses should engage with, and provide value to their consumers in a responsible manner- The
organisations are to disclose the content of the product in a transparent way and ensure that any impact is
communicated.

U.N. SUSTAINABLE GOAL 3 - ENSURE HEALTHY LIVES AND PROMOTE WELL-BEING FOR ALL
AT ALL AGES

The SDG-3 aims at health and quality of life for every section of the society, and covers all general health indices such as
infectious diseases, infant mortality, maternal mortality, life expectancy, etc. There are 13 indicators covering this goal. India
fares less than average in terms of health indices in general, and has very poor values in some geographic regions due to a
variety of reasons. The principles 3, 6 and 8 cover the elements of the goal for India.

 Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value
Chains- Providing safe and8 healthy work environment and fair living wages to the employees in the organisation.
 Principle 6: Businesses should respect and make efforts to protect and restore the environment - Conservation of
nature and environment for a healthy life of the inhabitants.
 Principle 8: Businesses should promote inclusive growth and equitable development - Providing for the disadvantaged,
vulnerable communities as prescribed by section 135 of Companies Act, 2013.

U.N. SUSTAINABLE GOAL 4 - ENSURE INCLUSIVE AND EQUITABLE QUALITY EDUCATION AND
PROMOTE LIFELONG LEARNING OPPORTUNITIES FOR ALL

The SDG-4 aims at education and learning for all with equal opportunities for access. The indicators cover different sections
such as primary education, technical and job related, etc. and are expressed as 10 measurable indicators. India as a nation
lags in terms of quality education for all and faces several challenges such as poverty that augments the issue. To urge
organisations to contribute towards sustainability, the NGRBC principles included are Principles 3, 8 and 9.

 Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value
Chains - Providing skill up-gradation and learning opportunities to the employees in the organisation.
 Principle 8: Businesses should promote inclusive growth and equitable development - Every form of intellectual
property and traditional knowledge be respected in the organisation and make efforts to ensure that benefits derived
from their knowledge are shared equitably.
 Principle 9: Businesses should engage with and provide value to their consumers in a responsible manner- The
organisations are to disclose the content of the product in a transparent way and ensure that any impact is
communicated.

U.N. SUSTAINABLE GOAL 5 - ACHIEVE GENDER EQUALITY AND EMPOWER ALL WOMEN AND
GIRLS

The SDG-5 aims at ending all forms of violence and discriminations due to gender differences, and to provide opportunities
for empowerment to women and girls. This cover finding ways to give equal opportunity irrespective of gender and has 9
indicators covering them. The state of women in India is much worse compared to other developed countries and how the
corporate can contribute to increasing equality and empowerment of women is provided in the principles 3, 4, 5 and 8 of the
NGRBC.

 Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value
chains - providing a workplace that gives dignity and safety to women.

31
 Principle 4: Businesses should respect the interests of and be responsive to all its stakeholders - Identifying the needs
of the stakeholders - women in this case.
 Principle 5: Businesses should respect and promote human rights - Identification of violence and other human rights
issues and providing an effective grievance redressal system for women.
 Principle 8: Businesses should promote inclusive growth and equitable development - Organisation to ensure that
equal opportunities and treatment is ensured for the women stakeholders.

U.N. SUSTAINABLE GOAL 6 - ENSURE AVAILABILITY AND SUSTAINABLE MANAGEMENT OF

WATER AND SANITATION FOR ALL

The SDG-6 is about ensuring clean water for drinking and other household activities, and access to hygienic toilets for all.
Sanitation and clean water have been a problem in most parts of India. Even though recent drives have made the conditions
better, as a country, India still lags in these parameters.8 indicators are used to monitor the water and sanitation coverage.
The organisations in India can contribute to achieving SDG 6 through the principles 2, 6 and 8.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe- Reducing wastage
by reuse, recovery, and recycling of effluent and by preventing water pollution. They also need to provide the extent of
impact on the stakeholders.
 Principle 6: Businesses should respect and make efforts to protect and restore the environment - Organisations can
prevent the pollution of water bodies by reducing the consumption, wastage, effluent let off, etc.
 Principle 8: Businesses should promote inclusive growth and equitable development - Organisations can find out local
and regional development priorities, and plan their CSR to help the communities.

U.N. SUSTAINABLE GOAL 7 - ENSURE ACCESS TO AFFORDABLE, RELIABLE, SUSTAINABLE

AND MODERN ENERGY FOR ALL

The SDG-7 is about ensuring reliable energy sources for lighting, cooking, and living at affordable rates for all. Electrification
has improved in most parts of India, but still, there are many regions deprived of affordable power. 5 indicators cover this
sustainable goal, and the principles that contribute to achieving the goal are principles 2, 6 and 7.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe - Energy efficient
and less carbon-efficient ways of operation and production processes.
 Principle 6: Businesses should respect and make efforts to protect and restore the environment - Organisations can
contribute by conserving energy usage and adding renewable sources to generate their power requirement.
 Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent - Organisations can use industry associations and trade groups to contribute towards
renewable energy development in India.

U.N. SUSTAINABLE GOAL 8 - PROMOTE SUSTAINED, INCLUSIVE AND SUSTAINABLE

ECONOMIC GROWTH, FULL AND PRODUCTIVE EMPLOYMENT AND DECENT WORK FOR ALL

The SDG-8 is about economic progress, jobs, productivity, and overall prosperity for a sustainable economy. This covers
the exploitation in the job market such as child labour, forced labour and safety at work. Further, it also covers the sectors
such as sustainable tourism that boost the overall economy of a region, giving jobs to a value chain. There are 10 indicators
for this sustainable goal and many of them directly relate to having a successful business enterprise that generates jobs and
livelihood for many. As a nation, India needs job creation and economic progress. The ways by which organisations in India
can contribute are given in principles 2, 3, 5 and 8 of the NGRBC.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe - Using efficient
methods of operation through reuse, reduce, recycle and having a strong disclosure system to the stakeholders.
 Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value
chains - providing a safe and fair workplace that promotes equality and provide equal opportunities to jobs,
employment, promotions and payment of timely and fair wages.
 Principle 5: Businesses should respect and promote human rights - Identification of violence and other human rights
issues and providing an effective grievance redressal system.

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 Principle 8: Businesses should promote inclusive growth and equitable development - Being equal opportunity
employer, preventing discrimination at work, and driving inclusive growth covering all stakeholders.

U.N. SUSTAINABLE GOAL 9 - BUILD RESILIENT INFRASTRUCTURE, PROMOTE INCLUSIVE AND

SUSTAINABLE INDUSTRIALIZATION AND FOSTER INNOVATION

The SDG-9 is about industrialization and giving focus to small scale industries, providing infrastructure, being less carbon-
intensive, and having the latest technology-based industries. There are 8 indicators related to this goal. India even though
industrialized, the growth is not organic, does not cover the growth of the small-scale sector and high technology industries.
Principles 3, 4 and 8 of the NGRBC cover this sustainable goal.

 Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value
chains - Providing a safe, hygienic, adequate environment to work, and provide decent, fair wages to the employees.
 Principle 4: Businesses should respect the interests of, and be responsive to all its stakeholders- Identifying the needs
of the external and internal stakeholders, and addressing their issues fairly.
 Principle 8: Businesses should promote inclusive growth and equitable development - Addressing impacts from
businesses such as land acquisition, displacement, creative products, and services to help the marginalized
communities.

U.N. SUSTAINABLE GOAL 10 - REDUCE INEQUALITY WITHIN AND AMONG COUNTRIES

The SDG-10 is about providing opportunities to the developing countries to catch up with the western industrialized nations.
The ten indicators cover changes in trade and commerce along with adequate participation and access to markets to have
a fair chance. India being a developing country also has to catch up and the organisations in India can contribute to that
through principles 2, 6 and 7.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe - Energy efficient,
with less carbon intensive ways of operation and production processes.
 Principle 6: Businesses should respect and make efforts to protect and restore the environment - Organisations can
contribute by having efficient use of resources, less energy-intensive methods to compete with the developed world.
 Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent - Organisations can use industry associations and trade groups to contribute towards
increasing trade exploring new markets and segments.

U.N. SUSTAINABLE GOAL 11- MAKE CITIES AND HUMAN SETTLEMENTS INCLUSIVE, SAFE,
RESILIENT AND SUSTAINABLE

The SDG-11 is about providing affordable housing, adequate public transport, clean and safe drinking water in the urban
areas. It is covered in ten indicators like the proportion of slum areas, access to public transportation, access to clean
drinking water, etc. India being a developing country with a considerable slum population in the major cities, has a long way
to go as far as sustainable urban areas are concerned. The contributions of the Indian organisations are elaborated in
principles 3, 4, 7, and 8.

 Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value
chains - providing decent, fair wages to the employees and work benefits contributing towards the living standard of
employees.
 Principle 4: Businesses should respect the interests of and be responsive to all its stakeholders - Benefits from the
business can be passed on to the affected communities. The organisation has to plan its operations considering the
impacts on the urban areas.
 Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent- Organisation when in an advocacy role, can affect policies that cover the urban
development.
 Principle 8: Businesses should promote inclusive growth and equitable development - Addressing impacts from
businesses such as land acquisition, displacement, and considering issues of marginalized communities when planning
their CSR activities.

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U.N. SUSTAINABLE GOAL 12 - ENSURE SUSTAINABLE CONSUMPTION AND PRODUCTION
PATTERNS

The SDG-12 is about reducing material footprint, resource consumption, controlling wastage, recycling, and reuse to
increase sustainability. The goals are covered in ten indicators that promote efficient usage. India being a poor country with
a huge population has to be responsible for the resource consumption as well as efficient production processes to ensure a
sustainable way forward. Organisations in India can help in this through efficient ways of manufacturing though the
principles of 2, 6, and 9.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe - Energy efficient,
less carbon-intensive ways of operation and production processes, reduce, reuse, and recycle for waste reduction.
 Principle 6: Businesses should respect and make efforts to protect and restore the environment - Organisations can
prevent or reduce pollution by reducing waste disposal and emissions.
 Principle 9: Businesses should engage with, and provide value to their consumers in a responsible manner -
Organisations should inform the consumers on safe and responsible ways of usage, reuse, recycling, and disposal of
their products including ways to eliminate over-consumption.

U.N. SUSTAINABLE GOAL 13 - TAKE URGENT ACTION TO COMBAT CLIMATE CHANGE AND ITS
IMPACTS

The SDG-13 is about fighting climate change by controlling the sources of GHG emissions. The goals are covered in 5
indicators that look at disaster related deaths, total greenhouse gas emissions, awareness, legal frameworks, etc.
Organisations in India can help in this by reducing the GHG emissions, improving resource usage efficiency through
NGRBC principles 2, 6, 7, and 8.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe – Energy-efficient
and less carbon-efficient ways of operation and production processes, reduce, reuse, and recycling for waste reduction.
 Principle 6: Businesses should respect and make efforts to protect and restore the environment - Organisations can
prevent or reduce the emission of GHG to the air
 Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent - Organisation when in an advocacy role, can affect policies that cover the climate
resilience
 Principle 8: Businesses should promote inclusive growth and equitable development - Organisations when designing
their CSR activities, should review the local and regional development priorities to help the marginalized groups and
communities.

U.N. SUSTAINABLE GOAL 14 - CONSERVE AND SUSTAINABLY USE THE OCEANS, SEAS AND
MARINE RESOURCES FOR SUSTAINABLE DEVELOPMENT

The SDG-14 is about conserving our marine resources and ecosystems sustainably. The goals are covered in 10 indicators
that look at marine pollution, ocean acidification, overfishing, habitat destruction, mangrove and coral conservation, and help
small island nations, etc. Organisations in India can help in this through NGRBC principles 2, 6, 7, 8, and 9.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe - The organisations
should make efforts to take back the waste generated such as used packaging or spent consumables, reusing,
recycling or disposing them without affecting the environment or people.
 Principle 6: Businesses should respect and make efforts to protect and restore the environment – Sustainably extract
the marine resources and prevent water pollution that eventually ends up in the sea.
 Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent - Organisation when in an advocacy role, can affect policies that cover the ocean
conservation.
 Principle 8: Businesses should promote inclusive growth and equitable development - Organisations when designing
their CSR activities, should review the local and regional development priorities to help the coastal groups and
communities.

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 Principle 9: Businesses should engage with and provide value to their consumers in a responsible manner -
Organisations should inform the consumers on safe and responsible ways of usage, reuse, recycling and disposal of
their products, including ways to eliminate over-consumption.

U.N. SUSTAINABLE GOAL 15 - PROTECT, RESTORE AND PROMOTE SUSTAINABLE USE OF

TERRESTRIAL ECOSYSTEMS, SUSTAINABLY MANAGE FORESTS, COMBAT DESERTIFICATION,
AND HALT AND REVERSE LAND DEGRADATION AND HALT BIODIVERSITY LOSS

The SDG-15 is about conserving our forest resources and terrestrial ecosystems sustainably. The prevention of habitat
destruction, deforestation, land degradation, over extraction, wildlife trafficking, poaching, other animal cruelty species
protection, and control of the invasive alien. The goal is covered in 12 indicators that look at NGRBC principles 2, 6, 7, 8,
and 9.

 Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe - The organisations
should review the exploitation of forest and wildlife caused by their products and its supply chain, including habitat
destruction.
 Principle 6: Businesses should respect and make efforts to protect and restore the environment - Extract the forest
resources in a sustainable manner.
 Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent - Organisation when in an advocacy role, can affect policies that cover the forest and
wildlife conservation.
 Principle 8: Businesses should promote inclusive growth and equitable development - Organisations when designing
their CSR activities, should review the local and regional development priorities to help the forest and tribal groups and
communities.
 Principle 9: Businesses should engage with, and provide value to their consumers in a responsible manner-
Organisations should inform the consumers on safe and responsible ways of usage, reuse, recycling and disposal of
their products, and ways to eliminate over-consumption.

U.N. SUSTAINABLE GOAL 16 - PROMOTE PEACEFUL AND INCLUSIVE SOCIETIES FOR

SUSTAINABLE DEVELOPMENT, PROVIDE ACCESS TO JUSTICE FOR ALL AND BUILD
EFFECTIVE, ACCOUNTABLE AND INCLUSIVE INSTITUTIONS AT ALL LEVELS

The SDG-16 is related to violence, harassment, trafficking, conflicts, crime, mafia and other hindrances to peace and human
rights in general. There are 12 indicators to judge the goal achievement and cover issues like arms trade, illicit finance,
money launderingetc. India also faces its share of violence and lack of peace that needs to be eradicated for economic
prosperity, and general well-being of the population in a sustainable manner. The NGRBC principles related to this goal are
1, 3, 4, 5, and 8.

 Principle 1: Businesses should conduct and govern themselves with integrity, and in a manner that is ethical,
transparent, and accountable - Organisations should have a governance structure that is fair and takes a hard stand
against misuse and violation. The procedures and policies are to be communicated effectively to the employees, having
policies in place for transparent disclosures to the stakeholders.
 Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value
chains - All kinds of violence and harassment has to be addressed at the workplace.
 Principle 4: Businesses should respect the interests of, and be responsive to all its stakeholders - Organisation should
identify their stakeholders, both external and internal, determine the expectations of these interested parties, and
devise their strategies accordingly to address them.
 Principle 5: Businesses should respect and promote human rights - Identification of violence and other human rights
issues, and providing an effective grievance redressal system.
 Principle 8: Businesses should promote inclusive growth and equitable development - Addressing impacts on peace
from businesses that may create illicit financial movement, tax evasion, etc.

U.N. SUSTAINABLE GOAL 17 - STRENGTHEN THE MEANS OF IMPLEMENTATION AND

REVITALIZE THE GLOBAL PARTNERSHIP FOR SUSTAINABLE DEVELOPMENT

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The SDG-17 is related to co-operation between communities and nations, forging partnerships that are mutually beneficial to
the parties involved, and extending help to the communities that are struggling in terms of finance, technology, climate
change, and access to markets. Additional focus of the goal is towards least developed countries, small island states, and
land-locked economies. This goal has 19 indicators that look at the effectiveness of partnerships between nations and
communities. The NGRBC principles that relate to the sustainable goal are principles 1, 7 and 8.

 Principle 1: Businesses should conduct and govern themselves with integrity, and in a manner that is ethical,
transparent, and accountable - Organisations should have a governance structure that is fair, and takes a hard stand
against misuse and violation. The procedures and policies are to be communicated effectively to the employees, have
policies in place for transparent disclosures to the stakeholders.
 Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent - Organisation when in an advocacy role, can affect policies that cover international
cooperation and trade.
 Principle 8: Businesses should promote inclusive growth and equitable development - Organisations when designing
their CSR activities, should review the local and regional development priorities. The organisation should put their
efforts to bringing up creative products, technologies and business concerns that helps the marginalized communities
to have well-being and better quality of life.

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1.7. MCA’S COMMITTEE RECOMMENDATION ON BUSINESS RESPONSIBILITY AND
SUSTAINABILITY REPORTING (BRSR)

1.7.1. CHRONOLOGY

 July 2011- MCA releases National Voluntary Guidelines (NVGs)

 August 2012- SEBI circular for the top 100 listed companies to disclose BRR in line with NVG
 2015- United Nations Sustainable Development Goals 2030 is released
 2015-16- The applicability of BRR extended to the top 500 listed companies
 March 2019- MCA revised the NVGs to National Guidelines on Responsible Business Conduct (NGRBC)
 December 2019- The applicability of BRR extended to the top 1,000 listed companies
 August 2020- MCA report on BRR with the proposed BRSR

1.7.2. BUSINESS RESPONSIBILITY REPORTING (BRR)

After the National Voluntary Guidelines on Social, Environmental and Economic Responsibilities of Business (NVGs)
released by the Ministry of Corporate Affairs (MCA) in 2011, the Securities and Exchange Board of India (SEBI) made it
mandatory for the top listed companies to disclose about non-financial data pertaining to environmental and social
responsibilities through Business Responsibility Report (BRR) that was in line with the principles of the NVGs. The
requirement being applicable for top 100 listed entities based on market capitalisation at BSE and NSE as on March 31,
2012 and this was to be done as part of the Annual Reports that they publish for the stakeholders.

1.7.3. APPLICABILITY OF BRR

This applies irrespective of the organisation’s sector even if they are not in the business of industrial activity, not
manufacturing any physical products or do not cause pollution (E.g.: financial services). It is mandatory for all the top 100
listed companies to have their BRR furnished to their corresponding Stock Exchanges (BSE or NSE) in electronic format,
and published in their company websites. If the organisational structure has a holding company and another subsidiary
company, they are required to prepare separate Business Responsibility Reports if they come under the top 100 on the list.
This applicability was extended to the top 500 listed organisations from financial year 2015-16 and then later to the 1,000
top listed organisations in December 2019.

In the case of multinational companies (MNCs) and international organisations that produce a single report for its operations
across the world, they will have to produce a separate report for the Indian subsidiary that elaborates their responsibility for
the operations in India. If an Indian company furnishes its reporting as per any of the internationally accepted frameworks,
such the Global Reporting Initiative (GRI) framework, the same report can be used along with a mapping of how the 9
principles in BRR are related to in the GRI requirements.

1.7.4. FORMAT FOR BRR

SEBI has prescribed a specific format for this 'Business Responsibility Report' that covers the basic information about the
company, its performance, and processes, as per the principles and core elements of the Business Responsibility
Reporting. The format also provides a set of generic reasons which the company can use for explaining their inability to
adopt the business responsibility policy. Failure to provide BRR will be considered as a violation of the Clause-55 of Equity
Listing Agreement, but there is no particular level of compliance with NVG been mandated. The format is available in the
SEBI website- https://www.sebi.gov.in/legal/circulars/nov-2015/format-for-business-responsibility-report-brr-_30954.html.
The format has five sections named as A, B, C, D, and E as below

 Section A - The general information about the organisation covering the name, address, sector, products and services
offered, the locations of their units and the markets they operated.
 Section B - Financial details of the organisation covering the turnover, capital, profits, taxes paid, and spending on the
CSR activities.

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 Section C - Other details that cover the information related to subsidiaries and supplementary business concerns,
suppliers, distributors. and vendors in the value chain that the organisation shares as BRR related activities.
 Section D - Business Responsibility related questionnaire checklist matrix mapped against each of the nine principles
with 16 questions in total.
 Section E - Principle wise performance for all the nine principles with specific set of questions for each of them.

1. MCA report on BRR and new format BRSR

When the NVGs were revised to NGRBC in 2019 with respect to the UN Sustainable Development Goals, a committee was
formed to have the BRR revised to include the changes. It was also a consideration that BRR be extended to non-listed
organisations as well. The format provided in the NGRBC for reporting the nine principles was used as the starting point and
stakeholder meetings were held 15 times to gather the opinions. The NITI Aayog, that monitors the progress related to the
UNSDG (they have a tracker with indicators) in India was a special invitee for the stakeholder consultations.

The committee came out with a recommended format for the reporting called as ‘Business Responsibility and Sustainability
Report (BRSR)”. Two formats are proposed for the BRSR along with separate guidance note for each of them. The format
with a wider coverage version called BRSR Comprehensive for the listed organisations, and smaller version called BRSR
Lite for the non-listed organisations. The structure of the new format has three sections A, B and C.

 Section A: General Disclosures - The section covers the general information and basic details of the organisation such
as scale, size, sector, products, employee strength, CSR activities etc. It also covers the organisation’s activity near the
environmentally fragile and sensitive areas, protected zones, socially critical areas such as water deficient.
 Section B: Management and Process - This section covers the commitment of the organisation to the business
responsibility by seeking the information related to the governance system, policies, procedures, and processes they
have in place to address their responsibilities in line with the NGRBC principles. This provides an insight into the
managerial infrastructure the organisation has to drive business responsibly.
 Section C: Principle-wise performance - The section requires the organisation to disclose how they perform with
respect to each of the nine Principles and Core Elements of the NGRBCs. The organisation will have to demonstrate
objectively how they will meet the commitment to responsible business conduct. The information required in the section
can be provided as two categories depending on the extent of the organisation’s ambition towards sustainability as
essential and leadership. They can report as either of the two.
o Essential - The bare minimum the organisation has to do in terms of responsible business conduct
o Leadership - The voluntary things taken up by the organisation that are beyond the basic essential things.

2. THE BRR LITE

Since the organisations outside the top listed companies have no experience of non-financial reporting, expecting them to
come out with a report that covers the elements listed in the comprehensive BRSR format will not be pragmatic and hence
the committee has proposed the idea of a second format called the BRSR Lite. This version also has the differential
category of Essential and Leadership; but much fewer in comparison to the comprehensive version, and seeks information
that smaller companies should be able to provide. The Lite version was made with the intention of having the MSME
organisations to also be a part of the BRSR reporting.

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1.8. FIDUCIARY DUTIES OF DIRECTORS TOWARDS COMPANY’S STAKEHOLDERS,
COMMUNITY AND ENVIRONMENTAL PROTECTION - SECTION 166 OF COMPANIES
ACT, 2013

The Companies Act, 2013 is framed with the purpose to protect the interest of various stakeholders in a company such as
top management, employees, customers, creditors, suppliers etc.A director should act in accordance with the provisions of
the Act, 2013, the Articles of Association of the company and in the best interests of the company, disregarding his
personal interest. The previous Act dated 1956 did not have a specific section for the duties of the Director, but listed them
in the Articles of Association (AoA).

Section 166 of the Companies Act, 2013 has seven sub sections, and details the fiduciary duties of the Director of an
organisation along with penalties for violation. The duties from a corporate governance perspective can be summarized as:

 Loyalty- To act in the best interest of the company

 Care- Responsibility and obligation to be careful and pay attention
 Disclosure- Disclosure of all the material information of the company to the stakeholders
 Conflict of Interest- To avoid any activity that has an interest conflicting with that of the company.

From a responsible business viewpoint, the directors are responsible for disclosures to the stakeholders. All interested
parties in a business spanning from customers, employees, regulators, people living in the surrounding areas, the people
who get affected by the actions of the organisation have the right to know the issues that relate to them, especially those
that are considered to be “Material” or significant enough to be disclosed. These duties are in line with the nine principles of
NGRBC.

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1.9. TEST YOUR UNDERSTANDING – MULTIPLE CHOICE QUESTIONS

Q1) What are the five Ps of Sustainability in the UN sustainable Development Goals?

a) People, Planet, Peace, Prosperity, Partnership

b) People, Profit, Planet, Peace, Partnership

c) People, Planet, Politics, Prosperity, Peace

d) People, Profit, Planet, Peace, Prosperity

e) All of the above

Q2) What is the most widely used Framework/Standard for Corporate Reporting?

a) Good Reporting Initiative-GRI

b) Global Reporting Initiative- GRI

c) Corporate Sustainability Reporting- CSR

d) Corporate Social Responsibility- CSR

e) None of the above

Q3) Which of the following scenario is part of a good CSR initiative?

a) A factory paying up for the complete hospital expenses, funeral charges and additional monetary benefits to an
employee’s family who lost his life in an accident happened in the factory.

b) A car manufacturer reducing their production to half resulting in 40% reduction in electricity consumption and fewer cars
on the road.

c) A global soft drink bottler asking all their delivery vehicles to shift to electric or CNG fuel and agreed to pay for the
alterations required. The total delivery transportation amounts to more than 10 million kms per day.

d) A company sourcing material from small factories that could not afford to have minimum wages for its workers; this has
resulted in having the product cheaper to end customers.

e) None of the above

Q4) What type of companies are exempted from mandatory furnishing of the Business responsibility Report (BRR) as per
the SEBI circular?

a) The non-polluting, service organisations like banks and insurance companies

b) The Government controlled public sector companies of strategic importance

c) The international companies that publish their sustainability report as per the GRI framework

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d) The unlisted organisations in India

e) None of the above

Q5) Which of these actions by the organisation contribute to the UN sustainable Goal-13 for Climate Action?

a) Overhauling the coal fired power plant in the factory to use the rice husk as fuel

b) Distributing free portable kerosene lamps to the tribal population; the region is not electrified.

c) Outsourcing many of the manufacturing processes to various small vendors generating 20% additional jobs, and
reduction in diesel and electricity consumption by 35% and 30% respectively in the facility.

d) Mining Company providing alternate housing to the people who lost their homes due to the new mining project

e) None of the above

Q6) How can organisations contribute to having gender equality and women friendly work places?

a) Not assigning women to physically exerting activities while allocating the daily work plans

b) Having unisex toilets in the factory of 2,000 people.

c) Preferential treatment for women during yearly promotions

d) Report the violent sexual harassment allegation made by women in the workplace to Police and related authorities

e) None of the above

Q7) Which of these cases are material enough to be reported by the organisation?

a) A share trading company considered transacting with the shares of an organisation that is accused of illegal mining in an
environmentally fragile zone; but did not.

b) Company’s product pricing with break-up of components transparently for the coming financial year

c) The total diesel and electricity consumption in the year by the largest EPC organisation in India.

d) Since the organisation’s market share has gone up due to better products, jobs were lost in the competitor organisation

e) All of the above

Q8) Which of the following statement is true?

a) It is mandatory for top listed companies to report their performance against 17 UN sustainable goals

b) Multi-national companies have to furnish BRR for their Indian subsidiary if it is in the top listed companies

c) The top listed companies have to pay penalty if they have not met the targets set for their environmental performance

41
d) Every company in India doing environmental damage has to report it using the BRR format

e) All of the above

Q9) The Business responsibility reporting is to be published in which of the following way?

a) electronic copy of the BRR to the Sensex where the organisation is listed and published in the company website

b) electronic copy of the BRR to SEBI and to the Sensex where the organisation is listed

c) Submission to the Ministry of corporate Affairs (MCA) and SEBI in electronic format

d) Publishing in the company website with view or download option for free for the public

e) All of the above

Q10) The Lite version of the proposed BRSR will be applicable for what type of companies?

a) Non-polluting service related organisations such as the banks and insurance companies

b) For the subsidiary companies when the main holding companies has published the report already

c) The organisations that are not listed in the Sensex

d) The organisation that select the “Essential” in the two categories (Essential and Leadership)

e) All of the above

Q11) Which one according to you is a best way of getting stakeholder opinion for a new factory being set up in a remote
forest location that may require resettlement of tribal people?

a) Keeping a suggestion box near the CEO’s office so that people can put comments

b) Looking in the daily newspapers for opinion about the project issues

c) Take a questionnaire survey in major cities covering 100 people each

d) Publish in newspapers (local and national), company website and Facebook page inviting for a public meeting/hearing
near the project site with one-month notice

e) All of the above

Q12) Who among the below is not an interested party for a new Crude Oil refinery?

a) The villagers near to the project site who owns the land for the proposed project.

b) The elected representatives to Legislative Assembly and Lok Sabha from the project area

c) NGO with mission against environmental pollution from factories operating in the project area

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d) Vegetable cooking Oil manufacturers and traders in the state.

e) All of the above

Q13) Which of the sentence about the UN Sustainable Development Goals is true?

a) The UN sustainable goals are not applicable to the least developed countries and small Island nations

b) The goals are made with targets for every country for each of the 17 goals

c) Publishing the BRR for top listed companies mandatorily is India’s target taken from UN sustainable goal

d) The UN sustainability goals are conceptualized with the principle of partnership and cooperation between countries

e) All of the above

Q14) Why did the MCA commit review the BRR and proposed a revised format?

a) The NVGs got revised to NGRBC after the release of UNSDG and other sustainability related mechanisms

b) The report quality in BRR published by many companies was not satisfactory

c) To account for the new GST requirements in the format

d) The survey of top 100 listed organisations reported that the format for BRR was not user friendly

e) All of the above

Q15) How are the nine principles in NGRBC linked to 17 UN Sustainable Development Goals?

a) The nine principles are the UN sustainable Development Goals that are applicable to India

b) The 9 principles are linked to many of the 17 UNSDGs and the mapping between the two are provided in the NGRBC
Annexure-4

c) They are two separate mechanisms and do not have any relation to each other.

d) The nine principles are pre-requisites for 17 UN Sustainable development goals

e) All of the above

Answers: 1. A; 2. B; 3. C; 4. D; 5. A; 6. D; 7. C; 8. B; 9. A; 10. C; 11.d; 12. D; 13. D; 14. A; 15. B.

References

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Carrots and Sticks 2020: Sustainability Reporting Policy: Global trends in disclosure as the ESG agenda goes
mainstream. Available at: https://www.carrotsandsticks.net/media/zirbzabv/carrots-and-sticks-2020-
interactive.pdf

The KPMG survey of Corporate Responsibility Reporting 2017. Available at:

https://assets.kpmg/content/dam/kpmg/xx/pdf/2017/10/kpmg-survey-of-corporate-responsibility-reporting-2017.pdf

National Guidelines on Responsible Business Conduct by Ministry of Corporate Affairs, Government of India. Available at:
https://www.mca.gov.in/Ministry/pdf/NationalGuildeline_15032019.pdf

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MODULE TWO: MCA BRSR DISCLOSURES
2.1 NINE PRINCIPLES OF NGRBC

2.1.1 BACKGROUND OF NGRBC

The Ten Point Charter - The Indian Government in 2007 laid down the economic, environmental and social
responsibilities of the business, and the expected practices of good governance system as a ten-point charter that
covered all elements related to employees, customers, environment, society, equality, corruption, skill development,
and innovation. The below mentioned ten points were the foundation on which the policy development in the country
was spearheaded resulting in the National Voluntary Guidelines (NVG) in 2011 :

1. Responsibly toward employees - Have a healthy respect for your workers and invest in their welfare
2. Responsibility toward businesses - Corporate social responsibility must not be defined by tax planning strategies
alone; it has to extend towards fulfilling their obligations to environment
3. Responsibility as an equal opportunity employer - Industry must be pro-active in offering employment to the less
privileged, at all levels of the job ladder
4. Responsibility as an economic equalizer - Resist excessive remuneration to promoters and senior executives,
and discourage conspicuous consumption
5. Responsibility toward skill development - Invest in people and in their skills
6. Responsibility as a ‘fair-competition’ player - Desist from non-competitive behavior
7. Responsibility toward the environment - Invest in environment-friendly technologies
8. Responsibility toward social and market innovation - Promote enterprise and innovation, within your firms and
outside
9. Responsibility toward anti-corruption agenda - Fight corruption at all levels
10. Responsibility toward consumers- Promote socially responsible media and finance socially responsible
advertising.

2.1.2 NVGS AND BRR

The Ministry of Corporate Affairs (MCA) released the National Voluntary Guidelines on Social, Environmental, and
Economic Responsibilities of Business (NVGs), a set of guidelines for the organisations in India, on how to
demonstrate their responsibilities related to economy, environment and society. The document is available for
download at https://www.mca.gov.in/Ministry/latestnews/National_Voluntary_Guidelines_2011_12jul2011.pdf. This
was made to suit all kinds of companies in India of varying sizes, sectors, scales and type of products and services.

The nine core elements of NVGs covered the elements of Ethics, Transparency, and accountability, Product life-cycle
sustainability, Employee well-being, Stakeholder engagement, Human rights, Environment, Policy advocacy, d
Inclusive growth and equitable development, and Value to customers and consumers. The NVGs were based on the
triple bottom line concept of sustainability.

45
The Guidelines were a refinement over the Corporate Social Responsibility Voluntary Guidelines 2009, released by
the Ministry of Corporate Affairs in December 2009. NVG used the terms 'Responsible Business' instead of
Corporate Social Responsibility (CSR) as the term 'Responsible Business' encompasses the limited scope and
understanding of the term CSR.

The NVGs, describes the solution to the following four questions:

1. What principles define a “Responsible Business”?

2. How to adopt the principles and make a strategy for business responsibility?
3. How to adopt each principle that justifies the business case?
4. What indicators are to be used to measure the performance in Responsibility to business?

Subsequent to the NVGs, the Securities and Exchange Board of India (SEBI), in August 2012 released a circular
(https://www.sebi.gov.in/sebi_data/attachdocs/1344915990072.pdf) mandating the disclosure of the non-financial
performance for the top 100 listed companies on BSE and NSE as on the end of the financial year 2011-12 in India in
a particular format named Business Responsibility Report (BRR). The new format has five sections A, B, C, D and F
of which the section D and F particularly relates to the non-financial responsibilities. . In December 2015, this
applicability was extended to the 500 top listed Indian companies. The applicability is irrespective of the sector in
which the organisation is into; the non-polluting, non-industrial sectors such as the financial institutions are also
covered.

The NVGs were revised to National Guidelines on Responsible Business Conduct (NGRBC) in 2019. This change
was due to the pressure from various international mechanisms and guidelines that were released later as below:

 The UN Sustainable Development Goals (UNSDGs)- 2015

 Paris Agreement on Climate Change (2015)
 Core Conventions 138 and 182 on Child Labour by the International Labour Organization (ILO)

This revision of the NVGs started off after the UNSDGs were released in 2015 and finally resulted in the National
Guidelines on Responsible Business Conduct (NGRBC). This new mechanism was to be used by all kinds of
organisations operating in India, irrespective of their size and scale of operation, sector of engagement, structure, or
location. This is also applicable to the foreign multinational companies that operate in India. In addition to following
these guidelines, the organisations are also expected to encourage and support their suppliers, vendors, distributors,
partners, and other collaborators to follow them.

2.1.3 THE NINE PRINCIPLES OF NGRBC

The nine principles in NGRBC are categorized into the ESG components of Environment, Society and Governance
with four of the nine in Governance, two in Environment and three in society. Even though they are separate, they
are interlinked to each other in some way. For example, the environmental protection is closely linked to the
stakeholder engagement and inclusive growth.

Governance
Environment Society
1. Ethics, Transparency &
8. Products Life Cycle 5. Employees' well-being Accountability
Sustainability 6. Human Rights 2. Stakeholder Engagement
9. Environment 7. Inclusive46
Growth 3. Policy Advocacy
4. Customer Value
PRINCIPLE 1- ETHICS, TRANSPARENCY AND ACCOUNTABILITY

Policies, Procedures Fight Corruption, anti-

Ethics, competition
Transparency
and
Disclosure of Risks to Accountability Non-cooperation with
stakeholders violating entities

Legal Compliance

The first principle of NGRBC revolves around the concept that any business enterprise that aims to demonstrate
responsible business, needs to have ethical conduct in all its actions and policies. The concept of trust for any
enterprise comes from the general perception and understanding that it performs its day-to-day business activities
with utmost integrity and trustworthiness. Such reputation and goodwill is built through years of ethically accepted
behaviour amongst the consumers, suppliers and general public.

The first principle stresses on the need to communicate risks related to the business concern, along with the actions
taken to address them, to the relevant stakeholders. The first principle also emphasizes that the business decisions
in an organisation should be open to disclosure and accessible to the relevant interested parties. This applies to the
actions related to all the nine principles of NGRBCs as well.

The overall behaviour and decision-making nature of the top management is also stressed in the principle as it leads
to establishing the foundation for the organisation’s integrity and a culture of ethics at all levels of the organisation.
The downstream managers and supervisors are also influenced by the nature by which the top management
conducts itself when dealing with critical situations and scenarios relating to governance, environment or society.

The essence of the six core elements associated with the first principle are:
1. The organisations’ governing structure should develop strategies, policies, procedures, and practices for their
offices, factories, and work areas, ensuring that ethics is not compromised by the employees.
2. The governance structure should make sure that these nine principles are understood by the employees and
implemented.
3. The entities in the value chain should be encouraged to adopt these principles by the governance structure.
4. The information relating to the policies, procedures and practices along with the performance should be made
available to the stakeholders. For matters and decisions that have an effect on any of the interested parties, the
organisation should make sure that the information is made available to the concerned stakeholders. In case of
adverse effects, more care has to be taken for transparent disclosures.
5. All kinds of regulatory and statutory requirements to be met by the organization, give way for fair competition,
and treat all stakeholders with equity.

47
6. The organisations should proactively respond to the outside entities that violate the nine principles of the
NGRBCs by taking punitive actions if needed or encourage them to comply with incentives. This includes their
suppliers, distributors, sub-contractors or regulatory officers that may engage with the business concern.
7. The organisations should take care of all kinds of conflicts of interests and ensure that these are addressed
through structures, policies and procedures of the organisation.
8. The governing structure in organisations should ensure that the business does not get into activities that aid
corruption, are illegal, or result in abusive outcomes. This also includes inaction or friendly treatment of
wrongdoers.
9. The organisations have to ensure that the taxes, duties and other payables from them are met in time in full in
the essence of the legal requirement.

PRINCIPLE 2 - SAFE AND SUSTAINABLE GOODS AND SERVICES

Quality of Products Pollution from operation

Safe and
Sustainable
Goods and
Use of Raw materials Services Non-biodegradable waste
and Resources

The second principle looks at the need of the people to have good quality of life from the products available from the
market. The organisations should make sure that their goods, services and the operations result in better life for the
consumers and end-users. It is the responsibility of the organisation to ensure the safety and fitness for the intended
use. This covers the expected physical properties, the performance, aesthetics, and revolves around the concept of
customer focus. This concept is a traditional requirement by which most management systems are designed. For
example, ISO 9001 for the Quality Management Systems is widely used by organisations to demonstrate their
commitment to customer focus and quality of their products and services.

This principle also aligns with the UN Sustainable Goal 12 - Responsible Production and Consumption. Traditionally,
the concept covers efficiency from an economic perspective as it is the main driving force or purpose of any business
to exist. This resulted in efficient usage of anything that directly relates to monetary gains, such as efficient use of
electricity, raw material, fuel, consumables, water (if it affects the cost), man hours etc. The matters that were
regulated by the authorities with a punitive action were also taken up by the companies. For example, the quality of
effluent let off by the factories. The companies ignored the items that did not have any returns and/or not regulated
by the authorities, such as controlling the packaging waste created when the products get distributed.

Any product or service goes through many transformations at various stages of conceptualization, design,
manufacturing, packaging, distribution, usage and disposal known as the product life cycle. The organisation should
be responsible for the environmental issues that arise in any of these stages due to wastage of material, depletion of
resources such as fossil fuels, water, and electricity, unfavorable emission to air, water or soil resulting in
contamination or non-biodegradable materials such as plastics and polymers. The organisations should design and
engineer their operations considering these issues that arise in the whole lifecycle of the product. For example: the

48
soft drink manufacturers are now becoming responsible to reduce or collect back the wastage from the PET bottles
they use to pack their product.

The principle urges the organisations to consider the issues that are to be looked after by the distributors, suppliers
or contractors as well (additional to the ones that are directly created by the organisation themselves). For example,
fuel emissions in the trucks used by the contractor for distribution, efficient use of raw material by the supplier at their
factory. Here, the impacts of a product are seen comprehensively from design to disposal.

The essence of the core elements associated with the second principle is:

1. When a product is designed by the organisation, the production methods and technologies have to be devised in
such a way so as to minimize the resource usage to make it sustainable. There can be savings in fuels, energy,
man hours, consumables and pollution from the process.
2. The organisations are also responsible to educate and make aware their consumers and clients about their
rights through methods such as environmental and social issues, accurate and transparent product labeling,
complete details of the composition and content, honest and non-misleading marketing communication, full
details of contents and composition, appropriate usage instruction for safety and required disposal methods.
3. The organisations should take measures that reduce the over exploitation of the nature’s resources by
consuming sustainably and encourage methods for reduce, reuse and recycling of the resources.

PRINCIPLE 3- PROMOTE WELL-BEING OF ALL EMPLOYEES INCLUDING THOSE IN THE VALUE

CHAINS

Unions and Collective

Skill Development
Bargaining
Well-Being
Equality of all Occupational Health
employees

Work-Life Balance Harassment/Violence

The third principle relates to all the initiatives an organisation has to take for the benefit of its employees from the
point of view of their dignity, health, well-being. There have been many regulatory frameworks developed as part of
the labour and occupational laws in the country for having a better workplace for the employees in terms of
occupational health and safety, equality, remunerations, collective bargaining etc. However, large sections of the
workforce in India still face challenges at their workplaces. The situation is worse for the people employed in
unorganized sectors or are working as contract labour.

The employees in the Indian context face higher levels of exploitation, harassment, and poor treatment from their
employers as compared to those in the developed world, mainly due to their unequal bargaining power, and poor
enforcement of labour and Occupational health and safety (OHS) laws in the country. Dignity and safety at the
workplace is a domain that has lot of catching up to do for the Indian corporates. The principle from NGRBC aims at

49
obligations from the Indian corporates to play their part in eradication and reduction of issues that workforce faces in
general.

The essence of the core elements associated with the principle is:

1. The organisations should ensure compliance with all regulatory requirements as far as employees are
concerned.This should also extend to the employees in the value chain.
2. The equity and equal opportunity should be the organisations’ way of functioning all the way from recruitment,
promotions, employment and exit of the employees.
3. The organisations are to respect the dignity of employee as a human being and should not restrict their freedom
of associations, unions and other participatory mechanism for collective bargaining of their rights and redressal
of issues they face at the workplace. The act of bargaining and negotiations are to happen between entities that
have equal power and hence, the employees are to have the power of bargaining with the big business
enterprise by doing it collectively as a group.
4. The organisations should prevent all kinds of child labour, bonded labour and any other forms of involuntary
labour, irrespective of whether payments are made to the employee in return or not.
5. The organisations should have a system in which the work-life balance of the employees is not compromised.
The issue is of greater gravity in case of women workforce as they face extra load in a patriarchal society. This
could be about providing adequate paid leaves, or appropriate work duration per day.
6. The businesses have to ensure timely payment of the worker’s wages and compensation. The wages should be
enough to meet their basic needs and economic security. Extra care should be taken for the employees with
special needs.
7. The payment of the wages has to be as per the living wages, that can take care of the basic needs and provide
economic security to the employees.
8. The organisations are responsible to create a workplace and work environment that is safe, hygienic and
comfortable for people to work for long durations. This should include the provisions for the disabled persons as
well. The required protective gear for safe working should be provided to the employees as appropriate. The
organisation should conduct awareness and training sessions on the safety of workplace to the employees
regularly.
9. The skill development, career development and training of the workforce is another responsibility of the
organisations employing them. This should cover all kinds of competence upgradation and learning opportunities
for the employees and it should be provided on an equal and non-discriminatory basis. The purpose is to have
higher levels of employee morale.
10. The creation of a workplace which is free of harassment and violence is also a responsibility of the organisation
where employees feel safe and secure in discharging their responsibilities. There should be sufficient modes of
grievance redressal when the employees feel they face some form of harassment.

PRINCIPLE 4- RESPECT FOR STAKEHOLDERS INTERESTS AND RESPONSIVENESS

Interested party or stakeholders - The concept of interested party or stakeholders to a business has been a point of
discussion in all the regulatory and voluntary systems that relate to the management system of any organisation, be it
related to the quality, environment or the occupational health and safety of the workers. Interested party means any
entity that has an interest in the business of the organisation. This creates some expectation from the entity towards
the organisation. For example, the customer expects the organisation to provide safe, high quality goods in time with
the lowest possible price. But a nearby villager expects the organisation to operate without polluting their farms,
water bodies, air quality and to provide employment opportunities (direct or indirect) to the local people.

50
The conventional business enterprises operate with their prime responsibilities aligned to the investors or the
shareholders and their activities majorly related to the economic progress and profits. The fourth principle urges the
organisations to think beyond and include all the other interested parties to their business such as employees,
suppliers, distributors, sub-contractors, and nearby communities that get affected by the operations of the
organisation. The stakeholders to a particular business have different levels of bargaining power and influence upon
the organization, and hence care should be taken to consider everyone’s concerns.

Customer Authorities

Investor Public
Business
Suppliers Competitors

Employees Natural environment

The essence of the core elements associated with the principle is:
1. The organisations have to be transparent and communicate with the stakeholders about the impacts of their
operations and business decisions on the people and the nature. The policies, decisions, and the impact of the
operations of the organisation to the stakeholders have to be disclosed transparently with no ambiguity on the
extent of the issues.
2. The organisations have to systematically determine the context of their operation and identify their interested
parties. Then the business has to review the expectations of these stakeholders from the business, and plan
their strategies to address these needs, if required, to the level they wish to.
3. The organisation should fairly share the benefits to the stakeholders or give an opportunity to them to benefit
from the operations in an equitable manner. Further, any disputes arising out of the impacts should be fairly
resolved.

PRINCIPLE 5- RESPECT AND PROMOTE HUMAN RIGHTS

Policy and Constitution of

Procedures India
Human
Rights
Awareness and International Bill of
Training Rights
51
The concept of human rights is a vast topic that covers a wide variety of violence and belligerent abusive issues
faced by people. Here, it refers to the human rights in the backdrop of the operation of the organisation. It refers to
the human rights issues that happen directly or indirectly due to the operation of the business. This often happens in
the case of projects in the remote areas that requires the resettlement and rehabilitation of people due to the impacts
from the operation. The most common example is the mining projects or hydropower projects in the forest areas that
displaces the indigenous people and tribal folk.

The project induced migration is more often than not nonvoluntary and results in widespread human rights abuses
on the local population. The contractors driven by the profits from the organisation (directly or indirectly) use their
influence and undue force to push out the people who have no voice and bargaining power. The local population, in
most cases, not having enough information about their rights and other legalities in the process, falls into unfavorable
agreements and contracts and eventually is at the receiving end of the human rights abuses. In many cases, it has
even resulted in the local population taking up unlawful methods of retaliation through violence and armed conflicts.
Presence of such ethnic armed minorities have created absence of peace in many of the mineral rich states in India.

The fifth principle about human rights requires the organisation to prevent issues of human rights violations that arise
out of their operations by treating people with dignity and respect. The organisations are expected to follow a
pragmatic approach while planning to make use of the opportunities that have a risk of human rights violation. It is
based on the principles in the Constitution of India that ensure fundamental rights and achievement of human rights
to every citizen of India. It also aligns with the Universal Declaration of Human Rights, in the formation of which, India
played an active role. The principle takes into account the “Corporate Responsibility to Respect Human Rights”, as
referred to in the United Nations “Protect, Respect, Remedy” Framework.

The essence of the core elements associated with the principle are:

1. The organisations should have a clear understanding of the human rights and various ways by which human
rights can be violated from the perspective of the Constitution of India, national laws and policies and the content
of International Bill of Human Rights. The human right is a non-negotiable element that cannot be violated from
the perspective of morality as well as legality. This applies to every community, population and demographic
groups in India.
2. The organisations when developing their management systems, should integrate the human rights element into
their policies, procedures and practices. This would ensure it to the population affected by the organisation and
its operations.
3. Businesses should recognize and respect the human rights of all relevant stakeholders and groups within and
beyond the workplace, including that of communities, consumers and vulnerable and marginalized groups.
4. The organisation should channel their efforts to spread awareness and realization of human right issues and
violations all through the supply chain from suppliers to end user.
5. The organisation should have an effective system of redressing the grievances relating to human rights. When
the organisations come across human rights violations from outside entities such as regulatory officers,
suppliers, customers etc., they should not shy away from being strict to the violators. This can include non-co-
operation to the entities that do not value human rights.

52
PRINCIPLE 6- PROTECTION AND RESTORATION OF ENVIRONMENT

Prevent Pollution Disclosure of

Environmental performance

Environment
Conserve Efficient
Biodiversity
Resource Use

The sixth principle looks at the environmental responsibility as a basic requirement for the economic prosperity and
sustainability. The issues that relate to the environment or biodiversity eventually affect the local population and then
later to the regional levels, if not contained. Hence, these issues have far reaching consequences and repercussions.
Global issues such as climate change, global warming and conservation of endangered species are common for
everyone and the organisations cannot avoid their responsibility towards these issues. The operations of the
organisations affect the environment directly and indirectly and these vary with respect to the products and services
they offer.

The organisation needs to look into how the wastewater, greenhouse gas emissions from fuel use and other
hazardous waste is interacting with the surrounding environment. They should control the quantity, and quality of
these emissions and wastes to reduce the pollution. They should also reduce the quantity of natural and national
resources such as the fossil fuels, electricity and water to an optimum usage.

The core elements associated with the principle are:

53
1. The organisations should have policies, procedures and practices in place to assess and rectify impacts to the
environment. This should cover the whole life cycle of the product.
2. The organisations have to make use of natural and manmade resources in an optimum manner to ensure their
sustainability by taking feedback from the stakeholders. This will eventually reduce the quantities of waste as
well.
3. The organisations have to measure their performance relating to the prevention of pollution, destruction of
forests, waste generation, energy use, land use etc.
4. The companies have to contribute towards climate change resilience in line with India’s commitment to various
international mechanisms such as Paris Agreement and National Action Plans for Climate Change.
5. The organisation should explore the comparison of its activities with industry best practices to reduce, reuse and
recycle/recover materials, resources. It should also encourage suppliers and customers to do so.
6. The companies have to look out for avenues by which they can improve their performance towards various
environmental responsibilities. The methods could be innovative production methods, renewable power based,
cleaner technologies, efficient and natural/eco-friendly techniques and retrofits.

PRINCIPLE 7- INFLUENCE ON PUBLIC AND REGULATORY POLICY

Public Good

Regulatory As collective
Grievance Policy groups
Redressal

The seventh principle of influencing the policy formulation positively recognizes that the businesses operate within
the framework of statutory and legislative policies of the governing authority. These frameworks both guide as well as
restrict the enterprises to move forward. India being a democratic federal system of governance, such frameworks
are formulated in participation with and collaboration between each of the stakeholders of which the corporate
segment is a major one. For example, the NVGs, BRR and the NGRBC were made after several rounds of
stakeholder consultations and public hearings that included the opinions of the industry representatives.

Corporates in any country are the backbone of their economy and they are one of the most important stakeholders to
policy formulations along with the general public. The seventh principle talks about the right of organisations to have
influence on and actively participate to make and review policies in the context of grievance redressal, or as part of
public opinion. The purpose of their role in public advocacy is to move towards public good. The Principle further
highlights that -

1. The core elements of the NGRBC have to be met holistically when the organisation go ahead with their
contributions to policy formulation and policy advocacy.
2. The collective associations such as the trade groups and industry chambers have to be utilized when moving
ahead with the policy advocacy and formulation.
3. The role in policy advocacy by the organisation should be in such a way that it encourages fair competition and
prevents human rights abuses.

PRINCIPLE 8- PROMOTE INCLUSIVE GROWTH AND EQUITABLE DEVELOPMENT

54
 Equity Not charity

Inclusive
Innovative growth
products Sensitive to local
communities

India being a developing nation faces several challenges in the context of social and economic progress and
prosperity as compared to the developed world of European countries, North East Asian countries, North America
and Australia. Even among the developing countries, India has considerable population of the world’s poor and is
backward in most of the human development indices used to measure growth and development. The corporates
have a responsibility in this country to spearhead a growth that takes care of everyone and every kind of community
without disregarding the issues faced by some of them.

The term equitable development refers to fair and impartial ways of development. This approach aims to meet the
needs of underprivileged and non-represented communities that are marginalized through an institutional framework
of policies and programs that compensate for the disparities they face. This preferential treatment is the positive
discrimination to have a level playing field and equal opportunities for all the communities. The reservations in India
and affirmative action in the USA are all examples of such policy driven frameworks. To consider a daily life example,
seats reserved for ladies or disabled in a bus ensures that they also have a chance to get a seat to sit on.

Organisations in the country are encouraged to contribute towards the development of the downtrodden and the
marginalized through innovative schemes and programs that do justice to the value of the efforts the companies put
in a very competitive business environment. This need is expected to be met by business actions and not charity to
the poor or the marginalized. Likewise, Kochi Metro rail employed the transgender community in the stations and
ticket counters to serve the customers to provide them with a decent living.

This can work only with close participation and collaboration amongst the organisations, authorities, the civil
associations contributing to one another for a better livelihood, and assistance to the marginalized communities. The
people in the society and the organisations which have products and services to offer are interdependent and hence
it is also in the business interest of the organisations. Needless to say, people without living wages cannot support
the market by purchasing the goods manufactured.

The core elements of the eighth principle are:

1. The organisation should have systems in place to identify and address impacts of their activities on the social,
cultural, and economic aspects of the people. This includes business created issues like land acquisition and
use and construction activities for new facilities.
2. The organisations should review, measure and track the adverse impacts of their activities on the society and
environment and make action plans to mitigate them adequately.

55
3. The organisation should make efforts to bring up creative products, technologies, and business concerns that
help the marginalized communities to have well-being and a better quality of life.
4. Organisations when designing their CSR activities should review the local and regional development priorities to
help the marginalized groups and communities,
5. The organisation should take care to ensure that business induced displacement or relocation of communities
does not happen, and in unavoidable cases, should make sure to have mutually agreed, participative, and
informed negotiations to provide fair compensation to the affected people.
6. All forms of intellectual property and traditional knowledge should get the deserved respect from the
organisation, and efforts should be made to ensure that benefits derived from their knowledge are shared
equitably.

PRINCIPLE 9- PROVIDE VALUE TO THE CONSUMERS IN A RESPONSIBLE MANNER

Quality Easy to Use

Competitive Price Value to

customer
Easy to dispose
Safe Product

The conventional system of any business includes mutually beneficial transactions between sellers and buyers
satisfying both for long term continuation. The primary purpose of any business is to create or provide useful
products and services to the customer in exchange of reasonable profits. So, organisations that aims to operate for a
long time building up their business empire needs to consider the value that they create for one of their key
stakeholder that is, the customer.
As the famous phrase about business goes “Customer is the King” or the Gandhiji’s talisman of Customer being the
most important entity for any business concern, the organisation has to behave in a responsible manner to their
customers.

In today’s world of globalization and capitalistic markets, the choices available for the customer are vast with wider
varieties than ever before. The organisations have to make sure that they are able to make quality products available
at reasonable prices, that are easy to use, and easily disposable after the usage is complete. If any of these is
compromised, the customer will try to find other organisations that provide what they want. For example, the whole
market of disposable products (mostly plastics) came up in the last few 30-40 years and threatened many traditional
products with exponentially cheaper prices and ease of use and throw. However, when the disposal of the plastic
items became a problem, customers moved away from the disposable products.

The organisations also have to address the issues that arise out of the long-term usage of certain products, mostly
related to the health of the consumer. These are most commonly seen in food products, drugs and cosmetics. The
long-term usage causes the deterioration of health and well-being of the user such as obesity, diabetes, and cancer.
For example, sugar in soft drinks and bakery foods, nicotine in cigarettes, particles in asbestos. The organisations

56
are expected to undertake awareness programs and make accurate and complete labeling so as not to misguide the
user on the potential impacts from long term use of their products.

The core elements associated with the principle are:

1. Organisations should put in their efforts to reduce the negative impacts of their products and services on
consumers, natural environment and society at large.
2. When conceptualizing, designing, and marketing their products, the organisation should not in any manner
prevent the freedom of choice and fair competition.
3. The organisation should transparently and accurately disclose all kinds of adverse impacts to the user, planet,
society, on the biodiversity from their products. This may be done by labeling, marketing, or by providing
information on their social media platforms.
4. When handling customer data, the right to privacy of the customer needs to be maintained.
5. Organisations should inform the customers on the safe and responsible ways of usage, reuse, recycling, and
disposal of their products, and ways to eliminate over-consumption.
6. When advertising about their products, the organisations should ensure that misleading and confusing
information is not exposed to the customers about their products or its usage.
7. Business enterprises should make available transparent and accessible grievance redressal and feedback
management system for their customers to raise their voices or to seek clarifications.
8. Organisations, when in the business of providing essential goods and services (e.g. Utilities), should enable
universal access, including to those whose services have been discontinued for any reason, in a non-
discriminatory and responsible manner.

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2.2 REPORT OF THE COMMITTEE ON BUSINESS RESPONSIBILITY REPORTING

Introduction

The Committee in its report refers to the words of economist Milton Friedman ““the social responsibility of
business is to increase its profits”, shareholder primacy has been the cornerstone of business operations. The
Committee stated in its report that the increasing global challenges on climate change, environmental risks, growing
inequality etc. has compelled the business leaders to rethink the role of businesses in the society and not view them
merely as economic units for generating wealth.
In the verge of facing global challenges, the Business Round Table (BRT - an influential association of
CEOs of the United States of America’s biggest companies) along with 181 signatories in 2019 has reaffirmed the
commitment of their businesses to all stakeholders. BRT is supported by the “Davos Manifesto: The Universal
Purpose of a Company in the Fourth Industrial Revolution” released in 2020by The World Economic Forum. The
Committee stated that the reaffirmed statement by big forums has asserted a move towards stakeholder capitalism
and emphasized that the performance of a company must be measured not only on the return to shareholders, but
also on how it achieves its environmental, social, and good governance objectives.
Business Responsibility and Sustainability Reporting Format
Introduction
The Business Responsibility & Sustainability Reporting (BRSR) format is enclosed as Annexure - 2A in the Report of
the Committee on Business Responsibility Reporting. The BRSR format consists of three sections “Section – A”,
“Section – B”, & “Section – C”.
Section A provides the subtitles for explaining the General Disclosures of the business such as Company Details,
Products & Services, List of Operations, Details about employees, Holding, Subsidiary and Associate Companies,
Corporate Social Responsibility (CSR) and Transparency & Disclosure Compliances.
Section B provides a table full of questions on Management and Process disclosures related to the businesses aimed
at demonstrating the structures, policies and processes put in place towards adopting the Principles and Core
Elements. The questions are framed in a fashion to help the businesses to explain their Policy and Management
processes, Governance, Leadership & Oversight and Stakeholder Engagement.
Section C provides the disclosure of principle wise performance of the businesses across the nine principles of
NGRBC. These principles set the basis for the businesses to substantiate their contribution for sustainable
development. The desired information is categorized as “Essential” and “Leadership”. While the essential level is
expected from every business that has adopted NGRBC, the leadership level is expected of businesses which
aspire to progress to a higher level in their quest to be socially, environmentally and ethically responsible.

Section A: General Disclosures

This section includes seven parts -
Part-I: Company details
The information requested in this Part-I is more or less related to the legal status of the company. Based on
the information provided in the section, the reader will come to know about the registered name of the company, year

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of incorporation, address of the company (both registered & corporate), contact details of the company (both online
/offline) and financial status of the company. Explanations for the requested information are as follows:
1. Corporate Identity Number (CIN): The number issued by the Registrar of Companies at the time of
Registration under Companies Act, every company shall have a unique number.
2. Name of the Company: The name by which the company has got the Certificate of Incorporation from the
Registrar of Companies.
3. Year of Incorporation: The year in which the company was incorporated and received the Certificate of
Incorporation from the Registrar of Companies.
4. Registered office address: The address refers to both registered and corporate, Registered address
means the address at which the company shall be able to receive all legal documents and lawsuit.
5. Corporate address: Corporate address means the place at which the company shall have its operation.
Corporate address shall be used for business purpose.
6. Email: Official online Email-id used for only official communication.
7. Telephone: Telephone number either landline or Mobile used for official communication.
8. Website: An online web link that can provide the key information and online communication details of the
company.
9. Financial year for which reporting is being done: (Drop-Down List): The Company has to clearly
indicate the financial year for which the report is prepared. For example, If the report is prepared for the
period between 1 April 2019 and 31 March 2020 then the report must indicate the financial year as 2019-20.
10. Whether shares listed on recognized Stock Exchange(s): Yes/No.
11. Authorised Capital: The information related to the company’s issuance of number of shares with reference
to their statement mentioned in the Memorandum of Association and Articles of Association.
12. Paid-up Capital: The information related to the money received by the company from shareholders in
exchange for shares.

Part-II: Products/Services
The information requested in Part-II tells about the sector (Public/Private) of the company, the business
activities of the company as a whole and their division. The section requires a description of each business activity
and its percentage of turnover of the company. Further, it requests the company to mention about Top 3 products
/services sold in terms of turnover (both manufactured/traded). Based on the information provided in the section, the
reader shall be able to understand the brand value of the company in terms of production and turnover. Explanations
for the requested information are as follows:
13. Sector (s) in which the company is engaged/Number of business activities: The sector refers to the
work engagement of the company either in manufacturing or service. For example, if the company is
manufacturing or servicing automobile parts then it comes under automobile sector. Number of business
activities refers to functioning of the organization as a single business unit or multiple business units. If the
company is having multiple units then it has to describe the main activity & the activities of its allied group by
means of their internal group coding system. The company has to mention the percentage of turnover of
each business activity.

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 14. Top 3 Products/Services sold by the company by Turnover (including both manufactured & traded):
The Company might be manufacturing different types of products/services, but they have to define the top
three products/services along with the National Industrial Classification Code (NIC Code) and percentage
turnover contribution of each such product. If the company is involved in branding their products/services
then they have to define the each individual brand and the contribution by each branded product/service in
terms of percentage of the total turnover.

15. What is the contribution of exports to total turnover of the Company in percentage? : Out of the total
turnover, the company has to declare their contribution in terms of percentage achieved by means of
international trade. The contribution of any company towards export shows its competitive advantage and
that means the companies that are doing export are better than other non-exporting companies.

Part-III: Operations
16. Number of locations where plants (in case of manufacturing businesses) and/or operations/offices
(in case of non-manufacturing) of the Company are situated: The information of all the national and
international locations in which the company manages different kinds of operations. The company has to
provide details about both manufacturing and non-manufacturing businesses, if the business is related to
manufacturing then they have to mention about the number of plants in operation and if the business is
related to non-manufacturing then they have to mention about the number of offices in operation.

17. Location of top 3 plants (in case of manufacturing businesses) or operations/offices (in case of non-
manufacturing) in India by contribution to turnover:
(a) National: If the company is having different operating units in different states within the country then
they have to list the top 3 manufacturing & non-manufacturing operating units that are contributing to their
turnover.

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For example: Out of the top 3 operating units,
- If any one of the operating units is located in or within 50 km of the protected areas, then it comes
under Category A. Some of the protected areas are listed and explained below:
i. National Parks: The areas in which the animals and plants are kept in the natural state for
protection of the functioning ecosystems. Normally, the Government controls the national
parks and the public is allowed for visit.
ii. Wild life Sanctuaries: The area that provides protection for the wildlife in their natural habitat.
No human intervention is allowed in the wildlife sanctuary without escort.
iii. Biosphere Reserves: The protected areas that include terrestrial, marine and coastal
ecosystems and these reserves are used for the conservation of plants and animals. There
are 18 Biosphere Reserves in India established by the Government that protect large areas of
natural habitats.
iv. Wetlands: Some parts of the landscape area that are covered by water in a seasonal manner
or permanent manner.
- If any one of the operating unit is located in or within 50 km of Biodiversity Hotspots then it comes
under Category B. The explanation for biodiversity hotspots is as follows:
i. Biodiversity hotspots: The biogeographic region that was under threat due to human
habitation. The entire biogeographic regions that are identified as biodiversity hotspot have
lost at least 70% of their original habitat.
- If any one of the operating unit is located in high water-stressed zones defined as “Over-exploited”
or “critical” by the Central Groundwater Board then it comes under Category C. The explanation
for high water stressed zone is as follows:
i. High water stressed zones: The high water stressed zones are the regions in which the
demand for ground water exceeds the availability of ground water. The Central Groundwater
Board has identified water stressed zones situated in Tamil Nadu (541), followed by
Rajasthan (218), Uttar Pradesh (139) and Telangana (137), and few other states revolving
under water drought.

- If any one of the operating units is located within Coastal Regulation Zones then it comes under
Category D. The explanation for coastal regulation zone is as follows:
-

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 i. Coastal Regulation Zone: According to the Environmental Protection Act, 1986 of India, the
Coastal Regulation Zone includes the following - land up to 500m from the High Tide Line
(HTL), the banks of streams, ponds, inlets of backwater and rivers subject to the fluctuations
in tide.
(b) International: If the company is having different operating units in different foreign countries, then
they have to list the top 3 manufacturing & non-manufacturing operations in each country, which are
contributing to their turnover.

18. Markets Served by the Company:

a. Locations of the market (National & International): The locations refer to the number of location of
the market within the country & foreign countries for which the company provides its service. If the
market is within the country then the company shall mention the number of states and if it is foreign
country(s) then the company shall mention the number of countries.
b. Location of top 3 markets by contribution to Turnover:
I. National: In case, if the company is serving the top 3 markets within the country then the
company has to mention the name of each market with reference to each state. Also, the
company has to mention percentage turnover contribution of that market to the total turnover.
II. International: In case, if the company is serving the top 3 markets in a foreign country(s) then
the company has to mention the name of each market with reference to each country. Also, the
company has to mention percentage turnover contribution of each market to the total turnover.

Part-IV: Employees
19. Details as at the end of Financial Year: In order to give an accurate count of the employees, the company
has to take the details of the employees at the end of the financial year.
a. Employees (Including differently abled): It includes the permanent employees coming under pay
role with benefits like Insurance & PF and employees other than permanent coming under contract
without any benefits. All Male, Female and other genders to be mentioned in numbers and also in terms
of percentage to total number of employees.
b. Differently abled Employees: It includes the differently abled employees coming under pay role with
benefits like Insurance & PF and differently abled employees other than permanent coming under
contract without any benefits. All Male, Female and other genders to be mentioned in numbers and also
in terms of percentage to total number of differently abled employees.
c. Workmen (including differently abled): It includes the unskilled, semi-skilled, skilled & highly skilled
workmen (including differently abled) who are permanent that is, coming under pay role with benefits
like Insurance & PF and other than permanent coming under contract without any benefits. All Male,
Female and other genders to be mentioned in numbers and also in terms of percentage to total number
of employees.
d. Differently abled Workmen: It includes the unskilled, semi-skilled, skilled & highly skilled differently
abled workmen coming under pay role with benefits like Insurance & PF and differently abled workmen

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 other than permanent coming under contract without any benefits. All Male, Female and other genders
to be mentioned in numbers and also in terms of percentage to total number of employees.

20. Participation/Inclusion/Representation of women (including differently abled): It includes the number

and percentage of females appointed as members of the Board of Directors and Key Management
Personnel. If the company appoints differently abled females in such positions then the number of differently
abled female personnel and their percentage among the total number to be mentioned.

Part-V: Holding, Subsidiary and Associate Companies (including joint ventures)

21. (a) Names of subsidiary / associate companies: This part requests the parent company to give the
details of holding, subsidiary and associate companies (Including joint ventures) that are all linked with
them.
The details include the type of relation (holding/subsidiary/associate/Joint venture) with parent company,
Name, Corporate Identity Number, Foreign Company Registration Number of each holding, subsidiary and
associate company (Including joint ventures).
All the information mentioned above shall be taken from Form No. MGT-7 (as per the Companies Act 2013,
Form No. MGT-7 is used by the companies to file their returns for every financial year).
Apart from the above details, the parent company has to confirm the involvement of the
holding/subsidiary/associate/joint ventures companies in business responsibility initiatives by mentioning
“Yes” or “No” (this information is not be available in Form No. MGT-7).

(b) Do any other entity/entities (e.g. suppliers, distributors etc.) that the Company does business
with, participate in the BR initiatives of the Company? If yes, then indicate the percentage of such
entity/entities? [Less than 30%, 30-60%, More than 60%]: If the answer for this part is “Yes” then the
parent company has to mention the percentage contribution of the holding/subsidiary/associate/joint
ventures companies in their business responsibility initiatives.

Part-VI: CSR Details

According to Section 135 of the Companies Act, 2013 filing CSR is applicable to “Every company having net worth of

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rupees five hundred crore or more, or turnover of rupees one thousand crore or more or a net profit of rupees five
crore or more during any financial year shall constitute a Corporate Social Responsibility Committee of the Board
consisting of three or more directors, out of which at least one director shall be an independent director”.

22. (a) (i) Whether CSR is applicable as per section 135: (Yes/No)): With reference to the clause for CSR
mentioned in Section 135 of Companies Act, 2013, the company has to declare the following, net worth is
Rs.500 Crore (or more) (or) Turnover of Rs.1000 Crore (or more) (or) a net profit of Rs.5 crore (or more).

If the company(s) declaration is “YES” then the company has to fill the below details.
(ii) Turnover (in Rs.): In case of “YES” to the above clause, the turnover (Rs.1000 Crore (or more)) of
the company to be mentioned as appropriate.
(iii) Net worth (in Rs.): In case of “YES” to the above clause, the net worth (Rs.500 Crore (or more)) of
the company to be mentioned as appropriate.
(b) Net Profits for the last three financial years: In case of “YES” to the above clause net profit (Rs.5
Crore (or more)) of the company to be mentioned as appropriate.
The table below requests the details such as the profit before tax and the net profit. According to the Rule
2 (1) (f) under section 198 of Companies CSR Policy Rules, 2014, the net profit is defined as the net profit
of the company as per its financial statements prepared in accordance with the applicable provisions of
the Act and shall not include the following:
- Any profit arising from any overseas branch or branches of the company, whether operated as a
separate company or otherwise.
- Any dividend received from other companies in India, which are covered under and complying with
the provision of Section 135 of the Act.

23. Average net profit of the company for last three financial years (as defined in explanation to sub-
section (5) section 135 of the Act (in Rs.): The purpose of asking the average of the net profit for the last
three financial years is to confirm, whether the company spends, in every financial year, at least two per
cent of the average net profits of

the
company made during the three immediately preceding financial years, in pursuance of its Corporate Social
Responsibility Policy. The information requested in this part is in accordance to the sub section (5) of
section 135 of the Companies Act.

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24. Prescribed CSR Expenditure (two per cent of the amount as in item 23 above): The information
requested in this part is relevant to the sum of amount proposed by the company for CSR expenditure.
According to the sub section (5) of section 135 of the Companies Act, the expenditure for CSR shall be
planned with a minimum limit of 2% of the average profit (as calculated above), but it is the decision of the
company to go above the limit or not. However, by no means the company can fail to allocate fund for CSR
expenditure. As per second proviso to sub section (5) of section 135, if a company fails to spend above
calculated CSR amount, the Board shall, in its report made under clause (o) of sub-section (3) of section
134, specify reasons for not spending the amount.

25. (a) Total amount spent on CSR for the financial year (in Rs.):

The information requested in this part is relevant to the amount spent by the company on CSR for the
financial year. If the company spent the amount in accordance to the sub section (5) of the Companies Act,
then the total expenditures pertaining to the minimum limit of 2% of average net profit to be mentioned in
this item.
(b) Amount spent in local area (in Rs.): According to the sub section (5) of the Companies Act, the
company shall give preference to the local area and areas around it where it operates, for spending the
amount earmarked for Corporate Social Responsibility activities. As the company is having a direct impact
on the livelihood of nearby areas, they are directed by the Companies Act to give preference for the local
public.

(c) Manner in which the amount spent during the financial year as detailed below:
The table given below insists the company to mention the project or activity identified by the company to
fulfill their CSR goal. While identifying the CSR project or activity they have to mention the sector that covers
the CSR project or activity. The CSR project or activity shall include sectors like Education, Community
Development, Rural Development and Livelihood & skilling, Health & Environment welfare. In doing so, the
company has to indicate whether the project is located in a particular state or union territory of the country. If
the CSR project is undertaken in a particular state then the district need to be provided in the table below.
In the process of implementing their CSR project or activity the company normally allocates the
budget amount with respect to each CSR activity, also the company shall incur some expenditure related to
administrative overheads and other expenses. Information of expenditure and fund allocation pertaining to
the CSR projects need to be provided in the table below.
The mode of amount spent for the CSR project or activity refers to the transaction of money in a
transparent and accountable method. If the CSR fund is transferred to a particular account through online
then the company has to mention the mode as online. If it is a physical transaction mode then they have to
mention accordingly.

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 26. Details of the implementing Agency(ies): In case of implementing the CSR project or activity certain
companies appoint an implementing agency; the implementing agencies shall be an NGO or Health &
Environment welfare trust or a Public Relation agency. In doing so, the company has to provide the name of
each CSR project, the projects location and address, details of the implementing agency such as name of
the agency, registered office address and contact details (both telephone & online).

27. Whether a responsibility statement of the CSR Committee on the implementation and monitoring of
CSR Policy is enclosed to the Board’s Report: Yes/No:
If the CSR committee of the company has enclosed any responsibility statement on the
implementation and monitoring of CSR Policy in the Board’s Report, then the company shall mention “YES”
in this part. The responsibility statement of the CSR committee normally includes whether or not the
implementation and monitoring of CSR policy is in compliance with CSR objectives and Policy of the
Company. Also, it refers to the accomplishment of CSR activities in compliance with Companies Act, 2013 &
OPE guidelines and to meet the CSR objectives and policy of the Company.

28. Link to CSR Policy: If the company has made the CSR policy publicly available, then it can provide a web
link of the CSR policy for public reference.

Part - VII: Transparency and Disclosure Compliances

29. Complaints/Grievances on any aspect of the National Guidelines on Responsible Business Conduct
in the financial year:

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 This part insists the company to address the complaints/grievances handled during the financial year. The
complaints/grievances received from the any of the stakeholders group such as Communities, Business
Partners, Investors, Shareholder’s, Customers, Value Chain Partners and Others has to mentioned in the
below table.
Communities refers to local communities, particularly vulnerable and marginalised groups and in regions
that are underdeveloped. The complaints/grievances received from the local communities in the current
financial year and previous financial year has to be addressed in the below table.
Apart from local communities, the stakeholder’s list includes:
- The investors who invested money in the company.
- Business partners who are sharing profit.
- Shareholders holding the stocks of the company.
- Value chain partners involved in the transformation of business from idea to reality.

The company shall also explain the mechanism followed by them to solve the issue. The company has to
mention the number of complaints at the beginning of the year, received during the year pending at the
close of the year to be carried forward to the next financial year.

30. Overview of the company’s high priority responsible business conduct issues. Please indicate, up to three,
high priority responsible business conduct and sustainability issues pertaining to environmental, social and

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 governance matters that present a risk or an opportunity to your business and outline the approach that your
company is taking to address them:

SECTION B: MANAGEMENT AND PROCESS DISCLOSURE

This section is aimed at helping businesses demonstrate the structures, policies and processes put in place towards
adopting the Principles and Core Elements.

Disclosure Questions: Policy and management processes a. Name your company’s

policy/policies that cover each
principle and its core
elements of the NGRBCs.
Principle 1 Business should conduct and govern Integrity & Governance Policy
(P1) themselves with integrity in a manner that is
Ethical, Transparent and Accountable.
As the core elements of principle 1 mainly
discuss about strong institution and governance
structure, the company may give title of the
policy relevant to integrity in their business
conduct & governance.

Principle 2 Business should provide goods and services in Policy for handling Goods &
(P2) a manner that is sustainable and safe. Services and Product Safety
As the core elements of principle 2 mainly
discuss about the efficient manufacturing of
products, safety aspects and handling of goods,
the company may give title of the policy relevant
to goods & services and product safety.

Principle 3 Business should respect and promote the well- Employee Welfare and
(P3) being of all employees, including those in their Development Policy
value chains.
As the core elements of principle 3 mainly
discuss about the wellbeing of the employees in
terms of equality, freedom and grievance, the
company may give title of the policy relevant to
wellbeing of the employees.

Principle Business should respect the interests of and be Stakeholders Welfare Policy
4(P4) responsible to all its stakeholders.
As the core elements of principle 4 mainly

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 discuss about the development of the system to
identify stakeholders and identifying the impacts
on stakeholders, the company may give title of
the policy relevant to stakeholder’s wellbeing.

Principle Businesses should respect and promote human Human Rights Policy
5(P5) rights.
The core elements of Principle 5 discuss about
the involvement of the businesses to ensure
their employees are aware about the prevailing
human rights regulation in their country. The
businesses need to ensure whether or not, it
has policies, procedures to demonstrate respect
on human rights for all its stakeholders under
impact.
Principle 6 Businesses should respect and make efforts to Environmental Protection
(P6) protect and restore the environment Policy
As the core elements of Principle 6 include
strategies for sustainable and efficient use of
natural resources, improving the environmental
performance, the company may give title of the
policy relevant to Environmental Protection.

Principle 7 Businesses, when engaging in influencing Public care and Regulatory

(P7) public and regulatory policy, should do so in a Policy
manner that is responsible and transparent.
As the core elements of Principle 7 include the
companies should undertake policy advocacy
through trade and industry chambers and
associations, and other similar collective
platforms, the company may give title of the
policy relevant for Public Care and Regulations.

Principle 8 Businesses should promote inclusive growth Growth and Equitable

(P8) and equitable development. development Policy
As the core elements of Principle 8 include the
company should take appropriate actions to
minimize any adverse impacts that it has on
social, cultural and economic aspects of society,
the company may give title of the policy relevant
for Growth and Equitable Development.

Principle 9 Businesses should engage with and provide Consumer value development
(P9) value to their consumers in a responsible Policy
manner.
As the core elements of Principle 9 include the

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company should minimize and mitigate any
adverse impact of its goods and services on
consumers, the natural environment and society
at large, the company may give title of the policy
relevant for Consumer Value Development.

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SECTION C: PRINCIPLE WISE PERFORMANCE DISCLOSURE
This section is aimed at helping businesses demonstrate their performance in integrating the Principles and Core
Elements with key processes and decisions. The information sought is categorized as “Essential” and “Leadership”.
While the essential level is expected from every business that has adopted these Guidelines, the leadership level is
expected of businesses which aspire to progress to a higher level in their quest to be socially, environmentally and
ethically responsible.
Both the Essential and Leadership indicators for Principle 1: The Business should conduct and govern themselves
with integrity in a manner that is Ethical, Transparent and Accountable are as under:

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Please refer the “Report of the Committee on Business Responsibility Reporting” for rest of the principles and the
whole reporting format. The report is available at:
http://www.mca.gov.in/Ministry/pdf/BRR_11082020.pdf

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 2.3 COMPARISON OF BRR DISCLOSURES AND BRSR DISCLOSURES

BRR BRSR Remark

Applicable to top 1000 listed Applicable to all listed and unlisted The scope of BRSR has been enhanced to
entities based on market companies (to be done in a phased make it applicable to all companies.
capitalization. manner).
Reporting done by companies as a Reporting to be done on the MCA21 Thus, a listed company may have to report
part of their annual reports. portal preferably in XBRL format. twice. Firstly, in the annual report and second
on the MCA21 portal.
Format of BRR prescribed by SEBI. Two formats prescribed by the The comprehensive format would be for the
Committee. A comprehensive format large companies and the companies already
and a Lite version. reporting under the Listing Regulations.
Whereas the Lite version is for the companies
who may be unfamiliar with any sort of
sustainability reporting and the BRSR would
be their first effort at developing a
sustainability report.

Structure of the BRSR framework

In contrast with the SEBI prescribed format for BRR to be disclosed in the annual report, the BRSR framework
emphasize on the basic and most desired elements of sustainability and responsibility reporting. The BRSR formats
have been formulated to serve as a single source of sustainability information reporting for companies across the
country.

The broad components of the BRR as compared to the BRSR are as follows:
Components of BRR Components of BRSR
(As per SEBI prescribed format) (Comprehensive and Lite version)
 General information about the Company  General disclosures about the Company
More detailed than the SEBI format. Certain data would be pre-filled
based on disclosures filed in Form MGT-7/ AOC- 4
 Basic financial details of the Company  Basic financial details of the Company
Other details - information about subsidiaries and BR  Details of whether holding, subsidiary, associate, joint venture
initiatives of the subsidiaries, if any company, if any, participates in the BR initiatives of the parent
company
 BR information -  Management and Process Disclosures -
details of the BR efforts of the Company based on the 9 Structures, policies and processes put in place toward adopting the
principles of the NVG principles and core elements of sustainability reporting
 Principle-wise performance Based on the NGRBC framework
 Principle-wise performance disclosure

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2.4 TEST YOUR UNDERSTANDING – MULTIPLE CHOICE QUESTIONS

Q1) Why were the NVGs revised to NBRBC?

a) As per the new international mechanisms such as US Sustainability Development Goals and Paris Agreement
b) It had a deadline date and had to be revised for the next period
c) The organisations were ignoring the NVGs
d) To cover the Micro, Small, Medium Enterprises
e) All of the above

Q2) Which of the following is not one of the nine principles?

a) Ethics, Transparency and Accountability
b) Prevention of contagious diseases.
c) Protection of Environment
d) Employee well-being
e) All of the above

Q3) Which one of the following is not as per the principle of Ethical approach?
a) Avoiding the company owned by one of the directors when transportation is outsourced to contractors
b) Engaging a consultant to give commission to client for obtaining a tender.
c) The organisation transparently reporting the potential pollution from the new project
d) Prevention of funding by a bank to an organisation involved in illegal arms dealing
e) All of the above

Q4) Which one of the following is true for Sustainable consumption Principle?
a) The sustainable use principle does not include efficient use of electricity
b) The principle of sustainable consumption is taken form the SDG-1 for poverty eradication
c) The organisation has to have zero waste and reuse everything as per the NGRBC principle for
d) The companies should take efforts to take back the packaging waste.
e) All of the above

Q5) What accounts for forced labour?

a) Person having to pay money to the company, working there to compensate for it (at same rate as others)
b) Employee does not like his work; but he is forced to work as he is the only earning member in his family
c) Women forced by her in laws to take up a job
d) Employer asking employee to send the monthly report when he is on holidays
e) All of the above

Q6) What is the best source to refer for guidance when reviewing human rights?
a) The Companies Act
b) Occupational Health & Safety Law
c) The Constitution of India
d) Google web search
e) None of the above

Q7) What is not an effective way to fight climate change?

a) Reducing the fossil fuel usage by changing the process
b) Installing solar panels to power the headquarters office

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c) Reduce the electricity drawn from the grid and use DG set instead
d) Install a waste heat recovery system for energy efficiency.
e) None of the above

Q8) How can organisations involve in policy advocacy relating to pollution?

a) Only if the organisation is nonpolluting service-based company.
b) They can engage in policy advocacy for the public good in ethical manner
c) When the policy is for another state where the organisation does not operate
d) Only if the organisation is in the top 100 listed organisations
e) None of the above

Q9) How should an organisation behave in the need for resettlement of people?
a) Get Police help to evict the people who refuse to move out for a project of national interest.
b) They should provide fair compensation after mutual agreement to the people in such a way that their livelihood is
not threatened
c) Convince the people to donate their land for national cause
d) Give compensation slightly above the market rate and ask them to leave
e) None of the above

Q10) For a new chemical factory, the effluent let out can contaminate the river; how to disclose the issue?
a) Explain the extent of the damage the contamination can create and give them the detail mitigating system of water
treatment before the let off
b) After the wastewater treatment, the pollution is completely contained and hence there is no need to disclose it
c) Pay for the construction of few bore wells in the nearby villages so that every house has clean water.
d) The Pollution control board has approved it; so nothing to be done.
e) All of the above

Answers: 1. A; 2. B; 3. B; 4. D; 5. A; 6. C; 7. C; 8. B; 9. B; 10. A

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MODULE THREE: MCA BRSR DISCLOSURES

3.1. INTRODUCTION

In Module 2, we looked at the MCA BRSR disclosures and covered the BRSR Comprehensive format proposed by
the Committee on Business Responsibility Reporting.
In this Module, we look at the following:

 Aspects related to quality and utility of disclosures

 Guidance Note for Business Responsibility & Sustainability Reporting Format (Comprehensive)
 Business Responsibility & Sustainability Reporting Format Lite
 Guidance Note for Business Responsibility & Sustainability Reporting Format Lite
The Committee on Business Responsibility Reporting considered the fact that only the top 500 listed companies
have so far been involved in sustainability and business responsibility reporting. The Committee recommended a
trimmed down BRSR Lite version for companies that are inexperienced with sustainability reporting and BRR
formats. The questions in the BRSR Lite version are fewer in number, and the required information is relatively
easier to compile.

The Guidance Notes provide clarity on the definitions and interpretation of questions covered in BRSR formats. The
objective of the Guidance Notes is to facilitate the preparation of BRSR reports by companies. The terms used in
the reports are aligned to the NGRBC, Companies Act, 2013, and any other applicable standards. Two guidance
notes are provided, one each for the BRSR Comprehensive and BRSR Lite.

3.2. ASPECTS RELATED TO QUALITY AND UTILITY OF DISCLOSURES

The study conducted by the Committee on Business Responsibility Reporting was based on the analysis of data
from the SEBI BRR reports filed by Indian Companies. The study revealed that the SEBI BRR reporting was an
important step towards enhancing the awareness of corporates towards sustainability and business responsibility
disclosures. The study pointed out that although the companies had reported complete information, the information
provided lacked accuracy and clarity. The data provided by the companies lacked consistency which made
comparability difficult. The study showed that disclosures pertaining to supply chain and contract labor were the
weakest. The ability of the companies to respond to the questions principle- wise is tabulated below:

Ability of companies to respond to SEBI-BRR questions and how it has been addressed in the formats
NVG / Specific question Ability of the company to How it has been addressed in the
NGRBC respond proposed formats
Principle

1 Policy relating to Principle All responded Not applicable

1

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1 Number of stakeholder Most responded on With regard to complaints, the proposed
complaints received and numbers; few on resolution format specifically seeks the number of
resolved complaints at the beginning of the year,
complaints received during the year and
complaints pending resolution at the end of
the year.

2 Resource use by products Limited response Question simplified to briefly describe the
whose design has actions taken to mitigate the adverse
incorporated social or environmental and social impacts in
environmental concerns production and disposal as identified in the
Life Cycle Assessments or any other
means.
Additional Information:

 Life Cycle Assessments (LCA) for any

or all of its top 3 brands/ products
manufactured
 Percentage of R&D and capital
expenditure (capex) investments in
specific technologies to improve the
environmental and social impacts.
2 Procedures for About half of the No change as the question is critical from a
sustainable sourcing companies responded human rights perspective and for protection
of environment.

2 Mechanism to recycle Over 90% of the Question has been made more specific.
waste and extent of companies responded to
recycling done the question on
mechanism, very few
responded to a detailed
extent
3 Numbers of employees Over 90% of the Details sought in a more granular manner.
broken down by gender, companies responded
disability, contract/casual,
etc.

3 Number of complaints Over 95% of the No change required.

related to child labour, companies responded
involuntary labour, cases
on sexual harassment

3 Safety and skill Most companies More granular data sought as this is a
upgradation programmes responded in the critical issue.
for employees affirmative but data not
provided

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 4 Mapping of stakeholders Over 95% of the No change required.
and identification of companies responded
disadvantaged,
marginalised, vulnerable

5 Existence of a human Almost 100% of the Question retained; Additional information

rights policy, its coverage, companies responded sought.
and instances of
complaints and resolution

6 Strategies/initiatives to Over 90% of the No change required.

address global companies responded
environmental issues

7 Membership of industry Over 95% of the Question retained; More details sought
association, policy companies responded under leadership indicators.
advocacy channels

8 Details of CSR All companies responded Additional details sought.

interventions in line with the Companies
Act
9 Consumer complaints Most companies have More granular details sought on the nature
data provided these details of complaints.

9 Product labelling Over 60% of the Question retained.

companies responded

9 Cases of unfair trade Over 90% of the Modified to seek information on corrective
practices, irresponsible companies responded action under leadership indicators.
advertising, etc.

The Committee highlighted some additional aspects and issues that could improve the quality and utility of
disclosures. These are presented below along with how the proposed formats address these.

Additional Changes proposed by the study How addressed in BRSR

information
to be
sought in
the
proposed
formats
S. No.
1. The information sought must be in a standardised form The format has been revamped to
include quantitative and qualitative
information in a standardised
manner
2. Guidance must accompany the formats to enable Guidance document will form a part
companies to interpret questions unambiguously of the BRSR

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 3. Companies may be encouraged to extend their policies Several questions in the BRSR
to value chain partners seek information related to value
chains
4. Questions relating to how the businesses are being BRSR seeks these details
responsible for the well-being of contract/casual
employees must be included
5. Disclosures may also be sought on initiatives taken by BRSR seeks disaggregated data for
companies to address the gender gap women employees and those that
are differently abled.

3.3. GUIDANCE NOTE FOR BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORTING

FORMAT (COMPREHENSIVE)

The Guidance Note for filling up the BRSR Comprehensive format is as under and is appended as Annexure 2B of
the Report of the Committee on Business Responsibility Reporting.

SECTION A: GENERAL DISCLOSURES

Part-I: Company details

The information required at Serial numbers 2 to 6, 11 and 12 (highlighted in blue) of the BRSR Comprehensive
Format is auto filled once the CIN is entered at Serial number 1.
1. CIN No. :
The number can be entered directly or searched by entering existing registration number or Company
name in the ‘Find CIN’ service under the menu MCA Services on the MCA website.
2. Name of Company: Auto filled after entering the CIN.
3. Year of Incorporation: Auto filled after entering the CIN.
4. Registered office address: Auto filled after entering the CIN.
5. Corporate address: Auto filled after entering the CIN.
6. Email: Auto filled after entering the CIN.

7. Telephone: Contact details of the Company to be entered

8. Website: Company Website details to be entered
9. Financial year for which reporting is being done: (Drop-Down List):
Relevant financial year to be selected from the drop-down list
10. Whether shares listed on recognized Stock Exchange(s):
Option applicable as at the end of the financial year to be selected
11. Authorised Capital: Auto filled after entering the CIN.
12. Paid-up Capital: Auto filled after entering the CIN.

Part-II: Products / Services

13. Sector (s) in which the company is engaged/Number of business activities
These details are pre-filled from the eForm MGT 7 filed by the Company.

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 14. Top 3 Products / Services sold by the company by Turnover and brands associated with them:
 Enter the names of the top 3 products manufactured or services provided and their contribution to the
total turnover
 Enter the National Industrial Classification (NIC) 5-digit code. Use reference
http://mospi.nic.in/classification/national-industrial-classification/alphabetic-index-5digit.
 Enter the names of brands associated with these products, and their contribution to the total turnover
for each product.
o For each of the 3 products, enter the brands associated with it in the column next to the product
name with corresponding percentage contribution to turnover
o Add extra columns if required for more brands

For example:
Company’s Top 3 products: A, B & C contribute 20%, 15% and 12% to the total turnover
Product A – 2 Brands
 A1 (16% of turnover)
 A2 (4% of turnover)
Product B – 2 Brands
 B1 (10% of turnover)
 B2 (5% of turnover)
Product C: 1 Brand
 C1 – 12%

Brand(s) associated with the product/service and %

% of total of total Turnover contributed by the Brand(s)
S. Product/ Service NIC Turnover
No. Code (Add More
contribut Brand 1 Contribution Brand 2 Contribution
to % of total to % of total Column
ed
Turnover Turnover s)

1 A 20% A1 16% A2 4%
2 B 15% B1 10% B2 5%
3 C 12% C1 12%

15. Percentage exports by value to total turnover of the Company:

 Enter the percentage contribution of exports to the total turnover of the Company for the FY (by value).

Part III: Operations

16. Number of locations where plants (in case of manufacturing businesses) and/or operations/offices
(in case of non-manufacturing) of the Company are situated:
 Enter the number of plants and offices located within and outside India
 The information of all the national and international locations which the company manages for
different kinds of operations is to be provided. The company has to provide details about both
manufacturing and non-manufacturing businesses, if the business is related to manufacturing then

84
 they have to mention about the number of plants in operation and if the business is related to non-
manufacturing then they have to mention about the number of offices in operation.

For Example:

Location Number of plants Number of offices Total

National 5 3 8
International 2 1 3

17. Location of top 3 plants (in case of manufacturing businesses) or operations/offices (in case of
non-manufacturing) in India by contribution to turnover:
(a) National
 From the Drop-down list, Select the State and District in the country where the top 3 plants (in case of
manufacturing businesses) and/or areas of operation/offices (in case of non-manufacturing
businesses), by turnover, are situated.
 Provide the turnover from each of these plants as percentage of total turnover.
 Enter if these locations fall into any of the vulnerable categories A to D by selecting ‘Yes’ or ‘No’.

Explanation:
The categories are defined as under
o Category A: In or within 50 km of Protected Areas (areas in which human occupation or at
least the exploitation of resources is limited such as National Parks, Wild-life Sanctuaries,
Conservation Reserves, Community Reserves and Marine Protected Areas. Ref-
http://www.wiienvis.nic.in/Database/Protected_Area_854.aspx
o Category B: In or within 50 km of Biodiversity Hotspots (According to Conservation
International, to qualify as a hotspot a region must meet two strict criteria: it must contain at
least 1,500 species of vascular plants (> 0.5% of the world’s total) as endemics, and it has to
have lost at least 70% of its original habitat. Ref-
http://www.bsienvis.nic.in/Database/Biodiversity-Hotspots-in-India_20500.aspx
o Category C: In high water-stressed zones defined as “Over-exploited” or “critical” by the
Central Groundwater Board. Ref-
http://cgwb.gov.in/GW-Assessment/Categorization%20of%20AU.pdf
o Category D: Within Coastal Regulation Zones (the coastal stretches of the country and the
water area up to its territorial water limit , excluding the islands of Andaman and Nicobar and
Lakshadweep and the marine area surrounding these islands , as Coastal Regulation Zones.

(b) International
If the Company has plants and/or offices in international locations:
 Select the Countries for the top 3 (by turnover) international locations of plants in case of
manufacturing businesses and that of operations in case of non-manufacturing or service provider
entities from the drop-down list.
 Enter the percentage of turnover in respect of each country.

18. Markets Served by the Company:

(a) Locations of the market (National & International):

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  Enter the number of states for National locations and number of countries for International locations
where the markets of the Company are situated.

(b) Location of top 3 markets by contribution to Turnover:

I) National:
 Select the States of the top 3 locations of markets from the drop-down list on the basis of their
contribution to turnover.
 Enter the percentage to total turnover of the company earned from each of the three markets.
ii) International:
 Select the Countries of the top 3 locations of markets from the drop-down list on the basis of their
contribution to turnover.
 Enter the percentage to total turnover of the company earned from each of the three markets.

Part IV - Employees
19. Details as at the end of Financial Year

a. Employees (Including differently abled):

b. Differently abled Employees:
c. Workmen (including differently abled):
d. Differently abled Workmen:

 Enter the total number of employees and workmen (including differently abled) in the company.
 Classify the same on the basis of Permanent, and Other than Permanent.
 For each category of employees/workmen, enter the number of male, female and other category of
employees/workmen. The % for each category will be auto calculated.
Explanation:
 Employee as defined under Sec 2(K) of the Code on Wages, 2019 means, any person
(other than an apprentice engaged under the Apprentices Act, 1961), employed on wages
by an establishment to do any skilled, semi-skilled or unskilled, manual, operational,
supervisory, managerial, administrative, technical or clerical work for hire or reward,
whether the terms of employment be express or implied, and also includes a person
declared to be an employee by the appropriate Government, but does not include any
member of the Armed Forces of the Union. Ref-
http://egazette.nic.in/WriteReadData/2019/210356.pdf
 Workman as defined under Sec 2(s) of Industrial Disputes Act, 1947 means any person
(including an apprentice) employed in any industry to do any manual, unskilled, skilled,
technical, operational, clerical or supervisory work for hire or reward, whether the terms of
employment be express or implied, and for the purposes of any proceeding under this Act
in relation to an industrial dispute, includes any such person who has been dismissed,
discharged or retrenched in connection with, or as a consequence of, that dispute, or
whose dismissal, discharge or retrenchment has led to that dispute, but does not include
any such person—
(i) who is subject to the Air Force Act, 1950 (45 of 1950), or the Army Act, 1950 (46 of
1950), or the Navy Act, 1957 (62 of 1957); or
(ii) who is employed in the police service or as an officer or other employee of a prison; or
(iii) who is employed mainly in a managerial or administrative capacity; or
(iv) who, being employed in a supervisory capacity, draws wages exceeding ten thousand

86
 rupees per mensem or exercises, either by the nature of the duties attached to the office
or by reason of the powers vested in him, functions mainly of a managerial nature.
Ref-https://indiacode.nic.in/bitstream/123456789/2169/1/A1947-14.pdf

20. Participation/Inclusion/Representation of women (including differently abled):

 Enter the total number of persons (including differently abled) comprising the Board of Directors
and Key Management Personnel as per the Companies Act, 2013.
 Also enter the number of females and differently abled females in both the categories. The % will
be auto calculated.

Explanation:
Board of Directors or Board as defined under Sec 2(10) of the Companies Act 2013, in relation to a
company, means the collective body of the directors of the company.
Ref- https://www.mca.gov.in/Ministry/pdf/CompaniesAct2013.pdf
Key Management Personnel as defined under Sec 2(51) of the Companies Act 2013, in relation to a
company, means—
(i) The Chief Executive Officer or the managing director or the manager;
(ii) The company secretary;
(iii) The whole-time director;
(iv) The Chief Financial Officer; and
(v) such other officer as may be prescribed
Ref-https://www.mca.gov.in/Ministry/pdf/CompaniesAct2013.pdf

Part V: Holding, Subsidiary and Associate Companies (including joint ventures)

21. (a) Names of subsidiary / associate companies, CIN number, type and % age of shares
 Auto filled from MGT 7 filed by Company.

Does the company participate in the Business Responsibility initiatives of the parent
company?
 Select the Radio Button Yes / No.

87
 For Example:
The Company has rolled out safety and skill up-gradation training programs for its employees, but
this has not been implemented by the subsidiary Company. In this case, the answer would be
selected as ‘No’.
.
(b) Do any other entity/entities (e.g. suppliers, distributors etc.) that the Company does business
with participate in the BR initiatives of the Company?

 Select Yes or No, as the case may be.

If yes, then indicate the percentage of such entity/entities?

 Select the percentage of participation for each entity from the drop-down list / radio buttons.
 Less than 30%
 30-60%
 More than 60%

Part VI: CSR Details

22. (a) (i) Whether CSR is applicable as per section 135: (Yes/No) (Radio Button):

 If Form AOC-4 has already been filed by the company for the current financial year, click the Pre-fill
button.
 On clicking the button, system shall automatically display the details of items to be filled regarding the
CSR project or activity being undertaken by the company and implementing agencies.
 Select Yes or No as the case may be.

When CSR applicability selected as ‘No’, the other details required in this section are optional.
(ii) Enter the turnover and net worth of the company in rupees
.
22. (b) Net Profits for the last three financial years:
To be filled if the CSR applicability is selected as ‘Yes’ in 22(a).

 Enter the details with respect to three immediately preceding financial years viz.:
o Financial year ended
o Profit before tax (in Rupees)
o Net Profit computed u/s 198 adjusted as per rule 2(1)(f) of the Companies (CSR Policy)
Rules, 2014 (in Rupees)
 Financial year should be entered in descending order starting with the immediate preceding financial
year. E.g. 2015, 2014, 2013... so on
 Adjusted net profit mentioned above would be considered for calculating the average net profit as
specified in explanation of sub-section (5) of the section 135.

23. Average net profit of the company for last three financial years (as defined in explanation to sub-
section (5) section 135 of the Act (in Rs.):

 Average net profit (as defined in explanation to sub-section (5) section 135 of the Act) of the company
during the three immediately preceding financial years will be auto-calculated based on amounts

88
 entered in field ‘Net Profit computed u/s 198 adjusted as per rule 2(1)(f) of the Companies (CSR
Policy) Rules, 2014 (in Rupees)’.
 Amount can be entered manually if CSR is not applicable however make sure that the same is in
Rupee figures.

24. Prescribed CSR Expenditure (two per cent of the amount as in item 23 above):
 2% the amount as in item 23 will be auto calculated.
 In case of average loss during the last three financial years, prescribed CSR expenditure can be
manually entered (if any). Enter value in Rupee figures only.

25. Details of amount spent:

(a) Total amount spent on CSR for the financial year (in Rs.):

 Enter the total amount spent on CSR for the financial year in Rupees.
(b) Amount spent in local area (in Rs.):
 Enter the total amount spent on CSR for the financial year within the local limits of company. Enter
value in Rupees.
(c) Manner in which the amount spent during the financial year as detailed below:
 Enter the details of amount spent for CSR in tabular format given.
 First mention the ‘Number of CSR activities’.
 If the number is more than 20, fill the first 19 rows and provide consolidated details in 20th row. In
case the number of programmes/projects/activities are more than 20, attach the details of remaining
projects/programmes in an excel sheet under attachment section ‘Details of remaining CSR activities’.

26. Details of the implementing agency:

If the CSR amount was spent with the help of implementing agency(ies), enter the details of the Projects
for which implementing agencies were involved and the details (name, address, contact number and email
address) of the implementing agency(ies).

27. Whether a responsibility statement of the CSR Committee on the implementation and monitoring of
CSR Policy is enclosed to the Board’s Report: Yes/No (Radio Button):
 Select Yes or No as the case may be.

28. Link to CSR Policy: If the company has made the CSR policy publicly available, then it can provide a web
link of the CSR policy for public reference.
 Provide the link of the document containing CSR Policy placed in the public domain.

Part VII: Transparency and Disclosure Compliances

29. Complaints/Grievances on any aspect of the National Guidelines on Responsible Business
Conduct in the financial year:
 Enter the group of stakeholders from which complaints have been received pertaining to the National
Guidelines on Responsible Business Conduct.
 For each such identified group of stakeholders select yes or no as the case may be for Grievance
Redressal Mechanism in Place.
 If Yes, then mention the name in the Text Box.

89
  Enter the number of complaints received against each stakeholder group and number of complaints at
the beginning of the year, received during the year and pending resolution at close of year.
Explanation:
Stakeholder as per National Guidelines on Responsible Business Conduct: Individual or group concerned
or interested with or impacted by the activities of the businesses and vice-versa, now or in the future. Typically,
stakeholders of a business include, but is not limited to, its investors/shareholders, employees (and their
families), customers, communities, value chain members and other business partners, regulators, civil society
actors, and media.
For example, NGOs such as, human rights activists are groups interested in the Company’s
activities and are the stakeholders.
Note: The local community can range from persons living adjacent to an organization’s operations, to those living
at a distance who are still likely to be impacted by their operations.

Value Chain as per National Guidelines on Responsible Business Conduct: Refers to both the value chain
as well as the value created by the distribution channel for end-use customers. It also includes business
partners and those employed by value chain partners who may work out of their own premises.

For example, logistics service providers, farmers providing inputs, R & D centers, product service centers,
recycling units etc. are part of the organization’s value chain.

Grievance Redressal Mechanism as per National Guidelines on Responsible Business Conduct:

Mechanism for any stakeholder individually or collectively to raise and resolve reasonable concerns affecting
them without impeding access to other judicial or administrative remedies. The mechanism should be:
o Clear, transparent and have independent governance structures
o Accessible
o Predictable
o Equitable
o Based on dialogue and mediation

30. Overview of the company’s high priority responsible business conduct issues:
 Enter, up to three, high priority responsible business conduct and sustainability issues that present a risk or
an opportunity to the business.
 State the approach that the company is taking or has taken to address the same.
Many businesses conduct a materiality analysis to determine the environment and social issues that are of
high concern to its stakeholders (ideally based on detailed stakeholder engagements) and have a high
impact on business (based on detailed internal analysis on key business success factors). The core
elements that align with or contribute to these material sustainability issues must be treated as high priority. In
cases, where the business has not undertaken its own materiality assessment, it should go by
suggestions found in globally accepted guidelines.

For Example:
o The risk from Climate Change posed to the organization.
o The opportunity to benefit by reduced costs from recycling of materials or reduced wastage in the
manufacturing process.
Explanation:
o Sustainability for the purpose of this question may be understood as defined in the NGRBC.
o ‘Sustainability’ as per National Guidelines on Responsible Business Conduct:

90
  The outcome achieved by balancing the social, environmental and economic impacts of business.
It is the process that ensures that business goals are pursued without compromising any of the
three elements.

SECTION B: MANAGEMENT AND PROCESS DISCLOSURES

This Section is aimed at helping businesses demonstrate the structures, policies and processes put in place
towards adopting the principles and the core elements.
S Question Guidance
No.
Policy and Management Processes
1 (a) Name the policy/policies that cover each Name the policy or policies that cover its Core
principle and its core elements of the NGRBC Elements, independent of whether a policy
covers one or more principles. If more than one
(b) Has the policy being approved by the Board? policy covers a principle, name all of them in the
appropriate columns.
(c) Weblinks of policies
Select Yes or No, as the case may be, for each
principle.
Enter the link of the document containing the
Policy placed in the public domain.
A policy may cover more than one principal, or
conversely, a principal might be covered by more
than policy – in all such cases please mention all
the policy(ies) against each principal that cover
them.
For Example, A Company could have a Human
Capital Policy covering both Principle 3 – well-
being of employees; and Principle 5 – protection
of human rights.
2 Whether the company has translated the policy Select Yes or No, as the case may be, for each
into procedures. principle.
Whereas policies set out general guidelines,
procedures lay down specific plan of action for
implementation of the outlined policies.
For Example;
A Company has a policy to prevent
discrimination in hiring. The procedures relating
to the policy would set out in detail giving the
process for implementation such as, specific
responsibilities, reporting of discrimination and
redressed mechanisms for complaints.
3 Do the enlisted policies extend to your value Select ‘Yes’ or’ No’, as the case may be, for
chain partners? each principle.

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 For example, if the organization has a policy on
usage of clean energy, is this policy also being
followed by the raw material supplier
organisations?
4 Name of the national and international codes / Under each principle, enter which national and
certifications /labels/ standards adopted by your international code, certification, label or standard
company and mapped to each principle which have been adopted by the company
covering the provisions of that Principle.

For example – Forest Stewardship Council,

Fairtrade, Rainforest Alliance, Trustea)
standards (SA 8000, OHSAS, ISO, BIS).
ISO 14001:2015 certification helps the
companies reduce environmental footprint and
decreasing waste and pollution caused.

Governance, leadership and oversight

5 Details of the Director responsible for  Enter the number of directors responsible
implementation of the Business Responsibility for implementation of the BR policy (ies).
policy (ies)  Enter the DIN Number of such directors.
The Name and Designation of the
Directors shall be automatically pre-filled.
6 Does the company have a specified committee of  Select Yes or No, as the case may be
the Board/ Directors/ Officials to oversee the  Enter the number of persons forming part
implementation of the policy? If yes, please enter of such committee.
the composition.  For Directors, enter the DIN Number of
such directors. The Name and
Designation of the Directors shall be
automatically pre-filled.
 For Employees/Officials of the Company
forming part of the Committee, enter the
Employee ID Number, Name and
Designation of such official
7 Details of Review of NGRBCs by the Company:  Select the frequency of review by each
(a) Performance against above policies and follow reviewing entity from the drop-down
up action menu:
(b) compliance with statutory requirements of  For - Board Committee; and – Any other
relevance to the principles and rectify any non- Committee
compliances  Quarterly
 Half-yearly
 Annually

8 Has the company carried out independent Select Yes or No, as the case may be
assessment/ evaluation of the working of this policy
by an internal or external agency?

92
 Stakeholder Engagement

9 Process for identification of key stakeholders In about 50 words, enter the criteria used and
steps undertaken to identify stakeholders. If
details are available in the website, please
provide the weblink.
10,1 Channels of Communication & Accessing Select the Tick boxes the applicable options.
1 Information (Email, SMS, Newspaper, Pamphlets,
Advertisement, Community Meetings, Notice
Board, Website). In case of any other medium
please specify.
12 an If the Answer to question (1) above is “No” :  Select Yes or No, as the case may be for
 The company does not consider the Principles each principle
material to its business (Yes/No)
 The company does not have the financial Enter the reason in the Text Box.
or/human and technical resources available for the
task (Yes/No)
 It is planned to be done in the next financial year
(Yes/No)
 Any other reason (please specify)

SECTION C: PRINCIPLE WISE PERFORMANCE DISCLOSURE

Responses to Section C indicate how a company is performing in respect of each Principle and Core Elements of
the NGRBCs. This section requires companies to demonstrate their intent and commitment to responsible business
conduct through actions and outcomes. The questions in this section have been divided into two categories:
1. Essential: Those that are mandatory for all companies.
2. Leadership: Those that are voluntary and which provide an opportunity for companies to present their impacts
and outcomes.

PRINCIPLE 1 BUSINESSES SHOULD CONDUCT AND GOVERN THEMSELVES WITH INTEGRITY IN A

MANNER THAT IS ETHICAL, TRANSPARENT AND ACCOUNTABLE.

Essential Indicators
Q. Field Name Instruction/Guidance
No.
1 Percentage Coverage by  Enter the total number of training and awareness programmes
training and awareness on the 9 principles for each of the following segments of
programmes on the Principles stakeholders in the current financial year:
in the financial year o Board of Directors
o Key Management personnel
o Employees other than BoD & KMP
o Workmen.
o Any others to be specified

93
  Calculate the percentage of persons covered under each of
above categories as compared to the total persons in each
category and enter in Column 2.

2 Number of meetings/  Enter the total Number of meetings/ dialogues held on business
dialogues organized on responsibility and sustainability with the shareholders in the
responsible business conduct current financial year and the previous financial year.
with shareholders  Enter the percentage of shareholders attending the meetings in
current financial year and the previous financial year
3 Details of fines and penalties Enter the data for each of the following categories: for current
imposed, imprisonment and financial year
punishment awarded; appeals/ Monetary: Non-Monetary
revisions filed  Penalty/Punishment  Imprisonment
 Fine  Punishment
 Award
 Compounding Fee

 Select the relevant NGRBC Principle

 Select the Adjudicating Authority from drop-down list as per
data required to be entered in services.ecourts.gov.in –
Supreme Court & Case Type, Case Number & Year; High Court
& Bench; District Court & State, District & Court Complex.

4 Details of the Appeal/ Revision  Populate the case number from Point 3 above.
preferred in cases where fines/  Select the adjudicating authority from drop-down
penalties have been  Select the NGRBC Principle from drop-down
impugned.  Enter the details of the Appeal/ Revision preferred as regards
each principle of NGBRC.

94
5 Number of complaints / cases Enter the number of complaints / cases of bribery/corruption
of bribery/corruption registered registered in the current financial year against the
with law enforcement agencies company/employee(s) of the company with law enforcement
against the business agencies or lodged with the Company internally.
As per Sec 2(d) of Prevention of Corruption Act 1988, Undue
Advantage means any gratification whatever, other than legal
remuneration. Explanation: For the purposes of this clause the word
“gratification” is not limited to pecuniary gratifications or to
gratifications estimable in money;
the expression “legal remuneration” is not restricted to remuneration
paid to a public servant, but includes all remuneration which he is
permitted by the Government or the organisation, which he serves, to
receive
Ref:
https://indiacode.nic.in/bitstream/123456789/9317/1/corruptiona1988-
49.pdf
6 Details of disclosure of interest (a) Enter the number of instances of disclosure of
involving members of Board interest made by the directors as per section 184
of the Companies Act, 2013 in the current
financial year.
(b) Enter the number of complaints involving conflict
of interest pertaining to Board members, received
in the current financial year.
Previous year detail would be pre-filled from data
filed.

Leadership Indicators

Q. No. Field Name Instruction/Guidance

1 Percentage Coverage by awareness Pertains to the NGRBC Principle awareness programmes
programmes on the Principles in the conducted for value chain partners
current financial year  Enter the total number of awareness programmes
conducted
 Enter the percentage of such partners covered by
awareness programmes in the current financial year
compared to the total value chain partners.
2 Have full details of non-disputed If there are non-disputed fines/penalties imposed on your
fines/penalties imposed on your business by regulatory and judicial bodies in the year
business by regulatory and judicial  Disclose whether these been placed in public domain
bodies in the year been made available or not.
in public domain  Provide the channels for such communication e.g.
website, annual report, newspaper advertisements,
etc.

95
  Provide the web links to access such
Information online.
3 Provide details of such instances Based on the information disclosed above, describe up to
(up to 3) where corrective actions have three instances involving punishment/fines/penalties
been taken on the above fines/penalties imposed wherein corrective actions have been taken
imposed
4 Provide details of such instances (up to Narrate up to three instances where corrective actions
3) where corrective actions were taken have been taken on the complaints / cases of corruption
on the complaints / cases of corruption and conflicts of interest to prevent recurrence of such
and conflicts of interest. instances in future.

5 Does the company have a Business  Outline in 100 words, the Business Continuity
Continuity & Disaster Management Disaster Management Plan of the company, if any.
plan? Give details.  If details are available in the website, please also
provide a weblink.

PRINCIPLE 2 BUSINESSES SHOULD PROVIDE GOODS AND SERVICES IN A MANNER THAT IS

SUSTAINABLE AND SAFE

Essential Indicators

Q. Field Name Instruction/Guidance

No.
1 Has the company conducted Life Cycle The NIC Code, names and turnover percentage of the top
Assessment (LCA) for any or all of its top 3 Products manufactured or services provided by the
3 products manufactured company will be pre-filled from Question 14 of Section A.
Select Yes or No, as the case may be, to each of the
following, whether:
(a) the LCAs have been conducted in the current
financial year.
(b) the said assessment has been conducted by an
independent external agency.
(c) Results have been communicated in
public domain.

96
2 List 3 of your products or services whose Enter the Product or Service name in Column 1
design has incorporated social or
environmental concerns and/or risks and In column 2, Action Taken:
briefly describe the actions taken to  Describe the social /environmental risks or concerns
mitigate the adverse environmental and identified through the LCA for the product/ Service.
social impacts in production and disposal  Whom did they pose a risk to?
as identified in the LCA or any other  What measures have been taken to address them and
means what are the outcomes?

3 Percentage of R&D and capital In respect of current financial year:

expenditure (capex) investments in  Enter the percentage of R & D investments made by
specific technologies to improve the the company in specific technologies to improve the
environmental and social impacts of impact of its product and processes on environment
product and processes to total R&D and society to total R&D investment
investments made by the company.  Enter the percentage of capex investments made by
the company in specific technologies to improve the
impact of its product and processes on environment
and society to total capex
 Previous year data would be pre-filled from past
reports.
4 (a) Does the company have procedures Sustainable sourcing means incorporation of social, ethical
in place for sustainable sourcing? and environmental considerations in decisions pertaining to
(b) If yes, what percentage of your
selection of suppliers and procurement of inputs.
inputs was sourced sustainably?
(a) Select Yes if the organization has the procedures for
sustainable sourcing in place
(b) Enter the percentage of inputs sourced sustainably to
total inputs sourced by the organization
5 Percentage of input material (by value of Enter the percentage of input material (by value) sourced
all inputs) to total inputs sourced from from suppliers falling under the following categories to total
suppliers material sourced by the company (by value) during the
current financial year from:
(a) suppliers adhering to internal or external
sustainability standards / codes / policies of the
company (as per Question 4 of Section B).
(b) Adhering to internal standards/guidelines
(c) MSMEs and small producers
(d) within the district and neighboring districts

97
6 Describe the processes in place to safely Mention the process(es) that the company follows to safely
collect, reuse, recycle and dispose your collect, reuse, recycle and dispose its products at the end
products at the end of life of their useful life to minimise impact on the environment,
separately for
(a) plastics (including packaging),
(b) E-waste and
(c) other waste
As per Rule 2(o) of Plastic Waste Management Rules,
2016, Plastics means material which contains as an
essential ingredient a high polymer such as polyethylene
terephthalate, high density polyethylene, Vinyl, low density
polyethylene, polypropylene, polystyrene resins, multi-
materials like acrylonitrile butadiene styrene,
polyphenylene oxide, polycarbonate, Polybutylene
terephthalate
As per Rule 2(o) of Plastic Waste Management Rules,
2016, Plastic Waste means any plastic discarded after
use or after their intended use is over.
Ref- http://www.mppcb.nic.in/proc/Plastic%20Waste
%20Management%20Rules,%202016%20English
.pdf
As per Rule 3(1)(r) of E-waste (Management) Rules,
2016, E-Waste means electrical and electronic
equipment, whole or in part discarded as waste by the
consumer or bulk consumer as well as rejects from
manufacturing, refurbishment and repair processes.
Ref-http://greene.gov.in/wp-
content/uploads/2018/01/EWM-Rules-2016- english-
23.03.2016.pdf

Leadership Indicators

Q. Field Name Instruction/Guidance

No.
1 Describe the improvements in  Mention the improvements witnessed in the environmental
environmental and social impacts of and social impacts of product and processes due to R&D
product and processes due to R&D and Capex Investments in specific technologies.
and Capex Investments in specific  The company may provide data on per unit consumption of
technologies energy, water and raw material before and after the R&D
intervention.
 If the improvement is in the use of the product also (e.g.
detergent or fridge), this data also may be provided.

98
2 Do you have a preferential i. Select Yes or No, as the case may be, as to whether
procurement policy? From which the company has a preferential procurement policy for
marginal/vulnerable groups do you marginal/vulnerable groups.
procure? What percentage of total ii. From drop-down menu, Enter the groups from which
procurement (by value) does it the company procures input material/services.
constitute? iii. Enter the percentage of total procurement (by value)
procured from such groups.
Vulnerable and Marginalized Groups as per National
Guidelines on Responsible Business Conduct: Group of
individuals who are unable to realize their rights or enjoy
opportunities due to adverse physical, mental, social, economic,
cultural, political, geographic or health circumstances. These
groups in India can be identified on the basis, inter alia, of the
following:
i. Gender and transgender (women, girls et al.)
ii. Age (children, elderly et al.)
iii. Descent/identity/ethnicity (caste,
religion, scheduled castes, scheduled tribes, et al.)
iv. Occupation (displaced, landless small / marginal
farmers, migrant workers, et al.)
v. Persons with disability
vi. Political or religious beliefs Ref-
https://www.mca.gov.in/Ministry/pdf/NationalGuildeline_1503201
9.pdf

3 To which stakeholder groups From drop-down menu:

information on the impacts of your  Select the stakeholder groups as per list in Q 29 of
products has been communicated Section A to whom the impacts of the products have
been communicated (Communities, Business partners,
Investors, Shareholders, Customers, Value Chain
Partner, Other)
 Select Channels of communication. (Email, SMS,
Newspaper, Pamphlets, Advertisement, Community
Meetings, Notice Board, Website, Others)
 Select the frequency of such communication
(Monthly, Quarterly, Annually, Other)
4 Provide details of instances on how Mention three examples as to how feedback received from
the feedback received from stakeholders was used by the company for improvements in the
stakeholders was used for products and services.
improvements

99
 5 Percentage of recycled or reused Enter the percentage of raw material (recycled or reused) used
input material to total raw material in production to total raw material used by the company during
used in production the current financial Year.
Previous year data would be pre-filled from past data.

6 Quantities collected for reuse, Mention the Quantities of plastics (including packaging), E- waste
recycle and safe disposal at end of and other waste at end of life for the current financial year.
life  collected
 reused
 recycled
 safely disposed
Previous year data would be pre-filled.

PRINCIPLE 3 BUSINESSES SHOULD RESPECT AND PROMOTE THE WELL-BEING OF ALL

EMPLOYEES, INCLUDING THOSE IN THEIR VALUE CHAINS

Essential Indicators
Q. Field Name Instruction/Guidance
No.

100
1 Details of employees and workmen  (a) to (d) The first Column the total number of
covered by employee welfare measures employees/workmen, differently abled, permanent,
non-permanent, male, female and other categories are
pre-filled from Section A. Q.19.
 Under each category, enter the number covered by
welfare measures such as Health insurance, Accident
insurance, Maternity and Paternity benefits, and Day
Care facilities.
 The percentage will be auto calculated.

Maternity benefits
As per sec 2 (h) of Maternity Benefit Act, 1961,
Maternity Benefit means the payment referred to in sub-
section (1) of section 5.
Sec 5 (1): Subject to the provisions of this Act, every
woman shall be entitled to, and her employer shall be
liable for, the payment of maternity benefit at the rate of
the average daily wage for the period of her actual
absence immediately preceding and including the day of
her delivery and for the six weeks immediately following
that day.
Explanation: For the purpose of this sub-section,
the average daily wage means the average of the woman’s
wages payable to her for the days on which she has
worked during the period of three calendar months
immediately preceding the date from which she absents
herself on account of maternity, or one rupee a day,
whichever is higher.
Ref-
https://labour.gov.in/sites/default/files/TheMate
rnityBenefitAct1961.pdf
2 Details of statutory dues deducted and Enter the details of statutory dues (PF, Gratuity, ESI)
deposited with the authorities approved by giving No. of employees eligible for deduction, deducted
government and deposited with the authorities approved by
government for the current financial year.
Previous year data would be pre-filled.
3 Is there a mechanism available to receive  Select ‘Yes’ if there is mechanism to address
and redress grievances for each category grievances for Permanent and non-permanent
of employees and workmen employees and workmen.
 If ‘Yes; is selected, Text Boxes will appear.
 Mention the grievance redressal mechanism available
with the company to receive and redress grievances of
each of the above segment of employees.

101
4 Number of complaints made by  Mention the number of complaints of sexual
employees and workmen harassment, Working Conditions, Occupational
Health, Discrimination at workplace, Child Labour, and
Forced Labour/Involuntary Labour
o at the beginning of the year
o received during the year
o pending resolution at the end of the year for
all the employees and workmen.
 Any complaint received from employees or workmen
but not falling in any of the above categories may be
mentioned under ‘Others’.

Sexual Harassment under Sec 2(n) of The Sexual

Harassment of Women at Workplace (Prevention,
Prohibition and Redressal) Act, 2013 includes any one
or more of the following unwelcome acts or behaviour
(whether directly or by implication) namely:
i. physical contact and advances
ii. a demand or request for sexual favours
iii. making sexually coloured remarks
iv. showing pornography
v. any other unwelcome physical, verbal or non-
verbal conduct of sexual nature
Ref- http://legislative.gov.in/sites/default/files/A2013
-14.pdf

Health and Working Conditions

Sec 23 of the Occupational Safety, Health and Working
Conditions Code Bill, 2019 states that
(1) The employer shall be responsible to maintain in his
establishment such health and working conditions for the
employees as may be prescribed by the Central
Government.
(2) Without prejudice to the generality of the power
conferred under sub-section (1), the Central Government
may prescribe for providing all or any of the following
matters in the establishment or class of establishments,
namely:
i. cleanliness and hygiene
ii. ventilation, temperature and humidity
iii. environment free from dust, noxious gas, fumes
and other impurities

102
 iv. adequate standard of humidification, artificially
increasing the humidity of the air, ventilation and
cooling of the air in work rooms
v. potable drinking water
vi. adequate standards to prevent overcrowding and
to provide sufficient space to employees or
persons, as the case may be, employed therein
vii. adequate lighting
viii. sufficient arrangement for latrine and urinal
accommodation to male, female and transgender
separately for employees maintaining hygiene
therein
ix. effective arrangements for treatment of wastes
and effluents; and
x. any other arrangement which the Central
Government considers appropriate.
Ref- https://labour.gov.in/sites/default/files/186_201
9_LS_Eng_0.pdf

Child Labour
As per Sec 2(ii) of the Child Labour (Prohibition &
Regulation) Act, 1986, Child means a person who has
not completed is 14th year of age.
The amendment Act, 2016 prohibits the employment of
adolescents in the age group of 14 to 18 years in
hazardous occupations and processes and regulates their
working conditions where they are not prohibited.
Ref-
https://labour.gov.in/sites/default/files/act_3.pdf
5 Percentage of membership in  Column 1 - Total number of employees in various
association(s) or Unions recognised by categories would be prefilled from data entered in
the Board of permanent employees who section A. Q.19.
are members of the employee  Column 2 – Under each category, enter the no. of
association(s) recognised by employees and workmen (both permanent and other
the management than permanent) who are member of association(s) or
Unions recognised by the Board of the company
 Column 3 - Percentage of the total number of
employees covered would be automatically calculated
under each category.
 Previous year data would be prefilled from past data.

103
6 Assessments for the year If the plants and offices of the company have been
assessed for Child labour, Forced/Involuntary labour,
Health and safety practices and sexual harassment, enter
the percentage of the number of such establishments
assessed to total number of establishments of the
company.
For instance, if a company has assessed 5 out of
its 10 establishments, enter 50%.
7 Details of wages paid to employees and (a) The total number of employees and workmen under
workmen equal to and more than the each category, male, female and other would be
legal minimum wage prefilled as per data entered in section A, Q19.
• Enter the number of employees who were paid
wages equal to minimum wage and number of
employees who were paid wages more than the
minimum wage
(b) Under each category of differently abled
employee/ workmen, enter the total no. of employees
who were paid equal to or more than minimum wages
during the current financial year
 The percentages would be automatically calculated.
 Previous year data would be prefilled from past reports.
8 Details of safety related  Enter the Lost Time Injury Frequency Rate (LTIFR)
incidents during the current financial year.
 If the same is not available, provide the data
pertaining to Accidents at the workplace, Fatalities,
Permanent Disability and Temporary disability caused
during the current financial year.

9 Details of Training imparted to the (a) Under each category of employee/ workmen,
employees and workmen enter the total no. of employees who were given
training on health and safety measures and skill
upgradation during the current financial year.
Under each category of differently abled employee
(employee/ workmen, enter the total no. of
employees who were given training on health and
safety measures and skill upgradation during the
current financial year.

10 Describe the measures taken by the In about 50 words, narrate the measures in place. If more
company to ensure a details are available in the website of the Company, please
safe work place provide a weblink.

104
 Leadership Indicators

Q. Field Name Instruction/Guidance

No.
1 Provide the measures undertaken by the Briefly outline the steps in about 100 words. If details are
company to ensure that statutory dues available in the website, please also provide a weblink.
have been deducted and deposited by the
value chain partners

2 Provide the corrective actions taken for Briefly outline the steps in about 100 words. If details are
children identified as employed in your available in the website, please also provide a weblink.
Establishments
3 Provide the corrective actions taken for Briefly outline the steps in about 100 words. If details are
forced/involuntary labour identified in your available in the website, please also provide a weblink.
establishments / value chain
4 Provide the actions taken to prevent Briefly outline the steps in about 100 words. If details are
adverse consequences to the complainant available in the website, please also provide a weblink.
in discrimination and harassment cases

5 Provide the corrective actions taken on Briefly outline the steps in about 100 words. If details are
the outcomes of health and safety audits available in the website, please also provide a weblink.
of your establishments, including value
chain partners
6 % of accident-affected persons Briefly outline the steps in about 100 words. If details are
rehabilitated and placed in suitable available in the website, please also provide a weblink.
Employment

7 Details on assessment of value chain In the case of value chain partners of the company
partners assessed for Sexual Harassment, Working Conditions,
Health and Safety, Discrimination at workplace, Child
labour, Forced/Involuntary labour, Wages and Others,
enter the %age of value chain partners by value of
business done with such partners.

PRINCIPLE 4: BUSINESSES SHOULD RESPECT THE INTERESTS OF AND BE RESPONSIVE TO ALL ITS
STAKEHOLDERS

Essential Indicators

Q. No. Field Name Instruction/Guidance

105
 1 List stakeholder groups identified  Select the key stakeholder groups (e.g. employees,
as key for your business and communities etc.) identified by the business as described
frequency of engagement with in Section B Q.9.
each stakeholder group.  Select Yes or No, as the case maybe as to whether each
such identified stakeholder belongs to Vulnerable and
Marginalised Group.
 Select the channel of communication and the frequency of
engagement with them –
(Email, SMS, Newspaper, Pamphlets, Advertisement,
Community Meetings, Notice Board, Website)
Frequency (Annually/ Half yearly/ Quarterly) from Drop
Down List
 Select Yes or No, as the case may be as to whether
environment and social issues are discussed with each
such stakeholder.

Leadership Indicators

Q. No. Field Name Instruction/Guidance

1 Provide details of instances of Concerns discussed during stakeholder engagements and
engagement with and actions taken formal complaints received may be detailed.
to address the concerns of Briefly outline the steps in about 100 words. If details are
vulnerable/marginalised groups. available in the website, please also provide a weblink.

2 Provide details of instances as to Mention at least 3 instances where inputs received from
how the inputs received from stakeholders are incorporated by the company.
stakeholders are incorporated.

PRINCIPLE 5 BUSINESSES SHOULD RESPECT AND PROMOTE HUMAN RIGHTS

Essential Indicators
Q. Field Name Instruction/Guidance
No.

106
1 Percentage of employees provided (a) Enter the number of employees and workmen under
training on human rights policies and different categories (including differently abled) who
issues in the Financial Year were provided training on human rights policies and
issues during the current financial year.
(b) Enter the number of differently abled employees and
workmen under different categories who were
provided training on human rights policies and issues
during the current financial year.
 The total number of employees and workmen in
different categories would be prefilled from section A,
Q.19.
 The percentage would be automatically calculated

2 Details of remuneration/ salary/ (a) Enter the number and the Average remuneration,
wages salary, or wages paid, as the case may be to Board of
Directors, KMPs, other employees and workmen as
male, female and others (including differently abled).
(b) Enter separately the number of differently abled
personnel and the Average remuneration, salary, or
wages paid, as the case may be to Board of
Directors, KMPs, other employees and workmen as
male, female and others.

Remuneration
As per sec 2(78) of Companies Act 2013, Remuneration
means any money or its equivalent given or passed to any
person for services rendered by him and includes
perquisites as defined under the Income-tax Act, 1961 (43
of 1961)
Ref- http://www.mca.gov.in/Ministry/pdf/Companies
Act2013.pdf

Salary
As per Income Tax Act, 1961, Salary includes:
 wages
 any annuity or pension
 any gratuity
 any fees, commissions, perquisites or profits in lieu
of or in addition to any salary or wages
 any advance of salary
 the annual accretion to the balance at the credit of an
employee participating in a recognised provident fund,
to the extent to which it is chargeable to tax under

107
 Rule 6 of Part `A' of the Fourth Schedule; and
 the aggregate of all sums that are comprised in the
transferred balance as referred to in sub-rule (2) of
Rule 11 of Part A of the Fourth Schedule of an
employee participating in a recognised provident fund,
to the extent to which it is chargeable to tax under sub-
rule (4) thereof
Ref- https://www.incometaxindia.gov.in/Acts/Income
-tax%20Act,%201961/1968/10212000000203566
 htm

Wages
As per Sec 2(y) of Code on Wages, 2019, Wages means
all remuneration whether by way of salaries, allowances or
otherwise, expressed in terms of money or capable of being
so expressed which would, if the terms of employment,
express or implied, were fulfilled, be payable to a person
employed in respect of his employment or of work done in
such employment, and includes:
i. basic pay
ii. dearness allowance
iii. retaining allowance, if any, but
does not include
 any contribution paid by the employer to any pension or
provident fund, and the interest which may have accrued
thereon
 any conveyance allowance or the value of any travelling
concession
 any sum paid to the employed person to defray special
expenses entailed on him by the nature of his
employment
 house rent allowance
 remuneration payable under any award or settlement
between the parties or order of a court or Tribunal
 any overtime allowances
 any commission payable to the employee
 any gratuity payable on the termination of employment
 any retrenchment compensation or other retirement
benefit payable to the employee or any ex gratia payment
made to him on the termination of employment

108
 Provided that, for calculating the wages under this clause,
if payments made by the employer to the employee under
clauses (a) to (i) exceeds one-half, or such other per cent.
as may be notified by the Central Government, of the all
remuneration calculated under this clause, the amount
which exceeds such one-half, or the per cent. so notified,
shall be deemed as remuneration and shall be accordingly
added in wages under this clause.

Provided further that for the purpose of equal wages to all

genders and for the purpose of payment of wages, the
emoluments specified in clauses (d), (f), (g) and (h) shall
be taken for computation of wage.
Explanation: Where an employee is given in lieu of the
whole or part of the wages payable to him, any
remuneration in kind by his employer, the value of such
remuneration in kind which does not exceed fifteen per
cent. of the total wages payable to him, shall be deemed
to form part of the wages of such employee
Ref- https://labour.gov.in/sites/default/files/THE%20
CODE%20ON%20WAGES%2C%202019%20No.
%2029%20of%202019.pdf

3 Do you have a focal point (Individual/ Select Yes or No as the case may be.
Committee) responsible for addressing
human rights impacts or issues caused
or contributed to by the business?

4 Describe the internal mechanisms to Briefly describe the mechanisms in place to address and
address and redress grievances related redress grievances related to human rights issues in about
to human rights issues 100 words. If details are available in the website, please
also provide a weblink.
5 Stakeholders groups governed by the  The list of stakeholders will be collated from Question
grievance redressal mechanism for No. 1 of Principle 4.
Human Rights issues  Select Yes or No, whether vulnerable or marginalized
for each.
 Select Yes or No as the case may be as to whether
each group has been covered by grievance redressal
mechanism for human rights issues.

109
 6 Number of Human Rights related Mention the number of complaints related to Human Rights
grievances issues pending at the beginning of the year, received during
the year and pending resolution at the end of the year for
the current financial year.

7 Do human rights requirements form part Select Yes or No as the case may be.
of your business agreements
and contracts?

Leadership Indicators

Q. No. Field Name Instruction/Guidance

1 Details of a business process being Provide details about the changes made in the business
modified / introduced as a result of processes of the company in response to addressing the
addressing human rights human rights complaints/grievances.
Grievances/complaints.
2 Details of the scope and Provide details of the scope and coverage of any
coverage of any Human rights due- Human rights due diligence conducted by the company.
diligence conducted

PRINCIPLE 6 BUSINESSES SHOULD RESPECT AND MAKE EFFORTS TO PROTECT AND RESTORE
THE ENVIRONMENT
Essential Indicators
Q. No. Field Name Instruction/Guidance
1 Does the company have strategies/ Select Yes or No, as the case may be, as to whether the
initiatives to address global company has strategies/ initiatives to address global
environmental issues such as environmental issues.
climate change resource scarcity, Also provide the link of the document containing details of
health pandemics and emergencies, such strategies and initiatives in the public domain
natural disasters etc.
2 Does the company have any project Select Yes or No, as the case may be. If yes, a text box will
related to Low Carbon Economy be populated.
Enter the details of the projects undertaken by the
company to reduce GHG emissions.

3 Emissions/waste generated by the Select Yes or No, as the case may be. If yes, a text box will
company exceeded the limits be populated.
prescribed under the relevant Enter the details of the quantum of emissions and waste
environmental laws generated over and above the prescribed limits under the
relevant laws.

110
4 Details of the environmental impact  Enter Yes if EIA has been conducted.
assessments (EIA) undertaken?  If Yes, Enter details of environmental impact assessment
undertaken by the company as per the relevant EIA
Notification No. and date
 Enter Yes or No :
o whether EIA conducted by independent Agency
o whether results communicated in Public Domain
 Enter the Weblink if available
5 What are the material  Enter the details of material environmental risks
environmental risks identified and identified either as a result of the EIA conducted by
the mitigation measures adopted by the company or any other analysis, pertaining to Land
the business use, Emissions, Water (including marine life), Energy
(including electricity) and Biodiversity or any other
aspect impacting the environment
 Also provide the details of mitigation measures adopted
for the risks so identified.

6 Details of Energy and water (a) Aligned with India’s Nationally Determined
consumed by the company Contributions (NDCs), under the Paris Agreement,
2016, this provides details of energy and water
consumption by the Company in its operations. It is
the total net quantity of energy consumed by the
operations of the business divided by its total
turnover. It excludes consumption in
the value chain and during product use.

(b) Total quantity of water consumed by the operations of

the business divided by its total turnover. It excludes
consumption in the value chain and during product
use.
(c) Percentage of water consumed from recycled and
harvested sources to total water consumed.
(d) Percentage of water consumed from groundwater
sources to total water consumed.

7 Air emissions and liquid discharges For each of the 3 major facilities identified in Section A, Q
for the 3 major Facilities as reported 17, the following data is required to be provided for the
to the regulatory authorities current financial year:
 Permissible limit for emissions under relevant law
 Actual Measured value of such emissions and
Discharges

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8 Details of solid waste management During the current financial year:
relating to various aspects (a) Enter the total solid waste generated in Metric Tons.
(b) Percentage of recycled waste to total waste
generated.
(c) Percentage of waste sent to landfill to total
waste generated.

Leadership Indicators

Q. No. Field Name Instruction/Guidance

1 Carbon emitted per unit of Total carbon emitted as per Scope 1 and Scope 2 of
production and turnover for top 3 Greenhouse Gas Protocol.
products (a) For the business as a whole (per unit of
revenue/turnover)
(b) For each of the 3 top products (Section A, Q
17),) per unit of that product produced

2 Percentage of renewable Compute and enter the percentage of renewable energy

energy consumed to total energy consumed to total energy consumed during the current
consumed financial year.
3 Details of solid waste (a) Compute and enter the percentage of non- Biodegradable
management waste to total waste generated during the current financial
year.

(b) Compute and enter the percentage of recyclable

waste to total waste generated during the current
financial year.
(c) Compute and enter the percentage of hazardous
waste to total waste generated
during the current financial year.

4 Briefly describe the solid waste Briefly outline the steps undertaken for solid waste
management practices in your management. If details are available in the
workplaces website, please also provide a weblink. (in about 100
words)
5 Describe the strategy adopted by Briefly outline the strategy adopted by the company to
company to reduce usage of reduce usage of hazardous and toxic chemicals in the
hazardous and toxic chemicals in products and processes and the practices adopted to
products and processes and the manage such wastes. (in about 100 words)
practices adopted to manage such
wastes

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6 List innovative, resource- efficient & Briefly outline the innovative, resource-efficient & low
low carbon technologies/solutions or carbon technologies/solutions or initiatives undertaken
initiatives undertaken resulting in resulting in lower resource footprint adopted by the
lower resource footprint adopted by company pertaining to Land, Air, Water (including marine
the business, if any. life), Energy (including electricity) and Biodiversity.
If details are available in the website, please also provide
a weblink.

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PRINCIPLE 7 BUSINESSES, WHEN ENGAGING IN INFLUENCING PUBLIC AND REGULATORY
POLICY, SHOULD DO SO IN A MANNER THAT IS RESPONSIBLE AND TRANSPARENT

Essential Indicators
Q. No. Field Name Instruction/Guidance
1 Details of the trade and industry (a) Mention the number of affiliations with trade and
chambers/ associations you are a industry chambers/ associations on the basis of no. of
member of or are affiliated to members.
(b) Select the names of such trade and industry
chambers/ associations.
If any other, Specify in the Text Box.
Also select the scope of the trade association,
industry chamber, etc. as to whether it is state level or
national level.
2 Details of adverse orders and case  Enter the name of the Adjudicating Authority and the
details for anti- competitive conduct name of the opposing party wherein the company is
by your business. involved in case pertaining to anti- competitive
conduct by the business along with the case number.
 Mention the brief details of the Judgment or Award.
 Select Yes or No as the case may be as to whether an
appeal has been preferred or not.
Anti-Competitive Conduct
Sec 3 of Competition Act, 2002, states that No
enterprise or association of enterprises or person or
association of persons shall enter into any agreement in
respect of production, supply, distribution, storage,
acquisition or control of goods or provision of services,
which causes or is likely to cause an appreciable adverse
effect on competition within India.
Sec 4 of Competition Act, 2002, states that No
enterprise or group shall abuse its dominant position
Sec 6 of Competition Act, 2002, states that No person or
enterprise shall enter into a combination which causes or is
likely to cause an appreciable adverse effect on
competition within the relevant market in India and such a
combination shall be void. Ref-
https://www.cci.gov.in/sites/default/files/cci_pdf
/competitionact2012.pdf

Leadership Indicators
Q. No. Field Name Instruction/Guidance
1 Details of public policy positions  Enter the name of the public policies on which
advocated for and available in the advocacy positions have been taken by the company.
public domain.  Provide the details of methods resorted to in each

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 case including affiliation with other similar business
entities by forming coalitions, representing through
trade chambers, social marketing, etc.
 Select Yes or No, as the case may be, for the
availability of information on each public policy
advocated in public domain.
 Select the appropriate frequency of Board review from
the drop-down menu containing the following options:
 Quarterly
 Half-yearly
 Annually
Also provide the link of the document containing details of
such public policy position advocated in the public domain
2 Details of corrective action for anti-  Click the Pre-fill button. On clicking the button, system
competitive conduct by the business shall automatically populate the details of the adverse
taken based on adverse orders from orders against the company from Principle 7, Q 2.
regulatory authorities.  Enter the details of the corrective action taken by the
company against each such order.

PRINCIPLE 8 BUSINESSES SHOULD PROMOTE INCLUSIVE GROWTH AND EQUITABLE

DEVELOPMENT

Essential Indicators
Q. No. Field Name Instruction/Guidance
1 Details of social impact Select Yes or No, as the case may be:
assessments undertaken for (a) Whether social impact assessment of projects has
projects in the current financial year been conducted by the company.
(b) Whether the said assessment has been conducted by
an independent external agency.
(c) Whether information on such impact
assessment is available in public domain. Also
provide the link of the document containing details of
such social impact assessment in the public domain.
2 Information on project(s) for which Enter the following details of the project wherein land
ongoing Rehabilitation and acquisition for which Rehabilitation and Resettlement is
Resettlement is being undertaken ongoing by the business during the year (if any):
(a) Name of the project for which R&R is ongoing
(b) State/district of the project
(c) Number of Project Affected Families (PAFs)
(d) % of PAFs covered by R&R in the year
(e) Amounts paid to PAFs in the FY.

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3 CSR projects undertaken by your Select the aspirational districts from the dropdown menu
company in designated aspirational and their states where the CSR activities were undertaken
districts as identified by government and the amount spent.
Bodies
4 Describe the mechanisms to receive Describe the mechanism in about 50 words
grievances of the local Community

5 Brief information on the various Provide brief information of intellectual properties based
intellectual properties owned or on traditional knowledge owned or acquired by the
acquired by your business based on business in the current Financial Year, Select Owned or
traditional knowledge where the Acquired, as the case may be. Select Yes or No as the
benefits derived therefrom are case may be whether benefit arising out of such and IPRs
shared Equitably are shared on the lines of Access to Biological

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 Resources and Associated Knowledge and Benefits
Sharing Regulations, 2014.

Intellectual Properties
Intellectual property refers to creations of the mind:
inventions; literary and artistic works; and symbols, names
and images used in commerce. Intellectual property is
divided into two categories:
i. Industrial Property includes patents for
inventions, trademarks, industrial designs and
geographical indications.
ii. Copyright covers literary works (such as novels,
poems and plays), films, music, artistic works
(e.g., drawings, paintings, photographs and
sculptures) and architectural design. Rights
related to copyright include those of performing
artists in their performances, producers of
phonograms in their recordings, and
broadcasters in their radio and television
programs.
Ref: https://www.wipo.int/edocs/pubdocs/en/intpro
perty/450/wipo_pub_450.pdf

Traditional Knowledge
Traditional knowledge in a general sense
embraces the content of knowledge itself as well as
traditional cultural expressions, including distinctive signs
and symbols associated with TK.
Traditional knowledge in the narrow sense refers to
knowledge as such, in particular the knowledge resulting
from intellectual activity in a traditional context, and
includes know-how, practices, skills, and innovations.
Ref- https://www.wipo.int/tk/en/tk/

6 List of adverse orders and case In case of such orders, enter the name of the Adjudicating
details of intellectual property rights Authority, name of the opposing party wherein the
disputes related to traditional company is involved in case pertaining to intellectual
knowledge during the FY. property rights dispute along with the Case No. of such
case.
Mention the brief of the Judgment or Award of such case.
Also Select Yes or No as the case may be as to
whether an appeal has been preferred.

117
 Leadership Indicators

Q. No. Field Name Instruction/Guidance

1 Provide details of actions Enter the negative social impacts identified in the
taken tomitigate any negative social assessments and briefly outline the corrective actions
impacts identified in SIA taken.
2 Details of the benefits derived of the The list of IPR will be pre-filled from E5. Briefly outline the
various intellectual properties basis for calculating the benefits shared by the company
owned or acquired by your with the “owners” of such traditional knowledge.
company based on traditional
knowledge shared

3 Details of corrective actions taken in Enter the details of the corrective action taken by the
intellectual property related cases company against each such order.
wherein usage of traditional
knowledge is involved.
4 Details of beneficiaries of CSR For each CSR Project undertaken by the
Projects company, enter:
(a) total number of beneficiaries,
(b) %age of such beneficiaries belonging to
vulnerable and marginalised groups,
(c) Names of vulnerable and marginalised
groups.

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PRINCIPLE 9 BUSINESSES SHOULD ENGAGE WITH AND PROVIDE VALUE TO THEIR CONSUMERS
IN A RESPONSIBLE MANNER

Essential Indicators
Q. No. Field Name Instruction/Guidance
1 Describe the mechanisms in place In about 100 words, outline the mechanism put in place by
to receive and respond to consumer the company to receive and respond to consumer
feedback feedback. If more details are available on the website of
the Company, please provide the weblink.

2 % of goods and services of your Enter the %age of goods and services by turnover
business carrying information carrying information regarding:
relevant to consumers  Environmental and social parameters relevant to the
product such as energy used, water consumed, and
number of people involved in its production etc.
 Safe and responsible usage
 Recycling and safe disposal of the product after use
Please note that if the question is not relevant to your
product/service, please enter “Not applicable”.
3 Number of consumer Enter the number of consumer complaints received and
complaints number of consumer complaints pending resolution at
close of year for both, the current financial year with
respect to:
(i) Data Privacy
(ii) Advertising
(iii) Delivery of essential services
(iv) Restrictive Trade Practices under
Competition Act, 2002
(v) Unfair Trade Practices under Consumer Protection
Act, 1986

Restrictive Trade Practices

Sec 3 of Competition Act, 2002, states that No
enterprise or association of enterprises or person or
association of persons shall enter into any agreement in
respect of production, supply, distribution, storage,
acquisition or control of
goods or provision of services, which causes or is

119
 likely to cause an appreciable adverse effect on
competition within India.
Sec 4 of Competition Act, 2002, states that No
enterprise or group shall abuse its dominant position
Sec 6 of Competition Act, 2002, states that No person or
enterprise shall enter into a combination which causes or is
likely to cause an appreciable adverse effect on
competition within the relevant market in India and such a
combination shall be void.
Ref- https://www.cci.gov.in/sites/default/files/cci_pdf
/competitionact2012.pdf

Unfair Trade Practices

Sec 2 (1) (r) of Consumer Protection Act 1996, Unfair
trade practice means a trade practice which, for the
purpose of promoting the sale, use or supply of any goods
or for the provision of any service, adopts any unfair
method or unfair or deceptive practices.
Ref- http://ncdrc.nic.in/bare_acts/Consumer%20Prot
ection%20Act-1986.html

Leadership Indicators

1 Channels / platforms where In 100 words, describe the Channels / platforms where
information on goods and services information on goods and services of the business can be
of the business can be accessed. accessed. For Example, websites of the company, Mobile
Apps, Help Desks, Call Centers, etc.
Also provide the link of the document containing such
information as available in the public
domain.
2 Steps taken to inform and educate In 100 words, describe the steps taken to provide
vulnerable and marginalised information to the vulnerable and marginalised consumers
consumers about safe and and educate them regarding safe and responsible usage of
responsible usage of products products.
3 Corrective actions taken in respect In 100 words, detail the corrective actions taken by the
of complaints received on data company to address complaints received on data privacy,
privacy, advertising, and delivery of advertising, and delivery of essential services.
essential services.
4 Mechanisms in place to inform In 100 words, detail the mechanisms in place to inform
consumers of any risk of consumers of any risk of disruption/discontinuation of
disruption/discontinuation essential services.
of essential services.

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 5 Details of Product information over In 100 words, detail the kind of information specified on
and above mandate of law. your products and the associated Standards/ Labels in
accordance with which disclosures are being made.

6 Consumer survey/ consumer In 100 words, detail the outcomes of any consumer survey
satisfaction trends carried out by you and the trends emerging from it.

3.4. BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORTING FORMAT LITE

The BRSR Lite format is proposed for sustainability reporting by companies which are unfamiliar with sustainability
reporting in the past. The BRSR Lite version also includes the Essential and Leadership categories of questions.
Some of the questions included in the BRSR Comprehensive Format have been excluded from the BRSR Lite
version, making it easier for smaller companies to provide the information
The rationale behind this thinking is that the implementation of reporting requirement would be done in phases, so
that smaller companies have the time to adapt and learn from the larger ones. The unlisted companies below a
specified threshold of turnover or paid-up capital can begin with adopting a Lite version of the format, on a voluntary
basis.

The format for Business Responsibility and Sustainability Reporting Lite version is provided at Annexure 3A of the
Report of the Committee on Business Responsibility Reporting.

3.4.1. COMPARISON BETWEEN BRSR COMPREHENSIVE AND BRSR LITE

I. Differences and exclusions

The following table provides a snapshot of the comparison of the number of questions covered in the BRSR
Comprehensive format with the BRSR Lite format and the exclusions made in the BRSR Lite version.
Description Question No. of Question Question
Exclusions / changes in Comprehensiv s
BRSR Lite Format e Lite

SECTION A: GENERAL DISCLOSURES

I Company details - 1 -12 1-12

II Products - 13-15 13-15
III Operations 16 & 18 excluded 16 -
17 16
18 -
IV Employees - 19 17
20 18
V Holding / Subsidiary/Associate - 21 19

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 (including Joint Ventures) details
VI CSR - 22-25 20-23
26 to 28 excluded 26-28 -
VII Transparency and Disclosures Section excluded 29-30 -
Compliances

SECTION B: MANAGEMENT AND PROCESS DISCLOSURES

Policy and management 2 excluded 1-4 1-3

processes
Governance, leadership and Section excluded- 5-8 -
oversight
Stakeholder Engagement 10 excluded 9-12 5-7

SECTION C: PRINCIPLE WISE PERFORMANCE DISCLOSURE

Principle Indicator
1 Essential 1,2 excluded 1-7 1-4
Leadership 1,5 excluded 1-5 1-3
2 Essential 4 excluded 1-6 1-4
5 moved to Leadership
Leadership 2,3,4,6 excluded 1-6 1-3
3 Essential 6,7,10 excluded 1-9 1-6
9 – moved to Leadership
Leadership 1,7 excluded 1-7 1-6
4 Essential - 1 1
Leadership 1 excluded 1 -
5 Essential 1,6,7 excluded 1-7 1-3
5 – moved to Leadership
Leadership 2 1-2 1-2
6 Essential 1,2,3,4,8 1-8 1-2
5 – Moved to leadership
Leadership 1,5,6 1-6 1-4
7 Essential 2 1-2 1
Leadership 1,2 1-2 -
8 Essential 1,2 1-6 1-3
3 - moved to leadership -
Leadership 1,4 1-4 1-3
9 Essential - 1-3 1-3
Leadership 2 to 6 excluded 1-6 1

Description of the changes in BRSR Lite in comparison with BRSR Comprehensive format:

SECTION A: GENERAL DISCLOSURES

Part 1: Company details:

122
Same as BRR format Comprehensive
Part II: Products
Same as BRR format Comprehensive
Part III: Operations:
The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite:
16. Number of locations where plants (in case of manufacturing businesses) and/or operations/offices (in case of
non-manufacturing) of the Company are situated.
18. Markets served by the Company.
Part IV: Employees:
Same as BRR format Comprehensive
Part V: Holding / Subsidiary details
Same as BRR format Comprehensive
Part VI: CSR
The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite:
26. Details of Implementing Agency (ies)
27. Whether a responsibility statement of the CSR Committee on the implementation and monitoring of CSR Policy
is enclosed to the Board’s Report: Yes/No (Radio Button)
28. Link to CSR Policy
Part VII. Transparency and Disclosures Compliances (Entire Section omitted in BRSR Lite).
The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite:
29. Complaints/Grievances on any aspect of the National Guidelines on Responsible Business Conduct in the
financial year:
30. Overview of the company’s high priority responsible business conduct issues.

SECTION B: MANAGEMENT AND PROCESS DISCLOSURES

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite:
Policy and management processes
2. Whether the company has translated the policy into procedures.

Governance, leadership and oversight

5. Details of the Director responsible for implementation of the Business Responsibility policy (ies)
6. Does the company have a specified committee of the Board/ Directors/ Officials to oversee the implementation of
the policy?

123
8. Has the company carried out independent assessment/ evaluation of the working of this policy by an internal or
external agency?

Stakeholder Engagement10. Mention the channels to communicate to stakeholders, features of your policies,
procedures, decisions and performance that impact them and details and outcomes of its stakeholder engagement

SECTION C: PRINCIPLE WISE PERFORMANCE DISCLOSURE

PRINCIPLE 1
Businesses should conduct and govern themselves with integrity in a manner that is Ethical, Transparent
and Accountable.

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite:
Essential Indicators
1. Percentage coverage by training and awareness programmes on any or all the Principles in the financial year:
2. Meetings/ dialogues organized on responsible business conduct and sustainability with shareholders

Leadership Indicators
1. Percentage coverage by awareness programmes on any or all the Principles in the financial year: Segment
5. Does the company have a business continuity and disaster management plan? Give details in 100 words/ web
link.

PRINCIPLE 2
Businesses should provide goods and services in a manner that is sustainable and safe

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite :
Essential Indicators
4. a. Does the company have procedures in place for sustainable sourcing?
b. If yes, what percentage of your inputs was sourced sustainably?

Leadership Indicators
2. Do you have a preferential procurement policy where you give preference to purchase from suppliers
comprising marginal/vulnerable groups?
3. Information on the impact of your products has been communicated to stakeholder:
4. Provide details of at least three instances on how the feedback received from stakeholders was used for
improvements or modifications in the company’s existing policies and practices. (Text Box)
6. Provide separate details of quantities collected for reuse, recycling, safe disposal after sale, and at end of life of
your products

The following question has moved from Essential indicators in BRSR Comprehensive to Leadership indicator in
BRSR Lite:
5. Percentage of input material (by value of all inputs) to total inputs sourced from suppliers)

PRINCIPLE 3

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Businesses should respect and promote the well-being of all employees, including those in their value
chains

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite:
Essential Indicators
6. Assessments for the year
7. a. Details of employees and workmen in terms of minimum wages paid:
b. Details of differently abled employees and workmen in terms of minimum wages paid
10. Describe the measures taken by the company to ensure a safe and healthy workplace.

Leadership Indicators
1. Provide the measures undertaken by the company to ensure that statutory dues have been deducted and
deposited by the value chain partners
7. Details on assessment of value chain partners:

The following question has moved from Essential indicators in BRSR Comprehensive to Leadership indicator in
BRSR Lite:
9. Details of training to employees and workmen (% to total no. of employees/workmen in the category): -

PRINCIPLE 4
Businesses should respect the interests of and be responsive to all its stakeholders

The following question included in BRSR Comprehensive Format are excluded from BRSR Lite:

Leadership Indicators
1. Provide details of instances of engagement with, and actions taken to, address the concerns of vulnerable /
marginalised stakeholder groups.

PRINCIPLE 5
Businesses should respect and promote human rights

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite :
Essential Indicators
1. a. Percentage of employees and workmen that have been provided training on human rights issues and
policy(ies) of the company in the Financial Year
b. Percentage of differently abled employees and workmen that have been provided training on human rights
issues and policy(ies) of the company in the Financial Year
6. Details of Human Rights related grievances
7. Do human rights requirements form part of your business agreements and contracts?
Leadership indicators
2.Details of the scope and coverage of any human rights due- diligence conducted

The following question has moved from Essential indicators in BRSR Comprehensive to Leadership indicator in
BRSR Lite:

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5. Stakeholders groups covered by the grievance redressal mechanism for Human Rights issues: -

PRINCIPLE 6
Businesses should respect and make efforts to protect and restore the environment

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite :
Essential Indicators
1. Does the company have strategies/ initiatives to address global environmental issues such as climate change
resource scarcity, health pandemics and emergencies, natural disasters etc.
2. Does the company have any project related to Low Carbon Economy? If Yes, provide details.
3. Have the emissions/waste generated by the company exceeded the limits prescribed under the relevant
environmental laws?
4. Details of environmental impact assessments of projects undertaken by the company: Current Financial Year 8.
What is the % of solid waste generated that is recycled and sent to the landfill?
8. Details of solid waste management relating to various aspects

Leadership Indicators
1. Carbon emitted per unit of production and revenue/turnover for each major product manufactured by the
company
5. Briefly describe the strategy adopted by your company to reduce usage of hazardous and toxic chemicals in your
products and processes and the practices adopted to manage such wastes.
6. List innovative technologies, solutions and initiatives undertaken resulting in lower environment footprint adopted
by the company

The following question has moved from Essential indicators in BRSR Comprehensive to Leadership indicator in
BRSR Lite:
5. What are the material environmental risks to the business identified and the mitigation measures adopted by
the company

PRINCIPLE 7
Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite :
Essential Indicators

2. Details of adverse judicial or regulatory orders for anti-competitive conduct by your company in the current
Financial Year

Leadership Indicators
1. Details of public policy positions advocated by the company:
2. Details of corrective action for anti-competitive conduct by the company taken based on adverse orders from
regulatory authorities. (Ref. Q 2 in Essential Indicators)

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The following question from ‘List the top 10 brands’ in BRSR Comprehensive has changed to ‘List the top 5 brands’
in BRSR Lite:
1. List the top 10 trade and industry chambers/ associations you are a member of/are affiliated to, on the basis of
no. of members.

PRINCIPLE 8
Businesses should promote inclusive growth and equitable development Essential Indicators

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite :
Essential Indicators
1. Details of Social Impact Assessments (SIA) undertaken by the company for projects in the current Financial Year
2. Information on project(s) for which ongoing Rehabilitation and Resettlement is being undertaken by your
company.

Leadership Indicators
1. Provide details of actions taken to mitigate any negative social impacts identified in the Social Impact
Assessments.
4. Details of beneficiaries of CSR Projects:

The following question has moved from Essential indicators in BRSR Comprehensive to Leadership indicator in
BRSR Lite:
3. Provide the following information on CSR projects undertaken by your company in designated aspirational
districts as identified by government bodies

PRINCIPLE 9
Businesses should engage with and provide value to their consumers in a responsible manner

The following questions included in BRSR Comprehensive Format are excluded from BRSR Lite :
Leadership Indicators
2. Steps taken to inform and educate consumers, especially vulnerable and marginalised consumers, about safe
and responsible usage of products and services.
3. Corrective actions taken in respect of complaints received on data privacy, advertising, and delivery of essential
services.
4. Mechanisms in place to inform consumers of any risk of disruption/discontinuation of essential services.
5. Does the company display product information on the product over and above what is mandated as per local
laws?
6. Did your company carry out any consumer survey?

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3.5. GUIDANCE NOTE ON BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORTING
FORMAT LITE

The Guidance Note for filling up the BRSR Lite format is given at Annexure 3B of the Report of the Committee on
Business Responsibility Reporting.

Part-I: Company Details

The information required at Serial numbers 2 to 6, 11 and 12 (highlighted in blue) of the BRSR Comprehensive
Format is auto filled based once the CIN is entered at Serial number 1.
1. CIN No. : The number can be entered or searched by entering Company name under ‘Find CIN’ option on
MCA Services.
2. Name of Company: Auto filled after entering the CIN.
3. Year of Incorporation:. Auto filled after entering the CIN.
4. Registered office address: Auto filled after entering the CIN.
5. Corporate address: Auto filled after entering the CIN.
6. Email: Auto filled after entering the CIN.
7. Telephone: Contact details of the Company to be entered
8. Website: Company Website details to be entered
9. Financial year for which reporting is being done: (Drop-Down List):
 Relevant financial year to be selected from the drop down list
10. Whether shares listed on recognized Stock Exchange(s):
 Option applicable for the financial year to be selected
11. Authorised Capital: Auto filled after entering the CIN.
12. Paid-up Capital: Auto filled after entering the CIN.

Part-II: Products/Services
13. Sector (s) in which the company is engaged/Number of business activities
These details are pre-filled from the eForm MGT 7 filed by the Company.

14. Top 3 Products / Services sold by the company by Turnover and brands associated with them:
 Enter the names of the top 3 products and their contribution to the total turnover
 Enter the National Industrial Classification (NIC) 5-digit code using ref:
http://mospi.nic.in/classification/national-industrial-classification/alphabetic-index-5digit.
 Enter the names of brands associated with these products, and their contribution to the total turnover
for each product.

15. What is the contribution of exports to total turnover of the Company in percentage?
 Enter the percentage contribution of exports to the total turnover of the Company for the financial year.

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Part III: Operations

16. Location of top 3 plants (in case of manufacturing businesses) or operations/offices (in case of
non-manufacturing) in India by contribution to turnover:
 From the Drop down list, Select the State and District in the country where the top 3 plants (in case of
manufacturing businesses) and/ or areas of operation/offices (in case of non-manufacturing
businesses), by turnover, are situated
 Provide the turnover from each of these plants as percentage of total turnover.
 Enter if these locations fall into any of the vulnerable categories A to D by selecting ‘Yes’ or ‘No’.

Explanation:
The categories are defined as under:
o Category A: In or within 50 km of Protected Areas (areas in which human occupation or at least
the exploitation of resources is limited such as National Parks, Wild-life Sanctuaries, Conservation
Reserves, Community Reserves and Marine Protected Areas. Ref-
http://www.wiienvis.nic.in/Database/Protected_Area_854.aspx)
o Category B: In or within 50 km of Biodiversity Hotspots (According to Conservation International,
to qualify as a hotspot a region must meet two strict criteria: it must contain at least 1,500 species
of vascular plants (> 0.5% of the world’s total) as endemics, and it has to have lost at least 70% of
its original habitat. Ref- http://www.bsienvis.nic.in/Database/Biodiversity-Hotspots-in-
India_20500.aspx )
o Category C: In high water-stressed zones defined as “Over-exploited” or “critical” by the Central
Groundwater Board.
 Category D: Within Coastal Regulation Zones (the coastal stretches of the country and the water
area up to its territorial water limit, excluding the islands of Andaman and Nicobar and
Lakshadweep and the marine areas surrounding these islands, as Coastal Regulation Zones.
Ref- http://egazette.nic.in/WriteReadData/2019/ 195679.pdf )

(b) International
If the Company has plants and/or offices in international locations:
 Select the Countries for the top 3 (by turnover) international locations of plants in case of
manufacturing businesses and that of operations in case of non-manufacturing or service provider
entities from the drop-down list.
 Enter the percentage of turnover in respect of each country.

Part IV: Employees

17. Details as at the end of Financial Year

 Employees (Including differently abled):

 Differently abled Employees:
 Workmen (including differently abled):
 Differently abled Workmen:

 Enter the total number of employees and workmen (including differently abled) in the company.
 Classify the same on the basis of Permanent, and Other than Permanent.
 For each category of employees/workmen, enter the number of male, female and other category of
employees/workmen. The % for each category will be auto calculated.

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 Explanation:
 Employee as defined under Sec 2(K) of the Code on Wages, 2019 means, any person
(other than an apprentice engaged under the Apprentices Act, 1961), employed on wages
by an establishment to do any skilled, semi-skilled or unskilled, manual, operational,
supervisory, managerial, administrative, technical or clerical work for hire or reward,
whether the terms of employment be express or implied, and also includes a person
declared to be an employee by the appropriate Government, but does not include any
member of the Armed Forces of the Union. Ref-
http://egazette.nic.in/WriteReadData/2019/210356.pdf
 Workman as defined under Sec 2(s) of Industrial Disputes Act, 1947 means any person
(including an apprentice) employed in any industry to do any manual, unskilled, skilled,
technical, operational, clerical or supervisory work for hire or reward, whether the terms of
employment be express or implied, and for the purposes of any proceeding under this Act
in relation to an industrial dispute, includes any such person who has been dismissed,
discharged or retrenched in connection with, or as a consequence of, that dispute, or
whose dismissal, discharge or retrenchment has led to that dispute, but does not include
any such person—
(i) who is subject to the Air Force Act, 1950 (45 of 1950), or the Army Act, 1950 (46 of
1950), or the Navy Act, 1957 (62 of 1957); or
(ii) who is employed in the police service or as an officer or other employee of a prison; or
(iii) who is employed mainly in a managerial or administrative capacity; or
(iv) who, being employed in a supervisory capacity, draws wages exceeding ten thousand
rupees per mensem or exercises, either by the nature of the duties attached to the office
or by reason of the powers vested in him, functions mainly of a managerial nature.
Ref.-https://indiacode.nic.in/bitstream/123456789/2169/1/A1947-14.pdf

18. Participation/Inclusion/Representation of women (including differently abled):

 Enter the total number of persons (including differently abled) comprising the Board of Directors
and Key Management Personnel as per the Companies Act, 2013.
 Also enter the number of females and differently abled females in both the categories. The % will
be auto calculated.

Explanation:
o Board of Directors or Board as defined under Sec 2(10) of the Companies Act 2013, in relation to
a company, means the collective body of the directors of the company.
o Key Management Personnel as defined under Sec 2(51) of the Companies Act 2013, in relation to
a company, means—
(i) the Chief Executive Officer or the managing director or the manager;
(ii) the company secretary;
(iii) the whole-time director;
(iv) the Chief Financial Officer; and
(v) such other officer as may be prescribed
Ref-https://www.mca.gov.in/Ministry/pdf/CompaniesAct2013.pdf

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Part VI: Holding, Subsidiary and Associate Companies (including joint ventures)
19. Names of subsidiary / associate companies, CIN number, type and % age of shares
 Auto filled from MGT 7 filed by Company.

(a) Does the company participate in the Business Responsibility initiatives of the parent
company?
 Select the Radio Button Yes / No.

(b) Do any other entity/entities (e.g. suppliers, distributors etc.) that the Company does business
with: participate in the BR initiatives of the Company?

 Select Yes or No, as the case may be.

If yes, then indicate the percentage of such entity/entities?

 Select the percentage of participation for each entity from the drop-down list / radio buttons.
i. Less than 30%,
ii. 30-60%,
iii. More than 60%:

Part VI: CSR Details.

20. (a) (i) Whether CSR is applicable as per section 135: (Yes/No) (Radio Button):

 If Form AOC-4 has already been filed by the company for the current financial year, click the Pre-fill
button.
 On clicking the button, system shall automatically display the details of items to be filled regarding the
CSR project or activity being undertaken by the company and implementing agencies.
 Select Yes or No as the case may be.

When CSR applicability selected as ‘No’, the other details required in this section are optional.
ii) Enter the turnover and net worth of the company in rupees.

20. (b) Net Profits for the last three financial years:
 To be filled is the CSR applicability is selected as ‘Yes’ in 22(a).
 Enter the details with respect to three immediately preceding financial years viz.:
o Financial year ended
o Profit before tax (in Rupees)
o Net Profit computed u/s 198 adjusted as per rule 2(1)(f) of the Companies (CSR Policy)
Rules, 2014 (in Rupees)
 Financial year should be entered in descending order starting with the immediate preceding financial
year. E.g. 2015, 2014, 2013... so on
 Adjusted net profit mentioned above would be considered for calculating the average net profit as
specified in explanation of sub-section (5) of the section 135.

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 21. Average net profit of the company for last three financial years (as defined in explanation to sub-
section (5) section 135 of the Act (in Rs.):

 Average net profit (as defined in explanation to sub-section (5) section 135 of the Act) of the company
during the three immediately preceding financial years will be auto-calculated based on amounts
entered in field ‘Net Profit computed u/s 198 adjusted as per rule 2(1)(f) of the Companies (CSR
Policy) Rules, 2014 (in Rupees)’.
 Amount can be entered manually if CSR is not applicable however make sure that the same is in
Rupee figures.

22. Prescribed CSR Expenditure (two per cent of the amount as in item 21 above):
 2% the amount as in item 21 will be auto calculated.
 In case of average loss during the last three financial years, prescribed CSR expenditure can be
manually entered (if any). Enter value in Rupee figures only
 First mention the ‘Number of CSR activities’
 If the number is more than 20, fill the first 19 rows and provide consolidated details in 20th row. In
case the number of programmes / projects / activities are more than 20, attach the details of remaining
projects / programmes in an excel sheet under attachment section ‘Details of remaining CSR
activities’.

23. (a) Total amount spent on CSR for the financial year (in Rs.):
 Enter the total amount spent on CSR for the financial year in Rupees.

(b) Amount spent in local area (in Rs.):

 Enter the total amount spent on CSR for the financial year, within the local limits of company. Enter
value in Rupees.

(c) Manner in which the amount spent during the financial year as detailed below:
 Enter the details of amount spent for CSR in tabular format given.

SECTION B: MANAGEMENT AND PROCESS DISCLOSURES

Question Guidance

Policy and Management Processes

1 (a) Name the policy/policies that cover

each principle and its core elements of the Name the policy or policies that cover its Core
NGRBC Elements.

(b) Has the policy being approved by the

Select Yes or No, as the case may be, for each
Board?
principle
(c) Weblinks of policies Enter the link of the document containing the Policy
placed in the public domain..

2 Do the enlisted policies extend to your value Select Yes or No, as the case may be, for each
chain partners? principle.

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 3 Name of the national and international codes Under each principle, enter which national and
/ certifications /labels/ standards adopted by international code, certification, label or standard
your company and mapped to each principle which have been adopted by the company covering
the provisions of that Principle.

Governance, leadership and oversight

4. Details of Review of NGRBCs by the Select the frequency of review by each reviewing
Company: entity from the drop down menu:
(a) Performance against above policies and
– Board Committee
follow up action
– Any other Committee
(b) compliance with statutory requirements
of relevance to the principles and rectify any  Quarterly
non-compliances  Half-yearly
 Annually

Stakeholder Engagement

5. Process for identification of key In about 50 words, enter the criteria used and steps
stakeholders undertaken to identify stakeholders. If details are
available in the website, please provide the weblink.
6. Channels of Communication & Accessing Select the Tick boxes the applicable options.
Information (Email, SMS, Newspaper, Pamphlets, Advertisement,
Community Meetings, Notice Board, Website). In
case of any other medium please specify.
7. the Answer to question (1) above is “No” :
 The company does not consider the Princ Select Yes or No, as the case may be for each
material to its business (Yes/No) principle
 The company does not have the financia  Select Yes or No, as the case may be for each
or/human and technical resources availabl principle
task (Yes/No)
 Select Yes or No, as the case may be for each
 It is planned to be done in the next financ
principle
(Yes/No)

 Any other reason (please specify)  Enter the reason on the Text Box

SECTION C: PRINCIPLE WISE PERFORMANCE DISCLOSURE

The instructions for filling the Section C for each principle are detailed in the Guidance note. The questions under
the Essential indicators for each principle are mandatory, whereas the questions covered under the Leadership
indicators are voluntary to provide the Companies an opportunity for companies to present their impacts and
outcomes. Please refer to the detailed guidance as given in Section C for BRSR Comprehensive Format above.
Please refer the “Report of the Committee on Business Responsibility Reporting” for the whole reporting format. The
report is available at:

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http://www.mca.gov.in/Ministry/pdf/BRR_11082020.pdf

3.6. TEST YOUR UNDERSTANDING - MULTIPLE CHOICE QUESTIONS

Q1) Which of the following statements is true in respect of BRSR comprehensive format?
a) The format is mandatory for top listed companies specified by SEBI.
b) The BRSR comprehensive format is optional for all Companies
c) The Companies can select any of the two formats for reporting.
d) None of the above.

Q2) Which of the following not part of the General Disclosures in BRSR Lite format?
a) Holding, Subsidiary and Associate Companies (including joint ventures)
b) Transparency and Disclosure Compliances
c) CSR details
d) Operations

Q3) Which one of the following is a reporting requirement in Section B- Policy and Management Process?
a) Separate Policy covering each principle
b) Multiple policies covering one principle
c) Multiple principles covered by one policy
d) Any of the above.

Q4). Which of the following are mandatory under Principle wise Performance disclosures in Section C?
a) Leadership indicators
b) Profitability indicators
d) Essential indicators
e) All of the above

Q5). Which of the following is true about the awareness programmes conducted on the Principles for Value Chain
Partners?

a) This is covered under Leadership Indicator.

b) This is covered under Essential Indicator.
c) This is not required as a part of the BRSR reporting.
d) This can be reported as additional information.

Q6). Which of the following is true about BRSR reporting?

a) It is based on the NGRBC requirements.
b) It is based on the NVG framework
d) It is based on the Companies Act
e) None of the above

Q7). Which of the following is true with respect to Principle wise performance disclosures?
a) Essential indicators would be phased out in future

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b) Leadership indicators would gradually move to Essential indicators
c).None of the above

Q8). Which of the following is part of reporting on principle to protect and restore the environment?
a) Air emissions and liquid discharges
b) Energy and water consumed by the company
c) Solid waste management practices
d) All of the above

Q9.) Which of the following is the rationale for the reporting mechanisms to resolve grievances of the local
community?
a) To meet the CSR spending requirement
b) To ensure that there are no disputes which affect the continuity of business operations?
c) To promote inclusive growth and equitable development
d) None of the above

Q10) Why is the Life Cycle Assessment (LCA) for manufactured products important?
a) To ensure that the product meets customer satisfaction
b) To ensure that the product is free from manufacturing defects
c) To ensure that the product is sustainable at all stages of its lifecycle
d) All of the above

Answers: 1. A; 2. B; 3. D; 4. D; 5. A; 6. A; 7. B; 8. D; 9. C; 10. C.

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MODULE FOUR:
BRSR VIS-À-VIS GLOBAL FRAMEWORKS
OVERVIEW OF GRI AND IR FRAMEWORKS (GLOBAL)

4.1GRI – GLOBAL REPORTING INITIATIVE

GRI™ is an independent international organization that has been working on corporate sustainability reporting since 1997.
GRI’s mission is to empower decision-makers through its standards and network of stakeholders to enable a sustainable
economy and world. (https://www.globalreporting.org)
GRI is an independent body, which, in collaboration with the United Nations Environmental Protection Agency and
the United Nations Global Compact aids the production, on-going review and assessment of the GRI Standards.
The GRI Sustainability Reporting Standards (GRI Standards) comprises a group of modular reporting standards which are
available for adoption by any organization to report about its activities, initiatives and impacts on aspects related to
sustainability.
The GRI Standards are developed through a transparent, multi-stakeholder process and are issued by the Global
Sustainability Standards Board (GSSB), an independent standard-setting body created by GRI.

4.1.1 BACKGROUND TO GRI STANDARDS

GRI Standards provide an international, standardized language that businesses could use to report on their
business sustainability efforts, pertaining to disclosure of information relating to corporate impacts, both negative
and positive, on environmental, social and economic aspects.

The GRI Standards help businesses produce a sustainability report to facilitate assessment of business activities
and to work towards improvements in a more sustainable business, economy and the world.

The first draft of the Standards was released in 1997 followed by an enhanced revised version in 2000. This has
been updated with new releases of the Standards, the latest being the 2016 GRI Standards. These Standards
were developed by the United States-based non-profit group Ceres (Coalitions for Environmentally Responsible
Economies), a Boston Massachusetts based organization formed in 1989 , which has been working in the area of
Corporate Governance.

The GRI Standards are developed in accordance with international labor practices and environmental requirements, such
as, ISO 14000 series, which includes ISO 14010, IS0 14011, IS0 14012 and ISO 26000, set out guidelines for assessing
environmental impact, while OHSAS 18001 lays down a health and safety risk management system.

Many organizations in more than 90 countries currently use the GRI Standards to report sustainability information. The
GRI Standards are referred to in the policy or regulation in more than 40 countries and regions, and by more than 20 stock
exchanges around the world. The usage and adoption of the GRI standards is increasing rapidly with the increasing
awareness and importance of sustainability requirements.

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In addition, since December 2014, the European Commission Directive adopted a new obligation that large multinational
corporations should provide a non-financial disclosure to the markets. That is, it became law that public companies with
more than 500 employees should provide a report detailing environmental and social facets of business, using recognized
frameworks such as the GRI Standards.

GRI reporting enables disclosure of information in a systematic and standard manner which is easily quantifiable and
compared. The benefits of using a structured and standardized approach can lead to Improvements in sustainability
performance, risk management, stakeholder relations, employee engagement, benchmarking sustainability performance
and building credibility for an organization...
The full set of GRI Standards can be downloaded at www.globalreporting.org/standards.

4.1.2 GRI STANDARDS

GRI Standards are structured in a set of

interrelated modules that can be referenced and
used together.
There are three core modules, known as GRI’s 100
series. This GRI 100 series are universal standards
that apply to every organization aiming to develop
a sustainability report. The set of GRI Standards
includes:
- 3 Universal Standards that apply to every
organization preparing sustainability report
- 33 Topic-specific Standards (on e.g., water,
occupational health and safety, anti-corruption) for
reporting on material topics

Organizations can select and use the relevant

topic-specific Standards, based on
their material topics that reflect the reporting
organization’s significant economic, environmental,
and social impacts; or substantively influence the
assessments and decisions of stakeholders.
Organizations can select one of the following approaches to use GRI Standards:
1. Selected GRI Standards can be used, which might constitute a 'GRI-referenced' report
2. GRI Standards can be used as a set to prepare a sustainability report in accordance with the GRI Standards
(Core or Comprehensive option)

GRI Universal standards are as follows:

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  GRI Standards 101: Foundation
 GRI Standards 102: General Disclosures
 GRI Standards 103: Management Approach

Topic-specific Standards are as follows:

GRI 200: Economic

• GRI 201: Economic Performance 2016
• GRI 202: Market Presence 2016
• GRI 203: Indirect Economic Impacts 2016
• GRI 204: Procurement Practices 2016
• GRI 205: Anti-corruption 2016
• GRI 206: Anti-competitive Behavior 2016
• GRI 207: Tax 2019

GRI 300: Environmental

• GRI 301: Materials 2016
• GRI 302: Energy 2016
• GRI 303: Water and Effluents 2018
• GRI 304: Biodiversity 2016
• GRI 305: Emissions 2016
• GRI 306: Waste 2020
• GRI 307: Environmental Compliance 2016
• GRI 308: Supplier Environmental Assessment 2016

GRI 400: Social

 GRI 401: Employment 2016
 GRI 402: Labor/Management Relations 2016
 GRI 403: Occupational Health and Safety 2018
 GRI 404: Training and Education 2016
 GRI 405: Diversity and Equal Opportunity 2016
 GRI 406: Non-discrimination 2016
 GRI 407: Freedom of Association and Collective Bargaining 2016
 GRI 408: Child Labor 2016
 GRI 409: Forced or Compulsory Labor 2016
 GRI 410: Security Practices 2016
 GRI 411: Rights of Indigenous Peoples 2016
 GRI 412: Human Rights Assessment 2016
 GRI 413: Local Communities 2016
 GRI 414: Supplier Social Assessment 2016
 GRI 415: Public Policy 2016
 GRI 416: Customer Health and Safety 2016
 GRI 417: Marketing and Labeling 2016
 GRI 418: Customer Privacy 2016
 GRI 419: Socioeconomic Compliance 2016
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AllorganizationswhousetheGRIStandardsarerequiredtocomplywiththeUniversal
Standards;GRI101:Foundation2016,GRI102:GeneralDisclosures2016andGRI103: Management Approach 2016.
After referencing the Universal GRI Standards, an organization can then look at the topic-specific GRI Standards, to report
on what is known ‘Material Topics’. A material topic is a topic that reflects a reporting organization’s significant economic,
environmental and social impacts; or that substantively influences the assessments and decisions of stakeholders” (GRI
101: Foundation 2016, Key Terms)

4.1.3. GRI 101

GRI 101 serves as a starting point for using the GRI Standards. It sets out the Reporting Principles which all
reporting organizations are required to apply if they wish to claim their
sustainabilityreporthasbeenpreparedinaccordancewiththeGRIStandards.

The Reporting Principles also provide the organization with a basis for determining its material topics that reflect the
reporting organization’s significant economic, environmental, and social impacts or substantively influence the
assessments and decisions of stakeholders.

The GRI Reporting Principles listed below share characteristics with the suitable criteria defined in the AICPA
Attestation Standards: Objectivity, Measurability, Completeness and Relevance. GRI Standards can therefore be used
as a basis for suitable criteria in an assurance engagement.

GRI Reporting Principles for defining report content (see “Reporting Principles” within GRI 101: Foundation
2016for more detailed explanations.
GRI Reporting Principles for defining report GRI Reporting Principles for defining report
content quality

Stakeholder Inclusiveness Accuracy

Sustainability Context Balance

Materiality Clarity

Completeness Comparability

Reliability

Timeliness

4.1. 4 GRI 102

The GRI Standards include:

 Requirements: that is mandatory instructions.

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  Recommendations. These are cases where a particular course of action is encouraged, but not required.

 Guidance. These sections include background information, explanations and examples to help organizations
better understand the requirements.

GRI 102: GENERAL DISCLOSURES

ORGANISATIONAL PROFILE
102-1 Name of the organization
102-2 Activities. Primary brands, products, and services:
102-3 Location of organization's headquarters.
102-4 Location of operations
102-5 Ownership and legal form
102-6 Markets served
102-7 Scale of the organization
102-8 Information on employees and other workers
102-9 Supply chain
102-10 Significant changes to the organization and its supply chain
102-11 a. Whether and how the organization applies the Precautionary Principle or approach.
102-12 External initiatives
102-13 Membership of associations

STRATEGY
102-14 Statement from senior decision-maker
102-15 Key impacts, risks, and opportunities

ETHICS AND INTEGRITY

102-16 Values, principles, standards, and norms of behavior
102-17 Mechanisms for advice and concerns about ethics

GOVERNANCE
102-18 Governance structure
102-19 Delegating authority
102-20 Executive-level responsibility for economic, environmental, and social topics
102-21 Consulting stakeholders on economic, environmental, and social topics
102-22 Composition of the highest governance body and its committees
102-23 Chair of the highest governance body
102-24 Nominating and selecting the highest governance body
102-25 Conflicts of interest
102-26 Role of highest governance body in setting purpose, values, and strategy
102-27 Collective knowledge of highest governance body
102-28 Evaluating the highest governance body's performance
102-29 Identifying and managing economic, environmental, and social impacts

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102-30 Effectiveness of risk management processes
102-31 Review of economic, environmental, and social topics
102-32 Highest governance body's role in sustainability reporting
102-33 Communicating critical concerns.
102-34 Nature and total number of critical concerns
102-35 Remuneration policies
102-36 Process for determining remuneration
102-37 Stakeholders' involvement in remuneration
102-38 Annual total compensation ratio
102-39 Percentage increase in annual total compensation ratio

STAKEHOLDER ENGAGEMENT
102-40 List of stakeholder groups
102-41 Collective bargaining agreements
102-42 Identifying and selecting stakeholders
102-43 Approach to stakeholder engagement
102-44 Key topics and concerns raised
102-45 Entities included in the consolidated financial statements
102-46 Defining report content and topic Boundaries
102-47 List of material topics
102-48 Restatements of information
102-49 Changes in reporting
102-50 Reporting period
102-51 Date of most recent report
102-52 Reporting cycle
102-53 Contact point for questions regarding the report
102-54 Claims of reporting in accordance with the GRI Standards
102-55 GRI content index
102-56 External assurance

4.1.5 GRI 103: MANAGEMENT APPROACH

This Standard includes general requirements and disclosures for reporting the management approach for material topics.
These are set out in the Standard as follows:

• General requirements for reporting the management approach

• Disclosure 103-1 Explanation of the material topic and its Boundary
• Disclosure 103-2 The management approach and its components
• Disclosure 103-3 Evaluation of the management approach
Material topics are those that reflect an organization’s significant economic, environmental and social impacts; or that
substantively influence the assessments and decisions of stakeholders. The list of material topics is reported in Disclosure
102-47 of GRI 102: General Disclosures. For more information on identifying material topics, see GRI 101 : Foundation.
The explanation of why the topic is material can include:
• a description of the significant impacts identified and the reasonable expectations and interests of stakeholders

141
 regarding the topic;
• a description of the process, such as due diligence, that the organization used to identify the impacts related to the
topic.

The topic Boundary is the description of where the impacts for a material topic occur, and the organization’s involvement
with these impacts.

103-1 EXPLANATION OF THE MATERIAL TOPIC AND ITS BOUNDARY

For each material topic, the reporting organization shall report the following information:
a. An explanation of why the topic is material.

b. The Boundary for the material topic, which includes a description of:

i. where the impacts occur;

ii. the organization’s involvement with the impacts. For example, whether the
organization has caused or contributed to the impacts or is directly linked to
the impacts through its business relationships.
c. Any specific limitation regarding the topic Boundary
.

103-2 THE MANAGEMENT APPROACH AND ITS COMPONENTS

a. An explanation of how the organization manages the topic.
b. A statement of the purpose of the management approach.
c. A description of the following, if the management approach includes that component:
i. Policies
ii. Commitments
iii. Goals and targets
iv. Responsibilities
v. Resources
vi. Grievance mechanisms
vii. Specific actions, such as processes, projects, programs and initiatives

103-3: EVALUATION OF THE MANAGEMENT APPROACH

An explanation of how the organization evaluates the management approach, including:

i. the mechanisms for evaluating the effectiveness of the management approach;
ii. the results of the evaluation of the management approach;
iii. any related adjustments to the management approach.

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GRI 201: ECONOMIC PERFORMANCE 2016

201-1 Direct economic value generated and distributed

201-2 Financial implications and other risks and opportunities due to climate change

201-3 Defined benefit plan obligations and other retirement plans

201-4 Financial assistance received from government

GRI 202: MARKET PRESENCE 2016

202-1 Ratios of standard entry level wage by gender compared to local minimum wage

202-2 Proportion of senior management hired from the local community

GRI 203: INDIRECT ECONOMIC IMPACTS 2016

203-1 Infrastructure investments and services supported

203-2 Significant indirect economic impacts

GRI 204: PROCUREMENT PRACTICES 2016

204-1 Proportion of spending on local suppliers

GRI 205: ANTI-CORRUPTION 2016

205-1 Operations assessed for risks related to corruption

205-2 Communication and training about anti-corruption policies and procedures

205-3 Confirmed incidents of corruption and actions taken

GRI 206: ANTI-COMPETITIVE BEHAVIOR 2016

206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

GRI 207: TAX

207-1 Approach to tax

207-2 Tax governance, control and risk management

207-3 Stakeholder engagement and management concerns related to tax

207-4 Country-by-country reporting

4.1. 6 300 SERIES (ENVIRONMENTAL TOPICS)

GRI 301: MATERIALS 2016

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301-1 Materials used by weight or volume

301-2 Recycled input materials used

301-3 Reclaimed products and their packaging materials

GRI 302: ENERGY 2016

302-1 Energy consumption within the organization

302-2 Energy consumption outside of the organization

302-3 Energy intensity

302-4 Reduction of energy consumption

302-5 Reductions in energy requirements of products and services

GRI 303: WATER AND EFFLUENTS 2018

303-1 Interactions with water as a shared resource

303-2 Management of water discharge-related impacts

303-3 Water withdrawal

303-4 Water discharge

303-5 Water consumption

GRI 304: BIODIVERSITY 2016

304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value
outside protected areas

304-2 Significant impacts of activities, products, and services on biodiversity

304-3 Habitats protected or restored

304-4 IUCN Red List species and national conservation list species with habitats in areas affected by operations

GRI 305: EMISSIONS 2016

305-1 Direct (Scope 1) GHG emissions

305-2 Energy indirect (Scope 2) GHG emissions

305-3 Other indirect (Scope 3) GHG emissions

305-4 GHG emissions intensity

305-5 Reduction of GHG emissions

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305-6 Emissions of ozone-depleting substances (ODS)

305-7 Nitrogen oxides (NOX), sulfur oxides (SOX), and other significant air emissions

GRI 306: EFFLUENTS AND WASTE 2016

306-1 Waste generation and significant waste-related impacts

306-2 Management of significant waste-related impacts

306-3 Waste generated

306-4 Waste diverted from disposal

306-5 Waste directed to disposal

GRI 307: ENVIRONMENTAL COMPLIANCE 2016

307-1 Non-compliance with environmental laws and regulations

GRI 308: SUPPLIER ENVIRONMENTAL ASSESSMENT 2016

308-1 New suppliers that were screened using environmental criteria

308-2 Negative environmental impacts in the supply chain and actions taken

4.1.7 400 SERIES (SOCIAL TOPICS)

GRI 401: EMPLOYMENT 2016

401-1 New employee hires and employee turnover

401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees

401-3 Parental leave

GRI 402: LABOR/MANAGEMENT RELATIONS 2016

402-1 Minimum notice periods regarding operational changes

GRI 403: OCCUPATIONAL HEALTH AND SAFETY 2018

403-1 Occupational health and safety management system

403-2 Hazard identification, risk assessment, and incident investigation

403-3 OCCUPATIONAL HEALTH SERVICES

403-4 Worker participation, consultation, and communication on occupational health and safety

403-5 Worker training on occupational health and safety

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403-6 Promotion of worker health

403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

403-8 Workers covered by an occupational health and safety management system

403-9 Work-related injuries

403-10 Work-related ill health

GRI 404: TRAINING AND EDUCATION 2016

404-1 Average hours of training per year per employee

404-2 Programs for upgrading employee skills and transition assistance programs

404-3 Percentage of employees receiving regular performance and career development reviews

GRI 405: DIVERSITY AND EQUAL OPPORTUNITY 2016

405-1 Diversity of governance bodies and employees

405-2 Ratio of basic salary and remuneration of women to men

GRI 406: NON-DISCRIMINATION 2016

406-1 Incidents of discrimination and corrective actions taken

GRI 407: FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING 2016

407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk

GRI 408: CHILD LABOR 2016

408-1 Operations and suppliers at significant risk for incidents of child labor

GRI 409: FORCED OR COMPULSORY LABOR 2016

409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labor

GRI 410: SECURITY PRACTICES 2016

410-1 Security personnel trained in human rights policies or procedures

GRI 411: RIGHTS OF INDIGENOUS PEOPLES 2016

411-1 Incidents of violations involving rights of indigenous peoples

GRI 412: HUMAN RIGHTS ASSESSMENT 2016

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412-1 Operations that have been subject to human rights reviews or impact assessments

412-2 Employee training on human rights policies or procedures

412-3 Significant investment agreements and contracts that include human rights clauses or that underwent human
rights screening

GRI 413: LOCAL COMMUNITIES 2016

413-1 Operations with local community engagement, impact assessments, and development programs

413-2 Operations with significant actual and potential negative impacts on local communities

GRI 414: SUPPLIER SOCIAL ASSESSMENT 2016

414-1 New suppliers that were screened using social criteria

414-2 Negative social impacts in the supply chain and actions taken

GRI 415: PUBLIC POLICY 2016

415-1 Political contributions

GRI 416: CUSTOMER HEALTH AND SAFETY 2016

416-1 Assessment of the health and safety impacts of product and service categories

416-2 Incidents of non-compliance concerning the health and safety impacts of products and services

GRI 417: MARKETING AND LABELING 2016

417-1 Requirements for product and service information and labeling

417-2 Incidents of non-compliance concerning product and service information and labeling

417-3 Incidents of non-compliance concerning marketing communications

GRI 418: CUSTOMER PRIVACY 2016

418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data

GRI 419: SOCIOECONOMIC COMPLIANCE 2016

419-1 Non-compliance with laws and regulations in the social and economic area

4.2 INTEGRATED REPORTING FRAMEWORK

The Integrated Reporting Framework was released in 2013 by the IIRC after extensive consultation and testing by
businesses and investors throughout the world.

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4.2.1 OBJECTIVES OF THE INTEGRATED REPORTING FRAMEWORK

1) The Framework will underpin and accelerate the evolution of corporate reporting
2) It reflects developments in financial, governance, management commentary and sustainability reporting.
3) The benefits of the Framework are the enabling of informed decision-making that leads to efficient capital allocation
and the creation and preservation of value.
4) The Framework is intended as a guidance for all businesses producing integrated reports.
5) The Integrated framework reflects the wider range of factors and the long term impact of corporate decisions and
actions in creating value.

4.2.2 APPLICABILITY OF THE FRAMEWORK

This Framework is primarily in the context of private sector, for-profit companies of any size but it can also be applied,
adapted as necessary, by public sector and not-for-profit organizations.

4.2.3 REPORTING BOUNDARY

The boundary for an integrated report is wider in scope, including the financial reporting entity and the other
stakeholders. The financial reporting entity is determined according to the applicable financial reporting standards.
The scope of integrated reporting extends to looking beyond the financial entity, that is, other entities/stakeholders
beyond the financial reporting entity that have a significant effect on the ability of the financial reporting entity to create
value.

4.2.4 STRUCTURE OF THE INTEGRATED REPORTING FRAMEWORK

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 The Integrated Reporting Framework includes principles-based guidance, the Guiding Principles, and Content
Elements

A. GUIDING PRINCIPLES

1) Strategic focus: Insight into strategic objectives, and how those objectives relate to the organization’s ability to
create and sustain value over time and the resources and relationships on which the organization depends.
2) Connectivity of information: An Integrated Report shows the connections between the different components of
the organization’s business model, external factors that affect the organization, and the various resources and
relationships on which the organization and its overall performance depend.
3) Future orientation: An Integrated Report includes management’s expectations about the future, as well as other
information to help report users understand and assess the organization’s prospects and the uncertainties it
faces.
4) Responsiveness and stakeholder inclusiveness: An Integrated Report provides insight into the organization’s
relationships with its key stakeholders and how and to what extent the organization understands, takes into
account and responds to their needs.

5) Conciseness, reliability and materiality: An Integrated Report provides concise, reliable information that is
material to assessing the organization’s ability to create and sustain value in the short, medium and long term.

B. CONTENT ELEMENTS

1) Organizational overview and business model: What does the organization do and how does it create and
sustain value in the short, medium and long term?
2) Operating context, including risks and opportunities: What are the circumstances under which the
organization operates, including the key resources and relationships on which it depends and the key risks and
opportunities that it faces?
3) Strategic objectives and strategies to achieve those objectives: Where does the organization want to go and
how is it going to get there?
4) Governance and remuneration: What is the organization’s governance structure, and how does governance
support the strategic objectives of the organization and relate to the organization’s approach to remuneration?
5) Performance: How has the organization performed against its strategic objectives and related strategies?
6) Future outlook: What opportunities, challenges and uncertainties is the organization likely to encounter in
achieving its strategic objectives and what are the resulting implications for its strategies and future performance?

4.2.5 FEATURES OF THE INTEGRATED REPORTING FRAMEWORK:

1) This Framework is principles-based.
2) The framework aims to balance between flexibility and prescription to recognize uniqueness of an organization at
the same time serve as a comparable standard
3) It identifies information included in an integrated report for assessing the organization’s ability to create value
4) Primary focus of the framework is the private sector, but can also be applied to public sector and not-for-profit
organizations.
5) The Framework does not lay down specific key performance indicators (KPIs), measurement methods

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 6) Requires judgment to decide material matters, and the application of generally accepted measurement and
disclosure methods.
7) The information in the integrated report is prepared on the same basis as, or is easily reconcilable with other
published information.

4.2.6 FORM OF INTEGRATED REPORT

The integrated report is based on connectivity of information to communicate how value is created over time.

The integrated report could be:

1) Either a standalone report or be a part of another communication. The report should be distinguishable, a
designated, identifiable and be more than a summary in other communications
2) Prepared in response to existing compliance requirements.
3) Linked to a web based or paper based link to more detailed information

An integrated report should include a statement that includes:

1) An acknowledgement of the governing members’ responsibility to ensure the integrity of the report
2) An acknowledgement that they have applied their collective mind to the preparation and presentation of the
integrated report
3) Their opinion or conclusion about whether the integrated report is presented in accordance with this Framework
or, it should explain:
 What role those charged with governance played in its preparation and presentation
 What steps are being taken to include such a statement in future reports
 The time frame for doing so, which should be no later than the organization’s third integrated report that
references this Framework.

4.2.7 TYPES OF CAPITAL AND VALUE CREATION

All organizations depend on various forms of capital for their activities and performance. The capitals are stocks of value
that increase, decrease or get transformed through the activities and outputs of the organization.

For example, an organization’s financial capital is increased when it makes a profit, and the intellectual capital increases
when the organization obtains a patent or copyright.

4.2.8 SIX TYPES OF CAPITAL

The Integrated Reporting Framework has categorized the capitals under six types:

1) Financial Capital
2) Manufactured Capital
3) Intellectual Capital
4) Human Capital
5) Social and relationship capital
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 6) Natural capital

4.2.9 INTEGRATED REPORT AND THE FLOW OF CAPITALS

1) An integrated report provides information on the resources and relationships with respect to an organization –
referred to as “the capitals”

2) The report lays out the interaction with the external environment and the capitals, to create value over the short,
medium and long term.

3) The ability of an organization to create value for itself enables financial returns to the owners of financial capital.
This is connected with the value the organization creates for stakeholders and society at large through its
activities, interactions and relationships. The factors that are material to the organization's ability to create value
for itself are included in the integrated report.

4) The actions of an organization can involve the increase or a decrease in the value stored in some capitals,
resulting in a net increase or a decrease to the overall stock of capitals.

5) The overall stock of capitals is not fixed, but constantly flows or changes from one type to another capital, as an
increase, decrease or a transformation from one type of capital to another. For example, when an organization
spends money on research and development, R & D costs reduce its financial capital. The impact is that financial
capital gets transformed into intellectual capital.

4.3 MAPPING OF BRSR WITH GRI AND IR FRAMEWORKS

BRSR GRI

SECTION A: GENERAL DISCLOSURES

Not covered.
1. Corporate Identity Number (CIN) of the Company (if
applicable):
GRI 102: General Disclosures
2. Name of the Company: Disclosure 102-1
Name of the organization
Not covered.
3. Year of incorporation:
GRI 102: General Disclosures
4. Registered office address: Disclosure 102-3
Location of the headquarters
5. Corporate address:
GRI 102: General Disclosures
6. E-mail: Disclosure 102-53
Contact point for questions regarding the report
7. Telephone:
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 Not covered by the GRI Standards.
8. Website:
GRI 102: General Disclosures
9. Financial year for which reporting is being done: Disclosure 102-50
Reporting period

Not covered
10. Whether shares listed on recognized Stock 102-5. The reporting organization shall report the
Exchange(s): Yes/No following information:
a. Nature of ownership and legal form.
GRI 102: General Disclosures
11. Authorized Capital Disclosure 102-7 (a-iv)
Scale of the organization
12. Paid-up Capital a. Scale of the organization, including:
iv. total capitalization (for private sector
organizations) broken down in terms of debt and
equity;
GRI 102: General Disclosures
13. Sector(s) in which the company is engaged: Disclosure 102-6 (ii)
a. sectors served;

GRI 102: General Disclosures

14. Top 3 Products/Services sold by the company by Disclosure 102-2 (b)
Turnover (including both manufactured and traded) Activities, brands, products and services
b. Primary brands, products, and services, including
an explanation of any products or services that are
banned in certain markets.

GRI 102: General Disclosures

15. What is the contribution of exports to total turnover of Disclosure 102-7 (a-iii)
the Company in percentage Scale of the organization
a. Scale of the organization, including:
iii. net sales (for private sector organizations) or net
revenues (for public sector organizations);

GRI 102: General Disclosures

16. Number of locations where plants (in case of Disclosure 102-4
manufacturing businesses) and/or operations/offices Location of operations

17. Location of top 3 plants (in case of manufacturing

businesses) or operations/offices (in case of non-
manufacturing) in India by contribution to turnover:

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 GRI 102: General Disclosures
18. Markets served by the Company: Disclosure 102-6
. Markets served
a. National (No. of States) i. geographic locations where products and services
International (No. of Countries) are offered;
b. Location of top 3 Markets by contribution to Turnover: ii. sectors served;
iii. types of customers and beneficiaries
102-7. The reporting organization shall report the
19. Details as at the end of Financial Year: following information:
Employees (including differently abled): a. Scale of the organization, including:
Male (%) Female (%) Other (%) i. total number of employees;
1. Permanent GRI 102: General Disclosures
2 Other than Permanent Disclosure 102-8 (a and b) Information on employees
3.Differently abled Employees: and other workers
a. Total number of employees by employment
contract (permanent and temporary), by gender.
b. Total number of employees by employment
contract (permanent and temporary), by regional
Disclosures GRI
405: Diversity and Equal Opportunity
Disclosure 405-1 (b-iii)
b. Percentage of employees per employee category
in each of the following diversity categories:
iii. Other indicators of diversity where relevant (such
as minority or vulnerable groups).
GRI 405: Diversity and Equal Opportunity
20. Participation/Inclusion/Representation of women Disclosure 405-1 (b-iii)
(including differently abled): b. Percentage of employees per employee category
Total number of persons (including differently abled) in each of the following diversity categories:
comprising the Board of Directors and Key Management iii. Other indicators of diversity where relevant (such
Personnel as per the Companies Act, 2013. as minority or vulnerable groups).

GRI 102: General Disclosures

21. (a) Names of subsidiary / associate companies, CIN Disclosure 102-45 (b)
number, type and % age of shares. Does the company Entities included in the consolidated financial
participate in the Business Responsibility initiatives of the statements
parent company? b. Whether any entity included in the organization’s
(b) Do any other entity/entities (e.g. suppliers, distributors consolidated financial statements or equivalent
etc.) that the Company does business with: participate in documents is not covered by the report.
the BR initiatives of the Company

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Not covered GRI 201: Economic Performance
Disclosure 201-1 (a-iii)
Direct economic value generated and distributed
a. Direct economic value generated and distributed
(EVG&D) on an accruals basis, including the basic
components for the organization’s global operations as
listed below. If data are presented on a cash basis,
report the justification for this decision in addition to
reporting the following basic components:
iii. Economic value retained: ‘direct economic value
generated’ less ‘economic value distributed’.
GRI 103: Management Approach
22. (a) (i) Whether CSR is applicable as per section 135: Disclosure 103-2 (c-v)
The management approach and its components
23. Average net profit of the company for last three c. A description of the following, if the management
financial years (as defined in explanation to sub-section approach includes that component.
(5) section 135 of the Act (in Rs.) v. Resources
GRI 413-1 Operations with local community
24. Prescribed CSR Expenditure (two per cent. of the engagement, impact assessments, and development
amount as in item 23 above) programs
The reporting organization shall report the following
25. (a) Total amount spent on CSR for the financial year information:
(in Rs.) a. Percentage of operations with implemented local
community engagement, impact assessments, and/or
26. Details of Implementing Agency(ies): development programs, including the use of:
i. social impact assessments, including gender impact
27. Whether a responsibility statement of the CSR assessments, based on participatory processes;
Committee on the implementation and monitoring of CSR ii. environmental impact assessments and ongoing
Policy is enclosed to the Board’s Report monitoring;
iii. public disclosure of results of environmental and
28. Link to CSR Policy social impact assessments;
iv. local community development programs based on
local communities’ needs;
v. stakeholder engagement plans based on
stakeholder mapping;
vi. broad based local community consultation
committees and processes that include vulnerable
groups;
vii. works councils, occupational health and safety
committees and other worker representation bodies to
deal with impacts;
viii. formal local community grievance processes.
GRI 102: General Disclosures
29. Complaints/Grievances on any aspect of the National Disclosure 102-16
Guidelines on Responsible Business Conduct in the Values, principles, standards and norms of behavior
financial year GRI 103: Management Approach, to be used together
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 with GRI 205: Anti- corruption
30. Overview of the company’s high priority responsible Disclosure 103-2
business conduct issues. The management approach and its components
c. A description of the following, if the management
approach includes that component: i. Policies

155
SECTION B: MANAGEMENT AND PROCESS DISCLOSURES
Disclosure 102-43
1. Approach to stakeholder engagement
a. Name your company’s policy/policies that cover each Disclosure 102-55 (b-ii)
principle and its core elements of the NGRBCs. GRI content index
b. Has the policy been approved by the Board? b. For each disclosure, the content index shall
c. Web Link of the Policies include:
ii. the page number(s) or URL(s) where the
2. Whether the company has translated the policy into information can be found, either within the report or in
procedures. other published materials;
GRI 103: Management Approach
3. Do the enlisted policies extend to your value chain General requirements for reporting the
partners? management approach
1.2 If there is no management approach for a material
4. Name of the national and international topic, the reporting organization shall describe:
codes/certifications/labels/ standards (e.g. Forest 1.2.1 any plans to implement a management
Stewardship Council, Fairtrade, Rainforest Alliance, approach; or
Trustee) standards (e.g. SA 8000, OHSAS, ISO, BIS) 1.2.2 the reasons for not having a management
adopted by your company and mapped to each principle approach.
Disclosure 103-2 (c-i and c-vi) The management
approach and its components
c. A description of the following, if the management
approach includes that component:
i. Policies
vi. Grievance mechanisms
Disclosure 103-3
Evaluation of the management approach
a. An explanation of how the organization evaluates
the management approach, including:
i. the mechanisms for evaluating the effectiveness of
the management approach;
GRI 102: General Disclosures
5. Details of the Director responsible for implementation of Disclosure 102-20
the Business Responsibility policy (ies) Executive-level responsibility for economic,
No. of Directors: 1. DIN Number 2. Name 3. Designation environmental, and social topics
GRI 102: General Disclosures
6. Does the company have a specified committee of the Disclosure 102-18 (b)
Board/ Directors/ Officials to oversee the implementation Governance structure
of the policy? (Yes/No) If yes, please indicate the b. Committees responsible for decision- making on
composition. economic, environmental, and social topics.
Disclosure 102-26
Role of the highest governance body in setting
purpose, values, and strategy

156
 GRI 102: General Disclosures
7. Details of Review of NGRBCs by the Company Disclosure 102-31
Review of economic, environmental, and social topics
Disclosure 102-52
Reporting cycle
GRI 101: Foundation
8. Has the company carried out independent assessment/ Stakeholder Inclusiveness principle
evaluation of the working of this policy by an internal or 1.1 The reporting organization shall identify its
external agency? stakeholders, and explain how it
Stakeholder Engagement has responded to their reasonable expectations and
interests.
9. Describe the process of identifying key stakeholder GRI 102: General Disclosures
groups of the company Disclosure 102-40
List of stakeholder groups
10. Mention the channels to communicate to Disclosure 102-42
stakeholders, features of your policies, procedures, Identifying and selecting stakeholders
decisions and performance that impact them and details
and outcomes of its stakeholder engagement

11 Channels of Communication & Accessing Information

12 If answer to question (1) above is “No” i.e. not all

Principles are covered by a policy, reasons to be stated

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SECTION C: PRINCIPLE WISE PERFORMANCE DISCLOSURE

PRINCIPLE 1: BUSINESSES SHOULD CONDUCT AND GOVERN THEMSELVES WITH INTEGRITY,

AND IN A MANNER THAT IS ETHICAL, TRANSPARENT, AND ACCOUNTABLE

Essential Indicators GRI 102: General Disclosures

1. Percentage Coverage by training and awareness Disclosure 102-16
programmes on the Principles in the financial year Values, principles, standards and norms of behavior
GRI 103: Management Approach, to be used
2. Number of meetings/ dialogues organized on together with GRI 205: Anti- corruption
responsible business conduct with shareholders Disclosure 103-2
The management approach and its components
3. Details of fines and penalties imposed, imprisonment c. A description of the following, if the management
and punishment awarded; appeals/ revisions filed approach includes that component:
i. Policies GRI 102: General Disclosures
4 Details of the Appeal/ Revision preferred in cases where Disclosure 102-17
fines/ penalties have been impugned. Mechanisms for advice and concerns about ethics
Disclosure 102-44
5 Number of complaints / cases of bribery/corruption Key topics and concerns raised
registered with law enforcement agencies against the
business

6.Details of disclosure of interest involving members of

Board:

Leadership indicators:
1 Percentage Coverage by awareness programmes on
the Principles in the current financial year

Enter the total number of awareness programmes

conducted on the Principles under NGRBC for Value
Chain Partners and the percentage of such partners
covered by awareness programmes in the current
financial year.

2. Have full details of non-disputed fines/penalties

imposed on your business by regulatory and judicial
bodies in the year been made available in public domain
Disclose whether or not non-disputed fines/penalties
imposed on business by regulatory and judicial institutions
have been placed in public domain or not.

3 Provide details of such instances (up to 3) where

corrective actions

4. Provide details of such instances (up to 3) where

158
corrective actions were taken on the complaints / cases of
corruption and conflicts of interest.

5. Does the company have a Business Continuity &

Disaster Management plan? Give details.

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PRINCIPLE 2: BUSINESSES SHOULD PROVIDE GOODS AND SERVICES IN A MANNER THAT IS
SUSTAINABLE AND SAFE.
Essential Indicators GRI 102: General Disclosures
1. Has the company Disclosure 102-2 (b)
conducted Life Cycle Activities, brands, products, and services
Assessments (LCA) b. Primary brands, products, and services, including an explanation of any products or services
for any or all of its top that are banned in certain markets.
3 brands/ products
manufactured? NIC
Code* Product
/Service % of total
Turnover contributed
Life Cycle
Assessment
conducted in the
Current Financial
Year Whether
conducted by
independent external
agency, Results
communicated in
public domain

2. List 3 of your
products or services
whose design has
incorporated social or
environmental
concerns and/or risks
and briefly describe
the actions taken to
mitigate the adverse
environmental and
social impacts in
production and
disposal as identified
in the LCA or any
other means.

3. Percentage of R&D
and capital
expenditure (capex)
investments in
specific technologies
to improve the
environmental and
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social impacts of
product and
processes to total
R&D and capex
investments made by
the company,
respectively.

GRI 103: Management Approach, used together with GRI 204: Procurement Practices
4. a. Does the Disclosure 103-2
company have The management approach and its components
procedures in place c. A description of the following, if the management approach includes that component:
for sustainable i. Policies
sourcing? GRI 204: Procurement Practices
b. If yes, what Disclosure 204-1
percentage of your Proportion of spending on local suppliers
inputs was sourced
sustainably?

5. Percentage of
input material (by
value of all inputs) to
total inputs sourced
from suppliers: (%
input)
6. Describe the GRI 301: Materials
processes in place to Disclosure 301-2
safely collect, reuse, Recycled input materials used
recycle and dispose
after sale and at the GRI 303: Water
end of life of your Disclosure 303-3
products, separately Water recycled and reused
for (a) Plastics
(including packaging)
(b) E-waste and (c)
other waste
GRI 103: Management Approach, used together with GRI 204: Procurement Practices
Leadership Indicators Disclosure 103-2
2. Do you have a The management approach and its components
preferential
procurement policy
where you give
preference to
purchase from
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suppliers comprising
marginal/vulnerable
groups? (Yes/No)
(Radio Button) From
which
marginal/vulnerable
groups do you
procure? (Drop Down
List from NGRBC list)
What percentage of
total procurement (by
value) does it
constitute? (% input)

3. Information on the
impact of your
products has been
GRI 103: Management Approach, used together with:
1. Describe the • GRI 301: Materials
improvements in • GRI 306: Effluents and Waste
environmental and Disclosure 103-2
social impacts of The management approach and its components
product and GRI 301: Materials
processes due to Disclosure 301-3 (a)
R&D and Capex Reclaimed products and their packaging materials
Investments in a. Percentage of reclaimed products and their packaging materials for each product category.
specific technologies. GRI 306: Effluents and Waste
Disclosure 306-2
3. Information on the Waste by type and disposal method
impact of your a. Total weight of hazardous waste, with a breakdown by the following disposal methods where
products has been applicable: i. Reuse
communicated to: ii. Recycling
Stakeholder Group, b. Total weight of non-hazardous waste, with a breakdown by the following disposal methods
Channels of where applicable:
communication, ii. Recycling
Frequency

4. Provide details of
at least three
instances on how the
feedback received
from stakeholders
was used for
improvements or
modifications in the
company’s existing
162
policies and
practices.

5. Percentage of
recycled or reused
input material to total
raw material (by
value) used in
production:

6. Provide separate
details of quantities
collected for reuse,
recycling, safe
disposal after sale,
and at end of life of
your products
PRINCIPLE 3: BUSINESSES SHOULD RESPECT AND PROMOTE THE WELL-BEING OF ALL EMPLOYEES,
INCLUDING THOSE IN THEIR VALUE CHAINS.
Essential Indicators GRI 407: Freedom of Association and Collective Bargaining
5. Percentage of Management approach disclosures
membership of 1.2 The reporting organization should describe any policy or policies considered likely to affect
employees and workers’ decisions to form or join a trade union, to bargain collectively or to engage in trade union
workmen in activities.
association(s) or
Unions recognised by
the Board
GRI 102: General Disclosures
1. Businesses Disclosure 102-16 & 102-17
should respect and  How stakeholders’ views are sought and taken into account regarding remuneration. If
promote the well- applicable, the results of votes on remuneration policies and proposals.
being of all  Process for determining remuneration.
employees,  Whetherremunerationconsultantsareinvolvedindeterminingremunerationandwheth
including those in er they are independent of management.
their value chains  Anyotherrelationshipsthattheremunerationconsultantshavewiththeorganization.

2. Details of
statutory dues (PF,
Gratuity, ESI)
deducted and
deposited with the
authorities
approved by
government, for
Current FY and

163
Previous Financial
Year.

6. Assessments for
the year:

7. a. Details of
employees and
workmen in terms of
minimum wages
paid:

b. Details of
differently abled
employees and
workmen in terms of
minimum wages
paid:
GRI 103: Management Approach, used together with:
8. Details of safety • GRI 410: Security Practices
related incidents
during the current
Financial Year

Leadership GRI 103: Management Approach, to be used together with:

Indicators • GRI 406: Non-discrimination
1. Provide the • GRI 408: Child Labor
measures • GRI 409: Forced or Compulsory Labor
undertaken by the
company to ensure
that statutory dues
have been
deducted and
deposited by the
value chain
partners.

2. Provide the
corrective actions
taken for
children/adolescent
s identified as
employed in your
establishments and
value chain.

164
3. Provide the
corrective actions
taken for
forced/involuntary
labour identified in
your establishments
and value chain.

4. Provide the
actions taken to
prevent adverse
consequences to
the complainant in
discrimination and
harassment cases.

5. Provide the
corrective actions
taken on the
outcomes of health
and safety audits of
your
establishments,
including value
chain partners.
(Text Box)

6. Percentage of
accident-affected
employees/workme
n rehabilitated and
placed in suitable
employment. (Text
Box)

7. Details on
assessment of
value chain
partners:
% of value chain
partners (by value
of business done
with such partners)
that were assessed
8. Details of safety
related incidents 10
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Describe the
measures taken by
the company to
ensure a safe work
place

3. Is there a Disclosure 103-2 (c-vi)

mechanism available c. A description of the following, if the management approach includes that component:
to receive and vi. Grievance mechanisms
redress grievances GRI 406: Non-discrimination
for the following Disclosure 406-1 (a) Incidents of discrimination and corrective actions taken
categories of a. Total number of incidents of discrimination during the reporting period.
employees and
workmen? If yes,
please name the
mechanism.

4. Number of
Complaints made by
employees and
workmen: :
9. a. Details of GRI 404: Training and Education
training to employees Disclosure 404-2 (a)
and workmen (% to Programs for upgrading employee skills and transition assistance programs
total no. of a. Type and scope of programs implemented and assistance provided to upgrade employee
employees/workmen skills.
in the category): b. Disclosure 404-3
Details of training Percentage of employees receiving regular performance and career development reviews
imparted to the
differently abled
employees and
workmen (% to total
no. of differently
abled
employees/workmen
in the category):

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PRINCIPLE 4: BUSINESSES SHOULD RESPECT THE INTERESTS OF AND BE RESPONSIVE TO ALL
ITS STAKEHOLDERS.
Essential Indicators GRI 101: Foundation
1. List stakeholder groups identified as key for your Stakeholder Inclusiveness principle
company as described in Section B, Q. 9, and the 1.1 The reporting organization shall identify its
frequency of engagement with each stakeholder group. stakeholders, and explain how it
has responded to their reasonable expectations and
interests.
GRI 102: General Disclosures
Disclosure 102-40
List of stakeholder groups
Disclosure 102-42
Identifying and selecting stakeholders
Leadership Indicators GRI 101: Foundation
Stakeholder Inclusiveness principle
1. Provide details of instances of engagement with, and 1.1 The reporting organization shall identify its
actions taken to, address the concerns of stakeholders, and explain how it
vulnerable/marginalised stakeholder groups. has responded to their reasonable expectations and
interests.
GRI 102: General Disclosures
Disclosure 102-40
List of stakeholder groups
Disclosure 102-42
Identifying and selecting stakeholders
2. Provide details of 3 instances as to how the inputs GRI 102: General Disclosures
received from stakeholders were incorporated into policies Disclosure 102-43
and activities of the company. Approach to stakeholder engagement
GRI 103: Management Approach, used together
with:
• GRI 411: Rights of Indigenous Peoples
• GRI 413: Local Communities
Disclosure 103-2 (c-vii)
c. A description of the following, if the management
approach includes that component:
vii. Specific actions, such as processes, projects,
programs and initiatives
GRI 413: Local Communities
Disclosure 413-1 (a-vi)
Operations with local community engagement, impact
assessments, and development programs
a. Percentage of operations with implemented local
community engagement, impact assessments, and/ or
development programs, including the use of:
vi. broad based local community consultation
committees and processes that include vulnerable
groups;
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PRINCIPLE 5: BUSINESSES SOULD RESPECT AND PROMOTE HUMAN RIGHTS.
Essential Indicators GRI 103: Management Approach, used together
1. a. Percentage of employees and workmen that have with:
been provided training on human rights issues and • GRI 406: Non-discrimination
policy(ies) of the company in the Financial Year:b. • GRI 407: Freedom of Association and
Percentage of differently abled employees and workmen Collective Bargaining
that have been provided training on human rights issues • GRI 408: Child Labor
and policy(ies) of the company in the Financial Year: • GRI 409: Forced or Compulsory Labor
• GRI 410: Security Practices
2. a. Details of remuneration/salary/wages (including • GRI 411: Rights of Indigenous Peoples
differently abled): b. Details of remuneration/salary/wages • GRI 412: Human Rights Assessment
of differently abled: Do you have a focal point (Individual/ Disclosure 103-2 (c-i)
Committee) responsible for addressing human rights The management approach and its components
impacts or issues caused or contributed to by the c. A description of the following, if the management
business? (Yes/No) approach includes that component:
i. Policies

PRINCIPLE 6: BUSINESSES SHOULD RESPECT AND MAKE EFFORTS TO PROTECT AND RESTORE THE
ENVIRONMENT.
Essential Indicators GRI 103: Management Approach, to be used
1. Does the company have strategies/ initiatives to together with:
address global environmental issues such as climate • GRI 301: Materials
change resource scarcity, health pandemics and • GRI 302: Energy
emergencies, natural disasters etc.? If Yes, provide • GRI 303: Water
details. (Yes/No) • GRI 304: Biodiversity
• GRI 305: Emissions
2. Does the company have any project related to Low • GRI 306: Effluents and Waste
Carbon Economy? If Yes, provide details. (Yes/No) • GRI 308: Supplier Environmental Assessment
Disclosure 103-2 (c-i)
3. Have the emissions/waste generated by the company c. A description of the following, if the management
exceeded the limits prescribed under the relevant approach includes that component:
environmental laws? If Yes, provide details. i. Policies
GRI 102: General Disclosures
4. Details of environmental impact assessments of Disclosure 102-14
projects undertaken by the company: Statement from senior decision-maker
Disclosure 102-15
5. What are the material environmental risks to the Key impacts, risks, and opportunities
business identified and the mitigation measures adopted GRI 103: Management Approach, used together with
by the company with regard to the following: GRI Standards in the 300 series (Environmental
topics)
6. Details of energy and water consumption by the Disclosure 103-2 (c-vii)
company: c. A description of the following, if the management
approach includes that component:
7. Air emissions and liquid discharges per unit of vii. Specific actions, such as processes, projects,
production for the 3 major facilities of the company programs and initiatives
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(Section A, Q17) as reported to regulatory authorities8. GRI 201: Economic Performance
What is the % of solid waste generated that is recycled Disclosure 201-2
and sent to the landfill? Financial implications and other risks and
opportunities due to climate change

Leadership Indicators GRI 102: General Disclosures

1. Carbon emitted per unit of production and Disclosure 102-15
revenue/turnover for each major product manufactured by Key impacts, risks, and opportunities
the company: GRI 103: Management Approach, used together with
GRI Standards in the 300 series (Environmental
2. Percentage of renewable energy consumed to total topics)
energy consumed: Disclosure 103-2 (c-vii)
c. A description of the following, if the management
3. Provide details of solid waste management relating to approach includes that component:
the following aspects: vii. Specific actions, such as processes, projects,
programs and initiatives
4. Briefly describe the solid waste management practices GRI 201: Economic Performance
adopted in your establishments. Disclosure 201-2
Financial implications and other risks and
5. Briefly describe the strategy adopted by your company opportunities due to climate change
to reduce usage of hazardous and toxic chemicals in your
products and processes and the practices adopted to
manage such wastes.

6. List innovative technologies, solutions and initiatives

undertaken resulting in lower environment footprint
adopted by the company, if any.

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Principle 7: BUSINESSES, WHEN ENGAGING IN INFLUENCING PUBLIC AND REGULATORY POLICY,
SHOULD DO SO IN A MANNER THAT IS RESPONSIBLE AND TRANSPARENT.
Essential Indicators GRI 102: General Disclosures
1. a. Number of affiliations with trade and industry Disclosure 102-13
chambers/ associations. Membership of associations
b. List the top 10 trade and industry chambers/
associations you are a member of/are affiliated to, on the
basis of no. of members2. Details of adverse judicial or
regulatory orders for anti-competitive conduct by your
company in the current Financial Year
GRI 415: Public Policy
Leadership Indicators Management approach disclosures
1. Details of public policy positions advocated by the 1.2 The reporting organization should report:
company 1.2.1 the significant issues that are the focus of its
participation in public policy development and
2. Details of corrective action for anti-competitive conduct lobbying;
by the company taken based on adverse orders from
regulatory authorities. (Ref. Q 2 in Essential Indicators)

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Principle 8: BUSINESSES SHOULD PROMOTE INCLUSIVE GROWTH AND EQUITABLE DEVELOPMENT.
Essential Indicators GRI 103: Management Approach, to be used
1. Details of Social Impact Assessments (SIA) undertaken together with:
by the company for projects in the current Financial • GRI 203: Indirect Economic Impacts
Year.? • GRI 413: Local Communities
Disclosure 103-2 (c-vii)
6. List of adverse orders and case details of intellectual The management approach and its components
property rights disputes related to traditional knowledge c. A description of the following, if the management
during the FY. approach includes that component:
vii. Specific actions, such as processes, projects,
programs and initiatives
2. Information on project(s) for which ongoing GRI 201: Economic Performance
Rehabilitation and Resettlement is being undertaken by Disclosure 201-1 (a-ii)
your company. Direct economic value generated and distributed
a. Direct economic value generated and distributed
3. Provide the following information on CSR projects (EVG&D) on an accruals basis, including the basic
undertaken by your company in designated aspirational components for the organization’s global operations as
districts as identified by government bodies listed below. If data are presented on a cash basis,
report the justification for this decision in addition to
4. Describe the mechanisms to receive and redress reporting the following basic components:
grievances of the community. ii. Economic value distributed: operating costs,
employee wages and benefits, payments to providers
5. Have the benefits derived of the various intellectual of capital, payments to government by country, and
properties owned or acquired by your company based on community investments;
traditional knowledge been shared equitably. GRI 203: Indirect Economic Impacts
Disclosure 203-1
Infrastructure investments and services supported
Leadership Indicators GRI 103: Management Approach, to be used
1. Provide details of actions taken to mitigate any negative together with:
social impacts identified in the Social Impact • GRI 203: Indirect Economic Impacts
Assessments. Details of negative social impact • GRI 413: Local Communities
2. Details of the benefits derived of the various intellectual Disclosure 103-2 (a)
properties owned or acquired by your company based on The management approach and its components
traditional knowledge shared a. An explanation of how the organization manages
3. Details of corrective actions taken in intellectual the topic. GRI 413: Local
property related cases wherein usage of traditional Communities
knowledge is involved. Disclosure 413-1 (a-i and a-ii) Operations with local
4. Details of beneficiaries of CSR Projects: community engagement, impact assessments, and
development programs
a. Percentage of operations with implemented local
community engagement, impact assessments, and/ or
development programs, including the use of:
i. social impact assessments, including gender
impact assessments, based on participatory
processes;
ii. environmental impact assessments and ongoing
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 monitoring;

Principle 9: BUSINESSES SHOULD ENGAGE WITH AND PROVIDE VALUE TO THEIR CONSUMERS IN A
RESPONSIBLE MANNER.
Essential Indicators GRI 103: Management Approach, used together
1. Describe the mechanisms in place to receive and with:
respond to consumer complaints and feedback. • GRI 416: Customer Health and Safety
• GRI 417: Marketing and Labeling
2. % of products and services (by turnover) of your • GRI 418: Customer Privacy
business carrying information about 3. Number of • GRI 419: Socioeconomic Compliance
consumer complaints Disclosure 103-2 (c-vi)
c. A description of the following, if the management
approach includes that component:
vi. Grievance mechanisms
Leadership Indicators GRI 103: Management Approach, used together with
1. Channels / platforms where information on products GRI 417: Marketing and Labeling
and services of the company can be accessed (provide Disclosure 103-2 (c-ii)
web link if applicable). c. A description of the following, if the management
approach includes that component:
2. Steps taken to inform and educate consumers, ii. Commitments
especially vulnerable and marginalised consumers, about GRI 417: Marketing and Labeling
safe and responsible usage of products and services. Disclosure 417-1
Requirements for product and service information and
5. Does the company display product information on the labeling
product over and above what is mandated as per local
laws? (Yes/No/Not Applicable) (Additional information)

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 GRI 206: Anti-competitive Behavior
3. Corrective actions taken in respect of complaints Disclosure 206-1
received on data privacy, advertising, and delivery of Legal actions for anti-competitive behavior, anti-trust,
essential services. and monopoly practices
GRI 417: Marketing and Labeling
4. Mechanisms in place to inform consumers of any risk of Disclosure 417-2
disruption/discontinuation of essential service Incidents of non-compliance concerning product and
service information and labeling
Disclosure 417-3
Incidents of non-compliance concerning marketing
communications
6. Did your company carry out any consumer survey? GRI 102: General Disclosures
Give Details. Disclosure 102-43
Approach to stakeholder engagement

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4.4 MAPPING OF GRI AND IR FRAMEWORKS

IR content GRI Standard

Organizational overview, Company information GRI 102-1,3,5

Principle activities and revenue streams, Products and Markets GRI 102-2
Products and Markets GRI 102-4,6,7
Business Model: Inputs - Human Capital GRI 102-8
Business Model: Inputs – Social and Relationship
Capital, Social and Relationship Capital - Suppliers GRI 102-9
Corporate Sustainability,
Details of the Directors GRI 102-12,13
Strategy, Risk and Opportunities GRI 102-15
Progressing with integrity GRI 102-16,17
Corporate Governance Report GRI 102 – (18-34)

Board Evaluation, Remuneration Policy for Board and Senior

Management, Particulars of Remuneration GRI 102 – (35-39)
Stakeholder Engagement GRI 102 -

Particulars of Holding, Subsidiary and Associate Companies GRI 102-45

Material Issues GRI 102-47
Name, designation & address of Compliance Officer GRI 102-53
External Assurance GRI 102-56
Corporate Governance Report, Board of Directors, Corporate
sustainability
Corporate sustainability GRI 102-(18-34)
Occupational Health and Safety GRI 102-21
Particulars Of Remuneration GRI 102-35-39
Strategy, Corporate sustainability GRI 103-1,2,3
Statement of Profit and Loss GRI 201-1
Risks and opportunities, Natural Capital GRI 201-2
Employee benefits expense, Employee benefits,
Retirement benefit obligations GRI 201-3
Annual Report on Corporate Social Responsibility Activities;
Communities, Business Model - Social and GRI 203
Relationship Capital
Social and Relationship Capital – Suppliers, Business Model –
Inputs Social and Relationship Capital GRI 204

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4.5 SUSTAINABLE FINANCE

In the past decade, forms of sustainable finance have grown substantially due to an increasing demand by institutional
and retail investors to better reflect sustainability issues in their investment choices. In particular, the use of
environmental, social and governance (ESG) investment approaches has been driven by increased investor demand to
make better use of non-financial information to guide asset allocation decisions to improve long-term value, while also
better aligning portfolios with societal values. In this respect, growing concerns over the impact of climate change and
the consequences of pandemics have drawn greater attention to environmental and social risks, combined with policy
signals that the financial sector should be a driving force in advancing global sustainability.

Environmental, social and governance (ESG) investment, sustainable investment, socially responsible investment,
impact investment, moral investment and other terms are being used more or less synonymously to define the practice
of incorporating ESG factors in investment decisions.

Investors are increasingly choosing to integrate ESG factors in their investment decisions. Some examine ESG factors
mainly via the risk management lens as an opportunity for higher financial returns, while other institutional investors
perceive ESG as non-financial objectives such as carbon emissions or other sustainability-performance targets that
they aim to promote.
Despite the growing interest in ESG factors, ESG integration is still challenging for many investors. The effect of ESG
factors on the financial performance of investments is unclear, and the resources necessary to make informed
decisions remain high. Reliable ESG data is not yet widely accessible, which may prevent institutional investors from
being able to assess and analyse ESG factors and opportunities.
There are different strategies to integrate ESG factors into investments, and institutional investors select those which
are best suited to their portfolio and approach to ESG integration.

Institutional investors vary in their approaches to integrating ESG factors into their investment decisions.

The integration of ESG considerations in investment decisions is becoming a more common practice among
institutional investors.

Global data ESG data Asset ESG ESG

provider only classes ratings/rankings indices
covered
Bloomberg X All X X
CDP X All X
Fact set X All X
GRESB X Infrastructure X
and real
estate
ISS Financial X All X
Morningstar X All X
MSCI X All X X

175
 Refinitiv / X All X X
Thomson
Reuters
S&P’s Trucost X All X
Sustainalytics X All X X
TruValueLabs X All X X

Institutional investors integrate ESG considerations in the investment decision-making process to generate investment
ideas and themes, to select individual assets for their portfolio, but also to decide on the weights of different assets in
the investment portfolio. This would involve examining ESG factors at the country level, company level and asset level.

4.5.1 ESG CRITERIA ASSESSED BY INSTITUTIONAL INVESTORS AT THE ISSUER LEVEL

Type Example
Category
E Climate change Carbon emissions, climate change mitigation, climate
change adaptation, environmental strategy
E Pollution Air polluting emissions, spills, waste prevention and
management
E Water Use of water resources, water management and
conservation
E Energy Energy consumption
E Biodiversity Land, flora and fauna diversity
E Animal welfare Animal testing
S Privacy Data security
S Community involvement Social impact of business operation, products and
services
S Human capital Diversity and inclusion, training and development
G Corporate governance Board skills, balance of power and authority within the
board, quality of accounting and audit, management
turnover,
shareholders’ rights, disclosure of remuneration
G Market behaviour and business ethics Blocking competition, short-selling, transparency for
investors
S and G Involvement in controversial situations Corruption, violation of human rights
S and G Human rights in the workplace Work conditions, health and safety, non-discrimination
Source: OECD 2019 ESG survey.

Institutional investors that integrate ESG in their investments use different methods for the evaluation of ESG factors,
whether they conduct the analysis in-house or outsource it. Even investors that perform their ESG analysis internally
often rely on external data and other service providers for the evaluation of ESG factors. This section describes the
methodologies and tools being used by investors for ESG analysis and reviews the reasons for using external providers
and some of the implications of the broad use and reliance on such providers.
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ESG rating and index providers are a common source of data on ESG risks and opportunities. Some providers offer
ESG data as a subset of their traditional financial data analysis, while others specialise in ESG data only. ESG data
providers may cover all asset classes or focus on an area or category only. Table 4.2 illustrates some of the providers
used by pension funds and insurance companies that responded to the OECD ESG survey.

4.5.2 ESG INDEX AND RATING PROVIDERS

Sources:
https://www.bloomberg.com/professional/solution/esg/;https://www.cdp.net/en/data;https://www.factset.com/products-
data/esg-solutions; https://gresb.com/; https://www.issgovernance.com/; https://www.morningstar.com/company/esg-
investing; https://www.msci.com/
;https://www.refinitiv.com/en; https://www.trucost.com/; https://www.sustainalytics.com/esg-data/;
https://www.truvaluelabs.com/.

ESG disclosures and ratings represent an increasingly important tool for integrating sustainability considerations into
the investment process, in several ways. First, ESG practices help financial investors who seek to evaluate the financial
materiality of non-financial reporting about conditions, practices and strategies related to environmental, social and
governance issues over the medium term. For example, they could relate to risk management practices to reduce the
impact of climate change on corporate performance, or renewables strategies for new growth opportunities. Second,
ESG ratings and metrics are also being used by social investors to monitor and assess the impact from their
investments, such as to reduce carbon emissions or to better adhere to human rights standards. Moreover, certain
investors may use these metrics to incorporate a blend of both factors, depending on the investment strategy and
objectives. For each of these purposes, ESG criteria provide a useful framework for investors to assess how these
prominent non-financial factors in the short-term could affect firm performance and impact its external environment over
the long term. Thus, in concept, the ESG disclosures, metrics, and rates should serve to support investors to make
more informed decisions and value judgments.

The sustainable market size has grown considerably in the past decade and was estimated to exceed USD 30 trillion in
total assets in the five major markets3 at end-2019, an increase of more than 30% compared to 2016. Globally, almost
USD 1 trillion of assets were held in sustainable funds at end-2019. Of these, around 75% were held by institutional
investors and the remaining 25% by retail investors. The majority of sustainable investments are allocated in public
equities (51%) and fixed income (36%) assets, with the remaining share divided among real estate, private equities and
other types of assets (Global SustainableInvestmentAlliance,2018[1]). In this regard, it is important to understand the
difficulties related to the differentiation between ESG investing and impact investing. ESG investing generally applies
ESG ratings to the investment process (even though some of the strategies, such as exclusionary screening, may rely
on product or norms-based information), while impact investing is focused on solving social or environmental issues
through targeted investments. For the latter and according to the Global Impact Investing Network, the estimated
current size of the global impact investing market is USD 715billion.
With respect to sustainable investments, the European Union leads into assets committed, with the total estimated
amount higher than USD14trillion (GlobalSustainableInvestmentAlliance,2018). The United States follows with more
than USD 12 trillion of assets under management (AUM). The majority of this is held by asset managers and
investment institutions. The data for the United States also suggests that USD2.6trillion (around 20% of total AUM) is
managed through mutual funds, exchange traded funds and closed-end funds. Japan is the third largest centre for
sustainable investing, showing strong growth potential, despite a more modest AUM of around USD 2trillion.
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FIGURE 1.1. SHARE OF MARKET COVERAGE BY ESG SCORING COMPANIES BY REGION, 2012-
2019

World United States European Union Japan

25%

20%

15%

10%

5%

0%

2012 2013 2014 2015 2016 2017 2018 2019

Note: Calculated as the number of public companies with an ESG score over the total number of public companies, in each year
for the different areas. Source: Refinitiv, OECD calculations

178
OECD analysis using Refinitiv ESG data yields similar findings when focused exclusively on ESG ratings.
FindingsillustratedisparateESGmarketcoverageacrosseconomicregionswhenanalysingthefollowing markets: World,
United States, European Union, and Japan. Notably, market coverage is low in markets outside the United States,
despite significantly increasing in recent years (see Figure 1.1). In the United States, market coverage has reached an
all-time-high of almost 25% of public companies while in Europe and worldwide it remains just over 10%. Japan lags
behind with just over5%.
When analysing market capitalisation, however, a different pattern emerges: The market capitalisation of total ESG
scoring companies (companies for which Refinitiv has calculated an ESG score based on the information reported by
the company) represents 78% of the total global market capitalisation, representing around 95% in the US, 89% in the
EU, and 78% in Japan (see Figure below).

SHARE OF MARKET CAPITALISATION BY ESG SCORING COMPANIES BY REGION, 2019

Top20%ESG 0-80%ESG Non-ESG

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
World United States Japan
European
Union
Source: Refinitiv, OECD
calculations

Of total assets under management in sustainable funds, the majority are currently held by institutional investors, even
though retail investors are increasing at a higher rate. Evidently, investor interest in ESG products is growing, yet
concerns remain that, if ESG products are not clearly labelled with transparent methodologies, this could contribute to
misaligned expectations when compared to actual outcomes.
ESGinvestingcanfallwithinabroaderspectrumofinvestingbasedonfinancialandsocialimpact.Atone end of the spectrum,
pure social investing, such as philanthropy for example, seeks only social return. At the other end, pure financial
investment pursues the objective of maximising financial returns based on a given investment strategy, risk parameters
or constraints. Additionally, impact investing4 seeks a social return, in addition to financial returns – but the balance of
179
social and financial returns depends greatly on the chosen investment objective and strategy. As such, the delineation
between what constitutes these different approaches and their anticipated impact on long-term value is not obvious.
In contrast, ESG investing incorporates different meanings depending on the motivation of the investor that uses it.
When used by impact investors who want to better align capital allocation with environmental and social causes, what
matters the most is how the sustainable practices of the company are reflected in the ESG rating. Yet, investors who
have pledged ESG integration broadly see it as a necessity for long- term value creation, which will reward long-term
investments, such as those that reduce exposure to reputational risks. Anecdotal evidence from surveys of institutional
and retail investors suggest that investors are increasingly seeking both enhanced financial returns over time, and the
societal alignment

of their investments, to maximise financial and social returns. While such alignment may be possible in concept as
environmental and social factors become more material,5 in practice the returns of ESG have yet to show such
evidence.
In this regard, ESG investment approaches may include some or all of five distinct forms. On one side, the least amount
of complexity is through excluding certain firms categorically (e.g. based on moral or risk- related considerations), and
on the other side is full ESG integration such that it becomes an integrate part of the investment processes, governance
and decisions.

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4.6 TEST YOUR UNDERSTANDING – MULTIPLE CHOICE QUESTIONS

Q1) GRI Reporting Principles for defining report quality include the following:
a) Accuracy, Materiality and Balance
b) Balance, Clarity and Reliability
c) Comparability, Objectivity & Utility
d) None of the above

Q2) The 3 Universal standards are:

a) Foundation, General Disclosure, &Management Approach

b) Foundation, Boundary and Stakeholder engagement

c) Foundation, General Disclosure& Ethics

d) None of the above

Q3) GRI Standards include the following;

a) Requirement, Explanation & Disclosure
b) Requirement, Recommendation & Guidance
c) Title, Description and Guidance
d) None of the above

Q4) The starting point for using the GRI Standards is;
a) Boundary & Scope
b) Material topics
c) Foundation
d) All of the above

Q5) The content principles of GRI are;

a) Materiality & Stakeholder Inclusiveness
b) Sustainability Context & Completeness
c) All of the above
d) None of the above

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Q6) Management approach enables an organization to;

a) Explain how it manages economic, social, and environmental impacts related to material topics.
b) Describe the policies and procedures related to business conduct
c) Explain the governance and senior management structure
d) a) & b)
e) None of the above
.

Q7) The requirement of the GRI Stakeholder inclusiveness principle is;

a) to report on employee well being

b) Identify stakeholders and explain how it has reported to their reasonable expectations/interests.
c) Report on the lifecycle assessments of its products
d) None of the above

Q8) Which of the following best describes a Material Topic as per GRI framework?

a) It reflects an organization's significant economic, environmental, and social impacts

b) It substantively influences the assessments
c) It substantially influences the decisions of stakeholders
d) All of the above
e) None of the above

Q9) Which of the following are approaches to prepare a report using the GRI Standards?

a) Selected GRI Standards to prepare a GRI referenced Report

b) Used as a set to prepare Sustainability report with Core Option
c) Used as a set to prepare Sustainability report with Comprehensive Option
d) All of the above
e) None of the above

Q10) The GRI Standards are issued by the following:

a) Global Sustainability Standards Board
b) Global Business Responsibility Board
c) International Auditing and Assurance Standards Board (IAASB).
d) None of the Above

Answers: 1. B; 2. A; 3. B; 4. C; 5. C; 6. A; 7. B; 8. D; 9. D; 10. A.

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MODULE 5 - ASSURANCE ASPECTS
5.1 ASSURANCE OF CORPORATE SUSTAINABILITY REPORT

Assurance is the process of obtaining an opinion on the reliability of information based on an independent
review carried out by a third party. An organization that carries out an assurance process on sustainability
information by an independent agency or professional demonstrates greater commitment to sustainability.

Assurance of reporting helps to enhance the confidence of the stakeholders in the accuracy and reliability of
the reported information and provides the intended users with useful data for decision making.

Assurance is an evaluation method that uses a specified set of principles and standards to assess the quality
of an organisation’s subject matter and the underlying systems, processes and competencies that underpin its
performance.

According to a recent Governance & Accountability Institute research report, around 90% of the public
companies in the Standard & Poor’s 500 Index are publishing their sustainability reports. Out of these
companies, almost one third have obtained some kind of assurance on their sustainability reports.

In addition to external assurance, it is important for an organization to have systems of internal controls in
place. These internal systems are useful for the overall integrity and credibility of a report.

Most companies have developed organizational policies, procedures, processes, systems, and controls to
ensure the reliability of financial information and reporting. In the context of sustainability information
presented by the Companies, it is important to ensure that the internal systems, processes and controls are
adequate and reliable for presentation of non-financial data or information.

As part of corporate governance requirements, company directors are responsible to ensure and to confirm on
the adequacy of an organization’s internal controls to support the published financial reports. A well-
established internal audit function is also a component of ensuring reliability of internal systems, processes
and controls in accordance with accepted standards and frameworks. Companies can setup committees or
stakeholder groups to evaluate their sustainability reporting practices and to provide recommendations for
improvements on the reports.

Assurance includes the communication of the results of this evaluation to give the subject matter credibility for its
users. Auditing, verification and validation are some of the tools and processes by which assurance is obtained.

Assurance helps in:

 Increased recognition, trust & credibility

 Reduced risk and increased value
 Improved stakeholder communication
 Robust data gathering & processes
 Improved top-level engagement

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5.2 ASSURANCE FRAMEWORK

The information subject to the assurance engagement would depend upon the specific objectives of the
organization and the drivers for obtaining assurance.
The frameworks for independent assurance of sustainability reports include the international standards, such
as the ISAE 3000, Global Reporting Initiative (GRI) and the AA 1000 Accountability Principles (2008).

External assurance’ are the “Activities designed to result in published conclusions on the quality of the report
and the information (whether it be qualitative or quantitative) contained within it ‘. External assurance can also
refer to activities designed to result in published conclusions about systems or processes (e .g. the application
of GRI’s Materiality principle or the stakeholder engagement process). This is different from activities designed
to assess or validate the quality or level of performance of an organization, such as issuing performance
certifications or compliance assessments.” (GRI 102: General Disclosures 2016).

Organizations providing assurance-related services on sustainability information include Accounting firms,

engineering firms and environmental consulting firms. The assurance services use various standards and
methodologies to perform their assurance engagements.

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5.3 ASSURANCE STANDARDS FOR LIMITED/ REASONABLE ASSURANCE

The assurance providers can provide two different levels of assurance services:

5.3.1 REASONABLE ASSURANCE

This is in the nature of an Examination engagement. In an examination engagement, the assurance provider
obtains reasonable assurance in order to express his opinion on whether the subject matter of assurance
reviewed in terms of the relevant criteria is free from material misstatement
 This type of assurance is achieved when the risk of a material mis-statement of the subject matter
has been reduced to a low level.
 To achieve this, the assurance provider must conduct extensive procedures.
 The assurance provider obtains sufficient evidence to confirm whether the subject conforms to the
criteria.
Reasonable assurance conclusions are framed in a positive manner. For example,
‘Based on the procedures performed, in our opinion, the management assertion on [subject matter] is
properly prepared’.
Practitioner will understand the internal controls in place for preparation of subject matter including
evaluation of both its design and actual implementation. This will include assessing the SOPs for data
measurement, collation across the company, internal reviews and their outcomes/ corrective actions, IT
tools used for data compilations etc.
This assurance involves analysing the existing systems and preparedness of personnel involved to
collect and collate data related to KPIs.It iinvolves exhaustive evidence gathering procedures.

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5.3.2 LIMITED ASSURANCE

This is in the nature of a Review engagement. In a review engagement, the assurer obtains limited assurance
and provides a conclusion about whether any material modifications are required in the subject matter in order
for it to be in accordance with the relevant criteria. Review engagements are narrow in scope, involve limited
procedures, and the outcome is more specific but lower level of assurance than examination engagements.
The level of assurance is a based upon the following:
 specific objectives of the engagement
 degree of assurance required by the organization
 Importance of the sustainability information to the decision-makers.
 expectations of internal and external users of the sustainability information
 Alignment with financial reporting and disclosure
 factors relating to the prevailing legal and regulatory requirements
 Cost and benefit analysis of the different levels of assurance
This type of assurance is achieved when the risk of a material mis-statement of the subject
matter has been reduced through the collection of evidence, but not to the low level required by
reasonable assurance.
To achieve this, the assurance provider performs different or fewer tests than those required for
reasonable assurance or uses smaller sample sizes for the tests performed.
The assurance provider’s conclusion provides comfort over whether the subject is plausible against
the criteria.
Evidence gathering procedure limited to inspection, recalculations, establishing audit trail on sample
basis, probing, trend analysis etc.
Limited assurance conclusions are framed in a negative manner.
For example, ‘Based on the testing performed; nothing has come to our attention to indicate
that the management assertion on [subject matter] was not properly prepared
Different levels of assurance could be provided for aspects or elements of the sustainability
information, underlying systems or processes. .

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The two key assurance standards that are widely used are

 ISAE 3000
 AA 1000AS
.

5.3.3 ISAE 3000

ISAE 3000 is the standard for assurance over non-financial information. ISAE 3000 is issued by the International
Federation of Accountants (IFAC). The standard consists of guidelines for the ethical behavior, quality
management and performance of an ISAE 3000 engagement.
 Deals with assurance engagements other than audits or reviews of historical financial
information.
 This ISAE is effective for assurance engagements where the assurance report is dated on or
after December 15, 2015.
 The members of the engagement team and the engagement quality control reviewer are
subject to Code of Ethics for Professional Accountants issued by the International Ethics
Standards Board for Accountants (IESBA Code).
 The practitioner who is performing the engagement is a member of a firm that is subject to
ISQC
 Where a subject-matter specific ISAE is relevant to the subject matter of a particular
engagement that ISAE applies in addition to this ISAE.
 The practitioner shall comply with each requirement of this ISAE.
 Primary Objective:
To obtain either reasonable assurance or limited assurance, as appropriate, about whether the
subject matter information is free from material misstatement.
 When reasonable or limited assurance cannot be obtained and a qualified conclusion in the
practitioner’s assurance report is insufficient in the circumstances for purposes of reporting to
the intended users, practitioner must disclaim a conclusion or withdraw (or resign) from the
engagement, where withdrawal is possible under applicable law or regulation.
 If the engaging party imposes a limitation on the scope of the practitioner’s work in the terms of
a proposed assurance engagement such that the practitioner believes the limitation will result
in the practitioner disclaiming a conclusion on the subject matter information, the practitioner
shall not accept such an engagement.
 The practitioner shall not agree to a change in the terms of the engagement where there is no
reasonable justification for doing so. If such a change is made, the practitioner shall not
disregard evidence that was obtained prior to the change.

The subject of assurance can include:

 Sustainability reports
 ESG activities
 Systems and processes - internal control, IT systems etc.
Generally ISAE 3000 is applied for audits of internal control, sustainability and compliance with laws and
regulations.
ISAE 3000 recognizes two types of reports:
 Type 1 report provides assurance on the suitability of design and existence of controls
 Type 2 report provides assurance on suitability of design, existence and operational effectiveness

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The standard consists of guidelines for the ethical behavior, quality management and performance of an ISAE
3000 engagement.

ISAE 3000 recognizes two types of assurance engagement,

 “reasonable assurance engagement”

 and “limited assurance engagement”

This ISAE uses the terms “reasonable assurance engagement” and “limited assurance engagement” to
distinguish between the two types of assurance engagement a practitioner is permitted to perform. The objective
of a reasonable assurance engagement is a reduction in assurance engagement risk to an acceptably low level
in the circumstances of the engagement1 as the basis for a positive form of expression of the practitioner’s
conclusion.

The objective of a limited assurance engagement is a reduction in assurance engagement risk to a level that is
acceptable in the circumstances of the engagement, but where that risk is greater than for a reasonable
assurance engagement, as the basis for a negative form of expression of the practitioner’s conclusion

Requirements of ISAE 3000 include the following:

 Risk and materiality Ethics – the Code
 Quality control
 Engagement acceptance
 Planning
 Suitability of criteria
 Professional scepticism
 Obtaining evidence
 Using experts
 Documentation
 Reporting

5.3.3.1 FEATURES OF ISAE 3000

 Deals with assurance engagements other than audits or reviews of historical financial information.
 This ISAE is effective for assurance engagements where the assurance report is dated on or after
December 15, 2015.
 The members of the engagement team and the engagement quality control reviewer are subject to Code
of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants
(IESBA Code).
 The practitioner who is performing the engagement is a member of a firm that is subject to ISQC
 Where a subject-matter specific ISAE is relevant to the subject matter of a particular engagement that
ISAE applies in addition to this ISAE.
 The practitioner shall comply with each requirement of this ISAE.

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5.3.3.2 CONTENT OF ISAE 3000 REPORT

An ISAE 3000 report generally consists of the following:

 Scope of the report
 Standard used
 Control framework
 Risk management system
 Control matrix including risks, control objectives and controls.
The content of the ISAE 3000 report includes:
 Clear title
A title that clearly indicates the report is an independent assurance report:
 An addressee
An addressee identifies the party or parties to whom the assurance report is directed. Whenever practical,
the assurance report is addressed to all the intended users, but in some cases there may be other intended
users
 Identification of – level of assurance and subject matter
This includes for example:
• The point in time or period of time to which the evaluation or measurement of the subject matter
relates;
• Where applicable, the name of the entity or component of the entity to which the subject matter
relates; and
• An explanation of those characteristics of the subject matter or the subject matter information of
which the intended users should be aware, and how such characteristics may influence the
precision of the evaluation or measurement of the subject matter against the identified criteria, or
the persuasiveness of available evidence.
 Identification of – applicable criteria
The assurance report identifies the criteria against which the subject matter was evaluated or measured so
the intended users can understand the basis for the practitioner’s conclusion. The assurance report may
include the criteria, or refer to them if they are contained in an assertion prepared by the responsible party
that is available to the intended users or if they are otherwise available from a readily accessible source.
 Where appropriate, a description of any significant, inherent limitation associated with the evaluation or
measurement of the subject matter against the criteria:
While in some cases, inherent limitations can be expected to be well understood by readers of an assurance
report; in other cases it may be appropriate to make explicit reference in the assurance report.

 When the criteria used to evaluate or measure the subject matter are available only to specific intended
users, or are relevant only to a specific purpose, a statement restricting the use of the assurance report to
those intended users or that purpose: in addition, whenever the assurance report is intended only for specific
intended users or a specific purpose, the practitioner considers stating this fact in the assurance report.5
This provides a caution to readers that the assurance report is restricted to specific users or for specific
purposes.

 A statement to identify the responsible party and to describe the responsible party’s and the practitioner’s
responsibilities
 Statement on engagement performance in accordance with ISAE 3000
 Statement that the firm of which the practitioner is a member applies ISQC 1, or other professional
requirements at least as demanding

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 A statement that the practitioner complies with the independence and other ethical requirements of the
IESBA Code, or other professional requirements at least as demanding
 An informative summary of the work performed as the basis for the practitioner’s conclusion
The summary will help the intended users understand the nature of the assurance conveyed by the
assurance report. ISA 700, “The Auditor’s Report on Financial Statements”7 and ISRE 2400, “Engagements
to Review Financial Statements” provide a guide to the appropriate type of summary. Where no specific
ISAE provides guidance on evidence-gathering procedures for a particular subject matter, the summary
might include a more detailed description of the work performed
 The practitioner’s conclusion
The report must clearly state the assurance provider’s conclusion and the basis for conclusion
 The practitioner’s signature
 The date of the assurance report
 The location in the jurisdiction where the practitioner practices

5.3.3.3 LIMITATION OF ASSURANCE:

 Financial experts, not sustainability experts

 Negative assurance

 Suitable criteria

 Recommendations

 Is the right information being reported, not just is the reported information right (i.e., relevance as well as
reliability)

 Completeness

o The most difficult area, even when have good criteria

o Determining what is material is difficult given the diversity of readers and their needs

o Negative assurance appropriate for completeness?

 ISAE 3000 use by others

Please refer to https://www.ifac.org/system/files/downloads/b012-2010-iaasb-handbook-isae-3000.pdf for etil on

ISAE 3000.

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 5.3.4 AA1000 ASSURANCE

AA1000AS is a standard for assurance on sustainability information of any type:

 based on application of the AA1000 Accountability Principles (AA1000AP)

 focuses on the processes required for responsible and complete assurance engagements
 AA1000AP principles of Inclusivity, Materiality, Responsiveness and Impact.

The AA1000 Series of Standards are founded on the principles of:

 Inclusivity – People should have a say in the decisions that impact them
 Materiality – Decision makers should identify and be clear about the sustainability topics that matter
 Responsiveness – Organizations should act transparently on material sustainability topics and their related
impacts

There are two levels of AA1000AS (2008) assurance:

Primary Objective:

To obtain either reasonable assurance or limited assurance, as appropriate, about whether the subject matter
information is free from material misstatement.

Impact – Organisations should monitor, measure and be accountable for how their actions affect their broader
ecosystems

 A high level of assurance;

 The assurance provider shall evaluate the nature and extent of the organisation’s adherence to all four
AA1000 Accountability Principles.
 Evidence gathered by communicating with sources including those outside company on:
• Process of identification of stakeholders
• Mechanism of engaging with them and timing
• Response to the issues raised by stakeholder
• Involvement in identification of material issues
• Corroborating issues identified with independent media and secondary literature review
• Evidence gathering to be limited to only internal sources of the company. Limited corroborative evidence
gathering including secondary literature review

Additional procedures include the following:

 Extensive depth of evidence gathering at all levels of the organisation

 Detailed corroborative evidences sought

A moderate level of assurance is used to aassess the extent of adherence to the principles along with the
reliability of specified sustainability performance information

The moderate level of assurance is the same methodology as Type 1 High level and covers:

• Limited depth of evidence gathering including inquiry and analytical procedures and limited sampling at
lower levels in the organisation as necessary.

• Emphasis is on the plausibility of the information.

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AA1000AS is designed by sustainability professionals to focus on the quality of an organisation’s reporting and
performance, with emphasis on materiality, impact, stakeholders and strategy. On the other hand, ISAE 3000 for
“Assurance Engagements Other than Audits or Reviews of Historical Financial Information” is a standard for any
assurance engagement focusing on procedures, terms of engagement and engagement performance. .

The AA1000 Series is comprised of three standards:

o Accountability Principles (AA1000AP,2018)

o AA1000 Assurance Standard (AA1000AS, 2008) with 2018Addendum
o AA1000 Stakeholder Engagement Standard (AA1000SES, 2015)– Revision in Progress

Recently, the AA1000APS (2008) Accountability Principles have been replaced by the Accountability
Principles (AA1000AP, 2018).

Key changes include:

 Guiding Framework of Principles for Sustainability Management rather than

prescriptive
 Overarching Principle added —Impact that supports results-based management
and accountability
 Higher alignment with other leading sustainability-related frameworks and standard

ISAE3000 and AA1000 AS are complementary and can be applied together in an assurance
process.

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5.4 ROLE OF ACCOUNTANTS IN HELPING CORPORATES PREPARE AND PROMOTE USE
OF HIGH-QUALITY COMPARABLE, RELIABLE, AND RELEVANT BRR DISCLOSURES

An organization can obtain external assurance from the professional assurance providers, or other external
groups or persons.

Assurance Engagement is an Engagement in which a practitioner aims to obtain sufficient appropriate evidence
in order to express a conclusion designed to enhance the degree of confidence of the intended users other than
the responsible party about the subject matter information (that is, the outcome of the measurement or evaluation
of an underlying subject matter against criteria).”

It is important to ensure that the external assurance is conducted by:

 competent persons
 following professional standards
 Applying systematic, documented, and evidence-based processes.

There are following expectations from the assurance providers:

 independence from the organization to ensure objectivity of opinion and conclusions

 Demonstrated competence
o in the sustainability subject matter
o in assurance practices;
 application of quality control procedures to the assurance engagement

The assurance of sustainability information requires the following capabilities from the professionals:

 Understanding of the business, industry, internal and external factors that affect the organization
 Understanding the importance of sustainability from the corporate financial and strategic perspective
 Knowledge of the reporting frameworks and their interpretations in specific contexts
 Evaluation of organizational policies, internal systems, processes and controls
 Experience in the use of systems and tools for collection, analysis and reporting data and information
 Expertise in audit, assurance, attestation procedures

In addition to the relevant competence and capabilities, sustainability assurance engagement requires skill in
working with stakeholders and teams involving technical expertise and specialists, as required.

Sustainability assurance requires an understanding of the overall context of enhanced sensitivity to the corporate
obligation to environmental and public interest. Sustainability assurance engagements call for an enhanced level
of comfort on part of the professional in dealing with multi stakeholder perspectives, non-financial data, the
macroeconomic factors, the strategic choices and decision making facing an organisation.

The sustainability assurance involves

 a clear understanding the intended users
 specific requirements
 user and client expectations
 Manner in which the sustainability information and the assurance report would meet the requirements of the
intended users’ needs.
The work of the sustainability assurance engagement involves interfacing with highly technical

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 sustainability topics, such as, Greenhouse gas emissions, or situations relevant to the specific
industry sector, stakeholder communities or the geographical location in which the organization
operates.
It is important for an assurance provider to understand the scope of the engagement. The
assurance engagement would depend upon the specific sustainability information presented and
whether the organization requests complete assurance on all aspects of reporting or only on
selected aspects of sustainability activities or information.
The limitations on the scope of assurance and the reported information, exclusions, associated
reasons, and the effect on the materiality of the sustainability report need to be clearly understood
and documented by the Assurance provider...
It is very important to note the importance of sustainability information and its usage by various
stakeholders including investors for investment decision-making. The assurance engagement
involves interactions and information from directors and senior managers at the highest level of
governance in the organization. The other parties in the orgnisation involved in the sustainability
assurance engagement are the teams working in preparing the sustainability information, such as,
the sustainability department, CSR, quality control, and the internal audit. .

5.4.1 KEY POINTS PERTAINING TO CONDUCTING ASSURANCE ENGAGEMENT

Points to be considered pertaining to assurance engagement for an organization’s situation on
sustainability reporting:

 Specific sustainability information report

 Identification of stakeholders
 Materiality assessment
 Standards used to report information
 Use of internal measures
 Manner of reporting - stand-alone report, online, or integrated
 The level of assurance it is planning to obtain (reasonable or limited)
 policies, processes, management information systems, and internal controls
 roles and responsibilities of management
 Governance and board level involvement
 Timeline and constraints.
 The role and participation of the internal audit function
 Risk management framework

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5.4.2 BENEFITS TO THE ORGANIZATION FROM ASSURANCE

 Enhanced Quality of Disclosures

o Accuracy

o Balance

o Clarity

o Completeness

o Comparability

o Reliability

o Materiality

o Sustainability Context

o Stakeholder Inclusiveness

 Improved Trust, Credibility and Decision Making by Stakeholders

o Customers

o Investors and Analysts

o ESG/Sustainability themed indices (e.g. Dow Jones Sustainability Index, proposed BRSR Index)

o Governments

 Improved Performance

o Better inputs for management decision-making

o Opportunities to align with best practices
o “Pressure to perform”

5.4.3 KEY ELEMENTS OF ASSURANCE ENGAGEMENTS

The Key Elements of Assurance Engagements include:

3-Party Relation

All assurance engagements have at least three separate parties: the Practitioner, the Responsible Party and the
Intended Users.

Subject Matter

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Underlying aspect being measured and reported: non-financial KPIs on greenhouse gas (GHG) emissions, water
use or accident frequency

Criteria

Criteria may either be external (e.g. GRI Standards, IIRC, BRSR) or internal (customized KPIs developed by the
responsible party).

Evidence

Information used by the practitioner in arriving at the practitioner’s conclusion (Sufficiency and Adequacy)

5.4.4 ROLE OF THE ASSURANCE PROFESSIONALS IN ASSURANCE REPORTING

The assurance service provider should:

 Be keenly aware of the broad range of sustainability / non-financial aspects of your Company and the value
creation on various forms of capitals.
 Understand the connectedness between financial and sustainability processes / performance / reporting of
businesses.
 Familiarize yourself with the non-financial reporting requirements, especially the proposed BRSR Reporting
(recommended by MCA Committee).
 Inquire and assess the governance, policies, data management systems and reporting maturity of your
Company on non-financial aspects.
 Equip yourself with knowledge on assurance standards to provide high degree of credibility on non-financial
reporting

Certified accountants are qualified and experienced professionals possessing independence,

objectivity, credibility and integrity to qualify as assurance providers
Due to the evolving nature of sustainability concerns and requirements, it is very important for the
sustainability assurance professionals to keep themselves continuously up to date with evolving
practices in sustainability reporting around the world.
In addition to the assurance work on the content of the sustainability reports, the professionals could
play a big role in providing value added suggestions to improve internal controls, policies, management
processes, information systems and procedures, to enhance the reporting, quality of information and
improve the business efficiency.

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