BRSR Requirements & Essential BRSR Disclosures

by | Dec 12, 2023 | ESG, Sustainability

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SEBI established the BRSR framework with BRSR Requirements and Essential Disclosures, requiring certain listed businesses to provide ESG information as a mandated process. The BRSR framework intends to increase transparency and encourage companies to pursue responsible and sustainable business practices.

Must-know BRSR Requirements for Listed Companies in India

Companies who want to submit a BRSR because they are among the top 1,000 publicly traded companies by market capitalization or because they voluntarily choose to do so can employ this four-step process.

  1. Understanding the New Format with Expert Assistance: The first step for businesses would be to understand what BRSR Requirements and Essential Disclosures are intended to contain. The essential requirements are mentioned in a SEBI circular dated May 10, 2021, with more specific information accessible in Annexures I and II. Companies can seek expert help to comprehend the BRSR Requirements and Essential Disclosures filing format.
  2. Create a Reporting Timetable for Efficient Compliance: The second step in the process is to create a compliance timetable and work within it. When numerous teams are involved in the disclosure process, a timeframe is an absolute must. The senior management and sustainability reporting teams may need to collaborate to develop corporate responsibility disclosures.
  3. Obtain XBRL Reporting Assistance from a Technology Provider: Creating XBRL reports is a technological process that in-house compliance teams cannot perform independently. Companies must select XBRL reporting software or service providers who have technical skills. XBRL is a machine-readable format that improves the accessibility, analysis, and comparability of reports.
  4. Companies that have already filed a BRSR should be followed: Companies producing their initial BRSR documents can allude to the reports of companies that have previously met the requirement.

A Checklist for Essential BRSR Disclosures

SEBI has produced a guidance sheet outlining the BRSR Requirements and Essential Disclosures that must be included in your report. These are, in broad terms:

Section A: General Disclosures

The disclosures sought in this part are primarily internal and available only to the reporting companies. Name, CIN, registered office address, information about the company, paid-up capital, names and phone numbers of the person in charge of BRSR, details regarding activities, products, and turnover are all required. More information regarding the gender ratio of employees and workers, the representation of women in top management, and the employee turnover ratio must be published. While transitioning from BRR to BRSR, the reporting entity must pay close attention to two specific disclosure requirements.

This would necessitate a variety of exercises by the entities, beginning with identifying its many stakeholders and categorizing them into different groups. NGRBC has defined the term stakeholders as an individual or organization involved or interested in or impacted by the operations of the enterprises, now or in the future. Stakeholders in a company typically include but are not limited to, its investors/shareholders, employees (and their families), consumers, communities, supply chain members and other stakeholders, regulators, civil society actors, and media. Following the division of the stakeholders group, two groups will need to build a grievance redressal mechanism: “communities” and “value chain partners.”

Section B: Management and Process Disclosures

This section discusses management’s approach to the NGRBC principles upon which the BRSR reporting is based. It is crucial to highlight that the company needs to have the ability to create new policies or procedures for each of the principles; current policies or guidelines set by the organization can also serve the purpose. A policy may cover one or more directions, and a Principle and its Core Elements could be covered by more than one policy. A corporation may create a new unified BRSR Policy that includes policies and implementation procedures for all 9 Principles and their essential aspects.

On the other hand, the company may adopt different policies for each of the nine Principles based on the core elements of the Principles, such as a Code of Conduct/Ethics Policy, a Whistleblower Policy for Principle 1, and a Corporate Social Responsibility Policy for Principle 8. While setting particular goals, focus should be placed on addressing challenges from the organization’s overall operation. Companies active in e-commerce or other cyber-related areas, for example, should make data privacy and cyber security one of their particular commitments. Companies engaged in mining or other industrial operations that cause environmental damage may aim to achieve maximum environmental safeguards.

Section C: Principle-Wise Performance Disclosures

After we’ve covered the fundamentals, let’s move on to the principle-by-principle disclosure and suggested steps the reporting body can take to achieve its reporting requirements in letter and spirit.

brsr requirements essential brsr disclosures

Principle 1: Businesses should operate and manage themselves with integrity in an ethical, transparent, and accountable manner.

This approach is mainly focused on SDG 17 – Goal Partnerships. A company comprises people, from its internal stakeholders (employees, workers, senior management, Board of directors, and other critical administrative individuals) to its external stakeholders (investors, consumers, suppliers, other value chain partners, and so on). As a result, the compliance of the concept by the business can be secured if it is adhered to by the individuals associated with the firm jointly and severally. In such cases, organizing training and awareness activities for stakeholders is critical. Training and awareness for employees, workers, board members, and so on are primary responsibilities of the organization, and information is sought under the “essential” indicators. In contrast, programs conducted for other value chain partners indicate the entity’s “leadership” qualities.

Principle 2 – Businesses should deliver goods and services sustainably and safely.

The Principle is based on the United Nations Sustainable Development Goals, a segment of the 2030 Agenda. The Principle is derived from SDG 12 and states that sustainable production and consumption are inextricably linked, leading to improved quality of life and the protection and preservation of the earth’s natural resources. This necessitates organizations to invest in R&D and capital spending on technology that enhances their products’ environmental and social implications.

Principle 3 – Companies should value and promote the well-being of all employees, especially those in their value chains.

This Principle incorporates all policies and practices relating to fairness, dignity, and well-being, as stated in SDG 8, and the provision of decent employment to all employees involved in the value chain, without discrimination and in a way that encourages diversity. The principle recognizes that the employee’s well-being includes their family’s well-being. Decent work, job creation, social protection, workplace rights, and social dialogue are essential to the new 2030 Sustainable Development Goals. Furthermore, several of the other 16 goals’ aims include critical features of decent labour.

Principle 4 – Businesses must respect and respond to the interests of all stakeholders.

The most crucial step in achieving this idea is identifying stakeholders. The United Nations Guiding Principles (“UNGP”) also require organizations to identify their stakeholders, particularly those disadvantaged, marginalized, or vulnerable. Any organization has many stakeholders from many viewpoints, including economic, social, environmental, etc. While it may be impossible for a firm to be entirely responsive to all its stakeholders, it must identify its primary stakeholders.

Principle 5 states that businesses must respect and promote human rights.

Human rights are the elemental rights that all people are expected to enjoy. Because human rights are inherent in humans, they must be aware of their rights to assert them. In this regard, the UNGP provides several guiding questions, the answers to which might assist an organization’s management in incorporating human rights into its culture.

Principle 6 – Businesses should acclaim and try to maintain and restore the environment.

Part IVA of the Indian Constitution (Art 51A-Fundamental Duties) imposes a duty on every Indian citizen to safeguard and ease the natural environment, containing forests, lakes, rivers, and animals and compassion for living creatures. Although corporations are not recognized as citizens, they are ultimately a collection of citizens exclusively. As a result, a firm is equally responsible for environmental conservation and restoration.

Principle 7 – Businesses should do it responsibly and openly when influencing public and regulatory policy.

Principle 7 addresses the responsible conduct of business with the general public. Aside from the stakeholders with whom an entity is directly or indirectly affiliated, an organization bears a more outstanding obligation to the general public, whom it influences in some way. Except for a few giant corporations, corporations rarely interact directly with the public. They would rather be affiliated with significant associations/institutions/trade and industry chambers.

Principle 8 states that businesses should encourage inclusive growth and equitable development.

As Section 135 of the Companies Act 2013 articulated, the Principle recognizes the value of businesses’ energy and enterprise. It encourages them to innovate and contribute to the country’s overall development, specifically focusing on disadvantaged, vulnerable, and marginalized communities. The Principle also emphasizes the importance of collaboration among enterprises, government agencies, and civil society in advancing the SDG 17 development objective.

Principle 9 – Businesses must interact with and responsibly deliver value to their customers.

Consumers are always an essential part of any business. However, they are frequently exploited by companies. Consumer protection is thus a significant concern, if not in the industrialized nations of the United States, then in India. The Consumer Protection Act of 2019 is the primary piece of law in India that governs and works to protect consumers. The Competition Act of 2002 is another legislation that protects consumers and prevents business organizations from exploiting them.

Also Read: BRSR Framework: A Holistic Approach To Business Responsibility & Sustainability

Transparency and Accountability: The Core of BRSR Disclosure Requirements

The BRSR Core is a subset of the complete BRSR Requirements and Essential Disclosures, containing a specific set of key performance indicators (KPIs) / metrics across nine ESG criteria. Additional KPIs for assurance have been identified, focusing on the Indian / emerging market setting, such as job creation in small towns, business openness, and gross wages paid to women. To improve worldwide comparability, intensity ratios based on revenue adjusted for purchasing power parity (PPP) were included. The BRSR Core also offers a cross-reference to the disclosures contained in the BRSR for ease of reference.

The listed entity’s Board is responsible for ensuring that the assurance source of the BRSR Core has the necessary knowledge to offer reasonable assurance. The listed entity must provide no conflicts of interest with the assurance provider chosen to assess the BRSR Core. It should ensure that the assurance provider and its subcontractors do not sell their products or provide non-audit/non-assurance services, including consultancy services, to the mentioned entity or its group entities. This measure promotes the impartiality and independence of the assessment in the assurance process, boosting the assessment’s credibility and reliability.

Also Read: BRSR Principles And Their Role In Corporate Governance

Avoiding Common Mistakes in BRSR Disclosure Reporting

To ensure that your first BRSR report with BRSR Requirements and Essential Disclosures produces positive outcomes, avoid the following five mistakes:

1. Underestimating the amount of time and effort required to acquire data

Data collecting is a time-consuming procedure requiring a comprehensive understanding of all organizational activities. Because ESG issues influence your entire firm, many different departments must be included in this process. Appreciating the time required for coordination and cooperation among crucial departments is essential. Furthermore, verifying that the released information tracks the appropriate parameters and displays the appropriate ESG KPIs is critical. As a result, you should engage ESG experts to confirm the data’s integrity, which may take some time.

2. Failure to rely on a widely accepted sustainability reporting standard

Using a recognized sustainability reporting standard or methodology is very crucial in three areas:

Clarity: reporting guidelines aim to give stakeholders the most accurate image of how your organization handles ESG concerns. As a result, stakeholders may quickly and easily access the information they seek in your BRSR report.

Comparability: Because ESG data is standardized, investors can compare investment opportunities using sustainability reporting standards. A straightforward presentation lets investors determine the best investment options for establishing a green portfolio without sifting through many separate reports.

Self-control: Reporting following reporting standards might result in content your organization can use to track its BRSR performance over time.

3. Feeling overwhelmed by the vast number of ESG standards

Numerous sustainability reporting standards and frameworks exist, including ESRS, GRI, GHGP, and IFRS Standards. As a result, selecting the best one may require some clarification. The accepted standard should best fulfil your organization’s BRSR demands and be compatible with your company’s characteristics.

4. Not prioritizing material ESG topics

ESG issues should be ranked and prioritized to keep your report concise and informative. Reporting on too many ESG themes can limit the report’s informational usefulness and comprehensibility. The materiality assessment lets you identify your organization and sector’s most critical ESG issues. For example, in a GRI materiality evaluation, you investigate whether ESG variables may significantly influence your company’s environment and stakeholders. It is recommended that you integrate your stakeholders’ perspectives, including consumers, investors, employees, and civil society, to determine your most important ESG topics. Stakeholder insights may disclose priorities that corporate leaders are unaware of.

5. Failure to establish ESG objectives

If corporate sustainability is to contribute to a competitive advantage, your company should not be content with simply describing the current quo. Instead, to meet such standards, your organization must identify precise ESG goals and tangible activities. The objectives should be reasonable, and progress should be monitored regularly. Understanding your existing performance while evaluating it against your competitors’ performance, researching technical opportunities, and reaching out to your key stakeholders is critical.

Also Read: BRSR SEBI Format: Step-By-Step Guide

Bottom Line

The increasing prominence of non-financial disclosures, in addition to annual financial reports, guarantees that businesses explicitly acknowledge their environmental and social responsibilities. As the importance of BRSR Requirements and Essential Disclosures grows, it is intended that the information, together with financial data, will be utilized by banks, credit bureaus, and other financial institutions to assess the legitimacy of a company/business. It remains to be observed whether the BRSR gained acceptance and credibility across worldwide frameworks as a single source of data to be used by enterprises reporting in India, and if so, if they can be used as a primary document for business assessment, as authorities have intended.

FAQs

Q1. What exactly is BRSR in ESG?

SEBI established additional ESG indicators for mandatory disclosure under ‘BRSR Core’ for some listed businesses in India in July 2023. The Business Responsibility and Sustainability Report (BRSR) format superseded the old Business Responsibility Report (BRR) format in May 2021.

Q2. Is BRSR reporting required?

Following the introduction of Core Business Responsibility and Sustainability Reporting (BRSR), market regulator SEBI has now mandated certification of this unique ESG reporting structure.

Q3. What is the BRSR reporting system’s structure?

In its disclosure forms, BRSR incorporates ESG ideas. The report’s KPIs are classified into three categories: E, S, and G. For improved quantitative disclosures under principle-wise indicators, the inquiries have become more straightforward and explicit.

Also Read: SEBI ESG Rules: Stringent But In the Right Direction

 

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