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Introduction to Part 4: ESG in India and BRSR Reporting

Welcome to the fourth and insightful segment of our series, “Beyond Profits: The Power and Purpose of ESG in Today’s Business Landscape.” In this part, we direct our focus towards the Indian business milieu, exploring the dynamic landscape of Environmental, Social, and Governance (ESG) practices and the evolving concept of Business Responsibility and Sustainability Reporting (BRSR).

Titled “ESG in India and BRSR Reporting,” this section delves into how businesses in India are embracing ESG principles, aligning with global sustainability trends, and navigating the regulatory landscape. We will unravel the significance of BRSR as a framework for transparently communicating the impact of businesses on the environment, society, and governance.

The Imperative of ESG in India

In India, a nation characterized by its diverse economy and rapidly evolving business landscape, the integration of ESG has gained significant momentum. India, as one of the world’s most populous countries, faces a unique set of environmental challenges. Issues like air pollution, water scarcity, and climate change demand immediate attention. Businesses operating in India have realized that aligning their operations with environmental sustainability is not just a regulatory obligation but a strategic necessity. From energy-efficient manufacturing processes to green supply chains, companies are embracing eco-friendly practices to mitigate environmental risks and reduce their carbon footprint.

The Securities and Exchange Board of India (SEBI) introduced a disclosure framework for Environmental, Social, and Governance (ESG) reporting in India in 2021. This initiative aimed to enhance ESG disclosure and reporting practices among India’s top 1000 listed companies by market capitalization. SEBI’s ESG disclosure framework represented a significant step toward promoting sustainability and responsible business practices among Indian listed companies. By requiring ESG disclosures, SEBI aimed to drive greater attention to ESG issues, improve corporate transparency, and provide investors with more comprehensive information for making informed investment decisions. It also aligned with global trends in ESG reporting and sustainability disclosure. Companies were encouraged to embrace ESG reporting as a means of enhancing their competitiveness and attractiveness to responsible investors.

SEBI’s guidance document on ESG reporting for listed companies in India provides details on three categories of disclosures: general disclosures, management and process disclosures, and principle-wise (principle-based) disclosures. These categories are designed to guide companies in providing comprehensive and meaningful ESG-related information to their stakeholders. Here’s a brief overview of each type of disclosure:

• General Disclosures: General disclosures encompass overarching information about the company’s ESG policies, initiatives, and performance.
• Management and Process Disclosures: Management and process disclosures provide more detailed information about how the company manages and integrates ESG considerations into its operations and decision-making processes.
• Principle-wise (Principle-Based) Disclosures: Principle-wise disclosures are focused on providing specific information related to each of the ESG principles.

SEBI’s guidance document emphasizes the importance of transparent and meaningful ESG reporting, encouraging companies to provide relevant information that allows stakeholders to assess the company’s ESG performance and commitments.

Business Responsibility and Sustainability Report (BRSR) framework

The Business Responsibility and Sustainability Report (BRSR) framework in India is a reporting framework introduced by the SEBI to encourage greater transparency and disclosure of sustainability and business responsibility practices among listed companies. The BRSR framework was introduced in alignment with SEBI’s efforts to promote ESG disclosures and responsible business conduct.

The framework comprises a set of questions designed to assess a company’s business responsibility and sustainability practices. The framework includes a total of 140 questions, categorized into two main groups: essential indicators and leadership indicators. Here’s a breakdown of the questions within these categories:

Essential Indicators (98 Questions): These questions focus on key sustainability and business responsibility aspects that companies are required to disclose. They cover topics like Environmental Performance, Social Responsibility, Corporate Governance and Stakeholder Engagement.

Leadership Indicators (42 Questions): These questions are focused on evaluating a company’s leadership and strategic approach to sustainability and business responsibility. These questions cover Sustainability Strategy, Stakeholder Engagement Strategy and Sustainability Reporting.

These questions are designed to help companies assess and report on their ESG performance, identify areas for improvement, and demonstrate their commitment to responsible and sustainable business practices. The introduction of the BRSR framework reflects SEBI’s commitment to promoting responsible and sustainable business practices among Indian listed companies. It aligns with global trends in ESG reporting and encourages companies to assess, report on, and improve their ESG performance. The framework is intended to provide investors and stakeholders with greater insights into a company’s sustainability efforts and its commitment to ethical and responsible conduct.

BRSR Core for Assurance

Based   on   the recommendations of the ESG Advisory Committee and pursuant to public consultation, the Board decided to introduce the BRSR Core for assurance by listed entities. The BRSR Core for Assurance refers to a specific subset of the BRSR framework in India that is designated for external assurance or audit. The BRSR Core for Assurance typically covers a specific set of ESG disclosures within the broader BRSR framework. These disclosures are considered critical or material to a company’s sustainability and business responsibility performance. The scope may include disclosures related to environmental impact, social practices, governance standards, and other significant ESG issues. The Board further decided to introduce disclosures and assurance for the value chain of listed entities, as per the BRSR Core for 1000 listed companies as per the timelines provided in circular issued in July 2023.

By introducing external assurance for ESG disclosures, SEBI aims to enhance the credibility and reliability of sustainability reporting in India. SEBI has mandated reasonable assurance of BRSR Core in a phased manner starting with top 150 companies in FY 2023-24 and going up to 1,000 companies by FY 2026-27. Independent verification helps ensure that reported data is accurate, consistent, and meets established standards. Many countries and organizations are increasingly recognizing the importance of independent verification to build trust in sustainability disclosures.

The issuance of standards by the Sustainability Reporting Standards Board (SRSB) is a significant development in the field of sustainability reporting and assurance. The standards, SSAE 3000 and SAE 3410, play a crucial role in providing guidelines for assurance engagements related to sustainability information and greenhouse gas (GHG) statements. Here’s a brief overview of each standard:

• SSAE 3000 sets the framework for assurance engagements on sustainability information. Its primary objective is to guide assurance providers in assessing the reliability and accuracy of sustainability reports and disclosures.
• SAE 3410 specifically addresses assurance engagements related to greenhouse gas (GHG) statements. Its primary objective is to provide assurance providers with guidance on evaluating the completeness and accuracy of GHG emissions data and related disclosures.

KPIs of The BRSR Core

BRSR Core consists of a specific set of Key Performance Indicators (KPIs) or metrics organized under nine ESG attributes. These attributes and associated KPIs are designed to provide a focused and comprehensive view of a company’s ESG performance in critical areas. Here’s a list of these ESG attributes:

• Environmental Performance
• Resource Efficiency
• Biodiversity and Conservation
• Employee Well-being
• Diversity and Inclusion
• Community Engagement
• Ethical Practices
• Governance and Risk Management
• Sustainability Strategy

The BRSR Core provides a structured approach for companies to report on these key ESG attributes and KPIs. It helps investors, stakeholders, and the public assess a company’s performance in these critical areas, facilitating transparency and accountability. The goal is to encourage companies to prioritize and improve their ESG performance and contribute to responsible and sustainable business practices in India.

Nine Core Principles

There are nine core principles in the BRSR have been prepared in line with the National Guidance on Responsible Business Conduct (NGRBC) that encapsulate diverse aspects of business sustainability. They serve as a framework for companies to assess and report on their sustainability and business responsibility practices. Here are the nine core principles:

• Businesses should conduct and govern themselves with integrity, in a manner that is ethical, transparent, and accountable.
• Businesses should provide goods and services that are safe and contribute to sustainability throughout their life cycle.
• Businesses should promote the well-being of all employees.
• Businesses should respect the interests of and be responsive to all stakeholders, especially those who are disadvantaged, vulnerable, and marginalized.
• Businesses should respect and promote human rights.
• Businesses should respect and make efforts to protect and restore the environment.
• Businesses, when engaged in influencing public and regulatory policy, should do so in a responsible manner.
• Businesses should support inclusive growth and equitable development.
• Businesses should engage with and provide value to their customers and consumers in a responsible and sustainable manner.

These nine core principles provide a comprehensive framework for companies to assess and report on their responsible business conduct and sustainability efforts. Companies are encouraged to integrate these principles into their operations, policies, and reporting to contribute to a more responsible and sustainable business landscape.

Challenges

The introduction of the Business Responsibility and Sustainability Report (BRSR) framework in India, with its transition from Form 59 to 140 questions and a focus on quantitative Key Performance Indicators (KPIs), has presented companies with several challenges. Here’s an overview of the challenges faced by companies in adapting to this new reporting framework:

1. Sudden Change in Reporting Format: The shift from Form 59 to 140 questions represents a significant change in reporting requirements. Companies that were previously accustomed to a less detailed reporting format may find it challenging to gather and report on a broader set of sustainability and business responsibility metrics. Adapting to this new format may require additional resources, expertise, and systems for data collection and reporting.
2. Increased Cross-Departmental Collaboration: The BRSR framework’s expanded reporting scope encompasses various ESG attributes and metrics, which may require data and inputs from different departments within the organization. Collaborating across departments such as HR, Environmental Health and Safety (EHS), IT, Research and Development (R&D), Purchasing, Operations, and others can be complex and time-consuming. Companies need to establish efficient data collection and consolidation processes to meet reporting requirements.
3. Elevated Performance Expectations: The BRSR framework places a stronger emphasis on proactive sustainability efforts rather than merely avoiding harm. This shift in focus means that companies are expected to not only mitigate negative impacts but also actively contribute to positive environmental, social, and governance outcomes. Meeting these elevated performance expectations may require companies to set more ambitious sustainability goals, implement innovative sustainability initiatives, and engage with stakeholders more comprehensively.

Despite these challenges, the BRSR framework also presents companies with opportunities to enhance their sustainability performance, improve transparency, and strengthen stakeholder trust. By effectively addressing these challenges, companies can align with global sustainability reporting trends and contribute to more responsible and sustainable business practices.

Conclusion

We conclude our comprehensive exploration of the transformative landscape of Environmental, Social, and Governance (ESG) practices with its final part. As we navigate the evolving landscape of ESG, BRSR, and sustainability reporting, it is evident that businesses play a crucial role in fostering responsible and sustainable practices. This series serves as a guide, emphasizing the importance of transparency, accountability, and a proactive approach to addressing environmental, social, and governance considerations. By embracing these principles, businesses contribute not only to their own resilience and success but also to a more sustainable and responsible global business landscape. Thank you for joining us on this enlightening journey.