A Handbook on
Regulatory
ESG
Road Accident
Investigation method
Reporting in India
and RCA findings
CONTENTS
04
What is ESG?
06
Why report ESG?
08
What gets reported in ESG reports
12
National Voluntary Guideline
18
Preparation of report
What is ESG?
The term ESG, representing
environmental, social, and
governance, was first coined
in 2005 in a landmark study
(or initiative) titled “Who Cares
Wins” (WCW). It was initiated
by the UN Secretary-General
and UN Global Compact in
2004 in collaboration with the
Swiss government.
4 | A Handbook on Regulatory ESG Reporting in India
Environmental, Social, and Governance The term ESG is often used as a synonym
(ESG) represent the company’s efforts to for sustainability, CSR, public relations, social
systematically assess, manage, and monitor investment, or environmental compliance.
risks of the potential impact on the strategic While some of these elements may factor into
and financial decisions of the company. an ESG program, at the center of ESG is the
management of risk and the preservation of
shareholder value.
A Handbook on Regulatory ESG Reporting in India |5
Why report ESG?
Reporting performance on
environmental, social, and
governance issues enables
the company to communicate
with its stakeholders. It is
a communication tool that
plays an important role in
influencing investors that the
company’s actions are sincere.
6 | A Handbook on Regulatory ESG Reporting in India
Investors are concerned about the Customers are concerned about the
sustainability of the organizations in which practices of the organization. They do not
they invest. Reporting environmental, social, want to endorse products that have poor
and governance issues of the organization environmental, social, and governance
provides guidance to the investors. The issues. Shareholders are also concerned
analysis of performance across these ESG about the organization’s ESG performance.
factors helps screen investments. ESG Organizations with good ESG performance
reporting helps investors to avoid companies have higher returns on their investments and
or reduce their investment in organizations lower risks.
that might pose a greater financial risk due
to their environmental performance or other
social or governmental practices.
A Handbook on Regulatory ESG Reporting in India |7
What gets reported in
ESG reports
Typical topics include :-
Governance Environmental Social
Board Quality Climate Change Workforce & Human Capital
zz Independence zz Carbon Emissions zz Inclusion and Diversity
zz Skills and Qualifications zz Fossil Fuel Reserves zz Supply Chain Labor
zz Diversity zz Energy Efficiency zz Workplace Health and
zz Refreshment zz Renewable Energy Safety
zz Board Leadership zz Gender Pay Gap
Management Incentives Resource Management Value Chain
zz Pay-for-Performance zz Water Management zz Product Health and Safety
Alignment zz Raw Materials zz Data Privacy
zz Ownership Requirements zz Energy Sources zz Data Security
zz Metrics and Goals zz Predatory Sales / Pricing
Shareholder Rights Environmental Impact Society and Communities
zz Board Accountability to zz Air Quality zz Community Relations
Shareholders zz Ecological impacts zz Economic Impacts
zz Shareholders’ ability to act zz Critical Incidents zz Human Rights
zz Voting Rights (accidents) zz Corruption
zz Waste Management zz Political Activities
Plastics
8 | A Handbook on Regulatory ESG Reporting in India
Materiality
Materiality assessments are formal exercises aimed at engaging stakeholders to find out how important specific
environmental, social and governance (ESG) issues are to them. The insights gained can then be used to guide
strategy and communication.
Determining materiality
1st 2nd 3rd 4th
Step Step Step Step
To find the organization’s To identify the actual and To assess the significance To prioritize the most
context- potential impacts- of the impact- significant impacts for
zz Who are we? zz What can affect us? zz How much it will reporting-
zz What are the When? affect us? zz What is important
issues facing us? zz Who is affected? to us now?
zz Why? What can zz What can be
change? important to us
later?
Dont’s of ESG
Management
Excessive Focus on Ratings Treating ESG Solely as a Communications Effort
A company approach that focuses exclusively on Communications can help the company amplify its
improving the company’s rating is at risk of allocating messaging, but they cannot substitute for a robust
more resources to “checking boxes” instead of management system that addresses material risks.
developing a strategy that is tailored to the company’s
unique outlook and exposure to risk.
Lack of Board and Management Oversight Disconnect from Business Strategy
The company’s ESG management strategy should An ESG strategy that does not consider the
be positioned as a core part of the company’s vision company’s strategic objectives and does not inform
and values. The involvement of the board and senior the main corporate strategy fails to serve its purpose.
management is key.
Compliance-Oriented Approach Inconsistencies across the Firm
An approach to ESG management focused on Lack of a company-wide strategy and coordination
compliance with rules and regulations may appear leaves significant gaps in the company’s ESG
as reactive and indicate a reluctance to go above and management programs, with potential exposures to
beyond minimum requirements. risk.
Lack of Assessment and Monitoring
Lack of effective monitoring of ESG performance
impedes the company’s ability to make progress and
receive full credit for its ongoing initiatives through
reporting.
A Handbook on Regulatory ESG Reporting in India |9
Global Reporting Initiative (GRI) The Global Reporting Initiative (GRI) is an international
not-for-profit organization, with a network-based
structure. To enable all companies and organizations
to report their economic, environmental, social,
and governance performance, GRI produces free
sustainability reporting guidelines. The first version
of the GRI Guidelines (G1) was published in 2000,
providing the first global framework for sustainability
reporting. In 2001, GRI was established as an
independent, non-profit institution. In 2016, GRI set
the first global standards for sustainability reporting –
the GRI Standards.
Business Responsibility and In May 2021, SEBI issued a circular on “Business
Sustainability Reporting (BRSR) Responsibility and Sustainability Reporting by listed
entities”.
It is an initiative toward ensuring that investors have
access to standardized disclosures (relevant and
comparable information) on ESG parameters. It will
enable investors to identify and assess sustainability-
related risks and opportunities of companies and make
better investment decisions. Companies will be able
to demonstrate better their sustainability objectives,
position, and performance resulting in long-term value
creation. The BRSR shall be applicable to the top 1000
listed entities (by market capitalization). The reporting
shall be voluntary for FY 2021 –22 and mandatory from
FY 2022 –23.
10 | A Handbook on Regulatory ESG Reporting in India
A Handbook on Regulatory ESG Reporting in India | 11
National Voluntary
Guideline
The Ministry of Corporate Affairs (MCA),
Government of India, released a set of guidelines
in 2011 called the National Voluntary Guidelines
on the Social, Environmental and Economic
Responsibilities of Business (NVGs). This was
expected to provide guidance to businesses on
what constitutes responsible business conduct.
In order to align the NVGs with the Sustainable
Development Goals (SDGs) and the ‘Respect’ pillar
of the United Nations Guiding Principles (UNGP)
the process of revision of NVGs was started in
2015. After, revision and the new principles are
called the National Guidelines on Responsible
Business Conduct (NGRBC). As with the NVGs, the
NGRBC has been designed to assist businesses to
perform above and beyond the requirements of
regulatory compliance.
12 | A Handbook on Regulatory ESG Reporting in India
SEBI BRR Framework GRI Standards and Disclosures
Section A: General information about the company
A1 Not covered by the GRI Standards.
A2 GRI 102: General Disclosures; Disclosure 102-1
A3 GRI 102: General Disclosures; Disclosure 102-3
A4 Not covered by the GRI Standards.
A5 GRI 102: General Disclosures; Disclosure 102-53
A6 GRI 102: General Disclosures; Disclosure 102-50
A7 GRI 102: General Disclosures; Disclosure 102-6 (ii)
A8 GRI 102: General Disclosures; Disclosure 102-2 (b)
A9 GRI 102: General Disclosures; Disclosure 102-4
A10 GRI 102: General Disclosures; Disclosure 102-6
Section B: Financial details of the company
B1 GRI 102: General Disclosures; Disclosure 102-7 (a-iv)
B2 GRI 102: General Disclosures; Disclosure 102-7 (a-iii)
B3 GRI 201: Economic Performance; Disclosure 201-1 (a-iii)
B4 GRI 103: Management Approach; Disclosure 103-2 (c-v)
B5 GRI 102: General Disclosures; Disclosure 102-2 (a)
Section C: Other details
C1 GRI 102: General Disclosures; Disclosure 102-45
C2 GRI 102: General Disclosures; Disclosure 102-45 (b)
C3 GRI 102: General Disclosures; Disclosure 102-45
A Handbook on Regulatory ESG Reporting in India | 13
SEBI BRR Framework GRI Standards and Disclosures
Section D: BR Information
D1 GRI 102: General Disclosures; Disclosure 102-20
GRI 102: General Disclosures; Disclosures 102-18 (b), 102-26, 102-43, 102-55 (b-ii)
D2 GRI 103: Management Approach; General requirements for reporting the
management approach, Disclosure 103-2 (c-i and c-vi), Disclosure 103-3
D3 GRI 102: General Disclosures; Disclosures 102-31 and 102-52
Section E: Principle-wise performance
Principle 1
GRI 102: General Disclosures; Disclosure 102-16
P1-1 GRI 103: Management Approach (used together with GRI 205: Anti-corruption);
Disclosure 103-2
P1-2 GRI 102: General Disclosures; Disclosures 102-17 and 102-44
Principle 2
P2-1 GRI 102: General Disclosures; Disclosure 102-2 (b)
GRI 301: Materials; Disclosure 301-2
P2-2 GRI 302: Energy, Disclosures 302-4 and 302-5
GRI 303: Water, Disclosure 303-3
GRI 103: Management Approach (used together with GRI 204: Procurement
P2-3 Practices); Disclosure 103-2
GRI 204: Procurement Practices; Disclosure 204-1
GRI 103: Management Approach (used together with GRI 204: Procurement
P2-4
Practices); Disclosure 103-2
GRI 103: Management Approach (used together with GRI 301: Materials and GRI 306:
Effluents and Waste); Disclosure 103-2
P2-5
GRI 301: Materials; Disclosure 301-3 (a)
GRI 306: Effluents and Waste; Disclosure 306-2
14 | A Handbook on Regulatory ESG Reporting in India
SEBI BRR Framework GRI Standards and Disclosures
Section E: Principle-wise performance
Principle 3
P3-1 GRI 102: General Disclosures; Disclosure 102-7 (a-i)
P3-2 GRI 102: General Disclosures; Disclosure 102-8 (a and b)
P3-3 GRI 102: General Disclosures; Disclosure 102-8 (a)
P3-4 GRI 405: Diversity and Equal Opportunity, Disclosure 405-1 (b-ii)
GRI 407: Freedom of Association and Collective Bargaining; Management approach
P3-5
disclosures
P3-6 Not covered in the GRI Standards.
GRI 103: Management Approach (used together with GRI 406: Non-discrimination,
GRI 408: Child Labor, and GRI 409: Forced or Compulsory Labor); Disclosure 103-2
P3-7
(c-vi)
GRI 406: Non-discrimination; Disclosure 406-1 (a)
P3-8 GRI 404: Training and Education; Disclosures 404-2 (a) and 404-3
Principle 4
GRI 101: Foundation; Stakeholder Inclusiveness principle
P4-1
GRI 102: General Disclosures; Disclosures 102-40 and 102-42
GRI 101: Foundation; Stakeholder Inclusiveness principle
P4-2
GRI 102: General Disclosures; Disclosures 102-40 and 102-42
GRI 102: General Disclosures; Disclosure 102-43
GRI 103: Management Approach (used together with GRI 411: Rights of Indigenous
P4-3
peoples and GRI 413: Local Communities); Disclosure 103-2 (c-vii)
GRI 413: Local Communities; Disclosure 413-1 (a-vi)
A Handbook on Regulatory ESG Reporting in India | 15
SEBI BRR Framework GRI Standards and Disclosures
Principle 5
GRI 103: Management Approach (used together with GRI 406: Non-discrimination,
GRI 407: Freedom of Association and Collective Bargaining, GRI 408: Child Labor,
P5-1
GRI 409: Forced or Compulsory Labor, GRI 410: Security Practices, GRI 411: Rights of
Indigenous peoples, and GRI 412: Human Rights Assessment): Disclosure 103-2 (c-i)
GRI 103: Management Approach (used together with GRI 406: Non-discrimination,
GRI 407: Freedom of Association and Collective Bargaining, GRI 408: Child Labor,
P5-2
GRI 409: Forced or Compulsory Labor, GRI 410: Security Practices, GRI 411: Rights of
Indigenous Peoples, and GRI 412: Human Rights Assessment); Disclosure 103-2 (c-vi)
Principle 6
GRI 103: Management Approach (used together with GRI 301: Materials, GRI 302:
P6-1 Energy, GRI 303: Water, GRI 304: Biodiversity, GRI 305: Emissions, GRI 306: Effluents
and Waste, and GRI 308: Supplier Environmental Assessment); Disclosure 103-2 (c-1)
GRI 102: General Disclosures; Disclosures 102-14 and 102-15
GRI 103: Management Approach, used together with GRI Standards in the 300 series
P6-2
(Environmental topics); Disclosure 103-2 (c-vii)
GRI 201: Economic Performance; Disclosure 201-2
GRI 102: General Disclosures; Disclosure 102-15
GRI 103: Management Approach, used together with GRI Standards in the 300 series
P6-3
(Environmental topics); Disclosure 103-2 (C-vii)
GRI 201: Economic Performance; Disclosure 201-2
GRI 103: Management Approach (used together with GRI 307: Environmental
P6-4
Compliance); Disclosure 103-2 (c-ii and c-vii)
GRI 103: Management Approach (used together with GRI 301: Materials,
GRI 302: Energy, GRI 303: Water, GRI 304: Biodiversity, GRI 305: Emissions,
P6-5
GRI 306: Effluents and Waste, and GRI 308: Supplier Environmental Assessment);
Disclosure 103-2 (c-vii)
P6-6 Not covered by the GRI Standards.
P6-7 Not covered by the GRI Standards.
16 | A Handbook on Regulatory ESG Reporting in India
SEBI BRR Framework GRI Standards and Disclosures
Principle 7
P7-1 GRI 102: General Disclosures; Disclosure 102-13
P7-2 GRI 415: Public Policy; Management approach disclosures
Principle 8
GRI 103: Management Approach (used together with GRI 203: Indirect Economic
P8-1
Impacts and GRI 413: Local Communities); Disclosure 103-2 (c-vii)
GRI 103: Management Approach (used together with GRI 203: Indirect Economic
P8-2
Impacts and GRI 413: Local Communities); Disclosure 103-2 (a)
P8-3 GRI 413: Local Communities; Disclosure 413-1 (a-i and a-ii)
GRI 201: Economic Performance; Disclosure 201-1 (a-ii)
P8-4
GRI 203: Indirect Economic Impacts; Disclosure 203-1
GRI 103: Management Approach (used together with GRI 203: Indirect Economic
P8-5
Impacts and GRI 413: Local Communities); Disclosure 103-3
Principle 9
GRI 103: Management Approach (used together with GRI 416: Customer Health and
P9-1 Safety, GRI 417: Marketing and Labeling, GRI 418: Customer Privacy, and GRI 419:
Socioeconomic Compliance); Disclosure 103-2 (c-vi)
GRI 103: Management Approach (used together with GRI 417: Marketing and
P9-2
Labeling); Disclosure 103-2 (c-ii)
GRI 417: Marketing and Labeling: Disclosure 417-1
P9-3 GRI 206: Anti-competitive Behavior, Disclosure 206-1
GRI 417: Marketing and Labeling; Disclosures 417-2 and 417-3
P9-4 GRI 102: General Disclosures; Disclosure 102-43
A Handbook on Regulatory ESG Reporting in India | 17
Preparation of report
Standard is created to bring uniformity in
reporting. There are many frameworks and
standards used in reporting ESG performance.
Reports are useful only if they are based on facts
and figures.
Steps to start on ESG reporting
l Identification of relevant ESG requirements
and standards
l ESG gap assessment study
l Stakeholder mapping & materiality
l Plan intervention programs and
Implementation of the plans
l ESG Reporting
Useful Websites
[Link] [Link]
[Link] [Link]
may-2021/Business%20responsibility%20and%20 pdf/NationalGuildeline_15032019.pdf
sustainability%20reporting%20by%20listed%20
entitiesAnnexure1_p.PDF
[Link]
18 | A Handbook on Regulatory ESG Reporting in India
About Consultivo Academy
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Consultivo is uniquely placed to offer advisory and assurance services free from commercial constraints and conflict of
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Consultivo Academy is the strategic business unit for training and capacity building services. It nurtures and enrich people
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Phone 9831145556
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