Focal Point India. Guidance on Alignment of the GRI G3.1 Guidelines, NVGs and BRR

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1 Focal Point India Guidance on Alignment of the GRI Guidelines, NVGs and BRR

2 About the Global Reporting Initiative The Global Reporting Initiative (GRI) promotes the use of sustainability reporting as a way for organizations to become more sustainable and contribute to a sustainable global economy. GRI s mission is to make sustainability reporting standard practice. To enable all companies and organizations to report their economic, environmental, social and governance performance, GRI produces free Sustainability Reporting Guidelines. GRI is an international, not-for-profit, network-based organization; its activity involves thousands of professionals and organizations from many sectors, constituencies and regions. GRI was set up in the US in 1997 by CERES, with support from the United Nations Environment Programme (UNEP). Its Secretariat is located in Amsterdam, The Netherlands, and there are GRI Focal Points regional offices in Australia, Brazil, China, India, South Africa, and the USA. GRI enjoys strategic partnerships with the Organisation for Economic Cooperation and Development (OECD), the UN Global Compact, UNEP, and the International Organization for Standardization (ISO). To achieve its mission of making sustainability reporting standard practice, GRI is: y Standardizing sustainability reporting and providing up-to-date reporting guidance y Creating capacity through training and outreach y Promoting a Report or Explain approach to sustainability reporting policy y Supporting the development of integrated reporting Contact: info@globalreporting.org GRI Vision A sustainable global economy where organizations manage their economic, environmental, social, and governance performance and impacts responsibly, and report transparently. GRI ission To make sustainability reporting standard practice by providing guidance and support to organizations. About GRI s publications GRI s publications investigate issues around reporting, and suggest innovative ways to apply GRI s Reporting Framework, including with other standards. Copyright This document is copyright-protected by Stichting Global Reporting Initiative (GRI). The reproduction and distribution of this document for information is permitted without prior permission from GRI. However, neither this document nor any extract from it may be reproduced, stored, translated, or transferred in any form or by any means (electronic, mechanical, photocopies, recorded, or otherwise) for any other purpose without prior written permission from GRI. Global Reporting Initiative, the Global Reporting Initiative logo, Sustainability Reporting Guidelines, and GRI are trademarks of the Global Reporting Initiative GRI

3 About GRI Focal Point India GRI Focal Point India was established in January 2010, and is hosted by the German International Corporation, India (GIZ) until December The Focal Point has an important strategic collaboration with the Indian Institute of Corporate Affairs (IICA), an independent think tank under the inistry of Corporate Affairs, Government of India, through the IICA-GIZ CSR initiative. Focal Point India operates at the heart of the CSR and sustainability landscape in India. Contact Dr. Aditi Haldar Director- GRI Focal Point India GRI would like to thank Deutsche Geselleschaft für Internationale Zusammenarbeit (GIZ) GmbH for their financial support for this project Contributors Bastian Buck, GRI Senior anager Reporting Dr. Aditi Haldar, Director, GRI Focal Point India Anna Nefedova, Deloitte Nikki ckean-wood, GRI Senior anager Network Relations Rubina Sen, Coordinator, GRI Focal Point India Framework All stakeholders who participated in public consultations, including in umbai, Delhi, and Kolkata Layout Duncan ckean sparkwoodand21.com Disclaimer Neither the GRI Board of Directors, the Stichting Global Reporting Initiative or its project partners can assume responsibility for any consequences or damages resulting, directly or indirectly, from the use of GRI publications. The findings and views expressed herein do not necessarily represent the views, decisions or the stated policy of GRI or project partners, nor does citing of trade names or commercial processes constitute endorsement. Cover PHOTO anuel enal en.wikipedia.org/wiki/file:howrah_bridge,_kolkota.jpg

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5 Foreword Sustainability reporting is rapidly becoming the norm for large companies in many parts of the world. Some 95% of the largest 250 companies globally now produce a sustainability report, and four out of five of these choose to use the GRI Guidelines. Sustainability reporting is an important source of information for many stakeholders including civil society, investors, labour organisations, employees and the general public, and plays a key role in enhancing trust and promoting dialogue. In parallel with the upward trend in voluntary reporting, in many countries the state is playing an increasingly important role in promoting a culture of transparency and accountability. There is a growing emphasis on the need to combine complementary voluntary and mandatory approaches to organisational disclosure, as many more governments, market regulators and stock exchanges initiate policies and regulation on sustainability reporting. Through responsible and sustainable business conduct, companies can contribute to a more cohesive society and to sustainable growth. Governments, businesses and stakeholders directly benefit and the positive impact on social, environmental and human rights issues is evident. India has a long history of non-financial reporting, with initiatives going back to the eighties when the government made it a requirement for companies to report information to the authorities on various aspects of their operations including environmental, labour and employment conditions, and health and safety. In this context, the Companies Bill and its Rules of Implementation have the opportunity to add value to India s roadmap towards inclusive growth and development. Despite the widespread recognition of the value of Corporate Social Responsibility, Indian businesses often struggle to effectively achieve their CSR goals due to complex socio-economic challenges. There is still much to be done to incorporate environmental and social costs and benefits into mainstream financial reporting in India, but the recent developments and initiatives represent a growing positive trend. The evolutionary course of sustainability reporting is now taking shape as more companies move from informal statements to formal reporting. This pivotal initiative of making the linkage between the GRI Sustainability Reporting Guidelines, the National Voluntary Guidelines (NVGs) and the Business Responsibility Report (BRR) is in line with the requests of reporting entities that need to streamline their reporting work and look for alignment among the various reporting requirements and recommendations they strive to live up to. Warm Regards, Bhaskar Chatterjee Director General & CEO Guidance on Alignment of the GRI Guidelines, NVGs and BRR 5

6 Introduction GRI Focal Point India has developed this publication to break new paths, increasing both the quality and quantity of sustainability reports in India. y vision is that through linking GRI s Guidelines with India s NVGs and BRR framework, we will unburden existing Indian reporters from the difficulties of using multiple frameworks, and encourage new Indian reporters to take the first steps in reporting, safe in the knowledge that they are using all available guidance. I would like to personally thank all of our contributors to this document, including the diverse array of stakeholders who gave insightful comments on the document development in umbai, Delhi and Kolkata, and online, over the course of the project. I hope that you find this document interesting and instructive, as we progress together towards greater business responsibility and transparency. The GRI Sustainability Reporting Framework is continuously evolving, and we will strive to keep this linkage document up-to-date, particularly given the exciting launch of the G4 Guidelines this year. Dr. Aditi Haldar Director, GRI Focal Point India 6 Guidance on Alignment of the GRI Guidelines, NVGs and BRR

7 Executive Summary The sustainability of companies and their contributions to sustainable development are intrinsically linked. An effective sustainability reporting process can be vital for strengthening companies performance in both areas. This publication informs organizations in India about the complementarities and linkages between Indian and global guidance for sustainability reporting. It shows the linkages between: y The Business Responsibility Report (BRR) disclosure framework provided by the Securities Exchange Board of India (SEBI) y The business responsibility Principles in India s National Voluntary Guidelines (NVGs), released by the inistry of Corporate Affairs (CA), on which the SEBI BRR framework is based y The GRI Sustainability Reporting Framework The three instruments are complementary, and organizations can use and report against them in combination. The publication features: y Brief summaries of the BRR disclosure framework, the NVGs, and GRI s Framework y Background information on these instruments, their basic features and commonalities y A table presenting technical mapping of the complementarities and the options for combined use and reporting The publication is valuable for: y Organizations that already report against GRI s Framework and that must comply with the NVGs and SEBI BRR framework, or want to develop their reporting to meet these requirements y Organizations that want to start the sustainability reporting process and are looking for guidance [particularly top 100 companies listed on the National Stock Exchange (NSE) or Bombay Stock Exchange (BSE)] y Other interested stakeholders that use information contained in Indian sustainability reports, such as regulatory bodies, advisory organizations, civil society organizations, mediating institutions and academics Guidance on Alignment of the GRI Guidelines, NVGs and BRR 7

8 Sustainability reporting in India Recent milestones in Indian reporting Year Description 2009 Release of Voluntary Guidelines on Corporate Social Responsibility by the inistry of Corporate Affairs (CA) of the Government of India 2011 Launch of GRI s Guidelines - an update and completion of the third generation of the Guidelines 2011 Launch of India s National Voluntary Guidelines (NVGs) based on a revision of the Voluntary Guidelines 2012 The Securities Exchange Board of India (SEBI) releases a circular which mandates inclusion of Business Responsibility Reports (BRR) as part of the Annual Reports of top 100 listed companies based on market capitalization of the NSE and BSE 2013 Release of Guidelines on Corporate Social Responsibility and Sustainability for Central Public Sector Enterprises 2013 Release of GRI s G4 Guidelines The National Voluntary Guidelines (NVGs) on Social, Environmental and Economical Responsibilities of Business, launched by the inistry of Corporate Affairs (CA) in July 2011, strengthened the Indian corporate sector in its ambition to become a global leader in responsible business. The NVGs are a refinement of the Voluntary Guidelines on Corporate Social Responsibility released by CA in December 2009, incorporating significant stakeholder feedback. The NVGs provide nine broad-based Principles on responsible business behavior, each with recommended Core Elements. They have two basic aims: First, to help companies use their entrepreneurship to effectively contribute to the economic and social betterment of communities; and second, to make their operations sustainable in a manner that enables them to meet their current needs without compromising the needs of future generations. 8 Guidance on Alignment of the GRI Guidelines, NVGs and BRR

9 Principles of the National Voluntary Guidelines Principle 1: conduct and govern themselves with Ethics, Transparency and Accountability Principle 5: respect and promote human rights Principle 2: provide goods and services that are safe and contribute to sustainability throughout the life cycle Principle 3: promote the well-being of employees Principle 4: respect the interests of, and be responsive towards all stakeholders, especially the disadvantaged, vulnerable and marginalised Principle 6: respect, protect and make efforts to restore the environment Principle 7: Businesses when engaged in influencing public and regulatory policy should do so in a responsible manner Principle 8: support inclusive growth and Equitable Development Principle 9: engage with and provide value to their customers and consumers in a responsible manner Core Elements the purpose of the Core Elements is to actualize and implement the Principles. The Core Elements should provide a very clear basis for putting each Principle into practice. In August 2012, the Securities and Exchange Board of India (SEBI) released a circular which mandated the inclusion of Business Responsibility Reports (BRR) in the Annual Reports of the top 100 companies by market capitalization listed on the Bombay and National Stock Exchanges. The SEBI BRR disclosure framework is based on the NVGs. The framework has five sections with specific disclosure items. Section A - disclose general organizational information. Section B seeks information on companies financial details. Other details are covered in Section C. In Section D, information is requested on whether companies publish a BRR or sustainability report, and on the frequency of their reporting. A hyperlink to any report is also requested. In the same section, companies are asked to disclose if they have Business Responsibility policies for the nine Principles of the NVGs, and to explain why if they do not have such policies. In Section E, companies need to demonstrate their performance against each of the NVG Principles through reporting. An annex provides guidelines to stock exchanges on how to evaluate companies compliance with the framework ( Principles to assess compliance with Environmental, Social and Governance norms ). For more information, visit: Guidance on Alignment of the GRI Guidelines, NVGs and BRR 9

10 Global Reporting: The GRI Sustainability Reporting Framework GRI s Sustainability Reporting Framework has many elements that relate directly to the NVGs and therefore the SEBI BRR disclosure framework. GRI s Guidelines feature Reporting Principles and Standard Disclosures. The 10 Principles offer guidance on best practice for preparing a sustainability report, and are: yateriality y Stakeholder Inclusiveness y Sustainability Context ycompleteness y Balance y Comparability y Accuracy ytimeliness y Clarity y Reliability The Disclosures include items that request information about an organization s strategy and profile; Disclosures on anagement Approach, which concern how an organization manages its sustainability performance and impacts; and Indicators, which are usually metrics for calculating specific sustainability-related data. The Guidelines contents are organized into three Categories: Economic, Environmental and Social. The Social Category is broken down further by Labor, Human Rights, Society, and Product Responsibility sub- Categories. GRI also provides sector guidance. By 2012, GRI had published 10 Sector Supplements versions of its Guidelines that are tailored to address the sustainability issues of specific sectors. GRI strives for its Framework to harmonize with other reporting tools worldwide. The Guidelines include broad references to other global initiatives. This makes it easier for organizations to understand how complementary guidance can be used together, helping them prepare reports swiftly. Alignments and synergies between GRI s Framework and other instruments include those with: y The UN Global Compact Principles and Communication on Progress y The OECD Guidelines for ultinational Enterprises y ISO (the International Organization for Standardization) y The Carbon Disclosure Project Questionnaire For more information, visit: 10 Guidance on Alignment of the GRI Guidelines, NVGs and BRR

11 Background information: some basic features of the three instruments, and their commonalities Applicability Both the NVGs and GRI s Framework are applicable to all organizations regardless of their size, sector and ownership structure. The NVGs are tailored to the needs of Indian businesses; the GRI Framework is applicable to organizations wherever they are based or operate. Applicability of the SEBI BRR framework In arch 2012, the requirement to include BR Reports as part of Annual Reports became mandatory for top 100 entities based on market capitalization listed on BSE and NSE. Other listed entities may voluntarily disclose BR Reports as part of their Annual Reports. Listed entities which already submitted sustainability reports to overseas regulatory agencies and stakeholders, based on internationally accepted reporting frameworks, need not prepare a separate report to address the SEBI requirement. Instead, they may provide stakeholders with their existing report, together with details of the reporting framework they have used and mapping of their disclosures against the NVG-based principles featured in the SEBI requirement. Applicability of the National Voluntary Guidelines The National Voluntary Guidelines are designed to be used by all businesses irrespective of size, sector or location. It is expected that all businesses in India, including multinationals that operate in the country, will consciously work towards following the NVGs. The NVGs also provide a framework for responsible business action for Indian multinationals planning to invest or already operating in other parts of the world. The NVGs are also applicable across the value chain, and businesses are encouraged to move beyond their recommended minimum provisions. Businesses are therefore encouraged to ensure that not only do they follow the NVGs for areas within their immediate control or sphere of influence, but should encourage and support their vendors, distributors, partners and other collaborators across their value chains to follow the NVGs. It is also emphasized that if a business endeavours to function responsibly, it should adopt all nine NVG Principles in their entirety, rather than selectively. Applicability of the GRI Framework Users of GRI s Framework are encouraged to view sustainability reporting as a living process, which does not begin or end with a printed or online publication. Reporting should fit into a broader process for setting organizational strategy, implementing action plans, and assessing outcomes. All organizations private, public, or non-profit are encouraged to report against GRI s Guidelines, whether they are beginner or experienced reporters, and regardless of their size, sector, or location. Reporting can take various forms, including web or print, standalone, or combined with annual or financial reports. Guidance on Alignment of the GRI Guidelines, NVGs and BRR 11

12 The Reporting Process Reporting Approach The SEBI BRR framework is based on the Apply or Explain principle, which is also the fundamental basis of the NVGs. Section D of the SEBI BRR framework seeks an explanation if information is not reported. Users of GRI s Framework may determine the content of their report and their level of disclosure. However, GRI does support the Report or Explain approach to sustainability reporting policy, based on the principle that companies should report their performance and impacts or explain why if they do not. (For more information, visit report-or-explain/pages/default.aspx) Determining which topics to report In Section D (Governance related to the BRR), information is sought on whether the company publishes a BR or sustainability report. Companies are asked to disclose if they have BR policies against the nine Principles of the NVGs, and to explain why if they do not. The NVGs feature a section on anagement System and Processes for responsible business, and indicators that companies can adopt. The processes focus on changes in the leadership and leadership structure of the company, the integration of the NVG Principles and Core Elements into its business purpose, and the continuous engagement of stakeholders. The NVGs stress that a report should be based on the mission, vision and values of the business that is, that the report should cover the topics that are most critical and core to the business and its stakeholders. The Guidelines feature the ateriality Principle: The information in a report should reflect the organization s significant economic, environmental and social impacts, or information that would substantively influence the assessments and decisions of stakeholders. GRI provides extensive guidance on using the ateriality Principle in the Technical Protocol - Applying the Report Content Principles. In addition, the GRI Guidelines offer tips on stakeholders involvement in the reporting process, under the Principle of Stakeholder Inclusiveness. The determination of report content should be made by considering both the organization s purpose and experience, and the reasonable expectations and interests of its stakeholders. GRI s recommended three steps for defining report content are Identification, Prioritization and Validation. Identification aims to create a shortlist of relevant topics that should be assessed for inclusion in the report. Prioritization involves examining all identified topics that could be included, assessing which are material, and deciding the level of coverage and detail they will be afforded; the relative reporting priority. Validation requires all identified material Aspects a GRI term for sustainability topics to be assessed using the Reporting Principle of Completeness prior to gathering the information to be reported. This ensures that Aspects are checked against the dimensions of Scope, Boundary and Time. If necessary, adjustments should be made to the selection and coverage of the material Aspects. The first step in the reporting process recommended by GRI is to determine the report content, in consultation with stakeholders. All organizations should describe the scope of their reporting, and are encouraged to indicate plans for expanding that scope over time. 12 Guidance on Alignment of the GRI Guidelines, NVGs and BRR

13 Topics, Categories, Aspects, Disclosures on anagement Approach and Performance Indicators Report IDENTIFICATION PRIORITIZATION VALIDATION Sustainability Context ateriality Stakeholder Inclusiveness Completeness REVIEW Fig.1 from GRI's Guidelines Ensuring the Quality of GRI s Reporting Principles of Clarity, Accuracy, Balance, Timeliness, Comparability and Reliability offer guidance for ensuring the quality of reported information. The report should present information that is timely and accurate, in a way that is understandable, accessible, and usable by the organization s entire range of stakeholders. Stakeholders As part of their implementation guidance, the NVGs emphasize Building strong relationships and engaging with stakeholders on a consistent and continuous basis. Principle 4 encourages attention being placed on internal and external stakeholders, with focus on marginalized stakeholders. In Section D of the SEBI BRR framework, companies are asked to disclose if they have a BR policy formulated through stakeholder consultation, and if the policy has been formally communicated to all relevant internal and external stakeholders. It further asks companies if they address stakeholder grievances following their policies. The GRI Guidelines feature the Principle of Stakeholder Inclusiveness: The reporting organization should identify its stakeholders and explain in the report how it has responded to their reasonable expectations and interests. The rest of this document presents a comparison table of the complementarities, and possibilities for combined reporting, between GRI s Guidelines, the NVGs, and BRR. Guidance on Alignment of the GRI Guidelines, NVGs and BRR 13

14 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / Profile Disclosures 1.1 Statement from the most senior decision-maker of the organization. A-2 "Priorities in terms of Principle and Core Elements Any Significant Risk that the business would like its stakeholders to know 1.2 Description of key impacts, risks, and opportunities 6- Environment 3 Does the company identify and assess potential environmental risks? Y/N Any Goals and Targets that were set by the top management for improving their performance during the Reporting Period" L A-2 "Priorities in terms of Principle and Core Elements Any Significant Risk that the business would like its stakeholders to know 2- Products Life Cycle Sustainability 1 List up to 3 of your products or services whose design has incorporated social or environmental concerns, risks and/or opportunities. Any Goals and Targets that were set by the top management for improving their performance during the Reporting Period" Guidance on Alignment of the GRI Guidelines, NVGs and BRR 14

15 2.1 Name of the organization. Section A: General about the Company 2.2 Primary brands, products, and/or service 2.3 Operational structure of the organization, including main divisions, operating companies, subsidiaries, and joint ventures. 2.4 Location of organization's headquarters. Section A: General about the Company Section A: General about the Company Section C: Other Details Section A: General about the Company 2 Name of the company A-1 Basic details of the business Name; nature of ownership; details of the people in top management; location of its operations - national and international; products and services offered; markets served; 7 Sector(s) that the Company is engaged in (industrial activity code-wise) 8 List three key products/ services that the Company manufactures/provides (as in balance sheet) 1 Does the Company have any Subsidiary Company/ Companies? A-1 Basic details of the business Name; nature of ownership; details of the people in top management; location of its operations - national and international; products and services offered; markets served; A-1 Basic details of the business Name; nature of ownership; details of the people in top management; location of its operations - national and international; products and services offered; markets served; 3 Registered address A-1 Basic details of the business Name; nature of ownership; details of the people in top management; location of its operations - national and international; products and services offered; markets served; Guidance on Alignment of the GRI Guidelines, NVGs and BRR 15

16 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / 2.5 Number of countries where the organization operates, and names of countries with either major operations or that are specifically relevant to the sustainability issues covered in the report. 2.6 Nature of ownership and legal form. 2.7 arkets served (including geographic breakdown, sectors served, and types of customers/beneficiaries). 2.8 Scale of the reporting organization. Section A: General about the Company Section C: Other Details Section A: General about the Company Section A: General about the Company 9 "Total number of locations where business activity is undertaken by the Company i. Number of International Locations (Provide details of major 5) ii. Number of National Locations" 1 Does the Company have any Subsidiary Company/ Companies? 7 Sector(s) that the Company is engaged in (industrial activity code-wise) 10 arkets served by the Company Local/State/ National/International L A-1 Basic details of the business Name; nature of ownership; details of the people in top management; location of its operations - national and international; products and services offered; markets served; A-1 Basic details of the business Name; nature of ownership; details of the people in top management; location of its operations - national and international; products and services offered; markets served; A-1 Basic details of the business Name; nature of ownership; details of the people in top management; location of its operations - national and international; products and services offered; markets served; A-1 Economic and Financial Data Sales; Net Profit; Tax Paid; Total Assets; arket Capitalization (for listed companies); number of employees; Guidance on Alignment of the GRI Guidelines, NVGs and BRR 16

17 2.9 Significant changes during the reporting period regarding size, structure, or ownership Awards received in the reporting period. 3.1 Reporting period (e.g., fiscal/calendar year) for information provided. 3.2 Date of most recent previous report (if any). 3.3 Reporting cycle (annual, biennial, etc.) 3.4 Contact point for questions regarding the report or its contents. 3.5 Process for defining report content. 3.6 Boundary of the report (e.g., countries, divisions, subsidiaries, leased facilities, joint ventures, suppliers). See GRI Boundary Protocol for further guidance. Section A: General about the Company Section A: General about the Company Section C: Other Details 6 Financial Year Reported A-1 Reporting Period/Cycle 3 "Governance related to BR Indicate the frequency with which the Board of Directors, Committee of the Board or CEO to assess the BR performance of the Company. Within 3 months, 3-6 months, Annually, ore than 1 year Does the Company publish a BR or a Sustainability Report? What is the hyperlink for viewing this report? How frequently it is published?" 5 id 2 Do the Subsidiary Company/ Companies participate in the BR Initiatives of the parent company? If yes, then indicate the number of such subsidiary company(s) A-1 Reporting Period/Cycle L A-1 Whether the report s based on this framework or any other framework L Guidance on Alignment of the GRI Guidelines, NVGs and BRR 17

18 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / 3.7 State any specific limitations on the scope or boundary of the report (see completeness principle for explanation of scope). 3.8 Basis for reporting on joint ventures, subsidiaries, leased facilities, outsourced operations, and other entities that can significantly affect comparability from period to period and/or between organizations. 3.9 Data measurement techniques and the bases of calculations, including assumptions and techniques underlying estimations applied to the compilation of the Indicators and other information in the report. Explain any decisions not to apply, or to substantially diverge from, the GRI Indicator Protocols. Section C: Other Details 3 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%, ore than 60%] Guidance on Alignment of the GRI Guidelines, NVGs and BRR 18

19 3.10 Explanation of the effect of any re-statements of information provided in earlier reports, and the reasons for such restatement (e.g.,mergers/ acquisitions, change of base years/periods, nature of business, measurement methods) Significant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report Table identifying the location of the Standard Disclosures in the report Policy and current practice with regard to seeking external assurance for the report. 4.1 Governance structure of the organization, including committees under the highest governance body responsible for specific tasks, such as setting strategy or organizational oversight Has the company carried out independent audit/ evaluation of the working of this policy by an internal or external agency 1 "Details of Director/Directors responsible for BR a) Details of the Director/ Director responsible for implementation of the BR policy/policies DIN Number Name Designation b) Details of the BR head 1. DIN Number (if applicable) 2.Name 3.Designation 4.Telephone number 5. id" L "Principle 1: conduct and govern themselves with Ethics, Transparency and Accountability" P-1 "Governance structure of the business, including committees under the Board responsible for organizational oversight. In case no committee is constituted, then the details of the individual responsible for the oversight. andate and composition (including number of independent members and/ or non-executive members) of such committee with the number of oversight review meetings held." Guidance on Alignment of the GRI Guidelines, NVGs and BRR 19

20 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / 4.2 Indicate whether the Chair of the highest governance body is also an executive officer. 4.3 For organizations that have a unitary board structure, state the number and gender of members of the highest governance body that are independent and/or nonexecutive members. 4.4 echanisms for shareholders and employees to provide recommendations or direction to the highest governance body. 3 "Governance related to BR Indicate the frequency with which the Board of Directors, Committee of the Board or CEO to assess the BR performance of the Company. Within 3 months, 3-6 months, Annually, ore than 1 year Does the Company publish a BR or a Sustainability Report? What is the hyperlink for viewing this report? How frequently it is published?" "Principle 1: conduct and govern themselves with Ethics, Transparency and Accountability" "Principle 1: conduct and govern themselves with Ethics, Transparency and Accountability" "Principle 1: conduct and govern themselves with Ethics, Transparency and Accountability" P-1 P-1 P-1 State whether the person/ committee head responsible for oversight review is independent from the executive authority or not. If yes, how. andate and composition (including number of independent members and/ or non-executive members) of such committee with the number of oversight review meetings held. echanisms for shareholders and employees to provide recommendations or direction to the Board/ Chief Executive. Guidance on Alignment of the GRI Guidelines, NVGs and BRR 20

21 4.5 Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure arrangements), and the organization's performance (including social and environmental performance). 4.6 Processes in place for the highest governance body to ensure conflicts of interest are avoided. 4.7 Process for determining the composition, qualifications, and expertise of the members of the highest governance body and its committees, including any consideration of gender and other indicators of diversity. 4.8 Internally developed statements of mission or values, codes of conduct, and principles relevant to economic, environmental, and social performance and the status of their implementation. "Principle 1: conduct and govern themselves with Ethics, Transparency and Accountability" "Principle 1: conduct and govern themselves with Ethics, Transparency and Accountability" P-1 P-1 Processes in place for the Board/ Chief Executive to ensure conflicts of interest are avoided. Internally developed statement on Ethics, Codes of Conduct and details of the process followed to ensure that the same are followed Guidance on Alignment of the GRI Guidelines, NVGs and BRR 21

22 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / 4.9 Procedures of the highest governance body for overseeing the organization's identification and management of economic, environmental, and social performance, including relevant risks and opportunities, and adherence or compliance with internationally agreed standards, codes of conduct, and principles. 2.4 "For all nine Principles: Has the policy being approved by the Board? Is yes, has it been signed by D/owner/CEO/appropriate Board Director?" 2.5 For all nine Principles: Does the company have a specified committee of the Board/ Director/Official to oversee the implementation of the policy? 3 "Governance related to BR Indicate the frequency with which the Board of Directors, Committee of the Board or CEO to assess the BR performance of the Company. Within 3 months, 3-6 months, Annually, ore than 1 year Does the Company publish a BR or a Sustainability Report? What is the hyperlink for viewing this report? How frequently it is published?" L "Principle 1: conduct and govern themselves with Ethics, Transparency and Accountability" P-1 Frequency with which the Board/ Chief Executive assess BR performance. Guidance on Alignment of the GRI Guidelines, NVGs and BRR 22

23 4.10 Processes for evaluating the highest governance body's own performance, particularly with respect to economic, environmental, and social performance Explanation of whether and how the precautionary approach or principle is addressed by the organization Externally developed economic, environmental, and social charters, principles, or other initiatives to which the organization subscribes or endorses emberships in associations (such as industry associations) and/or national/ international advocacy organizations in which the organization: * Has positions in governance bodies; * Participates in projects or committees; * Provides substantive funding beyond routine membership dues; or * Views membership as strategic List of stakeholder groups engaged by the organization. 7- Policy Advocacy 1 Is your company a member of any trade and chamber or association? If Yes, Name only those major ones that your business deals with: 2.P4 Principle 4: Businesses should respect the interests of, and be responsive towards all stakeholders, especially those who are disadvantaged, vulnerable and marginalized L Principle 4: respect the interests of, and be responsive towards all stakeholders, especially those who are disadvantaged, vulnerable and marginalised. P-4 Statement on the process of identification of stakeholders and engaging with them Guidance on Alignment of the GRI Guidelines, NVGs and BRR 23

24 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / 4.15 Basis for identification and selection of stakeholders with whom to engage Approaches to stakeholder engagement, including frequency of engagement by type and by stakeholder group. 4- Stakeholder Engagement 4- Stakeholder Engagement 1 Has the company mapped its internal and external stakeholders? Yes/No 2 Out of the above, has the company identified the disadvantaged, vulnerable & marginalized stakeholders. 2.P4 Principle 4: Businesses should respect the interests of, and be responsive towards all stakeholders, especially those who are disadvantaged, vulnerable and marginalized 2.2 Has the policy being formulated in consultation with the relevant stakeholders? 2.7 Has the policy been formally communicated to all relevant internal and external stakeholders? L Principle 4: respect the interests of, and be responsive towards all stakeholders, especially those who are disadvantaged, vulnerable and marginalised. L Principle 4: respect the interests of, and be responsive towards all stakeholders, especially those who are disadvantaged, vulnerable and marginalised. P-4 P-4 Statement on the process of identification of stakeholders and engaging with them Statement on the process of identification of stakeholders and engaging with them Guidance on Alignment of the GRI Guidelines, NVGs and BRR 24

25 4.17 Key topics and concerns that have been raised through stakeholder engagement, and how the organization has responded to those key topics and concerns, including through its reporting. Economic Category Aspect: Economic Performance 4- Stakeholder Engagement 4- Stakeholder Engagement 5- Human Rights DA 2 Out of the above, has the company identified the disadvantaged, vulnerable & marginalized stakeholders. 2.9 Does the Company have a grievance redressal mechanism related to the policy/policies to address stakeholders grievances related to the policy/policies? 2 Out of the above, has the company identified the disadvantaged, vulnerable & marginalized stakeholders. 2 How many stakeholder complaints have been received in the past financial year and what percent was satisfactorily resolved by the management? 2.P2 Principle 2: Businesses should provide goods and services that are safe and contribute to sustainability throughout their life cycle 2.P8 Principle 8: support inclusive growth and equitable development 2.1 Do you have a policy/policies for... L Principle 4: respect the interests of, and be responsive towards all stakeholders, especially those who are disadvantaged, vulnerable and marginalised. P-4 Statement on significant issues on which formal dialogue has been undertaken with any of the stakeholder groups L A-2 Any Goals and Targets that were set by the top management for improving their performance during the Reporting Period Guidance on Alignment of the GRI Guidelines, NVGs and BRR 25

26 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / 2.2 Has the policy being formulated in consultation with the relevant stakeholders? 2.3 Does the policy conform to any national /international standards? If yes, specify? (50 words) 2.4 Has the policy being approved by the Board? Is yes, has it been signed by D/owner/CEO/appropriate Board Director? 2.5 Does the company have a specified committee of the Board/ Director/Official to oversee the implementation of the policy? 2.6 Indicate the link for the policy to be viewed online? 2.7 Has the policy been formally communicated to all relevant internal and external stakeholders? 2.8 Does the company have in-house structure to implement the policy/ policies. 2.9 Does the Company have a grievance redressal mechanism related to the policy/policies to address stakeholders grievances related to the policy/policies? Guidance on Alignment of the GRI Guidelines, NVGs and BRR 26

27 EC1 Direct economic value generated and distributed, including revenues, operating costs, employee compensation, donations and other community investments, retained earnings, and payments to capital providers and governments. EC2 Financial implications and other risks and opportunities for the organization's activities due to climate change. EC3 Coverage of the organization's defined benefit plan obligations. EC4 Significant financial assistance received from government. Aspect: arket Presence EC5 Range of ratios of standard entry level wage by gender compared to local minimum wage at significant locations of operation. Section B: Financial Details of the Company Section B: Financial Details of the Company Section B: Financial Details of the Company 2.10 Has the company carried out independent audit/ evaluation of the working of this policy by an internal or external agency? 1 Paid up Capital (INR) A-1 Economic and Financial Data Sales; Net Profit; Tax Paid; Total Assets; arket Capitalization (for listed companies); number of employees; 2 Total Turnover (INR) 3 Total profit after taxes (INR) Guidance on Alignment of the GRI Guidelines, NVGs and BRR 27

28 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / EC6 Policy, practices, and proportion of spending on locally-based suppliers at significant locations of operation. EC7 Procedures for local hiring and proportion of senior management hired from the local community at significant locations of operation. Aspect: Indirect Economic Impacts EC8 Development and impact of infrastructure investments and services provided primarily for public benefit through commercial, in-kind, or pro bono engagement. 2- Products Life Cycle Sustainability 2- Products Life Cycle Sustainability 3 Does the company have procedures in place for sustainable sourcing (including transportation)? 4 "Has the company taken any steps to procure goods and services from local & small producers, including communities surrounding their place of work? If yes, what steps have been taken to improve their capacity and capability of local and small vendors?" "Principle 2: provide goods and services that are safe and contribute to sustainability throughout their life cycle" P-2 Statement on use of sustainable practices used in the value chain L Guidance on Alignment of the GRI Guidelines, NVGs and BRR 28

29 EC9 Understanding and describing significant indirect economic impacts, including the extent of impacts. Environmental Category DA 2.P2 Principle 2: Businesses should provide goods and services that are safe and contribute to sustainability throughout their life cycle 2.P6 Principle 6: Business should respect, protect, and make efforts to restore the environment 2.1 Do you have a policy/policies for Has the policy being formulated in consultation with the relevant stakeholders? 2.3 Does the policy conform to any national /international standards? If yes, specify? (50 words) 2.4 Has the policy being approved by the Board? Is yes, has it been signed by D/owner/CEO/appropriate Board Director? 2.5 Does the company have a specified committee of the Board/ Director/Official to oversee the implementation of the policy? 2.6 Indicate the link for the policy to be viewed online? A-2 Any Goals and Targets that were set by the top management for improving their performance during the Reporting Period Guidance on Alignment of the GRI Guidelines, NVGs and BRR 29

30 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / Aspect: aterials EN1 aterials used by weight or volume. 6- Environment 6- Environment 2.7 Has the policy been formally communicated to all relevant internal and external stakeholders? 2.8 Does the company have in-house structure to implement the policy/ policies. 2.9 Does the Company have a grievance redressal mechanism related to the policy/policies to address stakeholders grievances related to the policy/policies? 2.10 Has the company carried out independent audit/ evaluation of the working of this policy by an internal or external agency? 3 Does the company identify and assess potential environmental risks? Y/N 3 Does the company identify and assess potential environmental risks? Y/N Guidance on Alignment of the GRI Guidelines, NVGs and BRR 30

31 EN2 Percentage of materials used that are recycled input materials. Aspect: Energy EN3 Direct energy consumption by primary energy source. EN4 Indirect energy consumption by primary source. EN5 Energy saved due to conservation and efficiency improvements. 2- Products Life Cycle Sustainability 6- Environment 5 Does the company have a mechanism to recycle products and waste? If yes what is the percentage of recycling of products and waste (separately as <5%, 5-10%, >10%). Also, provide details thereof, in about 50 words or so. 5 Has the company undertaken any other initiatives on clean technology, energy efficiency, renewable energy, etc. Y/N. If yes, please give hyperlink for web page etc. L "Principle 2: provide goods and services that are safe and contribute to sustainability throughout their life cycle" "Principle 6: Business should respect, protect, and make efforts to restore the environment." "Principle 6: Business should respect, protect, and make efforts to restore the environment." "Principle 6: Business should respect, protect, and make efforts to restore the environment." "Principle 6: Business should respect, protect, and make efforts to restore the environment." "Principle 6: Business should respect, protect, and make efforts to restore the environment." P-2 P-6 P-6 P-6 P-6 P-6 Statement on the use of recyclable raw materials used Percentage of materials used that are recycled input materials Total energy consumed by the business entity for its operations Use of renewable energy as percentage of total energy consumption Total energy consumed by the business entity for its operations Statement on use of energy saving processes and the total energy saved due to use of such processes Guidance on Alignment of the GRI Guidelines, NVGs and BRR 31

32 BRR (SEBI) NVG ITE TITLE SECTION # TITLE ATCH / SECTION # TITLE ATCH / EN6 Initiatives to provide energyefficient or renewable energy based products and services, and reductions in energy requirements as a result of these initiatives. 6- Environment 6- Environment 2- Products Life Cycle Sustainability 2 Does the company have strategies/ initiatives to address global environmental issues such as climate change, global warming, etc? Y/N. If yes, please give hyperlink for webpage etc. 5 Has the company undertaken any other initiatives on clean technology, energy efficiency, renewable energy, etc. Y/N. If yes, please give hyperlink for web page etc. 2 "For each such product, provide the following details in respect of resource use (energy, water, raw material etc.) per unit of product(optional): i. Reduction during sourcing/ production/ distribution achieved since the previous year throughout the value chain? ii. Reduction during usage by consumers (energy, water) has been achieved since the previous year?" L "Principle 2: provide goods and services that are safe and contribute to sustainability throughout their life cycle" "Principle 6: Business should respect, protect, and make efforts to restore the environment." P-2 P-6 "Statement on use of energyefficient technologies, designs and manufacturing/ service-delivery processes" Statement on use of energy saving processes and the total energy saved due to use of such processes Guidance on Alignment of the GRI Guidelines, NVGs and BRR 32

33 EN7 Initiatives to reduce indirect energy consumption and reductions achieved. Aspect: Water EN8 Total water withdrawal by source. 2- Products Life Cycle Sustainability 6- Environment 6- Environment 2- Products Life Cycle Sustainability 2.i """For each such product, provide the following details in respect of resource use (energy, water, raw material etc.) per unit of product(optional): i. Reduction during sourcing/ production/ distribution achieved since the previous year throughout the value chain?""" 2 Does the company have strategies/ initiatives to address global environmental issues such as climate change, global warming, etc? Y/N. If yes, please give hyperlink for webpage etc. 5 Has the company undertaken any other initiatives on clean technology, energy efficiency, renewable energy, etc. Y/N. If yes, please give hyperlink for web page etc. 2 "For each such product, provide the following details in respect of resource use (energy, water, raw material etc.) per unit of product(optional): i. Reduction during sourcing/ production/ distribution achieved since the previous year throughout the value chain? ii. Reduction during usage by consumers (energy, water) has been achieved since the previous year?" L "Principle 2: provide goods and services that are safe and contribute to sustainability throughout their life cycle" "Principle 6: Business should respect, protect, and make efforts to restore the environment." L "Principle 6: Business should respect, protect, and make efforts to restore the environment." Guidance on Alignment of the GRI Guidelines, NVGs and BRR 33 P-2 P-6 P-6 "Statement on use of energyefficient technologies, designs and manufacturing/ service-delivery processes" Statement on use of energy saving processes and the total energy saved due to use of such processes Total water consumed and the percentage of water that is recycled and reused