India’s biggest companies need to move quickly to meet the first BRSR Core submission deadline of June 2024 or risk being in violation of the Listing Obligation and Disclosure Requirements. What are the key steps you need to take to ensure your organisation demonstrates BRSR Core best practice compliance?
Across the entire value chain, from finished product to the metals, minerals and other raw materials that are required to make them, companies are increasingly being asked to demonstrate a clear understanding of the impact they are having on people and the planet.
The Securities and Exchange Board of India (SEBI) is one such organisation seeking to clearly establish ESG obligations for India’s biggest businesses with its new Business Responsibility and Sustainability Reporting (BRSR) Core framework.
BRSR Core was announced in early 2023 and whilst SEBI are yet to announce any penalties for non-compliance, it’s a very thorough piece of legislation that clearly sets out expectations with significant implications for businesses that need to comply. India’s biggest companies need to move quickly to meet the first BRSR Core submission deadline of June 2024 or face being in violation of the Listing Obligation and Disclosure Requirements.
As Achilles Regional Director for APAC, Smitha Shetty says “Complying with BRSR Core can be a complex process – the structure and sheer scale of today’s supply chains mean that ESG issues and their causes can be extremely hard to identify. The data required goes far beyond regular operational boundaries making it very difficult to obtain and maintain. Even if you can capture information, how can companies be sure of the provenance and veracity of the data they are using and demonstrate the level of rigour necessary to meet SEBI’s requirements?”
There are several steps that companies need to take to ensure they are as prepared as possible for BRSR Core submission in June 2024:
- Develop a Due Diligence Policy: Companies should develop a due diligence policy that outlines the processes and measures they will take to mitigate risks in their supply chains. This policy should be aligned with the requirements of the law and should be endorsed at the top level of an organisation prior to being communicated to all relevant stakeholders.
- Know Your Supply Chain: The first step is to understand your supply chain to identify potential ESG risks. This includes identifying high-risk products or suppliers and subcontractors and evaluating their adherence to international standards and regulations.
- Implement Due Diligence Measures: Companies should implement due diligence measures to identify and mitigate risks in their supply chains. This includes conducting risk assessments and audits engaging with suppliers to ensure compliance and implementing risk mitigation measures where necessary.
- Monitor and Evaluate Performance: Companies should monitor and evaluate the performance of their due diligence measures to ensure that they are effective in mitigating risks in their supply chains. This includes tracking supplier performance and conducting regular risk assessments. Monitoring and performance evaluation should support continual improvement within the supply chain.
- Publish Annual Reports: Companies need to publish an annual report on their BRSR Core compliance. These reports should include a description of due diligence processes, identified risks, risk mitigation measures, supplier engagement, remedy measures, verification measures, grievance mechanisms, transparency, and management approach. Read more on BRSR Core reporting requirements here.
- Engage with Stakeholders: Companies should engage with stakeholders, including customers, investors, civil society organizations, and affected communities, to understand their concerns and expectations related to supply chain due diligence.
- Seek External Support: Companies can seek external support from BRSR Core consultants such as Achilles’ partner BDO, and supply chain risk experts, like Achilles to ensure they understand what the law requires and provide the knowledge, experience and global scale required to achieve compliance.
In summary, getting started with BRSR Core requires a broad approach to be truly effective. This should include developing due diligence processes, assessing the supply chain, implementing due diligence measures, monitoring and evaluating performance, publishing a clear annual report that meets SEBI’s requirements and engaging with stakeholders.
To explore how Achilles can help you to achieve BRSR Core compliance within the timescales set out by SEBI contact us to arrange a no obligation initial consultation.