Analysis of Pillars Governance(P1-P4)
Analysis of Governance Principles of BRSR Data Authors: Aditya Kulkarni Lakshmi Murthy Anuradha Damle Raghavachari Madhavan For more details, reach out to info@altometa.online With a rapidly evolving business landscape, the importance of analysing companies based on Environmental, Social, and Governance (ESG) criteria has never been more pronounced. The Business Responsibility and Sustainability Report (BRSR) has become an essential framework for analysing the environmental, social, and governance (ESG) performance of companies. Mandated by regulatory bodies like the Securities and Exchange Board of India (SEBI), BRSR provides a standardized approach for Indian companies to disclose their sustainability practices, making it easier to evaluate and compare their commitment to responsible business operations. In this report we present an analysis of BRSR data filed by companies in FY 2022-23. Executive Summary This analysis of BRSR data focuses on Governance. While data on two principles (P1: Ethics, Transparency, and Accountability and P4: Stakeholder Engagement) are relevant for an understanding of Governance, this analysis focuses on quantitative information for P1. Key findings include: Varied Awareness: Training Variety Score for employees and workers is significantly lower than for Key Management Personnel and Board of Directors. Data Quality Issues: Inconsistent and potentially inaccurate reporting of conflicts of interest, disciplinary actions, and fines. Market Cap impact: When companies are segmented by market capitalization level, each segment exhibits a similar distribution of varied governance practices. The potential reasons for varied levels of Governance include level of resources dedicated for related programs, structure (or lack thereof) of implementation process, visibility, buy-in and prioritization from senior leadership and perceived value, importance and relevance of the programs. Our recommendations from this analysis are: Employee and Worker Training: Ensure appropriate Training Variety Score and coverage by designing and conducting awareness programs that reach all relevant audiences. Internal process of program implementation: Analyze the factors in “hypotheses of potential reasons” impacting the Governance level to identify and implement required changes to the process of implementing awareness programs. Data Accuracy and Transparency: Review internal data controls, and strengthen as required to ensure accurate and consistent reporting of all relevant data. Best Practices across companies: Support knowledge sharing among companies to foster best practices in ESG reporting and governance. Background & Focus Area The Business Responsibility and Sustainability report (BRSR) framework mandates annual disclosure filing by registered Indian companies to be compliant with the regulatory body SEBI. We use filing data from fiscal years 2022-23 as the basis for this analysis. Please refer to our earlier blog on a detailed review of everything about data: State of Sustainability Disclosures by Indian Companies – Altometa Consulting Our focus in this report is to perform an analysis for evaluating the state of Sustainability (specifically Governance) related disclosure, and classifying companies based on their Governance levels. Organizations can be better informed about their relative standing with respect to compliance, and interested parties (such as Investors) can make informed decisions based on Governance performance of companies. In this analysis we take the following approach: · Map the BRSR principles into Sustainability (ESG) components for analysis · Define factors for analysis of Governance related principles · Analyse the factors and derive insights · Summarize the overall impact and ways to improve Governance metrics of companies Mapping BRSR principles into Sustainability components We categorize the 9 Principles of BRSR, P1 to P9 into the Sustainability components of Environment, Social and Governance as shown in the table below: Environment P2 – Product Lifecycle Sustainability P4 – Stakeholder Engagement P6 – Environmental Management P9 – Consumer Protection-(9.2) Social P3 – Employee Well-being P4 – Stakeholder Engagement P5 – Human Rights P7 – Public Policy Advocacy P8 – Inclusive Growth and Equitable Development P9 – Consumer Protection Governance P1 – Ethics, Transparency, and Accountability P4 – Stakeholder Engagement Of the two principles P1 and P4 related to our focus area of Governance, P1 related disclosures have several numeric quantitative data; however, P4 related disclosures are qualitative and non-numeric. For the purposes of this analysis, we will focus on the numeric disclosures, and hence do not include P4 related data for our analysis. In a future report, we will provide qualitative assessment of the P4 disclosures. Governance Factors in P1 Disclosures (Ethics, Transparency, and Accountability) There are four P1-related numeric disclosure data elements in the BRSR filings: 1) Training and Awareness programs, 2) Conflicts of Interest, 3) Disciplinary Actions, and 4) Fines. 1) Training and Awareness BRSR filings contain data related to training and awareness programs that the company conducts. The goal of these programs is to ensure that people involved in company operations are completely aware of, and fully competent to conduct themselves in compliance with the company’s governance policies and procedures. We identify two aspects of awareness: a) The training variety score (average number of training types per member) and b) The prevalence of awareness within the company (percentage of members in the organization that are covered by trainings). While the prevalence of awareness is necessary for effective governance, we expect that high training variety score would encourage better skills and adherence to policies and procedures. Data on these aspects is available for specific categories of the targeted audience for training: Board of Directors (BOD), Key Management Personnel (KMP), Employees (EMP), Workers (WRK). To enable comparison of performance across companies, we normalize the reported training numbers by the size of each of these constituencies within the company and then aggregate them. These two ratios are created as aggregations: Training Variety Score Training Variety Score refers to the number of training session types offered per person in the target audience. Higher Training Variety Score values are desirable, as higher variety indicates a better chance that the company’s workforce is offered role-relevant training. We will provide an analysis of the Training Variety Score for each workforce segment. Percent Coverage (of Awareness) –Awareness Coverage Since availability of training variety is not sufficient to characterize the participation levels, we also define Percent Coverage as the proportion ofindividuals reached by the training program, expressed as a percentage. We will provide an analysis of Percent Coverage for each workforce segment. 2) Conflicts of Interest



