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Reading a real BRSR: Infosys FY24 walkthrough

The fastest way to learn BRSR is to open a filed one and read it. This lesson walks through the Infosys FY24 BRSR end-to-end, page by page, calling out what to notice, what to skip, and what the assurance provider probably looked at hardest. Open the filing in a second tab and read alongside.

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The fastest way to learn BRSR is to open a filed one and read it. Not summarise it, not analyse it. Read it. This lesson walks through the Infosys FY24 BRSR end-to-end. Open the Infosys FY24 Annual Report on the Investor Relations page at infosys.com and turn to the BRSR section (usually numbered pages within the Annual Report; the BRSR runs to roughly 60 pages within a larger Annual Report of 300-plus pages). Read alongside this lesson.

Why Infosys FY24. Three reasons. It is one of the top 10 listed entities by market capitalisation so BRSR Core assurance is mandatory. It is a service company so Scope 3 is dominated by upstream categories (purchased goods and services, business travel) that most students find easier to grasp than a manufacturer's Scope 3 downstream categories. And Infosys has published BRSRs consistently since FY22, so year-on-year comparability lets you see how the format matures.

The overall shape of a filed BRSR

Every BRSR runs three sections in the same order.

SectionPages (typical)What it is
Section A: General Disclosures5 to 10Corporate identity, listing, products, workforce, wages, turnover, CSR spend
Section B: Management and Process Disclosures3 to 6Nine-principle policy audit (yes-no-N/A table)
Section C: Principle-wise Performance40 to 50Essential and Leadership Indicators for each of the nine principles

Reading Section A of Infosys FY24

Section A opens with company identification: CIN, address, listing details on BSE and NSE, financial year covered (1 April 2023 to 31 March 2024), reporting boundary. Notice the reporting boundary. Infosys reports on the standalone entity, and separately identifies subsidiaries and joint ventures. This matters because BRSR data is not automatically consolidated. Each of the nine principles asks whether the data covers standalone only, or includes subsidiaries. Get this wrong and rating agencies will note a scope mismatch.

Products and services table. HSN or NIC code, description, revenue percentage. For Infosys, most revenue falls under NIC codes 62 and 63 (computer programming and information service activities). A single dominant NIC code makes the disclosure clean. A conglomerate has to list every material NIC code.

Workforce table. Permanent employees, non-permanent employees, differently-abled, gender split, disaggregated by workers versus employees (BRSR uses these two categories precisely). For Infosys the permanent-employees line is close to 320,000 globally, of which a large share is in India. Notice the gender split in the workers vs employees rows. Notice that the permanent-employee count is different from the "workers" count. Infosys is a service company; the "workers" category (defined by BRSR consistent with the Wages Code 2019) is small. In a manufacturing company, the workers count would dominate.

Wages disclosure. Median male, median female, median wage of workers, median wage of employees. This is where an assurance provider on BRSR Core will look first. Reconciling the medians against the payroll master data is a first-day walkthrough.

CSR spend. Section 135 of the Companies Act 2013 triggers CSR at Rs 500 crore net worth, Rs 1,000 crore turnover, or Rs 5 crore net profit thresholds. Infosys crosses these easily. The 2 percent-of-average-net-profit spend calculation is disclosed. Note the reconciliation against the CSR-2 filing under Companies Act; the numbers must match.

Reading Section B of Infosys FY24

Section B is the policy audit. Nine principles, each with a battery of yes-no-N/A questions. Does your company have a policy on Principle 1 ethics. Is it Board-approved. Does it cover the value chain. Are stakeholders consulted in updates.

For Infosys FY24 the Section B yes-answers are dense. The company has a Code of Conduct, a Whistleblower Policy, an Anti-Bribery Policy, a Human Rights Policy, an Environment Policy, and so on. Every yes-answer sits on a document that the company can produce. Compare this against a first-time filer in the top 500. A first-time filer often has three of these policies as free-standing documents and the other six embedded in an HR handbook that has not been formally adopted by the Board. When the assurance provider asks for the Human Rights Policy, the answer "it is part of the Code of Conduct" is not sufficient. The policy must exist as its own document, adopted by the Board, and reviewable.

Module 3 of this course walks through the drafting of the nine mini-policies you need. For now, notice the Infosys Section B as a template of what a mature Section B looks like.

Reading Section C of Infosys FY24

Section C is where the numbers live. Nine principles, Essential and Leadership Indicators for each. Roughly 40 to 50 pages depending on the extent of Leadership Indicators the company chooses to answer.

Look at Principle 3 in the Infosys FY24 BRSR. Essential Indicators cover benefits (retirement, health insurance, maternity and paternity leave, day care), safety-related information (does the company have a certified occupational health and safety management system; ISO 45001 is the common reference), and complaints on working conditions. Leadership Indicators go into training hours, career development, and grievance resolution rates.

Look at Principle 6 in the Infosys FY24 BRSR. GHG emissions Scope 1 (direct emissions from owned or controlled sources: diesel gensets, refrigerant leaks, company-owned vehicles), Scope 2 (indirect emissions from purchased electricity: campus buildings, data centres), and Scope 3 (fifteen categories, of which purchased goods and services, business travel, and employee commuting will dominate for a service company). Notice the emission-intensity ratios: tCO2e per rupee crore of revenue, tCO2e per full-time employee. These are BRSR Core attributes and get reasonable assurance.

Look at Principle 5 in the Infosys FY24 BRSR. Complaints on POSH, complaints on discrimination, complaints on child labour and forced labour (usually zero for a mature IT services company but the disclosure has to be made either way). Note that POSH complaints appear here and also under Principle 1. BRSR asks for POSH data at both places; the numbers must reconcile.

Two things to notice that first-time readers miss

First: BRSR Core attributes are marked. In the Infosys FY24 BRSR, rows that are BRSR Core (subject to reasonable assurance under SSAE 3410) are visually distinct. The assurance opinion, when it is published (Infosys publishes the SSAE 3410 assurance report as part of the Annual Report), references these specific rows. Learn to spot the marking so you know which rows are Core.

Second: intensity ratios are almost always reported alongside absolutes. Infosys reports absolute Scope 1 emissions in tCO2e and also emissions intensity per employee and per rupee crore of revenue. Rating agencies use intensity ratios for peer comparison. Absolutes are what regulators and assurance providers verify.

A recommended reading order for a first-time BRSR reader

  1. Section A workforce table (2 minutes). This anchors your sense of the company size.
  2. Section A wages disclosure (1 minute). This is the fastest tell of maturity.
  3. Section B row 1 (policies covered) and row 5 (Board oversight). This tells you whether the policy pack exists.
  4. Section C Principle 6 GHG table. This tells you Scope 1-2-3 accounting depth and whether market-based Scope 2 is disclosed.
  5. Section C Principle 5 human-rights complaints table. This tells you the risk register maturity.
  6. Section C Principle 9 customer complaints and data breaches. This tells you the DPDP overlap.

Six pages. Twelve minutes. You will know more about a company's ESG operating maturity than most one-day workshops teach.

Next lesson: where BRSR sits in the annual report calendar and the month-by-month timeline you need to hit.

Reading a real BRSR (Infosys FY24) — the right order
Assurance First What is trusted Section A General disclosures Section B Mgmt + process Section C Performance by P1-9 BRSR Core 9 attributes
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Citations
SEBI Circular, SEBI/HO/CFD/CMD-2/P/CIR/2021/562 dated 10 May 2021 (BRSR) (BRSR format for top 1,000 listed entities) L4-C1
Introduced Business Responsibility and Sustainability Reporting for the top 1,000 listed entities by market capitalisation from FY 2022-23. Voluntary for FY 2021-22. Replaced the earlier Business Responsibility Report (BRR).
SEBI Circular, SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 (BRSR Core 12-Jul-2023) (BRSR Core, value chain reporting, reasonable assurance rollout) L4-C2
Introduced BRSR Core (a subset of BRSR disclosures identified as key ESG attributes requiring reasonable assurance), mandated third-party assurance under a phased rollout by market capitalisation (top 150 for FY 2023-24, top 250 for FY 2024-25, top 500 for FY 2025-26, top 1,000 for FY 2026-27), and introduced value chain reporting for the top 250 listed entities on a comply-or-explain basis from FY 2024-25.
Companies Act 2013, Section 135 (CSR) (Corporate Social Responsibility) L4-C3
Section 135 of the Companies Act 2013 makes CSR mandatory for companies meeting any of the thresholds (net worth ≥ Rs 500 crore, or turnover ≥ Rs 1,000 crore, or net profit ≥ Rs 5 crore). 2 percent of average net profit of preceding three financial years must be spent on Schedule VII activities. CSR spend disclosed in BRSR Principle 8.
ICAI Standard, SSAE 3410 Sustainability Assurance Engagements (ICAI Standard on GHG and sustainability assurance) L4-C4
ICAI Standard on Sustainability Assurance Engagements 3410 (India-adopted variant of ISAE 3410 Assurance Engagements on Greenhouse Gas Statements from IAASB). Prescribes limited and reasonable assurance engagement approaches for GHG statements and BRSR Core attributes.
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Reading Module 1. Enrol to unlock the rest of the course.
Module 1: The story of BRSR
Module 2: Section A, general disclosures
  • Section A opener: corporate identity, listing, reporting boundary
  • Products and services: HSN, NIC, and the conglomerate problem
  • Workforce: permanent, non-permanent, workers versus employees
  • Wages medians: the row assurance providers test hardest
  • Turnover, CSR spend, holding-subsidiary transactions
Module 3: Section B, management and process disclosures on NGRBC
  • Section B decoded: the yes-no-NA table row by row
  • The nine mini-policies you actually need
  • Grievance mechanisms: one register, nine intake channels
  • Board oversight and committee structure for BRSR
  • Template: the NGRBC 9-Principle Policy Pack
Module 4: Section C, Principles 1 to 4
  • Principle 1: ethics, transparency, accountability
  • Principle 2: sustainable and safe products
  • Principle 3: employee well-being and the LTIFR calculation
  • Principle 4: stakeholder engagement and materiality assessment
Module 5: Section C, Principles 5 to 9
  • Principle 5: human rights
  • Principle 6 part one: GHG emissions Scope 1, 2 and 3
  • Principle 6 part two: water, energy, waste, biodiversity, air, EPR
  • Principle 7: policy advocacy
  • Principles 8 and 9: inclusive growth and customer value
Module 6: BRSR Core, the nine attributes that get assured
  • What BRSR Core is and why it exists: Circular 12 July 2023 clause by clause
  • The nine BRSR Core attributes and their intensity ratios
  • Verification mechanics: SSAE 3410 assurance vs ISF assessment, and how to choose
  • Verification provider selection: SSAE 3410 assurance providers and ISF-empanelled assessors
  • The eight common assurance findings and how to prevent them
Module 7: Data collection operating model and templates
  • The Data Owner Matrix: mapping every BRSR row to a name
  • The Monthly Data Collection Calendar: Q1 through Q4 with owner sign-offs
  • GHG Scope 1-2-3 Worksheet: worked example for a mid-size Indian manufacturer
  • Water and energy accounting: withdrawal, consumption, discharge, intensity
  • Waste accounting by CPCB category: the Waste Register template
Module 8: Filing, assurance engagement, value chain, ISSB roadmap
  • The BRSR filing timeline: month by month from Q4 to next-year AGM
  • Internal audit sign-off and Board approval: the resolution your Company Secretary needs
  • Drafting the SSAE 3410 assurance engagement letter
  • The XBRL filing: BSE Listing Centre and NSE NEAPS portal mechanics
  • Value chain reporting: now voluntary, and why sensible top 250 filers still disclose
  • Post-filing: ESG rating agency engagement and question preparation
  • The IFRS S1 and S2 ISSB transition roadmap: what Indian filers should be doing now