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The nine NGRBC principles that structure Sections B and C

Almost every question in Section B and Section C of BRSR maps to one of nine principles laid out in the National Guidelines on Responsible Business Conduct 2019. This is the working practitioner tour: what each principle covers, what data lives under it, and where the assurance-scrutiny risk sits.

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Legal basis
BRSR + ESG primary-source stack current to 29 August 2026. Core: SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 Regulation 34(2)(f); SEBI Circular SEBI/HO/CFD/CMD-2/P/CIR/2021/562 dated 10 May 2021 (BRSR); SEBI Circular SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023 (BRSR Core, value chain reporting, and reasonable assurance rollout from FY 2023-24 top 150 to FY 2026-27 top 1,000 by market capitalisation); SEBI Circular SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42 dated 28 March 2025 (Measures to facilitate ease of doing business with respect to framework for assurance or assessment, ESG disclosures for value chain, and introduction of voluntary disclosure on green credits: opened assessment-or-assurance choice for BRSR Core verification from FY 2025-26 with market-cap rollout preserved, reclassified value chain disclosure to voluntary from FY 2025-26 with assessment or assurance voluntary from FY 2026-27, refined value chain scope to partners individually 2 percent or more of purchases and sales by value with aggregated coverage may be limited to 75 percent, introduced voluntary green credits disclosure item, tightened no-conflict-of-interest test for verification providers). Frameworks: National Guidelines on Responsible Business Conduct 2019 (Ministry of Corporate Affairs, March 2019); GHG Protocol Corporate Accounting and Reporting Standard Revised Edition 2004; GHG Protocol Scope 2 Guidance 2015; GHG Protocol Corporate Value Chain (Scope 3) Standard 2011; IFRS S1 and IFRS S2 (ISSB, June 2023, effective 1 January 2024). Verification: ICAI Standard on Sustainability Assurance Engagements SSAE 3410 (assurance pathway); Industry Standards Forum BRSR Core Assessment Standards (assessment pathway, ISF jointly constituted by ASSOCHAM, CII and FICCI under the aegis of the stock exchanges in consultation with SEBI). Environmental Rules: Hazardous and Other Wastes (Management and Transboundary Movement) Rules 2016 as amended; Plastic Waste Management Rules 2016 as amended (including EPR framework); E-Waste (Management) Rules 2022; Bio-Medical Waste Management Rules 2016. Labour: Wages Code 2019 and Occupational Safety, Health and Working Conditions Code 2020 (in force 21 November 2025). Grid emission factors: Central Electricity Authority User Guide for CO2 Baseline Database. Reference BRSR filings for case material: Reliance FY24, TCS FY24, Infosys FY24, HDFC Bank FY24, ITC FY24, L&T FY24 (available on respective Investor Relations pages). Items requiring ongoing verification and flagged inside the relevant lessons: any further SEBI revision Circular after 28 March 2025 affecting BRSR Core rollout, value chain framework, or green credits scope; India adoption timeline for IFRS S1 and S2 (MCA and SEBI signal alignment intent; timing pending); any BRSR format revision Circular issued between 1 January 2026 and course launch date.

The Ministry of Corporate Affairs published the National Guidelines on Responsible Business Conduct in March 2019 [L3-C1]. Nine principles. Same nine that structure the current BRSR Section B (policy audit) and Section C (principle-wise performance). Knowing what each principle covers, and where its assurance risk sits, is the shortest path to reading a BRSR fluently. Twenty minutes of tour.

The nine principles at a glance

PrincipleShort labelWhat it covers
Principle 1Ethics, transparency, accountabilityAnti-corruption, Related Party Transactions, whistleblower, POSH data placement, ethics training
Principle 2Sustainable and safe productsR&D expenditure on sustainability, lifecycle assessment, product certifications, sustainable sourcing
Principle 3Employee well-beingWages, benefits, health insurance, safety metrics (LTIFR, fatalities), training hours, complaints on working conditions
Principle 4Stakeholder engagementMateriality assessment, stakeholder identification, engagement mechanisms, vulnerable stakeholder consideration
Principle 5Human rightsHuman rights training, complaints on discrimination, forced labour, child labour, minimum wage compliance, POSH again from the rights angle
Principle 6EnvironmentGHG emissions Scope 1, 2 and 3, energy consumption, water withdrawal-consumption-discharge, waste, biodiversity, air emissions, EPR compliance
Principle 7Policy advocacyIndustry association memberships, public consultation participation, transparency of lobbying
Principle 8Inclusive growth and equitable developmentSocial impact assessments, CSR spend under Section 135, procurement from small producers, sustainable development in operating areas
Principle 9Customer valueProduct recalls, customer complaints, data breaches under DPDP, product labelling, cyber security incidents affecting customers

How Section B uses the principles

Section B asks, for each of the nine principles, a battery of yes-no-N/A questions. Does your company have a policy that covers this principle. Is the policy Board-approved. Does it cover the value chain. Has it been translated for use by frontline employees. Are there mechanisms for stakeholder input. This is a policy audit dressed as a reporting section. Assurance providers open Section B first to check the policy pack exists and matches what is claimed. If a company answers "yes, we have a Board-approved human rights policy that covers the value chain" for Principle 5 but cannot produce the document, the entire Principle 5 disclosure loses credibility.

Module 3 walks through Section B row by row and gives you the nine-policy draft pack you need to make honest yes answers.

How Section C uses the principles

Section C asks, for each of the nine principles, a set of Essential Indicators (mandatory) and Leadership Indicators (recommended, to be answered on a comply-or-explain basis). Essential Indicators are the numbers that assurance providers verify. Leadership Indicators are aspirational and rating agencies read them to score the company on ESG maturity.

Modules 4 and 5 of this course walk through every Essential and Leadership Indicator for every principle, with worked examples and calculation methodologies.

Where the assurance-scrutiny risk sits

Not every principle carries equal assurance risk. The highest-risk principles for BRSR Core reasonable assurance are Principle 3 (safety metrics, wages), Principle 5 (POSH complaints, human rights complaints), and Principle 6 (GHG, water, waste). These are the principles where the numbers are calculated, denominators matter, and evidence has to survive an assurance walkthrough. Principles 1 and 4 are lower-risk in assurance terms because they are largely policy-and-process disclosures. Principle 7 is the lowest-risk from an assurance standpoint but the highest-risk from a reputational standpoint (a company that funds anti-climate lobbying while claiming environmental leadership will be caught here).

Which principles the ESG rating agencies weight highest

Every ESG rating agency has a proprietary weighting scheme. MSCI, CRISIL, Sustainalytics, and S&P Global weight the nine BRSR principles differently, and the weightings drift year on year. The consistent pattern across agencies through 2025 and 2026 has been to give the highest weight to Principle 6 environmental attributes (particularly GHG, water, and waste intensity) and to Principle 3 employee attributes (particularly safety and wages). Principle 9 customer-value attributes have risen in weight since the DPDP Act 2023 [L3-C2] came into force, because data-breach disclosures under Principle 9 now overlap with DPDP breach notifications and rating agencies triangulate the two.

The one-line summary you can quote to a partner

Nine NGRBC principles. Section B is a nine-principle policy audit. Section C is nine principles worth of Essential and Leadership Indicators. Principles 3, 5 and 6 carry the assurance risk. Principles 6 and 3 carry the ESG-rating weight. Principle 7 carries the reputational risk. Everything else is scaffolding around those five.

Next lesson: opening a real filed BRSR and reading it end-to-end. Infosys FY24 as the base case. Twenty minutes and you will know how to navigate any BRSR by structure.

Every claim in this lesson is cited. Yellow markers like [L1-C1] are clickable. Click any to see the verbatim text of the Section, Rule or judgment we're relying on. Learn how we verify content ›

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Citations
National Guidelines on Responsible Business Conduct 2019, NGRBC 2019 (successor to NVG-SEE 2011) (Nine principles of responsible business conduct) L3-C1
Ministry of Corporate Affairs, March 2019, National Guidelines on Responsible Business Conduct, articulating nine principles that structure BRSR Sections B and C. Successor to the National Voluntary Guidelines (NVG-SEE) issued by MCA in June 2011.
Digital Personal Data Protection Act 2023, DPDP Act 2023 (Data breach reporting overlap with BRSR Principle 9) L3-C2
Digital Personal Data Protection Act 2023. Section 8(6) requires personal data breach notification. Feeds BRSR Principle 9 (customer value) data breach disclosures.
Free preview
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