XYZ Ltd., a listed entity, is preparing its Annual Report for the financial year 2024-25. The company has operations in many countries and has…

CA Final · Advanced Auditing, Assurance and Professional Ethics · MTP · September 2025
XYZ Ltd., a listed entity, is preparing its Annual Report for the financial year 2024-25. The company has operations in many countries and has implemented policies on ethics, diversity, and environmental sustainability. The management has taken steps to align its reporting with the National Guidelines on Responsible Business Conduct (NGRBC). As part of its BRSR submission, the company provides information on its workforce strength, gender diversity, number of subsidiaries, and policies on human rights. It also discloses data on energy consumption, carbon emissions, and the number of employees trained in sustainability practices. However, it does not include life cycle assessments or details of its biodiversity conservation initiatives. Identify which sections of the BRSR reporting framework are covered by XYZ Ltd. based on the disclosures mentioned. Also, comment whether XYZ Ltd. has complied with the minimum mandatory disclosures required under BRSR.

Suggested Answer and Working Notes:

Sections of BRSR covered by XYZ Ltd.: In the given case, XYZ Ltd., a listed entity, has made disclosures that fall under the following sections of the BRSR framework: Section A - General Disclosures: This section contains the details of the listed companies, its products, services, operations, employee related details, its holding, subsidiary, associate companies etc.Section B - Management Process and disclosures: It contains questions related to policy and management processes, governance, leadership, and oversight.Section C – Principle-wise performance disclosures: Companies are required to report upon Key performance indicators (KPIs) in alignment with the nine principles of the NGRBC. The section classifies KPIs into two categories that companies are required to report upon:Essential indicators (Mandatory disclosures): This would include data on training programs conducted, environmental data on energy, emissions, water, waste management etc.Leadership indicators (Optional disclosures): This would include life cycle assessments, details of conflict management policy, additional data on biodiversity, energy consumption, supply chain managements etc. In the given situation, XYZ Ltd. has disclosed information related to its workforce strength, gender diversity, and number of subsidiaries, which aligns with Section A - General Disclosures about employee details and corporate structure. Further, disclosure of policies on ethics, diversity, human rights, and environmental sustainability initiatives indicates coverage of Governance and Policy are in compliance with Section B - Management Process and disclosures. Furthermore, XYZ Ltd. has disclosed data on energy consumption, carbon emissions, and sustainability-related training for employees, which are part of the Mandatory Essential Indicators under Section C - Principle-wise performance disclosures. Compliance with Minimum Mandatory Disclosures: XYZ Ltd. has disclosed essential indicators such as environmental data (energy, emissions), employee training, and policy-related disclosures, which are the core components of mandatory requirements. However, XYZ Ltd., has not disclosed life cycle assessments, details of its biodiversity conservation initiative which are leadership indicators. Since, disclosure of Leadership indications is optional, therefore, their exclusion does not violate compliance with mandatory BRSR requirements. Thus, it can be concluded that XYZ Ltd. appears to have complied with the minimum mandatory disclosures required under BRSR.

Topics: Emerging Areas: Sustainable Development Goals (SDG) & Environment, Social and Governance (ESG) Assurance

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