Principle 1 is the governance backbone of BRSR: it asks how the business conducts itself with integrity. It covers the anti-corruption policy, fines and penalties, disciplinary actions for bribery, conflicts of interest, related-party transactions, payment discipline and training on the NGRBC principles. It is mostly narrative and record-based rather than numeric, which makes it deceptively easy to under-answer.
Key takeaways
- 01Principle 1 is about ethics and governance, so most of its data sits with the Company Secretary and legal team, not the plant.
- 02It is largely disclosure- and narrative-based, but assurers and investors read the fines, penalties and anti-corruption answers closely.
- 03Answer the anti-corruption disclosure with substance: the policy, the controls, the complaints mechanism and training coverage, not a bare Yes.
- 04Fines and penalties must be disclosed by NGRBC principle, with the regulator, the amount and a case brief.
What Principle 1 asks
| Disclosure | What it asks | ICAI page |
|---|---|---|
| P1-E1 | Coverage of training and awareness on the NGRBC principles, by employee category | 84 |
| P1-E2 | Fines, penalties, settlements and compounding fees paid to regulators or courts | 85 |
| P1-E4 | Whether an anti-corruption or anti-bribery policy exists, with details | 88 |
| P1-E5 | Disciplinary action for bribery or corruption against directors, KMPs, employees or workers | 90 |
| P1-E6 | Complaints regarding conflict of interest of directors and KMPs | 90 |
| P1-E8 | Number of days of accounts payable | 91 |
| P1-E9 | Concentration of purchases, sales and related-party transactions | 92 |
The two Leadership indicators cover awareness programmes for value-chain partners (P1-L1) and processes to manage board-level conflicts of interest (P1-L2).
Who owns the data
Principle 1 is a Company Secretary and legal engagement
How to answer the anti-corruption disclosure (P1-E4)
This is the disclosure most companies under-answer. A bare Yes tells the reader nothing. A credible answer describes four things:
- 01The policy itself: board-approved, with a web link to the published version.
- 02The risk-assessment procedures and internal controls that back it up.
- 03The mechanism for receiving and dealing with bribery or corruption complaints.
- 04The coverage of anti-corruption training, by employee category, not just whether it happened.
How to answer fines and penalties (P1-E2)
Disclose both monetary actions (penalties, settlements, compounding fees) and non-monetary ones (imprisonment, punishment). For each, give the NGRBC principle it maps to, the name of the regulatory body, the amount in rupees, a brief of the case, and whether an appeal has been preferred. Materiality is judged per Regulation 30 of SEBI LODR.
Best practice for Principle 1
- Adopt a board-approved Code of Conduct and a whistle-blower or vigil mechanism (Companies Act 2013 Section 177 and SEBI LODR Regulation 22), and publish both on the company website.
- Constitute the Risk Management and Stakeholders Relationship Committees mandated for the top 1000 listed entities, with documented charters and meeting records.
- Track and disclose anti-corruption training coverage by employee category, rather than a simple Yes or No.
- Certify the anti-bribery programme to ISO 37001 and align with UN Global Compact Principle 10.
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