What SEBI asks, verbatim
Does the entity have an anti-corruption or anti-bribery policy? If yes, provide details in brief and if available, provide a web-link to the policy
Disclose existence of policy, risk assessment procedures and internal controls, mechanism to deal with complaints on bribery/corruption, and coverage of trainings on anti-corruption issues.
Quoted from the SEBI BRSR Format as amended March 2025, with measurement guidance from the ICAI Background Material on BRSR, Revised Edition 2024, page 88.
In plain English
The company must say whether it has a policy that stops bribery and corruption. If it does, it should give a short description and, if possible, a link to the policy online. The company should also mention how it checks for risks, what controls it has, how it handles complaints, and how it trains staff on anti‑corruption.
What a complete, assurance-ready answer contains
A complete, assurance‑ready answer confirms the policy’s existence, cites the latest revision date, and provides a URL to the publicly accessible document. It summarizes the risk assessment framework, lists key internal controls (e.g., segregation of duties, approval thresholds), and describes the complaint mechanism (hotline, whistle‑blower portal) and training schedule, including the number of employees trained and the training content. A common gap is omitting the policy’s version or failing to link to the actual policy, which prevents auditors from verifying the claim.
Describes the completeness and granularity an assurer expects. No company figures are named.
Where the data comes from
Usually found in board records and compliance registers. Forward to your Company Secretary or Legal team.
Much of what BRSR asks for already exists in filings the company makes elsewhere, such as Pollution Control Board consents, PAT returns, hazardous-waste manifests and EPR registrations. The free gap analysis cross-references those filings against all 108 fields and shows which are already covered.
Frequently asked questions
What does BRSR P1-E4 ask for?
The company must say whether it has a policy that stops bribery and corruption. If it does, it should give a short description and, if possible, a link to the policy online. The company should also mention how it checks for risks, what controls it has, how it handles complaints, and how it trains staff on anti‑corruption.
Is BRSR P1-E4 an Essential or a Leadership indicator?
P1-E4 is an Essential indicator, so it is mandatory for every BRSR filer. It sits under Principle 1, Ethics & Transparency.
Who inside the company holds the data for P1-E4?
Company Secretary / Legal. Usually found in board records and compliance registers. Forward to your Company Secretary or Legal team.
What unit does P1-E4 use?
Yes/No + narrative. Reporting in the wrong unit, or switching the denominator of an intensity ratio between years, is one of the more common reasons a figure has to be restated.
What does a complete answer to P1-E4 look like?
A complete, assurance‑ready answer confirms the policy’s existence, cites the latest revision date, and provides a URL to the publicly accessible document. It summarizes the risk assessment framework, lists key internal controls (e.g., segregation of duties, approval thresholds), and describes the complaint mechanism (hotline, whistle‑blower portal) and training schedule, including the number of employees trained and the training content. A common gap is omitting the policy’s version or failing to link to the actual policy, which prevents auditors from verifying the claim.
Other disclosures under Principle 1
% of board, KMPs, employees and workers trained on the ESG principles this year
Fines, penalties or settlements paid to regulators or courts this year (in Rs, and count)
Of those fines, which have been appealed (case details)
Number of directors, KMPs, employees or workers disciplined for bribery / corruption
Number of conflict-of-interest complaints
Any corrective action taken on the above fines or corruption cases
See P1-E4 against a real client
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