INTEGRATED REPORTING The Chartered Accountant • February 2023 • Vol. 71 • No. 08 • pp. 67–71 (Journal pp. 895–899)

Non-financial Information -A Journey towards Integrated Reporting

AG
CA. Ashim Kumar Ghosh
Author is member of the Institute • Contact: ashim742@yahoo.co.in / eboard@icai.in

The Genesis of Integrated Reporting

“Integrated Reporting is making of a wholesome report combining both financial information as well as non-financial information of a company. In other words, reporting of non-financial information along with financial information gives birth to the model of ‘Integrated Reporting’. Financial information is the data about the monetary transactions of a company that demonstrate the financial performance and financial position of a company. Financial statements generally include the Balance sheet or Statement of affairs, Statement of profit and loss or Income statement, and Cash flow statement. On the other hand, non-financial information is the data about some things which are generally not recorded in the books of account, or it is impossible to quantify them but is very much present in and around the company that exhibit the manner in which a company operates its business activities.”

1. What is Non-financial Information (NFI)?

NFI speaks about other relationship issues in qualitative terms regarding how the company is running and will run. A company’s activities have significant impact on the life of the general public of the present as well as future generations.

NFI is often defined as Environmental, Social, and Governance (ESG) information, referring to the three central components in measuring the sustainability and societal impact of a company. It is referred to as the information about society and the environment and is considered by stakeholders relevant to evaluating the company’s long-term ability to survive and succeed.

Key Qualitative Facets of Non-financial Disclosures:

• Social Information:
Contributions to the betterment of society, customer/supplier satisfaction, and community engagement.
• Environmental Information:
Energy and emissions, water consumption, resource efficiency, combating climate change, preservation of biodiversity, and environmental pollution mitigation.
• Corporate Social Responsibility (CSR):
Contributions towards social programmes and projects addressing poverty, health, education, environmental sustainability, and rural/community development.
• Sustainability Disclosures:
Product/service sustainability, sustainable procurement practices, and natural resources sustainability.
• Governance Parameters:
Transparency, integrity, discipline, commitment, internal control systems, shareholders’ rights, business outlook, and future strategic plans.
• Employee-Related Disclosures:
Employee satisfaction, occupational safety and health protection, human capital development, training, and equal opportunity policies.
• Human Rights & Business Ethics:
Human rights protection, anti-corruption and anti-bribery mechanisms, and prompt payment of government taxes.
• Research & Development (R&D):
Investments in sustainable technologies, process innovation, and green operational solutions.

2. What is the Significance of Integrated Reporting?

When an annual report of a company includes both financial information as well as non-financial information, we may address the same as an Integrated Report. Integrated Reporting is a process of data collection and formal disclosure on non-financial aspects of corporate activities along with its financial aspects that helps the company measure, understand, and communicate its impacts.

Risk Management & Competitiveness

Non-financial reporting is a vital mechanism to improve risk management and long-term social, environmental, and financial performance and market competitiveness. It provides an effective framework for identifying and navigating future threats and opportunities.

Public Accountability & Trust

Disclosure of non-financial information empowers communities and citizens affected by corporate operations to assert their rights, restore trust in businesses, and hold corporations accountable. This is essential for building societal trust, enhancing reputation, and cementing brand loyalty.

Multi-Stakeholder Paradigm Shift

Present circumstances require a fundamental change in corporate reporting where the focus shifts from serving only financial capital providers to addressing all stakeholders who have an interest in or are affected by operations: communities, employees, suppliers, customers, regulators, Government, and society at large.

Holistic Value Creation

Non-financial reporting makes sense because qualitative ESG factors are equally co-responsible with financial factors for sustainable value addition. Traditional financial information is no longer sufficient on its own to give investors and markets a holistic overview of business performance.

3. Global Scenario Towards Integrated Reporting

Several reporting standards and frameworks have emerged globally for integrated reporting by companies worldwide. Enterprises may utilize these standards individually or in hybrid combinations to articulate their non-financial performance. Prominent global architectures include:

UN Global Compact UN Guiding Principles on Business and Human Rights (UNGPs) OECD Guidelines for Multinational Enterprises Global Reporting Initiative (GRI) ISO 26000 International Integrated Reporting Council (IIRC) Sustainability Accounting Standards Board (SASB) Task Force on Climate-related Financial Disclosures (TCFD) Carbon Disclosure Project (CDP) Carbon Disclosure Standards Board (CDSB)

Here, the three guidelines, frameworks, and standards mostly used by companies globally are analyzed in detail:

A. Global Reporting Initiative (GRI)

Established 1997 • Ceres & Tellus Institute • UNEP

The GRI was formed in 1997 by United States-based non-profits Ceres (formerly the Coalition for Environmentally Responsible Economies) and the Tellus Institute, with the support of the United Nations Environment Programme (UNEP). It is an independent international organisation that helps businesses take responsibility for their impacts by providing a global common language to communicate those impacts across environmental, social, and economic factors for all stakeholders.

GRI Standards help organisations understand their outward impacts on the economy, environment, and society, enabling third parties to assess environmental and societal impacts from corporate activities and supply chains.

Structure of GRI Standards:
  • (a) Universal Standards: Foundation, General Disclosures, and Management Approach.
  • (b) Topic-Specified Standards: Economic, Environmental, and Social disclosures.

Standardized guidelines concerning the environment are contained within the GRI Indicator Protocol Set, covering ESG issues from employee safety and human rights to environmental management. The GRI offers 30 environmental performance indicators across 9 primary categories:

1. Materials 2. Energy 3. Water 4. Biodiversity 5. Emissions 6. Effluents & Waste 7. Products & Services 8. Compliance 9. Transport & Overall

B. International Integrated Reporting Council (IIRC)

Founded 2009 • <IR> Framework 2013 • Prince of Wales A4S & IFAC

The IIRC was founded in 2009 by the Prince of Wales Accounting for Sustainability Project (A4S), the Global Reporting Initiative, the International Federation of Accountants (IFAC), and others. It published the landmark Integrated Reporting <IR> Framework in 2013, seeking to communicate how an organization’s strategy, governance, performance, and prospects—in the context of its external environment—create short, medium, and long-term value.

The <IR> Framework operates through a process that starts with integrated thinking, aligning organizational functions in communicating value creation. It is anchored by three structural pillars:

7 Guiding Principles:
  1. Strategic focus & future orientation
  2. Connectivity of information
  3. Stakeholder relationships
  4. Materiality
  5. Conciseness
  6. Reliability & completeness
  7. Consistency & comparability
8 Key Content Elements:
  1. Organisational overview & external environment
  2. Governance
  3. Business model
  4. Risks and opportunities
  5. Strategy and resource allocation
  6. Performance
  7. Outlook
  8. Basis of preparation and presentation
The 6 Distinct but Interrelated Capitals:
1. Financial Capital
2. Manufactured Capital
3. Natural Capital
4. Human Capital
5. Intellectual Capital
6. Social & Relationship Capital

C. Sustainability Accounting Standards Board (SASB)

Founded 2011 • 77 Industry-Specific Standards across 11 Sectors

The SASB is a non-profit organisation founded in 2011 to develop sustainability accounting standards. It developed unique standards for seventy-seven (77) industries across eleven (11) sectors, recognizing that sustainability issues manifest differently from one industry to another due to differences in business models, resource dependencies, and operating profiles.

SASB is an ESG guidance framework setting standards for the disclosure of financially material sustainability information by companies to their investors. It identifies issues reasonably likely to impact the financial performance or condition of a company, defining sustainability as corporate activities that maintain or enhance the ability to create long-term shareholder value.

5 Sustainability Dimensions Grouping Corporate Activities:
1. Environment
2. Human Capital
3. Social Capital
4. Business Model & Innovation
5. Leadership & Governance
Enterprise Judgment & Principle-Based Adaptation: Organizations face the practical challenge of deciding what to communicate, to whom, and which framework to deploy. Because GRI, IIRC, and SASB are principle-based frameworks, management possesses the legitimate flexibility to adjust reporting tools in accordance with their decisive operating context, stakeholder prominence, and material impacts on the world.

4. Indian Scenario Towards Integrated Reporting: A Decade of Evolution

In India, non-financial reporting began long ago through statutory inclusions such as the Directors’ Report, Management Discussion & Analysis (MD&A) Report, and Corporate Governance Report in corporate Annual Reports, alongside voluntary disclosures. To establish formal regulatory governance over ESG parameters, the Ministry of Corporate Affairs (MCA) and the Securities and Exchange Board of India (SEBI) spearheaded a structured decadal evolution:

December 2009
CSR Voluntary Guidelines 2009: MCA releases the first voluntary framework encouraging businesses to partake in social and sustainable development.
July 2011
National Voluntary Guidelines (NVGs): MCA issues the National Voluntary Guidelines on Social, Environmental and Economic Responsibilities of Business—refining the 2009 framework into a structured set of nine (9) core principles and elements for responsible business conduct.
August 2012
SEBI Mandates BRR (Top 100): SEBI mandates the top 100 listed companies by market capitalization to furnish an annual Business Responsibility Report (BRR) based on the NVG framework alongside their annual reports.
2014
Companies Act, 2013 Enactment: Repeals the Companies Act, 1956 and introduces statutory Corporate Social Responsibility (CSR) obligations under Section 135, mandating formal disclosures on CSR expenditures directed towards the UN Sustainable Development Goals (SDGs).
November 2015
BRR Expansion (Top 500): SEBI broadens mandatory BRR filing coverage to the top 500 listed companies by market capitalization.
February 2017
SEBI Circular on <IR> Framework: SEBI advises the top 500 listed companies to voluntarily adopt the Integrated Reporting <IR> Framework prescribed by the IIRC to improve disclosure standards. Companies are permitted to integrate disclosures within MD&A, as a separate chapter in the Annual Report, or as a standalone report.
March 2019
National Guidelines on Responsible Business Conduct (NGRBC): MCA revises the NVGs to align with global commitments including the UN Sustainable Development Goals (SDGs), Paris Agreement on Climate Change, and UN Guiding Principles on Business and Human Rights (UNGPs).
May 2021 & FY 2022-23
BRSR Mandate (Top 1000): SEBI replaces BRR with the rigorous Business Responsibility and Sustainability Report (BRSR), mandating filing for the top 1000 listed entities from FY 2022-23 (voluntary in FY 2021-22).

Technical Architecture of the BRSR Framework:

The BRSR is structured around disclosures on the nine (9) principles laid down by the NGRBC, accompanied by a comprehensive Guidance Note enabling companies to interpret the scope of disclosures under each principle.

Disclosure requirements under each of the 9 principles are bifurcated into two distinct operational categories:

1. Essential Indicators (Mandatory):
Must be reported compulsorily by all mandated entities, capturing baseline ESG performance metrics.
2. Leadership Indicators (Voluntary):
Advanced disclosures showcasing aspirational sustainability leadership, broader supply chain stewardship, and deeper societal impact.

Conclusion: A Continuous Journey Towards Global Sustainable Development

Disclosure of non-financial information in integrated reporting by companies in India has significantly increased over time. In fact, it is an ongoing developmental journey that will continue to evolve in line with emerging international circumstances and regulatory standards.

By aligning corporate transparency with international frameworks, Indian businesses are becoming increasingly responsible, proactive, and resilient corporate citizens committed to achieving the UN Sustainable Development Goals (SDGs).