When Bank Submits Defective - BRSR Report To The SEBI - Duty of SEBI & RBI.

 Human Right Violation Research - HR Lab   

* Birendra K Jha                                                                                                                                                                              Certified Social Auditor; Practitioner Social Impact Assessment Audit; Practitioner BRSR (SEBI ) Audit- ESG Audit. EMail: birendrajha03@yahoo.com

The ICICI Bank has submitted the BRSR Report of the Annual Year 2024-2025. Somewhere I have addressed the need of Independent BRSR Audit of Human Right in the ICICI Bank.The Grant Thornton Bharat LLP has conducted Independent Audit of the most of the BRSR Principles. Why it has not Audited properly the Human Right Violation side?  Because in the BRSR Report of the Annual Year 2024-2025 submitted by the ICICI Bank, the BRSR Report on the Human Right is blank ( NIL )  as seen below: 

 

This shows the Bank intentionally has not conducted any Independent Audit on the Human Right violation as shown in Para 10. The necessary countermeasures also not conducted under Para 11. The two sections are  completely blank. In ICICI Bank massive Labour - Human Right Law violation is reported, where more than 700 employees have been removed in just six months in 2024 using unfair labour practices. This needed to be reported in the "OTHERS" Column appearing just below Wages. This is categorizing "OTHER HUMAN RIGHT VIOLATION". Removal of employees without conducting domestic enquiry is violation of human rights. The Bank has again submitted Assessment By Statutory Authorities 5%. This is bogus reply. This part is needed to be conducted under Independent Assessment Audit under the SEBI Law. Who conducted this Assessment Audit? This is defective reply. This raises doubt that the ICICI Bank is not reporting honestly.    

The following confidential letter speaks the gross violation of human rights in the ICICI Bank.

The ICICI Bank has listed down that in between 01.01.2024 to 01.06.2024, some  large number of employees have been removed. Out of them 782 employees have not reported. This is embarrassing. A permanent employees can't be removed without conducting domestic enquiry. Further if employees are not reporting then  disciplinary action is needed to be taken. This is only the legal way of closure of service.  This legal procedure is completely absent- leading to Major Human Right Violation.  Clearly this is ICICI Bank's gross violation of human right where employees have been removed without conducting domestic enquiry. This legal violation is not reported in the BRSR Report.       

Following excerpt, given by Regional Labour Commissioner ( Central )  further speaks the gravity of the situation. This violation has not been again reported in the BRSR Core: 

 

    

The ICICI Bank can't do like this. This is violation of the SEBI Guideline. This has violated Universal Declaration of Human Rights (Article 21- 23). This call is needed to be taken by the SEBI and the Reserve Bank of India. 

The ICICI Bank has also violated the RBI Guideline "Guidance Note on the Management of Operational Risk". This Guideline ( Clause 1.3) has attracted the Legal Risk, of ICICI Bank on Labour Law and Human Right violation. This damages sustainability and induces high attrition rate of employees. 

If SEBI and RBI do not step in, it shall  paralyze the whole banking operation.  The RBI should also conduct Third Party Assessment Audit on Labour Law violation.

Conclusion: 

A thorough investigation needed by SEBI for violating law on the BRSR Assessment Audit. The RBI in turn also needed to examine the RBI Guideline violation of the mandate "Guidance Note on the Management of Operational Risk" ( Clause 1.3).The Independent Directors sitting at the ICICI Bank have more important role to play. They should investigate this major violation.