Every year, India’s top 1,000 listed companies dutifully file their Business Responsibility and Sustainability Reports (BRSR) with market regulator Sebi. Under Principle 1 — the ethics and integrity principle — they must disclose the number of disciplinary actions taken by any law-enforcement agency against directors, key managerial personnel (KMPs), or employees for bribery and corruption.
Because private-to-private bribery is not a criminal offence in India, this question is structurally unanswerable for the vast majority of companies — there can be no law enforcement actions on conduct that the law does not criminalise.
The result, visible in individual BRSR filings across industries, is uniformly nil disclosures. Not because India’s private sector is clean. Because India’s law gives companies nothing to report.
