# BRSR Cement Sector Benchmark FY 2024-25 — Methodology

> **Version:** v0.5 (sample frame finalised at 14 entities; 2 documented exclusions)
> **Owner:** Ravi Patel + BatchWise SEO/GEO Manager
> **Anchor article target:** `/research/brsr-cement-sector-benchmark-fy2425/`
> **Status:** Methodology APPROVED 2026-05-27 by Ravi Patel. **Sample frame finalised at 14 entities**. Of 16 originally shortlisted listed cement entities, 2 were excluded for FY 2024-25 BRSR non-availability with documented reasoning (HeidelbergCement India — acquisition-cliff; NCL Industries — SEBI Top-1000 mandate exemption). The exclusion of NCL Industries is itself a substantive finding about BRSR mandate coverage in Indian listed cement — see Section 2.3 + Section 7 limitations. Scraping + extraction complete: 14 / 14 BRSR FY 2024-25 cached + extracted; NCL Industries Annual Report fetched + extracted as documented evidence of the mandate boundary (excluded from v1.0 statistical aggregation).

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## 1. Research question

> *Across the 15 largest Indian listed cement producers, what does the FY 2024-25 BRSR / BRSR Core disclosure reveal about (a) absolute and intensity-based environmental performance, (b) social and human-capital indicators, (c) governance and disclosure-quality maturity, and (d) CBAM-exposed transition readiness — and how does this compare cross-company and against sector-relevant decarbonisation benchmarks?*

Five sub-questions drive the dataset design:

1. **Emissions** — Scope 1 + Scope 2 (location + market basis where disclosed); intensity per tonne cement and per ₹ crore revenue
2. **Energy** — Total energy consumption (TJ), renewable share, specific heat consumption (MJ/kg clinker), specific electrical energy consumption (kWh/t cement), Waste Heat Recovery System (WHRS) capacity, thermal substitution rate (TSR / alternative fuel rate)
3. **Resources** — Water withdrawal + recycling, waste generation + recovery, biodiversity-area operations
4. **People** — Workforce composition + gender ratios, median remuneration by gender, LTIFR, wellbeing spend, complaints (POSH + child labour + forced labour + grievance)
5. **Governance + disclosure quality** — Board composition, ESG committee presence, voluntary GRI / IFRS S2 / TCFD disclosure, external assurance scope + assurance provider + assurance level

## 2. Sample frame

### 2.1 Universe definition
Indian listed cement producers as on **31 March 2025** with:
- (i) Listed on NSE and/or BSE
- (ii) Primary business classification "Cement & Cement Products" (NIC 2-digit 23 / NSE Industry "Construction Materials")
- (iii) Domestic cement capacity ≥ 1 MTPA (Million Tonnes Per Annum) as on 31 March 2025
- (iv) Cement-related revenue ≥ 50% of total revenue from operations FY 2024-25

### 2.2 Selected entities (15)

| # | Company | CIN | Primary listing | Market cap rank (31 Mar 2025) |
|---|---|---|---|---|
| 1 | UltraTech Cement Ltd | L26940MH2000PLC128420 | NSE/BSE | — |
| 2 | Ambuja Cements Ltd | L26942GJ1981PLC004717 | NSE/BSE | — |
| 3 | ACC Ltd | L26940MH1936PLC002515 | NSE/BSE | — |
| 4 | Shree Cement Ltd | L26943RJ1979PLC001935 | NSE/BSE | — |
| 5 | Dalmia Bharat Ltd | L40109TN2013PLC093499 | NSE/BSE | — |
| 6 | JK Cement Ltd | L17229UP1994PLC017199 | NSE/BSE | — |
| 7 | The Ramco Cements Ltd | L26941TN1957PLC003566 | NSE/BSE | — |
| 8 | JK Lakshmi Cement Ltd | L74999RJ1938PLC019511 | NSE/BSE | — |
| 9 | The India Cements Ltd | L26940TN1946PLC000931 | NSE/BSE | — |
| 10 | Birla Corporation Ltd | L01132WB1919PLC003334 | NSE/BSE | — |
| 11 | HeidelbergCement India Ltd | L26942HR1958PLC042301 | NSE/BSE | — |
| 12 | Star Cement Ltd | L26942ML2001PLC006411 | NSE/BSE | — |
| 13 | Sagar Cements Ltd | L26942TG1981PLC002887 | NSE/BSE | — |
| 14 | Nuvoco Vistas Corporation Ltd | L26940MH1999PLC118229 | NSE/BSE | — |
| 15 | Orient Cement Ltd | L26940OR2011PLC013933 | NSE/BSE | — |

CINs to be verified against MCA Master Data during scraping; Market cap rank to be filled at scraping time.

### 2.3 Exclusions
- Unlisted cement producers (no BRSR obligation)
- Cement traders + dealers (manufacturing exposure < 50%)
- Cement entities where cement revenue < 50% of consolidated revenue (multi-business conglomerates with diversified portfolios — captured under their primary listing if any)
- Subsidiaries of foreign cement majors (e.g., LafargeHolcim's pre-2022 entity structure is now consolidated under Adani as Ambuja-ACC)
- **HeidelbergCement India Ltd (HEIDELBERG) — EXCLUDED FROM v1.0 SAMPLE.** As of January 2025, Heidelberg Materials (German parent, 69.39% holder) was in advanced talks with UltraTech Cement to divest its Indian operations in an approximately ₹3,381 crore transaction. As of 27 May 2026 (anchor publication date), HeidelbergCement India has not published a FY 2024-25 BRSR on its own investor relations page (mycemco.com); the only BRSR available on the company website is undated (likely FY 2022-23 / FY 2023-24 vintage based on sitemap timestamps). Including FY 2023-24 data alongside FY 2024-25 disclosures from other entities would violate year-consistency. **Reason for exclusion: acquisition-cliff (parent in exit mode).** Re-included in v2.0 if (a) it publishes a stand-alone FY 2024-25 BRSR, or (b) acquisition closes and we capture it under UltraTech's consolidated reporting.
- **NCL Industries Limited (NCLIND) — EXCLUDED FROM v1.0 SAMPLE.** NCL Industries meets every other inclusion criterion (NSE/BSE listed, NIC 23-classified cement industry, 3.30 MTPA capacity ≥ 1 MTPA threshold, cement revenue 80.51% of turnover ≥ 50% threshold). However, NCL's Directors' Report (page 33 of FY 2024-25 Annual Report) explicitly states: "the requirement to furnish a BRSR is not applicable to your company" — NCL falls **outside the SEBI Top 1,000 listed entities by market capitalisation as on 31 December 2024**, per SEBI Gazette dated 17 May 2024 (Regulation 34(2)(f) of SEBI LODR 2015). **Reason for exclusion: BRSR mandate exemption (market cap below Top 1,000 threshold).** No Section A / B / C disclosures were filed; the Annual Report contains only Directors' Report + MD&A + financial statements. The NCL Annual Report is retained in the research evidence cache as documented evidence of the SEBI Top-1000 mandate boundary in Indian cement. This is itself a substantive finding for the anchor article: of 16 originally shortlisted listed Indian cement entities, 2 (12.5%) were excluded from v1.0 for FY 2024-25 BRSR non-availability with materially different reasons (one acquisition-context, one mandate exemption).

**Sample frame for v1.0 anchor publication is therefore 14 entities. The two exclusions are documented as substantive methodology findings, not data gaps.**

### 2.4 Acquisition-context notes within sample
Three entities in the v1.0 sample have material acquisition / corporate-action context that warrants disclosure to readers:

- **Ambuja Cements + ACC Ltd** — Both Adani Group since the 2022 Holcim-to-Adani deal. Reported separately under their respective listings; consolidated narratives appear in Adani Cement disclosures. Treated as separate entities in this dataset (separate FY 2024-25 BRSR filings exist for each).
- **India Cements (INDIACEM)** — UltraTech Cement acquired controlling stake in late 2024 / early 2025. FY 2024-25 BRSR was filed independently by India Cements as a separately-listed entity; we include it as an independent observation but flag the new ownership context. Future-year BRSR may consolidate under UltraTech.
- **Orient Cement (ORIENTCEM)** — Ambuja Cements completed acquisition in April 2025 (~46.66% stake). FY 2024-25 BRSR captured on orientcement.com pre-consolidation. Future-year reporting may consolidate under Adani Cement.

## 3. Data sources

### 3.1 Primary source (priority order)

1. **Company's standalone BRSR PDF** as filed on its investor relations page
2. **BRSR section within the company's annual report** for FY 2024-25
3. **NSE/BSE filing of the BRSR** (where the company has filed a stand-alone BRSR with the exchange)
4. **SEBI filing of BRSR Core assurance report** (where applicable per the phased mandate — Top 150 mandatory FY 2023-24, Top 250 FY 2024-25, Top 500 FY 2025-26, Top 1,000 FY 2026-27)

### 3.2 Cross-validation sources
- Company's sustainability report (where published separately)
- Company's GRI report (where filed)
- Company's CDP response (where publicly available)
- Company's analyst-day or investor-day presentation containing emissions disclosure

### 3.3 Strictly excluded sources
- Secondary aggregators (ESGNow, S&P Global ESG, Sustainalytics, MSCI ESG, ESG India ratings)
- Trade press summaries
- Sell-side equity analyst notes
- Any non-company-issued benchmark publication

### 3.4 Access protocol
- All BRSR PDFs to be fetched via the primary-source pipeline (`scripts/primary-source/fetch.ts`)
- Where direct fetch is blocked (WAF / Akamai protection), use the Claude-in-Chrome bridge to capture from a real browser session
- Every PDF fetched is cached at `scripts/primary-source/evidence/{domain}/{path}/{timestamp}/`
- Cached evidence file path is referenced in the dataset for every data point

## 4. Field definitions + coding rules

### 4.1 Coding principles
- **Verbatim where possible.** Numeric values + named entities recorded exactly as disclosed; no inference, no rounding.
- **Source page cited per data point.** Every field value carries a `source_page` reference to the BRSR PDF page number.
- **"Not disclosed" flagged explicitly.** Missing disclosure is treated as a data point (= disclosure quality signal), not as zero.
- **Unit consistency enforced post-collection.** Companies may report water in kL, m³, or ML — all converted to kL during normalisation, with original unit retained in `source_unit`.
- **Restatements separately tracked.** Where the company restates a prior year's figure, the restated value is captured + the original first-disclosed value retained in `restated_from`.

### 4.2 Calculated fields
- **Emissions intensity per ₹ crore revenue** = (Scope 1 + Scope 2 location-based) / Revenue from operations × 10000000
- **Emissions intensity per tonne cement** = (Scope 1 + Scope 2 location-based) / Cement production tonnes
- **Renewable energy share** = Renewable energy consumed / Total energy consumed × 100
- **Clinker factor** = Clinker production / Cement production (where both disclosed; flagged if implied from external grid data)
- **Female workforce share** = Female permanent employees + female permanent workers / Total permanent (employees + workers) × 100
- All calculated fields show derivation formula + the input data points used

### 4.3 Disclosure quality scoring

A page-level + KPI-level **Disclosure Quality Score** (DQS) on a 5-point scale:

| DQS | Definition |
|---|---|
| 5 | Quantitative + assured + restated for prior year + with methodology citation |
| 4 | Quantitative + assured (limited or reasonable) + with methodology citation |
| 3 | Quantitative + with methodology citation OR + with assurance (but not both) |
| 2 | Quantitative-only (no methodology, no assurance) |
| 1 | Qualitative description only |
| 0 | Not disclosed |

DQS scoring is applied per BRSR Core attribute (9 attributes) and aggregated for entity-level DQS.

## 5. Statistical treatment

### 5.1 Outlier rule
- For intensity metrics, **1.5 × IQR** (inter-quartile range) outliers are reported but excluded from sector median + percentile bands.
- Outliers retained in raw dataset with `outlier=true` flag; methodology document explains exclusion + the outlier value.
- Where N ≤ 8 entities for a sub-cut, outlier rule is suspended (all values reported with caveat that sample is too small for IQR-based exclusion).

### 5.2 Median + percentile bands
- Sector median, P25, P75, min, max reported for every numeric KPI
- Sample size (N) and missing-rate disclosed alongside every statistic
- Where N < 5 with disclosure, statistic is replaced with "insufficient sample"

### 5.3 No averages without weighting
- Plain arithmetic averages are NOT reported (distort sector picture)
- Where weighted averages are useful (e.g., revenue-weighted emissions intensity), the weighting basis is disclosed

### 5.4 No company-vs-company normalised rankings
- "Best in class" framing avoided (ASCI substantiation discipline)
- Rankings reported only against objective decarbonisation thresholds (e.g., kg CO2 / t cement) or against disclosed company targets

## 6. Quality control

### 6.1 Cross-validation protocol
- **Independent re-extraction** of 2 randomly-selected data points per entity by a different operator (yourself if scraping in-house, or Gemini-as-second-pair-of-eyes)
- Mismatches > 5% trigger full re-read of the source page
- All cross-validation results logged in `qc-log.md`

### 6.2 Calibration against external published benchmarks
For sense-checking only (not for data substitution):
- WBCSD Cement Sustainability Initiative (CSI) benchmark report (where Indian cement majors participate)
- Global Cement and Concrete Association (GCCA) "Concrete Future" benchmark
- WRI India / TERI cement sector emissions estimates
- CII / FICCI cement-sector sustainability reports

External benchmark divergence > 25% triggers methodology footnote, not data adjustment.

### 6.3 Time-stamping
- Every PDF source carries a fetch timestamp
- Dataset rows carry `last_verified` date
- Annual refresh cycle locks the dataset at a "vintage date" (target: 31 December each year for the just-completed FY)

## 7. Known limitations

The methodology declares the following limitations up-front:

1. **Self-reporting bias.** BRSR is self-reported; companies optimise disclosure for narrative + competitive positioning.
2. **Format variation.** Not all 15 cement companies use identical BRSR formats. Some bury Scope 2 in narrative; others publish a clean Section C Principle 6 table. Coding accommodates both but introduces parsing variability.
3. **Assurance variability.** BRSR Core assurance was mandatory for Top 150 in FY 2023-24; Top 250 in FY 2024-25. Not every cement major in our sample was in the Top 250. Where assurance is voluntary, assurance level differs (Reasonable vs Limited).
4. **Scope 3 patchy.** Scope 3 disclosure across 15 entities is inconsistent in both categories disclosed and methodology. Sector-level Scope 3 aggregation is reported with explicit limitations.
5. **Sub-segment disclosure variability.** Where a cement entity is multi-business (e.g., cement + RMC + AAC), the cement-segment-only data is preferred but not always disclosed separately. Where consolidated data is used, this is flagged.
6. **Captive vs grid electricity boundary.** Companies disclose location-based Scope 2 using grid emission factors of varying vintages. Sample data is normalised to **CEA V21.0 / V20.0** (the operative versions during the FY 2024-25 reporting period) where possible, with company-disclosed values retained as primary.
7. **No representation of unlisted cement.** ~20-30% of Indian cement capacity (regional + unlisted producers) is outside this benchmark.

## 8. Reproducibility kit

Published alongside the anchor article:

1. **Dataset (CSV + JSON)** — every row + every data point at `src/data/research/brsr-cement-fy2425.{csv,json}`
2. **Methodology document** — this file (`methodology.md`)
3. **Scraping scripts** — fetch + parse pipeline at `scripts/research/brsr-cement-benchmark/`
4. **Evidence cache** — all source BRSR PDFs cached at `scripts/primary-source/evidence/`
5. **Quality control log** — `qc-log.md` showing every cross-validation pass + outcome
6. **Restatement log** — `restatement-log.md` showing every restatement detected
7. **Changelog** — `CHANGELOG.md` showing every dataset revision

Anyone with the published methodology + dataset can independently reproduce every statistic in the anchor article.

## 9. Citability discipline

This methodology is designed to be **courtroom-citable + academic-defensible + journalism-grade**:

- Every statistical claim traces back to a primary BRSR source page
- Every source page is independently re-fetchable + cross-verifiable
- Methodology is published, frozen at the anchor article date, and not retroactively revised
- Limitations + sample-frame caveats are stated up-front
- No qualitative or narrative claims about specific companies that the underlying disclosure does not directly support

## 10. Versioning + refresh

- **v0.1** (current) — methodology design, pre-data-collection
- **v0.2** — methodology after Ravi sign-off, pre-scraping
- **v1.0** — methodology locked at anchor publication date
- **v1.1+** — minor corrections (typos, formatting); never retroactively edits a published statistic
- **v2.0** — annual refresh with FY 2025-26 data (locks v1.0 as historical anchor; publishes parallel v2.0 anchor)

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**Sign-off requested:** Ravi Patel
**Pre-scraping checklist:** ☐ Sample frame approved · ☐ Field definitions approved · ☐ Statistical treatment approved · ☐ Reproducibility kit scope approved