Gender Diversity — Employees + Workers Disclosure — BRSR Core Attribute

What this attribute is

Gender Diversity is part of the nine BRSR Core attributes that SEBI requires every Top-1,000 listed entity to subject to independent reasonable assurance under SAE 3000 (Revised). It sits within NGRBC Principle 3 — Employees + Workers Wellbeing and NGRBC Principle 5 — Human Rights — the cohort headcount + leadership representation flows through P3; the wage-ratio dimension flows through P5.

The attribute captures five families of metrics:

1. Headcount diversity — % female in total employees + workers, split by permanent vs other-than-permanent
2. Leadership representation — % female at Board, KMP (Key Managerial Personnel), and Senior Management
3. Maternity + return-to-work — number on maternity leave + return rate + 12-month retention
4. Remuneration ratio — median female-to-male remuneration ratio per employee category (the Female Wages sibling attribute covers the wage-share angle)
5. Turnover / attrition — gender-wise voluntary + involuntary attrition

The headline ESG-rating signal is the combination of leadership representation (board / KMP / senior management) + remuneration ratio + 12-month maternity retention. Improvement on all three signals a maturing inclusion programme; movement on headline % alone (without leadership + wage parity follow-through) signals tokenism.

Headcount diversity — the % female metric

% Female Employees = (Number of female employees)
                   ÷ (Total employees)

% Female Workers   = (Number of female workers)
                   ÷ (Total workers)

Reported separately for:

• Employees: Permanent (own payroll, permanent contract)
• Employees: Other than Permanent (own payroll, contract / temporary / trainee)
• Workers: Permanent (contractor’s permanent staff at the entity’s premises)
• Workers: Other than Permanent (contractor’s temporary / casual / pieceworkers)

The split matters: many entities have higher female representation in permanent staff (white-collar / corporate functions) than in non-permanent staff (production-line workers, security, housekeeping where the workforce skews male in Indian industry).

Differently-abled cohort

Alongside gender, BRSR Principle 5 EI 3 requires the same headcount split for differently-abled employees + workers. This sits under the same diversity umbrella + is part of the BRSR Core attribute scope. The attribute name in SEBI BRSR Core Annexure I is “Enabling gender diversity” but the disclosure structure routinely covers both gender + disability dimensions.

Leadership representation

Board level

% female directors = (Number of women directors) ÷ (Total directors).

Mandate floor: at least 1 woman director (Companies Act 2013 Sec 149(1)) + at least 1 independent woman director for Top 1,000 entities (SEBI LODR Reg 17(1)).

Reported splits:

• Total female directors
• Of which, Independent Directors
• Of which, Executive / Non-Executive

KMP level

% female KMP = (Number of women KMP) ÷ (Total KMP).

KMP per Section 2(51) of the Companies Act 2013: MD, WTD, CEO, CFO, Company Secretary, Manager, Chief Risk Officer, and other officers designated by the Board. The KMP register under Section 203 is the source-of-truth count.

Senior Management

% female Senior Management = (Number of women in Senior Management) ÷ (Total Senior Management).

Senior Management per SEBI LODR Reg 17 = officers / personnel one level below the Board. Includes all Heads of Department / Functional Heads, regardless of designation. Each entity should disclose its definition / scope of “Senior Management” in the BRSR cover note narrative.

Maternity + return-to-work

Per BRSR Principle 3 Essential Indicator 3:

Item	Permanent Female Employees	Permanent Female Workers
Total	A	A’
On maternity leave during the FY	B	B’
Returned to work after maternity leave during the FY	C	C’
Retained 12 months after return	D	D’

Return rate = C / B; 12-month retention rate = D / C.

Best-practice benchmark: 90%+ return rate; 80%+ 12-month retention. Sustained drop below either signals issues in the return-to-work programme (lactation facilities, flexible working, childcare support, role-protection on return).

Companies Act 2013 also mandates a lactation facility for entities with > 50 employees per Maternity Benefit (Amendment) Act 2017; some BRSR cover notes report the count of lactation rooms as a supplementary narrative.

Remuneration ratio (gender)

Female:Male Remuneration Ratio = Median female remuneration in the category
                                ÷ Median male remuneration in the category

For each of the following employee + worker categories:

• Board of Directors
• KMP
• Senior Management
• Middle Management
• Junior Management
• Workers (own + contractor)

A ratio of 1.00 = parity; < 1.00 = female remuneration below male median; > 1.00 = above. The disclosure is the ratio itself, not a derived “gender pay gap percentage.”

The sibling Female Wages Core attribute computes the WAGE-SHARE metric (% of total wages paid to female employees / workers) — different formula, complementary signal. Together they create the gender remuneration picture.

Worked example

Mid-size IT services entity for FY 2025-26.

Headcount

Cohort	Total	Female	% Female
Employees: Permanent	4,800	1,680	35.0%
Employees: Other than Permanent	600	270	45.0%
Workers: Permanent	0	0	n/a
Workers: Other than Permanent	350	95	27.1%
Total workforce	5,750	2,045	35.6%

Leadership representation

Level	Total	Female	% Female
Board	9	3	33.3%
— of which Independent	5	2	40.0%
KMP	5	2	40.0%
Senior Management	28	8	28.6%

Maternity + retention

• Permanent female employees: 1,680
• On maternity leave during FY 2025-26: 95
• Returned to work after maternity: 88
• Retained 12 months after return: 75
• Return rate = 88 / 95 = 92.6%
• 12-month retention = 75 / 88 = 85.2%

Remuneration ratio (Female:Male median)

Category	Ratio
Board of Directors	0.94
KMP	0.91
Senior Management	0.96
Middle Management	0.98
Junior Management	1.02
Workers (contract)	0.95

Overall pattern: parity at junior management + favourable at the lowest-recruitment-level (driven by graduate-hire pay grids being seniority-neutral), gap widens at senior + KMP levels — consistent with industry pattern. The disclosure surfaces the leadership gap for board oversight.

Evidence the assurance partner checks

Document	What it evidences	Source
Payroll master (gender-tagged, PAN-level)	Employee headcount + gender split + remuneration	HRMS / SAP HR / Workday
Contractor attendance + payroll registers	Worker headcount + gender split	Manpower agency
Board composition certificate	Board count + women director count + independent woman	Company Secretary
KMP register under Section 203	KMP count + gender split	MGT-7 Annexure
Senior Management list (Board-approved)	Senior Management cohort definition + count	Board minutes
Form MGT-9 (extract of annual return)	Cross-check on board + KMP composition	MCA filing
Maternity leave logs	Maternity leave usage + return events	HRMS leave module
Insurance maternity claim history	Independent cross-check on maternity claim count	Group medical insurance carrier
Lactation facility records / count	Lactation room infrastructure	Admin / facilities
12-month retention extract	Permanent female employees retained ≥ 12 months post return	HRMS attrition report
Gender-wise hires + exits log	Attrition rate computation	HRMS hire/exit logs

Common audit findings

1. Cohort definition inconsistency. % female computed on permanent employees only, while the SEBI-required disclosure is permanent + other-than-permanent + workers separately. Result: misleading headline. Restate per cohort with explicit splits.
2. Senior Management scope undefined. Without a documented scope (e.g., “all Heads of Department + Functional Heads, reporting to KMP”), the count is non-reproducible. The BRSR cover note should explicitly state the Senior Management scope used.
3. Contractor headcount source unverified. Worker headcount sourced from a contractor’s own self-report rather than the entity’s gate-pass / attendance register. Need independent contractor-attendance verification at the entity’s premises.
4. Maternity return rate inflated. Counting women who returned but didn’t actually resume work (e.g., resigned within 30 days of return). The return rate should include the post-return employment continuity check.
5. Remuneration ratio computed on mean instead of median. Mean is sensitive to outliers (a single high-earning CEO can distort the KMP mean dramatically). BRSR + GRI 405 convention is median, not mean.
6. Independent woman director missed. The Top 1,000 mandate requires 1 INDEPENDENT woman director. Some entities have a woman Executive Director or Non-Executive (non-independent) Director and miss the independence requirement. SEBI LODR Reg 17(1) non-compliance is a separate penalty.
7. Differently-abled cohort omitted. The BRSR diversity disclosure structure routinely covers both gender + disability dimensions. Entities that only report gender + omit the disability split create an incomplete disclosure.
8. Acquired-entity headcount inclusion timing. Acquisitions mid-year — clarify in the boundary disclosure whether acquired entity’s workforce is included from the acquisition date or excluded until next FY. Inconsistent treatment between numerator + denominator causes restatement at assurance stage.

Sibling attribute: Female Wages

Female Wages as % of Total Wages is the wage-share metric — % of total wage outlay paid to female employees + workers. This Gender Diversity attribute captures the headcount + leadership + retention + ratio metrics. Together they form the full BRSR Core gender diversity disclosure:

• Female Wages attribute → “what share of the wage bill went to women”
• Gender Diversity attribute → “what share of the headcount + leadership were women + did they stay?”

Both attributes are part of the BRSR Core assurance scope; their numbers must reconcile in the cover note narrative.

XBRL filing

This attribute is filed in the BRSR XBRL instance document under the Principle 3 Essential Indicator 3 (gender + disability split) + Principle 5 Essential Indicator 3 (remuneration ratio) elements from the MCA-published BRSR taxonomy module. Per-category gender counts + leadership representation + retention rate + remuneration ratio are filed as separate elements. Verify element names + unit references against the current MCA taxonomy version before generating the instance document.

Both current-year and previous-year context references must be populated. See XBRL Taxonomy for BRSR for the structural overview.

How this attribute rolls up into the BRSR Core engagement

This attribute is one of the BRSR Core attributes under Principle 3 + Principle 5. The signed BRSR Core assurance report attests these numbers to reasonable assurance under SAE 3000 (Revised). Workpapers retained by the assurance partner cover:

• Payroll master vouching (PAN-level, gender-tagged)
• Contractor attendance + payroll cross-check
• Board + KMP + Senior Management composition reconciliation
• Maternity leave + return + 12-month retention sampling
• Median remuneration computation re-performance
• Cohort boundary alignment with the parent BRSR scope

For the engagement that produces the signed assurance opinion, see BRSR Core Assurance.

Related reading

• NGRBC Principle 3 — Employees + Workers Wellbeing — parent pillar (headcount + leadership)
• NGRBC Principle 5 — Human Rights — parent pillar (remuneration ratio)
• Female Wages as % of Total Wages — sibling Core attribute (wage-share dimension)
• Spend on Employee Wellbeing — sibling Core attribute (financial input)
• POSH Complaints Disclosure — sibling Core attribute (workplace dignity)
• Safety Metrics — LTIFR + Fatalities — sibling Core attribute (safety outcome)
• Document Evidence Requirements — full evidence checklist
• XBRL Taxonomy for BRSR — XBRL filing structure
• BRSR Core Assurance — service