How does SEBI define child labour, forced labour and sexual harassment for BRSR complaints?

Guidance from the Securities and Exchange Board of India (SEBI) for the Business Responsibility and Sustainability Report (BRSR) defines a child as a person who has not completed the 14th year of age. Forced or involuntary labour is work extracted under the menace of penalty, and includes labour paid less than the government-stipulated minimum wage.

The complaint rows these terms feed

Principle 5 asks for complaints by employees and workers, filed during the year and pending at year end, with remarks, on: sexual harassment, discrimination at workplace, child labour, forced labour or involuntary labour, wages, and other human rights related issues.

Definitions in the guidance note

• Child: section 2(ii) of the Child Labour (Prohibition and Regulation) Act, 1986, as amended, a person who has not completed the 14th year of age. The Act prohibits employment of adolescents aged 14 to 18 in hazardous occupations and processes and regulates their working conditions where they are not prohibited.
• Forced or involuntary labour: all work or service extracted under the menace of penalty. It includes terms such as bonded labour and modern slavery, and any labour for which the worker receives less than the government-stipulated minimum wage.
• Sexual harassment: any one or more of the unwelcome acts or behaviour, directly or by implication: physical contact and advances, a demand or request for sexual favours, sexually coloured remarks, showing pornography, or any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
• Discrimination: unjust or prejudicial treatment of people, especially on the grounds of, but not limited to, caste, creed, sex, race, ethnicity, age, colour, religion, disability, socio-economic status or sexual orientation.

What follows for a supplier

The forced labour definition reaches wage payment. Because it includes labour paid below the minimum wage, a worker's complaint about pay below the minimum can be filed in the forced labour row as well as the wages row. The guidance does not say a wage register alone creates a disclosure. That is our reading.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not hold workforce or complaint records, so these rows stay with your HR team.

• Human rights assessments of value chain partners
• BRSR minimum wage table for workers
• BRSR and BRSR Core in plain words

Sources: SEBI, master circular for LODR compliance, 11 July 2023, BRSR guidance note and formats, SEBI, Updated BRSR format, Annexure II to circular of 12 July 2023

Last reviewed 2026-11-05. The guidance and formats are from SEBI's 11 July 2023 master circular and the Annexure II format. SEBI's April 2025 FAQ names a later master circular dated 11 November 2024, so check the current guidance note and format before you file.