Atul Limited. — Annual Report 2023

Jul 10, 2023

Corporate Statutory Financial Overview Reports Statements

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Business Responsibility and Sustainability Report

SECTION A: GENERAL DISCLOSURE

I. BASIC DETAILS

01. Corporate identity number

L99999GJ1975PLC002859

02. Name

Atul Ltd

03. Year of incorporation

04. Registered office address

05. Corporate office address

06. E-mail address

1975

Atul House, G I Patel Marg, Ahmedabad 380 014, Gujarat, India

Atul 396 020, Gujarat, India

sec@atul.co.in

07. Telephone

(+91 2632) 230000

08. Website

www.atul.co.in

09. Financial year

2022-23

10. Stock exchanges

BSE Ltd and National Stock Exchange of India Ltd

11. Paid-up capital

` 29,51,37,550

12. Contact person

Mr Bharathy Mohanan (+91 2632) 230000 bn_mohanan@atul.co.in

13. Reporting boundary

Standalone

66 Atul Ltd | Annual Report 2022-23

II. PRODUCTS | SERVICES

14. Business activities

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No. Main activities Business activities % of total turnover
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No.	Main activities	Business activities	% of total turnover
1.	Life Science Chemicals	R&D, technology, procurement, manufacturing, sales and marketing	36%
2.	Performance and Other Chemicals	R&D, technology, procurement, manufacturing, sales and marketing	63%
3.	Others	R&D, technology, procurement, manufacturing, sales and marketing	1%

15. Products | services sold

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No. Products | Services NIC code % of total turnover
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|No.|Products | Services|NIC* code|% of total turnover|
|---|---|---|---|
|||||
|1.|Intermediates|201|31%|
|2.|Epoxy resins and hardeners|202|30%|
|3.|Herbicides|202|23%|
|4.|Textile dyestuffs|202|12%|

*National Informatics Centre

III. OPERATIONS

16. Number of locations where offices and plants are situated

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8
Offices
4
Plants
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12
total
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17. Markets served

• a) Number of locations

Locations	Numbers
National (states)	29
International (countries)	83

b) Contribution of exports as a percentage of total turnover 50%

c) Types of customers The Company serves ~ 4,000 customers belonging to ~ 30 diverse industries.

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Corporate Statutory Financial Overview Reports Statements

IV. EMPLOYEES

18. As at the end of the financial year

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No. Particulars Total (A)
Male Female
No. (B) % (B/A) No. (C) % (C/A)
a. Employees
Managers
1. Permanent managers (A) 1,737 1,598 92% 139 8%
2. Other than permanent managers (B) 43 35 81% 8 19%
3. Total managers (A+B) 1,780 1,633 92% 147 8%
Workers
4. Permanent workers (C) 1,447 1,447 100% - NA
5. Other than permanent workers (D) 2,558 2,520 99% 38 1%
6. Total workers (C+D) 4,005 3,967 99% 38 1%
b. Differently abled employees
Managers
1. Permanent managers (E) 4 4 100% - NA
2. Other than permanent managers (F) - - NA - NA
3. Total differently abled managers (E+F) 4 4 100% - NA
Workers
4. Permanent workers (G) - - NA - NA
5. Other than permanent workers (H) - - NA - NA
6. Total differently abled workers (G+H) - - NA - NA
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NA: not applicable

19. Representation of women

Total (A)	No. and % of females	No. and % of females
	No. (B)	% (B/A)
	1 8%
	- -

68 Atul Ltd | Annual Report 2022-23

20. Turnover rate for permanent employees

(%)

MANAGERS WORKERS Male 19% 10%	MANAGERS WORKERS Male 19% 10%	FY 2022-23 Female Total 14% 19% - 10% Male 19% 10%	FY 2022-23 Female Total 14% 19% - 10% Male 19% 10%	FY 2022-23 Female Total 14% 19% - 10% Male 19% 10%	FY 2022-23 Female Total 14% 19% - 10% Male 19% 10%	FY 2021-22 Female Total 16% 19% - 10% Male 10% 9%	FY 2021-22 Female Total 16% 19% - 10% Male 10% 9%	FY 2021-22 Female Total 16% 19% - 10% Male 10% 9%	FY 2021-22 Female Total 16% 19% - 10% Male 10% 9%	FY 2020-21 Female Total	FY 2020-21 Female Total	FY 2020-21 Female Total
	19%		14%	19%	19%		16%	19%	10%		8%	10%
	10%		-	10%	10%		-	10%	9%		-	9%

V. HOLDING, SUBSIDIARY AND ASSOCIATE ENTITIES (INCLUDING JOINT VENTURES)

21. Subsidiary, joint venture and associate entities

This information is given on page numbers 30 and 31 in the annexure to the Directors' Report. The entities do not participate in business responsibility initiatives.

VI. CORPORATE SOCIAL RESPONSIBILITY

22. Applicability of CSR as per Section 135 of the Companies Act, 2013

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Turnover 5,002 cr Net worth 4,590 cr
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VII. TRANSPARENCY AND DISCLOSURES COMPLIANCES

23. Complaints or grievances on any of the nine principles under National Guidelines on Responsible Business Conduct (NGRBC)

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Stakeholder 2022-23 2021-22
group from Grievance redressal
whom mechanism and its Complaints Complaints Complaints Complaints
complaint is URL received pending Remarks received pending Remarks
resolution resolution
received
Communities A mechanism is in
place to interact with
community leaders Nil Nil - 6 Nil -
to understand
and address their
concerns, if any
Shareholders 22 Nil - 9 Nil -
Investors
(other than Nil Nil - Nil Nil -
shareholders) Under
Employees implementation Nil Nil - Nil Nil -
Customers Nil Nil - Nil Nil -
Value chain
Nil Nil - Nil Nil -
partners
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Corporate Statutory Financial Overview Reports Statements

24. Overview of material responsible business conduct areas

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High Medium Low
Material area identified Criticality Mitigating actions
Human resources • Learning and development initiatives
development • Performance management quality
• Recycle of water
•
Decrease in emissions, effluent and waste
Circular economy
• Recycle of plastic waste
• Conversion of domestic waste to manure
•
Energy saving through process efficiency
Energy efficiency
and redesign of equipment
Product stewardship • Decrease in consumption of raw materials
• Implementation of ISO 45001:2018
(occupational health and safety
Occupational health
management system)
and safety
• Actions on zero harm
• Safety assessments and audits
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70 Atul Ltd | Annual Report 2022-23

SECTION B: MANAGEMENT AND PROCESS DISCLOSURES

NGRBC principles and core elements

NGRBC released by the Ministry of Corporate Affairs has adopted nine principles related to business responsibility. They are as follows:

P1

• Businesses will conduct and govern themselves with integrity and in a manner that is ethical, transparent and accountable.

P2 P3

Businesses will provide goods and services in a manner that is sustainable and safe.

• Businesses will respect and promote the well-being of all employees, including those in their value chains.

P4

Businesses will respect the interests of and be responsive to all its stakeholders.

P5

Businesses will respect and promote human rights.

P6

Businesses will respect and make efforts to protect and restore the environment.

P7

• Businesses, when engaging in influencing public and regulatory policy, will do so in a manner that is responsible and transparent.

P8

Businesses will promote inclusive growth and equitable development.

P9

Businesses will engage with and provide value to their consumers in a responsible manner.

Yes No

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Disclosure questions P1 P2 P3 P4 P5 P6 P7 P8 P9
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Disclosure questions	Disclosure questions	P1	P2	P3	P4	P5	P6	P7	P8	P9
Policy and managementprocesses
01.	a) The policy	policies cover each principle and its core elements
	b) Policy approved by the Board
	c) URL of the policies	The Company is in the process of publishing these policies on its website.
02.	The policies are translated into procedures
03.	The enlisted policies extend to the value chain partners
04.	Name of the national and international codes	certifcations	labels	standards adopted and mapped against each principle	The Company has developed policies for its signifcant operations in conformance with the international standards (such as ISO 9000, ISO 14000, OHSAS 18000	ISO 45000), United Nations Global Compact guidelines and principles of International Labour Organisation. The Company is in the process of acquiring the sustainable procurement certifcation (ISO 20400).
05.	Specifc commitments, goals and targets set with defned timelines, if any	The Company is engaging with subject matter experts and actively pursuing sustainability improvement agenda.
06.	Performance against the specifc commitments, goals and targets along with reasons in case the same are not met	NA

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Corporate Statutory Financial Overview Reports Statements

GOVERNANCE, LEADERSHIP AND OVERSIGHT

Statement by Director responsible for the Business Responsibility Report, highlighting 07. environmental, social and governance (ESG) related challenges, targets and achievements

Highest authority responsible for 08. implementation and oversight of the business responsibility policy(ies)

Specific Committee of the Board or a 09. Director responsible for decision

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The Company is committed to integrating ESG principles into its businesses which is central to improving the quality of life of the communities it serves.

Board of Directors

The Company has appointed a Whole-time Director to oversee implementation of the policies.

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10. Details of review of national guidelines for responsible business conduct

|Subject for review
Performance against above policies and follow up action
Compliance with statutory requirements of relevance to the
principles and rectifcation of any non-compliance|Review by Director | a Committee of the Board | any
other committee and its frequency|Review by Director | a Committee of the Board | any
other committee and its frequency|Review by Director | a Committee of the Board | any
other committee and its frequency|Review by Director | a Committee of the Board | any
other committee and its frequency|Review by Director | a Committee of the Board | any
other committee and its frequency|Review by Director | a Committee of the Board | any
other committee and its frequency|Review by Director | a Committee of the Board | any
other committee and its frequency|Review by Director | a Committee of the Board | any
other committee and its frequency|Review by Director | a Committee of the Board | any
other committee and its frequency|
|---|---|---|---|---|---|---|---|---|---|
||P1|P2|P3|P4|P5|P6|P7|P8|P9|
||Quarterly|||||||||
||Quarterly|||||||||

11. Independent assessment | evaluation of the working of its policies by an external agency and name of the agency

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P1 P2 P3
Yes
P4 P5 P6 Primarily
by Aneja
Associates
P7 P8 P9
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72 Atul Ltd | Annual Report 2022-23

SECTION C: PRINCIPLE-WISE PERFORMANCE DISCLOSURE

PRINCIPLE 1

Businesses will conduct and govern themselves with integrity and in a manner that is ethical, transparent and accountable.

Essential indicators

1. Percentage coverage by training and awareness programs on any of the Principles during the financial year

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Number of
Segment Topics | Principles % of persons
programs
• Code of conduct
BOARD OF • Corporate governance
4 100%
DIRECTORS • Human rights
• Prevention of sexual harassment (POSH)
• Code of conduct
• Human rights
KMP 5 100%
• POSH
• Whistleblower
• Acceptance of gifts and business courtesies
EMPLOYEES • Atul Values
(excluding Executive 7 • Code of conduct 100%
Directors and KMP) • Equal employment opportunity and anti-discrimination
• Human rights • POSH • Whistleblower
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2. Fines | penalties | punishments | awards | compounding fees | settlement amount paid in proceedings (by the Company or by Directors | KMP) with regulators | law enforcement agencies | judicial institutions, in the financial year

• a. Monetary

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Name of the regulatory |
NGRBC Brief of the Has an appeal
Type enforcement agencies | Amount ( ` )
principle case been preferred?
judicial institutions
Penalty | fine NA NA Nil NA
Settlement NA NA Nil NA
Compounding fee NA NA Nil NA
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• b. Non-monetary

|Type|NGRBC
principle|Name of the regulatory |
enforcement agencies |
judicial institutions|Brief of the case|Has an appeal
been preferred?|
|---|---|---|---|---|
|Imprisonment|NA|NA|NA|NA|
|Punishment|NA|NA|NA|NA|

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Corporate Statutory Financial Overview Reports Statements

3. Appeal | revision preferred in cases where monetary or non-monetary action has been appealed

Not applicable.

4. Anti-corruption or bribery policy and URL of the policy

The Company has a dedicated code of conduct covering anti-corruption and anti-bribery aspects. The code of conduct has been published on the Company website: www.atul.co.in/pdf/investors/policies/Code-of-Conduct-18-19.pdf

5. Directors | KMP | employees (other than KMP) against whom disciplinary action was taken by any law enforcement agency for the charges of bribery | corruption

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2022-23 2021-22
Directors Nil Nil
KMP Nil Nil
Employees
Nil Nil
(other than KMP)
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6. Complaints with regard to conflict of interest

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2022-23 2021-22
Number Remarks Number Remarks
Conflict of interest of the Directors Nil Nil Nil Nil
Conflict of interest of KMP Nil Nil Nil Nil
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7. Details of any corrective action taken or underway on issues related to fines | penalties | action taken by regulators | law enforcement agencies | judicial institutions, on cases of corruption and conflicts of interest

Not applicable

Leadership indicators

1. Training and awareness programs conducted for value chain partners on any of the Principles during the financial year

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Number of % of value chain
Topics | Principles
programs partners
• Business ethics • Occupational health and
• Capacity utilisation safety
• Code of conduct • Plant setup and automation
1 46%
• Environment management • Quality management
• Labour and human rights • Supplier and contractor
sustainability
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2. Processes to avoid | manage conflict of interest involving members of the Board

The Company has a dedicated code of conduct to manage conflict of interest involving members of the Board. The code of conduct is available on the website of the Company: www.atul.co.in/pdf/investors/policies/Code-of-Conduct-18-19.pdf

74 Atul Ltd | Annual Report 2022-23

PRINCIPLE 2

Businesses will provide goods and services in a manner that is sustainable and safe.

Essential indicators

1. Percentage of research and development (R&D) spent and capital expenditure (CapEx) in specific technologies to improve environmental and social impacts of products and processes to total R&D spent and CapEx, respectively

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Improvements in social and environmental aspects
• commissioned equipment to convert existing
processes into continuous processes
R&D 17% 15%
• decreased consumption of solvents and raw
spent 2022-23 2021-22 materials in six products
• increased yield in twenty-two products
• commissioned 100 kLD sewage treatment plant
37% 26% • improved Carbon monoxide gas scrubber in new
CapEx phosgene plant
2022-23 2021-22
• reduced volatile organic compounds by nitrogen
blanketing in solvent storage tanks
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2. a) Procedures for sustainable sourcing:

  - The Company has procedures in place for sustainable sourcing.

  - The URL to its responsible sourcing policy is: www.atul.co.in/economic-sustainability/responsible-procurement/

• b) Percentage of inputs sourced sustainably:

  • 92%

3. Processes to safely reclaim products for reusing, recycling and disposing of at the end of life, for a) plastics (including packaging), b) e-waste, c) hazardous waste and d) other waste

The Company follows the applicable processes laid down by the regulatory authorities.

4. Applicability of extended producer responsibility (EPR) to the activities of the Company and whether the waste collection plan is in line with EPR plan submitted to pollution control boards

• EPR is applicable to the activities of the Company and the waste collection plan is in line with the EPR plan submitted to the Central Pollution Control Board.

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Corporate Statutory Financial Overview Reports Statements

Leadership indicators

1. Life cycle perspective | assessment (LCA) for products

• The Company has conducted a LCA for four products and product carbon foot printing for six products across Businesses.

2. Significant social or environmental concerns and | or risks arising from production or disposal of products identified in LCA or through any other means and their mitigation:

• There were no significant social or environmental concerns and | or risks arising from production or disposal of products.

3. Recycled or reused input material to total material (by value) used in production (for manufacturing industry) or providing services (for service industry)

• The Company has in-house facilities to recycle its waste and is continuously striving to maximise it. At present, it is recycling 5.50% of its waste.

4. Products and packaging reclaimed at end of life of products and reused, recycled and safely disposed (in metric tons)

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2022-23 2021-22
Safely Safely
Reused Recycled Reused Recycled
disposed disposed
Plastics (including
packaging)
E-waste
Nil Nil Nil Nil Nil Nil
Hazardous waste
Other waste
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5. Reclaimed products and their packaging materials (as percentage of products sold) for each product category

Not applicable

76 Atul Ltd | Annual Report 2022-23

PRINCIPLE 3

Businesses will respect and promote well-being of all employees, including those in their value chains.

Essential indicators

01. a) Details of measures for well-being of managers

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% of managers covered by
Health Accident Maternity Paternity Day care
Category Total insurance insurance benefits benefits facilities
(A)
No. (B) % (B/A) No. (C) % (C/A) No. (D) % (D/A) No. (E) % (E/A) No. (F) % (F/A)
Permanent managers
1,598 1,598 100% 1,598 100% - NA 13 0.81% - NA
Male
139 139 100% 139 100% 2 1.5% - NA - NA
Female
Total 1,737 1,737 100% 1,737 100% 2 0.11% 13 0.75% - NA
Other than permanent managers
35 - NA 35 100% - NA - NA - NA
Male
8 - NA 8 100% - NA - NA - NA
Female
43 - NA 43 100% - NA - NA - NA
Total
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• b) Measures for the well-being of workers

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% of workers covered by
Health Accident Maternity Paternity Day care
Category Total insurance insurance benefits benefits facilities
(A)
No. (B) % (B/A) No. (C) % (C/A) No. (D) % (D/A) No. (E) % (E/A) No. (F) % (F/A)
Permanent workers
1,447 1,447 100% 1,447 100% - NA 1,447 100% - NA
Male
- - NA - NA - NA - NA - NA
Female
1,447 1,447 100% 1,447 100% - NA 1,447 100% - NA
Total
Other than permanent workers
2,520 - NA 2,520 100% - NA - NA - NA
Male
38 - NA 38 100% - NA - NA - NA
Female
2,558 - NA 2,558 100% - NA - NA - NA
Total
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Corporate Statutory Financial Overview Reports Statements

02. Retirement benefits for current financial year and previous financial year

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2022-23 2021-22
Deducted Deducted
No. Benefits and and
Managers Workers deposited Managers Workers deposited
with the with the
authority authority
1. Provident fund 100% 100% Yes 100% 100% Yes
2. Gratuity 100% 100% NA 100% 100% NA
3. Employee state insurance 0.5% 16% Yes 1% 12% Yes
4. Others (please specify) NA NA NA NA NA NA
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03. Accessibility of workplaces

Most of the working locations are accessible to differently abled persons.

04. Equal opportunity policy as per the Rights of Persons with Disabilities Act, 2016

The Company provides equal opportunities to all its employees and to all eligible applicants for employment in the Company.

05. Return to work and retention rates of permanent employees who took parental leave in the financial year

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Return to work rate Retention rate
Male Female Total Male Female Total
100% 100% 100% 100% 100% 100%
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78 Atul Ltd | Annual Report 2022-23

06. Grievance redressal mechanism for employees

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Category Details of the mechanism in brief Category
Permanent Permanent
managers The employee may workers
register a complaint
with the concerned
immediate manager
Other than or the concerned HR Other than
permanent manager. permanent
managers workers
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07. Membership of employees in recognised association(s) or union(s)

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FY 2022-23 FY 2021-22
Employees who Employees who
Category Total Total
are part of are part of
employees % (B/A) employees % (D/C)
association(s) association(s)
(A) (C)
or unions (B) or unions (D)
Permanent employees
3,049 346 11% 2,906 398 14%
Male
139 - 0% 128 - 0%
Female
3,188 346 11% 3,034 398 13%
Total
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08. Training given to employees

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2022-23 2021-22
Skill Health Skill Health
Category Total training % and safety % Total training % and safety %
employees employees
imparted (B/A) training (C/A) imparted (E/D) training (F/D)
(A) (D)
(B) imparted (C) (E) imparted (F)
Permanent employees
3,049 1,337 44% 409 13% 2,906 1,258 43% 2,204 75%
Male
139 19 14% 32 23% 128 87 68% 128 100%
Female
3,188 1,356 43% 441 14% 3,034 1,345 44% 2,332 77%
Total
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Corporate Statutory Financial Overview Reports Statements

09. Performance and career development reviews of employees

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2022-23 2021-22
Category Total Employees who Total Employees who
employees had a career % (B/A) employees had a career % (D/C)
(A) review (B) (C) review (D)
Permanent employees
3,049 1,620 53% 2,906 2,097 72%
Male
139 139 100% 128 118 92%
Female
3,188 1,759 55% 3,034 2,215 73%
Total
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10. Health and safety management system

Implementation of occupational The Company has implemented health and safety management ISO 45001:2018 management system standard. systems

Coverage of such a system 100%

• environment, health and safety management system audit procedure

Processes used to identify • hazard and operability study procedure work-related hazards and • hazard identification and risk assessment procedure assess risks on a routine • management of change procedure and non-routine basis

• permit to work system

• safety observation audit system

Processes for workers to report the work-related hazards and to The Company has requisite processes. remove themselves from such risks Access to employees to non-occupational medical The employees have the requisite access. and healthcare services

80 Atul Ltd | Annual Report 2022-23

11. Safety related incidents

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Managers Workers
Safety incident | number Category 2022-23 2021-22
- -
Lost time injury frequency rate (per one
million-person hours worked)
0.05 0.06
10 16
Total recordable work-related injuries
16 20
- -
Number of fatalities
1 -
- -
High consequence work-related injury or ill-health
(excluding fatalities) - -
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12. Measures taken to ensure a safe and healthy workplace

The Company has environment, health and safety (EHS) policy. To ensure steady improvement in EHS performance, it is adopting voluntary standards such as ISO 45001.

13. Complaints made by employees

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2022-23 2021-22
Category
Pending Pending
Filed Remarks Filed Remarks
resolution resolution
Working conditions - - NA - - NA
Health and safety - - NA - - NA
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14. Plants and offices assessed (by the Company | statutory authorities | third parties)

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Health and 100% Working 100%
> >
safety practices covered conditions covered
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15. Provide details of any corrective action taken or underway to address safety-related incidents (if any) and on significant risks | concerns arising from assessments of health and safety practices and working conditions

• conducted training on scaffolding erection and inspection for targeted employees

• developed in-house process safety laboratory to assess process safety risk

• implemented ‘life-saving rules’ for the mandatory safety requirement

• implemented ‘line breaking work permit’

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Corporate Statutory Financial Overview Reports Statements

Leadership indicators

1. Extension of life insurance or other compensatory package in the event of death

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Managers > Yes Workers > Yes
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2. Measures undertaken to ensure that statutory dues are deducted and deposited by the value chain partners

• conducted quarterly audits of all statutory records and compliances maintained by the contractors

• imposed appropriate penalty on the contractor as per the defined standard operating procedure in case of any non-compliance with reference to provident fund remittance, payment of professional tax, employee compensation , etc

3. Number of managers | workers having suffered high consequence work related injury | ill-health | fatalities (as reported in Q11. of essential indicators, above), who have been rehabilitated and placed in suitable employment or whose family members have been placed in suitable employment

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Affected Managers | workers who | whose
managers | workers family members are rehabilitated
Category
2022-23 2021-22 2022-23 2021-22
Managers | workers Nil Nil Nil Nil
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4. Transition assistance programs to facilitate continued employability and the management of career endings resulting from retirement or termination of employment

The Company does not have any formal transition assistance program. Support is however provided on case-to-case basis.

5. Assessment of value chain partners

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92% 92%
Health and Working
assessed assessed
safety practices conditions
(by value) (by value)
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6. Corrective actions taken or underway to address significant risks | concerns arising from assessments of health and safety practices and working conditions of value chain partners

For contractors working in Atul premises:

No corrective action plan has been necessitated arising out of the assessment.

82 Atul Ltd | Annual Report 2022-23

PRINCIPLE 4

Businesses will respect the interests of and be responsive to all its stakeholders.

Essential indicators

1. Processes for identifying key stakeholder groups of the Company

Internal and external group of stakeholders have been identified - they comprise employees, customers, suppliers, communities and shareholders.

2. Key stakeholder groups and the frequency of engagement with vulnerable | marginalised groups

Ongoing

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||||||
|---|---|---|---|---|
|Stakeholder|Vulnerable ||Channels of|Frequency of|Purpose and|
|group|marginalised group|communication|engagement|scope of engagement|
|e-mails, goal setting|business information|
|and performance|and company policies,|
|appraisal review,|career progression,|
|No|
|intranet, talks and letters|performance management,|
|Employees|of Senior Management,|role rotation, training and|
|websites etc|development, etc|
|e-mails, information on|
|packaging,|
|feedback, launches,|
|personal meetings,|
|No|products and formulations|
|portal, social media,|
|Customers|surveys, telephone,|technical service, etc|
|website, etc|
|e-mails, information on|
|packaging, personal|feedback, requirement of|
|No|meetings, portal,|materials and services,|
|Suppliers|surveys, telephone,|technical service, etc|
|website, social media, etc|
|e-mails, letters, personal|payment to exchequers,|
|No|meetings,|policy advocacy, statutory|
|Government|representations, etc|approvals, etc|
|education, empowerment,|
|meetings, projects,|
|No|conservation, health,|
|visits, etc|
|Community|infrastructure, relief, etc|
|analyst meet, annual|
|general meeting, annual|
|information about business|
|No|report, stock exchange|
|and statutory approvals|
|Shareholders|intimations, newspapers,|
|website, etc|

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83

Corporate Statutory Financial Overview Reports Statements

Leadership indicators

1. Processes for consultation between stakeholders and the Board on economic, environmental and social topics or if consultation is delegated

• Business I Function heads interact with the aforesaid stakeholders and provide key updates to the Board.

2. Details of instances as to how the inputs received from stakeholders on management of environmental and social topics were incorporated into policies and activities of the Company

• Environmental and social topics are reviewed and shortlisted based on the materiality study, and standard operating procedures are updated | introduced.

3. Details of instances of engagement with and actions taken to address the concerns of vulnerable | marginalised stakeholder groups

• The concerns of the vulnerable | marginalised stakeholders groups are mainly addressed through six programs, namely, education, empowerment, health, infrastructure, relief and conservation, by Atul Foundation Trust.

PRINCIPLE 5

Businesses will respect and promote human rights.

Essential indicators

01. Employees who have been trained on human rights issues and policy(ies)

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2022-23 2021-22
Category
Total (A) Covered (B) % (B/A) Total (C) Covered (D) % (D/C)
Employees
Permanent 3,188 1,537 48% 3,034 967 32%
Other than permanent 2,601 - 0% 3,762 - 0%
Total employees 5,789 1,537 27% 6,796 967 14%
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02. Minimum wages paid to employees

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2022-23 2021-22
Equal to More than Equal to More than
Category Total Total
minimum wage minimum wage minimum wage minimum wage
(A) (D)
No. (B) % (B/A) No. (C) % (C/A) No. (E) % (E/D) No. (F) % (F/D)
Permanent employees
3,045 - NA 3,045 100% 2,906 - NA 2,906 100%
Male
139 - NA 139 100% 128 - NA 128 100%
Female
Other than permanent employees
2,558 2,558 100% - NA 3,726 - NA 3,726 100%
Male
43 43 100% - NA 36 - NA 36 100%
Female
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84 Atul Ltd | Annual Report 2022-23

03. Remuneration | salary | wages

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Male Female
Category
Median remuneration | Median remuneration |
Number Number
salary | wages salary | wages
Board of Directors 11 19,85,000 1 13,45,000
KMP (including Executive Directors) 5 2,17,39,428 - -
Employees other than Board of 3,044 3,96,601 139 5,82,025
Directors and KMP
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• Focal point (individual | committee) responsible

• 04. for addressing human rights impacts or issues Under progress caused or contributed to by the business:

05. Internal mechanisms to redress grievances related to human rights issues

The mechanism to redress grievances under human rights is same as for other grievances. An independent investigation is carried out by gathering, validating and analysing relevant information. Appropriate action(s) is(are) taken based on the recommendations.

06. Complaints made by employees

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Category 2022-23 2021-22
Filed Pending Remarks Filed Pending Remarks
resolution resolution
Child labour - - NA - - NA
Discrimination at workplace - - NA - - NA
Forced labour | involuntary - - NA - - NA
labour
Sexual harassment - - NA - - NA
Wages - - NA - - NA
Other human rights related - - NA - - NA
issues
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07. Mechanisms to prevent adverse consequences to the complainant in discrimination and harassment cases

Appropriate measures such as confidentiality, protecting the complainant, etc are mentioned in the respective policies.

08. Inclusion of human rights in business agreements and contracts

Adherence to human rights form a part of the business agreements and contracts.

85

Corporate Statutory Financial Overview Reports Statements

09. Plants and offices assessed (by the Company | statutory authorities | third parties)

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Child labour
Discrimination at workplace
100%
Forced | involuntary labour assessed
Sexual harassment
Wages
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10. Corrective action taken or underway to address significant risks | concerns arising from the assessments mentioned in Q 09. above

There were no significant risks | concerns arising from the human rights assessment.

Leadership indicators

• Business processes modified | introduced as a result

• 1. of addressing human rights grievances | complaints

The Company has not received any grievance | complaint regarding human rights.

2. Scope and coverage of human rights due-diligence

3. Accessibility of premises | offices to differently abled visitors

• The Company has not conducted human rights due-diligence. Please refer to Q 03. of Principle 3 above.

4. Assessment of value chain partners (by value):

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Child labour
Discrimination at workplace
92%
assessed
Forced | involuntary labour
(by value)
Sexual harassment
Wages
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5. Corrective action taken or underway to address significant risks | concerns arising from the assessments as mentioned in Q 4. above

• There were no significant risks | concerns arising from the assessment of value chain partners.

86 Atul Ltd | Annual Report 2022-23

Businesses will respect and make efforts to protect and restore the environment.

PRINCIPLE 6

Essential indicators

01. Total energy consumption (in Gigajoules) and energy intensity

		Parameter	Parameter	2022-23 5,41,227 84,78,228 1,95,958 92,15,413 NA 184.23	2021-22
		Total electricity consumption (A)			3,88,971
		Total fuel consumption (B)			94,38,540
		Energy consumption through other sources (C)			1,92,008
		Total energy consumption (A+B+C)			1,00,19,518
		Energy intensity per rupee of turnover (total energy consumption	turnover in rupees) Gigajoules per`million
		Energy intensity			NA

Independent assessment | evaluation | assurance by an external agency

Escon Tech carried out the evaluation of electricity consumption and Ernst and Young provided methodology for calculation.

02. Sites | facilities identified as designated consumers (DCs) under the Performance, Achieve and Trade (PAT) Scheme of Government of India

Power plant and caustic | chlorine plant have been identified as DC under the PAT Scheme. The Company has started disclosing PAT targets from 2020. In the year 2022-23, the Company achieved energy consumption of 0.81 tons of oil equivalent per ton of production against the target of 0.874.

87

Corporate Statutory Financial Overview Reports Statements

03. Disclosures related to water

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Parameter 2022-23 2021-22
Water withdrawal by source (in kL)
i Surface water 36,24,396 28,31,938
ii Groundwater 2,27,872 1,19,385
iii Third-party water - -
iv Seawater | desalinated water - -
v Others (rainwater storage) - -
Total volume of water withdrawal (in kL) (i + ii + iii + iv + v) 38,52,268 29,51,323
Total volume of water consumption (in kL) 38,52,268 29,51,323
Water intensity per rupee of turnover (water consumed/turnover) 770.15 598.77
(kL per ` cr of revenue)
Water intensity – the relevant metric may be selected by the Company NA NA
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Independent assessment | evaluation | assurance by an external agency

No assessment | evaluation | assurance has been carried out by an external agency.

04. Coverage and implementation of zero liquid discharge (ZLD)

ZLD is fully implemented in the Ankleshwar and Tarapur manufacturing sites. Projects are under commissioning to make two of the four areas at Atul site ZLD facilities.

05. Air emissions other than greenhouse gas (GHG) emissions

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Parameter Unit 2022-23 2021-22
NOx T/year 65.78 76.83
SOx T/year 62.73 65.05
Particulate matter (PM) T/year 15.10 10.58
Persistent organic pollutants (POPs) NA NA NA
Volatile organic compounds (VOCs) NA NA NA
Hazardous air pollutants (HAPs) T/year 5.50 4.25
- -
Others – please specify T/year
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Independent assessment | evaluation | assurance by an external agency

Independent assessment | evaluation | assurance has been carried out by Pollucon Laboratories Pvt Ltd.

88 Atul Ltd | Annual Report 2022-23

06. GHG emissions (Scope 1 and Scope 2 emissions) and their intensity

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Parameter Unit 2022-23 2021-22
Total Scope 1 emissions tCO2E 7,73,047 8,56,434
Total Scope 2 emissions tCO2E 1,06,605 83,179
Total Scope 1 and Scope 2 emissions per million of 17.59 19.06<br>turnover tCO2E<br>Total Scope 1 and Scope 2 emission intensity (optional) tCO2E/ NA NA
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Independent assessment | evaluation | assurance by an external agency

Methodology provided by Ernst and Young.

07. Projects related to reducing GHG emissions

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decrease in and arrest of air and nitrogen leakages using ultrasonic leak detection

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decrease in steam consumption by isolating steam headers

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decrease in water consumption by recycling water for the vacuum pump

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installation of variable frequency drive for chilled water supply pumps

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optimisation of chiller power by automation

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optimisation of pump power by impeller trimming

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optimisation of steam pressure for ejectors

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recovery of steam condensate from the reactor jacket

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replacement of compact fluorescent lamps by light emitting diode fittings

89

Corporate Statutory Financial Overview Reports Statements

08. Waste management

	anagement
		2022-23	2021-22
	Waste generated (in metric tons)
	Plastic waste (A)	510.30	381.00
	E-waste (B)	-	920 numbers
	Bio-medical waste (C)	0.60	0.67
	Construction and demolition waste (D)	-	-
	Batterywaste (E)	173 numbers	248 numbers
	Radioactive waste (F)	-	-
	Other hazardous waste (G)	1,22,818.74	64,497.90
	Other non-hazardous waste (H)	41,979.41	80,690.84
		2022-23	2021-22
	Waste recovered through recycling, re-using or other recovery operations (in metric tons)
	(i) Recycled	1,15,310.67	1,39,655.84
	(ii) Reused	-	-
	(iii) Other recoveryoperations	-	-
	Total	1,15,310.67	1,39,655.84
		2022-23	2021-22
	Waste disposed by nature of disposal method (in metric tons)
	(i) Incineration 205.30		0.67
	(ii) Landflling 7,813.67		5,914.00
	(iii) Other disposal operations -		-
	Total 8,018.97		5,914.67

Independent assessment | evaluation | assurance by an external agency

No assessment | evaluation | assurance has been carried out by an external agency

90 Atul Ltd | Annual Report 2022-23

09. Waste management practices and strategies adopted to reduce usage of hazardous and toxic chemicals in the products and processes and the practices adopted to manage such wastes

The Company has state-of-the-art research and development laboratories which has, amongst others, mandate to decrease | reuse | recycle hazardous and toxic wastes.

Hazardous and toxic wastes management SOP (SOP/INC/11) describes the procedure to collect, store, transport and dispose of hazardous and toxic wastes. Such wastes are dealt with as per the consolidation, consent and authorisation and complying with all requirements of Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.

10. Operations | offices in | around ecologically sensitive areas (such as national parks, wildlife sanctuaries, biosphere reserves, wetlands, biodiversity hotspots, forests, coastal regulation zones, etc) where environmental approvals | clearances are required

Not applicable

11. Impact assessments of projects undertaken based on applicable laws in the current financial year Nil

12. Compliance with the applicable environmental laws | regulations | guidelines in India such as the Water (Prevention and Control of Pollution) Act, Air (Prevention and Control of Pollution) Act, Environment protection act and rules thereunder

The Company is compliant with the applicable laws | regulations | guidelines.

Leadership indicators

1. Break-up of the total energy consumed (in Gigajoules) from renewable and non-renewable sources

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Parameter 2022-23 2021-22
From renewable sources
Total electricity consumption (A) 90,777 44,557
- -
Total fuel consumption (B)
- -
Energy consumption through other sources (C)
Total energy consumed from renewable sources (A+B+C) 90,777 44,557
From non-renewable sources
Total electricity consumption (D) 4,50,450 3,44,414
Total fuel consumption (E) 84,78,228 94,38,540
Energy consumption through other sources (F) 1,95,958 1,92,008
Total energy consumed from non-renewable sources (D+E+F) 91,24,636 99,74,962
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Independent assessment | evaluation | assurance by an external agency

Assessment | evaluation | assurance has been carried out by Escon Tech and methodology provided by Ernst and Young.

91

Corporate Statutory Financial Overview Reports Statements

2. Water discharge

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Parameter 2022-23 2021-22
Destination and level of treatment (in kL)
(i) To surface water
No treatment - -
With treatment – level of treatment - -
(ii) To groundwater
No treatment - -
With treatment – level of treatment - -
(iii) To seawater 33,25,819 35,40,589
No treatment - -
With treatment – level of treatment 33,25,819 advanced 35,40,589 advanced
treatment treatment
(iv) Sent to third-parties
No treatment - -
With treatment – level of treatment - -
(v) Others
No treatment - -
With treatment – level of treatment - -
Total water discharged (in kL) 33,25,819 35,40,589
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Independent assessment | evaluation | assurance by an external agency

Independent assessment | evaluation | assurance carried out by Gujarat Pollution Control Board (GPCB), scheduled auditors approved by GPCB and Pollucon Laboratories.

3. Water withdrawal, consumption and discharge in areas of water stress (in kL)

• Not applicable

Independent assessment | evaluation | assurance by an external agency

Not applicable

4. Scope 3 emissions and their intensity

• The Company has not carried out Scope 3 emissions calculation.

5. With respect to the ecologically sensitive areas reported in Q 10. of essential indicators above, details of significant direct and indirect impact on biodiversity in such areas along with prevention and remediation activities Not applicable.

92 Atul Ltd | Annual Report 2022-23

6. Specific initiatives or innovative technologies or solutions undertaken to improve resource efficiency or reduce impact due to emissions | effluent discharge | waste generation

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Initiative undertaken Details of the initiative Outcome of the initiative
Planted 6,89,850 saplings
Development of green belt Sequestration
in the last 13 years for the
around plants and colonies of carbon
development of a green belt
Decrease in sewage
Provided 100 kLD sewage
Elimination of sewage treatment plant for amenity treatment load to CETP
treatment load to CETP blocks at the Atul site Reuse of treated water from
the sewage treatment plant
Equipped reactors with vents
Elimination of volatile
| stacks to vapour recovery Reduction in process
organic compounds (VOCs)
systems | scrubbers stack emissions
and toxic chemical exposure
Enhancement of the Added equipment with Ease of operation at
capacity of CETP programmable logic controller CETP
(PLC) based operation
Improvement of the effluent Provided additional layer
Decrease in COD
quality separation with automation
for effluent discharge load at ETP
Revamp of effluent collection and transfer from source to Segregated acidic and basic effluent streams Decrease in effluent
load at CETP
CETP from the source
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7. Business continuity and disaster management plan

• The Company has a disaster management plan included in the offisite and onsite emergency plan.

Offsite emergency rehearsals as per the plan are conducted at periodic intervals decided by external authorities at Ankleshwar, Atul and Tarapur sites.

8. Significant adverse impact to the environment, arising from the value chain and their mitigation or adaptation measures

There is no significant adverse impact to the environment arising from the value chain of the Company.

9. Percentage of value chain partners (by value) that were assessed for environmental impact

92%

93

Corporate Statutory Financial Overview Reports Statements

PRINCIPLE 7

Businesses, when engaging in influencing public and regulatory policy, will do so in a manner that is responsible and transparent.

Essential indicators

1. Affiliations with trade and industry chambers | associations

• Membership of | affiliation to 10 trade and industry chambers | associations

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No. Name Reach
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Name	Reach
Alkali Manufacturers Association of India	National
Basic Chemicals, Cosmetics and Dyes Export Promotion Council of India	National
Bombay Chamber of Commerce and Industry	National
Federation of Indian Export Organisations	National
Fragrances and Flavours Association of India	National
Indian Chemical Council	National
Indian Resins Manufacturers Association	National
The Federation of Indian Chambers of Commerce and Industry	National
The Indian Pest Control Association	National
The Pesticides Manufacturers and Formulators Association of India	National

2. Corrective action taken or underway on any issue related to anti-competitive conduct, based on adverse orders from regulatory authorities

Not applicable

Leadership indicators

1. Advocacy of public policy positions

Not applicable.

94 Atul Ltd | Annual Report 2022-23

PRINCIPLE 8

Businesses will promote inclusive growth and equitable development.

Essential indicators

1. Social Impact Assessments (SIAs) of projects undertaken based on applicable laws

Not applicable

2. Projects for which ongoing rehabilitation and resettlement is being undertaken

Not applicable

3. Mechanisms to receive and redress grievances of the community

The Company has a process to receive and redress concerns received from the community. A site-level committee consisting of members from various departments is formed which receives the concerns and works towards its redressal.

4. Input material (inputs to total inputs by value) sourced from local or small scale suppliers

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Parameter 2022-23 2021-22
Directly sourced from micro, 993 cr 844 cr
small and medium enterprises | (23% of overall (21% of overall
small producers spend) spend)
1,268 cr 990 cr
Sourced directly from within
the district and neighbouring (30% of overall (24% of overall
districts spend) spend)
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Leadership indicators

1. Actions taken to mitigate any negative social impacts identified in the SIAs (Q 1. of essential indicators above)

• Not applicable

95

Corporate Statutory Financial Overview Reports Statements

2. CSR projects undertaken in designated aspirational districts as identified by government bodies

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Gujarat Aspirational district Amount spent ( ` )
Narmada ~ 50,000
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Internal guidelines for preferential Preferential procurement policy to give preference procurement from marginalised | vulnerable 3. to purchase from suppliers comprising vulnerable | groups are in place. The URL to the policy marginalised groups is: www.atul.co.in/economic-sustainability/ responsible-procurement

Vulnerable | marginalised groups from where the MSMEs and women-owned enterprises Company procures

Percentage of such procurement of the total (by value) 23% of overall spend

4. Benefits derived and shared from the intellectual properties owned or acquired based on traditional knowledge Not applicable

5. Corrective actions taken or underway based on any adverse order in intellectual property related disputes wherein usage of traditional knowledge is involved

• Not applicable

6. Beneficiaries of CSR projects

CSR project	No. of persons benefted from CSR projects	% of benefciaries from vulnerable and marginalised **groups **
Improvement of teaching methodology for primary school children – Atul Adhyapika	8,410 students	100%
Provision of education kits to children	4,323 students	100%
Enhancement of educationalpractices in Kalyani Shala	1,729 students	100%
Promotion of learningand life skills amongchildren	400 students	100%

96 Atul Ltd | Annual Report 2022-23

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No. of persons % of beneficiaries
from vulnerable
No. CSR project benefited from
and marginalised
CSR projects groups
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**No. **	CSR project	No. of persons benefted from CSR projects	% of benefciaries from vulnerable and marginalised **groups **
05.	Support to tribal children in Atul Vidyamandir	349 students	100%
06.	Development of a computer laboratoryin a school	300 students	100%
07.	Support to developa school in a tribal area	269 students	100%
08.	Provision of scholarships to needyand meritorious students	34 students	100%
09.	Support to developa library	30 students	100%
10.	Conservation of manuscripts	80,000 manuscripts	100%
11.	Contribution topublish books on Indian culture	ecology	philosophy
12.	Support to Industrial TrainingInstitute	8,116 students	100%
13.	Empowerment of women	youth through various vocational training courses	781 students
14.	Empowerment of women through self-help groups	723 women	100%
15.	Skill trainingtoyouth as apprentices	95 students	100%
16.	Development of micro-entrepreneurs toprovide sustainable livelihood	52 Students	100%
17.	Creation of livelihood opportunities for tribal families by providingcows	25 families	100%
18.	Settingupof health camps in remote villages	19,046patients	100%
19.	Establishment of Atul Medical Diagnostic Centre	4,616patients	100%
20.	Promotion of health and well-being of adolescents and women	3,755 adolescent girls and women	100%
21.	Provision of blood units to the needyand desertedpatients	84patents	100%
22.	Support to meet the treatment costs for needy patients	48patients	100%
23.	Promotion of Fit@50+ Women's Trans Himalayan Expedition	11 women	100%
24.	Support to food-affectedpeople in Valsad	10,364 individuals	100%
25.	Support to needy	special children	186 students
26.	Support to children with special needs	46 students	100%
27.	Construction of walkway and streetlights	Atul and nearby villages	100%
28.	Development of infrastructure in villages	Atul and nearby villages	100%
29.	Construction of toilet blocks in a school	687 students	100%
30	Renovation of toilets and boundarywall in a school	250 students	100%
31.	Establishment of solid waste management system in eight villages	23,704 individuals	100%
32.	Conservation of energythrough solar energy project	4,208 individuals	100%
33.	Development of nature-based wastewater recycling project	3,364 students	100%
34.	Conservation of energythrough biogasproject	200 families	100%
35.	Conservation of water through various interventions	38 farmers	100%
36.	Conservation of soil and water	1 village	100%
37.	Enhancement ofgreen cover - treeplantationproject	52,190 trees	100%
38.	Protection of animals	348 animals	100%

97

Corporate Statutory Financial Overview Reports Statements

PRINCIPLE 9

Businesses will engage with and provide value to their consumers in a responsible manner.

Essential indicators

1. Mechanisms to receive and respond to consumer complaints and feedback

Customer complaint portal is in place. All customer complaints are logged into 'customer complaint module'. Based on the nature of complaints, auto e-mails are triggered for action. The root cause and corrective and preventive actions are conveyed to customers. The complaint is closed after feedback (by phone | e-mail) from the customer.

Complaints are acknowledged within 48 hours and feedback is provided within seven working days.

2. Turnover of products | services as a percentage of turnover from all products | services that carry information

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Information related to As a percentage of total turnover
Environment and
100%
social parameters
Recycling and | or 100%
safe disposal
Safe and
100%
responsible usage
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3. Consumer complaints

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----- Start of picture text -----

2022-23 2021-22
Category
Received Pending resolution Received Pending resolution
- - - -
Advertising
- - - -
Cyber security
- - - -
Data privacy
Delivery of essential services 1 - 1 -
- - - -
Restrictive trade practices
- - - -
Unfair trade practices
Others 355 36 247 -
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98 Atul Ltd | Annual Report 2022-23

4. Product recalls on account of safety issues

	Number	Reason
Forced recalls	-	NA
Voluntaryrecalls	-	NA

5. Framework | policy on cyber security and risks related to data privacy

The Company has Information Security Policy in place to ensure that the data stored in the end user devices is protected.

6. Corrective action taken or underway on issues relating to advertising, and delivery of essential services; cyber security and data privacy of customers; re-occurrence of instances of product recalls; penalty | action taken by regulatory authorities on safety of products | services

There were no issues relating to advertising, delivery of essential services, cyber security and data privacy of customers. There was no re-occurrence of product recall. No penalty was levied or action was taken by any regulatory authority on account of any deficiency relating to safety of products | services in the financial year.

Leadership indicators

1. Channels, platforms and URL where information on products and services can be accessed

• www.atul.co.in

2. Steps taken to inform and educate consumers about safe and responsible use of products and (or) services

The Company shares material safety data sheets, technical data sheets and product labels on packaging in accordance with globally harmonised system regulations. For liquid chemicals, transport emergency cards are provided to transporters and training is imparted periodically to them and customers on safe handling. Interactions with farmers are arranged through Krishi Vigyan Kendras, farmer field days training sessions, etc.

3. Mechanisms to inform consumers of any risk of disruption | discontinuation of essential services

The customers are intimated regarding scheduled annual maintenance shutdown a few weeks in advance. For key customers, tentative schedules of annual maintenance shutdown are shared at least three months in advance. In case of any unforeseen disruptions in supply, information is conveyed through e-mail and telephone.

4. Display of product information and customer satisfaction survey

The Company provides information related to Chemical Abstracts Service number, European Community number, synonyms, hazard statement, precautionary statements, etc over and above what local law mandates.

The Company has a practice to carry out customer satisfaction surveys for major products at regular intervals.

5. Data breaches

• a. Number of instances of data breaches along with impact: nil

• b. Percentage of data breaches involving personally identifiable information of customers: not applicable

Note: Serial numbers are in accordance with Annexure-1 of notification of SEBI on Business Responsibility and Sustainability Report.

99