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ITC Limited Virginia House 37 J. L. Nehru Road Kolkata 700 071, India Tel. : 91 33 2288 9371 Fax : 91 33 2288 4016 / 1256 / 2259 / 2260

28[th] June, 2024

The Manager Listing Department National Stock Exchange of India Ltd. Exchange Plaza Plot No. C-1, G Block Bandra-Kurla Complex Bandra (East) Mumbai 400 051

The General Manager Dept. of Corporate Services BSE Ltd. P. J. Towers Dalal Street Mumbai 400 001

The Secretary The Calcutta Stock Exchange Ltd. 7, Lyons Range Kolkata 700 001

Dear Sirs,

Business Responsibility and Sustainability Report for the financial year ended 31[st] March, 2024

Disclosure Requirements) Regulations, 2015, the Business Responsibility and Sustainability Report of the Company for the financial year ended 31[st] March, 2024, which also forms part of the Report and Accounts of the Company for the financial year 2023-24.

Yours faithfully, ITC Limited

RAJENDR Digitally signed by RAJENDRA A KUMAR KUMAR SINGHI Date: 2024.06.28 SINGHI 11:07:52 +05'30' (R. K. Singhi) Executive Vice President & Company Secretary

Encl. as above.

FMCG ⚫ HOTELS ⚫ PAPERBOARDS & PACKAGING ⚫ AGRI-BUSINESS ⚫ INFORMATION TECHNOLOGY Visit us at www.itcportal.com ⚫ Corporate Identity Number : L16005WB1910PLC001985 ⚫ e-mail : [email protected]

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cc: Securities Exchange Commission Division of Corporate Finance Office of International Corporate Finance Mail Stop 3-9 450 Fifth Street Washington DC 20549 U.S.A. cc: Societe de la Bourse de Luxembourg 35A Boulevard Joseph II L-1840 Luxembourg

Business Responsibility and Sustainability Report

REPORT AND ACCOUNTS 2024

Business Responsibility and Sustainability Report 2024

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Glossary II
SECTION A GENERAL DISCLOSURES III
SECTION B MANAGEMENT AND PROCESS DISCLOSURES XIV
SECTION C PRINCIPLE WISE PERFORMANCE DISCLOSURE XVII
PRINCIPLE 1 Businesses should conduct and govern themselves with integrity, and in XVII
a manner that is ethical, transparent and accountable
PRINCIPLE 2 Businesses should provide goods and services in a manner that is XX
sustainable and safe
PRINCIPLE 3 Businesses should respect and promote the well-being of all XXIII
employees, including those in their value chains
PRINCIPLE 4 Businesses should respect the interests of and be responsive to all its XXIX
stakeholders
PRINCIPLE 5 Businesses should respect and promote human rights XXXIII
PRINCIPLE 6 Businesses should respect and make efforts to protect and restore the XXXVII
environment
PRINCIPLE 7 Businesses, when engaging in influencing public and regulatory policy, XLIV
should do so in a manner that is responsible and transparent
PRINCIPLE 8 Businesses should promote inclusive growth and equitable development XLVI
PRINCIPLE 9 Businesses should engage with and provide value to their consumers in L
a responsible manner
Independent Assurance Report LII
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Business Responsibility and Sustainability Report

REPORT AND ACCOUNTS 2024

Glossary

ITC Divisions/ Businesses

ABD: Agri Business Division ESPB: Education & Stationery Products Business FBD: Foods Business Division

HD: Hotels Division

ITD: India Tobacco Division

MAB: Safety Matches and Agarbattis PCPBD: Personal Care Products Business Division PPB: Packaging & Printing Business PSPD: Paperboards & Specialty Papers Division TM&D: Trade Marketing & Distribution

BIS: Bureau of Indian Standards CSR: Corporate Social Responsibility ECF: Elemental Chlorine Free EHS: Environment, Health and Safety ESG: Environment, Social and Governance FPO: Farmers’ Producer Organisation FPI: Foreign Portfolio Investment FII: Foreign Institutional Investor FSC®: Forest Stewardship Council® FSSAI: The Food Safety and Standards Authority of India

GAP: Good Agricultural Practices

ITC Specific Terms

CAPP: Core Area Perspective Plan CMC: Corporate Management Committee CSAT: Customer Satisfaction CIO: Chief Information Officer CISO: Chief Information Security Officer CSO: Chief Sustainability Officer FTC: Fixed Term Contract

FTR: Fixed Term Retainer

Sustainability 2.0 Targets: Refer ITC Sustainability Report 2024- Sustainability 2.0 Ambitions Section

ISC: Investor Service Centre

ITCMAARS: Meta Market for Advanced Agriculture and Rural Services

LSTC: Life Sciences & Technology Centre

MSK: Mission Sunehra Kal

SBU: Strategic Business Unit

SCRC: Sustainability Compliance and Review Committee

SIP: Social Investments Programme SPP: Service Provider Personnel

TPMs: Third-Party Manufacturers WOW: Well Being Out of Waste

General Terms

ATNI: Access to Nutrition Initiative ASCI: Advertising Standards Council of India AWS: Alliance for Water Stewardship B2B, B2C, D2C: Business-to-Business, Business-to-Consumer, Direct-to-Consumer

GP: Gram Panchayat

HACCP: Hazard Analysis and Critical Control Points

ISAE: International Standard on Assurance Engagements

LCA: Life-Cycle Assessment

LEED®: Leadership in Energy and Environmental Design

MCH: Mother and Child Health

MMU: Mobile Medical Unit MOU: Memorandum of Understanding

NA: Not Applicable

NGRBC: National Guidelines on Responsible Business Conduct

NOP: National Organic Programme

NPOP: National Programme for Organic Production

OHSAS: Occupational Health and Safety Assessment Series.

PAT: Perform, Achieve and Trade

PPP: Public-Private Partnership

RFA: Rainforest Alliance

SEBI: Securities and Exchange Board of India SEDEX: Supplier Ethical Data Exchange SC: Scheduled Caste ST: Scheduled Tribe SHG: Self Help Group SOP: Standard Operating Procedure STP: Sustainable Tobacco Programme UoM: Unit of Measurement

Business Responsibility and Sustainability Report

REPORT AND ACCOUNTS 2024

Section A: General Disclosures

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I. Details of the Listed Entity:
Corporate Identity Number L16005WB1910PLC001985
1.
(CIN) of the Company
2. Name of the Company ITC Limited
3. Year of Incorporation 1910
4. Registered office address
Virginia House, 37 Jawaharlal Nehru Road, Kolkata 700 071
5. Corporate office address
6. E-mail id [email protected]
7. Telephone +91 33 2288 9371
8. Website www.itcportal.com
Financial year for which 2023-24
9.
reporting is being done
Name of the Stock National Stock Exchange of India Limited (‘NSE’), BSE Limited (‘BSE’), and
10. Exchange(s) where shares The Calcutta Stock Exchange Limited (‘CSE’)
are listed
11. Paid-up capital ` 1248.47 Crores (As on 31.03.2024)
Name and contact details Ms. Madhulika Sharma
of the person who may be CSO
12.
contacted in case of any [email protected]
queries on the BRSR report +91 33 2288 9371
Reporting boundary The disclosures are on a standalone basis.
This report is prepared on a standalone basis. The reporting boundary for the current
13. year has been revised as compared to the previous year i.e. from consolidated basis
to standalone basis for the environmental indicators presented in Principle 6 of the
report. The change is not material.
Name of assurance Messrs. KPMG Assurance and Consulting Services LLP
14.
provider
15. Type of assurance obtained Reasonable Assurance for BRSR Core indicators
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II. Products/Services

16. Details of business activities: (accounting for 90% of the entity’s Turnover):

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S. Description of % of Turnover
Description of Business Activity
No. Main Activity of the Entity
1. FMCG Cigarettes etc. 44.06%
Others: Branded Packaged Foods Businesses (Staples & Meals;
Snacks; Dairy & Beverages; Biscuits & Cakes; Chocolates, Coffee & 30.13%
Confectionery); Personal Care Products; Education and Stationery
Products; Safety Matches and Agarbattis.
2. Hotels Hoteliering. 4.28%
3. Agri-Business Agri-commodities such as wheat, rice, spices, coffee, soya and 12.12%
leaf tobacco.
4. Paperboards, Paperboards, Paper including Specialty Paper & Packaging 9.41%
Paper & Packaging including flexibles.
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III

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17. Products/Services sold by the entity: (accounting for 90% of the entity’s Turnover):

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S. % of Total Turnover
No. Product/Service NIC Code Contributed
1 Cigarettes etc. 12003, 21002, 46307 44.06%
2 Others: Branded Packaged Foods 10202, 10304, 10308, 10501, 10504,
Businesses (Staples & Meals; Snacks; 10509, 10611, 10613, 10616, 10712,
Dairy & Beverages; Biscuits & Cakes; 10732, 10733, 10739, 10740, 10750,
Chocolates, Coffee & Confectionery); 10792, 10795, 10798, 20231, 20233, 30.13%
Education and Stationery Products; 20234, 20236, 20237, 20239, 46411,
Personal Care Products; 46491, 46496, 46497, 46909
Safety Matches and Agarbattis.
3 Hoteliering 55101, 56101, 56301, 74909, 47110,
47190, 68200, 77400, 79900, 96010, 4.28%
96020, 96905, 94990, 49223
4 Agri-commodities such as wheat, rice, 12001, 10209, 10302, 10304, 10406,
spices, coffee, soya and leaf tobacco. 10611, 10795, 46201, 46207, 46301, 12.12%
46305, 46306, 47300, 47737, 71200
5 Paperboards, Paper including Specialty 17015, 17016, 17093, 17022,
9.41%
Paper & Packaging including flexibles. 17029, 22203
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III. Operations

The Company’s Businesses and operations are spread across the country. Details of Plant Locations, including hotels owned / operated by the Company, are provided under the section ‘Shareholder Information’ in the Company’s Report and Accounts 2024.

18. Number of locations where plants and/or operations/offices of the entity are situated.

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Location Number of Plants Number of Offices Total
National 107 52 159
International 0 1 1
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19. Markets served by the entity

a. Number of Locations

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Location Number
National (No. of States) 28 States and 7 Union Territories
International (No. of Countries) 105 Countries
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b. What is the contribution of exports as a percentage of the total turnover of the entity?

FY 2023-24 9.11%

c. A Brief on Types of Customers

ITC is one of India’s foremost private sector companies and a diversified conglomerate with businesses spanning FMCG, Hotels, Paperboards, Paper & Packaging, Agri Businesses and Information Technology, and operates across all the three sectors of the economy – Agri, Manufacturing and Services, covering B2C, B2B and D2C segments. The Company’s vibrant portfolio of over 25 world-class Indian brands, largely built through an organic growth strategy in a relatively short period of time, represents an annual consumer spend of over ` 32,000 crores and reach over 250 million households in India.

Business Responsibility and Sustainability Report

REPORT AND ACCOUNTS 2024

IV. Employees

20. Details as at the end of Financial Year:

a. Employees and Workers (including Differently Abled):

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S. No. Particulars Total (A) Male Female
No. (B) % (B/A) No. (C) % (C/A)
EMPLOYEES
1 Permanent (D) 24,567 21,804 89% 2,763 11%
2 Other than Permanent (E) 30,679 25,729 84% 4,950 16%
3 Total employees (D + E) 55,246 47,533 86% 7,713 14%
WORKERS
4 Permanent (F) 12,745 11,966 94% 779 6%
5 Other than Permanent (G) 30,386 25,518 84% 4,868 16%
6 Total workers (F + G) 43,131 37,484 87% 5,647 13%
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Note: Definition of employee clustering is as under:

• Permanent employees include permanent workers, management and non-management staff. Workers is a subset of employees. • Other than Permanent Employees include Service Provider Personnel (SPP), Fixed Term Contract (FTC) and Fixed Term Retainer (FTR) (Management/Non-management and Workers) • Permanent Workers include only Workers who are on the rolls of the Company • Other than Permanent Workers include SPP and FTC (Worker) • Trainees and apprentices have not been included in the Workforce.

b. Differently abled Employees and workers:

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S. No. Particulars Total Male Female
(A)
No. (B) % (B/A) No. (C) % (C/A)
DIFFERENTLY ABLED EMPLOYEES
1 Permanent (D) 44 37 84% 7 16%
2 Other than Permanent (E) 458 360 79% 98 21%
3 Total differently abled employees (D + E) 502 397 79% 105 21%
DIFFERENTLY ABLED WORKERS
4 Permanent (F) 40 33 83% 7 18%
5 Other than Permanent (G) 308 263 85% 45 15%
6 Total differently abled workers (F + G) 348 296 85% 52 15%
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21. Participation/Inclusion/Representation of Women

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Total (A) No. and Percentage of Females
No. (B) % (B/A)
Board of Directors 16 3 18.75%
Key Managerial Personnel 5 0 0
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Comprising Chairman & Managing Director, Wholetime Directors and Company Secretary

22. Turnover rate for permanent employees and workers

In FY 2023-24, the overall attrition (voluntary separation, retirement, termination and abandonment of services) across employees was 9%. Gender-wise attrition stood at 9% for male employees and 15% for female employees.

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FY 2023-24 FY 2022-23 FY 2021-22
Male Female Total Male Female Total Male Female Total
Permanent Employees 9% 15% 9% 11% 18% 12% 9% 18% 10%
Permanent Workers 5% 15% 5% 7% 21% 7% 6% 25% 7%
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Business Responsibility and Sustainability Report

REPORT AND ACCOUNTS 2024

V. Holding, Subsidiary and Associate Companies (including joint ventures)

23. (a) Names of holding/subsidiary/associate companies/joint ventures (As on 31.03.2024)

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S. Name of the Holding/Subsidiary/ Indicate Whether % of Shares Does the Entity Indicated at
No. Associate Companies/ Holding/Subsidiary/ Held by Column A, Participate in the Business
Joint Ventures (A) Associate/ Listed Entity Responsibility Initiatives of the Listed
Joint Venture Entity? (Yes/No)
1 ITC Infotech India Limited Subsidiary 100.00 No
2 ITC Infotech Limited Subsidiary 100.00 No
3 ITC Infotech (USA), Inc. Subsidiary 100.00 No
4 Indivate Inc. Subsidiary 100.00 No
5 ITC Infotech Do Brasil LTDA. Subsidiary 100.00 No
6 ITC Infotech Malaysia SDN. BHD. Subsidiary 100.00 No
7 ITC Infotech France SAS Subsidiary 100.00 No
8 ITC Infotech GmbH Subsidiary 100.00 No
9 ITC Infotech de México, S.A. de C.V. Subsidiary 100.00 No
10 ITC Infotech Arabia Limited Subsidiary 100.00 No
11 Surya Nepal Private Limited Subsidiary 59.00 No
12 Surya Nepal Ventures Private Limited Subsidiary 59.00 No
13 Technico Agri Sciences Limited Subsidiary 100.00 No
14 Technico Pty Limited Subsidiary 100.00 No
15 Technico Technologies Inc. Subsidiary 100.00 No
16 Technico Asia Holdings Pty Limited Subsidiary 100.00 No
17 Technico Horticultural (Kunming) Co. Limited Subsidiary 100.00 No
18 Srinivasa Resorts Limited Subsidiary 68.00 No
19 Fortune Park Hotels Limited Subsidiary 100.00 No
20 Landbase India Limited Subsidiary 100.00 No
21 Bay Islands Hotels Limited Subsidiary 100.00 No
22 WelcomHotels Lanka (Private) Limited Subsidiary 100.00 No
23 Russell Credit Limited Subsidiary 100.00 No
24 Greenacre Holdings Limited Subsidiary 100.00 No
25 Wimco Limited Subsidiary 100.00 No
26 Gold Flake Corporation Limited Subsidiary 100.00 No
27 ITC Integrated Business Services Limited Subsidiary 100.00 No
28 MRR Trading & Investment Company Limited Subsidiary 100.00 No
29 North East Nutrients Private Limited Subsidiary 76.00 No
30 Prag Agro Farm Limited Subsidiary 100.00 No
31 Pavan Poplar Limited Subsidiary 100.00 No
32 ITC IndiVision Limited Subsidiary 100.00 No
33 ITC Fibre Innovations Limited Subsidiary 100.00 No
34 ITC Hotels Limited Subsidiary 100.00 No
35 Logix Developers Private Limited Joint Venture 27.90 No
36 ITC Filtrona Limited (formerly known as ITC Joint Venture 50.00 No
Essentra Limited)
37 Maharaja Heritage Resorts Limited Joint Venture 50.00 No
38 Gujarat Hotels Limited Associate 45.78 No
39 International Travel House Limited Associate 48.96 No
40 Russell Investments Limited Associate 25.43 No
41 Divya Management Limited Associate 33.33 No
42 Antrang Finance Limited Associate 33.33 No
43 ATC Limited Associate 47.50 No
44 Delectable Technologies Private Limited Associate 39.32 [#] No
45 Mother Sparsh Baby Care Private Limited Associate 26.50 [#] No
46 Sproutlife Foods Private Limited Associate 44.74 [#] No
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held directly or through subsidiary companies.

on a fully diluted basis.

Note: Refer Note 29(iii) of Consolidated Financial Statements forming part of Report and Accounts 2024, for further details on subsidiaries, associates and joint ventures.

Business Responsibility and Sustainability Report

REPORT AND ACCOUNTS 2024

VI. CSR Details

24. (i) Whether CSR is applicable as per section 135 of Companies Act, 2013: (Yes/No). Yes

(ii) Turnover of the Company for the year ended 31st March, 2024 - ` 69,446.20 crores

(iii) Net worth of the Company as at 31st March, 2024 - ` 69,035.30 crores (computed as per the Companies Act, 2013)

VII. Transparency and Disclosures Compliances

25. Complaints/grievances on any of the principles (Principles 1 to 9) under the National Guidelines on Responsible Business Conduct (NGRBC).

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Stakeholder Grievance FY 2023-24 FY 2022-23
group from Redressal
Number of Number of Remarks Number of Number of Remarks
whom Mechanism in
complaints complaints complaints complaints
complaint is Place (Yes/No)
filed during pending filed during pending
received (If Yes, then
the year resolution the year resolution
provide web-link
at close of at close of
for grievance
the year the year
redress policy)
Communities Yes 6 6 [#] - - - -
Investors and Yes 0 0 - 1 0 -
Shareholders
Employees Yes. It is available 18 1 - 144 8 -
and Workers through the ITC (resolved
Intranet after March
2024)
Customers Yes 21,995 2,011 - 18,846 1,648 -
Value Chain Yes - - - - - -
Partners
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*The details of grievance redressal mechanisms for each stakeholder group are provided in the table below.

The process is undertaken annually in February / March, and resolution initiated in April, and hence they are still open as on 31st March.

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Stakeholder Grievance Redressal Mechanism in Place
Group from whom
Complaint is Received
Communities ITC’s Social Investments Programme (SIP) team takes up Annual Community Engagement to
capture the views, issues, complaints and grievances of community members pertaining to
the projects implemented by SIP team, in addition to periodical need assessments and regular
interactions with all stakeholders. The major stakeholders of SIP being communities for whom
the programmes are implemented, this engagement focusses on primarily getting their feedback.
This annual engagement happens typically during February/March every year, and their resolution
tends to happen in the subsequent financial year.
During 2023-24, 42 such community engagements were held across major states where SIP
projects are implemented – Andhra Pradesh, Assam, Bihar, Himachal Pradesh, Karnataka,
Madhya Pradesh, Maharashtra, Punjab, Rajasthan, Tamil Nadu, Telangana, Uttar Pradesh,
Uttarakhand and West Bengal. These were conducted by ITC SIP team’s state level Managers.
Meetings were organised with community members in villages and urban catchments wherein the
programme implementing NGOs were also present. All meetings were planned and reviewed by
the SIP team at Head Office.
6 cases of grievances (mainly as requests for further interventions and scope of improvement)
were reported pertaining to the projects under SIP. The SIP state teams have taken cognisance
of the relevant requests and expectations and appropriate actions have been incorporated in the
plans for the upcoming year.
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VII

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Investors and Yes, https://www.itcportal.com/investor/index.aspx
Shareholders
The Company has an Investor Service Centre (‘ISC’) which is registered with the SEBI as
Category II Share Transfer Agent for providing in-house share registration and related services to
the shareholders and investors. ISC has effective systems and processes in place to ensure prompt
redressal of investor grievances, as follows:
(a) ISC has a ‘Complaint Identification Policy’ for identification of investor complaints. ISC attends
to shareholder / investor complaints within three working days, except where constrained by
disputes or legal impediments.
(b) The Head of ISC is responsible for redressal of investor grievances.
(c) The Company has a specific e-mail address earmarked for receiving investor complaints which
is [email protected].
(d) The ‘Investor Charter’ of the Company and the status of investor complaints received by the
Company are available on its website at https://www.itcportal.com/about-itc/shareholder-
value/investor-relations/investor-charter.aspx and https://www.itcportal.com/about-
itc/shareholder-value/pdf/investor-complaint.pdf, respectively.
(e) A Board Level Committee viz., the Securityholders Relationship Committee has been
mandated to oversee redressal of investor grievances, and review adherence to the service
standards adopted by the Company in respect of its in-house share registration activities.
(f) Details of investor complaints received by the Company are filed on a quarterly basis with the
Stock Exchanges where the Company’s shares are listed, and also with the SEBI on a
half-yearly basis.
Employees and The Company, through its Grievance Redressal Policy, seeks to address employee concerns and
Workers complaints pertaining to human rights and labour practices. A Grievance Redressal Procedure
with appropriate systems and mechanisms is available across ITC Units. It aims to facilitate open
and structured discussions on grievances raised on labour practices and human rights. The
implementation is ensured by Divisional/SBU Chief Executives, through members of the respective
Management Committees of the Businesses.
Customers Robust systems have been put in place across ITC Businesses to continuously engage with
consumers for gathering feedback and address their concerns, if any, in a timely manner. A
dedicated customer interactions team is in place to address any product related query/ complaint.
Several communication channels like email, telephone number and feedback forms are provided
to the consumers. In addition, the Company has an online reputation management team which
interacts with consumers via social media channels, and responds to their queries in real time.
A Customer Relationship Management (CRM) platform has been implemented for capturing
customer complaints, queries, feedback and suggestions received across channels. The CRM
platform also provides consumer insights for bringing about process related changes, and system
enhancements for improving the CSAT scores.
• Customer can reach out to ITC via following email in ITC Portal:
o [email protected]
o [email protected]
o [email protected]
• Customers can also raise their grievances via Brand-specific websites
Value Chain As per the Company’s Code of Conduct for Suppliers and Service Providers, they are expected to
Partners bring to the notice of the manager concerned at ITC, any actual or suspected breach of the Code.
Suppliers and Service Providers are encouraged to report any known or suspected improper
behaviour of ITC employees. Such reports are treated in a confidential manner.
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26. Overview of the entity’s material responsible business conduct issues

Please indicate material responsible business conduct and sustainability issues pertaining to environmental and social matters that present a risk or an opportunity to your business, rationale for identifying the same, approach to adapt or mitigate the risk along-with its financial implications

VIII

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S. Material Indicate Rationale for Iden- In case of Risk, Approach Financial Implications of
No. Issue whether tifying the Risk/ to Adapt or Mitigate the Risk or Opportunity
Identified Risk or Opportunity (Indicate Positive or
Opportunity Negative Implications)
(R/O)
1. Climate Risk Climate related Risk Mitigation Strategy Potential impact
Change physical and Physical Risk • As average temperatures
transition risks Management: rise, extreme weather
may impact events are expected to
• Usage of contemporary
business grow in terms of severity
climate risk modelling
operations, and frequency which could
tools for identifying
sourcing, supply high-risk/vulnerable have significant impact on
chain and increase sites and agri value the Company’s operations,
its physical assets and
compliance costs. chains, and undertaking
detailed assessments agri value chains. These
may lead to complete or
for developing locally
partial outage of operations.
contextual adaptation
Further, these events may
plans, risk mitigation
also adversely impact the
strategies and
availability and quality of
undertaking measures
agri raw materials and
for improving climate
consequently, the production
resilience;
and sales of the Company’s
• Promotion of climate
products;
smart agriculture, and
• Vagaries of weather caused
development of heat/
by climate change may
drought tolerant and
impact crop cycles, output
high yielding varieties to
and productivity resulting
improve productivity by
in disruption of operations/
adopting micro region-
specific agronomic supply chain;
practices: • Availability of water for
own operations as well
- Developing region-
specific package of as agri value chains may
be adversely impacted
practices and promoting
by erratic precipitation
climate smart farming
patterns;
techniques to mitigate
impact of weather; • Besides physical risks,
transition risks associated
- Enhancing climate
resilience of farmers with climate change, may
impact the Company’s
through capacity
operations:
building programmes by
leveraging ITCMAARS and - Additional levies may be
the Farmers’ Producer imposed by regulatory
Organisation (FPO) authorities for emission/
ecosystem, supported water intensive industries
by field demonstrations to address climate change,
under Choupal resulting in higher cost of
Pradarshan Khets; compliance, and potential
regulatory penalties and
- Comprehensive
reputational risk in case of
programmes on social
non-compliance.
forestry, soil and moisture
conservation and
biodiversity conservation;
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S. Material Indicate Rationale for Iden- In case of Risk, Approach Financial Implications of
No. Issue whether tifying the Risk/ to Adapt or Mitigate the Risk or Opportunity
Identified Risk or Opportunity (Indicate Positive or
Opportunity Negative Implications)
(R/O)
2. Product Risk Difficulty in Risk Mitigation Strategy Potential impact
and Plastic complying with • Going beyond compliance •Non-compliance with
Packaging current or future wherever possible:
plastic waste management
regulation on
- Ensuring plastic neutrality regulations could lead to
plastic packaging ahead of regulatory imposition of environmental
and/or failure to targets through
compensation, that may
meet commitments source segregation
negatively impact Company’s
programmes, creating
on packaging and
replicable, scalable and reputation. Additionally,
the environment.
sustainable models of stricter government laws
solid waste management, around usage of plastics
and developing viable including bans may give
recycling options for
rise to multiple challenges
Multi-Layered Plastic
such as redesign of product
(MLP) packaging.
packaging, shelf life- and
Additionally undertaking
third party assurance of product distribution related
underlying data related to issues;
plastic waste generation
•Disruptions in the supply
and collection;
chain for recycled plastic
- Ensuring a robust
or plastic packaging
compliance management
substitutes as required
system supported by
internal and external by law, could impact the
process review; Company’s ability to comply,
• Partnering with upstream produce and distribute
players and suppliers products;
for ensuring supply
•Inability to provide
of recycled plastic for
sustainable alternatives
meeting regulatory/
market demand for could have a negative impact
increasing recycled on consumer sentiment.
content in plastic
packaging;
• Harnessing the enterprise
strengths of ITC (Life
Sciences and Technology
Centre, Paperboards
& Specialty Paper
Division and Packaging
and Printing Division)
in driving cutting-edge
innovation to offer
sustainable alternatives
to single use plastics.
Pursue sustainable
packaging initiatives
like reduction in plastic
packaging intensity and
improving recyclability of
plastic packaging.
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S. Material Indicate Rationale for Iden- In case of Risk, Approach to Financial Implications of
No. Issue whether tifying the Risk/ Adapt or Mitigate the Risk or Opportunity
Identified Risk or Opportunity (Indicate Positive or
Opportunity Negative Implications)
(R/O)
3. Talent Man- Risk Difficulty in Risk Mitigation Strategy Potential impact
agement attracting and • Strengthening and • Lack of requisite quality of
retaining high communicating ITC’s talent management personnel
quality talent in a proposition about ‘Building could adversely affect
highly competitive Winning Businesses. business operations
market Building Business Leaders. and long-term growth
Creating Value for India’; prospects;
• Providing meaningful and • Talent attrition beyond
challenging roles which acceptable levels may
enrich individual capability impact ability to effectively
and act as a powerful fulfil Organisational goals
incentive to stay, learn and and Customer expectations.
grow;
• Building a robust
talent pipeline across
responsibility levels through
requisite quality in key
roles, depth of bench and
reliable succession plans;
• Investments in capability
building of managers
through access to the
best-in-class upskilling
programmes and
development interventions;
• Recognising and nurturing
specialism so that
employees who wish to
focus on niche, business
critical skills can continue
to grow in their area of
expertise;
• Benchmarking
compensation to the
relevant market periodically,
ensuring strong alignment
with short term and
long-term performance,
particularly at senior levels
and ring-fencing top talent;
• Ensuring the talent quotient
in the Company remains
healthy and vibrant through
annual segmentation
supported by differential
rewards and progression
opportunities for industry
leading talent;
• Energising and nurturing
pride in membership
through frequent leadership
outreach to managers;
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Section B: Management and Process Disclosures

The National Guidelines for Responsible Business Conduct (NGRBC) as brought out by the Ministry of Corporate Affairs advocates nine principles referred as P1-P9 as given below:

P1 Businesses should conduct and govern themselves with integrity, and in a manner that is ethical, transparent and accountable
P2 Businesses should provide goods and services in a manner that is sustainable and safe P3 Businesses should respect and promote the well-being of all employees, including those in their value chains
P4 Businesses should respect the interests of and be responsive to all its stakeholders
P5 Businesses should respect and promote human rights
P6 Businesses should respect and make efforts to protect and restore the environment
P7 Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent
P8 Businesses should promote inclusive growth and equitable development P9 Businesses should engage with and provide value to their consumers in a responsible manner

Disclosure Questions P1 P2 P3 P4 P5 P6 P7 P8 P9 Policy and Management Processes 1. a. Whether your entity’s Yes Yes Yes Yes Yes Yes Yes Yes Yes policy/policies cover each ITC has a comprehensive set of Board-approved Policies that cover NGRBC principles (P1 to P9) principle and its core and the underlying core elements. elements of the NGRBCs. To achieve its Sustainability 2.0 vision, the Company continues to strengthen its management (Yes/No) approach which is guided by a comprehensive set of Sustainability Policies that are being implemented across the organisation. The Company continues to strengthen the mechanisms of engagement with key stakeholders, identification of material sustainability issues and progressively monitoring and mitigating the impacts along the value chain of each Business. The Company will continue to update these systems and processes in line with the evolving disclosure standards and Environmental, Social and Governance (ESG) requirements. The overall responsibility for ensuring the implementation of Sustainability Policies resides with the Divisional / Strategic Business Unit (SBU) Chief Executives and the Heads of Corporate Functions who work with their respective management teams. Various committees designated with specific responsibilities have also been constituted for operationalising these Policies. The Sustainability Compliance Review Committee comprising senior members of management has the overall responsibility to monitor and evaluate compliance with these Policies. The responsibility for implementation of ITC’s CSR Policy rests with the Corporate Social Investments Programme (SIP) Team.

Disclosure Questions	P1	P2	P3	P4	P5	P6	P7	P8	P9
Policy and Management Processes
1. a. Whether your entity’s policy/policies cover each principle and its core elements of the NGRBCs. (Yes/No)	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes
	ITC has a comprehensive set of Board-approved Policies that cover NGRBC principles (P1 to P9) and the underlying core elements. To achieve its Sustainability 2.0 vision, the Company continues to strengthen its management approach which is guided by a comprehensive set of Sustainability Policies that are being implemented across the organisation. The Company continues to strengthen the mechanisms of engagement with key stakeholders, identifcation of material sustainability issues and progressively monitoring and mitigating the impacts along the value chain of each Business. The Company will continue to update these systems and processes in line with the evolving disclosure standards and Environmental, Social and Governance (ESG) requirements. The overall responsibility for ensuring the implementation of Sustainability Policies resides with the Divisional / Strategic Business Unit (SBU) Chief Executives and the Heads of Corporate Functions who work with their respective management teams. Various committees designated with specifc responsibilities have also been constituted for operationalising these Policies. The Sustainability Compliance Review Committee comprising senior members of management has the overall responsibility to monitor and evaluate compliance with these Policies. The responsibility for implementation of ITC’s CSR Policy rests with the Corporate Social Investments Programme (SIP) Team.
b. Has the policy been approved by the Board? (Yes/No)	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes
c. Web Link of the Policies, if available	https://www.itcportal.com/about-itc/policies/index.aspx
2. Whether the entity has translated the policy into procedures. (Yes / No)	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes
3. Do the enlisted policies extend to your value chain partners? (Yes/No)	Yes	Yes	Yes	Yes	Yes	Yes	Not Applicable	Yes	Yes
4. Name of the national and international codes/ certifcations/labels/ standards (e.g. Forest Stewardship Council, Fairtrade, Rainforest Alliance, Trustea) standards (e.g. SA 8000, OHSAS, ISO, BIS) adopted by your entity and mapped to each principle.	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes
	-	Food Safety Management System (FSSC 22000/ISO 22000/HACCP) Responsible Supply Chain Certifcations like Rainforest Alliance (RFA) and Forest Stewardship Council® (FSC®)	OHSAS 18001/ ISO 45001: Occupational Health and Safety Management Systems	ISAE 3000	SA 8000: Social Accountability, United Nations Guiding Principles on Business and Human Rights, Sustainable Tobacco Programme, RFA, FSC®	ISO 14001: Environment Management System, Alliance for Water Stewardship (AWS), LEED® Certifcation for Green Building, LEED® Zero Carbon, LEED® Zero Water	NGRBC	-	ATNI Framework, FSSAI, BRCGS and Packaging Materials Global Standard, HACCP, Sedex, NPOP, NOP, Halal and Kosher
	For more information on Environment, Social, Occupational Health and Safety, Food Safety Certifcations and Sustainable Farming Certifcations, refer to ‘Certifcations’ section of ITC Sustainability Report 2024.

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5. Specific commitments, goals and targets set by the entity with defined timelines, if any.

6. Performance of the entity against the specific commitments, goals and targets along with reasons in case the same are not met.

In line with its Sustainability 2.0 agenda, ITC has set short to medium targets for key priority areas like climate change, water stewardship, plastic waste and circular economy, sustainable agriculture, biodiversity conservation and sustainable livelihoods. In line with the above, ITC’s Businesses have targets for Key Performance Indicators (KPIs) like specific energy consumption, specific greenhouse gas emissions, specific water intake and specific waste generation. In order to achieve these targets, all ITC Units have established management systems which entail regular monitoring of environmental KPIs, development of an environmental management plan, and reviewing progress on a regular basis to ensure that Businesses are on track with respect to the agreed roadmap.

For more information on annual performance against the Sustainability 2.0 targets, refer to ‘Sustainability 2.0 Ambitions’ section of ITC Sustainability Report 2024.

Governance, Leadership and Oversight

7. Statement by director responsible for the business responsibility report, highlighting ESG related challenges, targets and achievements (listed entity has flexibility regarding the placement of this disclosure) Please refer to the ‘Chairman’s Message’ section in ITC Sustainability Report 2024.

8. Details of the highest authority responsible for implementation and oversight of the Business Responsibility policy (ies).

The CSR and Sustainability Committee of the Board, chaired by the Chairman & Managing Director, reviews and oversees implementation of the Sustainability Policies of the Company on an annual basis. In addition, the CSR and Sustainability Committee and the Board of Directors also review the progress of implementation of the Company’s CSR Programmes on a half-yearly basis. The composition of the CSR and Sustainability Committee as on 31st March, 2024 is given below:

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Sl. Name of the Designation/Nature DIN of the
No. Director of Directorship Director
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Sl. No.	Name of the Director	Designation/Nature of Directorship	DIN of the Director

1.	S. Puri (Chairman of the Committee)	Chairman & Managing Director	00280529
2.	M. Gupta	Non-Executive Director	06638754
3.	R. Jain	Non-Executive Director	07442202
4.	S. Panray	Non-Executive Director	09251023
5.	N. Rao	Independent Director	06954879
6.	A. K. Seth	Independent Director	08504093
7.	M. Shankar	Independent Director	06374957

At the highest level, the Board of Directors of the Company has the primary role of trusteeship to protect and enhance shareholder value through strategic supervision of ITC. As trustees, the Board ensures that the Company has clear goals aligned to shareholder value and its growth, and also in line with its Sustainability agenda.

The CMC of the Company is the management body responsible for compliance with the Sustainability Policies of the Company.

The CMC has constituted the SCRC which monitors and evaluates compliance with these Policies and places a quarterly report thereon for review by the CMC.

The Chief Executives of Divisions / SBUs, through members of the respective Management Committees, and Heads of Corporate Functions are responsible for ensuring implementation of the Sustainability Policies of the Company within their respective Division / SBU / Corporate Function, and communication of these Policies to the employees.

In addition, the CSO of the Company is, inter alia, responsible for periodic review of material issues, scanning the external environment for evolving sustainability trends and regulations, monitoring the progress on sustainability targets and facilitating the Businesses & Corporate Functions in implementing the sustainability initiatives. The CSO reports to the Group Head of Sustainability who is also a CMC Member and the Chairman of the SCRC. The CSO provides progress report-backs on the Company’s sustainability initiatives to the senior leadership of the Company.

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9. Does the entity have Yes, as stated under (8) above, the CSR and Sustainability Committee of the Board reviews,
a specified Committee monitors and provides strategic direction to the Company’s CSR and sustainability practices
of the Board/ Director towards fulfilling its Triple Bottom Line objectives. The Committee seeks to guide the Company in
responsible for decision
crafting unique models to support creation of sustainable livelihoods together with environmental
making on sustainability
related issues? (Yes re-generation.
/ No). If yes, provide
The CSR and Sustainability Committee of the Board also reviews the Business Responsibility and
details.
Sustainability Report of the Company and recommends the same to the Board for adoption, and
approves the Sustainability Report of the Company.
10. Details of Review of NGRBCs by the Company:
Subject for Review Indicate whether review was undertaken by Frequency (Annually/Half-yearly/
Director / Committee of the Board/ Any other Quarterly/Any other – please specify)
Committee
P1 P2 P3 P4 P5 P6 P7 P8 P9
Performance against Any other Any other Any other Any other Any other Any other Any other Any other Any other
above policies and follow Committee Committee Committee Committee Committee Committee Committee Committee Committee
up action
On a On a On a On a On a On a On a On a On a
quarterly quarterly quarterly quarterly quarterly quarterly quarterly quarterly quarterly
basis basis basis basis basis basis basis basis basis
Compliance with Any other Any other Any other Any other Any other Any other Any other Any other Any other
statutory requirements Committee Committee Committee Committee Committee Committee Committee Committee Committee
of relevance to the
principles, and, On a On a On a On a On a On a On a On a On a
rectification of any non- quarterly quarterly quarterly quarterly quarterly quarterly quarterly quarterly quarterly
compliances basis basis basis basis basis basis basis basis basis
The Company is in compliance with the applicable laws and regulations.
11. Has the entity • ITC has a robust review mechanism supported by both external and internal audits covering the
carried out independent implementation of key policies
assessment/ evaluation
of the working of its • ITC has been obtaining independent third-party assurance for its Sustainability Reports since
policies by an external 2004. In the reporting year, authenticity of the data and systems disclosed in the Sustainability
agency? (Yes/No). If yes, Report 2024 has been assured by an independent third-party assurance provider; the
provide name of the
assurance has been provided as per the International Standard for Assurance Engagements
agency.
(ISAE) 3000 at the ‘Reasonable Assurance’ level
• ITC has computed its Green House Gas (GHG) inventory, including GHG emissions, biogenic
emissions and GHG removals, in accordance with ISO 14064:2018; the GHG inventory of FY
2023-24 has been verified at the ‘Reasonable Assurance’ level by an independent third-party
assurance provider
• In addition to the above, relevant third-party assessments and certifications are conducted
across Business Units periodically
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Section C: Principle-wise Performance Disclosure

Principle 1

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

Essential Indicator

Percentage coverage by training and awareness programmes on any of the principles during the financial year

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Segment Total Number Topics/Principles covered under the %age of Persons in
of Training and Training and its Impact Respective Category
Awareness covered by the
Programmes Held Awareness Programmes
Board of 5 The Directors are briefed on the sustainability initiatives 100%
Directors of the Company from time to time. The Directors
are also updated on changes / developments in the
Key domestic / global corporate and industry scenario
Managerial including those pertaining to statutes / legislation &
Personnel economic environment and on matters affecting the
(other than Company, to enable them to take well informed and
Directors) timely decisions.
During the financial year 2023-24, the Directors and KMP
of the Company were briefed/updated on the following:
(a) Overview of the Company’s businesses and ITC’s
globally acknowledged sustainability initiatives
provided to newly appointed Directors.
(b) Review by the CSR and Sustainability Committee of
the implementation of the Sustainability Policies,
including framework and approach relating thereto.
(c) CSR initiatives including the Company’s CSR
Programmes and Sustainability 2.0 Vision & roadmap.
(d) Strategy of Corporate Communications covering
external stakeholders like media.
(e) Periodic review of the Company’s businesses.
Employees 11 Health and Safety, ITC Code of Conduct, Policy on 100%
other than Prevention of Sexual Harassment at the workplace,
BoD and and Wellness programmes
KMPs
Workers 11 Health and Safety, ITC Code of Conduct, Policy on 100%
Prevention of Sexual Harassment at the workplace,
and Wellness programmes
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11 Types of training programmes conducted, wherein all Employees/Workers were covered under at least one of the topics *Detailed training programmes on various health and safety sub-elements were also provided

2. Details of fines/penalties /punishment/award/compounding fees/settlement amount paid in proceedings (by the entity or by directors/KMPs) with regulators/law enforcement agencies/judicial institutions, in the financial year, in the following format (Note: the entity shall make disclosures on the basis of materiality as specified in Regulation 30 of SEBI (Listing Obligations and Disclosure Obligations) Regulations, 2015 and as disclosed on the entity’s website):

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Monetary
NGRBC Name of the Regulatory/ Amount Brief of the Has an Appeal been
Principle Enforcement Agencies/ (In INR) Case preferred?
Judicial Institutions (Yes/No)
Penalty/Fine
Settlement Nil
Compounding Fee
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Non-Monetary
NGRBC Name of the Regulatory/Enforcement Brief of the Has an Appeal
Principle Agencies/Judicial Institutions Case been preferred?
(Yes/No)
Imprisonment
Nil
Punishment
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The above disclosure has been made in accordance with the Company’s Policy for determination of materiality of events and information for disclosure to the Stock Exchanges.

3. Of the instances disclosed in Question 2 above, details of the Appeal/Revision preferred in cases where monetary or non-monetary action has been appealed.

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Case Details Name of the Regulatory/Enforcement Agencies/Judicial Institutions
Not applicable
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4. Does the entity have an anti-corruption or anti-bribery policy? If yes, provide details in brief and if available, provide a web-link to the policy.

The Company’s Code of Conduct covers aspects relating to anti-corruption and anti-bribery. In terms of the said Code, the Company believes in conducting its business in a transparent manner and does not indulge in bribery or corruption. The ITC Code of Conduct can be accessed on the Company’s corporate website at https://www.itcportal.com/about-itc/values/index.aspx#sectionb5

Further, in terms of the Company’s Code of Conduct for Suppliers and Service Providers:

(a) all Suppliers and Service Providers of the Company are required to avoid any actual or potential conflicts of interest in their business dealings with the Company that could create a perception of unfairness or lead to uncompetitive favours. If any such instance arises, the Suppliers and Service Providers are also required to disclose any such situation of conflict of interest, including involvement or interest of any employee of the Company or his / her immediate family members in their business.

(b) all Suppliers and Service Providers, in their dealings with the Company, are prohibited to indulge in any form of bribery or corruption that is intended to induce or reward improper conduct or influence any decision. The Company expects and seeks confirmation in its commercial and contractual terms that Suppliers and Service Providers have not offered or promised or provided any benefit, either in cash or in kind, to any employee or any relative / associate of any employee of the Company or of any of its associate companies, in order to facilitate their existing or future business with the Company.

The said Code of Conduct for Suppliers and Service Providers can be accessed on the Company’s corporate website at https://www.itcportal.com/about-itc/policies/sustainability-policy.aspx#coc-vendor

5. Number of Directors/KMPs/employees/workers against whom disciplinary action was taken by any law enforcement agency for the charges of bribery/corruption:

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FY 2023-24 FY 2022-23
Directors Nil Nil
KMPs Nil Nil
Employees Nil Nil
Workers Nil Nil
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6. Details of complaints with regard to conflict of interest:

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FY 2023-24 FY 2022-23
Number Remarks Number Remarks
Number of complaints received in Nil - Nil -
relation to issues of conflict of interest of
the Directors
Number of complaints received in Nil - Nil -
relation to issues of conflict of interest of
the KMPs
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7. Provide 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.

**8. Number of days of accounts payables ((Accounts payable *365)/Cost of goods/services procured) in the following format:**

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FY 2023-24 FY 2022-23
Number of days of accounts payables 43.50 40.60
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9. Open-ness of business

Provide details of concentration of purchases and sales with trading houses, dealers, and related parties alongwith loans and advances & investments, with related parties, in the following format

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Parameter Metrics FY 2023-24 FY 2022-23
Concentration of a. Purchases from trading houses as % of total purchases 0.29% 0.21%
Purchases
b. Number of trading houses where purchases are made from 57 56
c. Purchases from top 10 trading houses as % of total purchases from 82.94% 81.02%
trading houses
Concentration of a. Sales to dealers/distributors as % of total sales 80.40% 74.99%
Sales
b. Number of dealers/distributors to whom sales are made 6718 6198
c. Sales to top 10 dealers/distributors as % of total sales to dealers/ 7.41% 8.10%
distributors
Share of RPTs in a. Purchases (Purchases with related parties/Total Purchases) 3.17% 2.46%
b. Sales (Sales to related parties/Total Sales) 2.70% 3.31%
c. Loans & advances (Loans & advances given to related parties/Total 0.96% -
loans & advances)
d. Investments (Investments in related parties/Total Investments made) 18.08% 15.32%
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Leadership Indicators

1. Awareness programmes conducted for value chain partners on any of the Principles during the financial year:

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Total number Topics/principles covered under the training %age of value chain partners covered (by value
of awareness of business done with such partners) under the
programmes held awareness programmes
5 • Environment, Social, Governance (ESG) 100% identified Critical Tier-1 value chain partners
Landscape: Global & Indian including National
Guidelines on Responsible Business Conduct
(NGRBC) Principles and SEBI’s BRSR Core
Value Chain Reporting Requirements
• Environmental Compliance
• Fair Business Practices
• Corporate Governance and Ethics
• Occupational Health and Safety
• Fair Labour Practices and Human Rights
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2. Does the entity have processes in place to avoid/manage conflict of interests involving members of the Board? (Yes/No) If Yes, provide details of the same.

Yes, the ITC Code of Conduct requires the Directors, Senior Management and employees to avoid situations in which their personal interests could conflict with the interests of the Company. The Code, inter alia, clarifies that conflict of interest may arise when (a) an employee or a family member (family member includes spouse, children, siblings and parents) has a material interest in an entity that has a business relationship with the Company or is being evaluated

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for a commercial transaction, or (b) an employee is in a position to benefit someone with whom he/she has a close relationship, in relation to the Company’s business. However, this is an area in which it is impossible to provide comprehensive guidance, but the guiding principle is that conflict, if any, or any potential conflict must be disclosed to higher management for guidance and action as appropriate.

Further, the Directors of the Company are required to disclose to the Board whether they, directly or indirectly or on behalf of third parties, have material interest in any transaction or matter directly affecting the Company. In addition, an annual confirmation is sought from the Directors in this connection. For the financial year 2023-24, all Directors of the Company have confirmed that they did not, either directly or indirectly or on behalf of third parties, have material interest in any transaction or matter, directly affecting the Company.

Principle 2

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

Essential Indicators

1. Percentage of R&D and capital expenditure (capex) investments in specific technologies to improve the environmental and social impacts of product and processes to total R&D and capex investments made by the entity, respectively.

Details of investment in specific technologies to improve the environmental and social impacts of product and processes (“Specific R&D” and “Specific Capex”) are as follows:

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FY 2023-24 FY 2022-23
Specific R&D to total
13.3% 14.0%
R&D (Refer Note 1)
Specific Capex to total
30.0% 40.3%
Capex (Refer Note 2)
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Note 1: R&D

The Company’s state-of-the-art ITC Life Sciences and Technology Centre (LSTC) in Bengaluru is at the core of driving science-led product innovation to support and build ITC’s portfolio of world-class brands. ITC LSTC’s research and development initiatives are equipped with world-class scientific platforms and centres of excellence that not only help deliver superior differentiated value to consumers but also improvements in environmental and social impacts, some of which are summarised below -

Agroforestry and Crop Sciences: Agroforestry, one of LSTC’s key expertise, involves working on productivity improvement of trees by using contemporary research tools for Eucalyptus, Casuarina, Corymbia, and Subabul species. LSTC has released several new clones for all the four species, aimed at improving productivity and catering to the sourcing needs of ITC’s paper business. Last year, 12.8 million new clones with improved productivity were distributed to farmers. Crop sciences team is involved in development of crops such as Tobacco, Wheat and Potato that would help in meeting

targets of climate resilience and farmer profitability with enhanced yield and quality.

Sustainable Packaging & Material Sciences: This vertical works on reducing the impact of single-use plastics and plastic packaging by focusing on suitable alternatives, improving recyclability of multi-layered plastic packaging, and increasing the use of recycled content, thereby reducing the carbon footprint of packaging. LSTC is deeply engaged in developing innovative packaging solutions by improving functional barrier properties of paper, paper board and flexibles.

Health, Wellness and Nutrition: Wellness platform focuses on multiple aspects of human health stratified across age, gender, specific health concerns as well as uniqueness of the Indian consumer. LSTC, over the last decade, has been instrumental in creating scientifically validated solutions catering to areas such as diabetes, cardiovascular health, weight management, gut health, immunity, brain health, women’s health, kids’ health, targeted nutrition as well as various concerns associated with ageing. Solutions range from delivering benefits in various product formats including nutraceuticals. Scientific due diligence as well as clinical efficacy has helped in generating health claims and in providing nutrition, nourishment, health and wellness to the Indian consumer.

Apart from the above, various businesses of the Company also engage in focussed interventions in the areas of crop development, plastic substitution, sustainable packaging etc.

Note 2: Capex investments

Specific Capex include investments in the areas of renewable energy, green buildings, energy efficient equipment, pollution control equipment, water management and treatment system (including rain water harvesting) etc.

For more details, refer to ‘Report of the Board of Directors & Management Discussion and Analysis’ section forming part of ITC’s Report and Accounts 2024.

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2.a. Does the entity have procedures in place for sustainable sourcing?

Yes, there are procedures in place for sustainable sourcing. ITC has a Board approved Policy on ‘Sustainable Supply Chain and Responsible Sourcing’ and a ‘Code of Conduct for Suppliers and Service Providers’. The Code reflects ITC’s commitment to environmental conservation, business integrity and human rights across the supply chain. It upholds the spirit outlined in the International Labour Organisation Guidelines and United Nations Guiding Principles on Business and Human Rights. All suppliers are encouraged to fully comply with the Code. Additionally, ITC businesses, including Agri, FMCG and Paper Businesses, depend on farm and forestry-based supply chains for key raw materials. Accordingly, focus of ITC’s interventions in agri value chains has been largely around improving farmer livelihoods, increasing agricultural productivity, strengthening regional water security, and addressing the challenge of climate change and enhancing resilience. ITC’s key agri value chains are also certified as per global standards like Rainforest Alliance (RFA), Forest Stewardship Council®, Fairtrade, India Organic, USDA Organic and Bio-Suisse. These certifications specify environmental and social standards for agricultural practices, and help ensure sustainability, traceability and transparency across value chains.

Note: For more details on ITC’s sustainable sourcing practices pertaining to key agri value chains and key value chain partners like third-party manufacturers, refer to ‘Sustainable and Climate Resilient Agriculture’ and ‘Sustainable Supply Chain and Responsible Sourcing’ sections of ITC Sustainability Report 2024.

b. If yes, what percentage of inputs were sourced sustainably?

ITC businesses, including Agri, FMCG and Paper Businesses, depend on farm and forestry-based supply chains for key raw materials. Accordingly, farmers constitute a vital part of ITC’s supply chain, and the Company engages with farmers to ensure adoption of sustainable agriculture practices. ITC’s key agri value chains are also certified as per global standards like Rainforest Alliance (RFA), Forest Stewardship Council®, Fairtrade, India Organic, USDA Organic and Bio-Suisse.

3. Describe the processes in place to safely reclaim your products for reusing, recycling and disposing at the end of life, for (a) Plastics (including packaging) (b) E-waste (c) Hazardous waste and (d) other waste.

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Description of Processes
Plastics ITC first achieved Plastic Neutrality in FY 2021-22 by implementing an integrated solid waste management
(including programme that incorporates unique and multi-dimensional initiatives including the Company’s flagship
packaging) waste management initiative ‘ITC WOW – Well Being Out of Waste’. In FY 2023-24, the Company collected
and sustainably managed more than 70,000 tonnes of plastic waste across the Country. The amount of
plastic waste managed exceeded the amount of plastic packaging utilised by ITC during the year, enabling
the Company to maintain the milestone of Plastic Neutrality.
More than 99% of the solid waste generated in ITC’s operations including plastic waste is sent for recycling.
E-waste Not applicable
Hazardous Not applicable
waste
Other All ITC Units have established systems and procedures to ensure that waste is disposed through authorised
waste agencies in line with applicable regulations.
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Note: For further details, refer to the ‘Towards Circularity’ section of ITC Sustainability Report 2024.

4. Whether Extended Producer Responsibility (EPR) is applicable to the entity’s activities (Yes/No). If yes, whether the waste collection plan is in line with the Extended Producer Responsibility (EPR) plan submitted to Pollution Control Boards? If not, provide steps taken to address the same.

Yes, ITC is in compliance with the requirements of Extended Producer Responsibility (EPR) under the Plastic Waste Management Rules, 2016 (as amended).

Leadership Indicators

1. Has the entity conducted Life Cycle Perspective/Assessments (LCA) for any of its products (for manufacturing industry) or for its services (for service industry)?

In line with the overall strategy to embed principles of sustainability into the various stages of product or service life cycle, ITC initiated Life Cycle Assessments (LCA) of its products and services in 2010 with an objective to evaluate the impacts and identify areas for improvement in the value chain. LCA studies have been carried out for some of the

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Company’s key products from Paperboards and Specialty Papers Business, Personal Care Products Business, Branded Packaged Foods Business and Matches & Agarbattis Business for identifying additional opportunities to reduce environmental impact across the value chain. These assessments have enabled identification of concrete solutions towards more efficient packaging designs, and loading efficiencies in transportation. Studies conducted on the selected products also provided valuable insights which are duly considered for new product development and design.

Additionally, during the year, capacity building programmes were conducted for practitioners across ITC Businesses and LSTC in order to further strengthen the application of LCAs at product design stage itself including interventions related to using alternative raw materials/formulations, manufacturing processes, and packaging, and minimising use phase and end-of-life impacts.

Details of LCAs done in the last two years is given below:

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NIC code Name of Product/Service % of total Boundary Whether Results
turnover for which the conducted by Communicated
contributed Life Cycle Independent in Public Domain
Perspective/ External Agency (Yes/No) If yes,
Assessment was (Yes/No) Provide the
conducted web-link
46496 Classmate Notebook - Cradle-to-grave Yes No
20237 Savlon Powder Handwash - Cradle-to-grave Yes No
20237 Savlon Liquid Handwash - Cradle-to-grave Yes No
20239/46491 Nimyle Floor Cleaner - Cradle-to-gate Yes No
17016 CFKE Paperboard - Cradle-to-gate Yes No
17016 OmegaBev Vio Paperboard - Cradle-to-Gate Yes No
with end-of life
20238/46491 Mangaldeep Sandal - Cradle-to-Grave Yes No
Agarbatti
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2. If there are any significant social or environmental concerns and/or risks arising from production or disposal of your products/services, as identified in the Life Cycle Perspective/Assessments (LCA) or through any other means, briefly describe the same along-with action taken to mitigate the same.

No significant social or environmental risks were identified from the LCA studies carried out.

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

During FY 2023-24, the Kovai Unit of ITC’s Paperboards & Specialty Papers Business sourced nearly 89,000 tonnes of waste paper from external sources, which constituted over 71% of Unit’s total input materials. Additionally, ITC continues to integrate recycled plastic content in packaging across its leading brands.

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Indicate input Recycled or re-used input material to total material
material
FY 2023-24 FY 2022-23
Waste Paper Recycled Paper used: Recycled Paper used:
used in Kovai Mill ~ 89,000 tonnes ~ 84,000 tonnes
Use of Recycled Recycled plastic content Recycled Plastic content
Plastic Content used in packaging: ~ 170 tonnes used in packaging: ~98 tonnes
• Mangaldeep Zip Lock Packs with 20% PCR • Savlon Glycerine Soap Wrapper with 70% PCR
(Post-consumer Recycled Plastic) in PET layer.
• Savlon Wet wipes with 70% PCR in PET Layer • Fiama Handwash Portfolio with 50%
• Engage EPS portfolio with 50% PCR PCR PET Bottles.
PET Bottles
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4. Of the products and packaging reclaimed at end of life of products, amount (in metric tonnes) reused, recycled, and safely disposed.

During FY 2023-24, the Company collected and sustainably managed more than 70,000 tonnes of plastic waste across the Country. The amount of plastic waste managed exceeded the amount of plastic packaging utilised by ITC during the year, enabling the Company to sustain its plastic neutrality status for the third year in a row.

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FY 2023-24 FY 2022-23
Re-used Recycled Safely Disposed Re-used Recycled Safely Disposed
- -
Plastics (including ~ 31,000 ~39,000 ~ 27,500 ~ 32,500
packaging) tonnes tonnes tonnes tonnes
E-waste NA NA NA NA NA NA
Hazardous waste NA NA NA NA NA NA
Other waste NA NA NA NA NA NA
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NA: Not applicable

5. Reclaimed products and their packaging materials (as percentage of products sold) for each product category.

Please refer responses to Questions 3 and 4 above.

Principle 3

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

Essential Indicators

1. a. Details of Measures for the Well-being of Employees:

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% of Employees Covered by
Total Health Insurance Accident Maternity Paternity Day Care
(A) Insurance Benefits Benefits Facilities
Category
Number % (B/A) Number % (C/A) Number % Number % Number %
(B) (C) (D) (D/A) (E) (E/A) (F) (F/A)
Permanent Employees
Male 21,804 21,804 100% 21,804 100% NA NA 10,324 47% - -
Female 2,763 2,763 100% 2,763 100% 2,763 100% NA NA 2,763 100%
Total 24,567 24,567 100% 24,567 100% 2,763 100% 10,324 47% 2,763 100%
Other than Permanent Employees
Male 25,729 25,559 99% 25,560 99% NA NA NA NA - -
Female 4,950 4,876 99% 4,876 99% 4,950 100% NA NA 4,950 100%
Total 30,679 30,435 99% 30,436 99% 4,950 100% NA NA 4,950 100%
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*The Company offers paternity leave to all eligible male employees in managerial cadre

b. Details of Measures for the Well-being of Workers:

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% of Workers Covered by
Total Health Accident Maternity Paternity Day Care
Category (A) Insurance Insurance Benefits Benefits Facilities
Number % Number % Number % Number % Number %
(B) (B/A) (C) (C/A) (D) (D/A) (E) (E/A) (F) (F/A)
Permanent Workers
Male 11,966 11,966 100% 11,966 100% NA NA 486 4% - -
Female 779 779 100% 779 100% 779 100% NA NA 779 100%
Total 12,745 12,745 100% 12,745 100% 779 100% 486 4% 779 100%
Other than Permanent Workers
Male 25,518 25,496 99.9% 25,468 99.8% NA NA NA NA - -
Female 4,868 4,847 99.6% 4,847 99.6% 4,868 100% NA NA 4,868 100%
Total 30,386 30,343 99.9% 30,315 99.8% 4,868 100% NA NA 4,868 100%
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c. Spending on measures towards well-being of employees and workers (including permanent and other than permanent) in the following format-

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FY 23-24 FY 22-23
Cost incurred on well-being measures as a % of total revenue of 0.1% 0.1%
the company
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*Includes cost of accident insurance, health insurance, maternity leave benefit, paternity leave benefit, day-care facility cost. Note: Reporting for permanent employees including permanent workers, management and non-management staff of the Company. The other than permanent employees and workers include those deployed through Service Providers and their wages including well-being measures are provided by the service providers.

2. Details of Retirement Benefits, for Current FY and Previous Financial Year.

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FY 2023-24 FY 2022-23
No. of No. of Deducted and No. of No. of Deducted and
Benefits Employees Workers Deposited Employees Workers Deposited with the
Covered as Covered as with the Covered as Covered as Authority (Y/N/N.A.)
a % of Total a % of Total Authority a % of Total a % of Total
Employees Workers (Y/N/N.A.) Employees Workers
PF 100% 100% Y 100% 100% Y
Gratuity 100% 100% Y 100% 100% Y
ESI 10% 17% Y 12% 20% Y
Others, NA NA NA NA NA NA
please
specify
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*Covers all eligible employees

3. Accessibility of workplaces

Are the premises/offices of the entity accessible to differently-abled employees and workers, as per the requirements of the Rights of Persons with Disabilities Act, 2016? If not, whether any steps are being taken by the entity in this regard.

As part of its commitment to enhancing diversity, ITC places particular emphasis on representation and inclusion of differently-abled persons. Most of the divisional head-quarters have enabling infrastructure such as:

Elevators enabled with Braille signages for persons with visual difficulty
Ramps, tactile pavers and handrails to facilitate movement of persons with motor disability
Accessible parking places
Accessible washrooms

4. Does the entity have an equal opportunity policy as per the Rights of Persons with Disabilities Act, 2016? If so, provide a web-link to the policy.

Yes, the Company has a Policy on Diversity, Equity and Inclusion which clearly articulates its emphasis on Equal Opportunity. The said Policy clearly states ITC’s commitment towards providing equal opportunity. It also emphasizes the Company’s Zero Tolerance Policy on discrimination, inter alia, on the grounds of disability. The aforesaid Policy can be accessed at https://www.itcportal.com/about-itc/policies/sustainability-policy.aspx#EqualOpportunity

5. Return to work and Retention rates of permanent employees and workers that took parental leave.

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Permanent Employees Permanent Workers
Gender Return to Work Retention Rate Return to Work Retention Rate
Male 100% 87% NA NA
Female 100% 93% 100% 92%
Total 100% 88% 100% 92%
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6. Is there a mechanism available to receive and redress grievances for the following categories of employees and workers? If yes, give details of the mechanism in brief.

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Yes/No (If Yes, then give details of the mechanism in brief)
Permanent Yes, ITC’s Grievance Redressal Procedure is available to employees and workers. The objective of the policy
Workers is to facilitate open and structured discussion on employees’ work-related grievances with the intent of
ensuring that the grievance is dealt with in a fair and just manner whilst being in compliance with the
Company’s policies. ITC’s open-door practices encourage an amicable and fair resolution of grievances.
Employees are encouraged to first discuss the grievance with their immediate reporting authority, and
attempt to arrive at a resolution before invoking a formal grievance redressal mechanism. In Unionised
Units, grievances of workmen are also taken up for discussion by Union Office Bearers and resolved
through dialogue with human resources managers and other designated managers. Units also have
Committees with joint representation of workers and managers, which address grievances raised by one or
more workers. In addition, many Units have forums where workers interact with the unit leadership team in
small groups and share any suggestions or grievances they may have, for resolution.
The Company’s Whistleblower Policy is also available for the permanent employees.
Other than The Whistleblower Policy of the Company encourages all employees to bring to the Company’s attention,
Permanent instances of illegal or unethical conduct, actual or suspected incidents of fraud, actions that affect
Workers the financial integrity of the Company, or actual or suspected instances of leak of unpublished price
sensitive information that could adversely impact the Company’s operations, business performance and/
or reputation. In terms of the said Policy, the Company investigates such incidents, when reported, in an
impartial manner and takes appropriate action to ensure that the requisite standards of professional and
ethical conduct are always upheld. This Policy can be accessed on the Company’s corporate website at
https://www.itcportal.com/whistleblower-policy
Permanent Same as stated for Permanent Workers.
Employees
Other than Same as stated for Other than Permanent Workers.
Permanent
Employees
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7. Membership of employees and workers in association(s) or Unions recognised by the listed entity:

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FY 2023-24 FY 2022-23
Total No. of Employees/ % Total Employees/ No. of Employees/ %
Employees/ Workers in Respective (B/A) Workers in Respec- Workers in Respective (D/C)
Category
Workers in Category, who are part tive Category (C) Category, who are part
Respective of Association(s) or of Association(s) or
Category (A) Union (B) Union (D)
Total 24,567 10,372 42% 23,725 10,222 43%
Permanent
Employees
- Male 21,804 10,215 47% 21,337 10,113 47%
- Female 2,763 157 6% 2,388 109 5%
Total 12,745 10,372 81% 12,602 10,222 81%
Permanent
Workers
- Male 11,966 10,215 85% 11,948 10,113 85%
- Female 779 157 20% 654 109 17%
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*A vast majority of women workers are based in manufacturing units which currently do not have union representation These are units that were commissioned in the recent past. ITC believes that all employees are important stakeholders in the enterprise, and it is imperative to build a culture of mutual trust and respect, interdependence, and meaningful engagement. This approach helps in building, strengthening and sustaining harmonious employee relations across the organisation. It is ITC’s policy:

To respect the dignity of the individual and the freedom of employees to lawfully organise themselves into interest groups, independent of supervision by the management
To ensure that employees are not discriminated against for exercising this freedom in a lawful manner and consistent with ITC’s core values

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8. Details of training given to Employees and Workers:

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FY 2023-24 FY 2022-23
Total (A) On Health and On Skill Total (D) On Health and On Skill
Category Safety Measures Upgradation Safety Measures Upgradation
No. % No. % No. % No.(F) %
(B) (B/A) (C) (C/A) (E) (E/D) (F/D)
Employees
Male 21,804 12,174 56% 11,524 53% 21,337 9,914 46% 6,464 30%
Female 2,763 1,409 51% 1,673 61% 2,388 877 37% 832 35%
Total 24,567 13,583 55% 13,197 54% 23,725 10,791 45% 7,296 31%
Workers
Male 11,966 9,007 75% 6,591 55% 11,948 6,832 57% 4,052 34%
Female 779 685 88% 592 76% 654 524 80% 150 23%
Total 12,745 9,692 76% 7,183 56% 12,602 7,356 58% 4,202 33%
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Note: The above includes formal Induction training upon joining and refresher trainings (Once in 3 years). Other forms of EHS trainings on the job, like safety briefings, tool box talks, drills etc. which would have covered most of the employees and workers have not been included.

9. Details of Performance and Career Development Reviews of Employees and Workers.

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FY 2023-24 FY 2022-23
Category Current Financial Year Previous Financial Year
Total (A) No. (B) % (B/A) Total (C) No. (D) % (D/C)
Employees
Male 21,804 19,690 90% 21,337 17,560 82%
Female 2,763 2,712 98% 2,388 2,283 96%
Total 24,567 22,402 91% 23,725 19,843 84%
Workers
Male 11,966 9,852 82% 11,948 8,171 68%
Female 779 728 93% 654 549 84%
Total 12,745 10,580 83% 12,602 8,720 69%
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10. Health and Safety Management System:

a. Whether an Occupational Health and Safety Management System has been implemented by the Entity? (Yes/No). If yes, the coverage of such system?

Yes, ITC has implemented occupational health and safety management system in all its Factories, Hotels, Offices and Warehouses. ITC endeavours that Environment, Health & Safety (EHS) standards at all its units are ahead of applicable legislation and regulations, Standards and Codes, and are benchmarked against international best practices across sectors in which it operates. ITC’s approach to occupational health & safety standards is articulated in the Board approved Environment, Health and Safety Policy. It is based on an EHS management system that emphasises on enhancing EHS performance by setting objectives and targets and continually monitoring key performance indicators.

Further, the Company promotes a culture of safety through behaviour change programmes and by providing appropriate training to employees as well as service

providers’ employees, while continually investing in state-of-the-art technology and in developing human capital.

EHS requirements are integrated at the design stage for all new investments. Compliance with EHS standards during the construction phase as well as in operation phase of ITC units, Hotels, Warehouses and Offices is ensured by implementing project EHS management systems and through established EHS management systems with designated roles and responsibilities for competent resources, respectively.

b. What are the processes used to identify workrelated hazards and assess risks on a routine and nonroutine basis by the entity?

ITC has identified the EHS Risk Management framework as one of the integral steps towards building a robust safety management system in all its factories, hotels, offices and warehouses. This framework entails a set of processes for continual risk identification, assessment and mitigation, with active participation of the workforce in each of its

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facilities. Shop floor processes in this regard include hazard spotting tours, suggestion schemes, daily briefings and periodic EHS Committee meetings in which employees participate. In addition, all ITC Units undergo periodic Environment, Health & Safety audits at the Business as well as Corporate level which endeavours to identify additional latent risks besides verifying compliance with standards. Several national awards and certifications acknowledge ITC’s commitment and efforts towards providing a safe and healthy workplace to all.

c. Whether you have processes for workers to report the work-related hazards and to remove themselves from such risks. (Y/N)

Yes. A system is in place across ITC factories, hotels and offices for workers to spot and report work-related hazards, and offer suggestions for improvements.

Necessary training is given to all employees in recognising hazards and issues. Joint inspections by

management representatives and employees on the shop floor are also carried out at regular intervals, and respective corrective and preventive measures are undertaken to mitigate the identified risks. In order to create an open and transparent safety culture across ITC Units, employees are encouraged to participate and discuss safety related issues in forums like periodic EHS Committee meetings and Departmental Open Forums.

d. Do the employees/worker of the entity have access to non-occupational medical and healthcare services? (Yes/No)

Yes, permanent employees and their family members have access to the Company provided or Company supported medical benefits. Workers have access to medical benefits through Company provided group insurance policies, Company funded medical support and where applicable, statutory benefits under the Employees’ State Insurance Act.

11. Details of safety related incidents.

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Safety Incident/Number Category* FY 2023-24 FY 2022-23
Lost Time Injury Frequency Rate (LTIFR) (per one million-person Employees 0.05 0.07
hours worked)
Workers 0.09 0.12
Total recordable work-related injuries Employees 3 4
Workers 7 8
No. of fatalities Employees 0 0
Workers 0 1
High consequence work-related injury or ill-health (excluding Employees 0 0
fatalities)
Workers 0 1
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*Including the contract workforce

**Onsite accidents

Note: For Question 11, Employees include only permanent employees, permanent workers and other than permanent employees whereas workers include only SPPs (Service Providers Personnel. Trainees/Apprentices not included.

12. Describe the measures taken by the entity to ensure a safe and healthy work place.

In line with the Company’s Environment, Health and Safety Policy, safety as a value-led concept has been institutionalised by inculcating a sense of ownership at all levels and driving behavioural change, leading to the creation of a cohesive safety culture. ITC has put in place comprehensive health and safety protocols for the safety and well-being of its stakeholders. ITC endeavours that EHS standards at all its units are ahead of applicable legislations, regulations, and Standards and Codes, and are benchmarked against international best practices across the diverse sectors in which it operates.

ITC continues to strengthen its safety processes, adopting globally recognised best practices, and ensuring that facilities are designed, constructed, operated and maintained in an inherently safe manner. ITC will continue to undertake efforts for creating a safe working environment and a strong safety culture by:

• Integrating safety at the design stage itself and ensuring it through design reviews, stage inspections and precommissioning audits, thereby strengthening the engineering control measures through ‘design for safety’ principles.

• Conducting pre-commissioning and periodic operational audits during construction and operational stages respectively.

• Implementing behaviour-based safety initiatives to facilitate engagement for collaborative work on improving safety performances.

• Adoption of keystone behaviours by individual units to demonstrate collective commitment and create a shared vision of safety and discipline.

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Embracing and leveraging the digital landscape for safety management system.
Identifying solutions for strengthening the safety culture aligned with the goal of ‘Zero Accidents’.

13. Number of Complaints on the following made by employees and workers.

Employees are encouraged to report work area related safety issues through various programmes like hazard identification processes, suggestion schemes and EHS Committees.

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FY 2023-24 FY 2022-23
Filed during Pending Remarks Filed during Pending Remarks
the Year Resolution the Year Resolution
at the end of at the end of
Year Year
Working 12 1 134 8
Conditions (resolved after (resolved after
March 2024) March 2023)
Health & 0 0 7 0
Safety
14. Assessments for the year:
% of your plants and offices that were assessed (by
entity or statutory authorities or third parties)
Health and safety practices 100%
Working Conditions 100%
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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 & safety practices and working conditions.

Internal audits of ITC units at Divisional as well as Corporate level are being conducted on a periodic basis. Corrective and preventive measures are taken based on the findings. Detailed investigations are carried out for all accidents to identify the root causes and to understand the measures required to prevent recurrence. Accident investigation findings with corrective and preventive measures form part of the report presented to the Corporate Management Committee (monthly) and the Board of Directors (quarterly). The learnings from all accidents are disseminated across the organisation at periodic intervals and a formal compliance obtained.

Leadership Indicators

1. Does the entity extend any life insurance or any compensatory package in the event of death of (A) Employees (Y/N) (B) Workers (Y/N).

Yes. In the unfortunate event of the death of an employee including workers, the Company extends financial support to family members of the employee.

2. Provide the measures undertaken by the entity to ensure that statutory dues have been deducted and deposited by the value chain partners.

The Company ensures that statutory dues as payable by service providers for their employees are deposited on time and in full through periodic audits and controls.

3. Provide the number of employees/workers having suffered high consequence work-related injury/ill-health/ fatalities (as reported in Q11 of Essential Indicators above), who have been are rehabilitated and placed in suitable employment or whose family members have been placed in suitable employment.

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Total no. of affected No. of Employees/Workers that are
Employees/Workers rehabilitated and placed in suitable
employment or whose family members have
been placed in suitable employment
FY 2023-24 FY 2022-23 FY 2023-24 FY 2022-23
Employees 0 0 0 0
Workers 0 2 0 1
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*Onsite Accidents

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4. Does the entity provide transition assistance programmes to facilitate continued employability and the management of career endings resulting from retirement or termination of employment? (Yes/No)

ITC continually invests in human capital development which includes building skills and capabilities that are contemporary while providing employees with a diversity of experiences. These enhance the employability of the workforce and enable a smooth transition to alternate opportunities where sought. The Company has in place a programme called ‘Making New Choices’ for retiring staff. In addition, the Company provides pension benefits and post-retiral medical benefits for those members of staff who qualify. Workers are provided with pension benefits, as per requirements of the relevant statute.

5. Details on assessment of value chain partners:

ITC’s Policy on Sustainable Supply Chain and Responsible Sourcing ensures integration of sustainability in its supply chains. ITC’s suppliers /value-chain partners are expected to adopt the principles enumerated in ITC’s Code of Conduct for Suppliers and Service Providers. ITC reserves the right to verify compliance with the Code of Conduct for Suppliers and Service Providers at any time through appropriate audit and assessment mechanisms, including selfcertification.

Health and safety audits conducted at ITC’s own manufacturing sites cover all contract workers within ITC’s operational premises. Additionally, ITC conducts third-party desktop assessment of its Critical Tier - 1* suppliers which includes key aspects on Occupational Health and Safety, amongst other assessment criteria.

*All ITC Businesses have identified Critical Tier-1 suppliers based on aspects like buy value, ESG risk exposure, importance to business continuity, among others. ITC’s Sustainable Supply Chain Programme is focussed on working closely with the set of identified critical suppliers.

% of value chain partners (by value of business done with such partners) that were assessed Critical Tier-1 Suppliers Health and safety practices 40% Working Conditions

6. Provide details of any 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.

ITC’s Sectoral EHS Guidelines are shared by Businesses with their value chain partners, and periodic training is given to their concerned personnel.

Periodic audits by ITC are conducted for some of its key value chain partners against the Sectoral EHS guidelines. Corrective and preventive measures are recommended based on the audit findings.

Principle 4

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

Essential Indicators

1. Describe the processes for identifying key stakeholder groups of the entity.

In line with the Board approved Policy on Stakeholder Engagement, ITC has evolved a structured framework for identifying and engaging with its key stakeholders across the value chain. ITC’s engagement approach is anchored on the principles of materiality, completeness and responsiveness.

The engagement approach takes into cognisance the fact that each stakeholder group is unique and has a distinctive set of priorities. Insights gathered from stakeholder engagements, help validate the Company’s performance and shape new perspectives.

Note: For details on ITC’s Process of Stakeholder Engagement, refer to ‘Stakeholder Engagement’ section of ITC Sustainability Report 2024.

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2. List stakeholder groups identified as key for your entity and the frequency of engagement with each stakeholder group.

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Stakeholder Group Whether Channels of Frequency of Purpose and scope
identified as communication (Email, engagement of engagement
Vulnerable & SMS, Newspaper, (Annually/Half including key topics
Marginalized Pamphlets, Advertisement, yearly/Quarterly/ and concerns
Group (Yes/No) Community Meetings, others – please raised during such
Notice Board, Website), specify) engagement
Other
Providers of financial No For more details on consultation mechanisms and key issues discussed
capital with the stakeholder groups, refer to ‘Strengthening Relationships with
All Stakeholders’ section of ITC Sustainability Report 2024
Government and No
regulatory authorities
Customers No
Employees No
Farmers Yes
Value chain partners No
Media No
Civil Society No
Local communities Yes
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Leadership Indicators

1. Provide the processes for consultation between stakeholders and the Board on economic, environmental, and social topics or if consultation is delegated, how is feedback from such consultations provided to the Board.

ITC believes that an effective stakeholder engagement process is necessary for achieving its sustainability goal of inclusive growth. In this context, the Company has laid down a four layered mechanism to deal with the aspect of stakeholder engagement.

The Board, through the CSR and Sustainability Committee, inter alia, reviews, monitors and provides strategic direction to the Company’s CSR and sustainability practices towards fulfilling its Triple Bottom Line objectives. Half-yearly reports on the progress made by the Company in this regard are placed by the CMC before the CSR and Sustainability Committee. The CMC in turn has constituted the Sustainability Compliance Review Committee (SCRC), comprising senior members of management, which evaluates and monitors compliance with the Policy formulated in this connection. The SCRC places a quarterly report on the subject before the CMC.

The Company has a practice of periodically assessing employee engagement through a Company-wide survey. Since 2016, the Company has made a concerted effort to assess and improve engagement. The impact is visible in the consistent improvement of engagement over the years.

2. Whether stakeholder consultation is used to support the identification and management of environmental, and social topics (Yes/No). If so, provide details of instances as to how the inputs received from stakeholders on these topics were incorporated into policies and activities of the entity.

Yes, the Company believes that an effective stakeholder engagement process is necessary for achieving its sustainability goal of inclusive growth. Accordingly, the Company anchors stakeholder engagement on the following principles:

a) Materiality – Prioritised consideration of the economic, environmental and social impacts identified to be important to the stakeholders as well as the organisation.

b) Completeness – Understanding key concerns of stakeholders and their expectations.

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c) Responsiveness – Responding coherently and transparently to such issues and concerns. The Company has put in place systems and procedures to identify, prioritise and address the needs and concerns of its stakeholders across Businesses and Units in a continuous, consistent and systematic manner. It has implemented mechanisms to facilitate effective dialogues with all stakeholders across Businesses, identify material concerns and their resolution in an equitable and transparent manner. These measures have helped the Company develop strong relationships, which have stood the test of time. Select examples of how stakeholder inputs have been incorporated into ITC’s policies and activities are presented below:

1. Investors: The Company engages extensively with the investor ecosystem i.e., analysts representing institutional equity investors, fund/portfolio managers in top FIIs, Domestic Mutual Funds, FPIs, Private Insurance Companies etc. The Company hosted its second ‘Investor Day’ event for the investor community to provide deeper insights into ITC’s Corporate Strategy and operating segments including inter alia, the ‘ITC Next Strategy’ which incorporates Sustainability 2.0 as a significant strategic pillar of the organisation. The event was hosted in hybrid mode with over 100 physical attendees and 400+ overall attendees. The Company continues to communicate quarterly performance takeaways through press releases and detailed Investor presentations along with post-result calls with analysts. Key highlights of the performance are also being shared with the shareholders by e-mail. The Investors section of the Company’s website is also being updated on an ongoing basis. The Company is well-recognised for its ESG credentials, and is acknowledged as one of the pioneers of adopting the Triple Bottom Line philosophy in India.

2. Customers & Value Chain Partners: Customers, Consumers and Value Chain Partners are some of ITC’s core stakeholders. Various tech-enabled avenues have been deployed to constantly receive feedback and ideas from these stakeholders.

A specialised team, ‘Team Synthesis’, has progressively evolved from being a ‘Customer Interactions’ team to a ‘Customer Experience’ team to ‘Stakeholder Experience Team’, and now into a ‘Stakeholder Experience Management Team’. In its current avatar, in addition to keeping customer centricity as the base, SOPs and policies are designed and implemented in such a manner that the experience of all stakeholders is taken into equitable consideration. This has not just helped in achieving better experience for customers as well as the employees, but has also made every stakeholder accountable for the team’s and the organisation’s

growth. Rapidly evolving consumer needs are constantly being monitored through social listening, in-depth immersions and are being carefully synthesised to transform into relevant solutions. A few key initiatives that demonstrate the above are:

• The entire customer experience process has been incentivised for the associates, team leaders as well as for the Quality Analysts (QAs) in such a manner that each month they accumulate certain points for their monthly performance based on objective and quantitative parameters. This has given the primary stakeholders (the associates) an opportunity to perform better. The parameters include factors like ideation (KAIZEN) and initiatives taken beyond tasks to improve the process continuously.

• The scenarios related to matters like environment, product, packaging, ergonomics, quality engineering, etc. highlighted by the customers are answered as per the respective brand teams, and any new or unique scenario highlighted by the customers is shared with the respective stakeholders as a VOC (Voice of Customer).

3. Community: Presented ahead are some of the instances where inputs received from stakeholders were incorporated into interventions.

Core Area Perspective Plan (CAPP) is done in ITC’s catchments to understand the need of the communities and design the interventions basis that. A comprehensive community needs assessment was earlier undertaken in 2015-16 in ITC’s core areas, that is, factory and agri-catchments. Basis this the CAPP 1.0 was developed. Whilst we keep revisiting the needs, basis regular stakeholder engagements, CAPP 2.0 was taken up in FY 2021-22 which also focussed on ITC’s core catchments across 21 factories and 7 agri locations. The objectives of CAPP 2.0 were to:

• Revisit coverage and community needs in the changed external context;

• Assess reasons for not achieving the earlier planned outcomes (if any); and

• Re-strategise MSK themes and approach based on the findings

As a follow up to the second CAPP 2.0 done in FY 202122, household surveys are conducted every year on a lower sample to re-assess and reaffirm the continued relevance of the needs identified and accordingly cognise for the same in the future plans. In FY 2023-24, over 6,000 households across 4 states were covered.

Forming large-scale long-term partnerships with Government to amplify reach & scale is one of the core tenets of SIP’s implementation approach. In this case, stakeholder feedback was received

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through consultations and interactions and they were duly incorporated during renewal/extension of the partnership. During the year, some PPPs with government ended and discussions were initiated on what changes and additions need to be considered in the next phase of partnership. Two such examples are shared below:

• In Madhya Pradesh, Climate Smart Village (CSV) programme is being implemented in 1,500 villages by ITC directly. Considering the need for replicating CSVs across the state, ITC organised field visits for the State Agricultural Department. Post visits, discussions were taken up on how can CSV model be replicated by the Government. ITC presented its CSV approach to Department’s state and district level officials. Post the meetings, an MoU was signed to replicate ITC’s CSV model in the entire state starting with six districts in Phase-1. The CSV approach will be replicated by the Government staff with ITC’s support for capability building. On-ground delivery of the programme has since been initiated.

• In Andhra Pradesh, ITC was working with Women Development and Child Welfare in the area of Early Childhood Education and Care (ECCE) in 13 districts. ITC trained Integrated Child Development Services (ICDS) Supervisors who in turn cascaded the training to Anganwadi Sevikas. After successfully implementing the programme in 13 districts, it was decided that there is a need to replicate the approach to entire state. Accordingly, a MoU was signed with the Department during FY 2023-24 to expand the partnership to the entire state.

3. Provide details of instances of engagement with, and actions taken to, address the concerns of vulnerable/marginalized stakeholder groups.

ITC’s SIP adopts a bottoms-up approach to identify and address the emerging needs of the community. Presented hereunder are a few instances wherein changing community needs were addressed either through modifications in ongoing programme components or by introducing entirely new interventions.

• ITC through the skill training centres provides vocational training to unemployed youth from marginalised sections to help them get livelihood opportunities. In Pune, unemployed women from two villages were not able to travel to the skill centre as traveling cost was high, which they were not able to bear. During mobilisation meetings, the community requested if training can be provided in a nearby place. To overcome the challenge, ITC started a temporary community level vocational skilling centre in their villages itself. 27 youth from these villages including 20

women were trained in electrical trade with all required equipment and standards.

• In ITC catchments, toilets have been constructed and catchments were declared Open Defecation Free (ODF) by the Government, but many of the earlier constructed toilets are single pit. During meetings, the community expressed requirement of double pit toilets as their single pit toilet may get filled up in the coming year and thus toilet will become non-usable. In a twin pit toilet, once one pit is filled up, second pit is used and desludging is done for faecal sludge management in first pit. To address this, ITC worked with the local Swachh Bharat Mission team and helped needy households to retrofit another pit to their existing toilet. This intervention would thus help in sustaining the ODF status of the area.

• ITC has been working with Watershed Development Department of Karnataka as part of its partnership for drought proofing programme for last three years. In the current year, there was severe drought in North Karnataka districts which required additional support. ITC immediately geared up to respond to the issue by designing and implementing drought support interventions in three North Karnataka districts – Balagavi, Kalaburagi and Yadgir. ITC provided critical irrigation support using rain guns, liquid fertiliser application through drones, renovation of open wells and water bodies, and fodder support to feed the animals. Approximately 2,200 poor households were benefited covering 3,000 acres, who could save their rabi crop, ensure survival of their animals and also had income generation opportunities in the village itself.

• In Kapurthala district of Punjab, ITC has been implementing Crop Residue Management programme since 2018, to help farmers not to burn paddy crop residue and to incorporate stubble into soil in order to improve soil health. However, over a period of time, farmers realised that in addition to adding stubble into soil, there is also a need for options to sell stubble (ex-situ solutions) and generate income. Considering this need, a small pilot was taken up in 2022-23 with 10 rural entrepreneurs which was extended to 73 entrepreneurs in 2023-24. These entrepreneurs handled 1,900 tons of residue which was sold for fodder and ethanol purposes. A workshop was also organised in December 2023, to make the farmers aware of various ex-situ marketing solutions available. Solutions discussed included Biofuel, Bio-ethanol, Building material, Biogass, Biochar, Pellets, Kitchen and tableware. The solutions which were of interest to farmers were listed out and are being pursued in the field by connecting farmers and rural entrepreneurs with the specific buyers/end-users.

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Principle 5

Businesses should respect and promote human rights

Essential Indicators

1. Employees and workers who have been provided training on human rights issues and policy(ies) of the entity, in the following format:

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Category 2023-24 2022-23
Total (A) No. of % (B/A) Total (C) No. of % (D/C)
Employees/ Employees/
Workers Workers
Covered (B) Covered (D)
Employees
Permanent 24,567 24,567 100% 23,725 23,725 100%
Other than Permanent 30,679 30,679 100% 26,099 26,099 100%
Total Employees 55,246 55,246 100% 49,824 49,824 100%
Workers
Permanent 12,745 12,745 100% 12,602 12,602 100%
Other than Permanent 30,386 30,386 100% 25,987 25,987 100%
Total Workers 43,131 43,131 100% 38,589 38,589 100%
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2. Details of minimum wages paid to employees and workers, in the following format:

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Category 2023-24 2022-23
Total Equal to % More % Total Equal to % More %
(A) Minimum (B/A) than (C/A) (D) Minimum (E/D) than (F/D)
Wage (B) Minimum Wage (E) Minimum
Wage (C) Wage (F)
Employees
Permanent 24,567 310 1% 24,257 99% 23,725 41 0.2% 23,684 99.83%
Male 21,804 278 1% 21,526 99% 21,337 40 0.2% 21,297 99.8%
Female 2,763 32 1% 2,731 99% 2,388 1 0% 2,387 100%
Other than 30,679 10,963 36% 19,716 64% 26,099 8,819 34% 17,280 66%
Permanent
Male 25,729 8,274 32% 17,455 68% 22,157 6,571 30% 15,586 70%
Female 4,950 2,689 54% 2,261 46% 3,942 2,248 57% 1,694 43%
Workers
Permanent 12,745 310 2% 12,435 98% 12,602 41 0.3% 12,561 99.7%
Male 11,966 278 2% 11,688 98% 11,948 40 0.3% 11,908 99.7%
Female 779 32 4% 747 96% 654 1 0.2% 653 99.8%
Other than 30,386 10,870 36% 19,516 64% 25,987 8,819 34% 17,168 66%
Permanent
Male 25,518 8,217 32% 17,301 68% 22,061 6,571 30% 15,490 70%
Female 4,868 2,653 54% 2,215 46% 3,926 2,248 57% 1,678 43%
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3. a. Details of remuneration/salary/wages Median remuneration / wages:

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Male Female
Number Median Number Median
Remuneration/ Remuneration/
Salary/Wages of Salary/Wages of
Respective Category Respective Category
(in INR) (in INR)
Board of Directors (BoD) 13 1,11,00,000 3 1,07,50,000
Key Managerial Personnel 5 8,25,79,405 - -
Employees other than BoD 21,799 7,14,281 2,763 7,03,725
and KMP
Workers 11,966 5,08,615 779 2,10,163 [#]
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Comprising Chairman & Managing Director, Wholetime Directors and Company Secretary

The majority of female workers are employed in new manufacturing units. Since a significant majority of these recruits are new entrants, the median remuneration appears lower.

b. Gross wages paid to females as % of total wages paid by the entity, in the following format:

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FY 2023-24 FY 2022-23
Gross wages paid to females as % of 10% 10%
total wages paid
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Note: Pertains to permanent employees that include permanent workers, management and non-management staff.

4. Do you have a focal point (Individual/Committee) responsible for addressing human rights impacts or issues caused or contributed to by the business? (Yes/No).

Yes. ITC has a long-standing commitment to human rights and it is reflected in its Code of Conduct. The Company has policies on human rights which are applicable to its employees, suppliers and service providers. The said Policies and their implementation are directed towards adherence to applicable laws and upholding the spirit of human rights, as enshrined in existing international standards such as the Universal Declaration and the Fundamental Human Rights Conventions of the International Labour Organisation (ILO). The Company continues to work towards strengthening and introducing systems to ensure sound implementation of ITC’s policies on human rights and decent workplace. All ITC contracts for the construction of hotels, factories and property upgrades incorporate the environment, health, safety and human rights clauses, including workplace environment and compliance of labour practices and are supervised by ITC managers for adherence.

Human Rights related policies of the Company are available on the ITC Portal. These include ITC Code of Conduct, Policy on Freedom of Association, Policy on Prohibition of Child Labour and Prevention of Forced Labour at the Workplace, and Policy on Diversity, Equity & Inclusion. The implementation of these Policies is ensured by Divisional/SBU Chief Executives, through

members of the respective Management Committees of the respective Businesses.

5. Describe the internal mechanisms in place to redress grievances related to human rights issues.

ITC’s open-door practices encourage amicable resolution of grievances. Employees are encouraged to first discuss the grievance with their immediate reporting authority and attempt to arrive at a resolution. If grievances persist, employees can fill up the Grievance Redressal Form and submit to the concerned HR Manager. The process of registering a grievance is by filling up a grievance form and submitting it to the concerned HR Manager which is then evaluated and analysed and a resolution is arrived and communicated to the employee. The grievance redressal guidelines and necessary forms are available on the Company intranet where employees can access the same directly. The ITC Whistleblower Policy (the Policy) encourages Directors and employees of the Company to promptly bring to the Company’s attention, instances of illegal or unethical conduct, actual or suspected incidents of fraud, actions that affect the financial integrity of the Company, or actual or suspected instances of leak of unpublished price sensitive information, that could adversely impact the Company’s operations, business performance and/or reputation. The Company investigates such reported incidents in an impartial manner and takes appropriate action to ensure that the requisite standards of professional and ethical conduct are always upheld. The Policy is available at https://www.itcportal.com/aboutitc/values/index.aspx#sectionb5

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6. Number of Complaints on the following made by employees and workers:

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FY 2023-24 FY 2022-23
Filed Pending Remarks Filed Pending Remarks
during Resolution at during Resolution at
the Year the end of Year the Year the end of Year
Sexual Harassment 5 0 1 0
Discrimination at 0 0 0 0
workplace
Child Labour 0 0 0 0
Forced Labour/ 0 0 0 0
Involuntary Labour
Wages 0 0 2 0
Other Human 0 0 0 0
Rights Related Issues
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Note: ITC has a zero-tolerance approach to any behaviour that constitutes sexual harassment. There are Internal Complaints Committees to examine and investigate any complaints. In the past, where investigations have indicated any violations, appropriate disciplinary actions have been taken, reinforcing the Company’s stated position and helping create an environment free of any harassment.

7. Complaints filed under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, in the following format:

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FY 2023-24 FY 2022-23
Total Complaints reported under Sexual Harassment on of Women at 5 1
Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH)
Complaints on POSH as a % of female employees/workers 0.18% 0.04%
Complaints on POSH upheld 5 1
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Note: Pertains to permanent employees which includes permanent workers, management and non-management staff

8. Mechanisms to prevent adverse consequences to the complainant in discrimination and harassment cases.

ITC is committed to a workplace free from harassment, including sexual harassment at the workplace, and has zero tolerance for such unacceptable conduct. ITC encourages reporting of any harassment concerns and is responsive to complaints about harassment or other unwelcome or offensive conduct. As part of the Policy, the complainant will not suffer any harassment, retaliation or adverse employment condition upon this reporting. All employees are made aware of this Policy through regular training and awareness on the subject and confidentiality clauses are clearly stated. Committees have been constituted across locations to enquire into complaints of sexual harassment and to recommend appropriate action, wherever required.

9. Do human rights requirements form part of your business agreements and contracts? (Yes/No)

Yes, contract manufacturing agreements provide for compliance with accepted standards on issues related to EHS, human rights and labour practices. Additionally, ITC has a ‘Code of Conduct for Suppliers and Service Providers’. This requires suppliers to comply with applicable laws, labour standards, environmental regulations, and uphold human rights and principles of ethics and integrity in their operations. All Suppliers are expected to meet the requirements of this Code. ITC also expects its Suppliers to hold their business associates to the same standards as enshrined in this Code.

10. Assessments for the year:

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% of your plants and offices that were assessed (by entity or statutory
authorities or third parties)
Child labour 100%
Forced/involuntary labour 100%
Sexual Harassment 100%
Discrimination at workplace 100%
Wages 100%
Others-please specify -
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Note: The Company has Policies on Human Rights which are applicable to all its employees and value chain partners. The said Policies and their implementation are directed towards adherence to applicable laws and upholding the spirit of human rights, as enshrined in existing international standards such as the Universal Declaration and the Fundamental Human Rights Conventions of the International Labour Organisation (ILO).

11. Provide details of any corrective actions taken or underway to address significant risks/concerns arising from the assessments at Question 10 above.

Please refer to response to Question 10 of Principle 5 under essential indicators.

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Leadership Indicators

1. Details of a business process being modified/ introduced as a result of addressing human rights grievances/complaints.

ITC’s Code of Conduct for its employees as well as Suppliers and Service Providers, is adopted by the Board. The Code covers ITC’s commitment to human rights aspects like self-respect and human dignity, child labour, gender friendly workplace, relationships with suppliers and customers, health & safety, environment, transparency, anti-bribery and corruption, and exemplary personal conduct. ITC constantly engages with the rightsholders and stakeholders across the supply chain for devising programmes that support Human Rights and Social Development in an integrated manner.

An illustrative example for ITC’s leaf tobacco value chain is presented below. ITC coordinates Human Rights impact assessment with an independent party for its farm value chains. Sustainable Tobacco Programme 2.0 is an industry initiative to enhance agricultural supply chain due diligence and accelerate positive impacts on environmental, social and governance elements. The programme focuses on 8 themes demanding leaf suppliers’ commitment on – Water, Human Rights, Crop, Soil, Climate Change, Natural Habitats, Livelihoods and Governance. The Human Rights Due Diligence focusses on identifying human rights risks and impacts covering farmers and communities. Some of the actions undertaken as an outcome of the assessment are:

Training and Awareness on Human Rights: Training and Awareness on Human Rights organised in 361 villages covering subjects such as Farm Safety, Child Labour, Wages, Fair Treatment, Freedom of Association, WASH, No Discrimination and other areas pertaining to Human Rights.

Farm Safety: ITC undertakes a holistic approach that address the farm safety challenges in farming. 5,000 farmers have been provided with Personal Protective Equipment (PPE) kits for safe spraying of chemicals and Secured Storage Box for safe storage of chemicals was provided for 3,600 farmers. Technology like Drones were scaled up covering 11,560 acres minimising human interference while chemical spraying, besides increasing the efficacy of operation and water saving.

For enabling easy access to drinking water, ITC established community level water plants which are operated on a self-sustaining model. 9 new Reverse Osmosis plants were established in FY 2023-24 taking the total current operational plants to 169 units, which provide safe drinking water to over 2.2 lakh rural people.

2. Details of the scope and coverage of any Human rights due-diligence conducted.

The scope and coverage of Human Rights Due Diligence

extends to own operations including manufacturing locations, Hotels, offices and value chain partners.

3. Is the premise/office of the entity accessible to differently abled visitors, as per the requirements of the Rights of Persons with Disabilities Act, 2016?

Most of our establishments are accessible to the differently abled persons (including visitors), with facilities like Persons with Disabilities (PWD) friendly entrance, wheelchair, braille systems, and tactile pavers etc. Accessible washroom is available for the visitors.

4. Details on assessment of value chain partners:

ITC’s Policy on Sustainable Supply Chain and Responsible Sourcing ensures integration of sustainability in its supply chains. ITC’s suppliers / value-chain partners are expected to adopt the principles enumerated in ITC’s Code of Conduct for Suppliers and Service Providers. ITC reserves the right to verify compliance with the Code of Conduct for Suppliers and Service Providers at any time through appropriate audit and assessment mechanisms, including self-certification.

ITC periodically coordinates third party Human Rights impact assessment for the tobacco farm supply chain. Additionally, ITC conducts third-party desktop assessment of its Critical Tier - 1* suppliers which includes key aspects on Human Rights, Labour Rights and Occupational Health and Safety, amongst other assessment criteria.

For more details, refer to response to Question 1 (Principle 5) under leadership indicators.

% of value chain partners (by value of business done with such partners) that were assessed Critical Tier-1 Suppliers* Sexual Harassment Discrimination at workplace Child Labour 40% Forced Labour/Involuntary Labour Wages Others – please specify

5. Provide details of any corrective actions taken or underway to address significant risks/concerns arising from the assessments at Question 4 above.

Please refer to responses to Questions 1 and 4 of Principle 5 under Leadership Indicators.

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Principle 6

Businesses should respect and make efforts to protect and restore the environment

Essential Indicators

1. Details of total energy consumption (in Joules or multiples) and energy intensity, in the following format:

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Parameter FY 2023-24 FY 2022-23
(All quantities in TJ except where specified)
From renewable sources
Total electricity consumption (A) 1,083 968
Total fuel consumption (B) 11,910 10,337
Energy consumption through other sources (C) 175 189
Total energy consumed from renewable sources (A+B+C) 13,168 11,494
From non-renewable sources
Total electricity consumption (D) 1,011 1,023
Total fuel consumption (E) 12,058 14,234
Energy consumption through other sources (F) 0 0
Total energy consumed from non-renewable sources (D+E+F) 13,069 15,257
Total energy consumed (A+B+C+D+E+F) 26,237 26,751
Energy intensity per rupee of turnover
(Total energy consumed/Revenue from operations) 374 381
(in Giga Joules/Crore INR)
Energy intensity per rupee of turnover adjusted for Purchasing Power Parity (PPP)
(Total energy consumed/Revenue from operations adjusted for PPP) 856 862
(in GJ/Million USD)
Energy intensity in terms of physical output
23.01 23.59
(in GJ/tonne of production)
Energy intensity (optional) – the relevant metric may be selected by the entity
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*Since ITC is a conglomerate with multiple businesses wherein physical output is reported in different units of measurement, hence the data for energy intensity in terms of physical output (tonnes of production) is reported only for PSPD which accounts for more than 80% of ITC’s total energy consumption. For data of other Divisions, refer to ‘Climate Change’ section of ITC’s Sustainability Report 2024.

ITC’s energy consumption data has been assured at the ‘Reasonable Level’ by an independent third-party assurance provider.

2. Does the entity have any sites/facilities identified as designated consumers (DCs) under the Performance, Achieve and Trade (PAT) Scheme of the Government of India? (Y/N) If yes, disclose whether targets set under the PAT scheme have been achieved. In case targets have not been achieved, provide the remedial action taken, if any.

Three Units of ITC’s Paperboards and Speciality Papers Business and twelve Hotels of Hotels Business are covered under the PAT scheme. The details of Units under PAT scheme is available at https://beeindia.gov.in/en/programmesperform-achievetrade/pat-notifcations

ITC has made significant investments in reducing energy consumption and, accordingly, the performance of the Company’s Units covered far exceeds the energy efficiency targets fixed under the PAT scheme. The Bhadrachalam Unit is the first pulp and paper mill and the second unit in the country overall, to be rated GreenCo Platinum+ by CII, as part of Green Company rating system.

Note: Details of the energy efficiency initiatives measures implemented during the year are included in ‘Disclosure on Conservation of Energy and Technology Absorption’ section of the Report of the Board of Directors & Management Discussion and Analysis in ITC Report and Accounts 2024.

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3. Provide details of the following disclosures related to water, in the following format:

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Parameter FY 2023-24 FY 2022-23
Water withdrawal by source (in million kilolitres)
(i) Surface water 28.2 27.2
(ii) Groundwater 5.2 4.8
(iii) Third party water 1.7 1.8
(iv) Seawater/desalinated water 0 0
(v) Others 0 0
Total volume of water withdrawal (in million kilolitres) (i + ii + iii + iv + v) 35.1 33.8
Total volume of water consumption 13.3 13.8
(in million kilolitres) (Total water withdrawal – total water discharged)
Water intensity per rupee of turnover 189 197
(Total water consumption/Revenue from operations)
(in kilolitres/Crore INR)
Water intensity per rupee of turnover adjusted for Purchasing Power Parity (PPP) 433 446
(Total water consumption/Revenue from operations adjusted for PPP)
(in kilolitres/Million USD)
Water intensity in terms of physical output 8.33 8.87
(in kilolitres/tonne of production)
Water intensity (optional) – the relevant metric may be selected by the entity
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*Since ITC is a conglomerate with multiple businesses wherein physical output is reported in different units of measurement, hence the data for water intensity in terms of physical output (tonnes of production) is reported only for PSPD which accounts for ~70% of ITC’s total water consumption. For data of other Divisions, refer to ‘Water Security’ section of ITC’s Sustainability Report 2024.

There is a reclassification of ‘Rainwater’ under ‘surface water’ and ‘externally supplied waste water’ under ’third party’ for FY 2023 data, without any change in total water withdrawal.

ITC’s water withdrawal and consumption data has been assured at the ‘Reasonable Level’ by an independent third-party assurance provider.

Over the years, ITC has created rainwater harvesting potential through extensive investments in its Integrated Watershed Development Projects. The programme promotes the development and management of local water resources in waterstressed areas by facilitating community participation in planning and implementing such measures, whilst building, reviving and maintaining water-harvesting structures. As on 31st March 2024, ITC’s watershed development projects covering over 1.6 million acres of land created a total rainwater harvesting potential (RWH) of nearly 55 million kl (cumulative), which is over four times the net water consumed by ITC’s operations.

4. Provide the following details related to water discharged:

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Parameter FY 2023-24 FY 2022-23
Water discharge by destination and level of treatment (in million kilolitres)
(i) To Surface water 11.5 11.7
No treatment 0 0
With treatment – please specify level of treatment Secondary Secondary
(ii) To Groundwater 0 0
No treatment NA NA
With treatment – please specify level of treatment NA NA
(iii) To Seawater 0 0
No treatment NA NA
With treatment – please specify level of treatment NA NA
(iv) Sent to third-parties 10.4 8.3
No treatment 0 0
With treatment – please specify level of treatment Tertiary Tertiary
Total water discharged (in million kilolitres) 21.9 20.0
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ITC’s water discharge data has been assured at the ‘Reasonable Level’ by an independent third-party assurance provider.

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5. Has the entity implemented a mechanism for Zero Liquid Discharge? If yes, provide details of its coverage and implementation.

ITC’s approach to water stewardship focuses on reducing water intake by utilising treated wastewater within the process, thereby reducing demand for fresh water. ITC Units have put in place necessary systems to comply with the Consent to Operate (CTO) conditions including Zero Liquid Discharge, where applicable. 35 Units of ITC including 13 hotels have achieved zero effluent discharge.

6. Please provide details of air emissions (other than GHG emissions) by the entity, in the following format:

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Parameter Please specify unit FY 2023-24 FY 2022-23
NOx Tonnes 2,345 2,380
SOx Tonnes 2,390 3,600
Particulate matter (PM) Tonnes 562 705
Persistent organic pollutants (POP) NA NA NA
Volatile Organic Compounds (VOC) NA NA NA
Hazardous Air Pollutants (HAP) Tonnes 8.4 8
The data is for PSPD Bhadrachalam Unit’s Hydrogen Sulphide emissions (H2S)
7. Provide details of greenhouse gas emissions (Scope 1 and Scope 2 emissions) & its intensity.
Parameter Please specify unit FY 2023-24 FY 2022-23
Total Scope 1 emissions (Break-up of the GHG into CO2, CH4, N2O, HFCs, kilo tonnes of CO2 1,141 1,350
PFCs, SF6, NF3, if available) equivalent
Total Scope 2 emissions (Break-up of the GHG into CO2, CH4, N2O, HFCs, kilo tonnes of CO2 231 231
PFCs, SF6, NF3, if available) equivalent
Total Scope 1 and Scope 2 emissions per rupee of turnover (Total Scope 1 tonnes of CO2 equivalent/ 20 22
and Scope 2 GHG emissions/Revenue from operations) Crore INR
Total Scope 1 and Scope 2 emission intensity per rupee of turnover ad- tonnes of CO2 equivalent/ 45 51
justed for Purchasing Power Parity (PPP) (Total Scope 1 and Scope 2 GHG Million USD
emissions/Revenue from operations adjusted for PPP)
Total Scope 1 and Scope 2 emission intensity in terms of physical output tonnes of CO2 equivalent/ 1.10 1.29
tonne of production
Total Scope 1 and Scope 2 emission intensity (optional) – the relevant
metric may be selected by the entity
----- End of picture text -----*

*Since ITC is a conglomerate with multiple businesses wherein physical output is reported in different units of measurement, hence the data for Scope 1 and Scope 2 emission intensity in terms of physical output (tonnes of production) is reported only for PSPD which accounts for more than 75% of ITC’s total Scope 1 and Scope 2 emissions. For data of other Divisions, refer to ‘Climate Change’ section of ITC’s Sustainability Report 2024.

ITC’s GHG emissions (Scope 1 and Scope 2) data has been assured at the ‘Reasonable Level’ by an independent third-party assurance provider.

ITC’s PSPD has large-scale Farm Forestry programmes promoting sustainable forest management with primary aim of securing pulpwood requirement for Business continuity. ITC also has a large-scale Social Forestry programme, which, in addition to sequestering carbon, also benefits the stakeholders by improving productivity of wasteland, and de-risking poor rural households by diversifying farm portfolios through promotion of tree-based farming. During FY 2023-24, the Farm and Social Forestry programmes have together sequestered over 5.5 million tonnes of CO2.

8. Does the entity have any project related to reducing Green House Gas emission? If Yes, then provide details.

ITC has undertaken a target of 50% reduction in Specific GHG Emissions (% Reduction in Scope 1 & 2 emission per Unit of Production) by 2030 as part of its Sustainability 2.0 ambitions. Accordingly, actions are being undertaken to reduce greenhouse gas emissions by investing in energy efficiency and increasing share of renewable energy.

Energy efficiency:

All ITC Units focus on energy efficiency through process improvements and investment in new technologies. Over the years, ITC has implemented measures like installation of Vapour Absorption Machines (VAM), Automation in tube cleaning system of Heating, Ventilation and Air Conditioning (HVAC), and installation of energy efficient equipment such as chillers, AHUs, motors, fans, pumps, and agitators. In FY 2023-24, the investments in energy conservation equipment have resulted in energy savings of about 500 TJ, which is equivalent to over 50,000 tonnes of GHG emissions.

In line with ITC’s focus on accelerating digitalisation across Businesses, ITC’s PSPD is implementing several transformative projects leveraging Industry 4.0 technologies across key business areas, to enhance productivity, reduce carbon footprint, achieve strategic cost efficiencies and superior product performance.

Some of the major projects undertaken by ITC’s PSPD as part of its Digital Transformation Programme include process

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debottlenecking and throughput improvement for productivity and Overall Equipment Effectiveness (OEE), process capability improvement leading to reduction in defects and resource optimisation.

Renewable energy:

ITC has invested in renewable energy projects, for both renewable electricity and renewable thermal requirements. ITC has invested in several solar electricity projects during the year. Augmentation of Renewable Energy assets with commissioning of two offsite solar power plants, of capacity 13.5 MW in Uttar Pradesh and 14.5 MW in Karnataka. With investments over the years, ITC has increased its renewable energy capacity to over 200 MW. Based on the investments in renewable electricity and renewable thermal projects, ITC has been able to increase its renewable energy share to 50%, seven years ahead of its 2030 target.

9. Provide details related to waste management by the entity, in the following format:

Total waste generated is mentioned in rows (A) to (H)

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

Parameter (in kilo tonnes) FY 2023-24 FY 2022-23
- -
Plastic waste (A)
E-waste (B) 0.09 0.11
Bio-medical waste (C) 0.01 0.01
Construction and demolition waste (D) [#] 12 6
Battery waste (E) 0.13 0.15
Radioactive waste (F) - 0.001
Other Hazardous waste. Please specify, if any. (G) 22 18
Other Non-hazardous waste generated (H). Please specify, if any. (Break-up by 696 682
composition i.e. by materials relevant to the sector)
Total (A+B + C + D + E + F + G + H) 730 706
Waste intensity per rupee of turnover 10 10
(Total waste generated/Revenue from operations)
Waste intensity per rupee of turnover adjusted for Purchasing Power Parity 24 23
(PPP) (Total waste generated/Revenue from operations adjusted for PPP)
Waste intensity in terms of physical output [& ] 0.64 0.63
(in tonnes of waste generated/tonne of production)
Waste intensity (optional) – the relevant metric may be selected by the entity - -
Total waste recovered through recycling, re-using or other recovery operations
(i) Recycled 714 695
- -
(ii) Re-used
(iii) Other recovery operations 12 11
Total 726 705
Total waste disposed by nature of disposal method
(i) Incineration 0.5 0.6
(ii) Landfilling 1.3 0.4
(iii) Other disposal operations 0.4 0.1
Total 2.2 1.1
----- End of picture text -----**

Plastic waste is reported under Non-hazardous waste

** Insignificant quantity of radioactive waste was generated.

*** Waste re-used is reported under waste recycled

Construction and Demolition (C&D) waste: There is an increase in C&D waste on account of multiple new Projects being executed across ITC.

&Since ITC is a conglomerate with multiple businesses wherein physical output is reported in different units of measurement, hence the data for waste intensity in terms of physical output (tonnes of production) is reported only for PSPD which accounts for more than 80% of ITC’s total waste generation. For data of other Divisions, refer to ‘Towards Circularity’ section of ITC’s Sustainability Report 2024.

ITC’s waste data has been assured at the ‘Reasonable Level’ by an independent third-party assurance provider.

In FY 2023-24, ITC continued to recycle over 99% of waste from its operations. In addition to this, the Company’s PSPD recycled over 89,000 tonnes of externally sourced waste paper, thereby creating a positive environmental footprint. The Company also collected and sustainably managed more than 100% of its post-consumer plastic packaging waste.

Business Responsibility and Sustainability Report

REPORT AND ACCOUNTS 2024

10. Briefly describe the waste management practices adopted in your establishments. Describe the strategy adopted by your company to reduce usage of hazardous and toxic chemicals in your products and processes and the practices adopted to manage such waste

The Company has initiated measures across Units to ensure waste minimisation, segregation of waste at source and recycling. During the year, the recycling level reached over 99%. In addition, over 89,000 tonnes of externally sourced waste paper was used as raw material during the year.

ITC follows a proactive approach to manage hazardous chemicals by actively looking for alternatives, which not only helps keep its operations safe, but also ensures safest products for customers. This approach is demonstrated in pioneering practices implemented by ITC like Elemental Chlorine Free (ECF) bleaching, and ozone bleaching technology in India in its Paper Business, and switching from solvent-based inks to waterbased ones in its Packaging and Printing Business.

Note: For more details, refer to ‘Chemical Safety Management’ section of ITC Sustainability Report 2024

11. If the entity has 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.

ITC’s existing operations/offices comply with applicable environmental regulations of the Country, and operate as per Consent to Operate (CTO) conditions from the Central and State Pollution Control Boards in line with guidelines issued by the Ministry of Environment, Forest and Climate Change, Government of India.

12. Details of environmental impact assessments of projects undertaken by the entity based on applicable laws, in the current financial year.

==> picture [495 x 212] intentionally omitted <==

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

Name and EIA Date Whether Results Relevant Web link
brief details of Notification conducted communicated
project No. by in public
independent domain (Yes/
external No)
agency (Yes/
No)
Proposed Mill EIA September, Yes Yes https://parivesh.nic.
Expansion Notification 2023 in/newupgrade/#/
Plan (MEP) 2006 trackYourProposal/proposal-det
to increase ails?proposalId=IA%2FTG%2FIN
Paper/Board D1%2F444107%2F2023&propos
capacity at al=9432522
ITC Limited,
PSPD Unit
Bhadrachalam
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13. Is the entity compliant with the applicable environmental law/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 (Y/N). If not, provide details of all such non-compliances.

ITC’s existing operations/offices comply with applicable environmental regulations of the Country, and operate as per CTO conditions from the Central and State Pollution Control Boards.

Leadership Indicators

1. Water withdrawal, consumption and discharge in areas of water stress (in kilolitres).

ITC has developed the water risk assessment methodology for identifying water stressed areas based on WRI Aqueduct’s Baseline Water Stress and Central Ground Water Board’s (India) groundwater block classification. Site level assessment for water stress sites is done periodically using the above assessment framework and sites for interventions are prioritised on the basis of stakeholder consultation and business needs. ITC’s water stewardship goals are available in ‘Sustainability 2.0 Ambitions’ section of ITC Sustainability Report 2024.

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For each facility/plant located in areas of water stress, provide the following information:

(i) Name of the area: Kapurthala, Saharanpur, Ranjangaon, Kothagudem, Bengaluru and Kovai

(ii) Nature of operations: Manufacture of FMCG products and Paperboards & Specialty Papers

(iii) Water withdrawal, consumption and discharge in the following format

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Parameter FY 2023-24 FY 2022-23
Water withdrawal by source (in million kilolitres)
(i) Surface water 28.1 27.2
(ii) Groundwater 0.1 0.1
(iii) Third party water 0.5 0.5
(iv) Seawater/desalinated water 0 0
(v) Others 0 0
Total volume of water withdrawal (in million kilolitres) 28.7 27.8
Total volume of water consumption (in million kilolitres) 8.4 9.3
(Total water withdrawal – Total water discharged)
Water intensity per rupee of turnover (Water consumed/turnover) 121 132
(in kilolitre/crore INR)
Water intensity (optional) – the relevant metric may be selected by the entity
Water discharge by destination and level of treatment (in million kilolitres)
(i) Into Surface water 10.5 10.7
No treatment 0 0
With treatment – please specify level of treatment Secondary Secondary
(ii) Into Groundwater 0 0
No treatment NA NA
With treatment – please specify level of treatment NA NA
(iii) Into Seawater 0 0
No treatment NA NA
With treatment – please specify level of treatment NA NA
(iv) Sent to third-parties 9.8 7.7
No treatment 0 0
With treatment – please specify level of treatment Tertiary Tertiary
Total water discharged (in million kilolitres) 20.3 18.5
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ITC’s water withdrawal, discharge and consumption data has been assured at the ‘Reasonable Level’ by an independent thirdparty assurance provider.

2. Please provide details of total Scope 3 emissions & its intensity

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Parameter Unit FY 2023-24 FY 2022-23
Total Scope 3 emissions (Break-up of the GHG into Kilo tonnes of CO2 253 295
CO2, CH4, N2O, HFCs, PFCs, SF6, NF3, if available) equivalent
Total Scope 3 emissions per rupee of turnover Tonnes of CO2 3.60 4.21
equivalent/crore INR
- -
Total Scope 3 emission intensity (optional) – the
relevant metric may be selected by the entity
----- End of picture text -----

The scope of coverage for Scope 3 emission is mentioned in ‘Climate Change’ section of ITC Sustainability Report 2024.

Note: The Scope 3 emission for FY 2023-24 has reduced due to lower exports of some of the Agri commodities and substituting imported raw materials with domestically sourced raw materials.

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3. With respect to the ecologically sensitive areas reported at Question 11 of Essential Indicators above, provide details of significant direct & indirect impact of the entity on biodiversity in such areas along-with prevention and remediation activities.

Refer response in above Essential Indicator 11. For details on the Company’s approach to Biodiversity Management, refer to ‘Biodiversity Management’ section of ITC Sustainability Report 2024.

4. If the entity has undertaken any specific initiatives or used innovative technology or solutions to improve resource efficiency, or reduce impact due to emissions/effluent discharge/waste generated, please provide details of the same as well as outcome of such initiatives.

The Company has undertaken a number of initiatives, and also deployed innovative technologies across its operations for improving resource efficiency and minimising environmental impact. For details, refer to ‘Disclosure on Conservation of Energy and Technology Absorption’ forming part of the Report of the Board of Directors & Management Discussion and Analysis in ITC Report and Accounts 2024, and ‘Climate Change’, ‘Water Security’, ‘Towards Circularity’, ‘Chemical Safety Management’, and ‘Air Emissions Management’ sections of ITC Sustainability Report 2024.

5. Does the entity have a business continuity and disaster management plan?

Yes, all Businesses in ITC have Business Continuity Plans duly approved by the Management Committee of the respective Businesses. Such Business Continuity Plans have been made comprehensive to include all facets of operations and are being tested at pre-determined intervals.

6. Disclose any significant adverse impact to the environment, arising from the value chain of the entity. What mitigation or adaptation measures have been taken by the entity in this regard?

ITC has a Board approved Policy on ‘Sustainable Supply Chain and Responsible Sourcing’ and a ‘Code of Conduct for Suppliers and Service Providers’. The Code is shared and accepted by supply chain partners and service providers. ITC has a robust process of evaluating its Suppliers

and Service Providers before engaging with them, proactively making them aware of its expectations/ requirements, and seeking commitment for compliance through contractual agreements. Additionally, ITC facilitates its value chain partners in handling any adverse impacts. For example, managing hazardous chemicals is not only important within ITC factories, but also in the supply chain. Within the supply chain, farmers working with hazardous pesticides is an area of special attention. ITC’s approach is to eliminate or reduce the use of hazardous pesticides. Intensive training is conducted on Integrated Pest Management (IPM), which helps adopt a holistic approach in reducing pesticide usage as well as substituting such pesticides with naturebased solutions. The training programmes also cover the safe handling of pesticides used and the responsible management of waste generated.

7. Percentage of value chain partners (by value of business done with such partners) that were assessed for environmental impacts.

Key value chain partners like third-party manufacturers are encouraged to adopt management practices detailed under International Standards such as ISO 9001, ISO 14001, OHSAS 18001 and ITC’s Environment, Health and Safety (EHS) Guidelines. Contract manufacturing agreements also include aspects of EHS. Systems are in place for monitoring and reporting on key Third-Party Manufacturers’ (TPMs) environmental performance, including energy, water and waste management. ITC’s leading Agri value chains are assessed for certification standards such as Forest Stewardship Council® (FSC)®, Rainforest Alliance, Sustainable Tobacco Programme (STP 2.0), G.A.P., etc. These standards, among others, also include environmental criteria. Additionally, ITC conducts third-party assessment of its Critical Tier-1* suppliers on an ongoing basis, and this assessment covers key aspects on environmental compliance and management practices. 40% of ITC’s Critical Tier-1 suppliers have been assessed so far.

*All ITC Businesses have identified Critical Tier-1 suppliers based on buy value, ESG risk exposure, importance to business continuity, among others. ITC’s Sustainable Supply Chain Programme is focussed on working closely with the set of identified Critical suppliers.

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Principle 7

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

Essential Indicators

1 a. Number of affiliations with trade and industry chambers/ associations.

ITC’s Policy on Responsible Advocacy (https://www.itcportal.com/about-itc/policies/sustainability-policy.aspx) provides the framework for necessary interface with Government/Regulatory Authorities on matters concerning various sectors in which the Company operates. The Company’s engagement with the relevant authorities is guided by the values of commitment, integrity, transparency and the need to balance the interests of diverse stakeholders. The Company works with apex industry institutions that are engaged in policy advocacy as well as various other forums. The Company had active affiliations with 89 such trade and industry chambers/associations.

b. List the top 10 trade and industry chambers/ associations (determined based on the total members of such body) the entity is a member of/ affiliated to.

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

S. No. Name of the trade and industry chambers/ Reach of trade and industry chambers/ associations
associations (State/National)
1 ASSOCHAM National
2 All India Management Association National
3 Confederation of Indian Industry National
4 Madras Management Association State
5 Indian Merchants Chamber of Commerce National
6 Mahratta Chamber of Commerce, Industries State
& Agriculture
7 PHD Chamber of Commerce & Industry National
8 Bombay Management Association State
9 Federation of Indian Chambers of Commerce National
& Industry
10 Retailers Association of India National
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2. Provide details of corrective action taken or underway on any issues related to anti-competitive conduct by the entity, based on adverse orders from regulatory authorities.

The Company has not engaged in any anti-competitive conduct.

Leadership Indicators

1. Details of public policy positions advocated by the entity.

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

S. Public Policy Method Resorted for Whether Frequency of Web Link, if
No. Advocated such Advocacy Information Review by Board available
Available in Public (Annually/Half-
Domain? yearly/Quarterly/
(Yes/No) Others – please
specify)
1. The Company’s Policy The Company works with For more details, Annually -
on Responsible apex industry institutions refer to ‘Report of
Advocacy approved that are engaged in the Board
by the Board provides policy advocacy, like the of Directors &
Confederation of Indian
the framework for Management
Industry, Federation
necessary interface Discussion and
of Indian Chambers of
with Government/ Analysis’ section
Commerce & Industry,
Regulatory Authorities Associated Chambers of forming part of
on matters concerning ITC’s Report and
Commerce and Industry
various sectors in of India, and various Accounts 2024.
which the Company other forums including
operates. regional Chambers of
Commerce.
Sector-wise matters
taken up are in line The Company’s
with national priorities engagement with the
relevant authorities is
to strengthen
guided by the values of
domestic industry,
commitment, integrity,
promoting sustainable
transparency and taking
agriculture and
into consideration
business practices. interests of all
stakeholders.
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Principle 8

Businesses should promote inclusive growth and equitable development

Essential Indicators

1. Details of Social Impact Assessments (SIA) of projects undertaken by the entity based on applicable laws, in the current financial year.

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Name and Brief SIA Date of Whether Results Relevant
Details of Project Notification Notification Conducted by Communicated Web link
No. Independent in Public
External Domain
Agency (Yes/ (Yes/No)
No)
Not Applicable
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2. Provide Information on Project(s) for which Ongoing Rehabilitation and Resettlement (R&R) is being Undertaken by your Entity.

S. No.	Name of Project for which R&R is ongoing	State	District	No. of Project Affected Families (PAFs)	% of PAFs covered by R&R	Amount paid to PAFs in the FY (In INR)
Not Applicable

3. Describe the mechanisms to receive and redress grievances of the community.

ITC’s Social Investments Programme (SIP) adopts a bottom-up approach by keeping community needs and priorities as the key driver of all its interventions. Detailed and structured community engagements are planned every 4-5 years to revisit the changing needs of the community and the emerging priorities which feed into designing of new interventions and re-designing of ongoing and new programmes. Further, regular community interactions are undertaken by the internal state level programme teams and the implementing partners to discuss, identify and address any issues, complaints and grievances of the community members pertaining to the interventions of Social Investments Programme. SIP has also formalised and internalised the process of undertaking and recording such community interactions in-line with the new SEBI requirements on Business Responsibility and Sustainability Reporting. Such discussions not only focus on complaints and grievances, but also on providing resolution in a time bound manner.

During 2023-24, 42 such community engagements were held across all major states where SIP programmes are implemented. 6 grievances (mainly as requests for further interventions and scope of improvement) were reported. Largely, requests and demands were raised

during these meetings for further expansion of scope of existing programmes. The SIP state teams have taken cognisance of all the relevant concerns and applicable actions have been incorporated in plans for the upcoming year. Details on mechanisms to receive and redress grievances of the community are also provided under Question 25 of Section A of this Report.

4. Percentage of input material (inputs to total inputs by value) sourced from suppliers.

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

FY 2023-24 FY 2022-23
Directly sourced from
24.99% 17.65%
MSMEs/small producers
Directly from within India 92.41% 91.64%
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5. Job creation in smaller towns – Disclose wages paid

to persons employed (including employees or workers employed on a permanent or non-permanent / on contract basis) in the following locations, as % of total wage cost.

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

Location FY 2023-24 FY 2022-23
Rural 10% 11%
Semi-urban 15% 15%
Urban 17% 17%
Metropolitan 58% 57%
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Note: Pertains to permanent employees which includes permanent workers, management and non-management staff

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Leadership Indicators

1. Provide details of actions taken to mitigate any negative social impacts identified in the Social Impact Assessments (Reference: Question 1 of Essential Indicators above):

Not applicable

2. Provide the following information on CSR projects undertaken by your entity in designated aspirational districts as identified by government bodies:

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

State Aspirational District Amount (Rs. In Lakhs)
Telangana Bhadradri Kothagudem 1,082.08
Uttarakhand Haridwar 592.00
Madhya Pradesh Vidisha 266.60
Assam Darrang 241.12
Odisha Malkangiri 226.34
Rajasthan Baran 212.73
Rajasthan Jaisalmer 195.77
Bihar Begusarai 125.11
Haryana Nuh 121.16
Karnataka Yadgir 92.23
Chhattisgarh Sukma 89.85
Madhya Pradesh Damoh 86.35
Multiple (12 States) Multiple 974.19
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*Spends in balance 50 Aspirational Districts of the total 62 where ITC had CSR projects

3. a. Do you have a preferential procurement policy where you give preference to purchase from suppliers comprising marginalized /vulnerable groups? (Yes/No):

The Board approved Policy on Sustainable Supply Chain and Responsible Sourcing defines the supply chain partners which includes farmers. ITC is committed to collaborating with farmers to make them more sustainable and help build their adaptive capacity and resilience to emerging risks like climate change, water stress and other extreme weather events. ITC is also raising awareness and working with farmers on crop quality, safety, protection, integrity and traceability, as applicable.

b. From which marginalized /vulnerable groups do you procure?

Farmers including women farmers and small landholders have been identified as marginalised/ vulnerable group.

c. What percentage of total procurement (by value) does it constitute?

During FY 2023-24, ITC consumed over 2.4 million tonnes of agri raw materials, which is nearly 72% of

overall raw materials’ consumption.

4. Details of the benefits derived and shared from the intellectual properties owned or acquired by your entity (in the current financial year), based on traditional knowledge.

Not Applicable

5. Details of 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. Details of beneficiaries of CSR Projects:

In the social sector, the two most important stakeholders of ITC are:

Rural communities with whom the Company’s Agri-Businesses have forged long and enduring partnerships; and
Communities residing in close proximity to our manufacturing Units, situated in urban and semirural locations

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The beneficiaries of ITC’s CSR programmes mostly belong to the under privileged sections of the society and small & marginal farmers who face the challenges of securing sustainable livelihoods. These challenges are addressed through the Two Horizon approach of making today’s dominant source(s) of livelihoods sustainable; and strengthening capabilities for tomorrow.

The Two Horizon strategy ensures an integrated approach to development involving several interventions. Presented ahead are the total number of approximate beneficiaries for key interventions and estimated proportion of beneficiaries belonging to vulnerable and marginalised groups.

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CSR Projects No. Of Beneficiaries From CSR % Of Beneficiaries From Vulnerable
Projects (2023-24) And Marginalised Groups
Climate Smart Agriculture 10.50 Lakhs# SC / ST – 19%; Female – 19%
Natural Resources Management -Water 60,600 SC / ST – 11%; Female – 22%
Stewardship
On-Farm Livelihood Diversification - 10,800 SC / ST – 34%; Female – 28%
Social Forestry
Off-Farm Livelihood Diversification - 2.33 Lakhs SC / ST – 19%; Female – 40%
Improved Animal Husbandry Practices
Support to Education 4.10 Lakhs Children – 100%; ~50% Girl Children
Skilling of Youth 12,500 SC / ST – 31%; Female – 49%
Improving Health & Sanitation 6,600 SC / ST – 5%
-Household Sanitation
Improving Health & Sanitation - Waste 25 Lakhs SC / ST – 1.2%
Management
Improving Health & Sanitation -Mother 14.61 Lakhs 100% - Women, Adolescents And
and Child Health and Nutrition Children
Women Empowerment 8.17 Lakhs 100% Women
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Excludes farmers covered under NITI Aayog partnership programme or any other PPPs

Includes 1,300 candidates who were trained through other centres after mobilisation by ITC.
** includes Self Help Group (SHG) members and Financial Literacy programme SHG members

The table ahead presents the 2030 targets for key initiatives undertaken by SIP and progress made till FY 2023-24, which indicates that the progress is on track.

==> picture [494 x 221] intentionally omitted <==

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Objective Initiatives UoM Target Achieved till
2030 FY 2023-24
Horizon I - Sustainable Livelihoods Today
Climate Smart Agriculture Climate Smart Lakh Acres 40 27.94
for climate risk assessments, Agriculture area [1]
climate change adaptation,
and actions for sustainable Climate Smart Village Lakh Acres 30 19
improvement of yields and Area (Sub-part of
incomes above) [1#]
Natural Resources Natural Resources Lakh Acres 22 16.38
Management to conserve and Management - Water
replenish natural resources Stewardship
critical for agriculture
Water harvesting Nos. 50,000 32,400
structures (including
ground water
recharge structures)
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Objective Initiatives UoM Target Achieved till
2030 FY 2023-24
Storage Potential [#] Million KL 60 54.26
Crop Water Use Million KL 2,000 1,090
Efficiency [#]
Bio-Diversity Lakh Acres 10 4.70
Conservation [#]
Livelihood Diversification to On-farm livelihood Lakh Acres 6.30 4.90
improve incomes and de- Diversification – Social
risk livelihoods from climate Forestry [#]
change
Off-farm livelihood Household 10 7
diversification - Coverage
Improved Animal (Lakhs)
Husbandry Practices
Institutional Support for risk Link farmers No. of 50 24.75
mitigation and reduction of with Government Linkages
costs of cultivation programmes (Lakhs)
Agri Business Centres Nos. 2,000 1,158
Farmer Producer Nos. 4,000 1,660
Organisations
Horizon II - Creating Capabilities for Tomorrow
Support to Education for Improvement in No. in Lakhs 20 15.31
improving quality of education learning outcomes –
and creating conducive Children covered
learning environment
Infrastructure support Nos. 4,000 3,914
to Government
Schools and
Anganwadis
Skilling of youth for enabling Vocational Training – No. in Lakhs 2.25 1.12
livelihood and employability Youth trained
Provide access to sanitation Improving Health Nos. 40,000 43,804
and waste management & Sanitation -
services to improve habitats Household Toilets
constructed
Improving Health & No. of 75 50.59
Sanitation - Waste Households
Management (SWM) (Lakhs)
Provide healthcare and Beneficiaries covered Nos. in Lakhs 15 14.61
nutrition services to women under Maternal Child
and children Health & Nutrition
programme
Empowering women for Women covered Nos. in Lakhs 2.50 1.92
reduction in economic and through livelihood
social discrimination and other
microenterprises
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Note:

Figures on Climate Smart Village and Climate Smart Agriculture area pertains to scale in that FY

These indicators also contribute to five of the Company’s Sustainability 2030 (S 2.0) commitments

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Principle 9

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

Essential Indicators

1. Describe the mechanisms in place to receive and respond to consumer complaints and feedback.

A well-established system continues to be in place for dealing with consumer feedback. Consumers are provided multiple options to connect with the Company through email, telephone, website, social media, feedback forms, etc. In addition, the Company’s Businesses have a dedicated consumer response cell to respond to their queries and receive feedback on products so as to be able to continuously improve upon its products and services.

2. Turnover of products and/ services as a percentage of turnover from all products/service that carry information about:

All products/services of the Company contain relevant information as required under applicable laws.

3. Number of consumer complaints in respect of the following:

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FY 2023-24 Remarks FY 2022-23 Remarks
Received Pending Received Pending
during the resolution at during the resolution at
year end of year year end of year
Data privacy 0 0 - 0 0 -
Advertising 15 1 13 0
Cyber-security 0 0 0 0
Delivery of 591 135 521 0
essential
Services
Restrictive 967 38 726 0
Trade
Practices
Unfair Trade 28 8 13 0
Practices
Others 20,394 1,829 17,573 1,648
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*Definition of complaints under various categories is given below

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

Category Complaints Related to
The Company is not engaged in the delivery of essential services. These complaints are in
Delivery of Essential Services
relation to availability of the Company’s goods and services.
Quantity and weightage related, duplicate pack and complaints made on account of fraudulent
Restrictive Trade Practices
calls/e-mails offering ITC’s distributorship
Unfair Trade Practices High pricing (product sold above MRP)
Product quality related complaints, service-related complaints against distributor/ retailer/
Others
salesperson
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4. Details of instances of product recalls on account of safety issues:

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

Number Reasons for recall
Voluntary Recalls Nil Not Applicable
Forced Recalls Nil Not Applicable
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5. Does the entity have a framework/ policy on cyber security and risks related to data privacy? (Yes/No) If available, provide a web-link of the policy.

A Cyber Security Committee, led by the Chief Information Officer (CIO), is established to focus specifically on cyber security risks. Its primary responsibility is to monitor emerging practices and technologies and provide recommendations to

Business Responsibility and Sustainability Report

REPORT AND ACCOUNTS 2024

enhance the security of the organisation’s IT systems and infrastructure. The Chief Information Security Officer (CISO), a recently added role within the organisation, ensures that the cyber security systems remain effective and up-to-date. Further, the CIO actively participates in meetings of the Risk Management Committee whenever matters related to cyber security are discussed.

ITC’s Information Management Policy defines the framework/policy on cyber security and risks related to data privacy.

ITC’s Privacy Policy is part of Information Management Policy and is published on ITC Portal, please refer to https://www.itcportal.com/about-itc/policies/privacy-policy.aspx

6. Provide details of any corrective actions 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.

Robust systems have been put in place to identify the issues faced by the consumers and ensure timely resolution of the same. Efforts are in place to continually strengthen the quality assurance system and to improve delivery timelines.

7. Provide the following information relating to data breaches:

a. Number of instances of data breaches: Nil

b. Percentage of data breaches involving personally identifiable information of customers: Nil
c. Impact, if any, of the data breaches: Nil

Leadership Indicators

1. Channels / platforms where information on products and services of the entity can be accessed (provide web link, if available).

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Products/Initiative Link
ITC Corporate Website https://www.itcportal.com
ITC’s Businesses https://www.itcportal.com/businesses/index.aspx
ITCstore.in https://itcstore.in
ITC Brands https://www.itcportal.com/brands-microsite/default.aspx
Bingo! on Instagram https://www.instagram.com/bingo_snacks/
YiPPee! on Instagram https://www.instagram.com/sunfeast_yippee/
Aashirvaad on Instagram https://www.instagram.com/aashirvaad/
Sunfeast Dark Fantasy on Instagram https://www.instagram.com/sunfeastdarkfantasy/
Mom’s Magic on Instagram https://instagram.com/sfmomsmagic/
Classmate on Instagram https://instagram.com/classmatebyitc/
ITC: Creating Enduring Value for India https://youtu.be/VwnE4eN_BTk
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2. Steps taken to inform and educate consumers about safe and responsible usage of products and/or services.

All Businesses of the Company comply with the regulations and relevant voluntary codes concerning marketing communications, including advertising, promotion and sponsorship. The Company’s communications are aimed at enabling consumers to make informed purchase decisions. The Company also makes efforts to educate consumers on responsible usage of its products and services.

For more information, refer to ‘Product Sustainability’ section of ITC Sustainability Report 2024.

3. Mechanisms in place to inform consumers of any risk of disruption/discontinuation of essential services.

The Company is not engaged in providing essential services. However, the Company has necessary mechanisms in place to inform consumers if any major discontinuation happens in

relation to its products and services.

4. Does the entity display product information on the product over and above what is mandated as per local laws? (Yes/No/Not Applicable) If yes, provide details in brief. Did your entity carry out any survey with regard to consumer satisfaction relating to the major products / services of the entity, significant locations of operation of the entity or the entity as a whole? (Yes/No)

As an integral part of ITC’s consumer satisfaction focus, attention is paid to product information and labelling and consumer engagement by the Businesses. ITC’s Businesses have an established system for monitoring customer satisfaction and it ensures that their feedback is addressed in a systematic manner.

Note: For more information on Product Information, Labelling and Consumer Feedback Management, refer to ‘Product Sustainability’ section of ITC Sustainability Report 2024.

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KPMG Assurance and Consulting Services LLP Telephone: +91 (22) 3989 6000 2[nd] Floor, Block T2 (B Wing), Fax: +91 (22) 3090 2210 Lodha Excelus, Apollo Mills Compound, Internet: www.kpmg.com/in N. M. Joshi Marg, Mahalaxmi Mumbai - 400 011 India

Independent Practitioners’ Reasonable Assurance Report

To the Directors of ITC Limited

Assurance report on the sustainability disclosures in the Business Responsibility and Sustainability Reporting (BRSR) Core attributes F0F [1] (called ‘Identified Sustainability Information’ (ISI)) of ITC Limited (the ‘Company’) for the period 1 April 2023 to 31 March 2024. The ISI is included in the Business Responsibility and Sustainability Reporting of the Company for the period 1 April 2023 to 31 March 2024.

Opinion

We have performed a reasonable assurance engagement on whether the Company’s sustainability disclosures in the Identified Sustainability Information (refer to Appendix 1) for the period 1 April 2023 to 31 March 2024 has been prepared in accordance with the reporting criteria (refer table below).

Identified Sustainability Information (ISI) subject to assurance	Period subject to assurance	Reporting criteria
BRSR Core (refer Annexure 1)	1 April 2023 to 31 March 2024	- Regulation 34(2)(f) of the Securities and Exchange Board of India (SEBI) Listing Obligations and Disclosure Requirements (SEBI LODR). - Guidance notes for BRSR format issued by SEBI.

This engagement was conducted by a multidisciplinary team including assurance practitioners, engineers, and environmental and social professionals.

In our opinion, the Company’s Identified Sustainability Information for the period 1 April 2023 to 31 March 2024, subject to reasonable assurance is prepared, in all material respects, in accordance with the Regulation 34(2)(f) of the Securities and Exchange Board of India (SEBI) Listing Obligations and Disclosure Requirements (SEBI LODR) and basis of preparation set out in Section A: General Disclosure 13 of “Business Responsibility and Sustainability Report” section of Annual Report FY 2023-24 of the Company.

Basis for opinion

We conducted our engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised), Assurance Engagements Other Than Audits or Reviews of Historical Financial Information issued by the International Auditing and Assurance Standards Board (IAASB). Our responsibilities under those standards are further described in the “Our responsibilities” section of our report.

1 Notified by SEBI vide circular number SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023

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We have complied with the independence and other ethical requirements of the International Code of Ethics for Professional Accountants (including International Independence Standards) issued by the International Ethics Standards Board for Accountants (IESBA).

Our firm applies International Standard on Quality Management (ISQM) 1, Quality Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services Engagements , issued by the IAASB. This standard requires the firm to design, implement and operate a system of quality management, including policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.

We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Other information

Management and the Board of Directors are responsible for the other information. The other information comprises the information included in the Company’s Annual Report (but does not include the Identified Sustainability Information and assurance report thereon). The Company’s Annual Report is expected to be made available to us after the date of this assurance report.

Our reasonable assurance opinion on the Identified Sustainability Information does not cover the other information and we will not express any form of assurance conclusion thereon.

In connection with our assurance on the Identified Sustainability Information, our responsibility is to read the other information identified above when it becomes available, and in doing so, consider whether other information is materially inconsistent with the Identified Sustainability Information or our knowledge obtained in the assurance, or otherwise appears to be materially misstated.

Other matter

The BRSR for the period from 1 April 2022 to 31 March 2023 was not subject to limited/reasonable assurance engagement and, accordingly, we do not express an opinion/conclusion, or provide any assurance on such information.

Our opinion/conclusion is not modified with respect to this matter.

Intended use or purpose

The ISI and our reasonable assurance report are intended for users who have reasonable knowledge of the BRSR Core attributes, the reporting criteria and ISI and who have read the information in the ISI with reasonable diligence and understand that the ISI is prepared and assured at appropriate levels of materiality.

Our opinion is not modified in respect of this matter.

Responsibilities for the identified Sustainability Information (ISI)

The management of the Company acknowledge and understand their responsibility for:

designing, implementing and maintaining internal controls relevant to the preparation of the ISI that is free from material misstatement, whether due to fraud or error;

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selecting or establishing suitable criteria for preparing the ISI, taking into account applicable laws and regulations, if any, related to reporting on the ISI, identification of key aspects, engagement with stakeholders, content, preparation and presentation of the ISI in accordance with the reporting criteria;
disclosure of the applicable criteria used for preparation of the ISI in the relevant report/statement;
preparing/properly calculating the ISI in accordance with the reporting criteria;
ensuring the reporting criteria is available for the intended users with relevant explanation;
establishing targets, goals and other performance measures, and implementing actions to achieve such targets, goals and performance measures;
responsible for providing the details of the management personnel who takes ownership of the ISI disclosed in the report;
ensuring compliance with law, regulation or applicable contracts;
making judgments and estimates that are reasonable in the circumstances;
identifying and describing any inherent limitations in the measurement or evaluation of information subject to assurance in accordance with the reporting criteria;
preventing and detecting fraud;
selecting the content of the ISI, including identifying and engaging with intended users to understand their information needs;
informing us of other information that will be included with the ISI; and
supervision of other staff involved in the preparation of the ISI.

Those charged with governance are responsible for overseeing the reporting process for the Company’s ISI.

Inherent limitations in preparing the ISI

The preparation of the Company’s BRSR information requires the management to establish or interpret the criteria, make determinations about the relevancy of information to be included, and make estimates and assumptions that affect the reported information.

Measurement of certain amounts and BRSR Core metrics, some of which are estimates, is subject to substantial inherent measurement uncertainty, for example, GHG emissions, water footprint, energy footprint. Obtaining sufficient appropriate evidence to support our opinion/conclusion does not reduce the uncertainty in the amounts and metrics.

Our responsibilities

We are responsible for:

Planning and performing the engagement to obtain reasonable assurance on the sustainability disclosures in the BRSR Core are free from material misstatement, whether due to fraud or error, in accordance with the Reporting Criteria in line with the section above.
Forming an independent opinion, based on the procedures we have performed and the evidence we have obtained, and
Reporting our reasonable assurance opinion to the Directors of ITC Limited.

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Exclusions

Our assurance scope excludes the following and therefore we will not express a conclusion on the same:

Operations of the Company other than those mentioned in the “Scope of Assurance”.
Aspects of the BRSR and the data/information (qualitative or quantitative) other than the ISI.
Data and information outside the defined reporting period i.e., from 1 April 2023 to 31 March 2024.
The statements that describe expression of opinion, belief, aspiration, expectation, aim, or future intentions provided by the Company.

Summary of the work we performed as the basis for our conclusion

We exercised professional judgment and maintained professional skepticism throughout the engagement. We designed and performed our procedures to obtain evidence that is sufficient and appropriate to provide a basis for our reasonable assurance opinion. The nature, timing, and extent of the procedures selected depended on our judgment, including an assessment of the risks of material misstatement of the information subject to reasonable assurance, whether due to fraud or error. We identified and assessed the risks of material misstatement through understanding the Information subject to reasonable assurance and the engagement circumstances. We also obtained an understanding of the internal control relevant to the information subject to reasonable assurance in order to design procedures that are appropriate in the circumstances but not for the purpose of expressing an opinion on the effectiveness of internal controls.

In carrying out our engagement, we:

assessed the suitability of the criteria used by the Company in preparing the reasonable assurance information;
evaluated the appropriateness of reporting policies, quantification methods and models used in the preparation of the information subject to reasonable assurance and the reasonableness of estimates made by the Company;
performing substantive testing of data related to ISI, limited to 20 operational locations of the Company: and
evaluated the overall presentation of the information subject to reasonable assurance.

Shivananda Shetty Partner

KPMG Assurance and Consulting Services LLP

Date: 15-June-2024 Place: Mumbai

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Annexure – 1

BRSR Core attributes

Annexure – 1 BRSR Core attributes
BRSR Indicator	Type of Assurance
P1 E8- Number of days of accountspayable	Reasonable
P1 E9-Concentration of purchases & sales done with trading houses, dealers, and	Reasonable
related parties Loans and advances & investments with related parties
P3 E1c- Spending on measures towards well-being of employees and workers – cost	Reasonable
incurred as a % of total revenue of the company
P3 E11- Details of safety related incidents including lost time injury frequency rate,	Reasonable
recordable work-relatedinjuries,no. of fatalities
P5 E3b- Gross wagespaid to females as % of wagespaid	Reasonable
P5 E7- Complaints filed under the Sexual Harassment of Women at Workplace	Reasonable
(Prevention, Prohibition and Redressal) Act, 2013, including complaints reported,
complaints as a % of female employees, and complaints upheld
P6 E1- Details of total energy consumption (in Joules or multiples) and energy	Reasonable
intensity,
P6 E3- Provide details of following disclosures related to water: water withdrawal by	Reasonable
source, volume of water consumption, water intensity metrices
P6 E4- Provide following details of water discharged: water discharge by destination	Reasonable
and level of treatment.
P6 E7- Provide details of greenhouse gas emissions (Scope 1 and Scope 2 emissions)	Reasonable
& its intensity
P6 E9- Provide details related to waste management bythe entity	Reasonable
P8 E4- Input material sourced from following sources as % of total purchases –	Reasonable
Directly sourced from MSMEs/ small producers and from within India
P8 E5- Job creation in smaller towns	Reasonable
P9 E7- Instances involving loss/breach of data of customers as a percentage of total	Reasonable
data breaches orcybersecurity events

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AI assistant

ITC Ltd — Environmental & Social Information 2024

60425_rns_2024-06-28_a503f8f0-2f5c-4a12-9c5e-18da0fd67171.pdf

Business Responsibility and Sustainability Report for the financial year ended 31[st] March, 2024

Business Responsibility and Sustainability Report 2024

Glossary

ITC Divisions/ Businesses

ITC Specific Terms

General Terms

Section A: General Disclosures

II. Products/Services

16. Details of business activities: (accounting for 90% of the entity’s Turnover):

17. Products/Services sold by the entity: (accounting for 90% of the entity’s Turnover):

III. Operations

18. Number of locations where plants and/or operations/offices of the entity are situated.

19. Markets served by the entity

a. Number of Locations

b. What is the contribution of exports as a percentage of the total turnover of the entity?

c. A Brief on Types of Customers

IV. Employees

20. Details as at the end of Financial Year:

a. Employees and Workers (including Differently Abled):

b. Differently abled Employees and workers:

21. Participation/Inclusion/Representation of Women

22. Turnover rate for permanent employees and workers

V. Holding, Subsidiary and Associate Companies (including joint ventures)

23. (a) Names of holding/subsidiary/associate companies/joint ventures (As on 31.03.2024)

on a fully diluted basis.

VI. CSR Details

VII. Transparency and Disclosures Compliances

25. Complaints/grievances on any of the principles (Principles 1 to 9) under the National Guidelines on Responsible Business Conduct (NGRBC).

The process is undertaken annually in February / March, and resolution initiated in April, and hence they are still open as on 31st March.

26. Overview of the entity’s material responsible business conduct issues

Section B: Management and Process Disclosures

Section C: Principle-wise Performance Disclosure

Principle 1

Essential Indicator

3. Of the instances disclosed in Question 2 above, details of the Appeal/Revision preferred in cases where monetary or non-monetary action has been appealed.

4. Does the entity have an anti-corruption or anti-bribery policy? If yes, provide details in brief and if available, provide a web-link to the policy.

5. Number of Directors/KMPs/employees/workers against whom disciplinary action was taken by any law enforcement agency for the charges of bribery/corruption:

6. Details of complaints with regard to conflict of interest:

7. Provide 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.

8. Number of days of accounts payables ((Accounts payable *365)/Cost of goods/services procured) in the following format:

9. Open-ness of business

Leadership Indicators

1. Awareness programmes conducted for value chain partners on any of the Principles during the financial year:

Principle 2

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

Essential Indicators

1. Percentage of R&D and capital expenditure (capex) investments in specific technologies to improve the environmental and social impacts of product and processes to total R&D and capex investments made by the entity, respectively.

Note 1: R&D

Note 2: Capex investments

2.a. Does the entity have procedures in place for sustainable sourcing?

b. If yes, what percentage of inputs were sourced sustainably?

3. Describe the processes in place to safely reclaim your products for reusing, recycling and disposing at the end of life, for (a) Plastics (including packaging) (b) E-waste (c) Hazardous waste and (d) other waste.

4. Whether Extended Producer Responsibility (EPR) is applicable to the entity’s activities (Yes/No). If yes, whether the waste collection plan is in line with the Extended Producer Responsibility (EPR) plan submitted to Pollution Control Boards? If not, provide steps taken to address the same.

Leadership Indicators

1. Has the entity conducted Life Cycle Perspective/Assessments (LCA) for any of its products (for manufacturing industry) or for its services (for service industry)?

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

4. Of the products and packaging reclaimed at end of life of products, amount (in metric tonnes) reused, recycled, and safely disposed.

5. Reclaimed products and their packaging materials (as percentage of products sold) for each product category.

Principle 3

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

Essential Indicators

1. a. Details of Measures for the Well-being of Employees:

b. Details of Measures for the Well-being of Workers:

Business Responsibility and Sustainability Report

c. Spending on measures towards well-being of employees and workers (including permanent and other than permanent) in the following format-

2. Details of Retirement Benefits, for Current FY and Previous Financial Year.

3. Accessibility of workplaces

Are the premises/offices of the entity accessible to differently-abled employees and workers, as per the requirements of the Rights of Persons with Disabilities Act, 2016? If not, whether any steps are being taken by the entity in this regard.

4. Does the entity have an equal opportunity policy as per the Rights of Persons with Disabilities Act, 2016? If so, provide a web-link to the policy.

5. Return to work and Retention rates of permanent employees and workers that took parental leave.

7. Membership of employees and workers in association(s) or Unions recognised by the listed entity:

8. Details of training given to Employees and Workers:

9. Details of Performance and Career Development Reviews of Employees and Workers.

10. Health and Safety Management System:

a. Whether an Occupational Health and Safety Management System has been implemented by the Entity? (Yes/No). If yes, the coverage of such system?

b. What are the processes used to identify workrelated hazards and assess risks on a routine and nonroutine basis by the entity?

c. Whether you have processes for workers to report the work-related hazards and to remove themselves from such risks. (Y/N)

ITC Ltd Environmental & Social Information 2024

**8. Number of days of accounts payables ((Accounts payable *365)/Cost of goods/services procured) in the following format:**