Environment, Social and Governance Charter

OCL Iron & Steels Limited endeavors to conduct its business on the principles of ethics and transparency, social responsibility, and environmental sustainability. In this endeavor, the Company aspires to integrate the best practices into all aspects of its business. It is a pre requisite for us to conduct business in a legal and ethical manner, and in compliance with all applicable laws and regulations.

In this context, this ESG Policy has been developed based on the global standards and best practices being followed across industries. We adhere to this ESG Policy in letter and spirit to ensure growth and development.

We reserve the right to modify and amend this ESG Policy following any changes in the standards referred to, or to prevailing regulations, or in accordance to the policies of the Company.

This ESG Policy takes cognizance of the themes including environment, equitable treatment, well-being of employees and corporate governance as described in the NGRBC issued by the MCA. Further information on these principles can be accessed from the website of MCA: https://www.mca.gov.in/Ministry/pdf/NationalGuildeline_15032019.pdf. Principles and norms described under the theme of ‘climate change’ are based on the standards specified by the UNFCCC from time-to-time.

• BRR: Business Responsibility Report(s)
• BRSR: Business Responsibility and Sustainability Report(s)
• BRSR Core: BRSR Core is a subset of the comprehensive BRSR, comprising nine (09) key performance indicators/ metrics namely, (a) greenhouse gas [GHG] footprint; (b) water footprint; (c) energy footprint; (d) embracing circularity — details related to waste management by the entity; (e) enhancing employee well-being and safety; (f) enabling gender diversity in business; (g) enabling inclusive development; (h) fairness in engaging with customers and suppliers and; (i) open-ness of business under the ESG umbrella.
• Company: Company refers to OCL Iron & Steels Limited
• CSR: Corporate Social Responsibility
• ESG: Environmental, Social and Governance
• ESG Policy: ESG Policy refers to this environmental, social and governance (ESG) policy, i.e., the current document unless specified otherwise.
• ILO: International Labor Organization
• ISO: International Organization for Standardization
• MCA: Ministry of Corporate Affairs
• NAP: National Action Plan
• NDC: National Determined Contribution(s)
• NGRBC: National Guidelines on Responsible Business Conduct issued by the MCA
• NVG: National Voluntary Guideline(s) on the Social, Environmental and Economic Responsibilities of Business
• . Paris Agreement: The Paris Agreement (French: Accord de Paris), often referred to as the Paris Accords or the Paris Climate Accords, is an international treaty on climate change. Adopted by one hundred and ninety-six (196) countries including India in 2015, the agreement intends to reduce and mitigate greenhouse gas emissions
• SDG: Sustainable Development Goal(s)
• SEBI: Securities Exchange Board of India
• UN: United Nations
• UNFCCC: United Nations Framework Convention on Climate Change
• UNGA: United Nations General Assembly
• UNGP: United Nations Guiding Principle(s) on Business and Human Rights
• UNHRC: United Nations Human Rights Council
• UNWG: United Nations Working Group
• 2030 Agenda: The 2030 Development Agenda titled ‘Transforming our World: the 2030 Agenda for Sustainable Development’, is an international treaty which was adopted unanimously by all the member states of the UNGA including India in 2015.

The UNGA adopted the 2030 Agenda and seventeen (17) SDGs as a universal and transformative development strategy. The 2030 Agenda commits to the global community to achieve sustainable development in its three (03) dimensions — economic, social and environmental, in a balanced and integrated manner.

Building a sustainable and robust economy requires a shift in corporate business models, a reoriented and mobilized financial system under a regulatory system that promotes transparency and incentivizes action. Recognizing the need of the hour, numerous developments have taken place in the Indian regulatory scenario through significant policy changes to keep in line with global sustainability trends.

India ratified the Paris Agreement on October 02, 2016, and its commitments are called the NDCs. This was followed by ratification and subsequent adoption of Glasgow Climate Pact by India which laid forth five (05) nectar elements scheme which proposes—

• India will reach its non-fossil energy capacity to five hundred gigawatts (500 GW) by 2030.
• India will meet fifty (50) percent of its energy requirements from renewable energy by 2030.
• India will meet fifty (50) percent of its energy requirements from renewable energy by 2030.
• By 2030, India will reduce the carbon intensity of its economy by less than forty-five (45) percent.
• By 2070, India will achieve the target of net zero (0) greenhouse gas emissions. The MCA, Government of India, released a set of guidelines in 2011 called the NVGs. This was expected to provide guidance to businesses on what constitutes responsible business conduct. In order to align the NVGs with the SDGs and the ‘respect’ pillar of the UNGP the process of revision of NVGs was started in 2015.

The primary rationale for the update is to capture the following key drivers:

• The UNGPs: Through its resolution 17/4 of 16 June 2011, the UNHRC endorsed the Guiding Principles on Business and Human Rights: Implementing the United Nations ‘Protect, Respect and Remedy’ Framework. The UNGPs are grounded in recognition of a) the state’s existing obligations to respect, protect and fulfill human rights and fundamental freedoms; b) the requirement of business enterprises to respect human rights, and c) the need for access to effective remedy for those who are affected by adverse business-related human rights impacts or abuse. Since their release, the UNGPs have become the authoritative global standard for business and human rights. In further support of the UNGPs, the UNHRC established the UNWG and tasked it with facilitating the global dissemination and implementation of the UNGPs. The UNWG has strongly encouraged all states to develop an NAP as part of the states’ responsibility to disseminate and implement the UNGPs.
• UN SDGs: In September 2015, the UN General Assembly adopted the 2030 Agenda for sustainable development which established seventeen (17) SDGs, comprising targets and indicators, as well as follow-up and review mechanisms. Significantly, the SDGs recognize the role of business as a major driver for economic growth and infrastructure, whilst explicitly calling for businesses to act in accordance with the UNGPs.
• Paris Agreement on Climate Change (2015): This is an agreement under the UNFCC reached in December 2015, in which countries have committed to take steps to combat climate change and adapt to its effects. The Paris Agreement also constitutes SDG 13.
• Core Conventions 138 and 182 on Child Labor by the ILO: India, in June 2017, ratified ILO Core Conventions 138 (minimum age of employment of children) and ILO Core Convention 182 (worst forms of child labor).
• BRSRs: In 2012, the SEBI amended the listing agreement for companies listed in the stock exchanges in India, and mandated the submission of annual BRRs by the top hundred (100) listed companies. The annual BRR is based on the business reporting framework of the NVGs, and SEBI has since extended this requirement to the top five hundred (500) listed companies. In the backdrop of global developments and the increasing focus on sustainability investing, the existing BRR was radically enhanced to BRSR for ESG reporting in 2021. The BRSR is a notable departure from the existing BRR and set a significant step towards bringing sustainability reporting at par with financial reporting which will enable enterprises for better demonstration of their sustainability objectives, position and performance resulting into long-term value creation.
• Companies Act, 2013: Notified in the gazette of India on August 30, 2013, Section 135 of the Companies Act, 2013 requires companies to undertake CSR initiatives in communities, and has since, provided additional rules and guidance on the areas and target groups of such interventions in consistency with national socio-economic priorities.
  After, revision and modification, the new principles are called the NGRBC. As with the NVGs, the NGRBC has been designed to assist businesses to perform above and beyond the requirements of regulatory compliance.

The nine (09) thematic pillars of business responsibility have been articulated in the form of nine (09) principles, to be read in consonance with the ‘core elements’ as described in the NGRBC. The nine (09) key principles are as follows:

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

The NGRBC suggest two (02) versions of BRSR reporting — ‘comprehensive’ and ‘lite’. The comprehensive version of reporting is for listed organizations, while the lite version is for unlisted companies. The reporting under BRSR comprises of three (03) sections namely, (a) general disclosures [mandatory]; (b) management and process disclosures [mandatory] and; (c) principle-wise disclosures.

In 2023, in a bid to address the need for ESG disclosure assurance, SEBI has introduced BRSR Core which shall enhance the reliability of ESG disclosures.

Our ESG Policy is driven by our vision to be a leader in sustainable business. We understand that mineral is a finite resource and thus, we have outlined a minimal wastage policy and have been meticulously following it. Our automated rolling mill is powered by its in-house captive power plant which runs with rejected coal and waste heat from Direct Reduced Iron (DRI), minimizing the carbon footprint and ensuring uninterrupted power supply for production. It has received ISO – 9001, 14001 and OHSAS 18001 certification. We strive to engage in business with only such stakeholders, as far as practically possible, who hold ISO certification(s) or any other relevant certification(s). We envision integration of ESG aspects into our business operations which will help in generating superior long-term value, and reducing risks faced by the business.

Through our ESG Policy, we aim to: (a) define our position on ESG matters; and (2) guide employees on the manner to integrate ESG aspects in their decision-making processes relating to activities of the Company.

This ESG Policy provides the most essential principles and norms required for adherence with global standards and industry best practices. We strive to exceed these principles and norms through exemplary actions. We liaise with only such third-party stakeholders, as far as practically possible, who ensure adherence to the principles mentioned in this ESG Policy.

We have developed internal standards and information management systems for operationalizing compliance with this ESG Policy and monitoring progress. Such standards and systems update from time to time to make it consistent with global standards and prevailing regulations.

We comply with all applicable statutory laws, rules, and regulations including NGRBC read with the Companies Act, 2013 and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. We maintain records of all licenses, permits and approvals, necessary for conduct of the business.

As Manufacturing & Trading of Iron & Steel Products, we are committed to positively impact the environment, our customers, employees, and the community at large. At OCL Iron & Steels Limited, ESG initiatives and principles are aligned with our CSR initiatives which would complement with our strategic goals in terms of services we seek to offer all our stakeholders. The ESG policy framework will serve as a guiding document for all CSR initiatives and other operational activities undertaken by us and will be integrated to the operations of our subsidiaries and associates across the globe.

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

• The Company believes in value-based governance and practices. It is committed to maintain the highest standards of ethics in all spheres of its business activities. The board of directors and senior management has a responsibility to set exemplary standards of ethical behavior, both internally within the organization, as well as in their external relationships. Management constantly endeavors to inculcate this ethical behavior at all levels in the organization so that it becomes an essential part of the work culture among all the employees. Every employee of the Company is obligated to conduct himself/ herself and deal on behalf of the Company with professionalism, honesty and integrity, while conforming to high moral and ethical standards.
• The Company strives hard to ensure that all business decisions and transactions are fair, transparent, amenable to disclosure and be visible to relevant stakeholders.
• Empowerment is an essential component of the Company’s principle of governance, which provides the management, freedom to take the enterprise forward. Empowerment unleashes creativity and innovation throughout the organization by truly vesting decision-making powers at the most appropriate levels in an organizational hierarchy.
• We are committed to protecting the integrity and privacy of data through robust cybersecurity systems and internal safeguards, as far as practically possible.

Principle II - Businesses should provide goods and services in a manner that is sustainable and safe.

• The Company is committed to continuously improve its safety, sustainability and goods and services by engaging:
• Sustainable products and services that generate measurable social or environmental benefits.
• The goods and services that does not deplete resources.
• The goods and services which safeguard water, energy, less generation of waste at various stages of handling.
• Promotion of environmental and safety awareness among all the employees, vendors and contractors.
• We use such equipment(s) and measure(s) during transfer(s) which reduces the wastage of natural resource(s) and allows us to follow our commitments, in spirit.

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

• The Company is committed to continue to take steps to promote a safe and conducive work environment for its employees and provides guidance on occupational health and safety, appropriate healthcare benefits and medical cover to all its employees.
• The Company respects the employees’ right to freedom of association, participation and collective bargaining. Employees at all levels shall have freedom of association and be free to participate in collective bargaining through their recognized unions/ associations. The Company has adequate grievance redressal mechanisms in place.
• The Company provides a workplace environment that is safe, hygienic, humane, and comfortable which upholds the dignity of the employees. It provides facilities for the well-being of its employees including those with special needs. The Company complies with all statutory provisions with regard to health, safety and well-being of its employees. Specific provisions contained in the applicable labor laws for ensuring health, safety, hygiene, comforts and well-being of employees are observed in letter and spirit.
• The Company liaise with only such third-party stakeholders, as far as practically possible, who provide certified personal protection equipment (PPE) that includes hard mining helmets with light-emitting diode (LED) lights, footwear, protective clothing, breathing apparatus, ventilators and self-rescuers to safeguard the workers from occupational hazards.
• The Company liaise with only such third-party stakeholders, as far as practically possible, who employ mining safety equipment(s) which includes plant and machinery such as underground communication and monitoring systems, mining radios and telephones, hazard detection devices such as proximity warning systems and gas detection units, fire protection apparatus, collision avoidance technology and powered haulage safety systems, atmospheric monitoring, air safety devices and good health practices at the work sites.
• The Company provides and maintains equal opportunities at the time of recruitment as well as during the course of employment irrespective of caste, creed, gender, race, religion, disability or sexual orientation. We have created systems and practices to ensure a harassment free workplace where employees feel safe and secure in discharging their responsibilities.

Principle IV - Businesses should respect the interests of and be responsive to all its stakeholders.

• The Company values the support of its stakeholders and respect their interests and concerns. We provide value-based services to the stakeholders.
• We have continuous engagement with our various stakeholders to understand their concerns and assess their requirements and respond to their needs in an effective manner. Resolution of differences with the stakeholders is done in a just, fair and equitable manner.
• The Company proactively engages with and responds to those sections in the society that are disadvantaged, vulnerable and marginalized. We also give special attention to stakeholders in areas that are underdeveloped.

Principle V - Businesses should respect and promote human rights.

• The Company recognizes and respects the human rights of all relevant stakeholders and groups within and beyond the workplace, including that of communities, consumers and vulnerable and marginalized groups.
• The Company within its sphere of influence promotes awareness and realization of human rights across its value chain.

Principle VI - Businesses should respect and make efforts to protect and restore the environment.

• Climate change and environmental sustainability present challenges and opportunities for the Company and our stakeholders. To address these, the Company is committed to incorporating leading environmental practices into its business strategy and operations and fostering environmental awareness and responsibility among our people, clients, suppliers, and other interested parties within the context of our business. The Company is committed to achieve the economic, ecological and social responsibility objectives of sustainable development through its varied business operations and activities.
• The Company complies with all legal/ regulatory requirements related to environment protection, management and sustainable development. We have regular monitoring programs to assess our performance of environment management and sustainable development. The Company identifies hazardous process, assess its risk and determine appropriate control measures to minimize the impact on environment.
• We have dedicated acreage of green belt(s) around our manufacturing facility to reduce our carbon footprint and foster environmental value.
• We commit ourselves to take all necessary initiatives towards optimization and zero (0) wastage utilization of natural resources.

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

• As a corporate citizen, the Company understands its responsibility to function within the democratic set up and the constitutional framework. It recognizes that businesses operate within the specified legislative and policy frameworks prescribed by the Government, which guides growth and also provide for certain desirable restrictions and boundaries. The Company and its employees respect the legal/ regulatory framework and complies with all the applicable provisions of existing local, state, national, and international laws.

Principle VIII - Businesses should promote inclusive growth and equitable development.

• The Company ensures that it takes appropriate actions to minimize any adverse impacts that it has on social, cultural and economic aspects of society including arising from land acquisition and use, construction of facilities and operations.
• We make efforts to minimize the negative impacts of displacement of people and disruption of livelihoods through our business operations and where displacement is unavoidable, the Company undertakes the process in a humane, participative, informed and transparent manner, where just and fair compensation is paid to those impacted.

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

• We provide information and guidance to the consumers on, safe and responsible usage and disposal of their products (including reuse and recycling), and to eliminate over-consumption.

We are committed to embedding the principles of ESG into our operations, business facilities and value chain by continuously engaging with our stakeholders. We encourage the adoption of eco-friendly practices to maintain the functioning of a sustainable supply chain. We assess and adopt clean technologies, promoting a balance of risk, capital cost and quality. We strive to minimize our environmental footprint by setting relevant targets and address climate change by transitioning to resource neutral operations. We embrace digitization to unlock value. We strive to minimize the environmental impacts of our products, transport and logistics services. We seek to improve process efficiencies to reduce waste generation and partner with vendors who also outline same values to accelerate the transition to improve output quality. We endeavor to prioritize responsible business conduct to build stronger relationships with our stakeholders, including customers, employees, investors, and the community.