Management and Process Disclosures

Section B: Management and Process Disclosures

Sl. No. Disclosure Questions P1 P2 P3 P4 P5 P6 P7 P8 P9


Ethical & Transparent business conduct





Sustainable and safe goods





Well-being of Employees





Interest of Stakeholders





Promote
Human rights





Protect & Restore Environment





Public Policy Advocacy





Diversity & Inclusion





Value to
Consumers



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, the company has policies which are relevant to NGRBC principles.
b. Has the policy been approved by the Board? (Yes/No) Yes, all the policies are approved by Board
c. Web Link of the Policies, if available Company policies are available on Schaeffler india official website, https://www.schaeffler.co.in/en/investor-relations/corporate-governance/codes-and-policies/. Also some policies & internal documents are available on company Intranet page.
2. Whether the entity has translated the policy into procedures. (Yes/No) Yes, all the policies are translated into procedures.
3. Do the enlisted policies extend to your value chain partners? (Yes/No) Yes, we have Supplier code of conduct & sustainability target agreement (Internal document) applicable to suppliers
4. Name of the national and international codes/certifications/labels/standards (e.g. Forest Stewardship Council, Fairtrade, Rainforest Alliance, Trustee) standards (e.g. SA 8000, OHSAS, ISO, BIS) adopted by your entity and mapped to each principle. ISO 9001:2015
IATF 16949
ISO/TS
22163:2017
Quality Assurance programme certification		 ISO 9001:2015
IATF 16949
ISO/TS
22163:2017
ISO
14001:2015
ISO
45001:2018
BIS series 		LKSG
ILO
Convention
ISO
45001:2018 		ISO
9001:2015
IATF 16949
TISAX
BIS series 		LKSG
ILO Convention
ISO
45001:2018 		ISO 45001:2018
ISO 14001:2015
ISO 50001:2018
EU-EMAS 		BIS Specifications LKSG
ILO
Convention 		ISO 9001:2015
IATF 16949
Quality Assurance programm certification ISO/TS
22163:2017
TISAX
BIS series
5. Specific commitments, goals and targets set by the entity with defined timelines, if any. Details are available on Page 52
6. Performance of the entity against the specific commitments, goals and targets along-with reasons in case the same are not met. We have process of monitoring ESG performance to track deviations on time. We conduct regular quarterly reviews with the Board of Directors, in which we discuss our ESG performance, make changes in our strategy required if any. Also, Monthly reviews are conducted at the plants by Plant heads. Details about progress so far on our targets is available on page 52 of our Annual report.
P1 Businesses should conduct and govern themselves with integrity, and in a manner that is Ethical, Transparent and Accountable.
1. Code of Conduct for Directors, Senior Management & Employees
2. Code on Prohibition of Insider Trading
3. Dividend Distribution Policy
4. Policy on Determination of Material Subsidiary
5. Policy on Determination of Materiality for Disclosure of Events or Information 		6. Related Party Transactions Policy
7. Vigil Mechanism or Whistle Blower Policy
8. Internal Audit Charter
9. Business Integrity Compliance (Internal Policy)
10. ESG Group policy (Internal doc.)
P2 Businesses should provide goods and services in a manner that is sustainable and safe
1. The Schaeffler Supplier Code of Conduct (Internal policy Document)
2. Sustainability target agreement (Internal doc.)
3. EHS policy (Internal Document)
4. Human right policy (Internal Document)
5. Code of Conduct for Directors, Senior Management & Employees
6. ESG Group policy (Internal doc.)
P3 Businesses should respect and promote the well-being of all employees, including those in their value chains
1. Nomination and Remuneration Policy
2. Policy against Sexual Harassment
3. Vigil Mechanism or Whistle Blower Policy
4. The Schaeffler Supplier Code of Conduct (Internal policy Document) 		5. Human right policy (Internal Document)
6. Car policy, Parental policy, workman leave policy, Employee death benefit
Policy Etc. (All are internal policies available on company intranet)
7. ESG Group policy(Internal doc.)
P4 Businesses should respect the interests of and be responsive to all its stakeholders
1. Divided distribution policy
2. Code on Prohibition of Insider Trading
3. Policy on Determination of Materiality for Disclosure of Events or Information
4. Related Party Transactions Policy
5. Business Integrity Compliance (Internal Policy)
P5 Businesses should respect and promote human rights
1. Code of Conduct for Directors, Senior Management & Employees
2. Human Rights group policy (Internal Document)
3. Nomination and Remuneration Policy
4. The Schaeffler Supplier Code of Conduct (Internal policy Document)
5. EHS policy (Internal Document)
6. ESG Group policy (Internal doc.)
P5 Businesses should respect and promote human rights
1. Code of Conduct for Directors, Senior Management & Employees
2. Human Rights group policy (Internal Document)
3. Nomination and Remuneration Policy
4. The Schaeffler Supplier Code of Conduct (Internal policy Document)
5. EHS policy (Internal Document)
6. ESG Group policy (Internal doc.)
P6 Businesses should respect and make efforts to protect and restore the environment
1. EHS policy (Internal Document)
2. Environmental Protection and Company Security (Group Policy)
3. Sustainability target agreement (Internal Document)
4. Risk Management Policy 		5. Policy for Preservation of Documents & Archival of Information
6. Emergency Planning 172930 – 172949 (Group) (Internal Document)
7. ESG Group policy(Internal doc.)
P7 Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent
1. Code of Conduct for Directors, Senior Management & Employees 2. Business Integrity Compliance (Internal Policy)
P8 Businesses should promote inclusive growth and equitable development
1. Corporate Social Responsibility Policy
2. The Schaeffler Supplier Code of Conduct (Internal policy) 		3. Human right Group policy (Internal Document)
P9 Businesses should engage with and provide value to their consumers in a responsible manner
1. Cyber security policy
2. Code of Conduct for Directors, Senior Management & Employees 		3. Internal Audit Charter
4. Quality Policy (Group, Internal policy)
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)
A statement from the Chairman, please refer page 28.
8.
Details of the highest authority responsible for implementation and oversight of the Business Responsibility policy (ies).
Name of highest authority : Mr. Harsha Kadam
Designation : MD & CEO
DIN : 07736005
Category : E & NID
9.
Does the entity have a specified Committee of the Board/Director responsible for decision making on sustainability related issues? (Yes/No). If yes, provide details

The company has a structured “Sustainability Network” organisation to set targets, review and follow up actions in defined areas of ESG. Sustainability Network is overseen with six pillars in responsibility of Executive Management Leaders.

Six pillars – Strategy, Sustainable purchasing, Sustainable production, Sustainable products, Sustainability reporting, People and Culture

The network is responsible for reviewing, monitoring, and discussing key sustainability performance indicators and defining strategy and action plans to achieve them. Team ensures Schaeffler standards, and stakeholders’ expectations are fulfilled. Quarterly reviews in Board meeting, are conducted where ESG performance are discussed & suitable changes are made in our strategy if required.

In addition, we have various Board committees, which are responsible for and takes decisions on sustainability related issues.

  1. The Risk Management Committee: The RMC Committee formulated a detailed Risk Management Policy covering the framework for identification of internal and external risks specifically faced by the Company, in particular including financial, operational, sectoral, sustainability (particularly, ESG related risks), information, cyber security risks or any other risk as may be determined by the Committee, Measures for risk mitigation including systems and processes for internal control of identified risks, Business continuity plan. The RMC Committee ensures that appropriate methodology processes and systems are in place to monitor and evaluate risks associated with the business of the Company.
  2. The Corporate Social Responsibility (CSR) Committee: The CSR Committee defines the focus areas and indicate the activities to be undertaken by the company under CSR domain. CSR Committee formulate the Annual action Plan, monitor the budget under the CSR activities of the Company. CSR committee reviews status of the projects taken towards social cause & further gives directions to uplift the life of the community surrounding, which contributes for sustainability.

10. Details of Review of NGRBCs by the Company:

Subject for review Indicate whether review was undertaken by Director/Committee of the Board/Any other Committee
P1 P2 P3 P4 P5 P6 P7 P8 P9
Performance against above policies and follow up action

Compliance with statutory requirements of relevance to the principles, and, rectification of any non-compliances 		Yes, Done by Executive management, relevant committee & Board
Subject for review Frequency
P1 P2 P3 P4 P5 P6 P7 P8 P9
Performance against above policies and follow up action

Compliance with statutory requirements of relevance to the principles, and, rectification of any non-compliances 		Periodic reviews by relevant executive management for six pillars & Quarterly by Relevant committee & Board

11. Has the entity carried out independent assessment/ evaluation of the working of its policies by an external agency? (Yes/No). If yes, provide name of the agency.

Yes, an assurance engagement was carried out by BDO AG to provide assurance about design, implementation and operating effectiveness of Compliance Management System on topics anti corruption, anti-trust and prevention of economic crime. During the EHS audits, as part of the requirements of ISO standards, EHS policy is assessed/evaluated & suitable review is undertaken if required. Independent external agencies Ms. EMAS and Ms. Intechnica are conducting our EHS & energy management systems audits. Also, we have robust internal audit process which carry out a detailed examination of policies & procedures and regulatory requirements. As a part of process, report on the status of compliance is submitted to Board on a regular basis. To comply with best practices and mitigate risks, policies are reviewed and revised periodically by various business leaders, and then approved by the management/Board.

12. If answer to question (1) above is “No” i.e. not all Principles are covered by a policy, reasons to be stated:

The entity does not consider the Principles material to its business (Yes/No) Answer to question (1) above is “Yes”, hence this question is Not Applicable
The entity is not at a stage where it is in a position to formulate and implement the policies on specified principles (Yes/No)
The entity does not have the financial or/human and technical resources available for the task (Yes/No)
It is planned to be done in the next financial year (Yes/No)
Any other reason (please specify)