PRINCIPLE 1 
PRINCIPLE 1
1. Percentage coverage by training and awareness programmes on any of the Principles during the financial year:
| Segment | Total number of training and awareness programmes held | Topics/principles covered under the training and its impact | %age of persons in respective category covered by the awareness programmes |
|---|---|---|---|
| Board of Directors | 2 | Integrity & Security @ Schaeffler | 100% |
| Review of Financial, Business and Operational Performance of the Company, ESG update | 100% | ||
| Key Managerial Personnel | 4 | Review of Financial, Business and Operational Performance of the Company, ESG update | 100% |
| Integrity & Security @ Schaeffler | 99% | ||
| Preventing Bribery & Corruption (PBAC) | 100% | ||
| New Compliance WBT “Antitrust Compliance” | 100% | ||
| Employees other than BoD and KMPs | 7 | Integrity & Security @ Schaeffler | 99% |
| Preventing Bribery & Corruption (PBAC) (For new joiners) | 100% | ||
| New Compliance WBT “Antitrust Compliance” (For new joiners) | 100% | ||
| New Hire Integration (For new joiners) | 93% | ||
| Prevention of Sexual Harassment (POSH) at Workplace | 90% | ||
| Product Safety Awareness Training | 95% | ||
| Sustainability Roadmap | 94% | ||
| Workers | 1 | Safety Induction, Basic EHS trainings, Safety DOJO for Shop floor employees, Shop floors rules and standard works, machine safety, fire protection, first aid, environment protection etc Prevention of Sexual Harassment (POSH) at Workplace | 100% |
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):
| Monetary | ||||
|---|---|---|---|---|
| NGRBC Principle | Name of the regulatory/ enforcement agencies/ judicial institutions | Amount (In INR) | Brief of the Case | Has an appeal been preferred? (Yes/No) |
| Penalty/Fine | During the year, there were no 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 accordance with the materiality as specified in Regulation 30 of SEBI (Listing Obligations and Disclosure Obligations) Regulations, 2015. | |||
| Settlement | ||||
| Compounding fee | ||||
| Non-Monetary | ||||
| NGRBC Principle | Name of the regulatory/enforcement agencies/ judicial institutions | Brief of the Case | Brief of the Case | Has an appeal been preferred? (Yes/No) |
| Imprisonment | During the year, there were no imprisonment/punishments against any Directors/KMP | |||
| Punishment | ||||
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.
| Case Details | Name of the regulatory/enforcement agencies/judicial institutions |
|---|---|
| Not applicable – As during the year, there were no fines/penalties/punishment/imprisonment/award/compounding fees settlement amount paid in proceedings (by the entity or by directors/KMPs) with regulators/law enforcement agencies/judicial institutions in accordance with the materiality as specified in Regulation 30 of SEBI (Listing Obligations and Disclosure Obligations) Regulations, 2015 | |
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.
Yes
Business practices of Schaeffler are based on the principles of mutual respect, integrity and fairness which are defined
in Schaeffler Group Code of Conduct, which is available on Schaeffler India website. Clause 2.2 of the Code of Conduct
provides guidance on corruption and bribery. The values and principles of code of conduct are implemented while
designing the policy of business integrity compliance policy of Schaeffler. Schaeffler India has a policy of business
integrity compliance (Internal policy doc.) This policy provides binding instructions on business integrity, particularly
in the compliance risk areas of corruption and bribery, conflicts of interest, and money laundering and financing of
terrorism to reduce the risk of respective violations of the law. Schaeffler also has a separate Code of Conduct for
Directors, Senior Management & Employees (refer: CoC of Directors, Senior Management & Employees) and Suppliers
Code of Conduct (refer: COC_ Suppliers). The relevant policies can be accessed through the web link provided. The
Company also creates awareness about the policy to all its employees, vendors and supply chain partners through
physical/virtual training sessions, e-modules Etc. Following are links
Coc of directors, senior management & employees
Code of conduct of supplier
Group code of conduct
In addition to this Business practices @ Schaeffler follows Anti-Corruption Guidelines (available for employees on
Schaeffler intranet) which defines: rules for:
5. Number of Directors/KMPs/employees/workers against whom disciplinary action was taken by any law enforcement agency for the charges of bribery/corruption:
| FY 2023 | FY 2022 | |
|---|---|---|
| Directors | Nil | Nil |
| KMPs | Nil | Nil |
| Employees | Nil | Nil |
| Workers | Nil | Nil |
6. Details of complaints with regard to conflict of interest:
| FY 2023 | FY 2022 | |||
|---|---|---|---|---|
| Number | Remark | Number | Remark | |
| Number of complaints received in relation to issues of Conflict of Interest of the Directors | 0 | No Conflict of Interest incidents were reported against Directors. |
0 | No Conflict of Interest incidents were reported against Directors. |
| Number of complaints received in relation to issues of Conflict of Interest of the KMPs | 0 |
No Conflict of Interest incidents were reported against KMPs |
0 | No Conflict of Interest incidents were reported against KMPs |
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, as we do not have any instances of corruption/conflicts of interest against Directors and KMPs.
1. Awareness programmes conducted for value chain partners on any of the Principles during the financial year:
| Total number of awareness programmes held | Topics/principles covered under the training | %age of value chain partners covered (by value of business done with such partners) under the awareness programmes |
|---|---|---|
| 1 | Supply Chain digitalisation (SupplyOn implementation – Sourcing Module, Web EDI, ASN, GTL, Performance Monitor) |
90% |
| 1 | Schaeffler Supplier Sustainability (Carbon emission management and targets, Environmental management certification, Occupational health and safety certification, SAQ and Sustainability Target agreement) | 89% * |
* Self-Assessment (SAQ) by supplier
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
All directors and employees are governed by Schaeffler Code of Conduct which includes Conflict of interest (COI).
Conflict of interest should be avoided & if it is unavoidable it must be disclosed to the Board of Directors to find a
solution that will protect the Company’s interests.
COI declaration are taken from the Board members on a periodic basis. Adequate resolution is agreed about the
declared conflict and documented. Following are links