Business Responsibility Policy

1. INTRODUCTION
   

   The Securities and Exchange Board of India (SEBI) had notified the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”) which are applicable to all listed entities with effect from 1stDecember, 2015.

   SEBI had, vide circular dated 13th August, 2012, mandated Business Responsibility Reporting (BRR) requirement for top 100 listed entities in their annual reports, which was extended to cover top 500 listed entities vide SEBI Circular No. SEBI/LAD-NRO/GN/2015-16/27, dated 22ndDecember, 2015 and further expanded the ambit to cover top 1000 listed entities vide SEBI Circular No. SEBI/LAD-NRO/GN/GN/2019/45 dated 26th December, 2019.

   As per Regulation 34(2)(f) of the Listing Regulations, annual report of listed entities (top 1000 listed entities based on market capitalization calculated as on 31stMarch of every year) shall contain, Business Responsibility Report (BRR) describing the initiatives taken by them from a social, environmental and economic perspective, in the format as specified by the Board.

   The business responsibility reporting requirement is in line with “National Voluntary Guidelines (NVGs) on Social, Environmental and Economic Responsibilities of Business” notified by Ministry of Corporate Affairs, Government of India, in July 2011. The key principles identified in the NVGs which are required to be reported by the entities include the areas such as environment, social governance, stakeholder’s relationships, etc.

2. OBJECTIVE

   The objective of this document is to enunciate a policy on Business Responsibility to fulfill SEBI requirement for Business Responsibility Reporting.

3. APPLICABILITY
   

   Based on the list of top 1000 listed entities based on market capitalization as on March 31, 2020, Savita Oil Technologies Limited (“SOTL” or “Company”) is covered under the same and hence, the Company is required to formulate policy on business responsibility reporting, which shall be forthwith implemented and the compliance of the same shall be reported in the ensuing Annual Report.

   This policy shall be applicable to the Company with effect from the date of approval by the Board of the Company.

4. IMPLEMENTATION
   

   While the Managing Director of the Company shall be the Head for Business Responsibility,he along with the Company Secretaryshall jointly and severally be responsible for implementing the Business Responsibility Policy of the Company.

   The Business Responsibility Policy shall be appropriately communicated within the Company across all levels and shall be displayed on the Company’s website. Compliance with the Policy shall be monitored and evaluated on regular basis. Respective Functional Heads will formulate action plan / checklist to ensure compliances of the various principles enunciated in the Business Responsibility Policy. Any grievances / complaints with respect to non-compliance with the Policy shall be reported to the Managing Director or the Company Secretary.

5. BOARD APPROVAL

   The Business Responsibility Policy has been formulated by the Management of the Company in consultation with the relevant stakeholders and hasbeen approved by the Board of Directors of the Company at its Board Meeting held on 4th February, 2021.

6. POLICY AMENDMENTS

   Any subsequent amendment / modification in the Listing Regulations, NVGs and / or other laws in this regard shall automatically apply to this Policy. The same shall be added / amended / modified from time to time as authorized by the Board of Directors.

   The Managing Director is authorized to amend or modify the Business Responsibility Policy, in whole or in part, from time to time.

Principle 1: Ethics, Transparency & Accountability

SOTL is committed to conduct its business in accordance with the applicable laws, rules and regulations and with highest standards of business ethics. The Company has in place the Code of Conduct (“Code”) for its Directors and Senior Management Personnel and their confirmations to the Code is obtained by the Company on periodical basis.

This Policy is intended to provide guidance and help in recognizing and dealing with ethical issues, provide mechanisms to report unethical conduct, and to help foster a culture of honesty and accountability. The objective is to ensure the highest standards of ethical conduct, transparency and accountability while dealing with the stakeholders.

Policy

1. The Company will follow its governance structures, practices and procedures that ensure ethical conduct at all levels and promote the adoption of these principles across its value chain.
2. The Company will endeavour transparent communication with its stakeholders and assure access to information relating to decisions that impact the stakeholders.
3. The Company will not engage in practices that are abusive, corrupt, or anti-competition.
4. The Company will truthfully discharge its responsibility on financial and other mandatory disclosures.
5. The Company shall avoid complicity with the actions of any third party that violates any of the principles contained in the SEBI Guidelines.
6. The Company shall ensure that genuine concerns of misconduct/ unlawful conduct can be reported in a responsible and confidential manner through its Vigil Mechanism.

Principle 2: Product Lifecycle Sustainability

SOTL has intertwined the principles of safety and sustainability into its processes and products throughout its lifecycle which covers various stages beginning from procurement of raw material, product design and manufacturing till its delivery to the customers.

Policy

As a part of the Policy on Product Lifecycle Sustainability, SOTL will –

1. Work towards safe and optimal use of resources over the life-cycle of its products and services, including recycling of resources wherever possible.
2. Take appropriate steps to raise the consumer's awareness of their rights through education, product labelling, appropriate and helpful marketing communication, full details of contents and composition and promotion of safe usage and disposal of its products and services.
3. Ensure that the manufacturing processes and technologies required to produce its products are resource efficient and sustainable.
4. Regularly review and improve upon the process of new technology development, deployment and commercialization, incorporating social, ethical, and environmental considerations.
5. Recognize and respect the rights of people who may be owners of traditional knowledge, and other forms of intellectual property.
6. Recognize that over-consumption results in unsustainable exploitation of our planet's resources, and should therefore, promote sustainable consumption, including recycling of resources.
7. Ensure compliance with the applicable laws with respect to product manufacturing and sales.

Principle 3: Employee Well Being

SOTL is committed to professional development and growth of employees through selecting the right candidates for right jobs, monitoring performance for optimum utilization of their potential, providing growth opportunities and inculcating the culture of mutual faith and accountability. SOTL is also committed to the holistic growth of employees by motivating them to perform at the peak of their potential by imparting necessary guidance and training at all levels and providing them with opportunities for enhancing their knowledge and honing their skills.

The policies, procedures and practices in the Company are aligned to meet employees’ well-being, diversity, non-discrimination, safety and health so as to have a healthy, cordial and harmonious relationships and value enhancement at all levels.

Policy

1. The Company shall provide and maintain 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.
2. The Company shall respect the right to freedom of association, participation, collective bargaining, and provide access to appropriate grievance redressal mechanisms.
3. The Company shall not use child labour, forced labour or any form of involuntary labour, paid or unpaid.
4. The Company shall ensure that no employee is made to work against his / her will or to work as bonded/forced labour or subjected to corporal punishment or coercion of any kind, related to work.
5. The Company shall provide a work environment that is free from any form of discrimination, exploitation and harassment including but not limited to sexual harassment.
6. The Company shall create systems and practices to ensure a harassment free workplace where employees feel safe and secure in discharging their responsibilities.
7. The Company shall strive to instil a sense of duty in every employee including those of service providers at the Company's premises, towards their personal safety, as well as that of their co-workers.
8. The Company shall strive to take cognizance of the work-life balance of its employees, especially that of women.
9. The Company shall strive to provide facilities for the wellbeing of its employees including those with special needs.
10. The Company shall ensure timely payment of fair living wages to meet basic needs and economic security of the employees.
11. The Company shall provide a workplace environment that is safe, hygienic humane, and which upholds the dignity of the employees.
12. The Company shall ensure continuous skill and competence upgrading of all employees by providing access to necessary learning opportunities, on an equal and non-discriminatory basis.
13. The Company shall promote employee morale and career development through enlightened human resource interventions.

Principle 4: Stakeholder Engagement

SOTL gives utmost importance to the healthy engagement with its various stakeholders like employees, suppliers, stockists, dealers, customers, shareholders / investors, communities surrounding the operations and government / regulatory authorities. The Company continues its engagement with them through various mechanisms such as supplier/vendor meets, customer/employee satisfaction surveys, investor forums, consultations with local communities etc.

Policy

1. The Company shall understand the concerns of its stakeholders, define its purpose and scope of engagement, and commit to engaging with them.
2. The Company shall acknowledge, assume responsibility and be transparent about the impact of its policies, decisions, products& services and associated operations on the stakeholders.
3. The Company shall strive to give special attention to stakeholders in areas that are underdeveloped.
4. The Company shall resolve differences with stakeholders in a just, fair and equitable manner.

Principle 5: Human Rights

SOTL believes that human rights are fundamental, inherent, universal, indivisible and interdependent in nature and hence, continuously strives to ensure that employees’ basic human rights are protected.

Policy

1. The Company will observe that basic human rights of the employees are respected, valued and protected keeping in mind the Constitution of India, Laws, Policies and the International Bill of Human Rights and accordingly, formulate all policies, practices, procedures and rules of the Company.
2. The Company shall integrate respect for human rights in management systems, in particular through assessing and managing human rights impacts of operations, and ensuring all individuals impacted by the business have access to grievance mechanisms.
3. The Company recognizes and respects the human rights of all relevant stakeholders and groups, including that of communities, consumers and vulnerable and marginalized groups.
4. The Company shall, within its sphere of influence, promote the awareness and realization of human rights across its value chain.
5. The Company shall encourage its business partners and third parties with whom it conducts business to abide by this policy.
6. The Company will ensure that each employee is made aware of his/her basic rights and redressal mechanisms.

Principle 6: Environment Protection

SOTL is committed to safety and preservation of environment and has formulated “Quality, Health, Safety and Environment Policy”. SOTL also believes in conservation of natural resources and minimizing hazardous impact on the ecological environment.

Policy

1. The Company shall utilize natural and manmade resources in an optimal and responsible manner and ensure the sustainability of resources by reducing, reusing, recycling and managing waste.
2. The Company shall take measures to check and prevent pollution. The Company shall endeavour to assess the environmental damage and bear the cost of pollution abatement with due regard to public interest.
3. The Company shall ensure that benefits arising out of access and commercialization of biological and other natural resources and associated traditional knowledge are shared equitably.
4. The Company shall continuously seek to improve its environmental performance by adopting cleaner production methods, promoting use of energy efficient and environment friendly technologies and use of renewable energy.
5. The Company shall develop Environment Management Systems and contingency plans and processes that shall help it in preventing, mitigating and controlling environmental damages and disasters, which may be caused due to its operations.
6. The Company shall strive to report its environmental performance, including the assessment of potential environmental risks associated with its operations, to the stakeholders, in a fair and transparent manner.
7. The Company shall proactively persuade and support its value chain to adopt these principles.

Principle 7: Responsible Advocacy

SOTL believes that to protect overall interest of its business and the diverse stakeholders, the Company has to express its fair views, opinions, representations, concerns etc on the policies framed by the competent authorities. The Company, may either itself or through various association/forums/chambers make such representations etc before the competent authorities. The Company’s engagement with the relevant association/forums/chambers etc is guided by the values of commitment, integrity, transparency and the need to balance interests of diverse stakeholders.

Policy

1. The Company will make reasonable efforts to ensure that its advocacy positions are consistent with the principles and core elements enhancing business responsibility and transparency.
2. The Company may, in the best interest of all stakeholders, provide inputs in policy making decisions to various governmental authorities and agencies which concern the business and the society in general, either directly or through the trade and industry chambers and such other collective platforms.

Principle 8: Inclusive Growth and Equitable Development

SOTL’s philosophy for delineating its responsibility as a corporate citizen is covered through its CSR policy which encompasses guidelines and mechanism for undertaking socially relevant programs for welfare and sustainable development of the community at large. The Company has in place a Corporate Social Responsibility Policy framed as per the provisions of Section 135 of the Companies Act, 2013 and the Companies (Corporate Social Responsibility) Rules, 2014 and has been contributing towards various CSR activities in accordance with the Schedule VII to the Companies Act, 2013.

Policy

SOTL’s core principles for inclusive growth and equitable development are –

1. Identification of the impact of the Company’s operations on social and economic development and to minimize the negative impacts, if any on the same.
2. Innovation and investment in products, technologies and processes on continuous basis for the overall wellbeing of the society.
3. The Company endeavours to undertake various community development activities at local and national level and to ensure that appropriate mechanism for resettlement and rehabilitation of communities which have been displaced if any due to business operations are in place.
4. The Company will endeavour to give priority to the regions that are underdeveloped near the business operations of the Company.

Principle 9: Customer Value

SOTL appreciates that customers are one of the most important stakeholders. The foundation of the Company is based on trust, satisfaction and loyalty of its consumers across the world. The Company’s products are petroleum specialty products and hence, it continuously strives to make available its products that are safe and competitively priced for the benefits of its customers / end users.

Policy

SOTL’s policy to enhance customer value and satisfaction covers –

1. The Company, while serving the needs of its customers, will take into account the overall well-being of the customers and that of society.
2. The Company will ensure that it does not restrict the freedom of choice and free competition in any manner while designing, promoting and selling its products.
3. The Company will disclose wherever and to whatever extent applicable and possible, all information truthfully and factually, through labelling and other means, including the risks to individuals, to society and to the planet from the use of the products, so that the customers can exercise their freedom to use them in a responsible manner. Where required, the Company shall also educate its customers on the safe and responsible usage of its products and services.
4. The Company will promote and advertise its products in ways that do not mislead or confuse the consumers or violate any of these Principles.
5. The Company will exercise due care and caution while providing goods and services that result in over exploitation of natural resources or lead to excessive conspicuous consumption.
6. The Company will provide adequate grievance handling mechanisms to address customer concerns and feedback.

Place – Mumbai
Approval date – 4th February, 2021