Rekha Surendh Iran: Stock Code: 513375
Rekha Surendh Iran: Stock Code: 513375
BSE Limited
1st Floor, New Trading Ring
Rotunda Building, P J Towers
Dalal Street, Fort Stock Code: 513375
Mumbai 400 001
Dear Sir/Madam,
Thanking you.
Yours faithfully,
For Carborundum Universal Limited
REKHA REKHA
SURENDH SURENDHIRAN
2023.07.11
IRAN 23:16:40 +05'30'
Rekha Surendhiran
Company Secretary
Management Reports
ANNEXURE C
BUSINESS RESPONSIBILITY AND SUSTAINABILITY REPORT (BRSR)
II. Products/services
15. Products/Services sold by the entity (accounting for 90% of the entity’s Turnover)
S.No. Products/Services NIC Code % of total Turnover contributed
1 Abrasives 23993 44.62
2 Electrominerals 729 21.73
3 Ceramics 23939 33.65
III. Operations
16. Number of locations where plants and/or operations/offices of the entity are situated
Location Number of locations where plants and/or operations/ Number of Total
offices of the entity are situated offices
National 20 13 33
International Nil Nil Nil
Note 1: The list of Subsidiary and Associate Companies in India and outside the Country is given in the questionnaire Sl. No. 21 of this
report. This report is made on a standalone basis (i.e. only for the entity) and only contains information related to the entity.
Note 2: The environmental data presented in this report only represents consolidated data from 20 plants in India. Human resource
and social data cover the whole entity data (i.e. 20 plants and 13 office locations).
b. What is the contribution of exports as a Percentage of the total turnover of the entity?
Total turnover contribution from exports is 26%.
c. A brief on types of customers
The Company caters to a diverse range of customers across various industries, including Iron & steel, Bearing, Automotive, Auto
OEM, Metalworking, Construction, Aerospace, Railways, General engineering, Cement, Mineral processing, Coal, Pharmaceuticals,
and Food Processing. In addition, the Company serves both retail and industrial customers through a distribution channel across India.
The Company sells its products through multiple channels, including distributors, direct sales, and digital marketing.
IV. Employees
Note: We have employed differently-abled workers in our IC Hosur, Abrasives - Tiruvottiyur & Hosur. Our office space is equipped with
elevators, accessible restrooms, and adjustable chairs to accommodate employees with disabilities. In addition, the majority of our
plants also have facilities in place to support employees with disabilities.
S.No. Name of the holding/subsidiary/associate Indicate whether % of shares Does the entity indicated
companies/joint ventures (A) holding/Subsidiary/ held by at column A, participate in
Associate/Joint listed entity the Business Responsibility
Venture initiatives of the listed entity?
(Yes/No)
1 Net Access India Limited Subsidiary 100 No
2 Southern Energy Development Corporation Limited Subsidiary 84.76 No
3 Pluss Advanced Technologies Limited Subsidiary 72.73 No
4 Sterling Abrasives Limited Subsidiary 60 No
5 Cumi (Australia) Pty Limited Subsidiary 51.22 No
6 Cumi International Limited Subsidiary 100 No
7 Volzhsky Abrasive Works Subsidiary 98.07 No
8 Foskor Zirconia (Pty) Limited Subsidiary 51 No
9 Cumi America Inc. Subsidiary 100 No
10 Cumi Middle East FZE Subsidiary 100 No
11 Cumi Abrasives & Ceramics Company Limited Subsidiary 100 No
12 Cumi Europe s.r.o Subsidiary 100 No
13 Cumi Awuko Abrasives GmbH Subsidiary 100 No
14 Rhodius Abrasives GmbH Subsidiary 100 No
15 Pluss Advanced Technologies B.V., Netherlands Subsidiary 72.73 No
Rhodius Schleifwerkzeuge Verwaltungsgesellschaft
16 Subsidiary 100 No
Mbh
17 Rhodius Nederland B.V Subsidiary 100 No
18 Rhodius France S.A.R.L. Subsidiary 100 No
19 Rhodius Korea Inc. Subsidiary 100 No
20 Rhodius South America Limited Subsidiary 100 No
Associate/
21 Ciria India Limited 30 No
Joint Venture
Associate/
22 Wendt (India) Limited 37.5 Yes
Joint Venture
Associate/
23 Murugappa Morgan Thermal Ceramics Limited 49 Yes
Joint Venture
Note: This report does not contain ESG information related to Subsidiaries and Associate Associate/Joint Venture Companies of CUMI.
This is a Standalone report (i.e only for the entity: 20 plants and 13 office locations).
22. (i) Whether CSR is applicable as per section 135 of Companies Act, 2013: (Yes/No): Yes
(ii) Turnover (in ₹): 25098.59 Million
(iii) Net worth (in ₹): 19719.00 Million
S. Material issue Indicate Rationale for identifying the risk/ In case of risk, approach to adapt or Financial implications
No identified whether risk opportunity mitigate of the risk or
or opportunity opportunity (Indicate
(R/O) positive or negative
implications)
1 Climate Change Risk Climate change is resulting in increasing To mitigate our exposure to these Negative
and Climate action frequency and intensity of extreme risks, we are taking proactive measures
obligations weather events, which can disrupt our such as investing in energy-efficient
operations, damage our infrastructure technologies, reducing greenhouse
and equipment, and lead to supply chain gas emissions, increasing water
disruptions. In addition, water scarcity is efficiency, plan to diversify our supply
already a significant concern in India, chains, and developing contingency
and climate change is expected to plans for extreme weather events.
exacerbate this issue, which could lead By implementing these methods, we
to production disruptions and increased can reduce our exposure to climate
costs. change risks and enhance our long-term
sustainability.
We are in a phase where Climate
obligations are rapidly evolving. The As a part of our sustainability efforts we
Indian government is taking steps are focusing on a significant reduction
to address climate change and we in water, energy and waste in the next
can expect more regulations to be few years.
introduced in the future. The risk could
potentially increase our operating costs
through carbon taxes or emissions caps.
Additionally, our customers, investors,
and other stakeholders are increasingly
concerned about climate change and
are demanding that we take action to
address it. Failure to take action may
result in reputational damage and loss
of business.
2 Environmental Risk Environmental risks, such as air and We have made sincere efforts to reduce Negative
risks water pollution, waste generation our environmental risks by transitioning
and disposal, climate change, and from fossil fuels to LPGs and increasing
resource scarcity, have the potential our use of renewable power sources
to affect our operations, reputation, across most of our plants. We have also
and financial performance. Failure to installed Effluent Treatment Plants (ETP)
comply with environmental regulations and Sewage Treatment Plants (STP)
and standards could result in fines, to treat, reuse or discharge water in
legal action, and reputational damage. accordance with the norms set by the
Dependence on fossil fuels and Pollution Control Board (PCB). As per
increasing energy costs could affect our our obligations under the EPR (plastic)
profitability and competitiveness in the regulation, we ensure the collection of
long run. plastic waste generated through third-
party engagement.
To monitor our compliance with
environmental regulations, we use the
KOMRISK tool, which enables us to
track and report on our environmental
performance on a monthly basis.
Additionally, we conduct regular
environmental monitoring to ensure
that we pose no threat to the
environment and prevent any potential
disruption to our business operations.
S. Material issue Indicate Rationale for identifying the risk/ In case of risk, approach to adapt or Financial implications
No identified whether risk opportunity mitigate of the risk or
or opportunity opportunity (Indicate
(R/O) positive or negative
implications)
3 Employee turnover Risk High turnover rates can lead to increased The Murugappa group places a great Negative
and Skills recruitment and training costs, loss emphasis on human capital as being
of knowledge and expertise, reduced essential for sustainable business
productivity, and lower employee operations and growth. To achieve
morale. this, the Company provides training
and development programs to allow
Moreover, we operate in a highly employees to enhance and refine
competitive industry, where access to their skills. By doing so, employees
skilled talent is essential for our success. can pursue career advancement while
Our ability to attract, retain, and simultaneously contributing towards
develop skilled employees is critical to the organisation’s objectives. We have
our ability to innovate, meet customer implemented various HR practices
demands, and achieve our business throughout the employment cycle,
objectives. Failure to do so could result including performance-based rewards
in a shortage of skilled labor, which and recognition mechanisms. Job
could limit our growth potential and put rotation and training are employed to
us at a competitive disadvantage. develop employee capacity, and regular
employee engagement activities are
conducted.
4 Market Preference Risk/opportunity We operate in a highly competitive We regularly conduct market research Negative/
industry where customer preferences and analysis to understand customer
and expectations are constantly preferences and expectations and adapt Positive
evolving. Failure to understand and our products and services accordingly.
adapt to these changing market We will also strengthen the integration
preferences could result in declining of sustainability into our business
sales and market share, impacting our strategy, operations, and decision-
financial performance and ability to making, reflecting our commitment
meet the needs of our stakeholders. to responsible and ethical business
practices that meet the evolving needs
Moreover, we operate in a global market of our stakeholders.
where customers are increasingly
focused on sustainability and ethical
business practices. Failure to align our
business practices with these changing
market preferences could result in
reputational damage, lost business
opportunities, and legal liabilities.
5 Technology Risk Opportunity Technology plays a vital role in our We have implemented various initiatives Positive
operations, from process automation to mitigate the risk of technology-
and quality control to supply related threats. We regularly invest in
chain management and customer research and development to enhance
engagement. Failure to keep up our technological capabilities, improve
with the latest technological trends our processes, and develop innovative
and innovations could put us at a solutions that meet the evolving needs
competitive disadvantage and impact of our customers. We also planning to
our ability to meet customer demands strengthen our cybersecurity measures
and expectations. in place to protect our digital assets and
ensure the confidentiality, integrity, and
Moreover, our operations are becoming availability of our data.
increasingly reliant on digital systems
and networks, which are vulnerable
to cyber threats and disruptions.
Cyberattacks and data breaches could
result in financial losses, reputational
damage, and legal liabilities, which
could impact our brand reputation and
stakeholder trust.
S. Material issue Indicate Rationale for identifying the risk/ In case of risk, approach to adapt or Financial implications
No identified whether risk opportunity mitigate of the risk or
or opportunity opportunity (Indicate
(R/O) positive or negative
implications)
6 Data Security Risk We understand that data security We have implemented various Negative
breaches can lead to significant measures, such as regular cybersecurity
reputational damage, financial losses, assessments, data security policies and
and legal penalties. The Company procedures, and employee awareness
often stores sensitive information to mitigate this risk. By proactively
such as customer data, supplier identifying and addressing this risk,
information, and intellectual property. we are committed to operating in a
If this information is breached or socially responsible and sustainable
compromised, it can result in a loss of manner, protecting our reputation,
trust with stakeholders and damage to and maintaining the trust of our
the Company's reputation. stakeholders.
7 Data Privacy Risk The rapid digitalisation of the economy Implementing Access Controls: We have Negative
has made data privacy a significant implemented access controls to ensure
concern. As a responsible and that only authorised personnel have
ethical Company, we are committed access to sensitive information.
to protecting the privacy of our
stakeholders and complying with Regular Training and Awareness: We
applicable regulations and laws. conduct regular training and awareness
The unauthorised use or disclosure programs for employees to educate
of personal information can lead them on data privacy best practices,
to significant reputational damage, including how to handle sensitive
financial losses, and legal penalties. information, how to spot phishing
attempts, and how to report suspicious
activity.
8 Corporate Opportunity Corporate governance is a fundamental The corporate business conduct policy Positive
Governance element of sustainable business which encompasses governance
operations. The identification of principles has been implemented across
(Transparency and risks and opportunities, policies and all operations. The leadership team and
Disclosures) operating procedures, implementation, operations staff are trained to have zero
monitoring, checking, and verification tolerance toward any breach of the code
of systems and procedures help of conduct.
the organisation to ensure business
continuity, and build trust and
reputation in the market.
Failure to implement adequate
Corporate Governance policies can lead
to legal and financial penalties, as well
as damage to our reputation and brand
image.
SECTION B: MANAGEMENT AND PROCESS DISCLOSURES • P6 Businesses should respect and make efforts to protect
and restore the environment.
The National Guidelines for Responsible Business Conduct
(NGRBCs) as prescribed by the Ministry of Corporate Affairs • P7 Businesses, when engaging in influencing public
advocates nine principles as given below: and regulatory policy, should do so in a manner that is
responsible and transparent.
• P1 Businesses should conduct and govern themselves with
integrity, and in a manner that is Ethical, Transparent and •
P8 Businesses should promote inclusive growth and
Accountable. equitable development.
• P2 Businesses should provide goods and services in a • P9 Businesses should engage with and provide value to
manner that is sustainable and safe. their consumers in a responsible manner.
• P3 Businesses should respect and promote the well-being CUMI has implemented a rigorous governance mechanism to
of all employees, including those in their value chains. ensure sustainable business operations. We have adopted the
Plan, Do, Check, and Act (PDAC) process to achieve ongoing
• P4 Businesses should respect the interests of and be
improvement in our systems. As part of our sustainability
responsive to all its stakeholders.
journey, we have identified material aspects such as climate
• P5 Businesses should respect and promote human rights. action obligation, environmental risks, supply chain disruptions,
regulatory changes, technology risks, customer data privacy, Principle 2: We have procedures/policies in place that already
organisation data security, employee turnover and skills, address some of the important objectives of a supply chain
community engagement etc sustainability policy. (1) Sustainability policy and (2) Product
safety policy demonstrates our commitment to environmental
To mitigate these material aspects, we have conducted an
and social responsibility. However, we are always striving to do
enterprise risk analysis and identified various opportunities,
better, and we believe that developing a dedicated supply chain
such as market research, Corporate Governance, HR policies,
sustainability policy can help us ensure that all of our suppliers
innovation and technology adaptation, data and information and vendors uphold the same high standards.
security systems, stakeholder grievance mechanism and
engagement processes. The Company has also established Principle 3: (1) HR policies (lifecycle) (2) Equitable and Inclusive
various policies, such as the Murugappa Five Lights, Code of Work Place (3) Occupational health and safety policy, (4)
Conduct, Human Resources enabling policies, Privacy policy, Gender equality and diversity policy (5) Leave pool policy (6)
Business Responsibility policy, Sustainability policy, Stakeholders Fair employee appraisal process (7) Group health and medical
engagement and grievances Redressal policy, Whistle-blower insurance, accident insurance.
policy, and Corporate Social Responsibility policy etc. In addition to the above, the Company also offers various
All leadership and operational team members have been career development programs to support employees in their
professional growth and advancement. We also have reward and
trained on these policies, and various awareness programs
recognition programs in place to acknowledge and appreciate
have been undertaken. The adherence to the Code of Conduct
the contributions of our employees. Moreover, we regularly
and an annual confirmation to the same at the beginning of
conduct employee engagement surveys to gather feedback and
every financial year reiterates our commitment to governance
insights from our employees, which helps us to continuously
process and non-negotiable ethical behaviour. The Company
improve and create a positive work environment for our staff.
has established a robust internal and external communication
We have awarded Certificate for Significant Achievement in HR
system to ensure the effective implementation of these
Excellence for the 13th CII National HR Excellence Award 2022-
policies across their facilities. While the respective business
23 and it can be viewed at https://www.cumi-murugappa.com/
heads are primarily responsible for policy implementation,
awards/.
the Business Group Core Management committee and Audit
Committee regularly monitor the overall governance aspects. Principle 4: (1) Procedures for identifying stakeholders (concerns
All major material incidents are reported to the Board, along and opportunities), (2) Feedback mechanism (3) Whistle-blower
with corrective and preventive programs. Overall, we have Policy.
demonstrated a strong commitment to responsible and Principle 5: (1) Human rights policy - Non-discrimination Policy,
sustainable business practices. Minimum Wage Policy, POSH Policy, Privacy Policy, Child Labour
The following policies/standards/procedures are being Policy etc. (2) Business code of conduct.
implemented under each principle: Principle 6: (1) Sustainability Policy (2) Health, Safety and
Principle 1: (1) Responsible business code of conduct (OECD or Environment Policy.
Equivalent), (2) Policies and procedures to meet the SEBI listing Principle 7, Principle 8 and Principle 9: Code of Ethics and
guidelines (Business Responsibility policy), (3) Board governance Conduct, Corporate Social Responsibility Policy, Responsible
structure, (4) Regulatory compliance tracking and assurance Marketing and Advertising Policy, Product Quality and Safety
policy, and (5) Anti-corruption and anti-bribery (covered under Policy, Privacy Policy, Social Media Policy, CUMI’s Right Path and
CUMI Right Path document and contractual agreements) (6) Code of Conduct besides the Whistle Blower policy and POSH
Conflict of Interest Policy (7) Transparency and Disclosure Policy. policy etc.
Disclosure Questions P1 P2 P3 P4 P5 P6 P7 P8 P9
1. a. Whether your entity’s policy or policies cover Y Y Y Y Y Y Y Y Y
each principle and its core elements of the
NGRBCs. (Yes/No)
b. Has the policy been approved by the Board? Y Y Y Y Y Y Y Y Y
(Yes/No)
c. Web Link of the Policies, if available https://www.cumi-murugappa.com/policies-disclosure/
Certain policies of the Company are only available to internal stakeholders
or employees.
2. Whether the entity has translated the policy into Y Y Y Y Y Y Y Y Y
procedures. (Yes/No)
3. Do the enlisted policies extend to your value chain The Company endeavors to encourage its value chain partners to engage
partners? (Yes/No) in responsible and sustainable business practices, taking into account their
respective capabilities and resources. To enable this, we have Fair trade
practice, Whistle-blower policy, Grievance mechanism and value chain
engagement process etc.,
4. Name of the national and international codes/ - - Y1 - Y2 Y3 - - -
certifications/labels/standards
5. Specific commitments, goals and targets set by • Ensure 100 per cent compliance against all regulatory and statutory
the entity with defined timelines, if any. requirements.
GOVERNANCE, LEADERSHIP AND OVERSIGHT committees within the Board, including but not limited to the
Audit Committee, Risk Management Committee, Stakeholders'
7.
Statement by Director responsible for the business
Relationship Committee, and Corporate Social Responsibility
responsibility report, highlighting ESG related challenges,
Committee. These committees play a vital role in ensuring
targets and achievements
effective governance, risk management, and sustainable
We recognise the importance of Environmental, Social, and development of our organisation (Please refer Sl. No. 9 for more
Governance (ESG) factors in creating a sustainable future for our details on their roles and responsibilities under ESG).
business and society as a whole. We believe that by prioritising
ESG considerations, we can better manage risk, drive long- As a Company committed to ESG principles, we have adopted
term value creation, and contribute to a more equitable and a set of policies and practices that align with our values and
prosperous world. ESG principles are embedded into every aspect goals this includes the Company’s Code of Conduct, Human
of our operations, right from our business strategy and decision- rights policy, Code of Conduct for Prevention of Insider Trading,
making processes to our daily practices and interactions with Diversity policy, Policy on prevention of sexual harassment,
stakeholders. Our Board is made up of individuals with diverse ethical guidelines on stakeholder dealing, Whistle Blower policy,
backgrounds and experiences, including expertise in ESG issues, Anti-corruption and anti-bribery, corporate social responsibility
which enables us to effectively manage these considerations in policy, Sustainability policy, Privacy policy, stakeholder
our decision-making processes. We have established multiple engagement etc.
We are steadfast in our commitment to sustainability, and we Relationship Committee, and Corporate Social Responsibility
have set a bold target of reducing our water consumption, Committee.
emissions, waste, and energy consumption. To achieve this
goal, we have implemented a range of measures, including 1. Risk Management Committee: The Risk Committee is
increasing our renewable energy capacity, implementing water responsible for identifying and assessing Environmental,
consumption reduction programs, and transitioning to climate- Social, and Governance (ESG) risks that may impact the
friendly fuels. In addition to these efforts, we recognise our Company's operations or reputation. The committee
responsibility to society, and we are dedicated to making a analyses these risks and recommends appropriate
positive impact through our Corporate Social Responsibility strategies and actions to mitigate them. By proactively
(CSR) activities. We understand that our success is intricately addressing ESG risks, we can better protect its stakeholders
linked to the health and prosperity of the communities in which and improve its long-term sustainability.
we operate, and we are committed to engaging in meaningful 2. ESG Committee: The ESG Committee is responsible for
CSR initiatives that contribute to the well-being of these implementing the Company's ESG policies and strategies.
communities. This involves coordinating with various departments
Overall, our commitment to sustainability and responsible and stakeholders to ensure that ESG considerations
corporate citizenship is an integral part of our business strategy, are integrated into business operations and decision-
and we believe that by pursuing these goals, we will not only making processes. The committee also monitors progress
create long-term value for our stakeholders but also contribute towards ESG goals and identifies areas for improvement,
to a more sustainable and equitable world. enabling the Company to continuously enhance its ESG
performance.
8.
Details of the highest authority responsible for
implementation and oversight of the Business 3. Audit Committee: The Audit Committee is responsible
Responsibility policy (ies). for reviewing the Company's financial performance
and ensuring that it complies with legal and regulatory
Name: Mr. N Ananthaseshan requirements. In addition, the committee reviews the
Company's ESG performance and sustainability reporting,
Designation: Managing Director
ensuring that they are accurate, transparent, and provide
9. Does the Company have a specified Committee of the relevant information to stakeholders. Through this
Board/Director responsible for decision making on oversight, the committee helps to maintain our reputation
Sustainability related issues? (Yes/No). If yes, provide and build trust with its stakeholders.
details.
4. Stakeholder Committee: The Stakeholder Committee is
Yes, The Board and its Committees bear the primary responsible for monitoring and addressing grievances
responsibility for overseeing the strategy, governance, from all Stakeholders, including Customers, Employees,
compliance, stakeholder interest, risk management, and Suppliers, and Communities. The committee ensures
sustainability practices of the Company, including the that stakeholder concerns are heard and addressed in
identification, mitigation, and management of ESG risks and a timely and effective manner, enhancing stakeholder
other material issues. We have established several Board satisfaction and loyalty. Through this approach, we build
committees to address business concerns, such as the Audit stronger relationships with its stakeholders and improve
Committee, Risk Management Committee, Stakeholders' its reputation as a responsible and ethical business.
10. Details of Review of National Guidelines on Responsible Business Conduct (NGRBCs) by the Company
Subject for Review Indicate whether review was undertaken Frequency (Annually/Half yearly/
by Director/Committee of the Board/Any Quarterly/Any other - please specify)
other Committee
P1 P2 P3 P4 P5 P6 P7 P8 P9 P1 P2 P3 P4 P5 P6 P7 P8 P9
Performance against above policies and
Y Y Y Y Y Y Y Y Y Q Q Q Q Q Q Q Q Q
follow-up action
Compliance with statutory requirements
of relevance to the principles, and, Y Y Y Y Y Y Y Y Y Q Q Q Q Q Q Q Q Q
rectification of any non- compliances
ote: As part of a regular process, the department heads, business leaders, functional heads and senior management staff review the
N
Company’s policies to ensure their continued relevance and effectiveness. Any necessary adjustments to the policies and processes are
made during this assessment, and the policies are presented to the Board of Directors as needed. The Company and its subsidiaries
ensure adherence to applicable regulations and have established compliance management system to this effect.
Aspect P1 P2 P3 P4 P5 P6 P7 P8 P9
11. Has the entity carried out independent The leadership team has developed various policies and procedures on material
assessment/evaluation of the working of its aspects of CUMI. Although we have not undergone external Environmental and
policies by an external agency? (Yes/No). If Social assessments, we have established a robust internal mechanism to ensure
yes, provide name of the agency compliance with relevant standards and regulations. This mechanism includes
site-level audits as well as corporate-level audits to assess our performance in
areas such as environment, health, safety, and quality management.
We have implemented various integrated management systems, including
ISO 9001 for quality management, IS 45001 for occupational health and safety
management, and ISO 50001 for energy management. These systems are
audited by reputable organisations. We have also partnered with ESG specialists
to assess our existing maturity levels and draw up plans to minimise the gap to
benchmarked practices and processes in ESG.
12. If answer to question (1) above is “No” i.e. not all Principles are covered by a policy, reasons to be stated.
All principles are covered in the policies.
PRINCIPLE 1: BUSINESSES SHOULD CONDUCT AND GOVERN Consistent with its Values and Beliefs represented by the Five
THEMSELVES WITH INTEGRITY, AND IN A MANNER THAT IS Lights - spirit of the Murugappa Group, the Company has
ETHICAL, TRANSPARENT, AND ACCOUNTABLE formulated a Code of Conduct applicable to the Board and
Senior Management which is posted on the Company's website
Carborundum Universal Limited (“CUMI”), a constituent of
(https://www.cumi-murugappa.com/policies-disclosure/). The
the Murugappa Group, is committed to the highest standards
Board meets at regular intervals and has a formal schedule of
of Corporate Governance in all its activities and processes.
matters reserved for its consideration and decision to ensure
CUMI’s value systems are aligned with the Murugappa Group’s
that it exercises full control over significant, strategic, financial,
Values and Beliefs guided by the Five Lights - spirit of the
operational and compliance matters. These include setting
Murugappa Group: Integrity, Quality, Passion, Respect and
Responsibility towards all stakeholders and the communities performance targets, reviewing operational and financial
that the Company operates in and serves. The Company as performance against set targets, evolving strategy, approving
well as all companies within the CUMI Group - its Subsidiaries, investments, ensuring adequate availability of financial
Associates or Joint Ventures are governed by this philosophy resources, overseeing risk management and reporting to the
in addition to the requirements of their local jurisdictions. The shareholders.
Board recognises that governance expectations are constantly Various committees have been constituted by the Boards of the
evolving and is committed to keeping its governance framework respective group companies in terms of regulatory requirements
under continuous review to meet both letter and spirit of the and to oversee operational/strategic matters thereby supporting
law and its own demanding levels of business ethics. the Board in discharging its duties efficiently. The Committees of
Our key elements in Corporate Governance are transparency, the Board are Audit Committee, Nomination & Remuneration
internal controls, risk management, internal/external Committee, Stakeholders Relationship Committee, Risk
communications and good standards of safety, health, Management Committee, and CSR committee. The Board at
environment and quality. The Corporate Governance philosophy the time of the constitution of committees approves the terms
of the Company is driven by the fundamental principles of: of reference of each committee. Recommendations of the
Adhering to the governance standards beyond the letter of law; committees on various matters are placed before the Board for
Maintaining transparency and high degree of disclosure levels; approval.
Maintaining a clear distinction between personal and corporate CUMl’s Right Path, a corporate manual setting out the corporate
interest, Having a transparent corporate structure driven by culture lays down the guidelines required to be adhered by every
business needs; and Ensuring compliance with applicable laws. employee both in letter and spirit. This manual was prepared with
The Board has been constituted in an appropriate manner, to a view to give clarity on ethical issues, maintaining transparency
preserve its independence and to separate the Board functions in all dealings and to practice ethics in a dynamic business
of Governance and Management. The Board members are environment. It is required to be adhered by all employees, the
eminent persons and have collective experience in diverse Company’s Code of Conduct, Code of Conduct for Prevention of
fields of technology, engineering, banking, foreign affairs, Insider Trading, Diversity policy, Policy on prevention of sexual
management, legal and compliance. The Company’s day-to-day harassment, ethical guidelines on stakeholder dealing, Whistle
affairs are managed by the Managing Director and Whole-time Blower policy which are also enshrined in the Right Path serve
Director, assisted by a competent management team under the as a guiding norm in matters relating to ethics, anti-bribery
overall supervision of the Board. The Company’s commitment and anticorruption for all employees. The anti-bribery clauses
to ethical and lawful business conduct is a fundamental shared are made part of its contractual arrangements with suppliers,
value of the Board, Senior Management and all its employees. vendors etc., The Company has also put in place transparent
processes for dealing with confidential and sensitive information to improve operational efficiencies while also promoting
of the Company, legitimate purposes for which it can be shared sustainable operations and energy conservation.
and the manner to conduct enquiry in case of a violation etc.,
In the Abrasives business which is the main business segment
beyond the mandate of law.
of the Company, sustainable sourcing is incorporated in the
In line with the Companies Act, 2013, Listing Regulations and processes and procedures as follows: 1. Energy Management
SEBI (Prohibition of Insider Trading) Regulations, 2015, the initiatives are captured in our Supplier addition checklist. 2.
Company has in place policies for determining ‘materiality’ for Focused Sustainability projects like reducing the weight of
disclosure of events/information to stock exchanges, policy for packing materials, water consumption, energy consumption etc
preservation and archival of documents, dividend distribution are reviewed. 3. Procurement of paper is undertaken only from
policy, business responsibility policy, whistle blower policy, FSC-certified mills. Also, we have plans to promote/support
the corporate social responsibility policy and policy for the SA 8000, ISO 14001, and OHSAS 45001 certified vendors in
prevention of sexual harassment at workplace. The above our supply chain as a way to integrate ESG aspects. The long-
policies are periodically reviewed by the Board. Due to the term plan is to conduct an ESG assessment of key suppliers and
adoption of a robust governance mechanism, no material communicates areas of further improvements to reinforce ESG
incidents were reported during FY 2022-23. principles.
The Company ensures that its Directors are kept up-to-date We continuously innovate and strive for optimal resource use
on sustainability initiatives and regulatory changes through over the life cycle of the products it manufactures. The Company
quarterly meetings. This practice helps the Directors to make has sustainable processes in place to recycle the products and
informed decisions that align with the latest industry standards waste, post-completion of the manufacturing life cycle. As part
and requirements. Key managerial and other employees/ of our initiative towards reducing our GHG emissions over our
workers are trained on various policies and work-related product life cycle, we have migrated towards natural gas in both
material aspects such as ethical guidelines on stakeholder Industrial Ceramics & Bonded Abrasives and promote renewable
dealing, health & safety, environment and climate change. A energy consumption through the installation of solar energy at
series of training programs and workshops are being conducted our plant locations. We have estimated our carbon footprint
for the employees to ensure that the Murugappa Five lights and net-zero strategy by engaging the Confederation of Indian
spirit is embraced across the Company. No incidents related Industries in certain businesses. We are further planning to
to corruption and bribery were reported either by internal, or undertake a life cycle assessment of major products.
external stakeholders including the whistle-blower mechanism
The EPR regulations require us to manage our plastic waste
for the FY 2022-23.
from Abrasives Business. We have recycled 313 metric tons of
PRINCIPLE 2: BUSINESSES SHOULD PROVIDE GOODS AND plastic packaging waste during the year by engaging third-party
SERVICES IN A MANNER THAT IS SUSTAINABLE AND SAFE services. There are many other initiatives to reduce waste such
as use of rejected material back into the product manufacturing
The Company exercises due diligence in the selection of
mix, including maximum recycling mix in products to ensure
suppliers/contractors/others who are aligned with our value
high recyclability etc.
system. True to our purpose of ‘Making Materials Matter,’
we harness the properties of the rare resources of nature to PRINCIPLE 3: BUSINESSES SHOULD RESPECT AND PROMOTE
maximise their efficiencies for the best possible material THE WELL-BEING OF ALL EMPLOYEES, INCLUDING THOSE IN
science solutions for an enduring planet. One of our long-term THEIR VALUE CHAINS
objectives within the sustainability space is to promote and
The organisation remained committed to prioritising the well-
facilitate the implementation of sustainable practices among
being of its employees. The Company has adopted employee-
our supply chain partners, vendors, and communities, with a
oriented policies covering areas such as employee contract
focus on encouraging and providing support for these efforts.
policy, employee and worker wage policy, PF/Gratuity policy,
We look at sustainability in all aspects of our business career development policy, fair employee appraisal process,
operations with a focus on innovation & process upgradation 360 Degree feedback process, employee grievance redressal
through purposeful Research & Development and collaboration mechanism, leave policy, travel policy, paternity and maternity
with leaders in Materials Technology. Our research and product leave policy, group health and medical insurance, accident
design has always centered on the sustainability of making ‘more insurance, policy on fairness to participating in open forums,
with less’, extending product life cycles, enhancing efficiencies, prevention of sexual harassment workplace policy and great
improving processes, reducing cost, and minimising. places to work policy.
The Company strives for sustainable resource exploitation The current workforce comprises 975 employees and 4488
through its integrated operations. Collaborative project workers, all of whom receive comprehensive health, accident,
opportunities among the various business units lead to maternity, and retirement benefits. Our return to work and
increased efficiencies in sourcing and product development. retention rates of permanent employees and workers over the
We adopt Total Productivity Maintenance (TPM) practices last year is 100%. Unit level grievance committee/IC committee
is responsible to address any grievances that employees or PRINCIPLE 4: BUSINESSES SHOULD RESPECT THE INTERESTS OF
workers (both permanent and contractual) may have. There AND BE RESPONSIVE TO ALL ITS STAKEHOLDERS
were, no pending grievances for the fiscal year 2022-23 due
CUMI strongly believes in order to deliver services that are
to the effective employee and worker engagement process
relevant to the market; stakeholder engagement is essential.
implemented by the organisation.
The major stakeholders are shareholders and investors,
Employee Safety and Health Safety continues to be the key employees, customers, suppliers, local communities, regulators,
area of focus for the Company. Most of the manufacturing and government agencies.
locations of the Company are certified ISO 14001 (Environment
The most critical material topics that are having some interest
Management System), QMS - ISO 9001 (Quality Management
or influence on the stakeholders are regulations, technology
System), and ISO 45001. Some of the plants are also certified
risk, market preference risk, environmental risk, climate action
EnMS ISO 50001:2011. Behaviour-based training both
obligation, employee turnover and skills, customer data privacy,
in-person as well as virtual was conducted to promote a culture
organisation data security, corruption and bribery, and supply
of safe working. The Behaviour-based safety model has been
chains.
piloted in select units of Electrominerals, Industrial Ceramics
and Abrasives Businesses. We conduct HIRA assessments in all The Company management regularly interacts with key
of our plants, and for certain units, we also perform working stakeholders. The consultation with the Board on key stakeholder
condition assessments based on the REBA model. Our risk concerns is largely facilitated by different organisational
register encompasses all work-related hazards, demonstrating functions which are responsible for the respective stakeholders.
our commitment to comprehensive risk management. Safety This is facilitated through periodic Board reviews held at least
awareness sessions continued on a regular basis to bring in more once a quarter. The Company conducts a customer satisfaction
awareness of safety. Separate kiosks have been set up at select survey on a periodic basis. The Company puts the customers at
units to provide virtual training on safety and to issue a work the fulcrum of its business strategy. The Company understands
passport on the successful completion of safety orientation. the requirements of the customers and provides holistic
We prioritise regular awareness sessions, training on the proper solutions rather than merely supplying materials.
use of protective equipment, and identifying and eliminating The Company on a periodical basis undertakes dedicated
any hazardous conditions. CUMI places great importance activities as a part of its CSR initiatives for the disadvantaged,
on workplace safety and has made sustained efforts to train vulnerable and marginalised stakeholders in and around the
our employees on safe work practices. Over the last year, Company’s factories/plants. Education, sports and health aids
100 per cent of our employees and workers have been trained are provided to schools in rural/underdeveloped areas and to
in health and safety. We remain committed to promoting and schools supporting differently abled children. The Company’s
empowering women through initiatives such as our friendly Corporate Social Responsibility (CSR) policy drives the initiatives
workplace policies, policies for the prevention of sexual undertaken by the Company towards the benefit of the
harassment, and the establishment of internal complaints disadvantaged, vulnerable, and marginalised stakeholders. The
and women welfare committees. Some of our plants have Company has spent ₹378.33 Lakhs on CSR activities benefiting
already taken measures to benchmark their safety protocols. more than 80 per cent from marginalised and weaker sections
Furthermore, the organisation has entered and emerged of the society during the FY 2022-23.
victorious in many competitions for exemplary safety practices
over the past year. Throughout the previous financial year, we PRINCIPLE 5: BUSINESSES SHOULD RESPECT AND PROMOTE
are pleased to report that we did not receive any complaints HUMAN RIGHTS
related to health, safety, or the environment (HSE) from our CUMI has a strong commitment to upholding human rights in all
employees or workers. This indicates that our organisation's of its business operations. The Company recognises that human
efforts to prioritise HSE and implement effective measures to rights are universal, inherent, interdependent, and indivisible.
promote a safe and healthy workplace have been successful. To integrate this aspect with its operations, the Company takes
• EMD was awarded the IEI Industry Excellence Award 2022 conscious efforts to understand the regulatory aspects of human
• EMD has been recognised with GOLD Award for Energy rights both nationally and internationally. CUMI respects the
Management and Conservation by Society of Energy human rights of all relevant stakeholders and groups, including
Engineers & Managers (SEEM) communities, consumers, vulnerable and marginalised groups,
• EMD was awarded the Kerala State Energy Conservation and business units within their sphere of influence. They strive
Award 2022 in appreciation of the commendable to promote awareness and realisation of human rights across
achievements towards energy conservation and their value chain.
management in the category of Large-Scale Energy The Company is committed to providing equal opportunities
Consumers during employment and recruitment, regardless of gender,
• Three of our units have won Safety Award this instituted race, caste, religion, disability, creed, etc., CUMI also
by Government of Kerala and National Safety Council prioritises maintaining a safe, hygienic, and humane workplace
environment that upholds the dignity of employees. This all plants and offices undergo third-party audits for compliance
includes regular training and communication. with human rights aspects. CUMI requires all its value chain
partners to comply with their supplier code of conduct, which
To ensure high standards of ethical, moral, and legal business
insists on 100 per cent compliance with human rights aspects
conduct, the Company has established a whistle-blower
such as child labor, forced/involuntary labor, sexual harassment,
mechanism that provides an avenue to raise concerns. The
and wages.
grievance mechanism also provides adequate safeguards against
employee victimisation. Awareness campaigns organised by PRINCIPLE 6: BUSINESSES SHOULD RESPECT, PROTECT AND
the Internal Complaints Committee, set up under the Sexual MAKE EFFORTS TO RESTORE THE ENVIRONMENT
Harassment of Women at Workplace (Prevention, Prohibition,
We at CUMI have implemented robust mechanisms to
and Redressal) Act, 2013, help promote a safe and respectful
ensure compliance with applicable environmental laws and
workplace. In the previous year, two referrals were received
regulations. We are dedicated to being an environmentally
under the policy for the prevention of sexual harassment, which
friendly organisation and have established an extensive
were resolved after due inquiry.
Environmental and Sustainability Policy that is followed across
All permanent and non-permanent employees at CUMI are paid all our business units. Additionally, the Company actively
more than minimum wages. About 99.66 per cent of permanent participates in initiatives to address environmental issues and
workers and 8.9 per cent of other than permanent workers are promote sustainable development. Almost all of our plants
paid more than the minimum wages. are certified for both ISO 14001 certification for Environment
Management Systems and ISO 9001 certification for Quality
No disputes or legal cases related to HR-related incidents or
Management Systems. The Company’s environment policy can
human rights were filed or pending against the organisation.
be viewed at https://www.cumi-murugappa.com/wp-content/
The corporate HR head is primarily responsible for the overall
themes/CUMI/pdf/Sustainability-Policy-2023.pdf.
implementation of various human rights-related policies and
addressing grievances. We have following polices/framework in Our sustainability vision for 2025 aims to reduce our
place to promote human rights. environmental footprint significantly. To achieve this, we plan
to lower our specific water consumption, emissions, and energy
• Compliance with the Code of Wages 2019 and other
consumption. We also intend to incorporate renewables into
applicable regulations,
our power mix and reduce waste considerably. As part of our
• Employee contract or agreement, commitment towards sustainability, we have progressed across
• Equal and fair wages policy, different components of the environment in the following ways
as underlined below.
• Employee and staff leave policy,
Throughout the year, the Company's various businesses
• Timely disbursement of salaries,
demonstrated a significant commitment to energy conservation
• Compliance with provident fund and gratuity, with a strong focus and dedication. The details of energy
• Leave policy, conservation initiatives and investments are available in
Annexure D. The primary energy conservation measures
• Parental leave, and come back to work policy,
undertaken involved identifying and optimising power
• Employee and staff health protection policy, consumption in power-intensive equipment, modifying the
• Occupational health and safety at workplace policy, manufacturing process, replacing legacy equipment with
efficient and energy-conserving alternatives, improving cycle
• Employee freedom of expression and participation policy,
time, and sourcing alternate fuels (fuel oil to LNG/CNG). As a
• Employees separation and notice period policy, result, we achieved several efficiency improvements in furnace
• Promoting inclusiveness and equal opportunities, operations, commissioned solar power units at multiple factory
locations, realised fuel savings through automation and heat
•
Non-discrimination and protection against sexual
recovery, and made improvements in combustion efficiency and
harassment,
specific fuel consumption. Our energy intensity has come down
• Employee information and privacy policy, by 6 per cent in the reporting fiscal year and we met a total of 11
• Grievance redressal mechanism for employees and service per cent of total power consumed from renewable energy with
providers, a total specific power consumption rate of 0.053 TJ/turnover
in Rupees million.
• Employee awareness programs on HR policies and human
rights, As part of our commitment to reducing greenhouse gas
emissions, we have enlisted the services of a third party to
• Fairtrade practices with service providers.
assess our overall carbon footprint. We are presently developing
No complaints regarding child labor, forced labor, bonded labor, customised carbon reduction strategies for each of our plants,
or involuntary labor were reported in the last financial year, and taking into account the specific requirements of each business.
To reduce our Scope 1 emission, we have successfully replaced as a moral duty in line with one's spiritual beliefs. Therefore,
fuel oil with carbon-effective LNG at most of our plants. our philanthropic endeavours reflect our ethical principles and
Furthermore, we are committed to achieving a renewable energy provide us with a means of fulfilling our obligations to various
mix of at least 25 per cent by integrating our renewable energy segments of society.
blend into our power supply. Accordingly, our total Scope 1 and
To effectively implement our well-defined CSR policy, a
Scope 2 emissions intensity have been reduced by 13 per cent
dedicated CSR Committee has been established to oversee the
from the last fiscal year with 8.2 Mt CO2e (Scope 1 and Scope 2)/
allocation of funds towards specific projects. The CSR policy
turnover in Rupees million.
outlines the Company's responsibility towards CSR, the guiding
The total volume of water consumed during the preceding principles of our initiative, the method of implementation,
financial year amounted to 375229 KL, characterised by a specific and a corresponding reporting process. With a focus on Skill
consumption rate of 15 KL per turnover in Rupees million. In an Development, Education, and Healthcare, these priority areas
effort to curtail water usage, a range of water-saving initiatives are at the forefront of the Company's CSR endeavours.
has been implemented, such as refining the treatment process,
The Company is committed to promoting inclusive growth
incorporating a jet aeration system, reusing rejected reverse
through a comprehensive Corporate Social Responsibility (CSR)
osmosis (RO) water as feedwater for boilers, and effectively
Policy, which can be viewed at the link CSR-Policy-2021.pdf
recycling rainwater. At all of our facilities, we have installed
both Sewage Treatment Plants and Effluent Treatment Plants, (https://www.cumi-murugappa.com/wp-content/uploads/2021/04/
which are in compliance with the applicable discharge norms as CSR-Policy-2021.pdf). In the previous fiscal year, we implemented
established by the pollution control board. Moreover, several of several projects in the areas of Child and Youth Empowerment,
our plants operate as Zero Liquid Discharge plants. Elderly Care, Health Services, and Sustainability, with a total
CSR spend of 378.33 Lakhs. These projects have benefitted
All of our business units follow the "reduce, reuse, and recycle" approximately 24,529 individuals, with 80 per cent of
approach to manage waste. We have implemented various the beneficiaries being from marginalised or vulnerable
initiatives to support this approach, including selling fired rejects communities.
from our Industrial Ceramics business to Super Refractories,
maximising the reuse of waste generated within our internal CUMI is committed to promoting social inclusion and economic
system or among group companies, and implementing a bio- empowerment, particularly for marginalised groups. As part
treatment system for food waste. As per the EPR regulations, of this commitment, we have exclusively engaged suppliers
we are responsible for managing our plastic waste. To fulfil from these groups for the supply of manpower to our various
this responsibility, we have recycled 313 metric tons of plastic plants. This not only supports our manufacturing processes but
packaging waste through third-party services this year. In the also helps to ensure the livelihoods of these suppliers. In the
reporting fiscal year, we have recycled/reused about 39 per cent previous fiscal year, 1 per cent of our annual procurement of
of the waste we have generated. goods and services are from marginalised suppliers.
PRINCIPLE 7: BUSINESSES, WHEN ENGAGING IN INFLUENCING We have implemented several measures to receive and
PUBLIC AND REGULATORY POLICY, SHOULD DO SO IN A address grievances from various stakeholders, including a
MANNER THAT IS RESPONSIBLE AND TRANSPARENT Stakeholder forum comprising local body members and other
community representatives, as well as need-based community
CUMI is an active member of several national and international interventions.
trade and industry chambers and associations. As part of these
groups, we provide recommendations and representations PRINCIPLE 9: BUSINESSES SHOULD ENGAGE WITH AND
to regulators and associations to advance and improve the PROVIDE VALUE TO THEIR CONSUMERS IN A RESPONSIBLE
industrial climate in India. Additionally, we regularly participate MANNER
in forums and discussions related to energy security and We, at CUMI place great importance on addressing customer
management, water and food security, and sustainable business complaints and recognise the need to be agile, transparent,
practices to share our views and opinions. However, during the and solution-oriented in order to resolve them effectively to
previous fiscal year, the Company did not engage in any public
the satisfaction of our customers. We believe that commitment
policy advocacy.
to transparency is vital to build trust and credibility with our
PRINCIPLE 8: BUSINESSES SHOULD PROMOTE INCLUSIVE customers, by demonstrating honesty and openness in handling
GROWTH AND EQUITABLE DEVELOPMENT complaints.
Prior to the mandatory implementation of Corporate Social Customers can communicate their complaints via email or
Responsibility (CSR) provisions under the Companies Act of phone calls to the regional salesperson, who will send an
2013, we had already made it a tradition to allocate a portion immediate acknowledgment of the complaint via email. The
of our profits to fulfill social responsibilities in accordance with complaint is then registered in the Company's Enterprise
the Murugappa Group's value system. The Company views Resource Planning (ERP) system. To ensure efficient resolution
social responsibility as more than a mere obligation, but rather of complaints, technical complaints are handled by the quality
control team, while commercial complaints are managed by use of its products and disposal mandated as per the local
the Marketing team. The Company has set a target of resolving laws. Also, in order to promote the safe and responsible usage
complaints within 30 days, in cases where the return of material of our products, we have made available Material Safety Data
is necessary for analysis. Through the ERP we have streamlined Sheets (MSDS) on our website. These sheets contain detailed
the complaint resolution process by routing the complaint to information about the potential hazards associated with
the appropriate team and tracking its progress. By centralising our products and provide guidance on how to handle, store,
complaint management in the ERP system, the Company ensures and dispose of our products in a safe manner. We also make
that complaints are addressed efficiently and effectively. the decision to voluntarily recall our products due to issues
with material breakage in interest of ensuring the safety and
During the previous fiscal year, we did not receive any complaints
satisfaction of our customers.
related to data privacy, advertising, cybersecurity, delivery of
essential services, restrictive trade practices, or unfair trade The Company conducts consumer surveys and monitors
practices. However, we have received 73 complaints under satisfaction trends periodically. Surveys are often carried out
other category, and we were able to resolve 86 per cent of those during customer plant visits, allowing us to gather firsthand
complaints to the satisfaction of our customers. The Company insight into their experiences with our products and services.
encourages our customers to prioritise safety by providing No cases of customer data breaches have been reported in the
instructions (instruction labels) regarding the handling, storage, previous fiscal year.
Segment Total number of training and Topics/principles covered under % age of persons in a
awareness programmes held the training and its impact respective category
covered by the
awareness programmes
Key Managerial Personnel An array of awareness sections/training programs for KMPs and KMP-100%
Employees other than BoD employees as listed below have been conducted in the last fiscal year. Employees-71%
and KMPs • Awareness on Whistleblowing and raising complaints under the Policy
of the Company
• Sustainability practices of the Company
• Awareness session on POSH
• Awareness session on Values workshop
• Training program on GHG accounting and mitigation measures
• Workshop on guiding principles and beliefs which define organisation
culture and serve as a reference for our decision-making processes
• Online and Offline training programs on occupational health and
safety
• Awareness sessions on SEBI (PIT) Regulations, 2015
Workers • Awareness on Whistleblowing and raising complaints under the Policy 26%
of the Company
• Awareness session on POSH
• Occupational Health and Safety
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.
Monetary
Segment NGRBC Name of the regulatory/ Amount (In INR) Brief of the Case Has an appeal been
Principle enforcement agencies/judicial preferred? (Yes/No)
institutions
Penalty/Fine NIL
Settlement NIL
Compounding fee NIL
Non-Monetary
Section NGRBC Principle Name of the regulatory/ Brief of the Case Has an appeal been
enforcement agencies/judicial preferred? (Yes/No)
institutions
Imprisonment NIL
Punishment NIL
3. Of the instances disclosed in Question 2 above, details of the Appeal/Revision are preferred in cases where monetary or
non-monetary action has been appealed.
Case Details Name of the regulatory/enforcement agencies/judicial institutions
NIL
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.
CUMl’s Right Path, a corporate manual setting out the corporate culture lays down the guidelines required to be adhered by every
employee both in letter and spirit. This manual was prepared with a view to give clarity on ethical issues, maintaining transparency in
all dealings and to practice ethics in a dynamic business environment. It is required to be adhered by all employees, the Company’s
Code of Conduct, Code of Conduct for Prevention of Insider Trading, Diversity policy, Policy on prevention of sexual harassment,
ethical guidelines on stakeholder dealing, Whistle Blower policy (https://www.cumi-murugappa.com/wp-content/themes/CUMI/
pdf/policies/Whistle-Blower-Policy.pdf) which are also enshrined in the Right Path serve as a guiding norm in matters relating to
ethics, anti-bribery and anti-corruption for all employees.
The Company strictly prohibits its employees and representatives from engaging in any form of bribery or corruption in any business
dealings involving government officials, customers, vendors, or employees. This includes offering, accepting, paying, or authorising
any form of bribe or corrupt payment. Our code of conduct includes a provision that prohibits employees from making any payments,
directly or indirectly, to any individual or entity in exchange for business or any other favourable action. The anti-bribery clauses are
made part of its contractual arrangements with suppliers, vendors etc. The Company has also put in place transparent processes for
dealing with confidential and sensitive information of the Company, legitimate purposes for which it can be shared and the manner
to conduct enquiry in case of a violation etc., beyond the mandate of law. Wherever feasible the contractual agreements with third
parties also include provisions for adherence to the anti-bribery policy of the Company.
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 2022-23 (Current Financial Year) FY 2021-22 (Previous Financial Year)
Directors
KMPs
NIL NIL
Employees
Workers
6. Details of complaints with regard to conflict of interest
FY 2022-23 (Current Financial Year) FY 2021-22 (Previous Financial Year)
Number Remarks Number Remarks
Number of complaints received in relation to
issues of Conflict of Interest of the Directors
NIL NIL
Number of complaints received in relation to
issues of Conflict of Interest of the 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
Leadership Indicators
1. Awareness programmes conducted for value chain partners on any of the Principles during the financial year
Total number of awareness Topics/principles covered % age of value chain partners covered (by value of business done
programmes held under the training with such partners) under the awareness programmes
The Company is in the process of developing and institutionalising a program for the value chain partners.
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 Company has instituted a Code of Conduct that serves as a guiding framework for its Board of Directors and Senior
Management personnel, elucidating clear directives on abstaining from and disclosing actual or potential conflicts of interest that may
arise in connection with the Company’s business operations. To reinforce the adherence to these directives, the Company mandates
an annual declaration from its Board of Directors and Senior Management personnel, disclosing any interests that they may hold in
other entities. Additionally, the Company undertakes necessary measures to procure requisite approvals, in compliance with the
relevant laws and regulations, before entering into any transactions with such entities.
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 products and processes to total R&D and capex investments made by the entity, respectively.
2. a) Does the entity have procedures in place for sustainable sourcing? (Yes/No)
b) If yes, what Percentage of inputs were sourced sustainably?
The Company exercises due diligence in the selection of suppliers/contractors/others who are aligned with its value system. True to
our purpose of ‘Making a Material Difference,’ we harness the properties of the rare resources of nature to maximise their efficiencies
for the best possible material science solutions for an enduring planet. One of our long-term objectives within the sustainability space
is to promote and facilitate the implementation of sustainable practices among our supply chain partners, vendors, and communities,
with a focus on encouraging and providing support for these efforts.
Sustainable sourcing is incorporated in the processes and procedures as follows: 1. Energy Management initiatives are captured in
our Supplier addition checklist. 2. Focused Sustainability projects like reducing the weight of packing materials, water consumption,
energy consumption etc. are reviewed. 3. Procurement of paper is undertaken only from FSC-certified mills. Also, we have plans to
promote/support SA 8000, ISO 14001, and OHSAS 45001 certified vendors in our supply chain as a way to integrate ESG aspects.
The long-term plan is to conduct an ESG assessment of key suppliers and communicates areas of further improvements to reinforce
ESG principles.
As a Company, we have implemented a process where we only engage with suppliers who are marginalised to provide us with
manpower for our various plants. This is done in order to support our manufacturing process while also ensuring that these
marginalised suppliers are able to earn a livelihood. We have committed to procuring 1 per cent of our annual goods and services
from these suppliers as part of our commitment to support marginalised communities.
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.
We are already implementing sustainable practices in our operations. Firstly, we are reusing materials to minimise waste. Secondly,
any waste generated on-site is either recycled within our facility or given to recycling vendors. Thirdly, a significant percentage of our
Abrasives products are covered under Extended Producer Responsibility (EPR) regulations as required by Indian law. Lastly, we are
adhering to Local Government policies by avoiding the use of single-use plastics.
The EPR regulations require us to manage plastic waste from our Abrasive units. We have collected and recycled 313 metric tons of
plastic packaging waste by engaging third-party services as part of EPR obligation in the reporting fiscal year. We recover more than
50 per cent of the gross loss of skeleton waste from the Abrasives Business in the form of marketable products. There are many other
initiatives to reduce waste such as the use of rejected material back into the product manufacturing mix, including maximum recycling
mix in products to ensure high recyclability etc., Therefore, plastic waste generated from our products and their packaging is safely
managed under EPR obligation through third-party engagement which undertakes recycling and coprocessing to effectively manage
waste.
E-waste and Hazardous Waste: Most of our products before and after use do not contribute to the generation of E-Waste and Hazardous
waste. However, the usage of Prodorite leads to the generation of hazardous chemicals, which are informed to the customers for safe
management and handling by customers based on Material Safety Data Sheet (MSDS) sheet provided along with the product.
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, it is applicable to our Abrasive units. Our EPR compliance obligation for the last fiscal year was 313 MT of plastic waste
(70 per cent of the plastic packaging which we purchased and introduced in the market) and we have achieved the target. The details
are summarised in the below.
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)? If yes, provide details in the following format?
Name of % of total Boundary for which the Whether conducted by Results communicated in
NIC Code Product/ Turnover Life Cycle Perspective/ independent external public domain (Yes/No) If
Service contributed Assessment was conducted agency (Yes/No) yes, provide the web-link.
While formal life cycle assessments have not yet been undertaken, we continuously innovate and strive for optimal resource use over
the life cycle of the products we manufacture. The Company has sustainable processes in place to recycle the damaged products
and waste, post-completion of the manufacturing life cycle. As part of our initiative towards reducing our GHG emissions over our
product life cycle, we have migrated towards natural gas in both Industrial Ceramics & Bonded Abrasives and promote renewable
energy consumption through the installation of solar energy at our plant locations. We have estimated our carbon footprint and
net-zero strategy by engaging with CII. We are further planning to undertake a life cycle assessment of our major products.
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.
Pollution Control Board (PCB). Our authorised vendors are responsible for recycling or reusing the waste whenever possible, thereby
minimising the amount of waste that goes to landfills or incinerators. However, in instances where certain waste cannot be feasibly
reintroduced into the circular economy, we make sure that it is properly disposed of through either incineration or safe landfills.
Please refer answer to “Essential Indicators, Sl. No. 4” for EPR compliance details.
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
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.
Our office space is equipped with elevators, accessible restrooms, and adjustable chairs to accommodate employees with disabilities.
In addition, the majority of our plants also have facilities in place to support employees with disabilities.
Disabled employees who are part of various business units have been mapped with roles that can be performed with ease and based
on this assessment, further evaluation is done to identify roles that can be performed remotely/home. Present work locations of
differently abled employees are accessible to them. Efforts are in progress to prepare other locations also accessible to our differently-
abled employees.
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, covered as part of Diversity and Inclusion Policy under Right Path. CUMI is an equal opportunity employment provider. The
Company encourages inclusive growth and supports equal employment opportunities for all job applicants and prospective
employees, without discrimination about sex, caste, community, religion, age, disability, sexual orientation etc. Discrimination based
on caste, colour, religion, or gender is considered a strict offence against the Company’s principles. Equality of opportunity and merit
is the sole criteria for selection.
5. Return to work and Retention rates of permanent employees and workers that took parental leave.
To ensure that all risks related to work-related hazards are identified and managed, a risk register is maintained. This register covers all
the potential risks that have been identified during the HIRA and REBA assessments, and is updated regularly to reflect any changes or
new risks that may arise. By maintaining a comprehensive risk register, the organisation can effectively monitor and manage all risks
related to occupational health and safety, and take appropriate measures to mitigate these risks and prevent accidents or injuries in
the workplace.
c. Whether you have processes for workers to report the work-related hazards and to remove themselves from such risks. (Y/N)
e actively promote a culture of reporting near-miss incidents/unsafe act among our employees through various digital platforms
W
(safety tree). These incidents are analysed from a central repository to identify potential hazards and take appropriate corrective
measures. Our sites have well-defined procedures in place for reporting work-related hazards, injuries, unsafe conditions, and unsafe
acts. By encouraging reporting and maintaining strict procedures for identifying and reporting incidents, we can effectively manage
and mitigate risks related to occupational health and safety across our organisation. We also formulated safety meetings for each
plant comprising of workers & management representatives. The forum provides an avenue to workers to raise any work-related
hazards, and implement corrective actions.
d. Do the employees/workers of the entity have access to non-occupational medical and healthcare services? (Yes/No)
Y es, all employees/workers are covered under the health insurance scheme. Regular Annual Health check-up for employees/workers
at external reputed hospitals/diagnostic centres for checking both occupational & non-occupational medical tests are provided.
11. Details of safety related incidents
12. Describe the measures taken by the entity to ensure a safe and healthy workplace.
The safety and health of employees are of utmost importance for the Company, and we have implemented a comprehensive safety
management system to ensure a safe working environment at all our factory locations. The measures are summarised below:
• Company has implemented ISO 45001 PDCA to continuously improve our health and safety management system.
• Safety hazards: we have identified all the potential risks and hazards that can emerge from our business operations through
internal and external safety audits.
• Risk mitigation measures have developed health and safety policies, machinery and equipment safety provisions, only authorised
entry to hazard areas, and supply of personnel protective equipment.
• Safety SOPs covering procedures to adhere to safe work practices.
• Training and awareness: monthly meetings by the site head and plant safety specialist with all employees on safe work place
practices, potential hazard, worker behaviour and PPEs.
t each unit, we have appointed a safety officer who is responsible for monitoring workplace safety. The safety office at each
A
site reports to the Corporate Safety head. We have also established safety committees comprising of workers and management
representatives to oversee safety practices and raise concerns regarding any work-related hazards. We actively promote a culture of
reporting near-miss incidents/unsafe act among our employees through various digital platforms (safety tree). To prioritise safety at
the management level, the Board reviews safety tracks and corrective actions as the first item in each Board meeting.
In the event of an accident, we conduct a root-cause analysis and take corrective actions to prevent future incidents. We also provide
safety training to all employees before they enter the plant premises, and implement behavior-based safety training to install safety
practices as a culture among our workforce. Additionally, we conduct Hazard Identification and Risk Assessment (HIRA) and working
condition assessments based on the Rapid Entire Body Assessment (REBA) model at select units to identify potential hazards and
improve working conditions for employees.
To effectively manage and mitigate risks related to occupational health and safety, we maintain a risk register that covers all potential
risks identified during the HIRA and REBA assessments. By promoting a culture of reporting near-miss incidents and maintaining strict
procedures for identifying and reporting hazards and unsafe conditions, we can effectively manage and mitigate risks across our
organisation.
We have also participated in the best safety practices competition and won awards for our safety practices, which is a testament to
our commitment to ensuring the safety and well-being of our employees.
13. Number of Complaints on the following made by employees and workers.
Category % of the plants and offices that were assessed (by entity or statutory authorities or third parties)
Health and safety practices 100
Working Conditions 100
Note: Please refer to the footnote of Sl. No. 13
a) Some of our plants were inspected/audited by safety experts from external agencies like National Safety Council-Kerala Chapter
& Dept of Factories & Boilers, Government of Kerala for Safety Award Assessment.
b) All Major plants of EMD underwent ISO 45001-2018 in March 2023 for Recertification audit and were recommended for
Certification.
c) All our EMD plants are inspected annually by Dept of Factories & Boilers, Government of Kerala and Electrical Inspectorate as
per statutory requirements.
d) Regular third-party inspections by competent person approved by the Dept of Factories & Boilers, Government of Kerala for all
lifting tools & Tackles, Air Compressors etc are done and certificate of fitness maintained by respective plants.
e) Periodic inspection by local factory inspectors/their representatives were conducted at all other units.
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.
Please refer to Essential Indicator number 12 for information regarding the steps taken by our organisation to ensure a safe and healthy
workplace. ISO 45001:2018 Occupational Health and Safety (OHS) Management Systems have been successfully implemented and
verified by authorised bodies. The process of ISO 45001 includes Plan-Do-Check-Act (PDCA) methodology, which involves identifying
risks, conducting hazard analysis, and developing risk mitigation plans with both passive and active measures. Standard Operating
Procedures (SOPs) have been developed and communicated to employees through training programs. Individual department heads
are responsible for implementing the OHS Management System, while OHS committees have been constituted at each site to
supervise and audit the system’s implementation.
We actively encourage our employees to report any instances of unsafe acts or near-misses through our safety digital platform. An
OHS dashboard has been developed and regularly reviewed by the plant head, providing a clear picture of the OHS performance at
each site. A tracking mechanism has been established to monitor the OHS management system’s effectiveness and ensure compliance
with the ISO 45001:2018 standard. To identify potential unsafe practices, we have implemented a safety tree that provides valuable
insights into incidents and helps us to take appropriate corrective actions. We also take into account the inputs from the safety tree to
identify any potential risks and implement corrective actions at the respective locations to ensure a safe working environment. Some
of our day-to-day activities to reduce accidents are listed below:
• Personal Protective Equipment compliances. The Company provides all necessary PPEs to employees and insists on wearing
them inside the factory.
• Regular Safety related Training Programmes - classroom, online, shopfloor talk, mock drills etc., are carried out to ensure a safe
& healthy workplace.
• Improving Plant safety through planned investment in technology upgrades to reduce manual activities identified as risky,
improve the environmental & plant ambience and improve working conditions inside the plant are undertaken in a programmed
manner.
• Emergency Mock drills are conducted to create awareness among workmen at periodic intervals.
• Continuous improvements like Kaizen, a suggestion scheme focusing on safety is undertaken to make the plant more safe place
to work.
• Safety studies like HAZOP, HAZID, What-If are conducted to improve the safety systems inside the plant.
• First Aid Training are imparted to employees through external and internal training programs.
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).
All employees are covered through the Employee Deposit Linked Insurance as part of the Provident Fund scheme. The Company
provides coverage for all its workers in accordance with the regulations stated in the Factories Act. Additionally, all the contractors we
hire are covered by ESI scheme. As per the Employee Deposit Linked Insurance scheme, the family will continue to get the last drawn
salary of the employee up to 48 months and continued health insurance coverage for 2 years.
2. Provide the measures undertaken by the entity to ensure that statutory dues have been deducted and deposited by the value
chain partners.
All our payment process is fully digitalised and integrated to the GST system. In order for payment to be processed, the service
provider must submit proof of remittance from the previous month along with their invoice. Failure to provide this proof will result in
their service payment being withheld, until the compliances are met.
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:
Category Total no. of affected employees/workers No. of employees/workers that are rehabilitated
and placed in suitable employment or whose family
members have been placed in suitable employment
FY 22-23 FY 21-22 FY 22-23 FY 21-22
(Current Financial Year) (Previous Financial Year) (Current Financial Year) (Previous Financial Year)
Employees Nil
Workers Nil
4. Does the entity provide transition assistance programs to facilitate continued employability and the management of career
endings resulting from retirement or termination of employment? (Yes/No)
No
5. Details on assessment of value chain partners
Aspect % of value chain partners (by value of business done with such partners) that were assessed
Health and safety practices None
Working Conditions None
We have not conducted any assessment of our value chain partners in the previous fiscal year on employee well-being such as SHE
and working conditions. However, we intend to conduct such audits as part of our ESG goals in the near future.
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.
Not applicable (Please refer answer to “Leadership Indicator Sl. No. 5“
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.
We place a strong emphasis on stakeholder engagement as a means of delivering relevant services to the market. We believe that
responsiveness to stakeholder requirements is fundamental to our success, as reflected in our Corporate Values & Beliefs of Integrity,
Passion, Quality, Respect, and Responsibility.
The key stakeholders include shareholders and investors, employees, customers, suppliers, local communities, regulators, and
government agencies. We have implemented a stakeholder identification process to classify the major stakeholders who have an
impact on our business, as well as the impact our business has on them. To lead our stakeholder engagement efforts, we have
established a Stakeholder Relationship Committee. Our management team regularly engages with key stakeholders, and different
organisational functions are responsible for facilitating consultation with the Board on important stakeholder concerns. The Board
conducts regular reviews of stakeholder engagement activities at least once a quarter.
2. List stakeholder groups identified as key for your entity and the frequency of engagement with each stakeholder group.
Moreover, to achieve the Company’s sustainability target we partnered with third-party agencies to identify the environment and
social ESG materiality and calculate our carbon footprints and GHG mitigation strategies. We also partnered with agencies to assess
maturity levels in this evolving frame work.
3. Provide details of instances of engagement with, and actions taken to, address the of vulnerable/marginalised stakeholder
groups.
The majority of our manufacturing sites are situated within industrial estates. Despite operating in these areas for many years, we
have not negatively impacted the surrounding community. Additionally, all of our contract workers are sourced from marginalised
communities. As described in the previous section, we have implemented CSR programs in the communities surrounding our plant
locations based on their needs. Our CSR initiatives have helped approximately 24,529 individuals in the past fiscal year, with 80
per cent of the beneficiaries belonging to vulnerable or marginalised communities. Additionally, we have made efforts to support
marginalised suppliers by procuring 1 per cent of our annual goods and services from them.
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
Category Current Financial Year 2022-23 Previous Financial Year 2021-22
Total (A) No. employees workers % (B/A) Total (c) No. employees workers % (D/C)
covered (B) covered (D)
Employees
Permanent 936 936 100 921 921 100
Other than permanent 39 39 100 18 18 100
Total Employees 975 975 100 939 939 100
Workers
Permanent 1185 1185 100 1200 1200 100
Other than permanent 3303 3303 100 3513 3513 100
Total Workers 4488 4488 100 4713 4713 100
Note: All our employees have been trained on the spirit of the Murugappa group’s five lights i.e. integrity, quality, passion, respect and
responsibility towards all stakeholders and communities. Awareness campaigns regarding these aspects were held periodically. These
aspects are communicated through notice boards, posters, email communication and regular meetings.
2. Details of minimum wages paid to employees and workers in the following format:
Category FY 2022-23 FY 2021-22
Total Equal to minimum More than Total Equal to minimum More than
wage minimum wage wage minimum wage
No. %B/A No. (C) %C/A No. %(E/D) No. %(F/D)
Employees
Permanent
Male 864 - - 864 100% 851 - - 851 100%
Female 72 - - 72 100% 70 - - 70 100%
Other than permanent
Male 35 - - 35 100% 13 - - 13 100%
Female 4 - - 4 100% 5 - - 5 100%
Workers
Permanent
Male 1172 - - 1172 100% 1188 - - 1188 100%
Female 13 4 31% 9 69% 12 - - 12 100%
Other than permanent
Male 3036 2757 91% 279 9% 3197 2707 85 483 15%
Female 267 251 94% 16 6% 316 270 85 46 15%
Note: We follow minimum wages act and ensure that all our employees and workers are paid wages that is equal or exceeding the
minimum wage prescribed by the law. All of our employees are paid more than minimum wages. 99.66 per cent of permanent workers
and 8.9 per cent of other than permanent workers in the last fiscal year received wages higher than the salary as per the Minimum
Wages Act. We ensure the timely disbursement of salaries, and all payments are made through net banking to both contractors and
workers for greater transparency.
Male Female
Number Median remuneration/ Number Median remuneration/
salary/wages of respective salary/wages of respective
category category
Board of Directors (BoD) 7 23.20 1 17
Key Managerial Personnel 3 219 1 71.47
Employees other than BoD and KMP 1859 6.5 59 8.39
Note: 1. The Nomination and Remuneration Committee of the Board will decide the matters related to the remuneration of the Board.
The key result areas of the Board are also decided by the committee and there is an annual evolution programme.
2. Employees who were in employment for the whole of FY 2022-23 considered for this purpose.
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, the Company has appointed HRSPOCS at each site. Employees can reach out to the HRSPOCS for any complaints related to
human rights, discrimination, etc. The Corporate HR will conduct a thorough fact-finding investigation and take appropriate action
based on the findings. The complainant will be informed of any actions taken as a result of the investigation.
Permanent Workers: Unit-level grievance committees are existing at each location. For any sexual Harassment grievance, the Internal
complaints (IC) committee under POSH exists for redressal. Workers can also reach out to the Ombudsman for any whistle-blower
matters.
Other than Permanent workers: Workers can raise their grievance through the contractor. If not resolved, can be escalated to the
Unit HR.
Permanent Employees: A dedicated mail id [email protected] is available to receive and resolve grievances.
Employees can reach out to IC Committee constituted under POSH for Sexual harassment complaints. The whistle-blower channel is
open to all employees for raising grievance or issues with confidentiality.
Other than Permanent Employees: Employees can raise their grievance through the contractor. If not resolved, can be escalated to
the Unit HR.
5. Describe the internal mechanisms in place to redress grievances related to human rights issues.
Employees can reach out to the Ombudsman for any complaints related to human rights, discrimination, etc., under whistle blower
mechanism or even to the Corporate HR/Unit HR. Absolute confidentiality will be maintained for all complaints. Ombudsman can set
up an enquiry to find out the facts and violations, if any. Based on the enquiry report, appropriate action will be taken.
6. Number of Complaints on the following made by employees and workers:
Category FY 2022-23 FY 2022-21
Filled during Pending resolution Remarks Filled during Pending resolution Remarks
the year at end of the year the year at end of the year
Sexual harassment 1 - - 2 - -
Discrimination at workplace Nil - - Nil - -
Child labour Nil - - Nil - -
Forced labour/involuntary labour Nil - - Nil - -
Wages Nil - - Nil - -
Other human related methods Nil - - Nil - -
7. Mechanisms to prevent adverse consequences to the complainant in discrimination and harassment cases.
The Company has several mechanisms in place to prevent discrimination and harassment at workplace. These mechanisms are listed
below.
• We have business Code of Conduct policy that clearly defines our commitment to provide a safe and inclusive work environment
for all employees and stakeholders. We follow the Murugappa five lights, which serve as a framework to guide our decision-
making processes and ensure ethical and responsible business practices.
• Our HR policies specifically aim to eliminate discrimination and harassment in the workplace. These policies are regularly
reviewed and updated as needed to ensure compliance with relevant laws and regulations.
• In order to monitor and ensure compliance with our HR policies, we conduct periodic audits of our individual plants. These
audits are conducted by our Corporate HR team to identify any gaps or areas of improvement in our HR practices.
• To raise awareness and promote a culture of respect and inclusivity, we conduct regular training and awareness programs on
topics such as Prevention Of Sexual Harassment (POSH) and workplace HR policies. We believe that these mechanisms work
together to prevent adverse consequences to complainants in cases of discrimination and harassment and promote a safe and
respectful work environment for all.
If an employee feels he/she has experienced any form of discrimination, they can confidentially contact the Ombudsman/HR for
assistance. The Ombudsman will conduct a thorough fact-finding investigation and take appropriate action based on the findings. The
complainant will be informed of any actions taken as a result of the investigation.
The Company has a gender-neutral policy to prevent sexual harassment in the workplace, and an Internal Complaints Committee (ICC)
has been established to lead awareness campaigns on creating a safe and harassment-free environment. The ICC meets quarterly to
review the progress of these programs. Any employee who has been wronged can file a complaint with the ICC, and all complaints will
be investigated with the utmost confidentiality. The committee will make appropriate decisions based on the investigation's findings.
8. Do human rights requirements form part of your business agreements and contracts?
Yes, Murugappa group’s five lights i.e. Integrity, Quality, Passion, Respect and Responsibility forms integral part of all our businesses.
Whereever possible all our business agreements and contracts will contain clauses related to compliance with respect to human
rights.
9. Assessments for the year
Category % of your plants and units assessed by (entity or statutory authorities or third party)
Child labour 100
Forced/involuntary labour 100
Sexual harassment 100
Discrimination at workplace 100
Wages 100
Others- please specify None
Note: We have various HR policies to prevent and protect human rights of our employees and workers such as (1) Human rights policy
- Non-discrimination Policy, Minimum Wage Policy, POSH Policy, Privacy Policy, Child Labour Policy,forced and involuntary labour etc.
(2) Business code of conduct.
10. Provide details of any corrective actions taken or underway to address significant risks/concerns arising from the assessments
at Question 9 above.
We have developed a process which respects human rights of our value chain starting from raw material receipt to processing and
dispatch. Majority of activities involved in our operations involve unskilled, semi-skilled, skilled and advanced level resources. Through
awareness sessions and training on human rights, we eliminate human rights grievances. There have been no grievances or complaints
received in regards to human rights violations that require modifications of the existing procedures in place to address the grievances.
The Company’s grievance redressal mechanisms for human rights violations have always been efficient and comprehensive upholding
human rights principles.
Leadership Indicators
1. Details of a business process being modified/introduced as a result of addressing human rights grievances/complaints.
There have been no grievances or complaints received in regards to human rights violations that required modifications of the existing
procedures in place to address the grievances. The Company’s grievance redressal mechanisms for human rights violations have been
efficient and comprehensive upholding human rights principles.
2. Details of the scope and coverage of any Human rights due-diligence conducted.
Please refer Sl. No. 9 of essential indicators.
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?
Yes, most of our offices and plants are accessible to differently abled visitors. In other locations steps are being taken to make them
also accessible.
% of value chain partners (by value of business done with such partners)
that were assessed
Sexual Harassment Murugappa group’s five lights i.e. Integrity, Quality, Passion, Respect and Responsibility forms
Discrimination at workplace integral part of all our businesses. Whereever possible all our business agreements and
Child Labour contracts will contain clauses related to compliance with respect to human rights. Nonetheless,
there has been no official assessment of the value chain partners.
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 answer of Sl. No.4 of Leadership Indicator.
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
3. Provide details of the following disclosures related to water in the following format:
Parameter FY 2022-23 FY 2021-22
(Current Financial Year) (Previous Financial Year)
Water withdrawal by source (in Kilolitres)
(i) Surface water (KL) 93079 102841
(ii) Groundwater (KL) 153434 166185
(iii) Third party water (KL) 128716 129369
(iv) Seawater/desalinated water - -
(v) Others - -
Total volume of water withdrawal (in KL) (i + ii + iii + iv + v) 375229 398395
Total volume of water consumption (in KL) 375229 398395
Water intensity per rupee of turnover
15 18
(Water consumed/turnover) KL/₹ million
Indicate if any independent assessment/evaluation/assurance We are ISO 14001 certified, water consumption and its
has been carried out by an external agency? (YES/NO) management are integral parts of our environmental
If yes, name of the external agency management system. As an ISO 14001-certified organisation,
we have implemented comprehensive measures to monitor and
manage our water consumption and minimise the environmental
impact of our operations. These efforts are in line with the
requirements of the ISO 14001 standard, which encompasses
various aspects of environmental management, including water
management.
While we have not engaged in an exclusive external water
audit assessment, our ISO 14001 certification underscores our
dedication to responsible water management and environmental
stewardship as a whole.
Note: All of our sites have valid Consent to Operate (CTO) under the Water Prevention and Control Act, 1974. To accurately monitor
the water flow, we have installed flow meters at the inlet and outlet lines, and these meters are regularly calibrated to maintain their
accuracy. Our absolute water consumption for the reporting fiscal year has been reduced by 6 per cent and we have achieved an
intensity water consumption reduction of 17 per cent from FY 2021-22.
4. Has the entity implemented a mechanism for Zero Liquid Discharge? If yes, provide details of its coverage and implementation.
We have obtained valid Consent to Operate (CTO) under the Water Prevention and Control Act, 1974, for all our sites. In order to
ensure precise measurement of water flow, we have installed flow meters at both the inlet and outlet lines. These flow meters
undergo regular calibration to uphold their accuracy and reliability. Our wastewater generation is well within the consented levels.
We are taking steps to decrease freshwater usage by implementing water reuse practices. This is achieved through the installation of
Sewage Treatment Plants (STPs) and Effluent Treatment Plants (ETPs) at each plant location. These systems enable the Company to
reuse and recycle water and utilise it again within the plant premises such as for process reuse, gardening, flushing etc. Thus, CUMI
has implemented a mechanism for zero liquid discharge (all our plants adopt complete reuse/recycling treated wastewater in the
plant and no wastewater is discharged into the open drains).
5. Please provide details of air emissions (other than GHG emissions) by the entity:
Parameter Please specify unit FY 2022-23 FY 2021-22
NOx µg/m3 26 27
SOx µg/m3 17 14
Particulate matter µg/m3 35 28
Persistent organic pollutants* - - -
Volatile organic compounds* - - -
Hazardous air Pollutants* - - -
Others -Please specify - - -
Indicate if any independent assessment/
evaluation/assurance has been carried out by an Ambient air quality monitoring is conducted through
external agency? (YES/NO) - third-party NABL-accredited laboratories and
submitted to Pollution Control Board
If yes, name of the external agency
Note: The data provided pertains to annual average ambient air quality at our plant locations, which is monitored periodically through
NABL-accredited third-party laboratories. Our monitoring is conducted to ensure that the National Ambient Air Quality Standards
(NAAQS) are met, and to prevent harm to our workers and the surrounding community. Please note that our consent to operate does
not require us to monitor PoP, VOCs, and hazardous air pollutants.
6. Provide details of greenhouse gas emissions (Scope 1 and Scope 2 emissions) & its intensity:
8. Provide details related to waste management by the entity, in the following format:
Parameter FY 2022-23 FY 2021-22
(Current Financial Year) (Previous Financial Year)
Total Waste generated (in Metric Tonnes)
Plastic waste (A) 473 373
E-waste (B) 4 2
Bio-medical waste (C) 2 0
Construction and demolition waste (D) 25 40
Battery waste (E) 15 10
Radioactive waste (F) 0 0
Other Hazardous waste. Please specify, if any. (G) 125 112
Other Non-hazardous waste generated (H). Please specify, if any.
13188 12169
(Break-up by composition i.e. by materials relevant to the sector)
Total (A+B + C + D + E + F + G + H) 13832 12706
For each category of waste generated, total waste recovered through recycling, re-using or other recovery operations
(in metric tonnes)
Category of waste
(i) Recycled 5161 5499
(ii) Re-used 307 200
(iii) Other recovery operations 0 0
Total 5468 5699
For each category of waste generated, total waste disposed by nature of disposal method (in metric tonnes)
Category of waste
(i) Incineration 13 3
(ii) Landfilling 24 10
(iii) Other disposal operations 8328 6995
Total 8364 7008
Indicate if any independent assessment/evaluation/assurance Most of our plants have implemented an environmental
has been carried out by an external agency? (Y/N) If yes, name of management system and have undergone an external audit by
the external agency. a certification body to achieve ISO 14001 certification. As part of
waste management, proper procedures are practiced to ensure
appropriate handling and disposal of waste materials through
PCB-authorised vendors.
9. 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 wastes.
We have adopted various waste management practices to ensure proper handling and disposal of different types of waste. Our waste
management strategy focuses on reducing the usage of hazardous and toxic chemicals in our products and processes, as well as
effectively managing the waste generated.
• aste Inventory Process: We have implemented a waste inventory process in accordance with ISO 14001 standards. This
W
process allows us to track and document the types and quantities of waste generated in our facilities.
Segregation and Storage of Hazardous Waste: We strictly segregate and store hazardous waste as per the guidelines outlined
•
in the Hazardous Waste Management (HWM) 2016 regulations. This ensures that hazardous waste is properly isolated and
handled to prevent any adverse environmental impact.
• E-Waste Segregation and Disposal: Electronic waste (e-waste) is segregated separately and disposed of through authorised
vendors who specialise in e-waste recycling and proper disposal methods. This helps us adhere to the regulations and prevent
any potential harm from electronic waste.
• Plastic Waste Management: To manage plastic waste, we follow the guidelines provided by the Central Pollution Control Board
(CPCB) and the Extended Producer Responsibility (EPR) framework. This includes proper collection, segregation, and disposal
of plastic waste through authorised recycling channels. Our Abrasives Business is obligated under EPR regulation and we have
achieved the target to collect and recycle 313 metric tons of plastic packaging waste through third-party services this fiscal year.
• Management of Other Solid Waste: Solid waste generated in our establishments is collected and categorised into two parts: wet
waste and dry waste. Wet waste, such as canteen waste, is sent for composting, while other solid waste is disposed of through
authorised recycling vendors to ensure proper waste management practices.
10. 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, please specify details in the following format:
S. Location of Type of operations Whether the conditions of environmental approval/clearance are being
No. operations/offices complied with? (Y/N)
If no, the reasons thereof and corrective action taken, if any.
1 Tiruvottiyur Chennai Unit Bonded abrasives The facilities we operate do not fall within notified ecologically sensitive
locations such as Wildlife Sanctuaries or Biosphere Reserves. However, it
is important to note that our Tiruvottiyur facility is situated near a Coastal
Regulation Zone (CRZ) area. However, this facility was established prior to
the CRZ notification, 1991.
11. Details of environmental impact assessments of projects undertaken by the entity based on applicable laws, in the current
financial year.
No Environmental impact assessments was conducted for the current financial year.
12. 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, in the following format:
S. No. Specify the law/regulation/ Provide details of the Any fines/penalties/action taken by Corrective action
guidelines which was not non- compliance regulatory agencies such as pollution taken, if any
complied with control boards or by courts
Our business units operate under the purview of the Environmental Protection Act and hold valid Consent to Establish and Consent
to Operate certificates from Pollution Control Boards. These certificates are regularly renewed as per the Board's directives. To
ensure compliance with environmental regulations, we regularly submit environmental monitoring reports and update our practices
in accordance with new guidelines or regulations. We have maintained a clean record with no instances of violation in the previous
fiscal year.
Leadership Indicators
1. Provide a break-up of the total energy consumed (in Joules or multiples) from renewable and non-renewable sources, in the
following format:
Parameter FY 2022-23 FY 2021-22
(Current Financial Year) (Previous Financial Year)
From renewable sources (Tera Joules)
Total electricity consumption (A) 144 150
Total fuel consumption (B) 0 0
Energy consumption through other sources (C) 0 0
Total energy consumed from renewable sources (A+B+C) 144 150
From non-renewable sources (Tera Joules)
Total electricity consumption (D) 585 598
Total fuel consumption (E) 612 505
Energy consumption through other sources (F) 0 0
Total energy consumed from non-renewable sources
1197 1103
(D+E+F)
6. 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, as per the following format:
Overall, our commitment to business continuity and disaster management planning is an essential part of CUMI's culture. We
understand that by being prepared, we can protect our employees, assets, and communities while ensuring running our business
operations.
8. 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?
As a manufacturing Company, there are several aspects that can have a significant adverse impact on the environment throughout
the value chain. Some of these aspects include raw material extraction, transportation, production processes, packaging, and waste
management.
To mitigate these impacts, the Company has taken several measures. We have identified material areas to improve our environmental
performance. We have also implemented various energy-efficient technologies and processes to reduce our carbon footprint,
including the use of renewable energy sources such as solar power.
In addition, we are planning to establish sustainable supply chain practices by working with suppliers who prioritise environmentally
friendly practices. We also have a robust waste management system that focuses on reducing waste, reusing materials, and recycling
wherever possible.
Moreover, we regularly conduct mock drills to assess our preparedness for any potential disasters, and we have developed SOPs and
procedures to respond to any environmental incidents that may occur. Our employees are continuously being trained on environment,
health and safety.
9. Percentage of value chain partners (by value of business done with such partners) that were assessed for environmental
impacts.
At present, we have not assessed our value chain partners for environmental impacts, but we acknowledge its significance and
commit to conducting them in the future. We believe in engaging with our partners to reduce our overall environmental impact and
ensure they follow sustainable practices.
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.
CUMI is an active member of several national and international (about 20) trade and industry chambers and 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
S. No. Name of the trade and industry chambers/associations Reach of trade and industry chambers/
associations (State/National)
1 Confederation of Indian Industry National
2 Indian Ceramic Society National
3 National Safety Council-Kerala Chapter State
4 Kerala Management Association State
5 Madras Management Association State
6 South India Chamber of Commerce National
7 SICMA - Europe International
8 Indo-German Chamber of Commerce International
9 Indo-Australian Chamber of Commerce International
10 Indian Carbon Society, India National
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.
Leadership Indicators
1. Details of public policy positions advocated by the entity
S. No. Public policy Method resorted for Whether information Whether information Web Link,
advocated such advocacy available in public available in public if available
domain? (Yes/No) domain? (Yes/No)
CUMI is an active member of several national and international trade and industry chambers and associations. As part of these
groups, we provide recommendations and representations to regulators and associations to advance and improve the industrial
climate in India. Additionally, we regularly participate in forums and discussions related to energy security and management, water
and food security, and sustainable business practices to share our views and opinions. However, during the previous fiscal year, the
Company did not engage in any public policy advocacy other than making representations to the consultation papers released by
SEBI and participation in decision making in IRMA and other business/industry association.
Name and brief details SIA Notification Date of Whether conducted by independent Results communicated in
of the project No. notification external agency (Yes/No) public domain (Yes/No)
Not Applicable
2. Provide information on the project(s) for which ongoing Rehabilitation and Resettlement (R&R) is being undertaken by your
entity, in the following format.
4. Percentage of input material (inputs to total inputs by value) sourced from suppliers:
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):
Details of negative social impact identified Corrective action taken
Not Applicable
2. Provide the following information on CSR projects undertaken by your entity in designated aspirational districts as identified
by government bodies:
State Aspirational District Amount spent (In INR)
We have not undertaken any projects in Aspiration Districts in the previous fiscal year and our CSR activities predominantly are
conducted in and around the places of our operations. However, the Company is committed to promoting inclusive growth through
a comprehensive Corporate Social Responsibility (CSR) Policy, which can be viewed at the link https://www.cumi-murugappa.com/
wp-content/uploads/2021/04/CSR-Policy-2021.pdf. In the previous fiscal year, we implemented several projects in the areas of Skill
Development, Women Child and Youth Empowerment, Elderly Care, Health Services, and Sustainability, with a total CSR spend of
₹378.33 Lakhs. These projects have benefitted approximately 24,529 individuals, with 80 per cent of the beneficiaries being from
marginalised or vulnerable communities. Kindly refer the Board’s report containing the details of our CSR projects in detail.
3. a. Do you have a preferential procurement policy where you Considering the nature of our products, the raw material
give preference to purchase from suppliers comprising and other input materials such as power and fuel cannot be
marginalised/vulnerable groups? (YES/NO) sourced from marginalised groups. However, as a Company,
b. From which marginalised/vulnerable groups do you we have implemented a process where we only engage with
procure? suppliers who are marginalised to provide us with manpower
for our various plants. This is done in order to support
c. What Percentage of total procurement (by value) does it
our manufacturing process while also ensuring that these
constitute?
marginalised suppliers are able to earn a livelihood. We have
committed to procuring 1 per cent of our annual goods and
services from these suppliers as part of our commitment to
support marginalised communities.
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:
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.
We believe that commitment to transparency is vital to build trust and credibility with our customers, by demonstrating honesty and
openness in handling complaints.
Customers can communicate their complaints via email or phone calls to the regional salesperson, who will send an immediate
acknowledgment of the complaint via email. The complaint is then registered in the Company's Enterprise Resource Planning (ERP)
system. To ensure efficient resolution of complaints, technical complaints are handled by the quality control team, while commercial
complaints are managed by the Marketing team. The Company has set a target of resolving complaints within 30 days, in cases where
the return of material is necessary for analysis. Through ERP we have streamlined the complaint resolution process by routing the
complaint to the appropriate team and tracking its progress. By centralising complaint management in the ERP system, the Company
ensures that complaints are addressed efficiently and effectively. Further, CUMI manufactures over 20000 SKUs and its product and
solution offerings are spread across varied business segments catering to the needs of almost all user industries cutting across many
sectors. In many cases, the products or solution offerings are customisable and we work with our customers closely to co-create the
solutions. Customer centricity is the top priority for the Company and is one of the strong pillar for its profitable existence close to 7
decades.
2. Turnover of products and/services as a Percentage of turnover from all products/service that carry information about:
5. (a) Does the entity have a framework/policy on cyber security and risks related to data privacy? (Yes/No)
(b) If available, provide a web-link of the policy.
Yes, we have IT Policy covering cyber security and risks related to data privacy. Cyber security risk has been identified as one of
our material aspects under technology risk (please refer to Section A).
As a risk mitigation measure to address cyber security threat, the Company does periodical penetration assessment testing
for all internally and internet facing applications. We have also undertaken, assessment of security risks from usage of public
Wi-Fi and Bluetooth devices. The security threat awareness is periodically published to create awareness among employees
and stakeholders for handling the risk proactively. The security process is included as an important step in the IT policy of the
Company. There is considerable amount of work undertaken on scoping of information specific to the role defined to prevent
any data or information leak, through continuous monitoring on the business-critical IT assets. Considering in some locations
the hybrid mode of work has become the new normal, data security and protection against the risk of phishing, malware attacks
was given priority. As a part of its IT security strategy, the Company during the year in partnership with third party expertise has
done a maturity assessment of its IT & OT platforms and is in the process of developing & implementing a comprehensive cyber
security framework.
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.
Not Applicable. We have not received or faced any issues related to the aspects such as 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 in the previous fiscal year.
Leadership Indicators
1. Channels/platforms where information on products and services of the entity can be accessed (provide web link, if available).
The information on the products and services of the entity can be accessed at
i) https://www.cumi-murugappa.com/abrasives/
ii) https://www.cumi-murugappa.com/emd/
ii) https://www.cumi-murugappa.com/ceramics/ic/
iv) https://www.cumi-murugappa.com/super-refractories/
2. Steps taken to inform and educate consumers about safe and responsible usage of products and/or services.
The Company encourages our customers to prioritise safety by providing instructions (instruction labels) regarding the handling,
storage, use of its products and disposal mandated as per the local laws. Also, in order to promote the safe and responsible usage
of our products, we have made available Material Safety Data Sheets (MSDS) on our website (ex. https://www.cumi-murugappa.
com/ceramics/ic/material-datasheet/). These sheets contain detailed information about the potential hazards associated with our
products and provide guidance on how to handle, store, and dispose of our products in a safe manner. A copy of the MSDS is sent to
Overseas customer with the product despatch which provides guidance on safe & responsible usage.
3. Mechanisms in place to inform consumers of any risk of disruption/discontinuation of essential services.
We use email communication with consumers/channel partners in case of any potential disruptions or discontinuations of essential
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).
Yes, we provide information as per the Legal Metrology- packaging law. Over and above the statutory requirement, information on
the usage of the product including safety aspects are also communicated in the packaging wherever required. The Company conducts
consumer surveys and monitors satisfaction trends periodically. Surveys are often carried out during customer plant visits, allowing
us to gather first hand insights into their experiences with our products and services. No cases of customer data breaches have been
reported in the previous fiscal year.
5. Provide the following information relating to data breaches
(a) Number of instances of data breaches along with impact
No cases of customer data breaches have been reported in the previous fiscal year.
(b) Percentage of data breaches involving personally identifiable information of customers
None.