Statutory Reports Annual Report 2023-24 | 71

Business Responsibility and Sustainability Report

BRSR OVERVIEW

SECTION A – General disclosures

SECTION B – Management and process disclosures

SECTION C – Principle-wise performance disclosure

Principle Principle Principle

1 2 3

Businesses, when engaging in Businesses should provide goods Businesses should respect and
influencing public and regulatory and services in a manner that is promote the well-being of all
policy, should do so in a manner sustainable and safe employees, including those in their
that is responsible and transparent value chains

Principle Principle Principle

4 5 6

Businesses should respect the Businesses should respect and Businesses should respect and
interests of and be responsive to promote human rights make efforts to protect and restore
all its stakeholders the environment

Principle Principle Principle

7 8 9

Businesses, when engaging in Businesses should promote Businesses should engage

influencing public and regulatory inclusive growth and equitable with and provide value to their
policy, should do so in a manner development consumers in a responsible
that is responsible and transparent manner
72 | Thirumalai Chemicals Limited

HIGHLIGHTS

Principle 1: Principle 2: Principle 3:

Ethics Product Stewardship Employee well-being

y 100% of the BoD, KMP’s, y 7.14% R&D investments utilised y 100% of our Employees and
E m p l o y e e s a n d Wo r ke r s to Improve Environmental and Workers have Health Insurance
underwent trainings on 9 NGRBC Social Impacts of products. and Accident Insurance
principles.
y 91% of our inputs are sustainably y 85% Employees and 75%
y NIL monetary/non-monetary sourced. Workers provided with Skill
proceedings or actions by the Upgradation training.
regulatory enforcement agency/ y 16.7% of our packaging material
judicial institutions is reused in FY23-24 y 92.5% and 91% of our plants and
offices are assessed for Health
y 100% value chain partners & Safety practices and Working
underwent Safety Protocol and Conditions respectively.
Material handling trainings

Principle 4: Principle 5: Principle 6:

Stakeholder Engagement Human Rights Environment

y Ro b u st Mechanism y 100% of Employees and y 493200 GJ of Energy utilised

to identify and engage with Workers provided with Human in FY 23-24
stakeholders. Rights training.
y 741832 Kilo Litre of Water
y N IL complaints of POS H , Consumption
Child Labour, Forced Labour,
Discrimination at workplace, y 101475 Mt CO2e of Scope
Wages issue for the reporting 13050 Mt CO2e of Scope
period FY23-24 2 and 166216 Mt CO2e
of Scope 3 Greenhouse gases
Emitted in FY23-24

Principle 7: Principle 8: Principle 9:

Public Policy Advocacy CSR Initiatives Customer Relations

y 0 cases filed regarding Unfair y 66% input material directly y 0 Voluntary or Forced Recalls
trade practices, Irresponsible sourced from MS M E /Small
advertising or Anti-Competitive Producers y 0 Incidents of Data Breach
behaviour.
y 89.5% input material sourced
y 5 chambers and associations in from within India
which TCL actively participates.
 Statutory Reports Annual Report 2023-24 | 73

SECTION A – GENERAL DISCLOSURES

I. Detailed of the listed entity
1. Corporate Identity Number (CIN) of the Listed Entity L24100MH1972PLC016149
2. Name of the company THIRUMALAI CHEMICALS LIMITED
3. Year of incorporation 25/05/1972
4. Registered office address Thirumalai House, Road No.29, Sion-East, Mumbai-400 022
5. Corporate address Spic House, 5th Floor, 88, Mount Road,Guindy, Chennai -
600032
6. E-mail [email protected]
7. Telephone Tel: +91 22 2401 7841 / 53 / 61
8. Website www.thirumalaichemicals.com
9. Financial year for which reporting is being done 2023-24
10. Name of the Stock Exchange(s) where shares are BSE Limited and National Stock Exchange of India Limited
listed
11. Paid-up Capital `10,23,88,120
12. Name of contact details of the person who may be Rajagopalan T (Company Secretary & Compliance office)
contacted in case of any queries on the BRSR Report Tel: +91 22 2401 7841 / 53 / 61
[email protected]
13. Reporting boundary Standalone
14 Name of assurance provider The report is not assured by an external assurance provider
15 Type of assurance obtained Not applicable

II. Products and Services

16. Details of business activities (accounting for 90% of the turnover):
S.
Description of Main Activity Description of Business Activity % Of Turnover of the entity
No.
1 Manufacture of basic Manufacturing, distribution, sales and marketing 100%
chemicals except fertilisers of basic chemicals except fertilisers and nitrogen
and nitrogen compounds compounds

17. Products/Services sold by the entity (accounting for 90% of the entity’s Turnover):
S.
Product/Service NIC Code % Of total Turnover contributed
No.
1 Phthalic Anhydride and Derivatives, Malic Acid, Fumaric Acid 2411 87%

III. Operations
18. Number of locations where plants and/or operations/offices of the entity are situated:
TCL has its:
i. Registered office in Mumbai
ii. Factories at Ranipet, Ranipet District, Tamil Nādu and Dahej, Gujarat
iii. Tank Farms at Walaja, Ranipet District, and Royapuram, Chennai, Tamil Nadu.
iv. Marketing offices at Chennai & Delhi
TCL has overseas subsidiaries in Malaysia, Singapore, the USA, the Netherlands & the UK.
Location Number of Manufacturing Units Number of Offices Total
National 2 3 5
74 | Thirumalai Chemicals Limited

19. Markets served by the entity:

a. Number of locations
Locations Number
National (No. of States) The Company sells its products in all the 28 states and 8 Union territories in the country
International (No. of Countries) The Company sells its products in 4 continents (US, Europe, Asia, Middle East, Africa)

b. What is the contribution of exports as a percentage of the total turnover of the entity?
For FY 23-24, the exports contribution was 9%
c. A brief on types of customers
Phthalic Anhydride is a white crystalline substance used in the manufacture of plasticizers, pigments, dyes and resins.
It is notably consumed by the Phthalate plasticiser industry as a key component and is used in the production of flexible plastic
products like wire & cable applications, hoses, pipes, coated fabrics, roofing membranes and swimming pool liners.
Phthalic Anhydride is also employed in the manufacturing of unsaturated polyester resins, (UPR), which are commonly mixed
with glass fibres to create fiberglass reinforced plastics. The materials find significant applications in the construction, marine
and transportation industries.
PA-based alkyd resins plays a crucial role in the formulation of paints and lacquers utilised in architectural, machinery, and
furniture applications.
TCL is the sole manufacturer of Malic Acid in India and it is used predominantly in food and beverage application with customers
including global companies like Perfetti, Symrise etc. Fumaric acid is used in the food industry and pharmaceutical industry.

IV. Employees
20. Details as at the end of Financial Year:
a. Employees and workers (including differently abled):
S. Male Female
Total
No. Particulars
(A) No. (B) % (B / A) No. (C) % (C / A)

EMPLOYEES
1. Permanent (D) 509 461 91% 48 9%
2. Other than Permanent* (E) 27 25 93% 2 7%
3. Total employees (D + E) 536 486 91% 50 9%
WORKERS
4. Permanent (F) 28 28 100% 0 0
5. Other than Permanent* (G) 734 667 91% 67 10%
6. Total workers (F + G) 762 695 91% 67 10%
* The Other than Permanent category of Employees & Workers are either Employed through contractor (Benefits as per the contractor) or Fixed
term appointment on contract directly by TCL based on requirement

b. Differently abled Employees and workers:

S. Male Female
Total
No. Particulars
(A) No. (B) % (B / A) No. (C) % (C / A)

DIFFERENTLY ABLED EMPLOYEES

1. Permanent (D) 0 0 0 0 0
2. Other than Permanent (E) 1 1 100 0 0
3. Total differently abled employees (D + E) 1 1 100 0 0
DIFFERENTLY ABLED WORKERS
4. Permanent (F) 0 0 0 0 0
5. Other than permanent (G) 0 0 0 0 0
6. Total differently abled workers (F + G) 0 0 0 0 0
 Statutory Reports Annual Report 2023-24 | 75

21. Participation/Inclusion/Representation of women

Total No. and percentage of Females

(A) No. (B) % (B / A)
Board of Directors 11 2 18%
Key Management Personnel 3 1 33%

22. Turnover rate for permanent employees and workers

FY 23-24 FY 22-23 FY 21-22
Male Female Total Male Female Total Male Female Total
Permanent Employees 12% 8% 20% 26% 13% 39% 19% 15% 34%
Permanent Workers 3.5% - 3.5% 3% - 3% 18% - 18%

V. Holding, Subsidiary and Associate Companies (including joint ventures)

23. (a) Names of holding / subsidiary / associate companies / joint ventures

Does the entity indicated at

Name of the holding / Indicate whether holding/
S. % Of shares held by listed column A, participate in the
subsidiary / associate Subsidiary/ Associate/
No. entity Business Responsibility initiatives
companies / joint ventures (A) Joint Venture
of the listed entity? (Yes/No)
1. TCL Intermediates Private Subsidiary of TCL 100% Yes,
Limited
The Company’s Code of
2. Optimistic Organic sdn bhd. Subsidiary of TCL & TCL (15.80%) Conduct provides guidelines
Cheminvest Cheminvest (84.20%) to the company along with all
3. Lapiz Europe Subsidiary of Cheminvest 100% its subsidiaries for conducting
4. TCL Global BV Subsidiary of TCL/ 100% business in an ethical,
Holding of TCL INC. responsible, and accountable
5. TCL INC. Subsidiary of TCL Global 100% manner. The Company
BV/ Holding entity of TCLS encourages its subsidiaries to
LLC carry out Business Responsibility
Initiatives to the extent that they
6. TCL Specialties LLC Sole Member Corporation 100%
are material in relation to the
(TCLS LLC)
subsidiaries’ business activities
and operating region.

VI. CSR
24. (i) Whether CSR is applicable as per section 135 of Companies Act, 2013: (Yes/No)
Yes, CSR is applicable for Thirumalai Chemicals Limited as per section 135 of Companies Act, 2013.
(ii) Turnover (in `) – 2,02,483 lakhs
(iii) Net worth (in `) – 98,395 lakhs
76 | Thirumalai Chemicals Limited

VII. Transparency and Disclosure Compliances

25. Complaints/Grievances on any of the principles (Principles 1 to 9) under the National Guidelines on Responsible
Business Conduct:
FY 23-24 FY 22-23
Stakeholder Grievance Redressal Number of Number of
group from Mechanism in Place (Yes/ Number of complaints Number of complaints
whom No) (If yes, then provide complaints pending complaints pending
complaint is web-link for grievance Remarks Remarks
filed during resolution at filed during resolution at
received redress policy) the year close of the the year close of the
year year
Communities Yes 0 0 - 0 0 -
Shareholders Yes 8 0 All 0 0 -
Complaints
were duly
addressed
and closed
Employees & Yes 0 0 - 0 -
Workers
Customers Yes 15 0 All 19 All
Complaints Complaints
were duly were duly
addressed addressed
and closed and closed
Value Chain Yes 0 0 - 0 0 -
Partner
Others Yes 0 0 - 0 0 -
Weblink https://thirumalaichemicals.com/wp-content/uploads/2023/05/STAKEHOLDER-GRIEVANCE-REDRESSAL-
POLICY.pdf

26.Overview of the entity’s material responsible business conduct issues. Please indicate material responsible business conduct
and sustainability issues pertaining to environmental and social matters that present a risk or an opportunity to your business,
rationale for identifying the same, approach to adapt or mitigate the risk along-with its financial implications, as per the following
format
In FY 22-23 , we carried out an extensive materiality assessment to identify and understand the material topics that directly or
indirectly impacted our organisation and business operations within the ESG framework. Through this detailed analysis, we were
able to focus our efforts on the most relevant sustainability issues for our stakeholders and strategic partners, aligning with our
goals and targets.
Our approach, which prioritised stakeholder input, both external and internal, is seen as a balanced and holistic methodology
to arrive at the topics most critical to the organisation. We identified key stakeholder groups vital to the entity and conducted
surveys, incorporating ESG-related criteria. Additionally, we performed peer-benchmarking and analysed various ESG Rating
agencies and standards within our sector to identify the specific materiality topics of importance to us. External Stakeholders
included customers, suppliers, investors, and community representatives, while internal stakeholders comprised employees
across different levels and departments. We designed comprehensive surveys that addressed a range of ESG-related topics
such as environmental impact, social responsibility, ethical governance, and economic performance. These surveys were tailored
to gather insights specific to each stakeholder group’s perspectives and expectations. Once the surveys were completed, we
analysed the data to identify the materiality topics. These findings were then mapped onto a materiality matrix., which visually
represented the importance and impact of each material topic. This matrix helped us prioritise and categorise issues into high,
medium, and low priority categories. The ESG materiality topics and matrix was presented by the senior management to the
Board of Directors, highlighting key ESG issues based on stakeholder input and strategic priorities. Following a detailed review
and discussion, the Board validated and firmed up the material topics, ensuring they accurately reflect the company’s impact
and objectives.
The comprehensive materiality assessment proved instrumental in establishing our ESG goals and targets. By identifying
and prioritising key sustainability issues through this assessment, we were able to set specific and impactful targets that
directly address the most relevant concerns for our stakeholders and business operations. Overall, integrating surveys and
 Statutory Reports Annual Report 2023-24 | 77

interviews from both external and internal stakeholders allowed us to conduct a robust materiality assessment that informed
our sustainability strategy and target-setting process effectively. This approach ensured that our ESG initiatives were aligned
with stakeholder expectations and industry best practices, leading to measurable progress and positive outcomes in our
sustainability journey.

Financial
implications
Indicate
of the risk or
Material whether
S. Rationale for identifying the risk / In case of risk, approach to adapt or opportunity
issue risk or
No. opportunity mitigate (Indicate
identified opportunity
positive or
(R/O)
negative
implications)
1 Health & R As a chemical manufacturing Our safety culture is exceptional, Negative
industry, prioritising health and safety supported by a robust reporting
Safety
is paramount and deeply ingrained in system that involves all levels of our
our organisation. We are committed organisation. We conduct regular
to creating a safe workplace by safety training sessions to enhance
maintaining an accident-free employee well-being and maintain a
environment, aiming for zero safety safe work environment.
accidents, injuries and incidents that
could harm our workplace or the
environment.
2 Business R Ethical practices form the foundation TCL has implemented stringent Negative
of our business operations. Our policies to ensure ethical practices
Ethics
Company’s Code of Conduct within the organisation. Our code of
outlines the essential compliance conduct and ethical policies establish
requirements and provides a comprehensive framework for
guidelines for internal stakeholders employees and internal stakeholders.
to fulfil their duties with the utmost We also offer training programs to
integrity and accountability. ensure understanding and adherence
to these standards.
3 Water O Energy & Water stewardship have Positive
become fundamental aspects
Stewardship
of our organisation’s identity. We
are dedicated to conducting our
business operations in a sustainable
and environmentally friendly
manner. In line with our dedication
to water stewardship, we commit
to achieving by a 10% reduction in
water consumption by year 2030.
4 Employee Employee development plays a Positive
pivotal role in our sustainability
Development
journey. By investing in the growth
and skills enhancement of our
workforce, we create a more
capable and adaptable team. This,
in turn, enables us to implement
sustainable practices effectively,
innovate solutions, and respond to
evolving challenges in our industry
and the broader environmental
landscape. Additionally, a well-
developed and motivated workforce
is more engaged, leading to higher
productivity, better retention rates
and stronger commitment to our
sustainability goals.
78 | Thirumalai Chemicals Limited

Financial
implications
Indicate
of the risk or
Material whether
S. Rationale for identifying the risk / In case of risk, approach to adapt or opportunity
issue risk or
No. opportunity mitigate (Indicate
identified opportunity
positive or
(R/O)
negative
implications)
5 Community O Community support is integral to our Positive
sustainability journey. We recognise
Support
the importance of engaging with
and supporting the communities
where we operate. By collaborating
with local stakeholders, NGO’s and
government bodies we understand
community needs and priorities
better. This enables us to develop
sustainable initiatives that not
only benefit our business but also
contribute positively to the social
and economic well-being of the
communities we serve. Through
partnerships, outreach programs,
and community projects, we aim
to foster trust, build relationships,
and create shared value, ultimately
enhancing our overall sustainability
impact. We provide training
programmes to the local youth to
improve the employment rate and
are involved with various charitable
organisations for providing
affordable healthcare and education.
6 Zero Waste O TCL has implemented a range of Positive
to measures to ensure the proper
handling and disposal of wastes.
Landfill
Our focus is on capturing and
synthesising valuable products
from waste streams, including
gases, liquids and solids. Through
these efforts, we have achieved
a remarkable recovery rate, with
over 85% of solid wastes being
transformed into highly pure
saleable products and valuable by-
products. This approach not only
minimises environmental impact
but also maximises resource
efficiency, contributing to our
overall sustainability goals. We aim
to achieve a 10% reduction in our
industrial waste by 2030, from the
baseline year 2022-23.
 Statutory Reports Annual Report 2023-24 | 79

Financial
implications
Indicate
of the risk or
Material whether
S. Rationale for identifying the risk / In case of risk, approach to adapt or opportunity
issue risk or
No. opportunity mitigate (Indicate
identified opportunity
positive or
(R/O)
negative
implications)
7 Carbon R TCL is committed to combating To achieve a near zero energy Negative
climate change through initiatives footprint, we have adopted a three-
Footprint
focused on enhancing energy pronged approach to energy savings.
efficiency and increasing the use First, we harness energy from waste
to renewable energy sources to heat, maximising resource utilisation.
lower our carbon footprint. Our Second, we prioritise energy
manufacturing processes are efficiency across our operations,
among the most efficient in the ensuring every unit of energy is used
industry, resulting in significant judiciously. Third, we foster a culture
reductions in specific energy of innovation, among our employees,
consumption. Over the last three encouraging them to propose, and
decades, we have achieved an implement creative solutions that
impressive 78% decrease in specific further reduce energy consumption
energy consumption, showcasing and contribute to sustainability
our commitment to sustainability goals. As a result of this approach
and environmental stewardship. and mitigation plans we look to
bring about 25% reduction in GHG
emissions from the baseline year
2022-23
8 Corporate R The Company’s Board of Director’s Compliance with progressive social Negative
is responsible for setting policies and norms and regulatory requirements
Governance
strategies, providing overarching is not just a necessary cost but also
supervision and control over the essential for our sustainability. These
management of the company. The values are ingrained in our culture ,and
Board and its committees regularly we continuously collaborate with our
review the implementation of these employees to ensure they internalise
policies and support the executive and work within this framework. As
management team as required. a result, we have gained a strong
They also ensure the implementation reputation as an employer, business
of good governance and risk partner ,and community member.
management policies and practices Both the Board of Directors and the
,as well as efficient business management team are dedicated to
processes, with a rigorous approach. upholding this culture of integrity and
transparency in all aspects of our
business operations
9 Regulatory R TCL’s policies and practices have The company strictly adheres Negative
consistently adhered to ethical to regulations and compliance
Issues &
standards, legal requirements and requirements, integrating them
Compliance sustainability principles. We firmly into our organisational culture and
believe that it is possible to uphold practices, we have established
these policies while remaining robust systems and processes to
competitive in the market, By monitor and ensure compliance with
prioritising compliance, we not only applicable laws, rules, regulations and
contribute positively to society and guidelines. This proactive approach
environment but also enhance our helps us operate ethically, mitigate
long-term competitiveness and risks, and uphold our commitment
reputation as a responsible business to legal and regulatory compliance
entity. across all aspects of our operations.
10 Product R TCL gives paramount importance We constantly communicate and Negative
to ensure product safety and to receive feedback from the customers
Safety &
deliver quality products for achieving and work upon to fulfil their needs
Quality customer delight. and requirements.
80 | Thirumalai Chemicals Limited

SECTION B – MANAGEMENT AND PROCESS DISCLOSURES

This section is aimed at helping businesses demonstrate the structures, policies and processes put in place towards adopting
the NGRBC Principles and Core Elements.
Our comprehensive management framework is in line with the NGRBC principles and serves as a driving force for our dedication
to sustainable solutions across the three pillars of people, planet, and profit. Our policies, practices and procedures are geared
towards achieving the needs of our stakeholders, including customers and employees, with clear goals and objectives.
The National Guidelines on Responsible Business Conduct (NGRBC) released by the Ministry of Corporate Affairs has updated
and adopted nine areas of Business Responsibility. These are briefly as under:

Principle 1 Businesses should conduct and govern themselves with integrity and in a manner that is ethical, transparent,
and accountable
Principle 2 Businesses should provide goods and services in a manner that is sustainable and safe
Principle 3 Businesses should respect and promote the well-being of all employees, including those in their value chains
Principle 4 Businesses should respect the interests of and be responsive to all its stakeholders
Principle 5 Businesses should respect and promote human rights
Principle 6 Businesses should respect and make efforts to protect and restore the environment
Principle 7 Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is
responsible and transparent
Principle 8 Businesses should promote inclusive growth and equitable development
Principle 9 Businesses should engage with and provide value to their consumers in a responsible manner

Disclosure questions P1 P2 P3 P4 P5 P6 P7 P8 P9
Policy and Management Processes
1. a) Whether your entity’s policy/policies cover each Y Y Y Y Y Y Y Y Y
principle and its core elements of the NGRBCs (Yes/No)
b) Has the policy been approved by the Board? (Yes/No) Y Y Y Y Y Y Y Y Y
c) Web Link of the Policies, if available https://thirumalaichemicals.com/compliance-policies/
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 Y Y Y Y Y Y Y Y Y
partners? (Yes/No)
4. Name of the national and international codes/ All the policies of the Company are in compliance with
certifications/labels/ standards (e.g. Forest Stewardship national /international standards wherever applicable.
Council, Fairtrade, Rainforest Alliance, Trustea) standards TCL is a FSSC 22000 (equivalent to GFSI), HACCP, Halal
(e.g. SA 8000, OHSAS, ISO, BIS) adopted by your entity and & Kosher Certified, ISO 9001, ISO 9004, ISO 14001 &
mapped to each principle. ISO 50001 compliant, SMETA and a Responsible Care
Company
5. Specific commitments, goals and targets set by the entity Our organisation is committed to integrating
with defined timelines, if any . Environmental, Social and Governance principles
into our core operations. We have set specific goals
across Environmental, Social and Governance (ESG)
dimensions.
Environmentally, we commit to *:
• 25% reduction in GHG emissions by 2030
• 10% reduction in water consumption by 2030
• 10% reduction in industrial waste by 2030
(*from the baseline year 2022-23)
Socially, we will:
• Ensure zero accidents at workplace
• Continue to implement practices towards the
Responsible Care Initiative
 Statutory Reports Annual Report 2023-24 | 81

Disclosure questions P1 P2 P3 P4 P5 P6 P7 P8 P9
• Ensure 100% digitally enabled workforce by 2030
• Invest in projects related to conservation of natural
resources, education and access to healthcare
• Continue to commit to product quality and safety as
per global standards and certifications (REACH)
In terms of governance, we commit to
• Zero tolerance for human rights violations
• Promote trust and transparency in financial and non-
financial disclosures.
• Zero regulatory violations and ensuring that all
compliance issues are reported
6. Performance of the entity against the specific In the current financial year, we have set targets and
commitments, goals and targets along-with reasons in case goals with a detailed implementation roadmap to
the same are not met. achieve our sustainability vision. Refer question 5 above.
The performance will be monitored from next financial
year.
Governance Leadership and Oversight
7. Statement by director responsible for the business responsibility report, highlighting ESG related challenges,
targets, and achievements
Please refer to ‘Chairman Letter’ in the Annual Report FY 23-24.
8. Details of the highest authority responsible for Name: Mr. Sanjay Sinha
implementation and oversight of the Business Responsibility
Designation: CEO
policy (ies).
e-mail id: [email protected]
9. Does the entity have a specified Committee of the Board/ ESG committee is constituted for handling sustainability
Director responsible for decision making on sustainability related matters and chaired by Mr. Sanjay Sinha. This
related issues? (Yes / No). If yes, provide details. committee will provide report to the Board on these
aspects

10. Details of Review of NGRBCs by the Company:

Indicate whether review was Frequency
undertaken by Director / Committee (Annually/Half - yearly/Quarterly/Any
of the Board/ Any other Committee other – please specify)
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 A A A A A Q A A H
follow up action
Compliance with statutory requirements of Y Y Y Y Y Y Y Y Y A A A A A Q A A H
relevance to the principles, and, rectification
of any non-compliances

11. Has the entity carried out independent assessment/ evaluation of the P1 P2 P3 P4 P5 P6 P7 P8 P9
working of its policies by an external agency? (Yes/No). If yes, provide N Y Y N N Y N N N
the name of the agency.

12. If answer to question (1) above is “No” i.e. not all Principles are covered by a policy, reasons to be stated:
Questions P1 P2 P3 P4 P5 P6 P7 P8 P9
The entity does not consider the Principles material to its business (Yes/No)
The entity is not at a stage where it is in a position to formulate and implement
the policies on specified principles (Yes/No)
The entity does not have the financial or/human and technical resources Not applicable
available for the task (Yes/No)
It is planned to be done in the next financial year (Yes/No)
Any other reason (please specify)
82 | Thirumalai Chemicals Limited

SECTION C – PRINCIPLE WISE PERFORMANCE DISCLOSURE

Principle 1 – Businesses should conduct and govern themselves with integrity, and in a manner that is ethical, transparent, and
accountable

At Thirumalai Chemicals we uphold a strong commitment to conducting and governing ourselves with integrity, ensuring that
all our actions and decisions are guided by ethical principles. Our commitment is unwavering as we conduct ourselves with the
highest standards of honesty, integrity ,and transparency.. These values are ingrained in our corporate culture and guide us in
creating sustainable and trustworthy relationships with our customers, employees and the community. Our Directors and Senior
Management adhere to a comprehensive Code of Conduct that outlines their responsibilities and ethical obligations, enabling
them to fulfil their duties in a responsible, transparent, fair and ethical manner.
SDG Linkages-

Essential Indicators
1. Percentage coverage by training and awareness programmes on any of the principles during the financial year:

Total number of % of persons in respective

Topics/principles covered under the
Segment training and awareness category covered by the
training and its impact
programmes held awareness programmes
Board of Directors 2 Familiarisation Programs for Directors 100%
Awareness program on Sustainability
Key Managerial Personnel 2 ESG Compliance, POSH 100%
Employees other than BoD 51 Awareness on employee Well-being. 100%
and KMPs
Awareness on Human Rights
Workers 17 Awareness on employee Well-being. 100%
Awareness on Human Rights

2. Details of fines / penalties /punishment/ award/ compounding fees/ settlement amount paid in proceedings (by the
entity or by directors / KMPs) with regulators/ law enforcement agencies/ judicial institutions, in the financial year, in
the following format (Note: the entity shall make disclosures on the basis of materiality as specified in Regulation 30 of
SEBI (Listing Obligations and Disclosure Obligations) Regulations, 2015 and as disclosed on the entity’s website):
Monetary
Name of the
regulatory/ Has an appeal been
NGRBC Principle Amount (In INR) Brief of the Case
enforcement agency/ preferred? (Yes/No)
judicial institutions
Penalty/ Fine Nil
Settlement
Compounding fee

Non-Monetary
Name of the
regulatory/ Has an appeal been
NGRBC Principle Amount (In INR) Brief of the Case
enforcement agency/ preferred? (Yes/No)
judicial institutions
Imprisonment Nil
Punishment
 Statutory Reports Annual Report 2023-24 | 83

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
Not applicable
4. Does the entity have an anti-corruption or anti-bribery policy? If yes, provide details in brief and if available, provide
a web link to the policy.
Yes, Our company maintains a robust and comprehensive anti-bribery and anti-corruption policy to ensure ethical business
practices and integrity throughout our operations. This policy underscores our commitment to conducting business with
transparency, fairness and honesty. It outlines clear guidelines and procedures to prevent bribery and corruption in all forms,
emphasising compliance with legal requirements and ethical standards. Through continuous training, monitoring, and
enforcement of this policy, we foster a culture of integrity and accountability within the organisation, building trust and assurance
among our stakeholders.
The anti-corruption and anti-bribery policy is available on our website in the following link :
https://thirumalaichemicals.com/wp-content/uploads/2023/05/ANTI-BRIBERY-AND-ANTI-CORRUPTION-POLICY.pdf

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 23-24 FY 22-23
Directors Nil Nil
KMPs Nil Nil
Employees Nil Nil
Workers Nil Nil

6. Details of complaints with regard to conflict of interest:

FY 23-24 FY 22-23
Number Remarks Number Remarks
Number of complaints received in relation to issues of Conflict of Nil Nil
Interest of the Directors
Number of complaints received in relation to issues of Conflict of Nil Nil
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

8. Number of days of accounts payables ((Accounts payable *365) / Cost of goods/services procured) in the following
format:

FY 23-24 FY 22-23
Number of days of accounts payables 112 days 104 days

9. Open-ness of business
Parameter Metrics FY 23-24 FY 22-23
Concentration of a. Purchases from trading houses* as % of total purchases 2.6% 2.7%
Purchases b. Number of trading houses where purchases are made 12 13
from
c. Purchases from top 10 trading houses as % of total 2.6% 2.7 %
purchases from trading houses
Concentration of a. Sales to dealers / distributors as % of total sales NA NA
Sales b. Number of dealers / distributors to whom sales are NA NA
made
c. Sales to top 10 dealers / distributors as % of total sales NA NA
to dealers / distributors
84 | Thirumalai Chemicals Limited

Parameter Metrics FY 23-24 FY 22-23

Share of RPTs in a. Purchases (Purchases with related parties / Total .007% .02%
Purchases)
b. Sales (Sales to related parties / Total Sales ) .04% .04%
c. Loans & advances (Loans & advances given to related Nil .062%
parties / Total loans & advances)
d. Investments (Investments in related parties / Total 94.79% 99.97%
Investments made)
*A trading house refers to a business entity that primarily engages in import and export of goods .

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 % of value chain partners covered (by value of business done
programmes held under the training with such partners) under the awareness programmes
4 Safety Protocols Contract employees, logistics and visiting vendors- 100%
Material Handling & Loading Logistics-100 %
Prevention of Sexual Contract employees-30%
Harassment
Product responsibility Critical vendors-57%

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, we have a comprehensive Code of Conduct policy which serves as a cornerstone, ensuring transparency and fairness in all
our business dealings. This policy outlines clear guidelines and expectations for ethical behaviour, emphasising the importance of
honesty, integrity and respect in each interaction. This commitment to ethical conduct not only strengthens trust and credibility
with our stakeholders but also reinforces our dedication to operating with integrity and accountability.

Principle 2 – Businesses should provide goods and services in a manner that is sustainable and safe.

TCL’s commitment to sustainability shines through its dedicated R&D team, which focuses on developing innovative products that
meet global standards and are environmentally friendly. TCL excels in business practices, striving for near-zero energy footprint by
manufacturing with high efficiency through energy-saving measures and waste data recovery. Additionally, the company strives
to integrate sustainability principles across all stages of the product lifecycle, from raw material procurement and manufacturing
to transportation, delivery, and consumer disposal. We uphold a strong commitment to environmental responsibility and ensure
that our products and services meet rigorous safety standards. Through continuous innovation and responsible practices, we
strive to minimise our environmental impact and prioritise the safety of our customers and communities.
SDG Linkages-

Essential Indicators
1. Percentage of R&D and capital expenditure (capex) investments in specific technologies to improve the
environmental and social impacts of product and processes to total R&D and capex investments made by the entity,
respectively.

Details of improvements in environmental

FY 23-24 FY 22-23
and social impacts
R&D 7.14 % 0% Reducing the waste by 2.8 tons per day
Capex 1% 3% 1. HCL Dosing system for Reliability
improvement
2. CCTV PTZ Camera (ETP)
 Statutory Reports Annual Report 2023-24 | 85

2. a. Does the entity have procedures in place for sustainable sourcing ? (Yes/No)
Yes, the company has embraced Responsible Care Guidelines and SEDEX Members Ethical Trade Audit (SMETA) Best
Practice Guidance to ensure sustainable sourcing. By sourcing raw materials in bulk, the company minimises road
transportation over long distances, effectively reducing its carbon footprint.
Kindly refer to our Sustainable Procurement Policy for more information regarding our sustainable sourcing practices
.Weblink : https://thirumalaichemicals.com/wp-content/uploads/2023/05/SUSTAINABLE-PROCUREMENT-POLICY.
pdf
b. If yes, what percentage of inputs were sourced sustainably ?
91% of our inputs are sourced sustainably.

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.
Waste type Waste management procedure in place
Plastic (including packaging) We are in process of tracking and increasing the reuse of our packaging
materials. 16.7% of packaging material is reused this financial year. The
remaining packaging materials and other plastics are disposed to authorised
pre-processors.
E-waste All our products like Phthalic Anhydride, Malic Acid, Fumaric acid are
Hazardous waste consumables in the manufacturing of plasticizers, pigments, dyes, resins,
Other waste (wastepaper and paper candies, beverages etc. Since Therefore, there is no scope for reusing /
products) recycling products at the end of life.
The specified category of wastes is not generated during our product life
cycle. The waste generated during our manufacturing and operations are
disposed through authourised vendors and as per waste management rules.

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, EPR is applicable for TCL and it is registered as a brand owner with the Central Pollution Control Board .

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?
Boundary for which the Results
Name of % of total Whether conducted
Life Cycle Perspective communicated If yes, provide the
NIC Code Product / Turnover by independent
/ Assessment was in public web-link.
Service contributed external agency
conducted domain
2411 Phthalic 100 % Life Cycle perspective is The data are obtained Yes http://192.168.1.202/iso/
Anhydride covered under the title” from the dossier
Product Stewardship”. submitted by the lead
Malic acid The product stewardship registrant representing
Fumaric summary is provided in the Consortium of
acid the public domain. The manufacturers of
summary covers the product to EU
registration Agency
1. Properties (ECHA) as a statutory
2.Health & safety requirement under the
information EU law named REACH.
TCL is a member of the
3.Environmental consortium and owns
information, which the right of the data.
includes biodegradability,
exposure potential during
manufacture, handling
and Use, and
4. Regulatory Information
Note: The above Life cycle assessment has been conducted from the perspective of REACH (EU) and not a cradle to grave analysis. TCL is
in the process of evaluating conducting full scale LCA for its products in the coming years.
86 | Thirumalai Chemicals Limited

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
Name of Product / Service Description of the risk / concern Action Taken
These parameters have been outlined in Material Safety Data Sheet (SDS) in the products tab in our website. http://www.
thirumalaichemicals.com/Products

3. Percentage of recycled or reused input material to total material (by value) used in production (for manufacturing
industry) or providing services (for service industry).

Recycled or re-used input material to total material

Indicate input material
FY 23-24 FY 22-23
Our products are chemicals such Phthalic Anhydride, Malic Acid and Fumaric Acid. While usage of recycle materials could
be limited, we are in process of tracking and increasing the reuse of our packaging materials.

4. Of the products and packaging reclaimed at end of life of products, amount (in metric tonnes) reused, recycled, and
safely disposed, as per the following format:
• Not Applicable, since all our chemicals are used as consumables for the manufacturing of other products. There is no
product reclamation at the end of product life.
• Plastics (including packaging ) 24419 MT was reused out of the total despatch of 146028 MT in the current reporting period.
• The waste material generated at the manufacturing plant are disposed as per the applicable regulatory requirements as
mentioned in Principle 6, Essential indicator 9.

5. Reclaimed products and their packaging materials (as percentage of products sold) for each product category.

Reclaimed products and their packaging materials as % of total products sold in respective
Indicate product category
category
Packaging material 16.7%

Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value chains

Our core values revolve around prioritising employee well-being. We are dedicated to fostering a workplace, that is supportive,
inclusive, and empowering, focusing on nurturing the physical, mental, and emotional health of our employees. Discrimination or
harassment based on any characteristic such a gender, caste religion, race, or ethnicity is strictly prohibited in our organisation.
We invest in our employee’s growth and development through various training programmes and skill building opportunities.
Ensuring a safe and healthy work environment is paramount, and we adhere to stringent safety protocols. Our commitment to
open and transparent communication encourages feedback and addresses employee concerns, ultimately cultivating a positive
and engaged workforce.
SDG Linkages-
 Statutory Reports Annual Report 2023-24 | 87

Essential Indicators
1. a. Details of measures for the well-being of employees:
% Of employees covered by
Total Health insurance Accident insurance Maternity benefits Paternity benefits Day care facilities
Category
(A) Number Number Number % (D / Number Number
% (B / A) % (C / A) % (E / A) % (F / A)
(B) (C) (D) A) (E) (F)
Permanent employees
Male 461 461 100 % 461 100% - - 0 0% 0 0%
Female 48 48 100% 48 100% 48 100% - - 0 0%
Total 509 509 100% 509 100% 48 100% 0 0% 0 0%
Other than Permanent employees
Male 25 25 100% 25 100% - - 0 0% 0 0%
Female 2 2 100% 2 100% 2 100% - - 0 0%
Total 27 27 100% 27 100% 2 100% 0 0% 0 0%

b. Details of measures for the well-being of workers:

% Of workers covered by
Health Accident Maternity Paternity Day care
Total
Category insurance insurance benefits benefits facilities
(A)
Number Number Number Number Number
% (B / A) % (C / A) % (D / A) % (E / A) % (F / A)
(B) (C) (D) (E) (F)
Permanent workers
Male 28 28 100% 28 100% - - 0 0% 0 0%
Female 0 - - - - - - - - - -
Total 28 28 100% 28 100% - - 0 0% 0 0%
Other than Permanent workers
Male 667 667 100% 667 100% - - 0 0% 0 0%
Female 67 67 100% 67 100% 67 100% - - 0 0%
Total 734 734 100% 734 100% 67 100% 0 0% 0 0%

c. Spending on measures towards well-being of employees and workers (including permanent and other than
permanent ) in the following format –

FY 23-24 FY 22-23
Cost incurred on well-being measures as a % of total revenue of the company 0.10 0.16

2. Details of retirement benefits, for Current FY and Previous Financial Year.

FY 23-24 FY 22-23
No. of No. of
No. of workers Deducted and No. of workers Deducted and
employees employees
covered as deposited with covered as deposited with
Benefits covered as covered as
a % of total the authority a % of total the authority
a % of total a % of total
workers (Y/N/NA) workers (Y/N/NA)
employees employees
PF 100% 100% Y 100% 100% Y
Gratuity 100% 100% Y 100% 100% Y
ESI* 100% 100% Y 100% 100% Y
Others –please specify NA NA NA NA NA NA
* Note: As per applicability under the Employees’ State Insurance Act, 1948.
88 | Thirumalai Chemicals Limited

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.
Currently some of the premises /offices are not accessible to differently abled employees and workers but the organisation is
fully committed to fostering an inclusive environment where all employees feel valued and supported. Hence, recognising the
importance to addressing this issue promptly, the company is dedicated to taking proactive steps to enhance accessibility soon.
By prioritising these efforts, we aim to create a more inclusive and accommodating environments for all individuals within our
workplace.

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. The company upholds a steadfast Equal opportunity Policy, which serves as the cornerstone of our organisational ethos. We
are committed to providing a work environment where all employees are treated with dignity, respect and fairness, regardless
of their background, identity or abilities. This policy underscores our commitment to fostering a diverse and inclusive workplace,
where every individual has the opportunity to thrive and contribute to our collective success. We firmly believe that diversity
strengthens our organisation, and we are dedicated to upholding these principles in all aspects of our operations.
Please find our weblink below:
https://thirumalaichemicals.com/wp-content/uploads/2023/05/EQUAL-EMPLOYMENT-OPPORTUNITY-POLICY.pdf

5. Return to work and Retention rates of permanent employees and workers that took parental leave.

Permanent employees Permanent workers

Gender
Return to work rate Retention rate Return to work rate Retention rate
Male NA NA NA NA
Female NA 100% NA NA
Total NA 100% NA NA

6. Is there a mechanism available to receive and redress grievances for the following categories of employees and
workers? If yes, give details of the mechanism in brief.
Yes / No (If yes, then give details of the
mechanism in brief)
Permanent Workers Grievance Redressal Policy in place.
Other than permanent workers Registration of grievance is through
Permanent Employees Phone number or e-mail ID available in the
company’s website.
Other than permanent employees

7. Membership of employees and workers in association(s) or Unions recognised by the listed entity:

FY 23-24 FY 22-23
No. of employees/ No. of employees/
Total workers in the Total workers in the
Category employees respective employees respective
%
/ workers in category, who / workers in category, who % (D/C)
(B/A)
respective are part of the respective are part of the
category (A) association(s) or category (C) association(s) or
Union (B) Union (D)
Total Permanent Employees
Male 461 0 0% 447 0 0%
Female 48 0 0% 41 0 0%
Total 509 0 0% 488 0 0%
Total Permanent Workers
Male 28 0 0% 31 0 0%
Female 0 0 0% 0 0 0%
Total 28 0 0% 31 0 0%
 Statutory Reports Annual Report 2023-24 | 89

8. Details of training given to employees and workers:

FY 23-24 FY 22-23
On health and On health and
Category Total (A) On skill upgradation Total On skill upgradation
safety measures safety measures
(D)
No. (B) % (B / A) No. (C) % (C / A) No. (E) % (E / D) No.(F) % (F / D)
Permanent Employees
Male 461 313 68% 391 85% 447 233 52% 264 59%
Female 48 31 65% 44 92% 41 18 44% 18 44%
Total 509 344 68% 435 85% 488 251 52% 282 58%
Permanent Workers
Male 28 19 68% 21 75% 31 12 39% 21 68%
Female 0 0 0 0 0 0 0 - 0 -
Total 28 19 68% 21 75% 31 12 39% 21 68%

9. Details of performance and career development reviews of employees and workers:

FY 23-24 FY 22-23
Category
Total (A) No. (B) % (B / A) Total (C) No. (D) % (D / C)
Employees
Male 461 322 70% 447 275 62%
Female 48 30 63% 41 28 68%
Total 509 352 69% 488 303 62%
Workers
Male 28 28 100% 31 31 100%
Female 0 0 0 0 0 0
Total 28 28 100% 31 31 100%
10. Health and safety management system:
a. Whether an occupational health and safety management system has been implemented by the entity? (Yes/ No). If yes,
what is the coverage of such a system?
Yes, TCL places the highest importance on the health, safety, and happiness of its employees. The organisation has
implemented comprehensive Occupational Health and Safety Management System with 100 % coverage across all areas
of operation. We prioritise the health and safety of our employees above all else, recognising it as a fundamental aspect of
our commitment to their well-being. In order to provide a safe and incident-free workplace, we have put into place stringent
rules and protocols and all employees, contract labours, vendors visiting the facility are covered under the Safety systems
of the organisation. 4 of our sites are certified under ISO 45001 which specifies requirements for Occupational Health and
Safety management systems.
b. What are the processes used to identify work-related hazards and assess risks on a routine and non-routine basis by the
entity?
1. Hazard Identification and Risk Assessment (HIRA)
For our organisation, HIRA is a critical process to identify potential workplace hazards and assess associated risks.
This procedure describes the methodology of calculating Hazard identification, Risk Assessment and Determining
Controls study with connection to the various plants of Thirumalai Chemicals Ltd. HIRA Register is maintained to list
out the sources or situations of various hazards and their associated risks. The identification of Hazard is done at the
Worker, Supervisor and Engineer level in each department and reported to the Section Head. The Section Head and
Head of Department analyze the identified hazards, review the severity and risk of the hazard, and take actions to
implement suitable control measures to minimise or eliminate the risk.
2. Job Safety Analysis
Job Safety Analysis (JSA) is a systematic procedure that breaks each job/task into key training sequences, identifies
safety elements of each job/task step and teaches the employee on how to avoid potential safety hazards.
90 | Thirumalai Chemicals Limited

3. Work Permit System

Work Permit system refers to a system procedure used to ensure that work is done safely and efficiently especially in
Hazardous industries usually in connection with maintenance work. A Work Permit System also known as Permit to
Work is an element of Process Safety and is usually given as a clearance from the Process Department to Maintenance
to carry out a particular work.
4. Internal and external audits are carried out to identify work-related hazards and assess risks on a routine and
non-routine basis by the entity.
Both these audits carried out to identify work related hazards ensure that minute details related to any process is not
missed and is seen with an eagle’s eye. The observations of the audit are highlighted to the top management to initiate
suitable actions to eliminate the hazards.
c. Whether you have processes for workers to report the work-related hazards and to remove themselves from such risks.
Yes, Safety portal is available for reporting any work-related hazards identified by the workers. Every employee in the
organisation is given a separate login id and password to access the Safety Portal. The Safety Portal covers all the aspects
in connection with Work related hazards. The employee can enter the USA (Unsafe Act) and USC (Unsafe Conditions) in
his work area. Once entered the area of concern is highlighted to the respective Section Heads and HOD’s who will initiate
actions for elimination of the USA and USC. Once resolved, the actions initiated is also recorded in the Safety Portal to close
the observations. In addition, the Safety Portal also enables the employees to enter Safety Contacts (Case Studies), learnings
from incidents, accidents inside and outside the industry.
d. Do the employees/ workers of the entity have access to non-occupational medical and healthcare services?
Yes, non-occupational medical and Healthcare services is made available to workers and employees. Periodic eye
screenings are conducted for employees to address age-related disorders. For other non-occupational ailments, employees
are referred to “Thirumalai Mission Hospital” which operates under the charity wing of Thirumalai Group. An annual medical
health check-up, covering major aspects of lifestyle diseases like diabetes, hypertension etc is conducted for both employees
and workers, followed by counselling

11. Details of safety related incidents, in the following format:

Safety incident/number Category FY 23-24 FY 22-23
Lost Time Injury Frequency Rate (LTIFR) (per one-million- Employees* Nil Nil
person hour worked) Workers 0.55 Nil
Total recordable work-related injuries Employees Nil Nil
Workers 1 Nil
No. of fatalities Employees Nil Nil
Workers Nil Nil
High consequence work-related injury or ill-health Employees Nil Nil
(excluding fatalities) Workers Nil Nil
*Employee data includes the FTE including workmen and contract employees.

12. Describe the measures taken by the entity to ensure a safe and healthy workplace.
Ensuring a healthy and safe workplace is a multifaceted approach that involves continuous education, active participation, and
thorough evaluations. One of the key initiatives includes raising Environmental, Health and Safety (EHA) awareness among all
employees through comprehensive training programs and regular safety toolbox talks. Innovative methods such as safety park
models are employed for practical training, enhancing the understanding of safe work practices. Additionally, the company
celebrates Environment Day and Safety Week to foster a culture of safety and environmental responsibility. To further incentivise
adherence to best practices, rewards and recognition programs are in place highlighting the contributions of employees who
demonstrate exemplary safety behaviours.
In maintaining a robust safety environment, the company also conducts cross-functional safety audits and specific electrical
safety audits to ensure compliance and identify potential threats. Process Safety Management (PSM) Implementation and Job
Safety Analysis (JSA) are conducted for all activities, ensuring that every task is scrutinised for safety risks. Furthermore, Hazard
Identification and Risk Assessment (HIRA) is performed for all operations, complemented by Hazard and Operability (HAZOP)
studies to pinpoint and mitigate risks. Engaging employees in activities like tree plantation programs also underscores the
commitment to environmental sustainability, reinforcing the holistic approach to workplace safety and health.
 Statutory Reports Annual Report 2023-24 | 91

13. Number of complaints on the following made by employees and workers

FY 23-24 FY 22-23
Pending Pending
Filed during Filed during
resolution at Remarks resolution at Remarks
the year the year
the end of year the end of year
Working conditions Nil Nil Nil Nil Nil Nil
Health & safety Nil Nil Nil Nil Nil Nil

14. Assessments for the year

% of your plants and offices that were assessed (by entity or statutory authorities or third
parties)
Health and safety practices 100%
Working conditions 100 %
*These assessments are done the entity.

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.
There are no critical observations generated from Health Safety, working conditions assessments by the entity, authorities or
third parties impacting operations .

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)
Employee-Yes
Workers- Yes

2. Provide the measures undertaken by the entity to ensure that statutory dues have been deducted and deposited by
the value chain partners
The Company has safeguards and checks and balances in place to determine if the statutory dues have been deducted and
deposited with respect of value chain partners to the extent applicable.

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:
No. of employees/workers that are
rehabilitated and placed in suitable
Total no. of affected employees/ workers
employment or whose family members
have been placed in suitable employment
FY 23-24 FY 22-23 FY 23-24 FY 22-23
Employees Nil Nil Nil Nil
Workers Nil Nil Nil 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:

% of value chain partners (by value of business done with such partners) that were assessed
Health and safety practices 92.5%
Working Conditions 91 %
*Note: The above assessment is done internally and has been only extended to our Tier 1 suppliers.

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
None
92 | Thirumalai Chemicals Limited

Principle 4: Businesses should respect the interests of and be responsive to all its stakeholders

We understand that Stakeholder engagement and involvement are crucial elements for the success of our business. It is essential
for us to respect the interests of all the stakeholders and be responsive to their needs, By actively engaging with stakeholders
such as customers, employees, investors, suppliers, and the community, we can gain valuable insights, build trust, and foster
positive relationships. We proactively involve our stakeholders by actively seeking their feedback, addressing their concerns,
and meeting their expectations. We consider their inputs invaluable in shaping our decision-making process and value their
feedback as a crucial component of our operations. This engagement allows us to align our strategies and decisions with the
expectations and concerns of our stakeholders, leading to greater long-term success and sustainability.
SDG Linkages-

Essential Indicators
1. Describe the processes for identifying key stakeholder groups of the entity.
Any individual, group, or institution that contributes to the corporation’s value chain or is significantly impacted by the entity’s
decision is recognised as a core stakeholder. The key stakeholders for the company are any such person or group that enhances
the business and has a stronger impact on it. Presently, Thirumalai Chemicals has systematically identified its internal and external
stakeholders and actively engages with investors, employees, customers, suppliers, governmental and regulatory authorities,
trade unions, and the local community. The company adheres to a structured system of timely feedback and response, utilising
both formal and informal channels of communication to ensure that stakeholders information remains current and updated.

Channels of
communication
Whether identified (Email, SMS, Frequency of Purpose and scope of
as vulnerable & Newspaper, Pamphlets, engagement (Annually/ engagement including key
Stakeholder group
marginalised group Advertisement, half-yearly/ quarterly / topics and concerns raised
(Yes/No) Community meetings, others – please specify) during such engagement
Notice board, Website),
Other
Employees No • Intranet Portal On a regular • Employee benefits
• Functional and basis • Equal opportunities
cross-functional • Recognition
committees
• Learning and
• Leader’s talk development
• Regular Employee • Safety and well-being
Communication
• Performance
Forums
review and career
development
• Business update
Customers No • Customer Service On a regular • Customer feedback
Support Basis • Resolution of their
• Customer queries
Satisfaction Survey
 Statutory Reports Annual Report 2023-24 | 93

2. List stakeholder groups identified as key for your entity and the frequency of engagement with each stakeholder
group
Channels of
communication
Purpose and scope of
Whether identified (Email, SMS, Frequency of
engagement including
as vulnerable & Newspaper, Pamphlets, engagement (Annually/
Stakeholder group key topics and concerns
marginalised group Advertisement, half-yearly/ quarterly /
raised during such
(Yes/No) Community meetings, others – please specify)
engagement
Notice board, Website),
Other
Suppliers No • Supplier and Annually • Resolving queries
and Vendors Vendor meets • Assessing
• Face-to-face performance
and electronic • Recognition and
correspondence engagement
• Supplier Audits activities
• Undertaking
discussion on
Sustainability
Parameters
Investors / No • Email Need based To update them
Shareholders • Newspaper about important
advertisement, developments
in the Company
• Website
and address their
• Annual General grievances
Meetings
• Disclosures to
Stock
exchanges.
Community No • Community Monthly • Community
surveys and development
consultations • Community
• CSR initiatives grievance
• Volunteering redressal
activities
• Community events
Regulatory No • Annual reports On a need basis • Policy Advocacy
And government • Making with concerned
bodies representations authorities
whenever needed • Deliberations
• Formal dialogues and inputs on
regulations and
policies that have
bearing on our
operations and
businesses.
• Amendment in
existing regulations
94 | Thirumalai Chemicals Limited

Leadership Indicators
1. Provide the processes for consultation between stakeholders and the Board on economic, environmental, and social
topics or if consultation is delegated, how is feedback from such consultations provided to the Board.
Our approach to stakeholder consultation is guided by our Stakeholder Engagement Policy, which outlines clear directives
and guidelines for our consultation process. We prioritise open and transparent communication channels to engage with our
stakeholders effectively. Additionally, any critical topics or issues are promptly communicated to ensure transparency and foster
constructive dialogue. This proactive approach enables us to address concerns, gather valuable feedback, and collaboratively
work towards sustainable solutions that benefit all stakeholders involved.
Weblink: https://thirumalaichemicals.com/wp-content/uploads/2023/05/STAKEHOLDER-ENGAGEMENT-POLICY.pdf

2. Whether stakeholder consultation is used to support the identification and management of environmental, and
social topics (Yes / No). If so, provide details of instances as to how the inputs received from stakeholders on these
topics were incorporated into policies and activities of the entity.
Yes, stakeholder consultation is used for identification of environmental and social topics. No critical issues concerning
environmental, and social topics were raised in the current reporting period.

3. Provide details of instances of engagement with, and actions taken to, address the concerns of vulnerable/
marginalised stakeholder groups.
We actively engage with the vulnerable/ marginalised stakeholder groups through our CSR initiatives, actively seeking their
inputs, suggestions, and concerns throughout the process. This inclusive approach ensures that their voices are heard and
integrated into our decision-making processes, by fostering meaningful dialogue and collaboration, we aim to address the specific
needs and challenges faced by these groups, driving positive impact and sustainable outcomes within our communities. No
concerns were recorded in the reporting period.

Principle 5: Businesses should respect and promote human rights

TCL is committed to respecting and promoting human rights. We strive to create a workplace that safeguards and advances
the rights and dignity of all individuals, both within and outside our organisation. We uphold fundamental principles such as
non-discrimination, fair labor practices, and safe working conditions across all aspects of our operations. Through our policies,
practices and partnerships, we endeavour to create a workplace and business environment that fosters dignity, equality, and
respect for human rights.
SDG Linkages-

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:

FY 23-24 FY 22-23
Category No. of employees / No. of employees /
Total (A) % (B / A) Total (C) % (D / C)
workers covered (B) workers covered (D)
Employees
Permanent 509 509 100% 488 290 59 %
Other than permanent 27 25 93% 24 18 75 %
Total employees 536 534 100% 512 308 60 %
Workers
Permanent 28 28 100% 31 31 100 %
Other than permanent 734 734 100% Aspects of Human rights forms part of our
business contract and all our contract work
adhere to firm’s policies and guidelines
regarding Human rights.
Total workers 762 762 100% 31 31 100 %
 Statutory Reports Annual Report 2023-24 | 95

2. Details of minimum wages paid to employees and workers

FY 23-24 FY 22-23
On health and On health and
Category Total (A) On skill upgradation Total On skill upgradation
safety measures safety measures
(D)
No. (B) % (B / A) No. (C) % (C / A) No. (E) % (E / D) No.(F) % (F / D)
Employees
Permanent
Male 461 51 11% 410 89% 447 68 14% 379 85%
Female 48 5 9% 43 90% 41 1 2% 40 98%
Other than Permanent
Male 25 0 0 25 100% 21 0 0 21 100%
Female 2 0 0 2 100% 3 0 0 3 100%
Workers
Permanent
Male 28 0 0 28 100% 31 0 0 31 100%
Female 0 0 0 0 0 0 0 0 0 0
Other than permanent
Male 667 667 100% 0 0 446 446 100% 0 0
Female 67 67 100% 0 0 49 49 100% 0 0

3.Details of remuneration/salary/wages
a. Median remuneration / wages:
Male Female
Median remuneration/ Median remuneration/
Number salary/ wages of respective Number salary/ wages of respective
category category
Board of Directors (BoD) 1* 3,33,00,000 1 1,41,00,000
Key managerial personnel 3 1,61,00,000 - -
Employees other than BoD and KMP 461 5,00,016 45 5,97,716
Workers 28 5,31,294 0 0
*The remaining Board members receive only sitting fees for attending meetings of the board/ committee.

b. Gross wages paid to females as % of total wages paid by the entity, in the following format:
FY 23-24 FY 22-23
Gross wages paid to females as % of total wages 9.79% 9.19%

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 responsibility for overseeing human rights impacts or issues fall under the purview of the head of Human Resources.
Any grievances raised in this context are addressed by the head of HR. This ensures that the company’s policies and actions
align with human rights standards and that employees’ concerns are appropriately handled.

5. Describe the internal mechanisms in place to redress grievances related to human rights issues.
There are various channels available for employees and workers to communicate grievances within the organisation :
1.Email and Phone: Employees can directly contact the HR department or specific individuals responsible for handling
grievances via email or phone calls.
2.Suggestion boxes: These provide a confidential and anonymous way for employees to raise concerns or suggestions,
including grievances ,without revealing their identity.
3. Hierarchical System: there is a designated system/process of hierarchy within the company to communicate grievances
right from the designated Human Rights Officer, Factory Manager, Site head and CEO & Managing Director,
96 | Thirumalai Chemicals Limited

6. Number of complaints on the following made by employees and workers:

FY 23-24 FY 22-23
Pending Pending
Filed during resolution Filed During resolution
Remarks Remarks
the year at the end of the year at the end of
year year
Sexual harassment Nil Nil Nil Nil Nil Nil
Discrimination at workplace Nil Nil Nil Nil Nil Nil
Child labour Nil Nil Nil Nil Nil Nil
Forced labour/Involuntary labour Nil Nil Nil Nil Nil Nil
Wages Nil Nil Nil Nil Nil Nil
Other human rights-related issues Nil Nil Nil Nil Nil Nil

7. Complaints filed under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act,
2013, in the following format:

FY 23-24 FY 22-23
Total Complaints reported under Sexual Harassment on of Women at Workplace Nil Nil
(Prevention, Prohibition and Redressal) Act, 2013 (POSH )
Complaints on POSH as a % of female employees / workers Nil Nil
Complaints on POSH upheld Nil Nil

8. Mechanisms to prevent adverse consequences to the complainant in discrimination and harassment cases.
TCL is dedicated to upholding a safe and productive work environment that is free from discrimination or harassment of any kind.
To ensure prompt and impartial resolution of any related complaints, we have established a trained internal complaints committee.
Also, TCL has a well-defined comprehensive POSH policy to address discrimination and harassment at workplace.
Weblink: https://thirumalaichemicals.com/wp-content/uploads/2023/05/POSH-POLICY.pdf
Further to this, there is also a Stakeholder Grievance Redressal policy for resolution of all grievances raised by the stakeholders,
Weblink:https://thirumalaichemicals.com/wp-content/uploads/2023/05/STAKEHOLDER-GRIEVANCE-REDRESSAL-POLICY.pdf

9. Do human rights requirements form part of your business agreements and contracts? (Yes/No)
The Company has a robust mechanism to address human rights requirements which are evidenced by the Company’s Code
of Conduct, Employment and Hiring policies, Supplier Code of Conduct in place. TCL has a Business and Human Rights policy
in place to outlining procedures and actions in response to human rights violations.
Weblink provided
https://thirumalaichemicals.com/wp-content/uploads/2023/05/BUSINESS-AND-HUMAN-RIGHTS-POLICY.pdf

10. Assessments of the year

% of your plants and offices that were assessed (by the entity or statutory authorities or third
parties)
Child labour 100% through statutory compliance
Forced/involuntary labour
Sexual harassment
Discrimination at workplace
Wages
Others – please specify

11. Provide details of any corrective actions taken or underway to address significant risks / concerns arising from the
assessments at Question 9 above.
No risk/concern were identified and there is no necessity for corrective action.
 Statutory Reports Annual Report 2023-24 | 97

Leadership Indicators
1. Details of a business process being modified / introduced as a result of addressing human rights grievances/
complaints.
Since there were no Human Rights grievances/complaints, no modifications of the processes was undertaken.

2. Details of the scope and coverage of any Human rights due diligence conducted
No due diligence has been conducted

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?
The premises are currently not accessible to disabled visitors. However, we are committed to working on improvements to make
it accessible in the future .

4. Details on assessment of value chain partners:

% of your plants and offices that were assessed (by the entity or statutory authorities or
third parties)
Sexual Harassment
Discrimination at workplace
Child Labour
Nil
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.
None.

Principle 6: Businesses should respect and make efforts to protect and restore the environment

We are committed to environmental responsibility recognising the importance of protecting and restoring the natural world.
We prioritise sustainable practices in our operations, minimise our ecological footprints, and actively seek opportunities to
contribute positively to environmental conservations efforts. Our dedication to respecting and safeguarding the environment
extends to promoting awareness, implementing green initiatives, and continuously improving our sustainability practises for the
benefit of current and future generations. Our commitment extends beyond compliance to environmental regulations; we strive
to be leaders in sustainable business practices by investing in eco-friendly technologies, collaborating with stakeholders on
environmental initiatives, and continually improving our environmental performance. By integrating environmental stewardship
into our core values and decision-making processes, we are dedicated to making a positive impact on the environment and
fostering a greener, more sustainable future.
SDG Linkages-

Essential Indicators
1. Details of total energy consumption (in Joules or multiples) and energy intensity
Unit@ FY 23-24 FY 22-23
From renewable sources
Total electricity consumption (A) GJ 17223 18037
Total fuel consumption (B) GJ - -
Energy consumption through other sources (C) (Waste Heat GJ 167932 150508
Recovery)
Total energy consumption (A+B+C) GJ 185156 168545
From non-renewable sources
Total electricity consumption (D) GJ 15334 13327
98 | Thirumalai Chemicals Limited

Parameter Unit@ FY 23-24 FY 22-23

Total fuel consumption (E) GJ 292710 674298
Energy consumption through other sources (F) GJ 0 0
Total energy consumed from non renewable sources (D+E+F) GJ 308044 687625
Total energy consumed (A+B+C+D+E+F) GJ 493200 856170#
Energy intensity per rupee of turnover (Total energy consumption/ GJ / million INR 24.36 46.35
turnover in rupees lakhs)
Energy intensity per rupee of turnover adjusted for Purchasing Power GJ / million INR 557.26 1060.59
Parity (PPP*) adjusted for
(Total energy consumed / Revenue from operations adjusted for PPP) PPP
Energy intensity in terms of physical output GJ / MT of 3.23 5.60
production
* PPP conversion factor, GDP (` per international $) by World Bank is considered for calculation.
@ GJ – Giga Joules
# For FY2022-23, the energy values are revisited and restated.
Note: Indicate if any independent assessment/ evaluation/assurance has been carried out by an external agency? (Y/N) If yes,
name of the external agency.
No assessment by external agency has been conducted in the current reporting year.

2. Does the entity have any sites/facilities identified as designated consumers (DCs) under the performance, achieve,
and trade (PAT) Scheme of the Government of India? (Y/N) If yes, disclose whether targets set under the PAT scheme
have been achieved. In case targets have not been achieved, provide the remedial action taken if any.
Not applicable. There are no sites/facilities that have been identified as Designated Consumers (DCs) under the Performance,
Achieve and Trade (PAT) Scheme of the Government of India

3. Provide details of the following disclosures related to water, in the following format:
Parameter FY 23-24 FY 22-23
Water withdrawal by source (in kilolitres)
(i) Surface water Nil Nil
(ii) Groundwater Nil Nil
(iii) Third-party water (Municipal Water Sources) 749810 567710
(iv) Seawater / desalinated water Nil Nil
(v) Others Nil Nil
Total volume of water withdrawal (in kilolitres) (i + ii + iii + iv + v) 749810 567710
Total volume of water consumption (in kilolitres ) 741832 556663
Water intensity per rupee of turnover (Total water consumption / Revenue from 36.63 30.14
operations) kL / million INR
Water intensity per rupee of turnover adjusted for Purchasing Power Parity 838.18 689.57
(PPP*)
(Total water consumption / Revenue from operations adjusted for PPP)
kL / million INR adjusted for PPP
Water intensity in terms of physical output 4.85 3.64
kL / MT of production
* PPP conversion factor, GDP (` per international $) by World Bank is considered for calculation

Note: Indicate if any independent assessment/ evaluation/assurance has been carried out by an external agency? (Y/N) If yes,
name of the external agency.
No assessment by external agency has been conducted in the current reporting year
 Statutory Reports Annual Report 2023-24 | 99

4. Provide the following details related to water discharged

Parameter FY 23-24 FY 22-23
Water discharge by destination and level of treatment (in kilolitres)
(i) To Surface water - -
No treatment - -
With treatment – please specify level of treatment - -
(ii) To Groundwater - -
No treatment - -
With treatment – please specify level of treatment - -
(iii) To Seawater - -
No treatment - -
With treatment – please specify level of treatment - -
(iv) Sent to third-parties - -
No treatment - -
With treatment – please specify level of treatment 7978* 11047*
(v) Others - -
No treatment - -
With treatment – please specify level of treatment - -
Total water discharged (in kilolitres) 7978 11047
*Ranipet manufacturing facility is Zero Liquid Discharge unit. The above-mentioned discharge pertains to Dahej Plant.

Note: Indicate if any independent assessment/ evaluation/assurance has been carried out by an external agency? (Y/N) If yes,
name of the external agency.
No assessment by external agency has been conducted in the current reporting year

5. Has the entity implemented a mechanism for zero liquid discharge? If yes, provide details of its coverage and
implementation.
Out of the two manufacturing facilities, Ranipet manufacturing unit has been 100% Zero Liquid Discharge since 2006. ZLD was
audited and certified by IIT Madras in 2021 for adequacy.

6. Please provide details of air emissions (other than GHG emissions) by the entity, in the following format:

Parameter Unit@ FY 23-24 FY 22-23

NOx µg/m3 56 50
SOx µg/m3 145 80
Particulate matter (PM) µg/m3 32 45
Persistent organic pollutants (POP) - NA NA
Volatile organic compounds (VOC) µg/m3 12 12
Hazardous air pollutants (HAP) - NA NA
Others (Carbon Monoxide) µg/m3 14 15
Note: Indicate if any independent assessment/ evaluation/assurance have been carried out by an external agency? (Y/N) If yes,
name of the external agency.
No assessment by external agency has been conducted in the current reporting year
100 | Thirumalai Chemicals Limited

7. Provide details of greenhouse gas emissions (Scope 1 and Scope 2 emissions) and its intensity:
Parameter Unit@ FY 23-24 FY 22-23
Total Scope 1 emissions (Break-up of the GHG into CO2, CH4, N2O, Metric tonnes of 101475 123850
HFCs, PFCs, SF6, NF3, if available) CO2 equivalent
Total Scope 2 emissions (Break-up of the GHG into CO2, CH4, N2O, Metric tonnes of 3050 3989
HFCs, PFCs, SF6, NF3, if available) CO2 equivalent
Total Scope 1 and Scope 2 emissions per rupee of turnover (Total Metric tonnes of 5.16 6.92
Scope 1 and Scope 2 GHG emissions / Revenue from operations ) CO2 equivalent /
million INR
Total Scope 1 and Scope 2 emission intensity per rupee of turnover Metric tonnes of 118.10 158.36
adjusted for Purchasing Power Parity (PPP*) (Total Scope 1 and CO2 equivalent
Scope 2 GHG emissions / Revenue from operations adjusted for / million INR
PPP) adjusted for PPP
Total Scope 1 and Scope 2 emission intensity in terms of physical Metric tonnes of 0.68 0.84
output CO2 equivalent /
MT of production
* PPP conversion factor, GDP (` per international $) by World Bank is considered for calculation

Note: Indicate if any independent assessment/ evaluation/assurance has been carried out by an external agency? (Y/N) If yes,
name of the external agency.
No assessment by external agency has been conducted in the current reporting year

8. Does the entity have any project related to reducing greenhouse gas emission? If yes, then provide details .
The company has identified and initiated several projects aimed at reducing greenhouse gas(GHG) emissions. These projects
are part of our ongoing commitment to sustainability and environmental responsibility.
• We are planning to switch Fuel from FO to PNG for thermic fluid heaters resulting in 10% emission reduction.
• Utilise excess steam generated in plant in purification section to reduce FO consumption which reduces the burning of FO/
PNG, hence reducing emissions.

9. Provide details related to waste management by the entity, in the following format:
Parameter FY 23-24 FY 22-23
Total waste generated (in metric tonnes)
Plastic waste (A ) 0 0.05
E-waste (B) 2.04 0.4
Bio-medical waste (C) 0.001 0
Construction and demolition waste (D) 0 0
Battery waste (E) 0 0
Radioactive waste (F) 0 0
Other Hazardous waste. Please specify, if any. (G) 5662.0 5216.0
Other Non-hazardous waste generated (H). Please specify, if any. 231.0 51.1
(Break-up by composition i.e. by materials relevant to the sector)
Total (A + B + C + D + E + F + G + H) 5895.0 5267.5
Waste intensity per rupee of turnover (Total waste generated/ Revenue from 0.29 0.29
Operations) MT/ million INR
Waste intensity per rupee of turnover adjusted for Purchasing Power Parity 6.66 6.53
(PPP*) (Total waste generated / Revenue from operations adjusted for PPP)
MT/ million INR adjusted for PPP
Waste intensity in terms of physical output 0.039 0.034
MT/ MT of production
For each category of waste generated, total waste recovered through recycling, re-using or other recovery operations (in
metric tonnes)
 Statutory Reports Annual Report 2023-24 | 101

Parameter FY 23-24 FY 22-23

Category of waste
(i) Recycled 12.4 7.85
(ii) Re-used NA NA
(iii) Other recovery operations NA NA
Total 12.4 7.85
For each category of waste generated, total waste disposed of by nature of disposal method (in metric tonnes)
Category of waste
(i) Incineration 0 0
(ii) Landfilling 32.5 94#
(iii) Other disposal operations 4847.3 5165.6#
Total 4880.0 @ 5260.0 @
* PPP conversion factor, GDP (` per international $) by World Bank is considered for calculation
# Values in some categories have changed for FY23, because of regrouping of waste categories as per SEBI guidelines.
@ The difference in value between the waste generated and disposed is the ATFD Salt waste stored inside the facility as per the
regulatory norms.
Note: Indicate if any independent assessment/ evaluation/assurance has been carried out by an external agency? (Y/N) If yes,
name of the external agency
No assessment by external agency has been conducted in the current reporting year.

10. Briefly describe the waste management practices adopted in your establishments. Describe the strategy adopted
by your company to reduce the usage of hazardous and toxic chemicals in your products and processes and the
practices adopted to manage such wastes.
1.  The Ranipet Unit is ZLD from 2006 onwards. All the waste waters generated in the unit is treated and recycled back into
the system.
2.  The Hazardous Waste generated in the manufacturing units are stored and disposed as per the Hazardous Waste
Management, Handling and Transboundary rules 2016.
3.  The Scrubber Solution which is a PA Plant effluent is collected and used as a raw material for the manufacture of Fumaric
Acid (Wealth from Wastes). The emissions from the Scrubber and Thermic Fluid Heater systems are connected online and
monitored on a 24 X 7 basis. These emissions are also monitored by TNPCB and CPCB. E-Waste generated in the unit is
disposed to TNPCB authorised E-Waste recyclers on a regular basis

11. 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:
Whether the conditions of environmental approval
Sr.
Location of operations/offices Location of operations/offices / clearance are being complied with? (Y/N) If no, the
No.
reasons thereof and corrective action taken, if any.
No Operations in these areas. All operations in SIPCOT and GIDC complexes earmarked for industry with valid EIA and EC’s

12. Details of Environmental Impact Assessments of projects undertaken by the entity based on applicable laws, in the
current financial year:
Results
Whether conducted by
Name and brief communicated in Relevant Web
EIA Notification No. Date independent external
details of project public domain (yes/ link
agency (Yes / No)
no)
Not applicable and all manufacturing facilities are located at Industrial estate areas.
102 | Thirumalai Chemicals Limited

13. 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 there under (Y/N). If not, provide details of all such non-compliances:
Yes, we are fully compliant with the applicable environmental law/ regulations and guidelines in India.

Specify the law / regulation Any fines / penalties / action taken by

Sr. Provide details of Corrective action
/ guidelines which was not regulatory agencies such as pollution
No. the non-compliance taken if any
complied with control boards or by courts
Not applicable

Leadership Indicators
1. Water withdrawal, consumption and discharge in areas of water stress (in kilolitres):
For each facility / plant located in areas of water stress, provide the following information:
(i) Name of the area: Not applicable
(ii) Nature of operations: Not applicable
(iii) Water withdrawal, consumption and discharge in the following format:
FY 23-24 FY 22-23
Water withdrawal by source (in kilolitres)
(i) Surface water
(ii) Groundwater
(iii) Third party water
(iv) Seawater / desalinated water
(v) Others
Total volume of water withdrawal (in kilolitres)
Total volume of water consumption (in kilolitres)
Water intensity per rupee of turnover (Water consumed / turnover)
Water intensity (optional) – the relevant metric may be selected by the entity
Water discharge by destination and level of treatment (in kilolitres)
(i) Into Surface water
No treatment
With treatment – please specify level of treatment Not applicable
(ii) Into Groundwater
No treatment
With treatment – please specify level of treatment
(iii) Into Seawater
No treatment
With treatment – please specify level of treatment
(iv) Sent to third-parties
No treatment
With treatment – please specify level of treatment
(v) Others
No treatment
With treatment – please specify level of treatment
Total water discharged (in kilolitres)
Note: Indicate if any independent assessment/ evaluation/assurance has been carried out by an external agency? (Y/N) If yes,
name of the external agency.
No independent assessment/ evaluation/assurance has been carried out by an external agency.
 Statutory Reports Annual Report 2023-24 | 103

2. Please provide details of total Scope 3 emissions & its intensity, in the following format:
Parameter Unit@ FY 23-24 FY 22-23
Total Scope 3 emissions ((Break-up of the GHG into CO2, CH4, N2O, Metric tonnes of We are in the No assessment
HFCs, PFCs, SF6, NF3, if available) CO2 equivalent process of was done in FY
Total Scope 3 emissions per rupee of turnover (in lakhs) identifying, 22-23.
assessing, and
cataloging
our Scope 3
emissions.
Total Scope 3 emission intensity (optional) – the relevant metric may -
be selected by the entity
Note: Indicate if any independent assessment/ evaluation/assurance has been carried out by an external agency?
(Y/N) If yes, name of the external agency.
No independent assessment/ evaluation/assurance has been carried out by an external agency.

3. With respect to the ecologically sensitive areas reported at Question 11 of Essential Indicators above, provide details
of significant direct & indirect impact of the entity on biodiversity in such areas along-with prevention and remediation
activities.
No ecologically sensitive areas around the unit

4. 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:
Sr. Details of the initiative (Web-link, if any, may be
Initiative undertaken Outcome of the initiative
No provided along-with summary)
1. Production of Fumaric Acid from the Adopted the Isomerisation process to produce 74.1 Cr. / Year Savings
Scrubber solution of PA Plant Fumaric Acid from Maleic Acid (Scrubber Solution)
http://www.thirumalaichemicals.com/environment.
html
2 Zero Liquid Discharge Process Implemented Zero Liquid Discharge Process 0.45 Cr. / Year Savings
http://www.thirumalaichemicals.com/environment.
html
3 PP and HDPE bags disposal to The used and damaged bags generated during the 0.02 Cr./ Year Savings
authorised recyclers process is sent to authorised recyclers instead of
Hazardous Waste

5. Does the entity have a business continuity and disaster management plan? Give details in 100 words/ web link.
Yes, the organisation has a disaster recovery plan, which is a comprehensive framework designed to ensure swift and effective
responses to unforeseen events that could disrupt operations. This plan outlines strategic measures to mitigate risks, restore
critical functions, and minimise downtime in the event of natural disasters, technological failures, or other emergencies. The
responsibility for the Business Continuity and Disaster Management plan lies with the Safety Department Head, referencing ISO
14001:2015, and ISO 45001 Clause 8.2- Emergency Preparedness and Response.
The procedure involves identifying potential emergencies by analyzing all activities and products for their environmental impact.
It also anticipates emergencies like major fires, flammable liquid releases, explosions, natural disasters, Structural Collapse,
Uncontrollable leakage of hazardous chemicals, Deluge of untreated effluent or High Pressure Steam Etc. Each one of them or
a combination of them can be an Emergency Situation
The Business Continuity and Disaster Management Plan applies to all the emergency situations which can occur in any of the
locations like the Factory premises in SIPCOT, Ranipet, Receiving terminal at Walaja Road Railway Station, Ammoor or Storage
Installation at Royapuram, Chennai near Chennai Port. The Emergency Preparedness and Response plan are prepared by the
Safety Head, Terminal Heads, and Productions Heads, approved by Management representatives ,and distributed to relevant
personnel. Regular testing, including unannounced drills, is conducted for each scenario, with observations documented for
continual improvement. Plans are regularly reviewed based on insights from mock drills and real emergencies by the Safety Head.
Web Link: https://thirumalaichemicals.com/wp-content/uploads/2023/05/BUSINESS-CONTINUITY-POLICY.pdf
104 | Thirumalai Chemicals Limited

6. 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.
Not yet assessed

7. Percentage of value chain partners (by value of business done with such partners) that were assessed for
environmental impacts.
There are vendor assessment checklist and supplier assessment checklist available covering various environmental management
parameters. These checklists enable us to track the environmental impacts of our value chain partners. While the entity has not
yet conducted an analysis of this data, we plan to do so in the future.

Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible
and transparent

TCL is affiliated with numerous reputable trade and industry chambers, enabling us to actively participate in diverse business
communities, acquire valuable insights and contribute to industry growth and development. These partnerships are instrumental
in fostering meaningful collaborations, staying informed about industry trends, and collectively striving to make a positive impact
on businesses.
SDG Linkages-

Essential Indicators
1. a. Number of affiliations with trade and industry chambers/ associations.
TCL is affiliated to 5 trade and industry chambers and associations.
b. List the top 10 trade and industry chambers/ associations (determined based on the total members of such a body)
the entity is a member of/ affiliated to.

S. Reach of trade and industry chambers/ associations

Name of the trade and industry chambers/ associations
No. (State/National)
1 Confederation of Indian Industry National
2 Indian Chemical Council National
3 Chemical Industries Association National
4 Indo American Chamber of Commerce India, USA
5 Chemicals & Petrochemicals Manufacturers Association 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.
Name of authority Brief of the case Corrective action taken
No cases were filed by any stakeholder against TCL regarding unfair trade practices, irresponsible advertising, and
anticompetitive behaviour during the financial year.

Leadership Indicators
1. Details of public policy positions advocated by the entity
Frequency of review
Whether information by board
S. Method resorted for Web-link, if
Public policy advocated available in the public (Annually/ half yearly/
No. such advocacy available
domain? (Yes/No) quarterly / others –
please specify)
1 Administrative participation by Through Industry
company personnel in Chem Skill associations covering
Development Centre (CSDC)- ~300 graduates Yes No board review -
Established for training Chemical every year including
Engineering graduates. industrial training
 Statutory Reports Annual Report 2023-24 | 105

PRINCIPLE 8: Businesses should promote inclusive growth and equitable development

At the core of our values, we endeavour to make a positive impact on the society and believe in creating opportunities that are
accessible to everyone, regardless of background or circumstances. This commitment is reflected in our CSR(Corporate Social
Responsibility) activities Through our initiatives and partnerships, we aim to empower marginalised communities, promote
diversity and inclusion, and contribute to building a more equitable and prosperous society for all. Our CSR policy covers wider
areas of principal support like Education, Health, Women Empowerment and Community development services. Our dedicated
CSR committee recommends the spending on approved CSR activities and monitors them to achieve impactful result.
SDG Linkages-

Essential Indicators
1. Details of Social Impact Assessments (SIA) of projects undertaken by the entity based on applicable laws, in the
current financial year.
Whether conducted Results
Name and brief by independent communicated in
SIA notification No. Date of notification Relevant web link
details of project external agency public domain (Yes/
(Yes/No) 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:
S Name of project for No. of project affected % Of PAFs Amounts paid to PAFs
State District
No. which R&R is ongoing families (PAFs) covered by R&R in the FY (In `)
Not Applicable

3. Describe the mechanisms to receive and redress grievances of the community.

There is a Manual system in place for community to record grievances at main entrance gate of each of facilities.

4. Percentage of input material (inputs to total inputs by value) sourced from suppliers:
FY 24 FY 23
Directly sourced from MSMEs/ small producers 66% 64 %
Directly from within India 89.5% 94.5%

5. Job creation in smaller towns – Disclose wages paid to persons employed (including employees or workers employed
on a permanent or non-permanent / on contract basis) in the following locations, as % of total wage cost
Location Current FY Previous FY
Rural 0 0
Semi-urban 13 12
Urban 72 77
Metropolitan 15 12
(Place to be categorised as per RBI Classification System - rural / semi-urban / urban / metropolitan)
106 | Thirumalai Chemicals Limited

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:
Sr. No. State Aspirational District Amount spent (In INR)
Not Applicable - - -

3. (a) Do you have a preferential procurement policy where you give preference to purchase from suppliers comprising
marginalised /vulnerable groups? (Yes/No)
Our selection of suppliers is purely based on their reputation in the Market, recommendation from any of their business
associates and our assessment of their technical ability.
(b) From which marginalised /vulnerable groups do you procure? NA
(c) What percentage of total procurement (by value) does it constitute? NA

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:
Sr. Intellectual Property based on Basis of calculating benefit
Owned/ Acquired (Yes/No) Benefit shared
No. traditional knowledge share
Nil

5. Details of corrective actions taken or underway, based on any adverse order in intellectual property related disputes
wherein usage of traditional knowledge is involved.
Name of authority Brief of the Case Corrective action taken
None

6. Details of beneficiaries of CSR Projects:

No. of persons % of beneficiaries
Sr.
CSR Project benefitted from CSR from vulnerable and
No.
Projects marginalised groups
1 Thirumalai Charity Trust- Early detection, Monitoring and Control of Non- 39160 90 %
Communicable diseases
2 Freedom Trust, Chennai (For providing beneficiaries with artificial limbs at 93 100%
HD Kote, Karnataka)
3 Bhuvana Foundation, Chennai (For donation under CSR for its School 112 100%
"Vidya Vanam" at Anaikatty, Coimbatore.)
4 South Central India Network for Development Alternatives (SCINDeA), 430 100%
Vellore (For a Project on RO based Water Purifier with 1 Year
Comprehensive AMC Plan for Students of 1 Rural School & Renovation of
a Toilet Block in 1 Rural School)
 Statutory Reports Annual Report 2023-24 | 107

PRINCIPLE 9: Businesses should engage with and provide value to their consumers in a responsible manner

Our company operates with a customer-centric mindset, placing a high value on engaging with our customers and providing
them with meaningful value in a responsible manner. We believe that by actively listening to our customers, understanding their
needs, and delivering products and services that meet and exceed their expectations, we can build lasting relationships and
drive sustainable growth. Our commitment to responsible engagements ensures that we prioritise transparency, fairness, and
ethical practices in all our interactions with customers, fostering trust and loyalty.
SDG Linkages-

Essential Indicators
1. Describe the mechanisms in place to receive and respond to consumer complaints and feedback.
Upon receiving a customer complaint, it is promptly directed to the respective plant for investigation. The root cause of the
problem is identified, and corrective actions are implemented. Subsequently, the details of the corrective actions taken are
communicated to the customer.

2. Turnover of products and/or services as a percentage of turnover from all products/services that carry information
about:
As a % to total turnover
Environmental and social parameters relevant to the product 100 %
Safe and responsible usage 100 %
Recycling and/or safe disposal None

3. Number of consumer complaints in respect of the following:

Current FY Previous FY
Pending Pending
Received Received
resolution at Remarks resolution at Remarks
during the year during the year
end of year end of year
Data privacy Nil Nil Nil Nil Nil Nil
Advertising Nil Nil Nil Nil Nil Nil
Cyber-security Nil Nil Nil Nil Nil Nil
Delivery of essential services Nil Nil Nil Nil Nil Nil
Restrictive trade practices Nil Nil Nil Nil Nil Nil
Unfair trade practices Nil Nil Nil Nil Nil Nil
Other 15 0 None 19 19 Quality
issues

4. Details of instances of product recalls on account of safety issues.

Number Reasons for Recall
Voluntary Recalls 0 0
Forced Recalls 0 0

5. Does the entity have a framework/policy on cyber security and risks related to data privacy? If available, provide a
web link to the policy.
Yes- Thirumalai Chemicals has a comprehensive Cyber Security policy to safeguard sensitive data, systems and networks
from cyber threat. It outlines comprehensive guidelines and procedures for ensuring the confidentiality, integrity, and availability
of information assets. By prioritising cybersecurity, we aim to protect our organisation and stakeholders from potential cyber-
attacks, and data breaches, maintaining trust, and upholding the integrity of our operations.
Weblink : https://thirumalaichemicals.com/wp-content/uploads/2023/05/CYBER-SECURITY-POLICY.pdf
108 | Thirumalai Chemicals Limited

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 the safety of products/services.
There have been no instances of issues related to advertising, delivery of essential services, cyber security and data privacy of
customers, hence no corrective actions were taken.

7. Provide the following information relating to data breaches:

a. Number of instances of data breaches Nil

b. Percentage of data breaches involving personally TCL through its robust IT infrastructure ensures complete
identifiable information of customers record of any data breach incidence. Since there were no data
breaches during the reporting period
c. Impact, if any, of the data breaches None

Leadership Indicators
1. Channels / platforms where information on products and services of the entity can be accessed (provide web link,
if available).
TCL’s services and information can be accessed through the website www.thirumalaichemicals.com.

2. Steps taken to inform and educate consumers about safe and responsible usage of products and/or services.
The customers are provided the required process and product handling annexures for safe usage.

3. Mechanisms in place to inform consumers of any risk of disruption/discontinuation of essential services.

In case of unavailability of products customers are kept duly informed.

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)
The information such as product Name, Batch No. CAS No., Date of production, Date of Expiry, supplier details, bag net weight
& gross weight, labelling instructions, hazard statements, & precautionary statements are displayed on the product. TCL hasn’t
carried out any customer satisfaction survey relating to the major products / services of the entity.