INDEX

S.NO. CHAPTER PARTICULARS PAGE NO.

1 CHAPTER 1 COMPANY OVERVIEW 2

2 CHAPTER 2 OUR COMMITMENT TO UNGC 8

3 CHAPTER 3 SUSTAINABILITY & SOCIAL

ACCOUNTABILITY POLICIES 9

4 CHAPTER 4 UN GLOBAL COMPACT: THE TEN PRINCIPLES

12

5 CHAPTER 5 HUMAN RIGHTS (Principles 1-2)

13

6 CHAPTER 6 LABOUR

(Principles 3-6) 18

7 CHAPTER 7 ENVIRONMENT (Principles 7-9)

29

8 CHAPTER 8 ETHICS

(Principle 10) 36

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CHAPTER I – Company Overview Gujarat Fluorochemicals Limited (GFL), a part of the Inox Group, is the largest manufacturer of chloromethanes, hydro-chloro-fluorocarbons (HCFC) and various grades of PTFE in India. The company operates its PTFE business through its manufacturing facility in Dahlej, Gujarat. The company possesses the largest PTFE facility in India and 4th largest in the world. Further, its forward and backward integrated operations make it one of the most cost competitive producers of these chemicals globally. The company has successfully created a niche for itself in the chemicals business and is set to explore markets for more value added products while continuing to gain from its other diversified businesses. Established in 1987, Gujarat Fluorochemcials Limited (GFL) is today one of the India’s largest producer of chloromethanes, refrigerants and polytetrafluoro-ethylene. We are among the few fully vertically integrated manufacturing company providing reliable and high quality products. VISION

To become the preferred the suppliers of fluoropolymers, fluoroelastomers and new

generations of refrigerants globally and achieve this status through technological,

operational and service excellence.

We shall endeavour to be a global player in our business.

We shall constantly endeavour to delight customers, workforce and all other stakeholders.

We shall do our business exercising with utmost care of environment and society at large.

MISSION We shall endeavour to always be the market leaders, by providing our customers the latest, the most innovative and the best available technologies , products and services. Through this, we shall provide to our customers the best “value for money” by producing best in class quality products at most competitive prices. VALUES We are governed by our fundamental values:

Quality: Commitment to excellence in quality

Integrity: Building trust in dealing with all stakeholders

Customer Value: delight the customers and deliver the value

Excellence: excellence in services and manufacturing practices to all our stakeholders

Innovation: enthuse our clients through our innovative approach

KEY STRENGTHS

The Company is one of the most competitive producers of fluoropolymers on account of its fully

integrated manufacturing operations beginning from basic raw materials to end product

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The Company’s robust R&D facilities helps it develop new products and grades in a short span of time enabling it to enhance its offerings portfolio

The Company operates in an industry which requires huge capex. Thus, it is unlikely to face new international competition in the industry

The Company’s continuous engagement with its customers helps it understand and fulfil their requirements

The Company is capable of carrying out further expansion with minimal investments in future

The Company has tie ups with global majors such as Chemours/AGC for supplying their needs of fluoropolymers due to GFL’s efficient &integrated plants

Product portfolio Refrigerants

The company is a prominent manufacturer and exporter of Chloro-Fluorocarbon refrigerant gases R-12 & R-22. These grades are manufactured in technical collaboration with M/s Pennwalt Corporation USA (now Atochem, North America), under the "Refron" brand name. In addition to HCFC, the Company is also engaged in supply and export of new genre gases in 400 & 500 series. Further, its contemporary manufacturing facilities, quality control and adequate storage facilities helps it stand competition in the market. In the coming period, the company plans to enter the more eco-friendly domain of CFC free refrigerants segment comprising of 404A, 407C, 410A. Chemicals

The chemical business segment of GFL comprises of Caustic Soda Lye, Methylene Chloride, Hydrogen Gas, AHCL, HCL and H2SO4. The Company carries out stable business operations with its focus on capacity utilization and cost of raw materials namely, salt, methanol and power. In case of power, the company possesses its own CPP capacity which is based on coal, gas and wheel in power from GFL owned wind turbines while the balance power is purchased from grid/power exchange. Fluoropolymers

GFL is a leading player in PTFE market, engaged in operation of one of the largest PTFE facilities in the world, accounting for 11% of the global PTFE capacity. The major key barriers to entry in this market are high capex intensity, restricted access to technology, the availability of key raw materials, long and stringent product development, and an approval cycle with customers. The company benefits from the advantage of these barriers as new players cannot easily enter this market on a standalone basis. The company has the capable of producing a wide range of chemicals through its vertically integrated facility, which makes it one of the most cost competitive producers of PTFE globally. The operational and costing advantage of this integration has ensured that the Company is well placed competitively and is less susceptible to the volatility of the commodity cycle. Further, the company obtains benefits from increasing capacity utilisation which results in a significant increase in operating leverage, higher operating margins and better return ratios. GFL’s gradual shift to value added products for its customers prompts it to generate better margins and more stable pricing for its products.

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Fluorospecialty Business

Looking at the recent upsurge in fluorine based Agro and Pharma molecules , and also taking in to consideration our niche capability of making Fluorine based chemicals, our Company, for past few years, has been working on establishing the capability of developing these Fluor intermediates through non-infringing competitive processes at the state of the art R&D Centre set up at Ranjitnagar. The team of highly capable scientists and support technical teams have been working tirelessly on new product developments. In past few years of its existence the R&D has successfully developed many Molecules for Pharmaceutical and Agro applications against specific enquiries. A couple of products have already been launched earlier at Ranjitnagar Unit and one of the product is already launched at the Dahej A Unit last year and a few more are slated to be launched this year at Ranjitnagar Unit in the Multi Product Plant clusters, which will be commissioned soon. These Multiproduct Plants at Ranjitnagar Unit will have capability to handle different chemistries making the Plants highly versatile and flexible, where product replacement and introduction of new products at short notice to service the market is possible. The R&D Centre, over the few years of its existence, has developed dexterity and alacrity required to support and sustain this business, where speed of response to customer’s enquiries is of prime importance. Having already established credibility with major innovator Companies across the globe and also in India, we are upbeat about the prospects of this Business.

Subsidiaries Inox Leisure Limited: INOX Leisure Limited (INOX) is amongst India’s largest multiplex chains with 143 multiplexes and 595 screens in 67 cities as on 30th June, 2019. INOX has redefined movie experiences in India making it truly a 7-star experience. Each INOX property is unique with its own distinct architecture and aesthetics. Beyond the normal screens, INOX also has INOX INSIGNIA for the discerning audience or KIDDLES for young patrons or MX4D® EFX Theatre for an immersive experience or the panoramic viewing with ScreenX at select locations. INOX brings the very latest in projection and audio technology with INOX Laserplex, IMAX & INOX ONYX. Some of the key multiplex features include plush micro adjustable leather recliners with a butler on call facility, gourmet meal choices by celebrity chef, designer staff uniforms. Inox Wind Limited: Inox Wind Limited is a fully integrated wind energy solution provider engaged in manufacture of wind turbines in India. The Company has a wind turbine manufacturing capacity of 1,600 MW and a cumulative installed base of more than 2.6 GW out of India’s installed base of 34 GW. The company has manufacturing facilities near Ahmedabad (Gujarat) and Barwani (Madhya Pradesh) for blades & tubular towers and at Una (Himachal Pradesh) for hubs & nacelles. Inox Renewables Limited: Commenced in 2007, Inox Renewables Limited is engaged in business of wind farming. Presently, the Company operates wind farms with a total capacity of 31 MW.

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Joint venture and foreign subsidiaries GFL has strengthened its supply chain of critical raw materials through its investment in joint venture, Morocco. It has also incorporated two subsidiaries to strengthen its presence in the international markets - Gujarat Fluorochemicals Americas LLC and Gujarat Fluorochemicals GmbH.

PRINCIPLE OF BUSINESS OPERATIONS

GFL has adopted the following principles for all its business operations: Principle 1: We will conduct Businesses and govern ourselves with Ethics, Transparency and Accountability. Principle 2: We will provide goods and services that are safe and contribute to sustainability throughout their life cycle. Principle 3: We will promote the well-being of all employees. Principle 4: We will respect the interests of, and be responsive towards all stakeholders, especially those who are disadvantaged, vulnerable and marginalized. Principle 5: We will respect and promote human rights. Principle 6: We will respect, protect, and make efforts to restore the environment. Principle 7: We will engage in influencing public and regulatory policy, should do so in a responsible manner. Principle 8: We will support inclusive growth and equitable development. Principle 9: We will engage with and provide value to their customers and consumers in a responsible manner.

Manufacturing Facilities The company operates in all its business segment through its state of the art manufacturing facilities (refer table 1 for details), which facilitates simpler and more cost efficient manufacturing process. In the refrigeration segment, the company operates with one of the largest and most efficient plant of refrigerant gases. The company continuously carries out up gradation of all its facilities for quality specifications, recoveries, valorisation of by-products, energy conservation, environment and safety controls etc; through in-house technological improvement initiatives. The two major manufacturing facilities of the company are situated in Ranjitnagar (Gujarat) and Dahej. Table 1: Summary of our Manufacturing units

Plant District/City Set up in

Location Products

Ranjitnagar Ghogambha District, Gujarat

1989 Located 57 kms from Vadodara near Halol

Referigerants and Speciality Chemicals

Dahej Bharuch District, Gujarat

2007 Located 45 kms from Bharuch

PTFE

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Exports The revenue from export sale of HCFC22, PTFE, PFA, FEP, FKM accounted for about 70% in the total revenue. The key markets for HCFC22 are the Middle East, South Asia and Japan. While for PTFE exports are largely to Europe and USA. Financial Highlights During the year under review, the revenue from operation grew by 33% to Rs. 2,73,055 lakhs from Rs. 2,05,558 lakhs on account of healthy demand in the downstream industry in the domestic as well international market. While, the Company’s EBITDA grew by 37% to reach Rs. 81,606 lakhs and the Profit after Tax (PAT) grew by 162% to reach Rs. 1,27,731 lakhs in fiscal 2018-19 from Rs. 48,731 lakhs in the fiscal 2017-18. Table 2 provides a summary of the financial summary along with key ratios of the Company.

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Table 2: Summary of Standalone Financial Performance

Particulars FY 2019 FY 2018 YoY growth

Revenue (Rs in Lakhs) 2,73,055 2,05,558 33%

EBITDA (Rs in Lakhs) 81,606 59,565 37%

PAT (Rs in Lakhs) 1,27,731 48,731 162%

Key Ratios:

Debt equity Ratio (in times) 0.20 0.22 -10%

Interest coverage Ratio (in times)

13.54 11.13 22%

Current Ratio (in times) 1.61 1.35 20%

Debtors Turnover (in times) 4.50 4.50 0%

Inventory Turnover (in times) 3.01 3.07 -2%

Operating Profit Margin 23% 20% 11%

Net Profit Margin 16% 23% -30%

Return on Net worth 10% 14% -32%

Revenue Mix (Rs. in Lakhs) FY 2018-19 FY 2017-18

Caustic Soda 46200 46000

Chloromethane 35100 26500

Refrigerants 36200 31300

PTFE 111800 72300

Others 36200 20600

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CHAPTER 2 - OUR COMMITMENT TO UNGC GFL being a globally responsible entity, accepts that the corporate and organizational success requires stable economies and healthy, skilled and educated workers among other factors. It also acknowledges that sustainable companies experience increase brand trust and investor support. The company acknowledges that shining of the UN Global Compact is a win-win for business and society and sets the connection between the bottom line and the companies environmental, social and governance practices. The Company, by signing the UN Global Compact shows its commitment for establishing globally recognized framework for the development, implementation and disclosure of environmental, social and governance policies and practices. The company signed the UN Global Compact.

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CHAPTER 3 – SUSTAINABILITY & SOCIAL ACCOUNTABILITY POLICIES

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CHAPTER 4 – UN GLOBAL COMPACT: THE TEN PRINCIPLES

This year, the company has become a member of the UN Global Compact with an aim of internalizing the 10 Global Compact Principles in the areas of Human Rights, Labour, Environment and Anti-corruption within the company strategies, policies & operations. Through this, the company aims to advance the broader developmental goals of the United Nations particularly the 17 Sustainable Development Goals (SDGs).

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CHAPTER 5: HUMAN RIGHTS (Principles 1-2)

Human rights are commonly understood as those rights that are inherent to the human being (e.g., the right to education, freedom of speech). The concept of human rights acknowledges that every single human being is entitled to enjoy his or her human rights without distinction as to race, color, sex, language, religion, political or other opinion, national or social origin, property, birth or other status.

Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights. Principle 2: Businesses should ensure that they are not complicit in human rights abuses.

UNGC Principle

No.

UNGC Principle Action for Implementation

HUMAN RIGHTS

PRINCIPLE 1

Business should

support and respect the

protection of internationally

proclaimed human rights

The Company has always respected and subscribed to the protection of internationally proclaimed human rights (Universal Declaration of Human Rights). It aims to encourage the protection of human rights through organization wide policy (Policy No: HR/67 – Guideline on Human Rights). This policy is available in the HR Operations Manual which is attached to this document.

All employees have been taken through awareness programme on protection of human rights and the employee handbook also covers aspects of human rights policy of the company which has been distributed to all the employees. Not only company employees but also contract labors have been taken through the human rights awareness program.

The company’s focus is on employee and emphasizes on Fairness

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and good governance. It strengthens employee relation by ensuring a safe and healthy workplace with the involvement & commitment of all the employees. All employees are covered under National Social Security schemes. The Company also voluntarily covers all employees and their immediate families under a group medical scheme over and above, all employees are covered under a onsite and offsite insurance scheme. Recruitment in the company are based on the policy of fairness and non-discrimination and in compliance prevailing labour laws. There are several policies in relation to human rights issues significant among them are: 1. HR/51 – GUIDELINE ON PREVENTION, PROHIBITION &

REDRESSAL OF SEXUAL HARASSMENT OF WOMEN AT WORKPLACE

2. HR/68 – GUIDELINE ON EQUAL EMPLOYMENT OPPORTUNITY, CHILD LABOUR, GENDER EQUALITY & PROTECTION OF HUMAN RIGHTS

As part of implementation of Sustainable Supply Chain, all our major suppliers have been shared with the company’s policy on “Sustainable Procurement”. Clause 3.2 of the said policy deals with human rights and covers aspect of Forced and Child labour, Working hours and Incentives and Equality. Our suppliers have signed a declaration to accept and take necessary action to abide by the policy.

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The company has Human Rights Protection & Compliance framework which provides employees to raise any issue related to human right violation. It also reiterates the no retaliation philosophy of the company.

Suggestion and grievance boxes have been installed various parts of our locations through employees can register complaints in this regard.

There has been no reported cases of human rights violation.

PRINCIPLE 2

Businesses should ensure that they are not complicit

in human rights abuses.

GFL ensures that in its entire supply chain, there is no human right abuse. The company is committed to ensure an inclusive growth of the society and protect the interest of indigenous people. Awareness program on human rights and campaign on human rights laws and policies are conducted regularly. The company has well defined human resource processes regarding succession planning, reward and recognition and leadership development. Skill gaps are identified within the organization and steps are taken to address these gaps to ensure that right people are in the right job. The company provides best of amenities and have employee

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centric policies. Keeping in mind employee needs and their future growth. Some of the benefits in which all employees are covered are listed below: 1. Provident Fund 2. Gratuity 3. Group Medical Insurance 4. Personal Accident Insurance 5. Loans & Advances 6. Higher Study Scheme 7. Spontaneous Recognition Scheme

There are policies in place through which the company ensures it is not complicit in human rights abuses. GFL is committed to treat individuals in all aspects of employment on the basis of ability irrespective of nationality, race, caste, creed, religion, gender etc. The Company does not tolerate racial, sexual or any other kind of discrimination or harassment. There is no disparity between salaries of men and women employees and the company follows the principle of equal pay for equal work. The company values the principle set in the ILO convention, 1958 to eliminate “discrimination in respect of employment and occupation”. The following policies are in place: 1. HR/2 – RECRUITMENT & SELECTION OF CANDIDATES 2. HR/20 – GUIDELINES ON PERFORMANCE MANAGEMENT

SYSTEM AND DEVELOPMENT PLAN 3. HR/21 – PERFORMANCE EVALUATION & TRAINING NEED

ASSESSMENT FOR TECHNICIANS 4. HR/22 – PERFORMANCE ASSESSMENT OF

ENGINEER/EXECUTIVECADRE EMPLOYEES 5. HR/28 – GUIDELINE ON SEPARATION PROCESS OF EMPLOYEES

6. HR/51 – GUIDELINE ON PREVENTION, PROHIBITION &

REDRESSAL OF SEXUAL HARASSMENT OF WOMEN AT WORKPLACE

7. HR/65 - GUIDELINE ON FORCE BONDED LABOUR PROHIBITION 8. HR/66 - GUIDELINE ON ANTI SLAVERY AND ANTI HUMAN

TRAFFICKING 9. HR/67 - GUIDELINE ON PROTECTION OF HUMAN RIGHTS 10. HR/68 – GUIDELINE ON EQUAL EMPLOYMENT OPPORTUNITY,

CHILD LABOUR, GENDER EQUALITY & PROTECTION OF HUMAN RIGHTS

11. HR/76 - GUIDELINE ON WAGE & SALARY DETERMINATION All the above policies are part of an employee handbook. At present, declaration for acceptance and adherence of the above policies is part of the joining process.

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The company has Protection & Compliance framework related to Anti slavery, Human Trafficking, Discrimination, Harassment, Forced/Compulsory Labour, Equal Employment Opportunity, Gender Equality & Minority Rights protection as enumerated in the policies mentioned above which provides employees a platform to raise any issue related to any such violation. It also reiterates the no retaliation philosophy of the company.

Suggestion and grievance boxes have been installed various parts of our locations through employees can register complaints in this regard.

There has been no complaints, legal cases, rulings or fines against the company in these aspects. As per Annual Report 2018-19 of the company, there was no complaint received from any stakeholder regarding human rights violation, forced labour, sexual harassment and discrimination in employment during the financial year.

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CHAPTER 6: LABOUR (Principles 3-6)

UNGC Principle

No.

UNGC Principle

Action for Implementation

LABOUR

PRINCIPLE 3

Businesses should uphold the freedom

of association and the

effective recognition of

the right to collective

bargaining.

The company recognizes the fact that employees have the inherent right to collective bargaining and protect human lab our dignity. The company respects the rights of all its employees to form associations in accordance with the local laws as applicable to achieve a form of workplace democracy. Through its HR policy: HR/43 – GUIDELINE ON EMPLOYEE RELATION, GFL upholds this right of all employees. The above guideline is a reiteration of the company to uphold the principles of the following ILO conventions:

S. No.

Convention/Recommendation No.

Issue Addressed

1 ILO Convention 87 Freedom of Association

2 ILO Convention 98

Right to Organise and Collective Bargaining

3 ILO Convention 135 Workers’ Representatives

At locations, there are Work Committees as required under the Industrial Disputes Act, 1947, representing workmen, which engage periodically with the management to discuss and resolve work and condition of service related issues. Not only our direct workmen, the company recognizes the right of association and collective bargaining by the Contract Labors and also participates in bargaining meetings.

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Over and above this, various other committees are established for workers participation in different areas of work life. Such committees are:

1. Canteen Committee 2. Sports Committee 3. Transport Committee 4. Cultural Committee 5. Magazine Committee 6. Safety Committee 7. Quality Circle

These committees regularly meet and discusses issues relating to respective areas alongwith Management Representative. The company boasts of a very effective Quality circle culture. Our Quality Circle teams have won state and national level awards.

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Quality Circle Award winning team of GFL unit

Research shows that organizations with engaged employees generate 2.5 times the revenue than those organizations which has disengaged employees. It has been a constant endeavour for HR function not only to give a challenging work environment to employees but also to give them space in their work environment to have rejuvenating experience through recognition, interaction and learning games.

For the fifth consecutive year, Inter Departmental Cricket competition was organized in the Plants. Around 500 employees participated in the bonanza across the company. Not only sports, GFL Dahej organized Family Day to value the contribution the employees’ families in the company’s success.

For the Company, our employees are partners in our progress wherein the relationship is built on trust and mutuality. Employees are encouraged to give their workplace improvement suggestions through the “Prayas” – an employee suggestion scheme in the Plants. In total, 913 suggestions have been received since last year.

Family Day Celebration at Dahej

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Suggestion Scheme winners under ‘Prayas’ initiative

To honor long term contribution shown by the employees, the company recognized employees who have completed 5/10/15/20 & 25 years of services with the Organization. Long Service Felicitation programs were organized across all locations for all such dedicated employees.

PRINCIPLE

4

Businesses should uphold

the elimination of

forced or compulsory

labour.

GFL respects the dignity of labour and all forms of forced and compulsory labour. The company has rolled out the following policies in this regard: 1. HR/65 – GUIDELINE ON FORCED/BONDED LABOUR PROHIBITION 2. HR/66 – GUIDELINE ON ANTI SLAVERY & HUMAN TRAFFICKING The above policies are a part of HR Operations Manual and Employee Handbook and are in reiteration of the company’s commitment to the following ILO convention:

S. No.

Convention/ Recommendation No.

Issue Addressed

1 ILO Conventions 29 and 105 Forced Labour and Abolition of

Forced labour

Long Service Awardees at Noida

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The Company follows 8 hours shift and six day work schedule and follows all the provisions of hours of work, weekly day off rest, extra wages for overtime, leave etc as per the Factories Act, 1948. These matters are covered in the Employee Handbook and awareness session held. Even contract labors are given awareness program on this subject. The Company strictly follows the Payment of Minimum Wages Act, 1948. The company is a free will company and the employee can quit their work at any point of time serving the requisite notice period as stipulated in their terms of appointment. The company has Protection & Compliance framework which provides employees to raise any issue related to forced/compulsory labour and anti slavery and human trafficking violation. It also reiterates the no retaliation philosophy of the company.

Suggestion and grievance boxes have been installed various parts of our locations through employees can register complaints in this regard.

There has been no reported cases of any such violation. The company has taken Social Accountability goals which are widely publicized across the company. The company has initiated actions to get itself SA8000 certified through Rina India Pvt. Limited. The preliminary assessment has been done for both Dahej & Ranjitnagar unit. To drive Social Accountability, each site has constituted Social Performance Team (SPT) as part of the certification program. To monitor progress and to extend top management support, Social Accountability Steering Committee has been formed.

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Social Accountability Campaign across Locations

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Social Accountability Awareness Booklets distributed at locations

after the Training Session

Social Accountability Awareness Pamphlets distributed at locations

after the Training Session

PRINCIPLE

5

Businesses

should uphold the effective abolition of child labour

GFL believes in protection of young and child population of the country and is committed not to employ child labour. The company has a “no child labour policy” as enumerated in the HR guideline: HR/74 – GUIDELINE ON CHILD LABOUR. This is a part of HR Operations Manual and are in reiteration of the company’s commitment to the following ILO convention:

S. No.

Convention/ Recommendation

No. Issue Addressed

1 ILO Convention 182 Worst Forms of Child Labour

2 The United Nations Convention on the Rights of the Child

The Company ensures that no child labour is engaged by the suppliers and the service providers and a specific clause is mentioned in this

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regard in all the service contracts/purchase orders. All suppliers have to declare that they have understood and will take necessary steps to comply with the Company’s Policy on Sustainable Procurement. Clause 3.2 of the said policy deals with human rights and covers aspect of Forced and Child labour, Working hours and Incentives and Equality. Our suppliers have signed a declaration to accept and take necessary action to abide by the policy.

As per our recruitment process, all prospective employees have to submit their age verification document alongwith their job application. All applicants whose age is below 18 are summarily rejected. To further augment the process in the digitized joining process, no person can complete the joining process if his age is calculated to be below 18 years by the system the moment the person keys in his date of birth. For Contract Labors, who are engaged at our sites, labors are allowed

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only after they submit their age verification proof. Clause 6 (d) of the HR Guideline – HR/29: GUIDELINE ON MANAGEMENT OF CONTRACT LABOUR AT PLANT/SITE/OFFICE in the HR Operations Manual mentions that no contract labour below the age of 18 yrs will be engaged in the Company.

The company has Protection & Compliance framework which provides employees to raise any issue related to child labour violation. It also reiterates the no retaliation philosophy of the company.

Suggestion and grievance boxes have been installed various parts of our locations through employees can register complaints in this regard.

There has been no reported cases of any such violation.

PRINCIPLE 6

Businesses should uphold

the elimination of discrimination in respect of employment

and occupation.

The company believes that human rights are the universal birth right of every person and all are entitled to the same regardless of discrimination of any kind. The company has in place the following policies to ensure a non discriminatory workplace regardless of “race, color, sex, religion, political or other opinion, national or other origin, birth or other status”. 1. HR/51 - GUIDELINE ON PREVENTION, PROHIBITION AND

REDRESSAL OF SEXUAL HARASSMENT OF WOMEN AT WORKPLACE

2. HR/68 - GUIDELINE ON EQUAL EMPLOYMENT OPPORTUNITY,CHILD LABOUR GENDER EQUALITY PROTECTION OF MINORITY RIGHTS

3. HR/76 - GUIDELINE ON WAGE & SALARY DETERMINATION These policies are based on the following ILO Conventions:

S. No.

Convention/ Recommendation No.

Issue Addressed

1 ILO Convention 100 and 111 Equal Remuneration and Discrimination-Employment and Occupation

2 ILO Convention 131 Minimum Wage Fixing

3 The United Nations Convention to eliminate All Forms of Discrimination Against Women.

4 The United Nations Convention on the Elimination of All forms of Racial Discrimination

The Company has a Protection & Compliance framework in regards to Sexual Harassment and each site has a Committee to address related complaints. All company employees are extensively trained to prevent unwanted conduct and protect individual dignity.

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As per the HR Operations Manual & Employee Handbook, employees are employed, trained, promoted and remunerated solely on the basis of performance. The company is an equal opportunity employer without any sexual discrimination based solely on the category of the work performed and in line with the Equal Remuneration Act, 1976. Employee treatment are non-discriminatory and breach of such policies can result in disciplinary action leading to and including separation from service. The Company has in place a structured and elaborate compliance framework to address and redress various aspects of discrimination.

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CHAPTER 7: ENVIRONMENT (Principles 7-9)

UNGC Principle

No.

UNGC Principle Action for Implementation

ENVIRONMENT

PRINCIPLE 7

Businesses should support a Precautionary

Approach to Environmental

Challenges

The Corporate Integrated Management System Policy is the guiding document focusing on our commitment towards Quality, Health, Safety, Environment, Sustainability, Security & Responsible Care across the supply chain. The following actions are taken in this regard: 1. Water meters were installed at various locations for better

monitoring of water consumption. Water level switches were installed in all the water tanks to avoid water flow. This has resulted in saving of 20 M3/Day.

2. With an initial capital investment of INR 0.2 million, we have installed a rain water harvesting system to capture water from canal outside plant area. Rainwater harvesting system includes two filter modules for removing suspended solids and total dissolved solids from water and final water having TDS less than 500 ppm. Rain water harvesting system enable us to replenish almost 450 m3 each year. We are also planning to extend same module in other part of Ranjitnagar premises.

3. During the FY 2010-11 at Ranjitnagar we developed and implemented a process for Fluoride reduction in aqueous effluent using ion exchange technique. This has helped in recycle and reuses of low TDS water stream from utilities back to process. The water is prepared through a selective resin bed to reduce the fluoride ion less than the permissible limit of 1.5 ppm and recycled back to cooling tower. This has resulted in

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saving of 20 M3/Day.

4. Proper storm water discharge forms an integral part of our goal of safe discharge. Storm water canal and a collection pit forms part of storm water drainage system. The storm water gets collected in the collection pit during the initial monsoon shower and off season rain and if analyzed for critical parameters before letting the same in the plantation area belonging to the company. In case of any parameter being high, we pump the water back to the ETP for treatment instead of letting it out it untreated resulting in saving of 120 M3/Day.

5. To augment our zero discharge facilities we have successfully commissioned by installing Single Effect Evaporator (SEE) and Multiple Effect Evaporator (MEE) and psychometric evaporator followed by a Spray Dryer. This also enables recovery and recycle of water for reuse within process. The condensate will be recycled for making scrubbing solution. Therefore no effluent will be required to be discharged and the stated process would be a ZERO DISCHARGE process. This has resulted in saving of 10 M3/Day.

6. Installed and Operating STP for Domestic wastewater and treated water will be utilized for plantation/ gardening purposes within the premises. This has resulted in saving of 30 M3/Day.

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7. Ensuring awareness on health and environment issues amongst the community residing in proximity of the manufacturing location, the Company organized various activities like celebrating World Environment Day, World Ozone Day, National Safety Day.

8. All the major Indian manufacturing units are ISO 45001, Environmental Management System (EMS) certified and monitoring follow‐up is a part of the EMS. As required by the EMS, audits are conducted for monitoring the performance. Environmental performance is also reviewed at the Corporate at regular intervals by the Senior Management.

9. Disposal of e‐wastes and batteries to authorized agencies for recycling and ultimate disposal.

10. Examples where our products and services has been designed to address social and environmental concerns are given under following example:

a) The design of the AHCL cylinder has incorporated

safety measures that ensure no leakage occurs during transportation. Also, a special cage has been designed for the cylinders so that they do not get damaged in case of any accident.

b) As hydrogen fluoride is a health hazard, an automatic sprinkler system has been installed around AHF bullets to prevent it from spreading, in case of any leakage.

c) The R-22 production process is designed in such a way so that it eliminates organic effluents by recycling them.

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11. The Company has procedures in place for sustainable sourcing including transportation and sources more than 75% of inputs directly from the manufacturer. To decrease the fuel consumption and emission due to transmission, GFL is gradually shifting to 20-30 MT capacity vehicles from 10-16 MT ones. Also, the import consignments are now being received at nearer ports like Dahej & Hazira, instead of distant ones like Kandla & Mumbai.

The Ranjitnagar plant is a zero effluent discharge plant where around 90% of the wastewater is recycled. This has been achieved by installation of Single Effect Evaporator (SEE) and Multiple Effect Evaporator (MEE). The plant also turns all of its canteen waste to compost, thereby reducing the burden on landfill sites. The Dahej plant has a well developed Environment Management Plan (EMP) in place which mainly focuses on reduction, reuse & recycling of resources. This plant also has well defined targets for reduction of water usage and to achieve these targets, a water recycling plan has been implemented within each area in the plant.

PRINCIPLE 8

Businesses should

undertake initiatives to

promote greater

environmental responsibility

The Company strives to improve its environmental health and safety performance in a continual manner. It also encourages its suppliers to adopt environment friendly practices in their operations. In its effort to do its bit towards fighting climate change, GFL has adopted a number of initiatives to increase its energy efficiency thereby reducing carbon emissions. 1. Sourcing and use of sulphuric acid with low SO2 content and

provision of standby SO2 scrubber in the AHF plant. 2. Multi-cyclone dust collector followed by Bag filter has been

provided to control the particulate matter. 3. Installed close loop sampling system to avoid emission. 4. We have introduced cleaner fuels like RLNG for power and

efficient designs which would not only help us keep environment clean, but also ensure continuous improvement of our systems.

The Emissions/Waste generated by the company are within the permissible limits given by CPCB/SPCB for FY 2018-19. No Show cause/legal notices from CPCB/SPCB are pending as on 31st March 2019. The company has committed to frame targets under the Science Based Target Initiative (SBTI) and we are the second one in the

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Chemical Industry to do so.

PRINCIPLE 9

Businesses

should encourage the development

and diffusion of environmentally

friendly technologies

The Company has undertaken various actions to encourage clean technology, energy efficiency and renewable energy. Following are the actions taken in this regard: 1. We have 3 days training program for new joiners regarding

On-Site Emergency Planning and Safety Manual which covers all safety aspects related to Plants, Service Dept. and EHS .

2. Every six month we conduct a On-site Mock Drill and report of same is timely submitted to govt. authority, also we conduct a Fire Drill every two month.

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3. Yes we have a fully trained Emergency Squad

Team/Emergency Response Team which has more than 75 members.

4. Emergency Handling facilities like SCBA, Fire Hydrants, Water Sprinklers, OHC, First Aid box, Fire Extinguishers everything gets inspected regularly to maintain it in tip top condition. We have a weekly inspection system for all Emergency Equipments.

5. SOP’s available for all Hazardous process. 6. We have a PSM system implemented where we do a PHA &

Hazop study for all new start ups and also we follow the Management of Change procedure.

7. Safety kit is compulsory for drivers carrying HCL cylinders and also we gave a trem cards to all drivers with basic training on trem cards.

8. To minimize the adverse health effects all necessary/ suitable personnel protective equipments like helmet, safety goggles, gum boots, earmuff/ear plug and safety net etc have been/will be provided for working personnel.

9. All suggested pollution control devices & measure are checked and operated / maintained properly on regular basis.

10. All precautionary methods have been adopted by the company as well as unit is also committed towards the Health & Safety of workers and have provided a facility of pre-medical check-up of employees for detecting any kind of adverse effect on the health of employee due to the chemical or work place condition and providing opportunity to improve the working condition.

11. With our in-house competence and with understanding of the process we have designed an occupational health and safety hazards risk matrix which maps each of the potential hazardous operation with possible risk and remedial actions to be taken.

12. With an objective of minimizing the impact of spillage on-site, off-site and to protect the factory personnel, environment and public in the vicinity of the site, we have established an emergency response plan. Plan sets out standard operating procedure to be implemented in case of any chemical spill in the premises. We have provided Dyke walls, sand bags to contain spillage. We have made Safety Manual, Material Safety Data Sheets (MSDS) readily available with incident officer and in Shift Executive Office.

13. Periodical training programme to inform the employees about their task, associated risk, and safe –working practices have been undertaken. Training is also includes information

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on accident prevention, proper control and maintenance of equipment and safe material handling practices. To refresh the academic and skill improvement as per management requirement, induction training and external training have been provided to fresher’s with respect to “Industrial Safety & Health Training”. On various topics like On-Site Emergency Handling, Hazardous Chemical Handling, trainings as per Section 111a of GFR-1963 etc.

14. Fire hydrant system installed and operating team is well trained for any kind of emergency if any. Fire Tender with crew members are 24*7.

15. Manual call points for fire location identification to be installed in plant premises. Adequate numbers of fire fighting equipments and extinguishers has been installed as per requirement of the fire risk in the plant.

16. Dedicated Training given to 60 persons for First Aid through REDCROSS and 80 Person for any kind of emergency.

Furthermore, the company has undertaken a number of energy efficiency initiatives like installation of variable frequency drives and LEDs, which decrease electricity consumption. At the Ranjitnagar plant, a co-generation plant has been installed to increase efficiency of the power plant to about 80% by the usage of waste heat from exhaust gas and jacket water. This plant has also installed a groundwater recharge system that includes filter modules for removing suspended solids and total dissolved solids from the water. This system enables the replenishment of almost 450 m3 water each year. Besides these initiatives, the Company’s Dahej Plant procures renewable power generated by wind turbines.

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CHAPTER 8: ETHICS (Principle 10)

UNGC Principle

No.

UNGC Principle Action for Implementation

ETHICS

PRINCIPLE 10

Businesses should work

against all forms of

corruption, including extortion

and bribery

GFL has formulated a Code of Conduct (CoC) to ensure that the business of the Company is conducted in accordance with the highest standards of ethics and values, while complying with the applicable laws and regulations. The CoC encourages each and every Director and Officer of the Company to act in accordance with the highest standards of personal and professional integrity, honesty and ethical conduct while working at the Company’s premises, at offsite locations, at the Company’s sponsored business and social events, and/or any other place where they represent the Company.

Any instance of non- compliance of any of the provisions of the CoC is treated as a breach of ethical conduct and is viewed seriously by the Company. The Company also has a Whistleblower policy which is a mechanism to reinforce implementation of the Company’s CoC which encourages each and every Director and Officer of the Company to take positive actions which not only commensurate with the Company’s belief but are also perceived to be so. This policy provides all employees and Directors of the Company and its subsidiaries a mechanism to report improper acts and provides adequate safeguards against victimization. Independent Auditor’s Certificate on Compliance with the Corporate Governance requirements under SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 is available on page 97 of the Company’s Annual Report 2018-19 which is available at the Company website at www.gfl.co.in Annexure H to the Board’s report available on page 82 of the Company’s Annual Report gives the Corporate Governance report. The HR Operations Manual has the following HR guidelines to ensure corruption and bribery free operations:

1. HR/69 - GUIDELINE ON PREVENTION OF CORRUPTION & BRIBERY 2. HR/70 - GUIDELINE ON CODE OF CONDUCT 3. HR/71- GUIDELINE ON PREVENTION OF FRAUD 4. HR/72 - GUIDELINE ON CONFLICT OF INTEREST 5. HR/73 - GUIDELINE ON WHISTLEBLOWER The company has Protection & Compliance framework which provides employees to raise any issue related to above policies violation. It also reiterates the no retaliation philosophy of the company.

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Suggestion and grievance boxes have been installed various parts of our locations through employees can register complaints in this regard. Every employee is extensively trained on the above guidelines which are included in the Employee Handbook. Every employee has to give a declaration to this effect.

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The company has also adopted a Statement of Fair Business Practices and Responsible Care Marketing & Sales.

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In compliance with the SEBI’s Prohibition of Insider Trading Regulations, a Code of Conduct for Prevention of Insider Training has been established with an objective to prevent possible circumstances of trading in securities of the Company by its officials based on possession of unpublished price sensitive information.

Under the said Code, annual disclosures regarding securities held and other disclosures in respect of trading in securities of the Company are taken from the Directors and Designated Persons (defined in the Code itself) from time to time. An Internal Sustainability & Ethics Assessment was undertaken across locations by external agency – Sharp & Tannan Associates

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http://www.sharp-tannan.com/ . The outcomes of the assessment are shown as below:

The Company has adopted an Enterprise Risk Management Framework derived from COSO ERM. The Company carries out ERM through external agency and also conducts internal audits at each manufacturing location which covers corruption/bribery as one of the aspects to be analyzed. The internal auditors of the company have reviewed ERM and reported that there are no material or additional risk identified. There has been no instances of fraud reported by the statutory auditors under section 143(12) of the Act and rules framed there under either to the Company or to the Central Government.