Philosophy

ITC believes that an effective stakeholder engagement process is necessary for achieving its sustainability goal of inclusive growth.

ITC endeavours to evolve a structured framework for engaging with its stakeholders and fostering enduring relationships with each one of them. ITC accordingly anchors its stakeholder engagement on the principles of:

• Materiality - taking prioritised consideration of the economic, environmental and social as well as the actual and potential impacts identified to be important to the organisation as well as its stakeholders.
• Completeness - understanding the stakeholders’ key concerns and expectations to ensure meaningful engagement with them through periodic interactions.
• Responsiveness - responding coherently and speedily to the relevant concerns.

Policy

It is ITC’s Policy:

1. To acknowledge, as an Enterprise of Tomorrow, its responsibility to meet stakeholder expectations in today’s fast-evolving business and sustainability landscape, to the extent possible;
2. To identify and engage with its key stakeholders at local, national and global levels on key issues;
3. To identify and address the relevant needs and concerns of its stakeholders;
4. To understand the concerns of stakeholders who are disadvantaged, vulnerable and marginalised and prioritise their concerns;
5. To work towards addressing these concerns in an equitable and transparent manner.

Governance and Implementation

(a) ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, to ensure progressive implementation of the Policy, and also communication of the Policy to the employees.

(b) Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.

(c) The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its

This Policy was approved by the Board on 25th April, 2014 and last amended on 30th October, 2025.

Policy on Stakeholder Engagement

Philosophy

ITC believes that it is necessary to represent to and engage with authorities on matters concerning the various sectors in which it operates. ITC’s engagement with the relevant authorities is guided by the values of commitment, integrity, transparency, and the need to balance interests of diverse stakeholders.

Policy

It is ITC’s Policy:

1. To ensure that its advocacy position is consistent with its values and philosophy;
2. To ensure that any engagement with Government, Regulatory Authorities and industry associations comply with applicable laws and regulations, and are performed in accordance with the Company’s Code of Conduct;
3. To work with industry organisations that are engaged in public policy advocacy and represent sectoral matters;
4. To ensure that policy advocacy is conducted ethically.

Governance and Implementation

(a) ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, to ensure progressive implementation of the Policy and its communication to the employees.

(b) Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.

(c) The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its implementation.

This Policy was approved by the Board on 25th April, 2014 and last amended on 30th October, 2025.

Policy on Responsible Advocacy

Philosophy

ITC is committed to providing products and services that offer best-in-class quality user experience and integrate sustainable practices across their lifecycle in accordance with the applicable laws.

Policy

It is ITC's Policy:

Product Quality, Safety and Consumer Health

• To have a robust safety management system to meet regulatory requirements related to safety (including food safety), quality processes and hygiene, and to also work towards adopting emerging safer processes and systems;
• To continuously train employees on quality and safety;
• To raise awareness among customers on how to use and dispose its products and packaging;

Sustainable Design & Innovation

• To continue to progressively incorporate relevant social and environmental considerations in product / service development processes;
• To make concerted efforts to leverage deep consumer insights and in-house R&D capabilities to introduce science-based, innovative and sustainable products and services in line with customer preferences and requirements;

Consumer Trust & Transparency

• To provide appropriate mechanisms for customer / consumer feedback to drive continuous improvement in the value propositions of its products and services;
• To continue to make clear and verifiable claims backed by evidence in accordance with the applicable regulatory requirements;

Compliance & Fair Competition

• To comply with applicable laws and regulations pertaining to its products and services, including their quality, safety, product labelling, advertising, promotion and sponsorship;
• To allow freedom of choice, in a competitive environment, while designing, promoting and selling its products and services.

Governance and Implementation

• ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, to ensure progressive implementation of the Policy and its communication to the employees.
• Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.
• The CSR and Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its implementation.

For additional information, refer to ITC's Policy on Resource Efficiency, ITC's Policy on Responsible Marketing, and ITC Foods Division's Nutrition Policy.

This Policy was approved by the Board on 25th April, 2014 and last amended on 22nd May, 2025.

Policy on Product Stewardship

Philosophy

ITC endeavours to progressively integrate sustainability in the supply chain(s) for its products and services across its diversified business portfolio. The Company encourages procurement from suppliers with sustainable practices and strives to enhance opportunities of sourcing from such suppliers including those belonging to marginalised, vulnerable and disadvantaged groups.

[ITC’s supply chain includes farmers, third party manufacturers, service providers, transporters, suppliers of agriculture / non-agriculture materials and capital goods, franchisees, dealers and distributors.]

Policy

It is ITC’s Policy:

A. Compliance and Awareness

1. To work with supply chain members who adopt and accept the Company’s Code of Conduct for Suppliers and Service Providers;
2. To continuously raise awareness of supply chain members to comply with the Company’s Code of Conduct for Suppliers and Service Providers and applicable laws and regulations related to labour and employment, including gender diversity, human rights, child labour, wages, working hours, bribery & corruption, occupational health, safety and environment;

B. Sustainability Assessment

1. To assess the sustainability risks of supply chain members and to recommend suppliers with corrective measures, wherever possible and to encourage suppliers to build resilience against identified risks;
2. To disengage business relationship with supply chain members in the event of repeated or serious non-compliance with the Code of Conduct and serious or consistent lack of commitment to corrective action;

C. Sustainable Practices and Performance

1. To encourage suppliers in identifying and adopting industry best practices and applicable environmental, social and governance (ESG) standards relating to labour and employment, including gender diversity, inclusion of marginalised and vulnerable groups / individuals, human rights, child labour, wages, working hours, bribery & corruption, occupational health, safety and environment;
2. To encourage resource-use efficiency, including sustainable natural resource management, greenhouse gas reduction and sustainable waste management, wherever practicable, through a set of key performance indicators in the supply chain;

D. Engagement with Farmers

1. To raise awareness and work with farmers on crop quality, safety, protection, integrity and traceability, as applicable.
2. To collaborate with farmers to make them more sustainable and help build their adaptive capacity and resilience to emerging risks like climate change, water stress and other extreme weather events;

Governance and Implementation

(a) ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, and Corporate Heads of Departments to ensure progressive implementation of the Policy and its communication to the employees.

(b) Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.

(c) The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its implementation.

This Policy was approved by the Board on 25th April, 2014 and last amended on 30th October, 2025.

Policy on Sustainable Supply Chain and Responsible Sourcing

Philosophy

ITC believes that all employees are important stakeholders in the enterprise and it is imperative to build a culture of mutual trust and respect, interdependence and meaningful engagement. This approach helps in building, strengthening and sustaining harmonious employee relations across the organisation.

Policy

It is ITC’s Policy:

1. To respect the dignity of the individual and the freedom of employees to lawfully organise themselves into interest groups, independent of supervision by the management;
2. To ensure that employees are not discriminated against for exercising this freedom in a lawful manner and consistent with ITC’s core values.

Governance and Implementation

(a) ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, to ensure progressive implementation of the Policy, and also communication of the Policy to the employees.

(b) Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.

(c) The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its implementation.

This Policy was approved by the Board on 25th April, 2014 and last amended on 30th October, 2025.

Policy on Freedom of Association

Guiding Principles

• ITC believes that a diverse workforce contributes to rich discourse, promotes holistic perspectives, fosters creative solutions, and is integral to serving its customers better while creating value for its stakeholders.
• Progressing Diversity, Equity and Inclusion at ITC is a systemic and ongoing endeavour. Through its policies, systems, and actions, ITC promotes diversity and enables an inclusive climate. Employees and business associates are encouraged to be authentic, share views freely, value differences, and treat each other with humanness and dignity.
• Merit and competence are fundamental to the dynamism and vitality of the enterprise. ITC offers equal opportunity based on performance and ability, in selection, progression, rewards, benefits, development, and employment.
• ITC is dedicated to maintaining a workplace free from harassment or discrimination based on caste, religion, disability, gender, gender identity, sexual orientation, race, colour, ancestry, marital status or affiliation with a political, religious or union organisation or majority / minority group. ITC recognizes that certain groups may face social or cultural hurdles in achieving their full potential. Where needed, ITC will undertake supportive actions to offset such difficulties in the spirit of equity at the workplace.

Scope

• These guiding principles apply to all employees and teams and reflect in engagements with business associates, communities and other stakeholders.

Systems, Policies and Practices

• Employees are encouraged to contribute views and perspectives and these are considered on the strength and power of the ideas alone. Forums such as Task Forces, Town Halls by Leaders, structured small group interactions, ideation contests and reviews by leaders are some amongst many opportunities available for contributing ideas and engaging in dialogue.
• Performance and ability are the foundation for reward decisions. This is reflected through objective and outcome-based assessment systems. Talent decisions such as selection, progression, development and positioning are founded on competencies, and their expression in the conduct of business. This ensures that there is no discrimination on the basis of gender while taking any remuneration or advancement decisions.
• Systems to record and assess employee voice and feedback are vital to fostering and reinforcing an inclusive workplace. Periodic engagement surveys, skip-level career and performance conversations, 360-degree feedback, grievance redressal systems and exit interviews provide insights that enable continuous improvement and redressal measures, where needed.
• Apart from an inclusive workplace, Company managed residential communities for employees at several locations, supported by social and recreational opportunities, provide a powerful means of workforce integration, reinforcing a culture of inclusion and fellowship.
• The work from home policy, applicable to roles where such arrangements are feasible, helps employees balance their professional and personal commitments.
• ITC is committed to a workplace free of harassment, including sexual harassment at the workplace, and has zero tolerance for such unacceptable conduct. ITC encourages reporting of any harassment concerns and is responsive to complaints about harassment or other unwelcome or offensive conduct. Committees have been constituted across locations to enquire into complaints of sexual harassment and to recommend appropriate action, wherever required. Necessary disclosures in relation to the sexual harassment complaints received and redressal thereof are provided in the Report and Accounts of the Company.

As part of its commitment to enhancing diversity, ITC places particular emphasis on representation and inclusion of women and the differently abled persons. This is sought to be accomplished systematically, through concerted actions, some of which are summarised below:

Representation

• ITC’s talent sourcing strategies are configured to enhance its diversity quotient. The Company assesses sources continuously, scrutinizes the available talent pool and consistently deploys inclusive hiring principles and practices to meet its diversity goals. This includes initiatives and efforts to enhance representation of women in the selection pool, collaborating with external partners to recruit differently abled persons, and where feasible, encouraging their deployment with business associates across the value chain.
• ITC invests in bespoke and ready to deploy capability programmes that support women achieve their full potential. Such interventions provide the thrust, as ITC strives to meet representation milestones across responsibility levels.

Inclusion & Enablement

• To enhance women participation in the workforce and realisation of their full potential, ITC offers comprehensive institutional support. This includes policies which enable greater flexibility such as off-site or alternate location working, extended child care leave and return to work programme, and child and caregiver travel support. Infrastructure provisions include special accommodation arrangements for women, secure transport and access to child care facilities at or near the workplace. ITC undertakes periodic infrastructure reviews and audits and differently abled persons are supported with the necessary infrastructure to help them discharge their responsibilities. ITC undertakes various wellbeing programmes focussed on the unique needs of women.
• ITC deploys various interventions and refreshes them periodically to reinforce the tenets of inclusive practices and behaviours in work teams. The Company endeavours to tackle implicit biases, if any, through a combination of persuasive campaigns and training programs which sensitize employees on such biases, and effective means to counter them.

Commitment and Assurance

• Promotion of Diversity, Equity and Inclusion receives continuous focus and sponsorship from leadership, with the Businesses and Functions actively committed to making progress. Diversity & Inclusion goals and initiatives, particularly those pertaining to women and differently abled persons, are integrated with Human Resource Plans across Businesses.
• As a means of continuous listening and initiating proactive actions, Employee Resource Groups (ERG) / Diversity Councils are in place across Businesses. ERGs are empowered to periodically review Diversity, Equity and Inclusion efforts, gather feedback and share suggestions with Business leadership teams.
• As a testimony to ITC’s commitment, and to ensure that the Company keeps making progress, various measures relating to Diversity, Equity and Inclusion, including feedback from employees, are tracked and remedial actions taken, where required.
• As a means of positive reinforcement, ITC celebrates success stories, promotes thematic events and recognizes organizational units making progress.

Accountability

Compliance with this Policy is overseen by the Heads of Human Resource of Businesses, who report into Chief Executives / Heads of respective Businesses, and by the Head of Corporate Human Resources who reports to the Chairman & Managing Director of the Company.

This Policy was approved by the Board on 25th April, 2014 and last amended on 30th October, 2025.

Policy on Diversity, Equity and Inclusion

Philosophy

ITC believes in a “No Child Labour and No Forced Labour” policy.

Policy

It is ITC’s Policy:

1. To ensure that no person below the age of eighteen years is employed in the workplace;
2. To prohibit the use of forced or compulsory labour at all its Units;
3. To ensure that no employee is made to work against his / her will or to work as bonded / forced labour, or subjected to corporal punishment or coercion of any kind, related to work;
4. To refrain from engaging with vendors and suppliers who resort to using child labour and forced labour in their operations.

Governance and Implementation

(a) ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, to ensure progressive implementation of the Policy, and also communication of the Policy to the employees.

(b) Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.

(c) The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its implementation.

This Policy was approved by the Board on 25th April, 2014 and last amended on 30th October, 2025.

Policy on Prohibition of Child Labour and Prevention of Forced Labour at the Workplace

Philosophy

ITC is committed to conducting its operations with due regard for the environment and to provide a safe and healthy workplace for its employees.

This Policy is applicable to the Company’s entire operations / employees as well as contractors or individuals in the Company’s premises.

Policy

It is ITC’s Policy:

A. Compliance and management systems

1. To contribute to sustainable development through the establishment and implementation of environment, health and safety (EHS) standards that meet the requirements of relevant laws, regulations and codes of practice;
2. To endeavour to create a safe working environment aligned with the goal of ‘Zero Accidents’;
3. To take into account environment and occupational health & safety aspects in planning and decision-making;

B. EHS Performance

1. To continuously endeavour to improve EHS performance and reduce environmental impacts by setting objectives and targets;
2. To regularly monitor key performance indicators and report the progress to stakeholders;
3. To provide safe and healthy working conditions for the prevention of work-related injury and ill-health through the process of risk identification and systematic assessment with active participation of the workforce;
4. To encourage a culture of safety by providing appropriate training to employees as well as service providers’ employees on EHS, encouraging investment in state-of-the-art technology and developing human capital;
5. To instill a sense of duty in every employee, including those of service providers at the Company’s premises, towards their personal safety, as well as that of their co-workers;

C. Awareness and training

1. To raise awareness among internal and external stakeholders on the Policy and relevant environmental issues;
2. To provide adequate training to employees towards effective implementation of the Policy.

For suppliers and partners, refer the section: D. Safe and Healthy Working Conditions of the ‘Code of Conduct for Suppliers and Service Providers’.

Governance and Implementation

(a) ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, and Corporate Head for EHS to ensure progressive implementation of the Policy and its communication to the employees.

(b) Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.

(c) The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its implementation.

This Policy was approved by the Board on 25th April, 2014 and last amended on 30th October, 2025.

Policy on Environment, Health and Safety

ITC’s Code of Conduct for Suppliers and Service Providers (“the Code”) reflects the Company’s commitment to respect human rights across the supply chain. This Code upholds the spirit outlined in the United Nations Guiding Principles on Business and Human Rights. All of ITC’s Suppliers and Service Providers are expected to meet the requirements of this Code.

This Code requires that Suppliers and Service Providers and their facilities comply with applicable laws, environmental regulations, respect human rights including minimum wages, occupational health and safety, as required by applicable laws and meet the requirements of this Code. Visit http://www.itcportal.com/sustainability/index.aspx for more information on ITC’s commitment to sustainability. ITC provides products and services of superior quality and value by sourcing its technologies, equipment, inputs and finished goods from international and Indian manufacturers and suppliers. ITC also expects that Suppliers and Service Providers will hold their business associates to the same standards as contained in this Code.

I. Labour Practices

ITC recognises and respects that its Suppliers and Service Providers are independent entities and the exclusive employers of their respective employees. ITC expects that the Suppliers and Service Providers will comply with all the prevailing labour legislations at all times, including the following:

A. Child Labour

Suppliers and Service Providers shall not engage child labour.

B. Anti-Discrimination, Fair Treatment and Anti-Harassment

Suppliers and Service Providers shall promote and maintain a workplace free from discrimination and prevent harassment, and treat their employees with fairness, dignity and respect. They shall not discriminate against their employees based on their caste, religion, disability, gender, sexual orientation, race, colour, ancestry, marital status, political or religious affiliation, trade union membership, etc. They shall provide appropriate safeguards to prevent and remediate such incidents, if any.

C. Forced Labour

Suppliers and Service Providers should not use forced or bonded labour in any form.

D. Safe and Healthy Working Conditions

Suppliers and Service Providers are expected to comply with applicable laws and endeavour to make the workplace, machinery, equipment and processes free from risk (including fire safety) to ensure personal safety of any person working in such workplace or with access to such equipment and process. Suppliers and Service Providers shall ensure, at a minimum, adequate access to potable water and sanitary facilities, lighting and ventilation. Suppliers and Service Providers shall manage all health and safety risks in order to prevent occupational injuries and illnesses.

For all work carried out in the Company’s premises, Suppliers and Service Providers shall maintain safe and hygienic working conditions in accordance with the ITC’s ‘HANDBOOK ON HEALTH AND SAFETY AT WORK’ which has been issued to them.

II. Environment and Resource Efficiency

Suppliers and Service Providers shall comply with applicable laws and endeavour to adopt resource efficient practices along with environment-friendly technologies, and shall endeavour to align to Company’s Policy on Resource Efficiency concerning the protection of the environment. Suppliers and Service Providers shall monitor and manage environmental aspects including GHG emissions, water, waste and biodiversity, wherever relevant and possible.

III. Quality Management

Suppliers shall have processes and management systems for providing products and services of superior quality, aligned with recognised national and international standards, and ITC’s requirements, as applicable.

IV. Human Rights and Grievance Redressal

ITC requires its business partners to establish a human rights compliant business environment at their workplace. ITC expects its Suppliers and Service Providers to establish processes for mapping / monitoring progress on human rights performance.

Suppliers and Service Providers shall have well-defined systems for capturing and addressing grievances raised by internal and external stakeholders.

V. Business Integrity

Suppliers and Service Providers should always be ethical in all aspects of their business, including their relationships, practices, sourcing & operations, and comply with the applicable laws in this regard.

Suppliers and Service Providers shall comply with the following:

A. Conflict of Interest

Suppliers and Service Providers shall avoid any actual or potential conflicts of interest in their business dealings with ITC that could create a perception of unfairness or lead to uncompetitive favours, and shall disclose to ITC any such situation of conflict of interest, including involvement or interest of any employee of ITC or his / her immediate family members in their business.

B. Anti-Bribery and Anti-Corruption

ITC expects that its Suppliers and Service Providers, in their dealings with ITC, do not indulge in any form of bribery or corruption that is intended to induce or reward improper conduct or influence any decision. ITC expects that its Suppliers and Service Providers shall endeavour to have a policy pertaining to anti-corruption and anti-bribery. ITC expects and seeks confirmation in its commercial and contractual terms that Suppliers and Service Providers will not offer or promise or provide any benefit, either in cash or in kind, to any employee or any relative / associate of any employee of ITC or of any of its associate companies, in order to facilitate their existing or future business with ITC.

C. Hospitality and Gifts

ITC prohibits offering of hospitality or gifts to influence business decisions. Hospitality or gifts exchanged, if any, during the course of business, as social and customary gestures, should be nominal in nature.

D. Anti-Competition and Anti-Trust

Suppliers and Service Providers shall comply with all applicable anti-trust and anti-competition laws, as relevant.

VI. Reporting of Breaches

Suppliers and Service Providers shall bring to the notice of the manager concerned at ITC, any actual or suspected breach of this Code.

Suppliers and Service Providers are encouraged to report any known or suspected improper behaviour of ITC employees. Such reports will be treated confidentially without fear of retaliation.

VII. Assessments

ITC has a robust process of evaluating its Suppliers and Service Providers before engaging with them, proactively making them aware of its expectations / requirements, and seeking commitment for compliance through contractual agreements. ITC reserves the right to verify compliance with this Code at any time through appropriate audit and assessment mechanisms, including self-certification. Suppliers and Service Providers shall undertake corrective actions identified during assessments, if any. In case of persistent non-compliance with the Code of Conduct and lack of commitment towards undertaking corrective actions, ITC reserves the right to disengage with such Suppliers and Service Providers.

ITC shall reinforce awareness of this Code amongst the Suppliers and Service Providers and shall support them in this endeavour.

This Policy was approved by the Board on 25th April, 2014 and last amended on 30th October, 2025.

Code of Conduct for Suppliers and Service Providers

Philosophy

ITC is committed to conducting its operations in a manner that protects, conserves and enriches biodiversity and strives to create an overall positive impact on nature. This Policy applies to own business operations and shall be progressively extended to key suppliers and value-chain partners.

Policy

It is ITC's Policy:

Conservation and Restoration

• To conserve, enrich and promote efficient and sustainable use of natural resources and raw materials in its business activities, minimise dependency on fossil energy through increased use of renewable sources of energy, and manage water consumption and waste in a sustainable manner with a view to protect and enhance biodiversity;
• To promote activities for biodiversity conservation in partnership with relevant stakeholders, including local governments, farmers, local communities, other self-help groups and non-governmental organizations (NGOs);
• To increase carbon sequestration by restoration of degraded village commons, river banks and tanks, foreshore plantations, and development of community-managed forests in forest fringe areas;
• To promote sustainable and climate smart agriculture among farmers, including adoption of climate-resilient crop varieties, conservation agriculture techniques, agro-forestry, precision farming, and water-use efficient (more crop per drop) practices, that help in restoring and conserving nature;

Biodiversity Assessment & Management

• To encourage management of operations in a manner such that environmental impacts (like emissions and waste) are avoided or minimised to the extent possible, and natural capital is replenished to create an overall positive impact on nature;
• To progressively conduct location-specific biodiversity risk assessments and follow the risk mitigation hierarchy while developing biodiversity management plans for sites operating in proximity to areas of national importance for biodiversity;

Stakeholder Engagement

• To continue to raise awareness of suppliers and other stakeholders on the importance of biodiversity conservation and sustainable use of natural resources;
• To respect rights of local communities who are dependent on nature for food, fuel, fodder and commons.

Governance and Implementation

• ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives through members of the respective Management Committees, and Corporate Head for Social Investments to ensure progressive implementation of the Policy and its communication to the employees.
• Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.
• The CSR and Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its implementation.

This Policy was approved by the Board on 24th July, 2021 and last amended on 22nd May, 2025.

Policy on Biodiversity Conservation

Philosophy

ITC aims for 'Zero Deforestation' and endeavors to source agri commodities and wood from sustainable sources. This Policy applies to own business operations and shall be progressively extended to key suppliers and value-chain partners.

Policy

It is ITC's Policy:

• To comply with applicable deforestation-related regulations across its operations;
• To strive to engage supply chain members who comply with applicable laws and regulations related to deforestation;
• To recognise and respect the rights of local communities, and engage / collaborate with them and farmers for safeguarding natural forests;
• To institute a system of assessing deforestation risks in the supply chain, and implementing appropriate mitigation measures;
• To work towards undertaking ecological restoration projects such as afforestation.

For key commodities, it is ITC's Policy:

Timber:

• To aim to source timber from sustainable sources;
• To engage with farmers and stakeholders in creating awareness, and promoting wood & fuel self-sufficiency through ITC's afforestation programmes;
• To encourage farmers in implementing energy conservation measures;
• To explore and aim to adopt appropriate alternative curing technologies to reduce dependency on fuelwood in the tobacco supply chain;
• To promote the usage of alternative fuels, such as agri waste by farmers, to reduce dependency on fuelwood and to encourage its traceability in the supply chain;
• To work towards procuring FSC® certified pulpwood from plantations in line with customer requirements.

Farm Crops:

• To aim to procure farm crops from sustainable sources;
• To encourage farmers to adopt sustainable practices aligned with certification standards such as Rain Forest Alliance, Global GAP, Fairtrade and other similar standards, wherever applicable.

Governance and Implementation

• ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, to ensure progressive implementation of the Policy and its communication to the employees.
• Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.
• The CSR and Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of its implementation.

This Policy was approved by the Board on 24th July, 2021 and last amended on 22nd May, 2025.

Policy on Deforestation

Philosophy

ITC believes that conservation and preservation of natural resources are fundamental to the survival and sustenance of life on earth. It is, therefore, important to collaborate with stakeholders to identify emerging trends and formulate the management approach for future readiness, in order to protect, conserve and contribute towards restoring natural resources.

Policy

It is ITC's Policy:

• To identify, assess and manage environment related risks & opportunities, and their associated impacts across its operations and value chains using the principles of materiality, and to endeavour that such practices are integrated in business strategies with allocation of appropriate resources;
• To set targets for continual improvement, evaluate performance against targets through a set of key metrics for operations and value chains and report the progress to stakeholders;
• To progressively implement an environmental management system that is benchmarked against industry best practices across diverse sectors in which ITC operates and is based on the principles of Standards such as ISO:14001;
• To comply with applicable environment-related legal and regulatory requirements;
• To raise awareness among stakeholders on relevant environmental issues and encourage positive environmental action;
• To provide adequate training to all employees towards effective implementation of this Policy.

For key priority areas, it is ITC's Policy:

Climate Change:

• To strive to contribute to national objectives on climate change and attempt to align its strategic efforts of managing carbon footprint in line with India's Nationally Determined Contribution under Paris Agreement;
• To enable the transition to a low carbon economy by progressively:
  a. enhancing energy efficiency by adoption of appropriate technologies;
  b. increasing the share of renewable energy to 100%;
• To continue to enhance carbon sequestration to mitigate impacts of climate change;
• To encourage value chain partners to implement systems for measuring and monitoring emissions, and work with them for decarbonising their operations wherever possible;
• To encourage farmers to maximise utilisation of farm land by improving crop yields, promoting crop rotation & diversification and aiding farmers to optimise resource-use and inputs;
• To assess physical risks of climate change across own operations and key agri value chains using climate scenarios;
• To enhance the climate resilience of vulnerable locations including agri value chains by striving to implement locally-contextual adaptation plans;

Circularity:

• To work on the design of products and packaging to improve recyclability, especially for plastic packaging, and to optimise the use of virgin materials and resources;
• To strive towards diverting waste from landfill using the principles of reduce, reuse, recycle and recover as appropriate;
• To promote innovative circular business models for sustainable management of waste including plastic waste;

Water Stewardship:

• To focus on an integrated water management approach that includes investing in water conservation measures, waste-water treatment and rainwater harvesting so as to strive to reduce net water consumption in its units;
• To work towards water security for stakeholders within defined catchment areas of units located in water-stressed areas by following the principles of water stewardship;
• To collaborate with and disclose water stewardship outcomes to stakeholders;
• To encourage and work with supply chain members, including farmers, to improve water-use efficiency in their operations, wherever possible.

Governance and Implementation

• ITC has appropriate systems and processes in place to ensure compliance with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, and Corporate Head for Sustainability to ensure progressive implementation of the Policy, and its communication to the employees.
• Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.
• The CSR and Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of implementation.

This Policy was approved by the Board on 24th July, 2021 and last amended on 22nd May, 2025.

Policy on Resource Efficiency

Philosophy

In line with its Triple Bottom Line philosophy, ITC remains firmly committed to discharging its duty as a responsible corporate citizen by ensuring full compliance with applicable tax laws in an ethical and transparent manner.

Policy

It is ITC's Policy:

• To pay taxes in a timely manner and ensure compliance with the spirit as well as the letter of the tax laws and regulations in the countries we operate;
• To conduct business operations in a tax-efficient manner in compliance with the applicable laws, including transfer pricing regulations;
• To conduct business operations in a manner that ensures that the Company does not:
  • transfer value created to low tax overseas jurisdictions;
  • deploy tax structures without any commercial substance; and
  • use secrecy jurisdictions or so-called "tax havens" by establishing entities for circumventing tax obligations;
• To engage with tax authorities with integrity, trust, fairness and in a transparent and cooperative manner.

Governance

• This policy is communicated to all employees in an appropriate and meaningful manner.
• The Company has suitable governance structures, systems and processes in place to ensure compliance, review and approval of its tax policy / strategy; Divisional / SBU Chief Executives, through members of the respective Management Committees, and Head - Corporate Taxation will ensure implementation of this Policy.
• Compliance with the Policy will be regularly monitored by the Divisions / SBUs and reviewed by the Corporate Management Committee (CMC).

This Policy was approved by the Board on 24th July, 2021.

Policy on Tax

Philosophy

ITC supports the cause of eliminating animal testing.

Policy

It is ITC's Policy:

• Not to undertake animal testing in respect of any of its existing cosmetic and food products. Notwithstanding the above, animal testing may be considered as a measure of last resort, if there is no effective alternative or if mandated by law for product safety or any other statutory requirements. In such a situation, ITC will comply with all legal, ethical and professional standards and, if required, use third-party facilities which conform to the same;
• To affirm that none of its existing products are subject to any form of animal testing, and is committed not to undertake animal testing. In the event of any requirements or mandates imposed by any governmental, regulatory, or relevant authorities in this matter, ITC shall adhere strictly to the principles of Replacement, Reduction, and Refinement (3R) of animal research in conducting such animal testing to address the welfare of animals used for testing;
• To comply with all applicable laws relating to animal testing where warranted or required by regulatory authorities;
• To endeavour to adopt non-animal alternative testing methods for providing assurance to consumers regarding the safety of its products;
• To instill a sense of commitment amongst suppliers for not testing products on animals.

Governance and Implementation

• ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, and Chief Scientist - Research & Technology Innovation, ITC Life Sciences and Technology Centre, to ensure progressive implementation of the Policy, and also communication of the Policy to the employees.
• Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.
• The CSR and Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of implementation.

This Policy was approved by the Board on 27th October, 2021 and last amended on 22nd May, 2025.

Policy on Animal Testing

Philosophy

The Company is committed to responsible marketing practices. The Company believes in marketing practices that are truthful and respectful, and strives to ensure that its marketing activities align with the core values of integrity, sustainability, and inclusivity.

Policy

ITC's Policy on Responsible Marketing covers:

A. What we market:

• To ensure that all marketing communications will be free from misleading claims.
• To accurately describe our products including providing relevant information as required by the applicable laws.
• To provide clear instructions on how to use our products, as may be required or appropriate.

B. How we market:

• To ensure that all marketing practices will comply with the applicable laws and regulations.
• To protect the privacy of customers and comply with applicable regulations pertaining to personal data, in case personal data is collected from customers.
• To carefully evaluate advertising platforms and media outlets and attempt to avoid platforms that have been established as promoting violence or pornography.
• To be mindful of the beliefs and practices of all religions and communities while developing advertising material.
• To strive to work with partners who adhere to applicable laws, regulations and standards.
• To provide training on responsible marketing principles, codes, and practices to relevant employees and partners.

C. Who we market to:

To strive that our marketing efforts are directed to appropriate audience, considering age, cultural sensitivities etc.

For additional information, refer to ITC's Policy on Product Stewardship and ITC Foods Division's Marketing and Communication Policy.

Governance and Implementation

• ITC has appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, as applicable, including processing of grievances for redressal. It shall be the responsibility of the Divisional / SBU Chief Executives, through members of the respective Management Committees, to ensure implementation of the Policy, and also communication of the Policy to the employees.
• Compliance with the Policy will be regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC will be reviewed by the CMC.
• The CSR and Sustainability Committee of the Board will supervise the implementation of this Policy and will annually review the progress of implementation.

This Policy was approved by the Board on 22nd May, 2025.

Policy on Responsible Marketing