Management - The Company leadership ‘walking the talk’ and a relentless focus on implementing the policy underline the Company’s approach to employment practices and creating a decent work environment.

The Human Resources and EHS functions of each business are the primary custodians of ITC’s labour and EHS policies and employment practices, the implementation of which is reviewed periodically at the unit and the divisional levels. The Corporate Human Resources and EHS functions provide specialist services to assist in the implementation and monitoring of the same. The multi-layered and multi-dimensional audit framework of the Company also helps in monitoring compliance with laid down policies and statutory regulations.

Training & Awareness - The policy is shared with employees and potential employees through training programmes, communication sessions, the Company portal, intranet sites and pre-placement presentations. Managers from HR, EHS and Engineering departments are provided regular training for effective implementation of these policies.

Monitoring & Follow-up - The HR and EHS resources of the Divisions regularly monitor progress to ensure proper implementation of these policies, while the Unit Heads and the Divisional Management Committees follow-up periodically to ensure full compliance. The Corporate EHS Department undertakes regular audits of the units.

Objectives - The primary objective is to nurture a culture of meritocracy amongst a committed and enthusiastic workforce from diverse backgrounds. In the pursuit of this objective, the following goals have been set for the next five years -

• All ITC’s units, which are already ‘beyond compliance’ in all areas related to labour practices, will continue to be so.

• Ensure that the Company’s record of attraction and retention of talent is superior to other companies in the comparative sample.

• Enable employees to perform to their fullest potential to add value to the enterprise, nation and themselves.

• Enhance the Company’s employee value proposition so that ITC retains its position as an employer of choice.

• Endeavour to eliminate accidents and injuries both onsite and offsite.

Awards - A number of awards for excellence in Human Resources and EHS management and practices bear testimony to ITC’s commitment to Human Resource Development and EHS and to best-in-class employment practices.

Context - High standards of employment and EHS practices enhance the Company’s performance, help in the attraction and retention of quality talent, and enhance the equity of the Company as a responsible employer.

Policy - ITC is committed to conducting business in a manner that reflects its high ethical standards. It expects its employees and business partners to subscribe and adhere to this philosophy, which honours all local laws and upholds the spirit of human rights as enshrined in existing international standards such as the Universal Declaration and the Fundamental Human Rights Conventions of the ILO. The Corporate Management Committee of the Company has approved policies covering crucial human rights areas. ITC’s Human Rights policies extend to all its operating sites.

Responsibility - It is the overall responsibility of the Divisional Chief Executives, through the members of their Divisional Management Committees, General Managers and Unit Heads, to ensure implementation of these policies on human rights, including designating of individuals for specific responsibilities in respect of their Division.

Corporate Human Resources is responsible for reviewing and updating standards on social policies, and for providing guidance and support to all concerned.

Management - The Human Rights policies approved by the CMC provide guidelines for the implementation of these policies and their periodic review. Corporate HR provides specialist services to assist in implementation and monitoring.

Training & Awareness - Employees are provided with training on the Company’s Human Rights policies at Induction Programmes. The policies are available on the Company’s website and intranet portals.

Monitoring & Follow-up - The HR resources of the Divisions ensure periodic follow-up to ensure implementation. The Internal Audit function of the Company is charged with the responsibility of ensuring compliance.

Objective - The Company’s primary objectives in the area of Human Rights performance and the goals for the next five years are to ensure that -

• All ITC’s operational units are and will remain fully compliant with the Company’s Human Rights policies, premised on a zero tolerance guiding principle towards such violations.

• All investment decisions will integrate Human Rights considerations into the decision-making process.

• All ITC’s business partners will follow and adhere to the Human Rights policies that the Company upholds.

Context - High standards on Human Rights enhance the Company’s reputation and build its brand equity, thus helping it achieve the goal of operational excellence. It gives ITC’s business partners, customers and other strategic stakeholders the confidence of dealing with a value-driven Company. It is a crucial value proposition that is offered to potential employees to attract and retain talent and motivate employees to give their best.