HEG : Business Responsibility Report 2023-24

Business

Responsibility &

Sustainability

Report

SECTION A: GENERAL DISCLOSURES

1. Details of the listed entity
2. 1. Corporate Identity Number (CIN) of the Listed Entity: L23109MP1972PLC008290
   2. Name of the Listed Entity: HEG Limited
   3. Year of incorporation: 1972
   4. Registered office address: Mandideep, Near Bhopal Dist. Raisen MP- 462046
   5. Corporate address: Bhilwara Towers, A-12,Sector-1, Noida - 201301
   6. E-mail:[e-mail]
   7. Telephone: [phone] (EPABX)
   8. Website: www.hegltd.com
   9. Financial year for which reporting is being done: 2023-24
   10. Name of the Stock Exchange(s) where shares are listed: 1. BSE Limited 2. National Stock Exchange of India Limited.
   11. Paid-upCapital: C 38.60 Crores
   12. Name and contact details (telephone, email address) of the person who may be contacted in case of any queries on the BRSR report: Mr. Manish Gulati, Executive Director
       Tel: [phone], 233524 to 233527, E Mail: [e-mail]
   13. Reporting boundary - Are the disclosures under this report made on a standalone basis (i.e. only for the entity) or on a consolidated basis (i.e. for the entity and all the entities which form a part of its consolidated financial statements, taken together): The disclosures under this report are made on Standalone Basis.
   14. Name of Assurance Provider: Since, HEG limited is not falling in the list of the top 150 listed companies based on the market capitalisation, therefore, it is not required to obtain assurance on BRSR, accordingly, this requirement would not be applicable.
   15. Type of Assurance obtained: Not Applicable.

92

HEG LIMITED

1. Products/services

16. Details of business activities (accounting for 90% of the turnover):

Sl. No. Description of Main Activity

Description of Business Activity

1 Manufacturing of Graphite Electrodes Manufacturing of Graphite Electrodes

17. Products/Services sold by the entity (accounting for 90% of the entity's Turnover):

• of Turnover of the entity 90.76%

Sl. No.		Product/Service		NIC Code
1		Manufacturing of Graphite Electrodes		23994

III. Operations

18. Number of locations where plants and/or operations/offices of the entity are situated:

• of total Turnover contributed 90.76%

Location

National

International

19. Markets served by the entity:a. Number of locations

Number of plants

2

0

Number of offices

1

0

Total

3

0

Locations		Number
National (No. of States)		25
International (No. of Countries)		42

1. What is the contribution of exports as a percentage of the total turnover of the entity? The overall contribution of the exports to the total turnover is 67.95%.
2. A brief on types of customers.
   HEG Limited is a leading manufacturer and exporter of graphite electrodes in India and operates world's largest single- site integrated graphite electrodes plant. The Company has a very renowned customer base. Some of them includes Jindal Steel & Power Limited (JSPL), Steel Authority of India Limited (SAIL), Arcelor Mittal, Qatar Steel, Emirates Steel, Tata Steel, CESLA Group, Jindal Stainless Limited, Acerinox Europia etc.

IV. Employees

20. Details as at the end of Financial Year:

a. Employees and workers (including differently abled):

Sl. No. Particulars

1. Permanent (D)
2. Other than Permanent (E)
3. Total employees (D + E)
4. Permanent (F)
5. Other than Permanent (G)*
6. Total workers (F + G)

Total		Male
(A)	No. (B)			% (B / A)

EMPLOYEES

597		578		97%
41		41		100%
638	619	97%

WORKERS

478		478		100%
16		16		100%
494		494		100%

Female

No. (C)		% (C / A)
19		3%
0		0%
19		3%
0		0%
0		0%
0		0%

*Excludes job-based workers, which are the workers that do not work on fixed number of days, instead they work to finish the specified given task, hired through contractors.

52nd Annual Report 2023-24

93

1. Differently abled Employees and workers:

Sl. No. Particulars			Total			Male
		(A)		No. (B)			% (B / A)
		DIFFERENTLY ABLED EMPLOYEES
1.		Permanent (D)			0		0			0%
2.		Other than Permanent (E)			0		0			0%
3.		Total differently abled employees (D	+ E)		0		0			0%
		DIFFERENTLY ABLED WORKERS
4.		Permanent (F)			0		0			0%
5.		Other than permanent (G)			0		0			0%
6.		Total differently abled workers (F +	G)		0		0			0%

21. Participation/Inclusion/Representation of women

Female

No. (C)			% (C / A)
0			0%
0			0%
0		0%
0			0%
0			0%
0		0%

		Total
		(A)
Board of Directors		10
Key Management Personnel*	4

*Includes 2 Executive Directors which are also included in the Board of Directors.

No. and percentage of Females

No. (B)		% (B / A)
2		20%
0		0%

22. Turnover rate for permanent employees and workers(Disclose trends for the past 3 years)

Permanent Employees

Permanent Workers

FY 2023-24

(Turnover rate in

current FY)

Male		Female		Total
13%		12%		13%
3%		0%		3%

FY 2022-23

(Turnover rate in

previous FY)

Male		Female		Total
9%		32%		10%
1%		0%		1%

FY 2021-22

(Turnover rate in the year prior to the previous FY)

Male		Female		Total
15%		25%		15%
4%		0%		4%

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

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

S.

No.

1.

2.

3.

Name of the holding/subsidiary/ associate companies/ joint ventures (A)

TACC Limited

Bhilwara Info technology Limited

Bhilwara Energy Limited

Indicate whether		% of shares
holding/ Subsidiary/		held by
Associate/Joint Venture		listed entity
Wholly Owned Subsidiary		100%
Associate		38.59%
Associate		49.01%

Does the entity indicated at column

A, participate in the Business Responsibility initiatives of the listed entity? (Yes/No)

No

No

No

VI. CSR Details

24. (i) Whether CSR is applicable as per section 135 of Companies Act, 2013: Yes

1. Turnover (in C ) : 2394.9 Crores
2. Net worth (in C ) : 4145.08 Crores

94

HEG LIMITED

VII. Transparency and Disclosures Compliances

25. Complaints/Grievances on any of the principles (Principles 1 to 9) under the National Guidelines on Responsible Business Conduct:

Stakeholder group from

Grievance

Redressal

Mechanism

in Place

(Yes/No)

FY 2023-24

Current Financial Year

FY 2022-23

Previous Financial Year

whom complaint is received

Communities

Investors (other than shareholders)

Shareholders

Employees and Workers

Customers

Value chain partners

Others (please specify)

(If Yes, then
provide		Number of
web-link for		complaints
grievance		filed during
redress		the year
policy)*
Yes		Nil
Yes		Nil
Yes	40
Yes		Nil
Yes	16

Yes		Nil
Not		Not
Applicable		Applicable

Number of complaints pending resolution at close of the year

Not Applicable

Not Applicable

0

Not Applicable

11

Not Applicable

Not Applicable

Remarks

-

-

-

-

1. Improved material supplied and usage at Customer end and its feedback is awaited.
2. In some cases further Dispatch is planned.
3. In few cases, insufficient response from the customer.

-

-

		Number of
Number of		complaints
complaints		pending		Remarks
filed during		resolution
the year		at close of
		the year
Nil		Not	-
		Applicable
Nil		Not	-
		Applicable
34		Nil		-
Nil		Not	-
		Applicable
25	20		Dispatch
				of new
				consignment
				awaited

Nil		Not	-
		Applicable
Not		Not	-
Applicable		Applicable

*The Company has a well-defined Business Ethics Policy, Anti-Bribery and Anti-Corruption Policy for all of its employees and stakeholders to report suspected violations of the Company's Code of Conduct, Supplier's Code of Conduct, or any other applicable Laws. In addition to this, the Company also has a separate department namely, "Secretarial Department" to take care the shareholders' grievances and resolve them appropriately on timely basis.

There is a specific email ID ([e-mail]) for addressing queries by any Investors and Shareholders. The Secretarial

Department is responsible to monitor and resolve the queries and concerns raised through this email ID, taking inputs and resolutions from the relevant departments within the Company.

The Company also has detailed HR Policies, covering different aspects related to grievance redressal including but not limited to Policy on Prevention of Sexual Harassment (POSH), Whistle Blower Policy to safeguard the interest of the employees and workers (including females).

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95

26. Overview of the entity's material responsible business conduct issues

Please indicate material responsible business conduct and sustainability issues pertaining to environmental and social matters that present a risk or an opportunity to your business, rationale for identifying the same, approach to adapt or mitigate the risk along-with its financial implications, as per the following format

Sl.

No.

1.

2.

3.

4.

		Indicate
Material		whether
issue		risk or
identified		opportunity
		(R/O)
Carbon		Opportunity
Reduction

Employee	Opportunity
well-being

Occupational Risk

Health and

Safety

Responsible	Risk
Sourcing

Financial

implications

of the risk or

Rationale

for

identifying

the

In case of risk, approach to

opportunity

risk/ opportunity

adapt or mitigate

(Indicate

positive or

negative

implications)

Businesses

have

substantial

Various

initiatives

have

been

Positive

opportunities

to

reduce their

taken

for

improving

energy

carbon footprint through strategic

efficiency

and

renewable

energy

substitution

and

efficiency

utilisation

like installation

of

improvements. By understanding

solar power panels, revamping of

and applying these approaches, the

furnace for better fuel efficiency,

organization can make meaningful

tree plantation, replacing diesel

progress

toward

sustainability

operated

vehicles

by

Electric

and

compliance

with

increasing

Vehicles etc, which has resulted

environmental regulations.

in reduction of the Company's

carbon footprints.

Productivity growth is recognized

Several initiatives for employees

Positive

as the most important long-term

and

workers

well-being

source

of

sustainable

gains

in

have

been

started.

Medical

the

business

operations.

When

examinations

for

workers,

individuals

experience

higher

wellness

and

mental

health

levels of well-being, they are most

ongoing services, and health-

likely to be engaged and satisfied

related services at Occupational

in their

work. This can

lead

to

Health centres are some of the

higher levels of productivity, as

main

programmes. This

is

also

individuals are motivated, focused

ensured through regular training

and committed to their tasks.

programmes

on

Healthy

life

style,

Stress management

and

Work-life balance etc.

By integrating a robust framework

The

organization

has identified,

Negative

for

workplace safety,

businesses

anticipated

and

assessed

not only comply with the law

hazards and risks to safety and

but also lay the foundation for

health arising from the work

sustainable growth. For achieving

environment and also determines

this, businesses must conduct a risk

the adequacy of existing controls

assessment to identify the hazards

to eliminate hazards or control

and dangers present in their

risks.

workplaces

and

put appropriate

management

mechanisms

to

address the associated risks.

Responsible

and

sustainable

The organization has policies and

Negative

sourcing can help to improve

procedures

to

ensure suppliers

business

reputation

and

attracts

follow

sustainable

practises

and

new

customers.

Environmental

to

mainstream

supply

chain

and social issues in the supply

sustainability.

chain can pose a significant risk to

the business. Responsible sourcing

can help to mitigate these risks

and ensure long-term business

continuity.

96

HEG LIMITED

		Indicate
Sl.	Material	whether
issue	risk or
No.	identified	opportunity
		(R/O)

1. Data Privacy Risk and Cyber Security
2. Operations Opportunity Environment
3. Diversity and Opportunity Inclusion

8.		Human		Risk
		Rights and
		Labour
		Management
9.		Ethics		Risk

10. Stakeholder Opportunity engagement

Financial

implications

of the risk or

Rationale

for

identifying

the

In case of risk, approach to

opportunity

risk/ opportunity

adapt or mitigate

(Indicate

positive or

negative

implications)

Applying

strong

data

protection

Respecting the rights to personal

Negative

measures

and

safeguards

protects

data privacy is a top priority

organization's

data,

therefore

for the Company. To ensure a

avoiding

considerable

problems,

standardised

and high

degree

which may impact organization's

of protection for Personal Data

confidential information.

processed

by

the

Company's

Group

Companies,

the

Company has embraced global

data protection standards.

Effective

business

operations

A compliance

tool

is

used

to

Positive

help

companies

minimize wastes

ensure that

all

environmental

and losses to retain more profit.

compliance

requirements

are

Regular audit of processes and

satisfied, and operational changes

output

ensures

optimization of

are made to address critical Key

resources and managing risks.

Performance Indicator (KPI) for

environmental compliance.

The

organisation

examines

The

business

prioritises

diversity

Positive

diversity and develops an inclusive

and inclusion and has a workable

workplace culture based on a

plan to do so. The

Company aims

core sense of belonging, fairness,

to have a comprehensive diversity

and equity in order to fully

and

inclusion

framework

and

realise the potential of human

to

increase

the

proportion

of

variety.

Diversity widens access

its female employees to the

to best talent. Inclusion allows

minimum extent possible.

engagement with talent effectively.

Together this leads to innovation,

creativity, productivity, reputation

and business results.

In order to gauge human rights

The

organization

has

established

Negative

risks,

the

organization

identifies

a human rights policy, a

and assesses any actual or potential

thorough process, and diligence

adverse

human

rights

impacts

procedures

to

assess

human

and considers it as a foundational

rights concerns at all operational

step

for

effective

management of

levels.

human right risks.

Upholding ethical standards helps

The

Company

has

an

Ethics

Negative

organization ensure transparency,

Policy that is applicable to all

reliability and integrity in their

stakeholders. The

Policy

offers

day-to-day operations. It leads

stakeholders

and

employees a

to strong bonds with internal

framework for applying business

and

external

stakeholders

like

principles

with

the

utmost

investors,

customers,

employees

integrity. Compliance is tracked,

etc.

and violations are strictly dealt

with.

Considering

engagement

with

The

organizations

maintain

Positive

stakeholders as crucial for success,

ongoing stakeholder engagement

the organization has a clear vision

procedures.

Periodic

training

derived from a robust strategic

programmes

and

interaction

planning process.

sessions are being organized to

ensure stakeholder engagement.

52nd Annual Report 2023-24

97

Sl.	Material
issue
No.	identified

11. Business Resilience

Indicate whether risk or opportunity (R/O)

Risk

Rationale	for	identifying	the		In case of risk, approach to
risk/ opportunity				adapt or mitigate
Business	resilience	ensures		The	Company	has	protocols,
continuity and stability in the		tools, and procedures in place
face of disruptions, allowing the		to	confront	and	manage
business to withstand and recover		crisis,	including	disaster-
from various	challenges.	This		related elements	with serious
resilience enables the organization		repercussions.
to maintain	operations,	serve
customers,	and	meet	obligations
even during adverse events.

Financial implications of the risk or opportunity (Indicate positive or negative implications)

Negative

SECTION B: MANAGEMENT AND PROCESS DISCLOSURES

Disclosure

Questions

Policy and management processes

P

1

P

2

P

3

P

4

P

5

P

6

P

7

P

8

P

9

1. a. Whether your entity's policy/policies cover each principle and its core elements of the NGRBCs. (Yes/No)

1. Has the policy been approved by the Board? * (Yes/No)
2. • Except for certain operational policies, which have been approved by the Executive Director of the Company, rest of the policies have been approved by the Board.

c. Web Link of the Policies, if available

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

# Link for Policies

Code of Conduct for Directors and Senior Management

http://hegltd.com/wp-content/uploads/2017/02/CODE_OF_CONDUCT_HEG_05-02-2015.pdf

Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information

https://hegltd.com/wp-content/uploads/2019/04/Code-of-Fair-Discloures-and-Conduct-final1-1.pdf

Dividend Distribution Policy

http://hegltd.com/wp-content/uploads/2018/04/Dividend-Distribution-Policy. pdf

Whistle Blower Policy

http://hegltd.com/wp-content/uploads/2018/07/Whistle-Blower-Policy-08.05.2018.pdf

Policy on Related Party Transactions

h t t p s : / / h e g l t d . c o m / w p - c o n t e n t / u p l o a d s / 2 0 2 2 / 0 5 / H E G _ R P T - Policy_09.02.2022.pdf

Policy on Disclosure on Material Events and Information

https://hegltd.com/wp-content/uploads/2022/05/HEG_Determination-Materiality-of-Events_09.02.2022.pdf

98

HEG LIMITED

Disclosure	P	P	P	P	P	P	P	P	P
Questions	1	2	3	4	5	6	7	8	9

Quality and Safety Policy

http://hegltd.com/quality-safety-policy/

Prevention, Prohibition and Redressal Against Sexual Harassment of Women

Employees

http://hegltd.com/wp-content/uploads/2020/01/Sexual-Harrassment-Policy_

January-2020.pdf

Rest of the Policies are available on Company's Intranet, accessible by all employees of the Company.

2. Whether the entity has translated the policy Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes
into procedures. (Yes / No)

3. Do the enlisted policies extend to your Our Supplier Code of Conduct, which is applicable to our upstream value chain

value chain partners? (Yes/No)partners, incorporates numerous ethical and business requirements (e.g. human rights, Environment, Health and Safety, working condition) also extends to them.

4. Name	of the national and international	-	NEMA	ISO	-	-	ISO	-	-	-
codes/certifications/labels/ standards (e.g.		Stand-	45001			14001,
Forest	Stewardship Council, Fairtrade,		ards				ISO
Rainforest Alliance, Trustea) standards (e.g.		are fol-				9001
SA 8000, OHSAS, ISO, BIS) adopted by		lowed
your entity and mapped to each principle.

5. Specific commitments, goals and targets set HEG Limited is aiming to be net zero by 2050 or sooner and strive to progress by the entity with defined timelines, if any. towards energy efficiency, renewable energy utilisation, recovery of waste heat for usage in production process, fuel switching, and more effective material use and

recycling while addressing climate change.

6. Performance of the entity against the Several internal projects are in progress to concentrate on carbon reduction, specific commitments, goals, and targets improve efficiency, reduce emissions overall, and address climate change. along-with reasons in case the same are not

met.

Governance, leadership, and oversight

7. Statement by director responsible for the business responsibility report, highlighting ESG related challenges, targets, and achievements (listed entity has flexibility regarding the placement of this disclosure)

We at HEG Limited are committed to the inclusive growth goals, boosting our efforts to align with the 17 Sustainable Development Goals (SDGs) set forth by the 'United Nations'. HEG's sustainability platform is based on the 3P philosophy - People, Planet and Profit. These aspects have, over the years, emerged as key filter while formulating business strategies at the Company. HEG is committed to achieve growth by promoting integrity & ethics and co-prosperity to ensure that our success is mutually beneficial for our customer, employees and the community.

Businesses continuously face new risks and challenges in an environment that is becoming more complex and dynamic due to factors including climate change, environmental degradation, biodiversity loss, rising inequality, higher expectations of the local communities, and related regulatory changes.

As a socially and environmentally conscious corporate citizen, we always work to enhance our performance while keeping a strong Corporate Governance as our main priority. Further, the Company's ESG / Sustainability initiatives are supervised closely by all the operational heads under the close monitoring by the Company's Board of Directors.

As top league leading players of graphite electrodes, sustainability is somewhat at the center of all we do. As we constantly offer best-in-class goods that surpass customer expectations, which allows us to forge enduring relationships within the graphite electrodes business, we have our eyes set firmly on assisting in hastening the introduction of the future of mobility to global consumers.

In terms of Environment initiatives, our focus is on minimizing climate change, reducing Green House Gas emission, bringing energy efficiency, reducing water consumption, recycling the waste products, creating a sustainable supply chain through sustainable sourcing.

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99

Disclosure Questions

P

1

P

2

P

3

P

4

P

5

P

6

P

7

P

8

P

9

For Social initiatives, we place a strong emphasis on investing in growing our people by enhancing their skills and capabilities through various knowledge enhancing initiatives, a more positive Company's culture, and a balance between Diversity & Inclusion, Occupational Health & Safety, Human rights and Supplier diversity.

In terms of Governance, we work to improve Board diversity, Business integrity, Cyber security, and policy & reporting.

While the Company has always made an effort to embed and comply with our initiatives into ESG framework; we have started rebuilding and reworking most of our initiatives/activities to fit further better into particular ESG boundaries. This year, together with the ongoing ESG initiatives as reported in our this year's BRSR report, the Company is in the process of developing a detailed ESG Strategy, Roadmap and action plan for 3 years which inter-alia includes determining key stakeholders, calculating materiality assessment, conducting ESG due diligence for ensuring ESG Compliance. These would be soon implemented. This would help the Company in minimizing the negative environmental and social impacts of our operations and further strengthen the governance compliance.

8. Details of the highest authority responsible for implementation and oversight of the Business Responsibility policy (ies).

9. Does the entity have a specified Committee of the Board/ Director responsible for decision making on sustainability related issues? (Yes / No). If yes, provide details.

Mr. Manish Gulati, Executive Director

Tel: [phone], 233524 to 233527

E Mail: [e-mail]

Mr. Ravi Jhunjhunwala (DIN: 00060972) Chairman, Managing Director & CEO and Mr. Manish Gulati, Executive Director are responsible for decision making on sustainability related issues.

10. Details of Review of NGRBCs by the Company:

Indicate whether review was undertaken

Frequency

Subject for Review

by Director / Committee of the Board/

(Annually/ Half yearly/ Quarterly/ Any

Any other Committee*

other - please specify)

P P P P P P P P P P P P P P P P P P

1

2

3

4

5

6

7

8

9

1

2

3

4

5

6

7

8

9

Performance against above policies and

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Annually

follow up action

Compliance with statutory requirements

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Annually

of relevance to the principles and,

rectification of any non-compliances

11. Has the entity carried out independent assessment/ evaluation of the working of

P

P

P

P

P

P

P

P

P

its policies by an external agency? (Yes/No). If yes, provide name of the agency.

1

2

3

4

5

6

7

8

9

The

Company

has carried out independent

assessment/evaluation of the working of

some of its polices, such as policies covered

under ISO and Social audit, by an external

agency Bureau Veritas.

12. If answer to question (1) above is "No" i.e. not all Principles are covered by a policy, reasons to be stated:

Questions

The entity does not consider the Principles material to its business (Yes/No)

The entity is not at a stage where it is in a position to formulate and implement the policies on specified principles (Yes/No)

The entity does not have the financial or/human and technical resources available for the task (Yes/No)

It is planned to be done in the next financial year (Yes/No)

Any other reason (please specify)

P1 P2 P3

P4 P5 P6 P7 P8 P9

Not Applicable

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HEG LIMITED

SECTION C: PRINCIPLE WISE PERFORMANCE DISCLOSURE

PRINCIPLE 1 Businesses should conduct and govern themselves with integrity, and in a manner that is Ethical, Transparent and Accountable.

Essential Indicators

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

Segment

Board of Directors

Key

Managerial

Personnel

Employees other than BoD and KMPs

Workers

Total number

of training

and awareness

programmes

held

4

4

554

554

Topics / principles covered under the training and its impact

Topics: Ethics, Transparency, Accountability, Environment Protection, Governance, Social Responsibility.

Impact: The Company considers Governance as an integral part of good management. The Company's philosophy on corporate governance envisages the attainment of the highest levels of transparency, accountability and equity, in all facets of its operation and its interaction with various stakeholders.

Topics: Ethics, Transparency, Accountability, Environment Protection, Governance, Social Responsibility.

Impact: The Company considers Governance as an integral part of good management. The Company's philosophy on corporate governance envisages the attainment of the highest levels of transparency, accountability and equity, in all facets of its operation and its interaction with various stakeholders.

Topics:

1. Integrity and Governance Policy
2. Policy for handling Goods & Services and Product Safety
3. Human Rights Policy
4. Environmental Protection Policy
5. Public Care and Regulatory Policy
6. Code of Conduct
7. Business Ethics
8. POSH

Impact: Overall grooming and increase in functional efficiency of the employees.

Topics:

1. Integrity and Governance Policy
2. Policy for handling Goods & Services and Product Safety
3. Human Rights Policy
4. Environmental Protection Policy
5. Public Care and Regulatory Policy
6. Code of Conduct
7. Business Ethics
8. POSH

Impact: Overall grooming and increase in functional efficiency of the workers.

%age of persons

in respective

category covered by the awareness programmes

100%

100%

97.48%

67.57%

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