Jindal Saw : Business Responsibility and Sustainability Report 2023-24

BUSINESS

RESPONSIBILITY &

SUSTAINABILITY

REPORT

F Y 2023 -24

INDEX

SECTION A:
GENERAL DISCLOSURES	03
SECTION B:
MANAGEMENT AND PROCESS DISCLOSURES	09
SECTION C:
PRINCIPLE WISE PERFORMANCE DISCLOSURE	12
PRINCIPLE 1	12
PRINCIPLE 2	15
PRINCIPLE 3	17
PRINCIPLE 4	22
PRINCIPLE 5	23
PRINCIPLE 6	26
PRINCIPLE 7	35
PRINCIPLE 8	36
PRINCIPLE 9	38
LIST OF ABBREVIATIONS	40

SECTION A: GENERAL DISCLOSURES

1. Details of the listed entity

Sr. No.	Particulars	Details
1.	Corporate Identity Number (CIN) of the Listed Entity	L27104UP1984PLC023979
2.	Name of the Listed Entity	Jindal SAW Limited
3.	Year of incorporation	1984
4.	Registered office address	A-1, Nandgaon Road, UPSIDC Industrial Area, Kosi Kalan, Mathura , Uttar
		Pradesh- 281403
5.	Corporate address	Jindal Centre, 12, Bhikaiji Cama Place, New Delhi-110066
6.	Email	[e-mail]
7.	Telephone	011-26188360-74
8.	Website	www.jindalsaw.com
9.	Financial year reported	2023-24
10.	Name of the Stock Exchange(s) where shares are listed	National Stock Exchange of India Ltd.
		BSE Ltd.
11.	Paid-up capital	639.52 Million
12.	Name and contact details (telephone, e-mail address) of the	Mr. Sunil K. Jain
	person who may be contacted in case of any queries on the	Company Secretary & Compliance Officer
	BRSR report	Contact No.: 011-61462220 Email: [e-mail]
13.	Reporting boundary - Are the disclosures under this report made	Standalone Basis
	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).
14.	Name of assurance provider	NA
15.	Type of assurance obtained	NA

1. Products/services

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

Sr. no.	Description of Main Activity	Description of Business Activity	Percentage of
			Turnover of the entity
1	Iron and steel products (Pipe and allied accessories)	Manufacturing & sale	89.8%
2	Pellet	10.19%

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

Sr. no.	Product/Service	NIC Code	Percentage of total Turnover
			contributed
1	Iron and steel products (Pipe and allied accessories)	24106	89.8%
2	Pellet	07100	10.19%

1. Operations

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

Location	Number of plants	Number of offices	Total
National	11	13	24
International	0	0	0

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3 | JINDAL SAW LTD.

19. Markets served by the entity:

a. Number of locations

Locations	Number
National (No. of States)	25
International (No. of Countries)	26

1. What is the contribution of exports as a percentage of the total turnover of the entity? Response: 23.77%
2. A brief on types of customers Response:
   Jindal SAW products cater to a diverse clientele spanning various sectors including Oil & Gas, Water & Sewage Transportation, Irrigation, Agriculture, Infrastructure, Automotive, Construction, and Power Generation, operating on a global scale. Our client base comprises National, International and Supermajor Oil Companies, PSU's, PSE's, Engineering companies, encompassing governmental entities (at central, state, or local levels), non-governmental organizations, and contractors.

20. Details as at the end of Financial Year:

1. Employees and workers (including differently abled):

Sr. No.	Particulars	Total (A)		Male		Female
			No. (B)	% (B / A)	No. (C)	% (C / A)
			Employees
1	Permanent (D)	4,036	3,947	97.79	89	2.2
2	Other than Permanent (E)	504	497	98.61	7	1.39
3	Total employees (D + E)	4,540	4,444	97.88	96	2.21
			Workers
4	Permanent (F)	3,481	3,481	100	0	0
5	Other than Permanent (G)	12,686	12,508	98.60	178	1.40
6	Total workers (F + G)	16,167	15,989	98.90	178	1.10

1. Differently abled Employees and workers:

Sr. No.	Particulars	Total (A)	Male			Female
				No. (B)	% (B / A)	No. (C)	% (C / A)
		Differently	abled Employees
1	Permanent (D)	24		24	100	0	0
2	Other than Permanent (E)	0		0	0	0	0
3	Total employees (D + E)	24		24	100	0	0
		Differently abled Workers
4	Permanent (F)	30		30	100	0	0
5	Other than Permanent (G)	23		23	100	0	0
6	Total workers (F + G)	53		53	100	0	0

21. Participation/ Inclusion/ Representation of women:

	Total (A)	No. and percentage of Females
		No. (B)	% (B / A)
Board of Directors	13	4	30.77
Key Management Personnel	7	3	42.86

22. Turnover rate for permanent employees and workers:

	Turnover rate of current FY 2023-24	Turnover rate of previous FY 2022-23	Turnover rate of the year prior to the
								previous FY 2021-22
	Male	Female	Total	Male	Female	Total	Male	Female	Total
Permanent Employees	10.64	17.33	10.77	5.2	20.3	5.3	3.7	15.5	2.7
Permanent Workers	4.91	0	4.91	1.8	0	1.8	1.7	0	1.7

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

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

Sr. No.	Name of the holding/ subsidiary/ associate	Indicate whether	Percentage of shares	Does the entity indicated at column A,
	companies/ joint ventures (A)	holding/ Subsidiary/	held by listed entity	participate in the Business Responsibility
		Associate/ Joint Venture		initiatives of the listed entity? (Yes/No)
1.	Jindal ITF Limited	Subsidiary	51.00%	No
2.	Jindal Metal & Alloys Limited	Subsidiary	80.71%	No
3.	S.V. Trading Limited	Subsidiary	100.00%	No
4.	Ralael Holdings Limited	Subsidiary	100.00%	No
5.	Jindal Saw Holdings FZE	Subsidiary	100.00%	No
6.	Greenray Holdings Limited	Subsidiary	100.00%	No
7.	JITF Shipyards Limited	Subsidiary	100.00%	No
8.	Jindal Intellicom Limited	Subsidiary	98.78%	No
9.	iCom Analytics Limited	Subsidiary	98.78%	No
10.	Jindal X LLC	Subsidiary	98.78%	No
11.	Jindal Saw Gulf L.L.C.	Subsidiary	100.00%	No
12.	World Transload and Logistics LLC	Subsidiary	100.00%	No
13.	5101 Boone LLP	Subsidiary	100.00%	No
14.	Tube Technologies INC	Subsidiary	100.00%	No
15.	Jindal Saw USA, LLC	Subsidiary	100.00%	No
16.	Jindal Saw Middle East FZE	Subsidiary	100.00%	No
17.	Derwent Sand SARL	Subsidiary	99.62%	No
18.	Helical Anchors INC	Subsidiary	100.00%	No
19.	Boone Real Property Holding LLC	Subsidiary	100.00%	No
20.	Drill Pipe International LLC	Subsidiary	100.00%	No
21.	Jindal Hunting Energy Services Limited	Subsidiary	51.00%	No
22.	Jindal MMG, LLC	Joint Venture	50.00%	No
23.	ReNew Surya Tejas Private Limited	Associate	31.20%	No

1. CSR Details

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

1. Turnover (in ₹.): 1,79,61,96,83,798.15
2. Net worth (in ₹.): 1,01,91,32,88,652.72

4 | BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORT

5 | JINDAL SAW LTD.

VI. Transparency and Disclosures Compliances

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

Sr.	Material issue	Indicate	Rationale for identifying	In case of risk, approach to	Financial implications of
No	identified	whether risk	the risk / opportunity	adapt or mitigate	the risk or opportunity
		or opportunity			(Indicate positive or negative

FY 2023-24

FY 2022-23

(R/O)

implications)

Stakeholder group from whom complaint is received

Grievance Redressal Mechanism in Place (Yes/No) (If yes, then provide weblink for grievance redress policy)

Number of	Number of	Remarks Number of	Number of	Remarks
complaints	complaints	complaint	complaints
filed during the	pending	filed during	pending
year	resolution at	the year	resolution at close
	close of the year		of the year

3	Energy and	Risk	As regulatory and compliance re-
	Emissions		quirements regarding climate change
	Management		intensify, our business must adapt to
			evolving standards through appropri-
			ate investments. However, immediate
			returns on investments in energy
			and emission management are not

We prioritize energy-efficient processes and emission reduction initiatives. Continuous investments in managing energy and emission that leads to improvement in process efficiency, which underscores

Negative. Despite the lack of immediate ROI visibility, we prioritize initiatives for energy-efficient processes and reducing emissions. Investments in energy and emission management

Communities
Investors
(Other than
shareholders)
Shareholders	Yes, at Jindal SAW
	we have a grievance

00

00

10

0	0
0	0
1	0

immediately visible, posing financial

uncertainties.

our commitment to sustainability.

systems and technologies impact our financials, which we acknowledge as part of our strategic approach to sustainability and regulatory compliance.

Employees and	redressal at place.
workers	Web link:https://jindal-
Customers
saw.org/pdf/vigil-mecha-
	nism-policy-new.pdf
Value Chain
Partners
Others (Contract
Employees &
workers)

00

250

00

00

0	0	NA
29	0
0	0
0	0

4	Occupational	Risk	Our workforce forms the foundation	We prioritize investments	Positive. Despite the investments
	Health and		of our operations, necessitating a	in assuring safe working	required in maintaining these
	Safety		commitment to providing a safe and	environment and technology	standards and ensuring a
			healthy environment. Occupational	while maintaining	safe work environment, with
			health and safety incidents not only	comprehensive safety training	safety technology and training,
			pose regulatory and reputational	programs to mitigate risks.	employee safety remains
			risks but also threaten business	Additionally, our well-equipped	our paramount concern.
			continuity and the well-being of our	Occupational Health Centres	The financial benefits of
			employees. Non-compliance could	(OHCs) underscore our	uninterrupted operations far
			adversely affect operational efficiency	commitment to employee well-	outweigh the associated costs,
			and compromise our ability to meet	being and safety.	safeguarding both our workforce
			customer demands.		and operational continuity.
5	Customer	Opportunity	Elevating customer satisfaction serves	NA	Positive. Enhanced customer

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

Sr.	Material issue	Indicate	Rationale for identifying	In case of risk, approach to	Financial implications of
No	identified	whether risk	the risk / opportunity	adapt or mitigate	the risk or opportunity
		or opportunity			(Indicate positive or negative
		(R/O)			implications)

	Satisfaction		as a strategic avenue for driving		satisfaction translates into
			market development, enhancing		tangible benefits such as
			market penetration, and delivering		increased repeat orders and
			superior value propositions to our		expanded market presence. This
			clientele. Furthermore, it plays a		solidifies our positioning as a
			pivotal role in strengthening the		valued reliable partner, thereby
			reliability of our brand, thereby		yielding favourable financial
			facilitating sustained growth and		outcomes and contributing to
			profitability.		sustained business success.
6	Ethics and	Opportunity	Prioritizing ethics and compliance	NA	Positive. A steadfast commitment

1	Product	Risk	Product innovation, quality, and safety
	innovation,		issues can significantly impact our
	safety, and		ability to meet customer demand and
	quality		generate value for stakeholders. Any
			lapses in these areas can lead to
			reputational damage, loss of market
			share, and legal liabilities.

We enforce rigorous testing, compliance measures, and comprehensive quality management systems to proactively identify and address potential issues. Investing in employee training ensures our workforce maintains high standards. Our proactive measures include being one of the first in the industry to adopt ISO 45001 certification, demonstrating our commitment to safety and quality manage- ment. Global accreditation further validates our dedication to excellence.

Positive: Positive financial implications are anticipated as we prioritize product innovation and quality, aiming for increased customer satisfaction and revenue growth through value- added products.

	Compliance		within our organization cultivates a		to ethics and compliance
			conducive business environment		yields tangible benefits such
			which favours in furthering employee		as heightened employee
			loyalty, consequently reducing		retention rates and cost savings
			attrition rates and enhancing talent		associated with rehiring efforts.
			attraction efforts. A motivated		Additionally, it empowers us to
			workforce inherently translates into		surpass performance targets,
			heightened productivity and develops		thereby promoting sustainable
			a cohesive organizational culture.		business growth and success.
			Moreover, the emphasis on ethics and
			compliance not only contributes to
			employee morale but also facilitates
			cost savings through increased
			productivity and efficiency gains.
7	Risk,	Opportunity	Taking a proactive stance on crisis	NA	Positive. Although the
	Opportunities		management not only enables the		establishment of robust Health,

2	Economic	Opportunity	Economic value distribution is integral NA	Positive. Economic value
	Value		to our stakeholder strategy, facilitating	distribution is anticipated to
	Distributed		the allocation of financial resources	enhance market capitalization,
			towards strategic investments aligned	providing opportunities for
			with our defined strategic objectives.	fundraising to support growth.

and Crisis	establishment of resilient systems but	Safety, and Environment (HSE)
Management	also positions the organization as a	protocols and employee
	forward-thinking entity, staying ahead	training initiatives require initial
	of industry competitors.	investments, the resulting
		prevention of avoidable
		operational disruptions
		yields substantial positive
		impacts, ultimately enhancing
		organizational resilience and
		sustainability.

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7 | JINDAL SAW LTD.

Sr.	Material issue	Indicate	Rationale for identifying	In case of risk, approach to	Financial implications of
No	identified	whether risk	the risk / opportunity	adapt or mitigate	the risk or opportunity
		or opportunity			(Indicate positive or negative
		(R/O)			implications)

SECTION B: MANAGEMENT AND PROCESS DISCLOSURES

This section is aimed at helping businesses demonstrate the structures, policies and processes put in place towards adopting the NGRBC Principles and Core Elements.

8	Supply Chain	Opportunity	The current global scenario with	NA
	Management		respect to conflicts and instability	has

significantly disrupted supply chain systems, presenting an opportune moment for us to innovate and establish alternative SCM models. This strategic move not only positions us to navigate uncertainties but also allows us to gain a competitive edge in the market while optimizing production costs.

Positive. Implementing a robust supply chain management strategy not only enhances operational efficiency but also provides improved customer satisfaction, thereby paving the way for sustainable business growth and profitability.

	Disclosure Section	P1	P2	P3	P4	P5	P6	P7	P8	P9
Policy and management processes
1. a.	Whether your entity's policy/policies cover each principle and its	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes
	core elements of the NGRBCs. (Yes/No)
b.	Has the policy been approved by the Board? (Yes/No)	Yes	No	Yes	Yes	Yes	Yes	Yes	Yes	No
c.	Web Link of the Policies, if available	P1:

• Entertainment / Gifts Guidelines:

https://www.jindalsaw.com/pdf/gift-guildelines.pdf

9	Employee	Opportunity	Prioritizing employee wellbeing	NA
	Wellbeing		is essential for the organization's
			sustainable growth. Despite
			the challenge of immediate ROI
			assessment, investing in employee
			wellbeing not only helps in attracting
			talent but also helps in retention
			and contributes to uplifting overall
			workforce morale.

Positive. While implementing and maintaining employee wellbeing programs require initial investments and ongoing costs, the tangible benefits such as increased employee loyalty and longer average service tenure contribute to enhanced organizational performance and overall business success.

• Whistle Blower/ Vigil Mechanism: https://www.jindalsaw.com/pdf/vigil-mechanism-policy-new.pdf

• Board Diversity:https://www.jindalsaw.com/pdf/POLICY-ONBOARD-DIVERSITY.pdf

• Related Party Transaction Policy: https://www.jindalsaw.com/pdf/policy-on-rpts-jindal-saw-ltd-final-2022.pdf

• Preservation of Documents:https://www.jindalsaw.com/pdf/Policy-of-Preservation-on-Documents.pdf

• Determining Material Subsidaries: https://www.jindalsaw.com/pdf/POLICY-FOR-DETERMINING-MATERIAL-SUBSIDIARIES-10-2020.pdf

10	Water	Risk	Water, a vital yet limited resource,
	Management		poses a significant risk due to its
			scarcity. Our commitment to efficient
			water management involves stringent
			monitoring and conservation efforts,
			including recycling practices. We
			ensure that our plants follow Zero
			Liquid Discharge (ZLD) mechanism
			for efficient water management and
			conservation.

Despite our efforts to minimize water usage in the manufacturing processes, the inherent risk lies in meeting discharge standards and addressing water scarcity concerns. To mitigate this risk, we prioritize water recycling initiatives and incorporate water reuse at various stages in our production processes.

Negative. While our direct water consumption remains relatively low, there are associated costs and investments required

to maintain robust water management practices.

• Determination of Materiality of Events or Information: https://www.jindalsaw.com/pdf/Policy_for_Determination_of_ Materiality_of_Events_or_Information_final.pdf

• Code of Conduct: https://www.jindalsaw.com/pdf/Policy-Code-of-Conduct.pdf

• Information Risk Management (IT): https://www.jindalsaw.com/pdf/IT-Information-And-Risk-Management-Policy.pdf

P2:

• We have plant Specific QMS policies available on intranet with Corporate IMS policy under approval.

11	Waste	Risk	Despite our diligent efforts to
	Management		minimize solid or hazardous waste
			generation, waste management
			remains a significant risk area within
			our operations.

Our waste management strategy primarily focuses on recycling and appropriate disposal practices for solid waste. Addition- ally, we utilize waste as a raw material input in our production processes to reduce environmental impact.

Negative. While our direct operations result in minimal waste generation, there are associated costs and investments required to maintain effective waste management practices. These expenditures, though essential, pose financial challenges to our operations.

P3:

• Prevention of Sextual Harassment (POSH):

https://www.jindalsaw.com/pdf/posh-policy.pdf

• Code of Conduct:

https://www.jindalsaw.com/pdf/Policy-Code-of-Conduct.pdf

P4:

• Dividend Distribution:

https://www.jindalsaw.com/pdf/Dividend-Distribution-Policy.pdf

12	Diversity and	Opportunity	Developing a diverse and inclusive	NA	Positive. Embracing diversity and
	Inclusion		workplace culture, free from		inclusion not only enhances our
			discrimination based on factors		organizational culture but also
			such as caste, creed, faith, gender,		brings substantial value to our
			or reduced mobility, is paramount		operations. This commitment
			for organizational success. We are		to D&I contributes positively to
			committed to cultivating an inclusive		employee morale, productivity,
			environment.		and overall business success.
13	Respect for	Risk	Human rights considerations are	To mitigate this risk, we have	Positive. Investing in frameworks
	Human Rights		often influenced by external factors	established robust policies and	and guidelines for human rights
			beyond our direct control, making	procedures that encourages	preservation incurs marginal
			them inherently risky. Dependence	and facilitates continuous	costs, however the benefits in
			on external environments and	dialogue and collaboration	maintaining are conducive work
			stakeholders can pose challenges	among stakeholders to ensure	environment and upholding
			in upholding human rights standards	a supportive work environment	ethical standards which far
			within our operations.	throughout the organization.	outweigh the initial investments.

• Jindal SAW's policies;

• Familiarization Programme for Independent Directors of Jindal SAW Limited

P5:

• Prevention of Sextual Harassment (POSH): https://www.jindalsaw.com/pdf/posh-policy.pdf

• Whistle Blower/ Vigil Mechanism: https://www.jindalsaw.com/pdf/vigil-mechanism-policy-new.pdf

• Remuneration:https://www.jindalsaw.com/pdf/POLICY-REMUNERATION-POLICY-OF-JINDAL-SAW.pdf

P6:

• EHS Policy

P7:

• Corporate Social Responsibility:

https://www.jindalsaw.com/pdf/CSR-Policy-2021.pdf

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9 | JINDAL SAW LTD.

Disclosure Section

P1

P2

P3

P4

P5

P6

P7

P8

P9

P8:

• Corporate Social Responsibility:

https://www.jindalsaw.com/pdf/CSR-Policy-2021.pdf

P9:

• Customer responsibility is covered under the Company's Quality Policy.

2.	Whether the entity has translated the policy into procedures. (Yes / No)	Y	N	Y	Y	Y	Y	Y	Y	N
3.	Do the enlisted policies extend to your value chain partners? (Yes/No)	N	N	N	N	N	N	N	N	N

10. Details of Review of NGRBCs by the Company:

Subject for Review

Indicate whether review was undertaken by

Frequency

Director / Committee of the Board/ Any other

(Annually/ Half yearly/ Quarterly/

Committee

Any other - please specify)

P1

P2

P3

P4

P5

P6

P7

P8

P9

P1

P2

P3

P4

P5

P6

P7

P8

P9

Performance against above policies and follow

All policies undergo regular review by department heads, business leaders, senior management

up action.

personnel, or relevant committees. They are subsequently presented to the Board of Directors as

needed. During these assessments, the effectiveness

of the policies is

evaluated,

and

any necessary

adjustments to policies and procedures are promptly implemented to ensure ongoing alignment with

organizational objectives and industry standards

4. Name of the national and international codes/certifications/labels/ standards (e.g., Forest Stewardship Council, Fairtrade, Rainforest Alli- ance, Trustee) standards (e.g., SA 8000, OHSAS, ISO, BIS) adopted by your entity and mapped

Our comprehensive Policy framework encompasses key policies including IMS Policy, CSR Policy, Waste Management Procedure, Employee Code of Conduct, and Employee Grievance Management. These policies are meticulously developed to adhere to established principles and align with the ethos of national and international standards such as API 5L, API 5CT, BIS standards, ISO 9000, ISO 14001, ISO 45001, UNGC guidelines, and GRI standards, ensuring relevance and applicability across our operations. Furthermore, Jindal SAW has implemented Integrated Management System (IMS) certification across its units.

Compliance with statutory requirements of	Jindal SAW ensures compliance with all relevant statutory requirements and promptly addressing any
relevance to the principles, and rectification of	instances of non-compliance in accordance with established principles.
any non-compliances

11.	Has the entity carried out independent assessment/ evaluation of the working of its policies by an external agency? (Yes/No). If yes, provide
	name of the agency.
	Response: Yes, entity carried out independent assessment/ evaluation of the working of its policies by an external agency namely S.K. Gupta and Co.
	Company Secretaries.
12.	If answer to question (1) above is "No" i.e., not all Principles are covered by a policy, reasons to be stated:

5.	Specific commitments, goals and targets set by the entity with defined	Jindal SAW is dedicated to developing the sustainable growth of the
	timelines, if any	organization. Through stakeholder engagement, we have identified
		key material issues such as Energy, Emission, Water, Waste, Gender
		Diversity. Currently, we are in the process of developing relevant
		policies, procedures, as well as short-term,mid-term, and long-term
		objectives and targets to address these issues comprehensively. Our
		focus extends to Diversity & Inclusion and various other ethical busi-
		ness practices. Additionally, multitude of policies aimed at expediting
		sustainability efforts are	also in the	pipeline for	development.
6.	Performance of the entity against the specific commitments, goals, and	NA	NA	NA	NA	NA	NA	NA	NA	NA
	targets 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)

Response:

Jindal SAW is committed to conducting business in an ethical and sustainable manner to create a positive impact on society and the environment. We continuously strive to minimize our carbon footprint through resource efficiency, operational improvements, increased utilisation of renewable energy and effective waste management systems. We foster an inclusive work environment and invest in human resources, emphasizing sustainability, innovation and efficient systems. Further, our CSR initiative, Svayam, raises awareness about accessible public spaces. We strive to build resilience within our business and among our stakeholders, by monitoring our activities and their environmental and social impacts to ensure that we generate value for everyone involved.

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

Mr Neeraj Kumar - Group CEO and Whole Time Director (DIN 01776688) Mr Sunil K Jain - Company Secretary (Membership No F3056)

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.

Response:

Yes, Jindal SAW's group CEO and Whole Time Director Mr Neeraj Kumar is driving the ESG of the organization. Other ESG related organizational structure under development.

Response: Not Applicable.

10 | BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORT

11 | JINDAL SAW LTD.

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	Total number of	Topics / principles covered under the	Percentage of persons in
	training and awareness	training and its impact	respective category covered by
	programmes held		the awareness programmes
Board of Directors	2	Legal and Secretarial Compliances and	100%
		Financials Overview
Key Managerial Personnel	4	POSH, Health and Managerial Skill	100%
Employees other than BoD	1,086	Safety, Environment, Human rights, Technical	100%
and KMPs		and Behavioural etc.
Workers	1,029	Safety, Environment, Human rights, Technical	100%
		and Behavioural etc.

2. Details of fines / penalties /punishment/ award/ compounding fees/ settlement amount paid in proceedings (by the entity or by directors / KMPs) with regulators/ law enforcement agencies/ judicial institutions, in the financial year, in the following format (Note: the entity shall make disclosures on the basis of materiality as specified in Regulation 30 of SEBI (Listing Obligations and Disclosure Obligations) Regulations, 2015 and as disclosed on the entity's website):

Monetary

	NGRBC	Name of the	Amount	Brief of the Case	Has an
	Principle	regulatory/	(In INR)		appeal been
		enforcement			preferred?
		agencies/ judicial			(Yes/No)
		institutions
Penalty/ Fine	Nil	Nil	Nil	Nil	Nil
Settlement	Principle 1	SEBI	26,30,550	The Company had on its own, informed SEBI of	No
				the historical and inadvertent error in classification
				of one of the Promoter Group entities as a
				public shareholder in the shareholding pattern.
				Subsequently, SEBI issued a show cause notice dated
				1st February 2022. In response to the show cause
				notice, the Company filed a reply on 22nd April	2022.
				In addition, the Company has also filed a settlement
				application with SEBI on 4th April 2022 for amicable
				settlement of the matter. The order in this matter was
				issued on 1st December 2023 in this regard.
Compounding Fee	Nil	Nil	Nil	Nil	Nil
			Non-monetary
	NGRBC	Name of the	Amount	Brief of the Case	Has an
	Principle	regulatory/	(In INR)		appeal been
		enforcement			preferred?
		agencies/ judicial			(Yes/No)
		institutions
Imprisonment	Nil	Nil	Nil	Nil	Nil
Punishment	Nil	Nil	Nil	Nil	Nil

3. Of the instances disclosed in Question 2 above, details of the Appeal/ Revision preferred in cases where monetary or non-monetary action has been appealed:

Case Details

Name of the regulatory/ enforcement agencies/ judicial institutions

Not applicable, as no appeal was preferred in monetary settlement.

1. Does the entity have an anti-corruption or anti-bribery policy? If yes, provide details in brief and if available, provide a web-link to the policy. Response:
   Jindal SAW upholds a robust Employee Code of Conduct, which encompasses provisions addressing anti-corruption and anti-bribery measures. Complementing this policy is our Vigil Mechanism, established in accordance with Section 177 of the Companies Act, 2013, to effectively handle instances of corruption or bribery. Our Guiding Principles underscore the company's stance against accepting gifts, favours, or entertainment from parties with whom official dealings occur. Additionally, the misuse of any authority, position, or information for personal gain is strictly prohibited. Employees are also required to disclose any conflicts of interest in writing to mitigate potential conflicts between personal and company interests. Furthermore, the Company has an Entertainments & Gifts policy which outline the position of Jindal SAW Ltd. with respect to providing entertainment, gifts, and accepting the same from the suppliers/vendors of the Company. The policy can be accessed here.
2. Number of Directors/KMPs/employees/workers against whom disciplinary action was taken by any law enforcement agency for the charges of bribery/ corruption:

		FY 2023-24			FY 2022-23
Directors			Nil			Nil
Key Managerial Personnel			Nil			Nil
Employees other than BoD and KMPs			Nil			Nil
Workers			Nil			Nil
6. Details of complaints with regard to conflict of interest:
			FY 2023-24	FY 2022-23
			Number	Remarks	Number	Remarks
Number of complaints received in relation to issues of Conflict	of Inter-	0	None	0	None
est of the Directors
Number of complaints received in relation to issues of Conflict	of Inter-	0	None	0	None
est of the KMPs

1. Provide details of any corrective action taken or underway on issues related to fines / penalties / action taken by regulators/ law enforcement agencies/ judicial institutions, on cases of corruption and conflicts of interest.
   Response: Not Applicable.
2. Number of days of accounts payables ((Accounts payable *365) / Cost of goods/services procured) in the following format:

	FY 2023-24	FY 2022-23
Number of days of accounts payables	96.16	77.49

12 | BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORT

13 | JINDAL SAW LTD.

9. Open-ness of business

Provide details of concentration of purchases and sales with trading houses, dealers, and related parties along-with loans and advances & investments, with related parties, in the following format

Parameter		Metrics	FY 2023-24	FY 2022-23
Concentration of Purchases	a.	Purchases from trading houses as % of	18.79%	8.56%
		total purchases.
	b.	Number of trading houses where pur-	40	36
		chases are made from
	c.	Purchases from top 10 trading houses as	89.20%	87.17%
		% of total purchases from trading houses
Concentration of Sales	a.	Sales to dealers / distributors as % of	5.4%	4.8%
		total sales
	b.	Number of dealers / distributors to whom	70	82
		sales are made
	c.	Sales to top 10 dealers / distributors as %	85.0%	76.7%
		of total sales to dealers / distributors
Share of RPTs in	a.	Purchases (Purchases with related par-	39.75%	45.71%
		ties / Total Purchases)
	b.	Sales (Sales to related parties / Total	7.01%	4.37%
		Sales)
	c.	Loans & advances (Loans & advances
		given to related parties / Total loans &	89.26%	92.40%
		advances)
	d.	Investments (Investments in related par-	99.99%	100%
		ties / Total Investments made)

Leadership Indicators:

1. Awareness programmes conducted for value chain partners on any of the principles during the financial year:

Total number of awareness

Topics / principles covered

Percentage of value chain partners covered (by value of business

under the training

done with such partners) under the awareness programmes

Nil

2.

Does the entity have processes in place to avoid/ manage conflict of interests involving

members of the

Board? (Yes/No) If Yes, provide

details of the same.

Response:

Yes, at Jindal SAW, we have in place processes to avoid and manage conflict

of interests involving

members

of the Board.

Within

our governance

framework, Jindal SAW prioritizes the stringent review of potential conflicts of interest among

directors,

adhering to best practices. Director

disclosures regarding any such conflicts are diligently presented to the

Board for

collective

consideration, ensuring

transparent decision-

making processes. Annual affirmations regarding adherence to

our Code of

Business

Conduct

and Ethics are obligatory for

directors and senior

management, underscoring our commitment to ethical governance. Additionally, our "Code of Conduct for Board of Directors" aligns with SEBI

LODR and Companies Act, 2013, mandating avoidance of situations where personal interests may conflict

with those

of the

Company. This

commitment extends to enhancing a culture of disclosure and appropriate action in managing conflicts of interest, upholding the

highest ethical

standards.

PRINCIPLE 2

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

Essential Indicators:

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

	FY 2023-24	FY 2022-23	Details of improvements in environmental and social impacts
R&D	0	21.60	R&D towards environmental and social impact of product and processes is an
			ongoing and integrated process.
Capex	4.48%	2.42%	The Company invests in specific technologies to improve the environment and
			social impacts of product and processes.

Research and Development is an ongoing and integrated process; therefore, no designated expenses have been allocated specifically under the category of Research and Development Expenditure

2. a. Does the entity have procedures in place for sustainable sourcing? (Yes/No)

Response:

Yes, Jindal SAW has procedures in place for sustainable sourcing.

1. If yes, what percentage of inputs were sourced sustainably?

Response:

Average 87% inputs were sourced sustainably within India.

1. Describe the processes in place to safely reclaim your products for reusing, recycling and disposing at the end of life, for (a) Plastics (including packaging) (b) E-waste (c) Hazardous waste and (d) other waste:
   Response:
   Jindal SAW manufactures pipes and accessories made of iron and steel. The products feature coatings, having low environmental impact, on both internal and external surfaces. Minimum packaging materials are utilized for transporting products from manufacturing sites to customer locations. Moreover, no plastic, e-waste, or hazardous waste is generated at the end of the product life cycle.
2. Whether Extended Producer Responsibility (EPR) is applicable to the entity's activities (Yes / No). If yes, whether the waste collection plan is in line with the Extended Producer Responsibility (EPR) plan submitted to Pollution Control Boards? If not, provide steps taken to address the same.

Response:

No, Extended Producer Responsibility (EPR) is not applicable to the Company's products and services.

Leadership Indicators:

1. Has the entity conducted Life Cycle Perspective / Assessments (LCA) for any of its products (for manufacturing industry) or for its services (for service industry)? If yes, provide details in the following format?

Particulars	Product 1
NIC code	24106
Name of the product	Iron and steel products (Pipe and allied accessories)
% of total Turnover contributed	89.8%
Boundary for which the Life Cycle Perspective / Assessment was	Cradle to Gate and Gate to Gate
conducted
Whether conducted by independent external agency (Yes/No)	Yes
Results communicated in public domain (Yes/No)	Yes
If yes, provide the web-link.	Weblink for the reports can be accessed through following links:
	Report 1,Report 2,Report 3

14 | BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORT

15 | JINDAL SAW LTD.

2. If there are any significant social or environmental concerns and/or risks arising from production or disposal of your products / services, as identified in the Life Cycle Perspective / Assessments (LCA) or through any other means, briefly describe the same along-with action taken to mitigate the same.

Name of Product / Service	Description of the risk / concern	Action Taken
	No significant social or	environmental
Iron and steel products (Pipe and allied accessories)	concern or risk arises from production	No action required
or disposal of the product were identi-
	fied as all the products	are recyclable.

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

PRINCIPLE 3

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

Essential Indicators:

1. a. Details of measures for the well-being of employees:

Category	Percentage of Employees (Permanent and Other employees) covered by
	Total (A) Health Insurance	Accident Insurance*	Maternity Benefits	Paternity Benefits	Day-care Facilities
		Number	%	Number	%	Number	%	Number	%	Number	%
		(B)	(B/A	(C)	(C/A)	(D)	(D/A)	(E)	(E/A)	(F)	(F/A)
					Permanent Employees

Indicate input material

Recycled or re-used input material to total material

Male

3,947

3,947

100%

3,947

100%

0

0%

0

0%

0

0%

Nutcoke

Cokefines

Iron Ore Fines

Sinter Fines

Sand

MS Scrap

FY 2023-24

1.64%

1.14%

7.63%

7.39%

85.93%

1.37%

FY 2022-23

0.73%

0.75%

7.50%

6.05%

83.94%

0.71%

Female	89	89	100%	89	100%	89	100%	0	0%	89	100%
Total	4,036	4,036	100%	4,036	100%	89	100%	0	0%	89	100%
				Other Than Permanent Employees
Male	497	0	0%	497	100%	0	0%	0	0%	0	0%
Female	7	0	0%	7	100%	7	100%	0	0%	7	100%
Total	504	0	0%	504	100%	7	100%	0	0%	7	100%

*Other than Permanent Workers are covered under Work Plan Compensation Policy

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

4. Of the products and packaging reclaimed at end of life of products, amount (in metric tonnes) reused, recycled, and safely disposed, as per the following format:

Category		Percentage of workers covered by
	Total (A)	Health Insurance	Accident Insurance	Maternity Benefits	Paternity Benefits	Day-care Facilities

Indicate input material

Plastics (including packaging)

E-waste

Hazardous Waste

Other Waste

FY 2023-24

Re-used	Recycled	Safely
		Disposed
0	0	0
0	0	0
0	0	0
0	0	0

FY 2022-23*

Re-used	Recycled	Safely
		Disposed
0	0	0
0	0	0
0	0	0
0	0	0

		Number	%	Number	%	Number	%	Number	%	Number	%
			(B/A)	(C)	(C/A)	(D)	(D/A)	(E)	(E/A)	(F)	(F/A)
					Permanent Workers
Male	3,481	3,481	100%	3,481	100%	0	0%	0	0%	0	0%
Female	0	0	0%	0	0%	0	0%	0	0%	0	0%
Total	3,481	3,481	100%	3,481	100%	0	0%	0	0%	0	0%
				Other than Permanent Workers

*Response for FY 2022-23 has been rectified as Jindal SAW manufactures pipes and accessories made of iron and steel no plastic, e-waste, or hazardous waste is generated at the end of the product life cycle.

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

Indicate product category	Reclaimed products and their packaging materials as % of total products sold in respective category
	Not Applicable

Male	12,508	0	0%	0	0%	0	0%	0	0%	0	0%
Female	178	0	0%	0	0%	178	100%	0	0%	178	100%
Total	12,686	0	0%	0	0%	178	100%	0	0%	178	100%

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

	FY 2023-24	FY 2022-23
Cost incurred on well-being measures as a % of total revenue of the Company	0.09%	0.09%

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

Benefits

PF

Gratuity

ESI

FY 2023-24

No. of	No. of	Deducted
employees	workers	and
covered as	covered as a % of	deposited
a % of total	total workers	with the authority
employees		(Y/N/N.A.)
100%	100%	Yes
100%	100%	Yes
1.10%	1.83%	Yes

FY 2022-23

No. of	No. of	Deducted and
employees	Workers covered	deposited with
covered as	as a percentage	the authority
a % of total	of total workers	(Y/N/N.A.)
employees
100%	100%	Yes
100%	100%	Yes
2%	18%	Yes

16 | BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORT

17 | JINDAL SAW LTD.

1. Accessibility of workplaces: Are the premises / offices of the entity accessible to differently abled employees and workers, as per the requirements of the Rights of Persons with Disabilities Act, 2016? If not, whether any steps are being taken by the entity in this regard.
   Response: Yes, some of the Jindal SAW's the premises/offices are accessible to differently abled employees and workers in compliance with the Rights of Persons with Disabilities Act, 2016.
2. Does the entity have an equal opportunity policy as per the Rights of Persons with Disabilities Act, 2016? If so, provide a web-link to the policy. Response:
   Jindal Saw strives to create a workplace that is inclusive and free from discrimination. The Company follows Rights of Persons with Disabilities Act, 2016 to ensure equal opportunities for all employees regardless of ability. The Company prioritizes respect for individuality and is dedicated to fostering a safe and supportive work environment free from prejudice, gender bias, and sexual harassment. It guarantees that no employee faces disadvantage due to disability and upholds equal opportunities for all.
3. Return to work and Retention rates of permanent employees and workers that took parental leave.

Gender	Permanent Employees		Permanent Workers
	Return to work rate	Retention rate	Return to work rate	Retention rate
Male	NA	NA	NA	NA
Female	NA	NA	NA	NA
Total	NA	NA	NA	NA

6. Is there a mechanism available to receive and redress grievances for the following categories of employees and worker? If yes, give details of the mechanism in brief.

Category	Yes/No (If Yes, then give details of the mechanism in brief)
Permanent Workers	Yes, Jindal SAW has an Employee Code of Conduct and a grievance management procedure in place
Other than Permanent Workers
to address and resolve grievances of both permanent and other than permanent employees as well as
Permanent Employees	workers. Employees and workers can report grievances through a designated point-of-contact and a
unique email ID.
Other than Permanent Employees

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

Category		FY 2022-23			FY 2021-22
	Total employees	No. of employees /	%	Total employees	No. of employees /	%
	/workers in	workers in respective	(B / A)	/workers in	workers in respective	(D / C)
	respective	category, who are part of		respective	category, who are part of
	category (A)	association(s) or Union (B)		category (C)	association(s) or Union (D)
		Total Permanent Employees
Male	0	0	NA	0	0	NA
Female	0	0	NA	0	0	NA
		Total Permanent Workers
Male	0	0	NA	0	0	NA
Female	0	0	NA	0	0	NA

8. Details of training given to employees and workers:

Category			FY 2022-23					FY 2021-22
	Total	On Health and safety	On Skill	Total	On Health and safety	On Skill
	(A)	measures	upgradation	(D)	measures	upgradation
		No.(B)	% (B/A)	No. (C)	% (C/A)		No.(E)	% (E/D)	No.(F)	% (F/D)
				Employees
Male	3,947	3,947	100%	3,947	100%	3,787	3,787	100%	2,569	67.84%
Female	89	89	100%	89	100%	59	59	100%	30	50.85%
Total	4,036	4,036	100%	4,036	100%	3,846	3,846	100%	2,599	67.58%
					Workers
Male	3,481	3,481	100%	3,481	100%	3,671	3,671	100%	1,500	40.86%
Female	0	0	0	0	0	0	NA	NA	NA	NA
Total	3,481	3,481	100%	3,481	100%	3,671	3,671	100%	1,500	40.86%

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

Category		FY 2023-24			FY 2022-23
	Total (A)	No.(B)	% (B/A)	Total (C)	No.(D)	% (D/C)
			Employees
Male	3,947	3,879	98.27%	3,787	3,787	100%
Female	89	66	74.15%	59	59	100%
Total	4,036	3,945	97.74%	3,846	3,846	100%
			Workers
Male	3,481	3,182	91.41%	3,671	3,671	100%
Female	0	0	0%	0	0	100%
Total	3,481	3,182	91.41%	3,671	3,671	100%

10. Health and safety management system:

1. Whether an occupational health and safety management system has been implemented by the entity? (Yes/ No). If yes, the coverage such system?
   Response:
   Yes, an Occupational Health and Safety Management System (OHSMS) has been implemented by Jindal SAW, adhering to the ISO 45001 standards across most of its units and is already in the process of being implemented in the remaining units. The coverage of this management system extends comprehensively across all operations within the plant boundaries, ensuring a systematic approach to identifying, assessing, and managing occupational health and safety risks. This includes measures aimed at promoting a safe working environment, preventing work-related injuries and illnesses, and complying with relevant regulatory requirements. This approach ensures that the system remains aligned with the overarching safety principles of the Company.
2. What are the processes used to identify work-related hazards and assess risks on a routine and non-routine basis by the entity
   Response:
   Jindal SAW employs a documented process to identify work-related hazards and assess risks on a routine and non-routine basis, including safety walks, routine checkups, periodic inspections, a work permit system, safety committee meetings, health checkups, and audits. Additionally, risk assessment is conducted through a Hazard Identification and Risk Assessment (HIRA) methodology to identify significant risks and implement appropriate measures for risk mitigation.
3. Whether you have processes for workers to report the work-related hazards and to remove themselves from such risks. (Y/N)
   Response:
   Jindal SAW employs various methods across its plants for workers to report hazards and remove themselves from risks. These include near miss reporting, safety meetings, Safety Toolbox Talks, an observation system via the "Safety Portal," and communication channels such as internal mail and phone. Hazard evaluation is conducted through methods like risk assessment and Hazard Identification and Risk Assessment (HIRA).

18 | BUSINESS RESPONSIBILITY & SUSTAINABILITY REPORT

19 | JINDAL SAW LTD.