ITC Sustainability Policies

Policy on Stakeholder Engagement

Philosophy

ITC believes that an effective stakeholder engagement process is necessary for achieving its sustainability goal of inclusive growth. ITC accordingly anchors its stakeholder engagement on the principles of:

Materiality - taking prioritised consideration of the economic, environmental and social impacts identified to be important to the organisation as well as its stakeholders.
Completeness - understanding the stakeholders' key concerns and expectations.
Responsiveness - responding coherently and speedily to such issues and concerns.

Policy

It is ITC's policy:

To identify and engage with all its stakeholders in a consistent and systematic manner;
To understand the concerns of stakeholders including those who are disadvantaged, vulnerable and marginalised and prioritise their concerns;
To work towards addressing these concerns in an equitable and transparent manner.

Implementation

This policy is communicated to all employees in an appropriate and meaningful manner.
ITC Units have appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, including processing of grievances for redressal. Divisional / SBU Chief Executives, through members of the respective Management Committees, will ensure implementation of this Policy.
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 every quarter. The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy.

This Policy was approved by the Board on 25^th April, 2014.

Policy on Responsible Advocacy

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:

To ensure that its advocacy position is consistent with its values and philosophy;
To work with industry organisations that are engaged in policy advocacy;
To ensure that policy advocacy is conducted ethically.

Implementation

This policy is communicated to all employees in an appropriate and meaningful manner.
ITC Units have appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, including processing of grievances for redressal. Divisional / SBU Chief Executives, through members of the respective Management Committees, will ensure implementation of this Policy.
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 every quarter. The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy.

This Policy was approved by the Board on 25^th April, 2014.

Policy on Product Responsibility

Philosophy

ITC is committed to providing products and services that offer best-in-class quality user experience, using sustainably sourced inputs and raw materials.

Policy

It is ITC's Policy:

To work towards sustainable utilisation of natural resources while producing goods and services, as well as building social and environmental capital through initiatives such as afforestation, regenerative agriculture, integrated watershed development and harnessing renewable energy, for an inclusive and secure future for its stakeholders;
To comply with regulatory requirements pertaining to its products and services, including marketing communication, advertising, promotion and sponsorship to enable customers to make informed purchase decisions;
To have a robust food safety management system to meet regulatory requirements related to food safety, quality processes and hygiene, and also voluntarily adopt emerging safer processes and systems;
To continue to progressively incorporate relevant social and environmental considerations in product / service development processes;
To allow freedom of choice, in a competitive environment, while designing, promoting and selling its products and services;
To provide appropriate mechanisms for customer / consumer feedback to drive continuous improvement in the value propositions of its products and services;
To raise awareness of consumers on responsible disposal of packaging, post- consumption of products;
To work towards safe and optimal resource use over the life-cycle of its products and services, including recycling of resources wherever possible;
To encourage consumers to make sustainable choices by introducing innovative and sustainable products and services.

Governance

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 every quarter.
The CSR and Sustainability Committee will be apprised annually on the implementation of the Policy.

This Policy was approved by the Board on 25^th April, 2014 and last amended on 24^th July, 2021.

Policy on Sustainable Supply Chain and Responsible Sourcing

Philosophy

ITC endeavours to integrate sustainability in the supply chain(s) for its products and services across its diversified business portfolio.

[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:

To continuously raise awareness of supply chain members to comply with 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;
To disengage business relationship with supply chain members in the event of a serious or consistent lack of commitment to corrective action;
To work with supply chain members who adopt and accept the Company's Code of Conduct for Suppliers and Service Providers;
To assess the sustainability risks of supply chain members and assist them to build resilience against such risks;
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;
To collaborate with farmers to make them more sustainable and help build their adaptive capacity and resilience to emerging risks like climate change and water stress and other extreme weather events;
To raise awareness and work with farmers on crop quality, safety, protection, integrity and traceability, as applicable.

Governance

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.
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 every quarter.
The CSR and Sustainability Committee will be apprised annually on the implementation of the Policy.

This Policy was approved by the Board on 25^th April, 2014 and last amended on 24^th July, 2021.

Policy on Freedom of Association

Philosophy

ITC believes 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:

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;
To ensure that employees are not discriminated against for exercising this freedom in a lawful manner and consistent with ITC's core values.

Implementation

This policy is communicated to all employees in an appropriate and meaningful manner.
ITC Units have appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, including processing of grievances for redressal. Divisional / SBU Chief Executives, through members of the respective Management Committees, will ensure implementation of this Policy.
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 every quarter. The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy.

This Policy was approved by the Board on 25^th April, 2014.

Policy on Diversity, Equity and Inclusion

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 organization 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.
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 summarized 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 realization 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 & 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.

This Policy was approved by the Board on 25^th April, 2014 and last amended on 18^th April, 2022.

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

Philosophy

ITC believes in a "No Child Labour and No Forced Labour" policy.

Policy

It is ITC's policy:

To ensure that no person below the age of eighteen years is employed in the workplace;
To prohibit the use of forced or compulsory labour at all its Units;
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;
To refrain from engaging with vendors and suppliers who resort to using child labour and forced labour in their operations.

Implementation

This policy is communicated to all employees in an appropriate and meaningful manner.
ITC Units have appropriate systems and processes in place to ensure compliance with the Policy and with statutory provisions, including processing of grievances for redressal. Divisional / SBU Chief Executives, through members of the respective Management Committees, will ensure implementation of this Policy.
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 every quarter. The CSR & Sustainability Committee of the Board will supervise the implementation of this Policy.

This Policy was approved by the Board on 25^th April, 2014.

Policy on Environment, Health and Safety

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.

Policy

It is ITC's Policy:

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, and endeavour to create the safest workplace environment;
To take into account environment and occupational health & safety aspects in planning and decision-making;
To enhance EHS performance by setting objectives and targets and continually monitoring key performance indicators;
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;
To encourage a culture of safety by providing appropriate training to employees as well as service providers' employees on EHS, investing in state-of-the-art technology and developing human capital;
To instil 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;
To ensure adoption of resource efficient and cleaner production methods and techniques in pursuit of a low carbon pathway;
To continuously enhance contribution from renewable energy sources to meet overall energy demand;
To focus on an integrated water management approach that includes investing in water conservation measures, waste-water treatment and rainwater harvesting so as to continually reduce net water consumption in its units;
To work towards recycling of all waste generated in operations.
[For Clauses 7,8 and 9, please also see the Company's Policy on Resource Efficiency]

Governance

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 and 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 every quarter.
The CSR and Sustainability Committee will be apprised annually on the implementation of the Policy.

This Policy was approved by the Board on 25^th April, 2014 and last amended on 24^th July, 2021.

Code of Conduct for Suppliers and Service Providers

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 International Labour Organisation Guidelines and 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, respect human rights, environmental regulations 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 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 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 and Fair Treatment:

Suppliers and Service Providers shall promote and maintain a workplace free from discrimination 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.

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

Suppliers and Service Providers shall comply with applicable laws concerning the protection of the environment and, wherever possible, adopt environment-friendly technologies and practices.

III. Human Rights

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 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.

IV. Business Integrity

ITC expects the highest standards of ethical conduct in all its endeavours. 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 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 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.

V. 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.

VI. 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.

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

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

Policy on Biodiversity Conservation

Philosophy

ITC is committed to conducting its operations in a manner that protects, conserves and enriches biodiversity.

Policy

It is ITC's Policy:

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 continue to raise awareness of suppliers and other stakeholders on the importance of biodiversity conservation and sustainable use of natural resources;
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;
In the context of biological diversity, to continue to recognise and respect the rights of local communities.

Governance

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 every quarter.
The CSR and Sustainability Committee will be apprised annually on the implementation of the Policy.

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

Policy on Deforestation

Philosophy

ITC is committed to 'Zero Deforestation' and endeavours to source agri commodities and wood from sustainable sources.

Policy

It is ITC's Policy:

To work with farmers, rural communities and relevant stakeholders to safeguard natural forests;
To work with supply chain members who comply with applicable laws and regulations related to deforestation;
To engage with farmers and stakeholders in creating awareness, and promoting wood & fuel self-sufficiency by including them in the Company's afforestation programmes;
To encourage farmers in implementing energy conservation measures;
To explore and 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 institute a system of assessing deforestation risks in the supply chain and implement appropriate mitigation measures.

Governance

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 every quarter.
The CSR and Sustainability Committee will be apprised annually on the implementation of the Policy.

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

Policy on Resource Efficiency

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 ensuring 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 enhance resource-use efficiency by monitoring the carbon footprint of operations, optimising distribution networks and working towards building resilience to impacts of climate change;
To continue to enhance carbon sequestration to mitigate impacts of climate change;
a. 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;
b. To collaborate with and disclose water stewardship outcomes to stakeholders;
c. To encourage and work with supply chain members, including farmers, to improve water-use efficiency in their operations;
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 work with farmers to maximise utilisation of farm land by improving crop yields, promoting crop rotation & diversification and aiding farmers to optimise resource-use and inputs.
[For Clause 3, please also see the Company's Policy on Environment, Health and Safety]

Governance

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 every quarter.
The CSR and Sustainability Committee will be apprised annually on the implementation of the Policy.

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

Policy on Tax

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 24^th July, 2021.

Policy on Animal Testing

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 endeavour to adopt non-animal alternative testing methods for providing assurance to consumers regarding the safety of its products;
To instil a sense of commitment amongst suppliers for not testing ingredients and products on animals.

Governance

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 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 every quarter.
The CSR and Sustainability Committee will be apprised annually on the implementation of this Policy.

This Policy was approved by the Board on 27^th October, 2021.