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relevance to the Company and provides clarifications to shareholders on behalf of the Board. The Board encourages open dialogue with all its shareholders - be it individuals, corporates or foreign investors. At the General Meetings, shareholders are provided with all requisite information.

Shareholders are also encouraged to write to the Company with their suggestions, comments and opinions on the working of the Company. Valid suggestions and comments are taken into consideration.

The Company’s corporate website ‘www.itcportal.com’ provides comprehensive information on ITC’s portfolio of businesses, its social responsibility activities and EHS performance. The website has entire sections dedicated to ITC’s profile, history and evolution, core values, corporate governance and leadership, and to ‘Shareholder Value’ and ‘Investor Relations’. It also provides a ready forum through which shareholders can express their views and opinions to the Company.

Precautionary Principles

The Company has in place an extensive framework of policies, processes and procedures that define its approach towards protection of property rights and risk management.

ITC ensures the protection of Company property by means of a comprehensive insurance mechanism. The Internal Audit Department and External Auditors conduct audits of financial accounting, projects, systems and IT security of all Divisions/SBUs. A Projects Policy Manual is also in place. Apart from this, the Company has clearly spelt out Environment, (Occupational) Health and Safety requirements, compliance reports of which are furnished every month to the Corporate Management Committee. Corporate EHS undertakes an EHS audit of all Units. All new projects are designed in accordance with corporate standards and are audited and certified by the Corporate EHS Department.

ITC has a Corporate Accounting and Systems Policies (CASP) document. The objective of CASP is to operationalise the tenets of Corporate Governance; ensure adherence to laid down accounting policies for uniformity of systems, procedures and practices across the Company and be a handbook for risk management. The Divisions have evolved their own DASP (Divisional Accounting and Systems Policies) for their respective businesses. Other major Central/Divisional policies are:

Policy for risk management in commodities trading
Forex Treasury Manual
Human Resource Policy
Information Technology Policy

trans.gif The Company is committed to complying with all the relevant statutes, and has benchmarked practices in various aspects of its operations and Corporate Governance. The Company has enunciated internal codes such as the ITC Code of Conduct and the Insider Trading Code. Expenditure control and monitoring is undertaken by way of monthly cost budgets along with variance analysis.

Auditing Process

Messrs. A. F. Ferguson & Co., Chartered Accountants, are the Statutory Auditors of the Company. They conduct audit of the financial statements of the Company, in accordance with the auditing standards generally accepted in India, and report the same to the shareholders of the Company. Additionally, ITC also has its own Internal Audit Department, which provides an independent and objective assessment of the status of the following: adequacy of operating systems and policies and compliance thereof, statutory compliance, risk exposures and their management, implementation of top management directives, quality of management decision making process and the financial health of the business in terms of quality of assets and profits.

Environmental and Social Review of Service Providers

Procedures detailed under ISO 14001 and OHSAS 18001, and the Corporate EHS Guidelines set out detailed and comprehensive norms that all suppliers and service providers must follow. These norms and guidelines are communicated to all the service providers before they are enlisted. These are also specified on job and work orders. The EHS coordinator of each Unit is responsible for elucidating ITC’s EHS norms and safe work practices, and educating the service providers and suppliers who interface with that Unit. All new ‘entrants’ in the capacity of service providers are imparted EHS training. ITC Units have solicited support from the National Safety Council for training service providers and their workmen involved in large construction work, like the installation of the new pulping facility in ITC’s Paperboard Unit at Bhadrachalam. Planned and surprise EHS audits at the Unit level, supplemented with audits by the Corporate EHS Department and Internal Audit Department help ensure compliance with all applicable statutes and relevant labour laws.



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