Section B: Management and Process Disclosures

Sl. No. Disclosure Questions P1 P2 P3 P4 P5 P6 P7 P8 P9
Ethical & Transparent business conduct Businesses should conduct and govern themselves with integrity and in a manner that is ethical, transparent and accountable Sustainable and safe goods Businesses should provide goods and service in a manner that is sustainable and safe Well-being of Employees Businesses should respect and promote the well-being of all employees, including those in their value chains Interest of Stakeholders Businesses should respect the interests of and be responsive to all its stakeholders Promote
Human rights Businesses should respect and promote human rights 		Protect & Restore Environment Businesses should respect and make efforts to protect and restore the environment Public Policy Advocacy Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent Diversity & Inclusion Businesses should promote inclusive growth and equitable development Value to
Consumers Businesses should engage with and provide value to their consumers in a responsible manner
Policy and management processes
1. a) Whether your entity’s policy/policies cover each principle and its core elements of the NGRBCs. (Yes/No) Yes Yes Yes Yes Yes Yes Yes Yes Yes
Yes, the Company has policies which are relevant to NGRBC principles. (See below)
b) Has the policy been approved by the Board? (Yes/No) Yes Yes Yes Yes Yes Yes Yes Yes Yes
Yes, all the relevant policies are approved by the Board of Directors
c) Web-link of the Policies, if available Yes Yes Yes Yes Yes Yes Yes Yes Yes
Company policies are available on Schaeffler India official website, also some policies & internal documents are available on company’s internal website. https://www.schaeffler.co.in/en/investor-relations/corporate-governance/codes-and-policies/
2. Whether the entity has translated the policy into procedures. (Yes/No) Yes Yes Yes Yes Yes Yes Yes Yes Yes
Yes, all the policies are translated into procedures. Procedures are available on management handbook on the Company’s internal website.
3. Do the enlisted policies extend to your value chain partners? (Yes/No) Yes Yes Yes Yes Yes Yes Yes Yes Yes
Yes, per CSRM (Category-specific Requirements Matrix), we extend the policies to the value chain partners, like we have Supplier code of conduct (Now, Business partners code of conduct) applicable to suppliers. https://www.schaeffler.co.in/en/company/purchasing-and-supplier-management/
4. Name of the national and international codes/ certifications/labels/standards (e.g. Forest Stewardship Council, Fairtrade, Rainforest Alliance, Trustee) standards (e.g. SA 8000, OHSAS, ISO, BIS) adopted by your entity and mapped to each principle. ISO 9001:2015
IATF 16949
ISO/TS 22163:2017
Quality Assurance programme certification		 ISO 9001:2015
IATF 16949
ISO/TS
22163:2017
ISO
14001:2015
ISO
45001:2018
BIS series 		LKSG
ILO
Convention
ISO
45001:2018 		ISO
9001:2015
IATF 16949
TISAX
BIS series 		LKSG
ILO Convention
ISO
45001:2018 		ISO 45001:2018
ISO 14001:2015
ISO 50001:2018
EU-EMAS 		BIS Specifications LKSG
ILO
Convention 		ISO 9001:2015
IATF 16949
Quality Assurance programm certification ISO/TS
22163:2017
TISAX
BIS series
1Our IT Procedures are compliant with General Data Protection Regulation (‘GDPR’) and the Digital Personal Data Protection Act, (‘DPDP’) 2023.
1Information security management system (ISMS) is aligned with international standards such as ISO/IEC 27001.
5. Specific commitments, goals and targets set by the entity with defined timelines, if any. Schaeffler India has developed an ambitious and structured programme with long-term goals to advance our commitment towards sustainability. (Refer page 55)
6. Performance of the entity against the specific commitments, goals and targets along-with reasons in case the same are not met. Schaeffler India has the process of monitoring ESG performance to track deviations on time. Schaeffler India conducts regular quarterly reviews of ESG performance with the Top Management and presents the same to the Board of Directors and the suggested changes, if any, are made in the strategy, if required. Also, Monthly reviews are conducted at plants by Plant Managers. Details about progress so far on our targets is available on page 55 in the Annual report.
P1 Businesses should conduct and govern themselves with integrity, and in a manner that is Ethical, Transparent and Accountable.
1. Code of Conduct for Directors, Senior Management & Employees
2. Code on Prohibition of Insider Trading
3. Dividend Distribution Policy
4. Policy on Determination of Material Subsidiary
5. Policy on Determination of Materiality for Disclosure of Events or Information
6. ESG Group policy (Internal document)
7. Risk Management Policy
8. Information_Cyber_Security-DataProtection (Internal policy document) 		9. Human right compliance policy (Group, Internal policy document)
10. Legal policy (Group Internal policy document)
11. Related Party Transactions Policy
12. Vigil Mechanism or Whistle-Blower Policy
13. Internal Audit Charter
14. Business Integrity Compliance (Group Internal policy)
15. Policy against Sexual Harassment (POSH Policy)
16. Compliance with Anti trust and Competition Law internal guidelines
17. Internal control system policy (Group Internal policy)
P2 Businesses should provide goods and services in a manner that is sustainable and safe
1. The Schaeffler Supplier Code of Conduct (Internal policy Document)
2. Sustainability target agreement (Internal doc.)
3. EHS policy (Internal Document)
4. Human right policy (Internal Document)
5. Code of Conduct for Directors, Senior Management & Employees
6. ESG Group policy (Internal doc.)
P3 Businesses should respect and promote the well-being of all employees, including those in their value chains.
1. Nomination and Remuneration Policy
2. Internal policies: Employee transfers, employee referral, employee death benefit etc.
3. Policy against Sexual Harassment
4. Vigil Mechanism or Whistle-Blower Policy
5. Compliance with Anti trust and Competition Law internal guidelines 		6. Code of Conduct for Directors, Senior Management & Employees
7. Internal policies: employee education Assistance, travel, mobile, Petro card, Internal job, relocation, car policy, Parental policy, workman leave policy
8. ESG Group policy (Internal document)
9. Human resource policy (Group Internal policy Document)
P4 Businesses should respect the interests of and be responsive to all its stakeholders.
1. Divided distribution policy
2. Code on Prohibition of Insider Trading
3. Policy on Determination of Materiality for Disclosure of Events or Information
4. Code of Fair Disclosure and Conduct; Policy for determination of “Legitimate Purposes”
5. Internal Audit Charter
6. Compliance with Anti trust and Competition Law internal guidelines 		7. Risk Management Policy
8. Related Party Transactions Policy
9. Business Integrity Compliance (Internal Policy)
10. Supplier code of Conduct, STA (Sustainability Target Agreement- Internal document)
11. Vigil Mechanism or Whistle-Blower Policy
12. Information_Cyber_Security-DataProtection (Internal policy document)
P5 Businesses should respect and promote human rights
1. Code of Conduct for Directors, Senior Management & Employees
2. Human right compliance policy (Group, Internal policy document)
3. Nomination and Remuneration Policy
4. The Schaeffler Supplier Code of Conduct (Internal policy Document)
5. EnEHS policy (Group policy)
6. ESG Group policy (Internal doc)
P6 Businesses should respect and make efforts to protect and restore the environment.
1. EnEHS policy (Group policy)
2. Emergency Planning 172930 – 172949 (Group Internal policy)
3. ESG Group policy (Internal document)
4. Business continuity, contingency & crisis mgmt.(Group Internal policy) 		5. Policy for Preservation of Documents & Archival of Information
6. Sustainability target agreement (Internal Document)
7. Risk Management Policy
P7 Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent.
1. Code of Conduct for Directors, Senior Management & Employees
2. Code on Prohibition of Insider Trading; Code of Fair Disclosure and Conduct; Policy for determination of “Legitimate Purposes”
3. Business Integrity Compliance (Internal Policy)
P8 Businesses should promote inclusive growth and equitable development.
1. Corporate Social Responsibility Policy
2. The Schaeffler Supplier Code of Conduct 		3. Human right compliance policy (Group, Internal policy document)
4. ESG Group policy (Group Internal doc)
P9 Businesses should engage with and provide value to their consumers in a responsible manner.
1. Cyber security policy
2. Code of Conduct for Directors, Senior Management & Employees
3. Privacy policy
4. Compliance with Anti trust and Competition Law internal guidelines
5. Information security policy, Artificial intelligence(AI) policy (Group, internal policy document) 		6. Internal Audit Charter
7. Quality & continuous improvement Policy (Group, internal policy document)
8. Information_ Cyber_ Security-Data Protection (Group, internal policy document)
9. Internal control system policy (Group)
(All are internal policies available on company intranet page.)
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).
A statement from the MD & CEO, please refer page 21.
8.
Details of the highest authority responsible for implementation and oversight of the Business Responsibility policy (ies).
Name of highest authority : Mr. Harsha Kadam
Designation : MD & CEO
DIN : 07736005
Category : E & NID
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.
The Company has a structured “Sustainability Network” to set Sustainability targets, to review the performance and follow up actions in defined areas of ESG. Sustainability Network is overseen by six pillars of Leadership Team.
Six pillars are – Strategy, Sustainable purchasing, Sustainable production, Sustainable products, Sustainability reporting, People and Culture.
The network is responsible for reviewing, monitoring, and discussing key sustainability performance indicators and defining strategy and action plans to achieve them. Team ensures Schaeffler standards, and stakeholders’ expectations are fulfilled. Quarterly reviews in Board meeting are conducted where ESG performance are discussed & suitable changes are made in our strategy if required.
1. The Risk Management Committee: The RM Committee formulated a detailed Risk Management Policy covering the framework for identification of internal and external risks specifically faced by the Company, in particular including financial, operational, sectoral, sustainability (particularly, ESG related risks), information, cyber security risks or any other risk as may be determined by the Committee, measures for risk mitigation including systems and processes for internal control of identified risks and Business continuity plan. The RM Committee ensures that appropriate methodology processes and systems are in place to monitor and evaluate risks associated with the business of the Company. The RM Committee monitors and oversee implementation of the Risk Management Policy, including evaluating the adequacy of risk management systems. (For composition of Risk Management Committee refer Corporate Governance Report).
2. The Corporate Social Responsibility (CSR) Committee: The CSR Committee defines the focus areas and indicate the activities to be undertaken by the Company under CSR domain. The CSR Committee formulate the Annual action Plan, monitor the budget under the CSR activities of the Company. The CSR committee reviews status of the CSR projects undertaken towards social cause and further gives directions to uplift the life of the community surrounding, which contributes for sustainability. (For composition of CSR committee please refer CSR report.)

10. Details of Review of NGRBCs by the Company:

Subject for review Indicate whether review was undertaken by Director/Committee of the Board/Any other Committee
P1 P2 P3 P4 P5 P6 P7 P8 P9
Performance against above policies and follow up action Compliance with statutory requirements of relevance to the principles, and, rectification of any non-compliances Yes, Done by Executive management, relevant committee & Board
Subject for review Frequency
P1 P2 P3 P4 P5 P6 P7 P8 P9
Performance against above policies and follow up action Compliance with statutory requirements of relevance to the principles, and, rectification of any non-compliances Periodic reviews by relevant executive management for six pillars & Quarterly by Relevant committee & Board

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.

Yes, an assurance engagement was carried out by BDO AG to provide assurance about design, implementation and operating effectiveness of Compliance Management System on topics anti corruption, anti-trust and prevention of economic crime. During the EHS audits, as part of the requirements of ISO standards, EHS policy is assessed/evaluated and suitable review is undertaken if required. Independent external agencies Ms. EMAS and Ms. Intechnica are conducting our EHS & energy management systems audits. Also, we have robust internal audit process which carry out a detailed examination of policies & procedures and regulatory requirements. As a part of process, report on the status of compliance is submitted to Board on a regular basis. To comply with best practices and mitigate risks, policies are reviewed and revised periodically by various business leaders, and then approved by the management/Board. Policy review is also part of ISO certification process which is done at HQ level.

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

The entity does not consider the Principles material to its business (Yes/No) Answer to question (1) above is “Yes”, hence this question is Not Applicable
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)