PRINCIPLE 1 
PRINCIPLE 1
PRINCIPLE 1
Businesses should conduct and govern themselves with integrity, and in a manner that is Ethical, Transparent and Accountable
1. Percentage coverage by training and awareness programmes on any of the Principles during the financial year:
| Segment | Total number of training and awareness programmes held | Topics/principles covered under the training and its impact | %age of persons in respective category covered by the awareness programmes |
|---|---|---|---|
| Board of Directors | 2 | Refreshing Integrity & Security @ Schaeffler | 100% |
| 5 | Operational, Financial Performance, Business Performance & Risk Management, ESG | 100% | |
| Induction of new Independent Director: | |||
| Interaction with Executive Leadership Team - Operational, Business and Functional details | 100% | ||
| Interaction with VP-Legal & CS - Listed entity structure, Regulatory framework, Shareholding structure, Board and Committee composition, Related Party Transaction framework, Insider Trading framework etc. | 100% | ||
| Interaction with Head – Internal Audit - Internal Audit framework, Scope and Risk matrix | 100% | ||
| Interaction with Group Audit Committee Chairperson - Group Audit framework | 100% | ||
| Key Managerial Personnel | 1 | Operational, Financial Performance, Business Performance & Risk Management, ESG | 100% |
| 4 | Integrity & Security @ Schaeffler | 100% | |
| Preventing Bribery & Corruption (PBAC) | 100% | ||
| New Compliance WBT “Antitrust Compliance” | 100% | ||
| Employees other than BoD and KMPs1 | 7 | Integrity & Security @ Schaeffler (New Joiners) | 100% |
| Preventing Bribery & Corruption (PBAC) (For new joiners) | 100% | ||
| Refreshing Integrity & Security @ Schaeffler (For existing) | 99% | ||
| New Compliance WBT “Antitrust Compliance” (For new joiners) | 93% | ||
| 62 | Schaeffler Governance Framework | 96% | |
| Windchill training | |||
| SIEMENS SINAMICS Training | |||
| Workshop on Become Master Presenter | |||
| The Trust Equation (Leadership Essential) | |||
| NITAL HNO3 Tank Process Implementation Awareness Training | |||
| Mastering Self-Motivation | |||
| Managing Export Control Concerns and Compliance in the Sales Process | |||
| GFR 111 A (Workplace safety) | |||
| Functional Training on Project Management | |||
| Finance for Non Finance | |||
| Electrical Cabinet: Design of special machinery | |||
| Diversity, Inclusion and Belonging | |||
| DFMEA Design for Potential Failure Modes and Effects Analysis Quality in | |||
| Critical Thinking and Problem Solving | |||
| Communicating Effectively to Improve Your Leadership Brand | |||
| Coaching Conversations | |||
| Power BI and Analysis Tools | |||
| Prevention of Sexual Harassment (POSH) at Workplace | |||
| Human rights | |||
| Performance and Goal Management (PMGM) | |||
| Workers1 | 51 | Awareness Training of Bearing Handling During Assembly and Roller Visual Defect | 79% |
| KAIZEN | |||
| PRESS SAFETY TOOL SETTING | |||
| 5S + DOJO Training | |||
| Addressing Poor Work Habits | |||
| Prevention of Sexual Harassment (POSH) at Workplace | |||
| Bearing Assembly Process | |||
| Chemical Material Handling | |||
| Cyber Security Awareness Workplace | |||
| Fire Extinguisher and Fire Hydrant Practical | |||
| KATA Coaching | |||
| Machine safety/Workplace Safety | |||
| Problem Solving and Decision-Making (8D and Other Tools) |
1In the above Snapshot we have not considered allied services like Canteen, Housekeeping, Security, Transportation, construction workers 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 Principle | Name of the regulatory/ enforcement agencies/ judicial institutions | Amount (In `) | Brief of the Case | Has an appeal been preferred? (Yes/No) |
| Penalty/Fine | During the year, there were no 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 accordance with the materiality as specified in Regulation 30 of SEBI (Listing Obligations and Disclosure Obligations) Regulations, 2015. | |||
| Settlement | ||||
| Compounding fee | ||||
| Non-Monetary | ||||
| NGRBC Principle | Name of the regulatory/enforcement agencies/ judicial institutions | Brief of the Case | Brief of the Case | Has an appeal been preferred? (Yes/No) |
| Imprisonment | During the year, there were no imprisonment/punishments against any Directors/KMP | |||
| Punishment | ||||
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.
Not applicable – As during the year, there were no fines/penalties/punishment/imprisonment/award/compounding fees settlement amount paid in proceedings (by the entity or by directors/KMPs) with regulators/law enforcement agencies/judicial institutions in accordance with the materiality as specified in Regulation 30 of SEBI (Listing Obligations and Disclosure Obligations) Regulations, 2015.
4. 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.
Yes
Business practices of Schaeffler are based on the principles of mutual
respect, integrity and fairness which are defined in Schaeffler Code of Conduct,
which is available on
Schaeffler India website. Clause 2.2 of the Code of Conduct provides guidance on
Anti-corruption. The values and principles of code of conduct are implemented while
designing
the business integrity compliance policy (Internal document)
This policy provides binding instructions on business integrity, particularly in the
compliance risk areas below, to reduce the risk of violations of the law.
Shaeffler India also has a separate Code of Conduct for Directors, Senior Management
& Employees (refer: CoC of Directors, Senior Management & Employees) and Suppliers
Code of Conduct (refer: COC_ Suppliers). The relevant policies can be accessed
through the web-link provided. The Company also creates awareness about the policy
to all its
employees, vendors and supply chain partners through physical/virtual training
sessions, e-modules Etc. Following are links.
Coc of directors, senior management & employees
Supplier Code of conduct
Group code of conduct
5. Number of Directors/KMPs/employees/workers against whom disciplinary action was taken by any law enforcement agency for the charges of bribery/corruption:
| FY 2024 | FY 2023 | |
|---|---|---|
| Directors | Nil | Nil |
| KMPs | Nil | Nil |
| Employees | Nil | Nil |
| Workers | Nil | Nil |
6. Details of complaints with regard to conflict of interest:
| FY 2023 | FY 2022 | |||
|---|---|---|---|---|
| Number | Remark | Number | Remark | |
| Number of complaints received in relation to issues of Conflict of Interest of the Directors | 0 |
No Conflict of Interest incidents were reported against Directors. |
0 |
No Conflict of Interest incidents were reported against Directors. |
| Number of complaints received in relation to issues of Conflict of Interest of the KMPs | 0 |
No Conflict of Interest incidents were reported against KMPs |
0 |
No Conflict of Interest incidents were reported against KMPs |
7. 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
Not applicable, as we do not have any instances of corruption/conflicts of interest against Directors and KMPs.
8. Number of days of accounts payables ((Accounts payable* 365)/Cost of goods/services procured) in the following format:
| FY 2024 | FY 2023 | |
|---|---|---|
| Number of days of account payables | 64 | 72 |
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 2024 | FY 2023 |
|---|---|---|---|
| Concentration of Purchases2 | a) Purchases from trading houses as % of total purchases | 3.0% | 3.0% |
| b) Number of trading houses where purchases are made from | 331 | 334 | |
| c) Purchases from top 10 trading houses as % of total purchases from trading houses | 35.5% | 36.8% | |
| Concentration of Sales | a) Sales to dealers/distributors as % of total sales | 16.6% | 15.7% |
| b) Number of dealers/distributors to whom sales are made | 753 | 755 | |
| c) Sales to top 10 dealers/distributors as % of total sales to dealers/distributors | 21.2% | 21.8% | |
| Share of RPTs in | a) Purchases (Purchases with related parties/Total Purchases) | 43.6% | 41.1% |
| b) Sales (Sales to related parties/Total Sales) | 12.3% | 12.6% | |
| c) Loans & advances (Loans & advances given to related parties/Total loans & advances)1 | 100.0% | 100.0% | |
| d) Investments (Investments in related parties/Total Investments made)1 | 100.0% | 100.0% |
1Here we have considered non - current Loans & Non-current
investments for calculation.
2Schaeffler India purchases production material directly from
Supply Chain Partners and do not involve any trading houses from
import/export perspective. Values mentioned here are concerned with domestic
dealers/traders &
consisting only of non production material.
1. Awareness programmes conducted for value chain partners on any of the Principles during the financial year:
| Total number of awareness programmes held | Topics/principles covered under the training | %age of value chain partners covered (by value of business done with such partners) under the awareness programmes (2024) | %age of value chain partners covered (by value of business done with such partners) under the awareness programmes (2023) |
|---|---|---|---|
| 25 | Supply Chain digitalization: The "SupplyOn" tool is implemented with Production Material suppliers as per group guideline. It covers topics such as Sourcing Module, Web EDI, ASN, GTL, Performance Monitor etc. | 95%2 | 90% |
| 35 | Schaeffler Supplier Sustainability (Carbon emission management and targets, Environmental management certification, Occupational health and safety certification, SAQ and Sustainability Target agreement). | 62%1 | 89%1 |
1 Self-Assessment (SAQ) by
supplier
2As a percentage of Purchase value from supply chain partners
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.
Yes
All directors are governed by Schaeffler India Code of Conduct for Directors, Senior
Management & Employees which includes Conflict of interest (COI) clause.
COI declarations are taken from the Board members on an annual basis. Adequate
resolution is agreed about the declared conflict and documented.
We have internal policy document on Business integrity & compliance (Internal
Policy) which lays down procedures for the Disclosure and Handling of Conflicts of
Interest.
Following are links for code of conduct:
Coc of directors, senior management & employees
Supplier Code of conduct
Group code of conduct
Business integrity & compliance policy (internal policy)