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Responding department: Corporate Human Resources

Stock Exchange Symbol: (ITC:IN)

Does your company have a publicly available commitment to respect human rights?

Yes, the Company has Board approved Human Rights policies which uphold rights and standards enshrined in various International standards. The Human Rights Policies pertain to freedom of association, diversity and equal opportunity, prohibition of child labour, prevention of forced labour at the workplace and includes human rights consideration of stakeholders beyond the workplace.

  • Policy on Freedom of Association: [link]
  • Policy on Diversity & Equal Opportunity: [link]
  • Policy on Prohibition of Child Labour and Prevention of Forced Labour at the Workplace: [link]
  • Policy on Environment, Health and Safety: [link]
  • Corporate Social Responsibility Policy: [link]

ITC Code of Conduct for Suppliers and Service Providers covers aspects pertaining to labour practices, EHS, Environment and Business Integrity and has been shared with concerned Suppliers and Vendors for formal sign-off ([link]).

Other relevant policies include:

  • Policy on Responsible Sourcing: [link]
  • Policy on Human Rights Consideration of Stakeholders Beyond the Workplace: [link]
  • Policy on Life-cycle Sustainability: [link]

How are human rights governed in your company?

Compliance with Policy is regularly monitored and evaluated by the Sustainability Compliance Review Committee (SCRC) of the Corporate Management Committee (CMC). The report of the SCRC is reviewed by the CMC every quarter. The CSR and Sustainability Committee of the Board supervise the implementation of these Policies.

How are human rights managed within your company?

This policy is communicated to all employees in an appropriate and meaningful manner through induction programnmes, sensitization workshops, policy manuals and intranet portals. 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, ensure implementation of this Policy. A comprehensive organization-wide integrated sustainability data management system (ISDMS) has been implemented to collect, collate and analyse the sustainability performance data, including that on Human Rights. The system provides a platform to benchmark performance internally among business units, as well as monitors data of each business.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

ITC has a structured approach to engaging with its stakeholders based on detailed materiality analysis, covering all aspects of the interface, including human rights. The Company's institutionalised systems and formal processes include

  •  identification of key stakeholder groups
  •  consultation mechanisms
  •  identification and prioritisation of concerns and needs
  •  addressing these needs and concerns in a consistent and transparent manner

A variety of consultation mechanisms appropriate for each group forms the basis of engagement with each of ITC’s key stakeholders. The Company’s method of engagement with these stakeholder groups, their key concerns, needs and expectations and ITC’s response to these are set out in its annual Sustainability Reports, that are available on the Company’s corporate website. In the case of employees and workers, the engagement process broadly comprises induction programmes / customised training workshops, individual performance appraisal and employee engagement surveys as well as a structured grievance handling process. In all ITC production units, any significant changes are proposed, discussed and finalised during the Long Term Agreement negotiations with recognised unions. Engagement with local communities is anchored in regular community needs assessment activities undertaken in collaboration with independent parties / civil society organisations, which form the basis for ITC’s community development initiatives. Regular assessments of the direct and indirect impacts of these initiatives also form a key element in the engagement process.

Priority human rights issues: What are some of the priority human rights issues for your company?

  • Health (including workplace health & safety, prevention of pollution)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Sexual harassment
  • Freedom of association and trade union rightsTransparency in payments to governments / responsible tax practicesWomen
  • Children (including child labour)

Actions on health

ITC has a formal EHS management structure with clearly defined roles and responsibilities, in complete conformity with OHSAS 18001 and ISO 14001 standards. All ITC manufacturing units are ISO 9001, ISO 14001 and OHSAS 18001 certified. All major hotels are ISO 14001 and ISO 22000/HACCP certified. All units (manufacturing facilities, hotels, offices, research & development centres, etc) have EHS committees with defined responsibilities. ITC’s Corporate EHS (CEHS) department is responsible for ensuring the Company’s EHS guidelines are implemented across all its businesses and for monitoring performance through systematic audits. As part of ITC’s commitment to employee safety and zero accidents, all accidents and incidents are recorded and investigated by trained managers to analyse the root cause and prevent any reoccurrence. For communities residing in its operational areas, the Company is engaged in ensuring open defecation free habitations through construction of toilets and campaigns to bring about behavioural change with regard to sanitation.

Actions on workplace diversity / non-discrimination

ITC’s Hotels Division has a proactive policy for employment of People With Disabilities (PWDs) who are employed in areas including Food Production, Beauty Salons, Secretarial work, Accounts, Laundry Valet/Fabric Care Operations, Bell Desk Operations, General Stores, Loss Prevention/Security, Food Testing laboratory, Time Office Management, Gardening, Engineering Operations, Staff Cafeteria, Training Department, Data Entry Operations.

Actions on access to water

Water resource management is a top priority for ITC as it engages with thousands of farmers across India who are constituents of the Company’s multiple supply chains and for whom water availability is critical to their livelihoods, especially as the majority are small and marginal farmers with little or no access to irrigation and are largely dependent on rain-fed agriculture. ITC’s Integrated Watershed Development Programme is targeted towards these farmers. Initiated in 2001, by the end of Dec 2014, the participatory projects run in partnership with local communities had covered approximately 171,626 hectares in 8 states, benefiting more than 138,875 households. Although these projects are targeted towards improving water availability for agriculture, the rise in the water table and better local water management practices support an improvement in drinking water points within the village. Apart from this external Programme, all ITC units are mandated to maximise water usage efficiencies and rainwater harvesting activities. Of the treated effluent which is not recycled or re-used within ITC’s production units and is discharged outside their  premises, the largest proportion is used for irrigation by communities in the vicinity. In 2013-14, this amounted to 15.8 million KL , i.e. 66% of the total volume of 23.9 million KL. ITC’s Integrated Watershed Development Programme combined with water resource management measures undertaken throughout its units have resulted in the Company being water positive for the past 12 years.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Internally – As with all ITC’s policies and practices, those pertaining to human rights are clearly communicated to all employees in a manner that is easy to understand through induction, training and awareness programmes, policy manuals, intranet portals, management briefings, formal communication meetings and trade unions.

Externally – In line with ITC’s commitment towards transparency and accountability in all areas of its operations, its human rights policies, practices and initiatives are available on the corporate website – . Information in this area is also communicated through the Company’s Annual Report & Accounts (which have included a Business Responsibility Report section since 2013) and its annual Sustainability Reports (published since 2004, GRI compliant and have included communication on progress on implementation of United Nations Global Compact Principles – UNGC-COP Elements – since 2010). These publications are also archived on the corporate website.

ITC also regularly participates and makes presentations at national and international public fora.

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

All ITC businesses and their respective units have a structured grievance handling process in place to enable employee grievances to be resolved in a just and equitable manner. Customers can highlight concerns related to product through defined stakeholder engagement process. Given the diverse nature of ITC’s businesses, the specific process varies from business to business. However, in all cases the process is based on transparency and accountability.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

ITC has been a participant of the UN Global Compact since 2008. The Company promotes sustainable practices premised on respect for human rights through its membership of a wide spectrum of industry associations across India. An illustration of this commitment is the CII-ITC Centre of Excellence for Sustainable Development (CII-CESD), set up by the Company in partnership with CII (Confederation of Indian Industry) in 2006. CII-CESD works towards enabling Indian businesses pursue sustainability goals and embed sustainable development concerns into their strategies and processes.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

ITC has introduced the following processes in the last couple of years, though these are not necessarily linked to UN Guiding Principles:

  • Code of Conduct for Suppliers and Service Providers
  • Process for Stakeholder expectation management
  • Roll-out of the grievance redressal procedure for management staff