Business ethics refer to implementing appropriate business policies and practices with regards to subjects including corporate governance, insider trading, bribery, discrimination, corporate social responsibility, and fiduciary responsibilities. A strong and fully embedded commitment to undertaking business ethically brings considerable benefits, including improved consumer perception (leading to increased loyalty), greater investment, reduced costs, and enhanced employee motivation, involvement and interaction to name just a few. JSW has always recognized its moral obligation to do all that it can to operate its business to the highest standards of personal and professional integrity, honesty and transparency, recognizing the intrinsic benefits that good business ethics and governance provide. However, in spite of all that we have so far achieved in operating our business ethically, we recognize that there remains a potential for us to do much more. JSW is committed to embed sound governance, deliver transparency, tackle corruption, manage risks and provide value through strong and robust business ethics. 

JSW Energy's Policy on Business Conduct is available here

Corporate Governance :

 

 

Board Effectiveness :

We adhere to the minimum attendance criteria as per the Companies Act, 2013. In accordance with Section 167-1 (b) of Companies Act, 2013 - The Directors are required to attend minimum of one meeting conducted during the year. The office of the Director shall become vacant, if he/ she absents himself from all the meetings of the Board of Directors held during a period of twelve months with or without seeking leave of absence of the Board. During the reporting year, 7 meetings were conducted for the Board, hence the minimum attendance requirement can be said to be 1 out of 7 which is 14%.

We comply with the maximum permissible limit related to Directorship requirements of the Companies Act, 2013 and Listing Obligation and Regulations Requirement i.e., a person shall not hold office as a director, including any alternate directorship, in more than twenty companies at the same time, out of which maximum 10 can be public. Out of 10 public companies, a director can hold directorship in not more than 7 listed companies. Hence, no Director holds directorships in more than 10 public companies or in more than 7 listed companies. No Director who is serving as Whole time Director / Managing Director in any listed entity is serving as an Independent Director in not more than 3 listed entities.

 

Risk Governance :

The Risk Management framework is guided by the Group level Risk Management team, cutting across all business verticals. Monitoring and auditing of the risk management process is also taken care by the Risk committee

During meetings with the Board of Directors, the Board is presented with the aspects of Global Energy sector Scenario, Global/Indian Economy, significant geo-political events impacting energy sector & power industry, Risk Management Practices, including climate-related risks Company’s Financials, Sales, Production, Business Strategy, Subsidiary’s performance before taking on record the financial results of the Company. Further, as part of the Independent director's familiarization program, independent directors are apprised regarding the company's strategies to manage risks as well as monthly updates on performance and any developments which affect the company.

We review our company's risk exposure at least twice a year. Our risk management procedures are internally audited on a periodic basis.

 

Code of Conduct: Systems and Procedure :

Our Company's Policy on Business Conduct acts as a guiding compass for both the organization and its employees. By adhering to this policy, we strive to foster a culture of ethical and responsible business practices.

All employees, including board of directors, are required to adhere to the code of conduct and laws and regulations of the country wherein we operate. Violations of these laws can result not only in severe fines for the company and also for individuals linked to the company. Every employee covered under the policy is held accountable for his/her behavior. Any violation to the code of conduct, the covered employee may be subject to disciplinary action after the investigation.

Reporting on Breaches

There were no cases related to money laundering during FY 23.

 

Cyber security:

For us, cybersecurity is a top priority. As we embed digitalisation into our operations, our business is more prone to cyber threats. We have meticulously devised ways through which we can protect our business and our stakeholders, through various vulnerability and breach assessments, keeping ourselves updated as per the industry best practices. This is headed by our Chief Information Officer and overseen by the Risk Management Committee

 

Stakeholder Engagement Procedure

JSW Energy Ltd has a well-established internal Stakeholder Engagement Framework. Our procedure is applied at all local operations. Stakeholder Engagement enables us to formulate separate strategic initiatives to strengthen our relationship with each of our stakeholders. The objective of engaging with the various stakeholders is defined independently, and the objective of engaging with local communities is provided in our CSR Policy. The highlights of the framework are as follows:

The framework is applicable to all JSW Group Companies and subsidiaries, joint ventures, merged and acquired entities and the factories/ plants/ sites, corporate offices (including regional, marketing and sales offices), research and development facilities, project sites (including temporary projects) under operational control. For project sites, it is applicable to the entire lifecycle (including planning, assessment, exploration, evaluation, design, development, operation, and closure of the project/business.

The framework guides the company in formulating a plan to identify and prioritize the stakeholders. Principal stakeholders of an existing site/project are likely to be those directly affected by any adverse environmental or social aspects associated with the site/project’s operations - these stakeholders are often referred to as Affected Communities. Such Affected Communities may also contain specific groups of marginalised and disadvantaged people in society, indigenous peoples, local tribes, etc.

A simplistic method of prioritization, based on a judgement of both the extent to which the stakeholder is impacted by the site/project, and the perceived level of power and influence the stakeholder has, been provided for all Group Companies. Sites/projects may choose to utilise this simplistic prioritization approach or adopt a more complex mechanism for prioritization of their identified stakeholders.

After the stakeholders have been shortlisted, a stakeholder Engagement Plan is drafted. As part of the implementation of the Stakeholder Engagement Plan, the person(s) responsible shall determine the methods that will be used to consult with each of the stakeholder groups that have been identified, including free two way conversations with the stakeholder. For sites/projects with potentially significant adverse impacts on Affected Communities, the site/project will need to conduct an Informed Consultation and Participation (ICP) process that will build upon the Stakeholder Consultation.

Resettlement planning, designing and implementing community development programs, and engagement with indigenous peoples’ groups are good examples of where informed participation by affected stakeholders can lead to better outcomes on the ground. In certain situations, capacity-building programs are established to enable affected stakeholders (particularly local communities and organizations) to be able to participate fully and effectively in the process.

As part of the implementation of the Stakeholder Engagement Plan, the person(s) responsible shall determine what information will be disclosed, in what formats, and the types of methods that will be used to communicate this information to each of the stakeholder groups identified. Information disclosure involves delivering information about the site/project to interested and affected parties, including Affected Communities, and ensuring access to such information by other stakeholders. The information should be in appropriate language(s), and accessible and understandable to the various segments of the site/project’s stakeholders and Affected Communities.

We have an internal guidance framework to determine how to handle any stakeholder engagement risks that may arise while engaging with the stakeholders. At the local level, this guidance can be adapted to better fit the stakeholder concerned.

Our Board of Directors are briefed on Stakeholder Engagement at least once a year. The group Chief Sustainability Officer is responsible for overseeing the Stakeholder Engagement Process and Materiality Assessment Process.

 

Grievance Mechanism

Our Grievance Management provides a mechanism through which all stakeholders, including Affected Communities, can raise grievances and have such grievances addressed in a transparent, credible and fair manner. The grievance could be written at jswel.investor@jsw.in. The local stakeholders can also send an email to any of the plant locations who will handle their grievances. In cases where the conventional grievance mechanism is not accessible, the stakeholders can approach the CSR offices present at each site.  Communication through the CSR offices provides a dedicated channel for the local stakeholders to report their grievances to the CSR department responsible for Stakeholder Engagement. Our process helps us understand the grievance of the local communities and maintain a register recording all the grievances shared.

 

Double Materiality Assessment

JSW Energy conducts materiality assessment once every two to three years. The Company engages in continuous interactions with its external and internal stakeholders to understand their perspective and identify their key issues and concerns. This facilitates in identifying topics of significance to both its internal and external stakeholders. This exercise helps the organisation to plan strategies for managing the risks and harnessing the opportunities.  

In furtherance to this, to align with the evolving ESG landscape we have revised our materiality assessment as per the principle of double materiality considering the aspects of Financial and Impact Materiality with approval from our senior leadership.

As part of our ongoing assessment, the company has identified three most significant material topics: Greenhouse gas emissions and Energy Resource Planning, Waste Management and Occupational Health and Safety. The interim result of the assessment can be seen in the materiality matrix below.

(Details of our impacts, business strategies and initiatives can be found out in the respective sections, refer to the hyperlink)