AIM 1

Keep community welfare at the core of business decisions

As a socially responsible organisation, we take utmost care to ensure that we cause no harm to local life and the environment. This principle of no harm is built into our commitment to responsible mining and manufacturing. We uphold human rights and the interests of potentially vulnerable communities like the indigenous people. We promote local economic growth and development, which makes us a developer of choice in the areas we operate.

Key material issues

Community development

Human rights

SDGs impacted

Sub-goals8.3 : Promote development-oriented policies that support productive activities, decent job creation, entrepreneurship, creativity and innovation, and encourage the formalization and growth of micro-, small- and medium-sized enterprises, including through access to financial services

Governance

Engaging with communities is a critical element for the success of our business and we have empowered management bodies to oversee the implementation of this pillar.

At the Board level, we have two committees to provide oversight to this work – the ESG Committee and the CSR Committee. Both committees are chaired by Independent Directors. The ESG Committee is tasked with oversight of overall ESG risks and is primarily concerned with ensuring the business retains its social license to operate (Aim 1). The CSR Committee is tasked with overseeing the implementation of our social impact programmes, which includes the programmes managed by the BU CSR teams, the Anil Agarwal and Vedanta Foundations.

The Board Committees are supported by the ESG & CSR ManComs respectively. These ManComs include senior executives to oversee delivery of the programmes. The ‘Community of Practice’ manages the on-ground implementation of this pillar’s aims.

The following policies and related standards guide action on this pillar: Social Policy, CSR Policy, Human Rights Policy, Indigenous Peoples & Vulnerable Tribal Groups Policy. These are part of the Vedanta Sustainability Framework (VSF).

Principles that govern our relationship with communities

No harm to the communities

Regulatory compliance Health, Safety, Environmental impacts Loss of land and Resettlement

Building trust

Open and consistent communication Human rights policies Stakeholder engagement Grievance management

Benefit sharing

Local employment opportunities Local procurement opportunities Welfare & community development programmes

Responsible social performance

We derive a deep sense of honour from the fact that a multitude of communities host our business operations. These communities are diverse and include agrarian societies, semi-urban populations, indigenous peoples, and city-dwellers. Each of these communities is at a different stage of development and, as a result, each has a different aspiration for themselves and different expectations from us. Due to this complexity, an inclusive, transparent, process-driven, need-based approach with host communities is essential to retaining our social license to operate.

In line with globally accepted principles, we call this, our approach towards improved social performance. Fundamental to this business philosophy is that we need to keep the wellbeing of the community in mind in every business decision that we make and create appropriate channels for consultation to ensure that our actions are in alignment with our intentions.

Delivery on this aim is being ensured using the following approach:

Having the right management structure in place

Drafting policies and standards aligned to global best-practice

Developing the right KPIs and driving their implementation

The Social Performance Organisation

Aim 1 is currently managed by the ‘Community’ Community of Practice (CoP).

Our social performance standards call for every site to have a Social Performance Manager (SPM), whose role is to drive the implementation of social performance principles at the location. The SPM is the convening authority for the Social Performance Steering Committee (SPSC).

The SPSC is a cross-functional body at each location, chaired by the BU CEO or site-head. It is tasked with ensuring that all business decisions are viewed through a social

risk lens and pro-active or remedial actions are taken by the responsible business teams to eliminate or minimise social risk. The SPSC is also meant to oversee the resolution of all grievances in a timely manner. The SPSC consists of representation from at least the following functions: External Affairs/Public Relations, Operations, Security, CSR, Human Resources, HSE, Finance, and Corporate Communications.

The SPM is supported by a Community Liaison Officer (CLO), whose primary responsibility is to have regular interactions with the local communities.

This structure allows us to expand responsibility for addressing social risk to departments other than CSR.

Social Performance is driven by the following policies within the Vedanta Sustainability Framework:

  • Social
  • Human Rights
  • Indigenous & Peoples Vulnerable Tribal Group

It is further supported by standards and guidance notes such as:

  • External Stakeholder Engagement, Grievance Management, Cultural Heritage, Land & Resettlement Management, Conducting ESIAs, Security Management, Community Investment, and Indigenous Peoples & Vulnerable Tribal Groups

These standards are benchmarked to respective ICMM, IFC Performance Standards, and GRI guidelines/standards. All our businesses undergo an Environmental and Social Impact Assessment (ESIA) before beginning operations. Any findings from the ESIA are considered and a mitigation plan developed.

Feedback and grievances

Feedback mechanisms are integral to our operations and a critical part of our stakeholder engagement process. They help us map our impact on the communities and take steps to address them.

All locations also have formal grievance mechanism cells where external stakeholders can register their grievances. It is the endeavour of the business to close all grievances in a fair and timely manner. All our sites follow VSF standard on grievance mechanism, which is in alignment with global best practice recommended by ICMM and IFC performance standards.

KPIs and implementation

Our KPIs have been designed to ensure that we are managing Social Performance along the principles of (i) Do no harm, (ii) Building respectful & trusting relationships, and (iii) Sharing the benefits that result from the economic progress our activities create

Key performance indicators

FY2025 Goals

FY2022 performance

Key performance indicators

Impact Management

FY2025 Goals

Zero social incidents category 4 and above

FY2022 performance

1 Category 4 social incident

Key performance indicators

Transparency & Trust

FY2025 Goals

Signatories and participants on VPSHR

FY2022 performance

Work to begin in FY2023

Key performance indicators

Transparency & Trust

FY2025 Goals

Annual human rights assessment across all the businesses

FY2022 performance

Human Rights self-assessment conducted across all BUs

Additionally, we also have KPIs on: Percentage of social incidents investigated and closed, percentage of grievances reported and resolved, programmes in place to encourage local employment and local procurement, and CSR investment targets for local communities.

Greater participation of site leadership teams, better tracking, investigation and closure of grievances, eliminating any negative impacts on communities, and engaging the communities in economic activities are some of the key outcomes that we seek from this programme.

Our Progress – Social Performance Pilots

In FY2022, we have completed one out of two pilot projects to implement social performance across our locations. Under the guidance of global experts, the Lanjigarh location undertook an extensive exercise to coach their site leadership teams on aligning with social performance thinking. Capacity building sessions, identification of key social risks, allocation of management resources, development of site-specific Standard Operating Procedures, and monthly check-ins of the Lanjigarh SPSC were some of the key activities of this programme.

Learnings from this pilot are being adopted in the unit and across the organisation.

A second pilot at HZL’s Rajapura Dariba Complex was kicked-off but has been delayed. We plan to bring this pilot on-track in the second half of FY2023.

PROTECTING THE RIGHT OF INDIGENOUS COMMUNITIES

Being a part of the mining sector, some of our operations are adjacent to territories that are owned by indigenous and vulnerable communities. Building trust with indigenous communities is vital for the continuation of our operations. We recognise the rights, cultures and beliefs of the indigenous communities and are committed to respect and protect them across all our units.

At Vedanta, we are committed to recognise, promote and protect the rights and freedoms of Indigenous Peoples in area of our operations. We are guided by UN Declaration on the Rights of Indigenous Peoples and ILO Convention 169 on Indigenous and Tribal Peoples. Our Indigenous Peoples Vulnerable Tribal Group Policy along with Cultural Heritage, Land and Resettlement Management and Indigenous Peoples/Vulnerable Tribal Groups standards guide corporate action on the subject

Vedanta has committed to following the principles of Free, Prior, Informed Consent (FPIC) in those project that have the potential to impact indigenous communities. In FY2019, we had undertaken an independent assessment to compare FPIC requirements with stringent Indian regulation that exists to safeguard the rights of indigenous communities. The study revealed that several portions of the Indian regulation align with the intent of FPIC. Where there are gaps, we are working to develop internal standards to comply with our commitment towards FPIC.

Resettlement

Throughout FY2022, the Lajigarh location worked on plans to resettle and rehabilitate 132 families who currently live on the site of the proposed expansion of Lanjigarh’s red-mud pond. The work has been meticulously planned over several years and is being done under the guidance of the State of Odhisha. New housing and employment opportunities for one adult member of each household, and compensation for the land/crops has been agreed upon after extensive consultation with the communities. This is also in accordance with the requirements of our Land Acquisition & Resettlement standard, which asks site teams to provide alternative homestead lands, homebuilding assistance, employment opportunities, and cash payments in lieu of employment.

Vedanta’s teams regularly connect with community members, and District and State authorities to resolve grievances, questions and concerns arising from this future relocation of the families.

It is anticipated that the resettlement process will be completed by FY2023

HUMAN RIGHTS

We are committed to protecting the fundamental rights of all individuals across our operations. To ensure that, we continue to strengthen our human rights management system and processes by benchmarking our performance with that of global peers and practices. We recognise the significance of human rights-related issues given the nature of our sector and are committed to upholding our core value of ‘Respect’.

Our Human Rights Policy prohibits forced or child labour across our supply chain. This Group-wide policy promotes fair working conditions, equal opportunities and respect for the cultural heritage of local communities. To identify potential human rights, forced and child labour related risks, we undertake periodic reviews and risk assessment across all our units.

Human Rights Policy

Our Human Rights policy is in alignment with the United Nations Declaration on Human Rights, UN Guiding Principles of Business and Human Rights (the Ruggie Principles), Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR), and the International Covenant on Economic, Social, and Cultural Rights (ICESCR), International Bill of Rights, and ILO.

Our Code of Business Conduct and Ethics (COBE) is aligned with all relevant national laws and regulations. Every year, all employees and business partners have to give a positive affirmation that they continue to align with and adhere to the requirements of the code. Additionally, all of our contract agreements also require our Business Partners to commit to adhering to the COBE.

Aim

To become signatories and participants of Voluntary Principles on Security and Human Rights (VPSHR) by 2025

Progress so far

In FY2022, all our sites conducted Human Rights self-assessment, using UN Global Compact selfassessment tool

We periodically conduct training on human rights and Code of Conduct for our employees and contractual workers. The trainings align with our human rights policy and guidance notes, which have been developed in alignment with the International Finance Corporation (IFC) Performance Standards and International Council on Mining and Metals (ICMM) guidelines.

Human Rights training

Total Headcount Number receiving human rights training % Trained
Security personnel 3,632 3,396 93.50

Human Rights Assessment

In FY2022, we conducted human rights self-assessment at all our sites using the Global Compact Self-Assessment Tool*. The assessments were carried out by crossfunctional site teams chaired by site heads including functional site leaders. The tool assesses the site on various thematic areas such as management approach, health safety impacts, labour rights: including forced labour, child labour, collective bargain and freedom of association, discrimination, environmental impacts and anti-corruption.

Through this assessment, we identified areas for development. Site level policies and plans are in place to reinforce a culture of respect to maintain human dignity in our day-today operations.

*Global Compact Self-Assessment Tool. Developed by the Danish Institute for Human Rights, the Confederation of Danish Industries, the Ministry of Economic and Business Affairs and the Danish Investment Fund for Developing Countries

Aligned to Modern Slavery Act

We have been complying with the Modern Slavery Act (UK) or MSA since 2016. With regular and systematic updates and audit mechanisms, we have been making our systems robust to ensure that our vendors and supply chain are entirely free of slave labour. We also seek MSA self-declaration from each of our vendors.

818

SUPPLIER WENT THROUGH ASSESSMENT ON ESG INDICATORS

Key initiatives

  • MSA clause included in vendor contracts, SCOC and recruitment procedures
  • MSA awareness and training programmes for vendors
  • Suppliers’ assessment on ESG indicators
  • Annual declaration from vendors
  • MSA compliance for onboarding new vendors
  • Supply chain managers regularly trained on Vedanta Code, SCOC and Human Rights Policy

More information on Vedanta’s adherence to the Modern Slavery Act can be found at: https://www.vedantaresources. com/SiteAssets/Images/Vedanta%20Slavery%20and%20 Human%20Trafficking%20Statement%202022.pdf

Right to freedom of association

When it comes to human rights we make no distinction between direct and indirect workers and have in place a comprehensive system for contractual labour management and employee wellbeing across all our locations. We endorse the right to freedom of association. Transparent and fair discussions between union representatives and management are initiated to form collective bargaining agreements. The arrangement includes remuneration, allowances, working conditions, incentives and bonuses, health and safety, manpower productivity, among others.

16,860

TOTAL FULL-TIME WORKFORCE

4,703

COVERED BY COLLECTIVE BARGAINING AGREEMENTS

28%

OF WORKFORCE COVERED BY COLLECTIVE BARGAINING AGREEMENT (FULL-TIME EMPLOYEES)

ON AVERAGE,

51%

OF OUR FULL-TIME EMPLOYEES AT BALCO, HZL, IRON ORE BUSINESS, FACOR AND ZINC INTERNATIONAL AND CMT AUSTRALIA ARE COVERED BY COLLECTIVE BARGAINING AGREEMENT

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