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1 SUPPLEMENTARY REPORT
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SUPPLEMENTARY REPORT
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Purpose of this Report
This report is published as a supplementary report to the Integrated Annual
Report FY 2019-20 of ATL. This additional report is prepared in response to the
stakeholder suggestions and queries. Information not sufficiently covered in the
Annual Report is disclosed herein and this report shall be removed from public
domain when disclosure as part of this report in incorporated in FY 21
Annual/ESG Report.
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Contents
Purpose of this Report ................................................................................................................ 2
1. Following good governance practices ............................................................................... 8
1.1. Board of Directors ....................................................................................................... 8
1.1.1. Composition of the Board .................................................................................... 8
1.1.2. Skills and Experience ........................................................................................... 9
1.1.3. Committees of the Board ..................................................................................... 9
1.2. Board Evaluation ....................................................................................................... 11
1.3. Remuneration Procedure ........................................................................................... 12
1.3.1. Remuneration to Non-executive Directors ........................................................ 12
1.3.2. Remuneration to Executive Directors ................................................................ 12
1.4. Board Meetings and Procedure ................................................................................. 13
1.5. Shareholding pattern ................................................................................................. 14
1.5.1. Management Ownership .................................................................................... 14
1.5.2. Rights, Preferences and Restrictions attached to Shares ................................... 15
1.5.3. Employee Stock Options.................................................................................... 15
1.5.4. Annual Total Compensation Ratio ..................................................................... 15
2. Risk Management ............................................................................................................ 16
2.1. Risk Governance ....................................................................................................... 16
2.2. Risk Management Framework .................................................................................. 18
2.3. Sensitivity Analysis and Stress Testing .................................................................... 19
2.4. Risk Culture............................................................................................................... 20
2.5. Audit Management .................................................................................................... 20
3.Code of Conduct ................................................................................................................... 20
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4. Preventing Corruption and Bribery .................................................................................. 21
4.1. Vigil Mechanism/Whistle Blower Policy ................................................................. 22
5. Public Policy .................................................................................................................... 23
6. Responsible Working Practices ....................................................................................... 23
6.1. Protecting Human Rights across value chain ............................................................ 23
6.1.1. Communication and Training for Employees .................................................... 23
6.1.2. Supplier Screening and Evaluation .................................................................... 24
6.1.3. Human Rights Risk Assessment ........................................................................ 24
6.1.4. Child Rights ....................................................................................................... 25
6.1.5. Working Hours and Remuneration .................................................................... 25
6.1.6. Freedom of Association and Collective Bargaining .......................................... 26
6.2. Fostering a Diverse and Inclusive Workforce ........................................................... 26
6.2.1. Gender Diversity ................................................................................................ 26
6.2.2. Inclusion of people with disabilities .................................................................. 27
6.3. Employee Engagement .............................................................................................. 27
6.3.1. Employee Engagement Trends .......................................................................... 28
7. Enabling a Safe and Healthy workplace .......................................................................... 28
7.2. Occupational Health and Safety Management .......................................................... 29
7.2.1. Incident Reporting and Investigation ................................................................. 29
7.2.2. OHS Risk Assessment ....................................................................................... 31
7.2.3. #Safety Culture .................................................................................................. 31
7.2.4. Safety Targets and Performance ........................................................................ 31
7.2.5. Health ................................................................................................................. 32
8. Energy Consumption ....................................................................................................... 32
9. Climate Action ................................................................................................................. 33
9.1. Governance................................................................................................................ 33
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9.1.1. Board Committee Oversight .............................................................................. 33
9.1.2. Compensation .................................................................................................... 34
9.2. Climate Change Risk Management Framework ....................................................... 34
9.3. Strategy...................................................................................................................... 35
9.3.1. Key aspects of ATL’s strategy ........................................................................... 35
9.4. Climate Change Risk Assessment ............................................................................. 36
9.4.1. Scenario Analysis............................................................................................... 36
9.4.2. Physical Risk ...................................................................................................... 36
9.4.3. Transition Risks ................................................................................................. 37
9.5. ATL’s Climate Change Mitigation Measures ........................................................... 38
9.5.1. Reduction of GHG emissions ............................................................................ 38
9.5.2. Maximise Renewable Energy Integration .......................................................... 38
9.5.3. Energy Efficiency Programs .............................................................................. 39
9.5.4. Carbon Sequestration ......................................................................................... 39
10. Biodiversity ................................................................................................................... 40
11. Water Risk .................................................................................................................... 41
11.1. Water Claim ........................................................................................................... 42
12. Pollution and Resources ................................................................................................ 43
12.1. Air Pollution .......................................................................................................... 43
12.2. Water Use and Discharge ...................................................................................... 44
12.2. Waste Management ............................................................................................... 45
13. Responsible Supply Chain ............................................................................................ 45
13.1. Supplier Code of Conduct ..................................................................................... 46
13.2. Supplier Screening and Evaluation Criteria .......................................................... 46
13.3. Identification of Critical Suppliers and Risk Assessment ..................................... 47
14. Cyber Security .............................................................................................................. 48
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15. Customer Satisfaction ................................................................................................... 49
15.1. Customer Data Protection ...................................................................................... 49
16. Stakeholder Engagement Governance .......................................................................... 49
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1. Following good governance practices
ATL has a robust corporate governance framework that steers the company to meet its
financial, operational, and strategic objectives while meeting all the applicable regulations and
addressing the stakeholder concerns. The company complies with the Code of Corporate
Governance as required under the SEBI (Listing Obligations and Disclosures Requirements)
Regulations, 2015 (“SEBI Listing Regulations”), as applicable.
1.1. Board of Directors
1.1.1. Composition of the Board
ATL’s board has a balanced one-tier system with productive combination of Executive and
Non-Executive Directors, including independent professionals.
The Board currently comprises of seven Directors among whom are Executive Directors and
remaining four are Independent Directors. Exceeding the requirements of Companies Act 2013,
the board comprises of 57% Independent Directors, bringing independent judgement and
diverse mindsets to the boardroom. Independent Directors are non-executive directors as
defined under Regulation 16(1)(b) of the SEBI Listing Regulations. The role of CEO and
Chairman is split, and the Chairman is Executive member of the Board and Non-Independent.
ATL’s Board has a judicious mix of experience, competence and sound, whose aim is to
provide real value to the company, working every day from a position of integrity and
43%
57%
COMPOSITION OF THE BOARD ACCORDING TO THE NATURE OF THE POSITION
Executive Directors Independent Directors
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transparency in the most efficient and effective way representing and protecting the interest of
shareholders.
ATL has an established Board Diversity policy to harness the differences and uniqueness in
knowledge, skill, regional and industry experience, cultural and geographical background, age,
ethnicity, race and gender, which will ensure that ATL retains its business advantage.
Accordingly, gender diversity is ensured with 28% of female on the Board as Non-executive
and independent director with the appointment of Mrs. Lisa MacCallum in FY 20-21. ATL’s
senior management team develops the company’s strategic direction and seeks approval of the
Board. The Management oversees its execution, while ATL’s Board of Directors provides
oversight of strategy execution.
Details on composition of the Board of Directors, their commitment to other Boards, and conflict of
interests, if any, are available in ATL’s Integrated Annual Report FY 2019-20, Page number 145.
The Board Charter are available on organizations website in the following link
https://www.adanitransmission.com/investors/board-and-committee-charters
1.1.2. Skills and Experience
ATL’s Board brings together a wealth of knowledge, perspectives, experience and diversity to
the Company. The Board has collective competency in the areas of the power sector, strategy,
financial, counterparty negotiation, risks, and legal, environment and social issues.
Details on the list of core skills/competencies identified by ATL as required in the context of the
company’s business and that the said skills are available within the Board Members, are available in
ATL’s Integrated Annual Report FY 2019-20, Page number 147.
1.1.3. Committees of the Board
The Board committees play a vital role in ensuring sound corporate governance practices. The
Committees are constituted to handle specific activities and ensure speedy resolution of the
diverse matters. The Board supervises the execution of its responsibilities by the Committees
and is responsible for their action.
The Board Charter of various Board Committees are available on organizations website in the
following link https://www.adanitransmission.com/investors/board-and-committee-charters
Independent Audit Committee
The Audit Committee of the Board acts as a link among the Management, the Statutory
Auditors, Internal Auditors and the Board of Directors to oversee the financial reporting
process of the company. The Committee’s purpose is to oversee the quality and integrity of
accounting, auditing and financial reporting process including review of the internal audit
reports and action taken report.
All Board members of the Audit Committee have accounting and financial management
knowledge and expertise/ exposure. Dr. Ravindra H. Dholakia, a Non-Executive &
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Independent Director and a member of the Audit Committee is the Board’s financial expert in
specific.
Nomination and Remuneration Committee
• The Nomination and Remuneration Committee of the Board has the mandate to
formulate criteria for determining qualifications, positive attributes and independence
of a director and recommend to the Board a policy, relating to the remuneration of the
directors, key managerial personnel and other employees.
• Formulation of criteria for evaluation of Independent Directors and the Board of
directors.
• Devising a policy on Board diversity
• Identifying persons who are qualified to become directors and who may be appointed
in senior management in accordance with the criteria laid down and recommend to the
Board their appointment and removal and shall carry out evaluation of every director’s
performance.
• To extend or continue the term of appointment of the independent director, on the basis
of the report of performance evaluation of independent directors.
• To recommend/review remuneration of the Managing Director(s) and Whole-time
Director(s) based on their performance and defined assessment criteria.
• To carry out any other function as is mandated by the Board from time to time and/or
enforced by any statutory notification, amendment or modification, as may be
applicable.
• To recommend to the board, all remuneration, in whatever form, payable to senior
management.
• To perform such other functions as may be necessary or appropriate for the performance
of its duties.
Stakeholders’ Relationship Committee
• Oversees various aspects of interest of shareholders, debenture holders and other
security holders including complaints related to transfer/transmission of shares, non-
receipt of annual report, non-receipt of declared dividends, issue of new/duplicate
certificates, general meetings etc.
• Reviewing the measures taken for effective exercise of voting rights by shareholders
• Reviewing of adherence to the service standards adopted in respect of various services
being rendered by the Registrar & Share Transfer Agent.
• Reviewing the various measures and initiatives taken for reducing the quantum of
unclaimed dividends and ensuring timely receipt of dividend warrants/annual
reports/statutory notices by the shareholders of the Company.
• Carry out any other function as is referred by the Board from time to time or enforced
by any statutory notification/amendment or modification as may be applicable.
Corporate Social Responsibility and Sustainability (CSR&S) Committee
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• Formulates and recommend to the Board, a Corporate Social Responsibility Policy
which shall delineate the activities to be undertaken by the company as specified in
Schedule VII of the Companies Act 2013.
• Recommend the amount of expenditure to be incurred and monitor the implementation
of CSR Policy.
• Further, the committee seeks Approval and review of the Company’s sustainability
policy and oversees the management processes and standards designed to manage the
Company’s Sustainability performance and regularly updating the Board’s competency
on the subject of Sustainable Development
• Reviewing the Company’s annual Sustainability Report assurance process and signing
off the Sustainability Report for public disclosure.
• Sub-delegation of authority and recommending the positioning to manage relevant
sustainability issues and sharing information.
• Regularly updating its competency on the subject of Sustainable Development and
reviewing its own performance and effectiveness including its terms of reference for
overseeing the Company’s Sustainability performance.
• To carry out any other function as is mandated by the Board from time to time and/or
enforced by any statutory notification, amendment or modification as may be applicable
or as may be necessary or appropriate for performance of its duties.
Risk Management Committee
• The committee is required to review the Company’s risk governance structure, risk
assessment and minimisation procedures and the guidelines, strategies and policies for
risk mitigation on short-term as well as long-term basis.
• To monitor and review the risk management plan of the Company.
• To review the current and expected risk exposures of the organisation, to ensure the
same are identified, qualitatively and quantitatively evaluated, analysed and
appropriately managed.
• Carry out any other function as is referred by the Board from time to time or enforced
by any statutory notification/amendment or modification as may be applicable.
• To review cyber security function of the Company.
1.2. Board Evaluation
The Nomination and Remuneration committee of ATL is responsible for the evaluation and
compensation of the members of the Board. In line with the evaluation criteria formulated by
the committee, the Board has adopted a formal mechanism for evaluating its performance as
well as that of its Committees and individual Directors, including the Chairman of the Board.
The exercise was carried out through a structured evaluation process covering various aspects
of the Board’s functioning, such as its composition and committees, experience and its
competencies, performance of specific duties and obligations, contribution at the meetings and
otherwise, independent judgment, and governance issues, among others. The evaluation of the
Board is conducted internally by means of peer appraisal annually as per statutory
requirements.
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ATL’s Board of directors are elected individually during the Annual General Meetings through
shareholder voting process formulated by the Nomination and Remuneration committee. The
average tenure of the board members is 5 years and the members elected are assured to have
the right experience and skills, are sufficiently independent, and act in the best interests of all
stakeholders.
For more information on Board of Directors election and Voting refer here.
Further, the Board is regularly educated on the emerging risks and trends of the energy sector.
On a half yearly basis, the Board members are presented with a comprehensive assessment of
the ESG risks and opportunities that has the potential to impact ATL’s business and the
corresponding mitigation strategies to be taken. This ESG presentation also covers the risk
related to climate change and the strategy formulated in detail.
1.3. Remuneration Procedure
The Nomination and Remuneration committee of the Board had established a Remuneration
Policy that rewards performance, based on review of achievements on a periodic basis. The
policy ensures that the level and composition of remuneration of the Directors is optimum.
Board compensation is guided by the Remuneration Policy and is in accordance with the
provisions of applicable law and the by-laws.
1.3.1. Remuneration to Non-executive Directors
Non-Executive Directors are remunerated for attending meeting of Board of Directors & its
Committees. The expenses incurred for attending each meeting of the Board and Committee
are reimbursed. Other than sitting fees paid to Non-Executive Directors, there were no
pecuniary relationships or transactions by the company with any of the Non-Executive and
Independent Directors of the Company. The company has not granted stock options to Non-
Executive and Independent Directors.
1.3.2. Remuneration to Executive Directors
The remuneration of the Executive Directors is recommended by the Nomination and
Remuneration Committee based on criteria such as industry benchmarks, the company’s
performance vis-à-vis the industry, responsibilities shouldered, performance/track record,
macroeconomic review on remuneration packages of heads of other organisations and is
decided by the Board of Directors.
The company pays remuneration by way of salary, perquisites and allowances (fixed
component), incentive remuneration and/or commission (variable components) to its Executive
Directors within the limits prescribed under the Companies Act, 2013. The executive
remuneration is voted and approved by the shareholders annually. In addition, ATL has
established pre-defined relative financial metrics relevant for CEO’s variable compensation
including compensation influenced by Operational Performance and Revenue Growth.
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None of the Directors of the Company are drawing any remuneration from the company. Mr.
Anil Sardana, Managing Director and CEO has drawn a remuneration of INR 7.65 Crore,
including both the fixed and variable remuneration, from one of the operating subsidiaries of
the Company during FY 19-20.
There is no separate provision for payment of severance fees under the resolutions governing
the appointment of Chairman and Whole-time Director. The company has not granted stock
options to the Executive Directors or Employees of the Company. The Executive and Promoter
group Directors are not being paid sitting fees for attending meetings of the Board of Directors
and its committees.
In addition, there is no separate provision for remuneration of senior executives based on ESG
performance. However, various ESG performance indicators like safety indicators, CSR
related indicators etc. are part of individual KRAs.
In FY 20-21, ATL has established a Claw Back Policy that is applicable to the CEO and the
senior executives included in the company's remuneration.
For more details refer Remuneration Policy (which is already disclosed on the website)
1.4. Board Meetings and Procedure
ATL’s internal guidelines for Board/Committee meetings facilitate the decision-making
process at the meetings of the Board/Committees in an informed and efficient manner.
Minimum four pre-scheduled Board meetings are held every year. Apart from the above,
additional Board meetings are convened by giving appropriate notice to address the specific
needs of the company. In case of business exigencies or urgency of matters, resolutions are
also passed by way of circulation.
In financial year 2019-20, four Board Meetings were held. The company has held at least one
Board meeting in every quarter and the gap between two meetings did not exceed one hundred
and twenty days. During the year, the Board of Directors accepted all recommendations of the
Committees of the Board, which were statutory in nature and required to be recommended by
the Committee and approved by the Board of Directors. During the year under review, the
Board of Directors of the Company have added 21 new policy documents and
amended/approved changes in few of the existing policies to enhance good governance
practices.
Attendance and meetings of the Board of Directors and Committees in 2019
Board of
Directors
Audit
Committee
Nomination
&
Remuneration
Committee
Stakeholders’
Relationship
Committee
Corporate
Social
Responsibility
&
Sustainability
(CSR&S)
Committee
Risk
Management
Committee
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Quorum 100% 100% 100% 100% 100% 100%
No. of
Meetings
4 4 4 4 2 3
For more information on please refer ATL’s Annual Report 2019-20.
1.5. Shareholding pattern
As of 31st March 2020, ATL's share capital was made up of 109,98,10,083 fully subscribed
and paid-up in equity shares with a par value of Rs.10 per share.
Currently, the promoter group of the Company is holding 74.92% equity stake of the Company
which is within the statutory limits. Further, the composition of the board of directors of the
Company comprises judicial mix of Two promoter Directors, four independent directors and
One professional Managing Director and CEO, thereby ensuring the requirement of having
57% Board being Independent.
1.5.1. Management Ownership
Directors No. of shares owned
Mr. Gautam S. Adani 1
Mr. Rajesh S. Adani 1
Promoters and Promoter Group
Foreign Portfolio Investors
Mutual Funds, Financial Institutions/Banks
N.R.I. and Foreign National
Private Bodies Corporate
Indian Public and others
Clearing Members (Shares in Transit)
0 10 20 30 40 50 60 70 80
Category-wise Shareholding (%)
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Mr. Anil Sardana (CEO) 0
Mr. K. Jairaj 0
Dr. Ravindra H. Dholakia 0
Mrs. Meera Shankar 0
Mrs. Lisa MacCallum 0
Key Managerial Personnel
Mr. Kaushal G. Shah, Chief Financial
Officer (Term of office up to 2nd February
2021)
0
Mr. Jaladhi Shukla Company Secretary 49
The CEO, Mr. Anil Kumar Sardana does not own any shares of the company, while Mr. Jaladhi
Shukla. Company Secretary owns 49 shares of the company.
1.5.2. Rights, Preferences and Restrictions attached to Shares
The Company has only one class of equity shares having par value of Rs.10 each and the holder
of the equity share is entitled to one vote per share. Therefore, the total voting power with
respect to the number of shares is 1099810083.
The dividend if proposed by Board of Directors is subject to approval of the shareholders in
the ensuing Annual General Meeting. In the event of liquidation of the Company, the holders
of equity shares will be entitled to receive the remaining assets of the Company, after
distribution of all preferential amounts, in proportion to the number of equity shares held.
To check if this table can be kept
Voting rights per share Total amount of shares Voting Power
One Vote 1,099,810,083 1,099,810,083
1.5.3. Employee Stock Options
The company does not have any Employees’ Stock Option Scheme and there is no separate
provision for payment of Severance Fees.
1.5.4. Annual Total Compensation Ratio
The annual total compensation of the Chief Executive Officer, who is the highest paid
individual of the organisation, is Rs. 76500000, which includes both the fixed and variable
remuneration corresponding to his role as top executive of the Company, as well as the fixed
remuneration corresponding to his role as a member of the Board of Directors and other
remunerations.
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The median compensation of the total workforce, excluding the highest-paid individual is Rs.
960000. The ratio between the total annual compensation of the highest-paid individual of the
organisation and the median total compensation of the entire workforce (excluding the highest-
paid individual) was 79.68 times in FY 2019-20.
Total CEO compensation
(INR)
Median Employee
Compensation in INR (Total
Workforce)
CEO-to-Employee Pay Ratio
76,500,000 960,000 79.68
2. Risk Management
ATL has established a comprehensive risk management system in place in order to facilitate
the fulfilment of the company’s strategies and objectives, ensuring that the risks that could have
an impact on them are identified, analysed, assessed, managed and controlled systematically.
Risk Management is a process driven by ATL’s Board of Directors who are assisted by the
Audit Committee and Risk Management Committee, which reviews and monitors the
effectiveness of the risk management processes of the company in accordance with the
corporate governance requirements.
2.1. Risk Governance
The responsibility of Risk Management at ATL is assigned to committees, departments, and
people at multiple levels of the organisation. The comprehensive nature of the Risk
Management System guarantees effective involvement of all the organisational units and
ensures that the different governing bodies responsible for risk control are kept abreast of the
status of the risks.
Board-Level Risk Management Committee - Audit Committee and Risk Management
Committee of the Board provides oversight to the identification and management of the most
significant risks and are responsible for review and monitoring of the effectiveness of the risk
management processes of the company. The Board-level Committee provides guidance to the
Management Risk Committee (MRC).
Management Risk Committee - The Management Risk Committee (MRC) assesses, manages
and reports on all significant risks, its impact on ATL’s business and the mitigation measures
identified and planned to the Board-level committee. The Committee also assesses the
effectiveness of risk identification process and provides guidance on top-priority risks and their
mitigation plan to the Business Risk Team (BRT) and Functional Risk Committees (FRCs).
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Site/Functional Risk Committees – The Functional Risk Committees represented by cross-
functional members are assigned the responsibility of monitoring the management of the
identified risks in respective business units.
Business Risk Team – The Business Risk Team of ATL is assigned the responsibility of overall
supervision and coordination of risk management at the different business units. Risks
identified by functional and site risk committees are evaluated and high potential risks are
reported with a mitigation plan to the business risk committee. The Chief Risk Officer, Mr.
Kaushal Shah, is the highest-ranking person with dedicated risk management responsibility on
an operational level and reports directly to the CEO.
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2.2. Risk Management Framework
ATL has established a Risk Management framework based on the COSO (The Committee of
Sponsoring Organizations of the Treadway Commission) framework and aligning towards ISO
31000 to effectively manage the risks identified with an aim to support the organization’s
strategy and to achieve business objectives.
ATL’s risk management framework focuses on the early identification of key risks and
conducts detailed consideration of the existing levels of mitigation and the management actions
required to either reduce or eliminate the risk. The risks identified are prioritized, evaluated to
understand the probability and magnitude of impact on business and appropriate management
plan is devised and executed.
The step-by-step Enterprise Risk Management process is as follows:
1. Risk identification is done by Functional Heads, Business Heads, Sr. Leaders based on their
business experience, business environment scanning and performance results. Employees
participate through suggestion box and expert’s opinion on business risks is also sought.
Internal audit reports identifying control weaknesses and strategic challenges are also used.
Risk Identification
Risk Analysis
Risk Evaluation &
Scoring
Risk Mitigation
Risk Treatment & Monitoring
Risk
Management
Process
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2. Identified enterprise risks need to be evaluated on criteria of Impact, Probability, and
Velocity with a mechanism to value the risks on standard parameters that should facilitate
ranking of enterprise risks for devoting focus and resources towards critical risks
3. Based on the risks identified and evaluated, a decision has to be taken for risk treatment. A
decision on Accept, Treat and Transfer is taken for every enterprise risk. Having decided to
treat the risk, a mitigation plan needs to be finalized based on cost-benefit analysis. Selected
mitigation measures are tracked for its implementation and achieving the desired outcome in
terms of time and benefit. While developing a risk mitigation plan, a risk indicator/is identified
to track movement in enterprise risk.
4. Each Risk Owner, Functional Head monitors movement in enterprise risk and its mitigation
plans. Monthly reports are made, and appropriate steps are taken for correction and
improvement.
5. The monitoring and reporting of enterprise risks and the status of mitigation plans helps us
to understand trends in various risks, importance to be given to various mitigation measures,
etc. Review by Functional Committee followed by Sr. Leadership committee helps to identify
focus areas and mitigation plans to be worked on to drive the positive trends in enterprise-level
risks.
2.3. Sensitivity Analysis and Stress Testing
To ensure effective risk management ATL conducts risk assessments in the form of Sensitivity
Analysis and Stress Testing to proactively capture potential risks that could generate significant
impact to the business as well as to assess the health of the organisation in terms of financial
risks, market risk etc.
In this context, in FY19-20, ATL has performed Sensitivity Analysis and Stress Testing to
identify, analyse and manage the following enterprise risks,
1. Financial Risks including Credit Risk and Liquidity Risk
2. Market risk including Interest Rate risk and Foreign Currency risk
3. For determination of defined employee benefit obligation
In addition, Sensitivity Analysis is conducted to identify and assess the climate change related
risks inherent in ATL’s operations. The organisation has adopted a climate scenario-based
analysis technique using IPCC’s RCP 4.5 (medium emission) and RCP 6.0 (high emission)
pathways (equivalent to 1.7-3.2℃) to assess its operating sites’ climate change related
projected risks and impacts. The climate change issues including Projected change in Monthly
maximum temperature, Monthly rainfall, Severe drought likelihood, and Land projected to be
below annual sea level were studied in this scenario analysis. The climate projections were
carried out for medium-term i.e., for a period covering 2020-2039. Climate Change risk
assessment is covered in more detail under the Climate Change section of this report.
Sensitivity Analysis is also conducted to analyse the baseline Water Stress level and Drought
Risk Level at ATL’s operating sites. This study is conducted using WRI’s Aqueduct tool and
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India Water Tool to understand the future change in water availability as well as to device
appropriate water conservation measures. The Drought Risk Level is studied as a part of
climate scenario-based analysis to analyse the likelihood, frequency and severity of drought
occurrences in ATL’s operating sites and to implement mitigation strategies including
rainwater harvesting to recharge aquifers. Water risk is covered in more detail under the Water
Risk section of this report.
Details of Sensitivity Analysis are available at ATL Annual Report 2019-20.
2.4. Risk Culture
Creating a strong risk culture that enables an internal environment that is risk aware, more
resilient to external influence and better able to adapt is paramount to ATL’s risk management
system. The company strives to create an internal environment where all employees have a
clear understanding of the importance of risk management. This purpose is achieved through
the establishment of the business unit-wise Functional Risk Committees, with members from
cross functional teams, that enables risk awareness among employees at unit level as well as
holistic approach towards risk assessment.
Continuous improvement of risk management is ensured by conducting monthly Cross-
Functional Risk Committee meetings for risk identification, assessment and monitoring as well
as to effectively review the risk management practices established. A report of the prioritized
risk and any feedback is provided to the Management Risk Committee (MRC).
2.5. Audit Management
Auditors are appointed for a fixed five-year term and are rotated every five years in accordance
with the regulations of Companies Act 2013. In the reporting period FY 19-20, the non-auditing
fees to the auditing agency exceeds the auditing fees.
In addition, all auditing activities of ATL are in adherence to the AICPA Auditing and
Accounting standards norms.
3.Code of Conduct
ATL has adopted a Code of Conduct for its Directors and Senior management, which lays
down the principles and standards that should govern the actions of the company and its
employees. The Code of Conduct expects all the members of the company to act in accordance
with the highest standards of personal and professional integrity, honesty and ethical conduct.
The Company Secretary of ATL directly oversees the strict compliance to the Code of Conduct
as well as reviews the effectiveness of the Code. Suspected and reported violations of the code
is appropriately investigated and action is taken by the Chairman of the Board or the Chairman
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of the Audit Committee ensuring boards oversight on Code of Conduct along with Ethical
issues.
Further, to review the compliance with the Code of Conduct, the members of the Board and
the Senior Management shall affirm the compliance with the code annually based on which an
Annual compliance report is prepared and evaluated by the Company Secretary to review the
effectiveness of ATL’s Code of Conduct.
The company has adopted a whistle blower policy and has established the necessary vigil
mechanism for employees and directors to report concerns about unethical behaviour, in
accordance to the provisions of the Companies Act, 2013 and SEBI Regulations. The policy
enables the employees to report about potentially illegal and/ or unacceptable practices without
fear of victimisation and reprisal. It aims to guide good governance practices and to ensure that
concerns are properly raised and addressed. The Vigilance and Ethics officer is responsible for
monitoring the effectiveness of the policy and dealing with concerns raised and reports filed.
To make more effective and controlled mechanism, employees can lodge a Protected
Disclosure to the Chairman’s Office by sending an email to [email protected].
Further, to address the concerns of the external stakeholders and members of the public, email
IDs of senior management is made available in public domain. ATL’s Annual Report of FY
19-20 includes the emails IDs of Company Secretary (E-mail ID: [email protected])
and Chief Sustainability Officer (E-mail ID: [email protected].) for this purpose.
In the reporting period FY 19-20, no breaches have occurred with respect ATL’s Code of
Conduct.
4. Preventing Corruption and Bribery
ATL is committed to conduct its business responsibly by ensuring ethical practices,
transparency and accountability across its value chain. As the organisation engages with a wide
range of business partners, it is our duty to ensure that ATL’ people and the third parties, who
act on our behalf, demonstrate high ethical standards and compliance with all applicable laws.
ATL’s Anti-corruption and Anti-Bribery Policy states the company’s zero tolerance towards
corruption and the payment or receipt of bribes for any purpose. It outlines how the organisation
defines bribery and corruption and its position on political/charitable contributions, facilitation
payments, gifts and hospitality.
To have a robust system in place, the Anti-corruption and Anti-Bribery clause is incorporated
as a part of the Employee Code of Conduct, Supplier code of Conduct and the Code of Conduct
for Board of Directors and Senior Management of the company. The Code of Conduct for the
Board and the Senior Management strictly prohibits all Directors, members of Senior
Management and their immediate families from accepting any payments or gifts from persons
or firms the company deals with.
22
The Code and Conduct for employees have an explicit statement on prohibition of bribery and
corruption. The Anti-Corruption and Bribery is clearly communicated to all employees of ATL
via their appointment letter, code of conduct and by displaying the policy on the company’s
employee portal. Further, to ensure compliance, all employees are trained on the Anti-
Corruption & Anti-Bribery policy as well as the Code of Conduct at the time of their induction
and annually thereafter. ATL’s annual online mandatory training on the zero-tolerance policy
ensures that employees are able to recognise, avoid, raise concerns and report any potential
instances of bribery or corruption. The managers at all levels are responsible for training of the
employees on the Anti-Corruption and Bribery Policy.
In order to ensure that the business partners also practice the same high ethical standards as of
ATL, the Anti-Corruption and Anti-Bribery Policy is clearly communicated to our contractors,
suppliers and other third parties through ATL’s supplier code of conduct and the vendor
agreements. According to the Supplier Code of Conduct, all of ATL’s suppliers shall refrain
from offering or accepting any undue payment or other considerations either directly or
indirectly.
It is also one of the key elements in ATL’s Supplier Risk Assessment. As a part of supplier
evaluation, ATL checks their policies on Bribery, Corruption and Whistle Blowing prior to the
business agreement.
To ensure thorough compliance to Anti-Corruption and Bribery Policy and regulations, ATL
has made zero political contribution in the reporting period. As per the policy of the company,
any political contribution goes through the approval of the Board and as per the applicable
regulation in India, company disclose the information as per Companies Act 2013 if any
political contribution is made.
4.1. Vigil Mechanism/Whistle Blower Policy
ATL has an established Whistle Blower Policy and Vigil Mechanism in place in accordance to
the provisions of the Companies Act, 2013 and SEBI Regulations. The policy and mechanism
enable the employees to report about potentially illegal and/ or unacceptable practices without
fear of victimisation and reprisal. It aims to guide good governance practices and to ensure that
concerns are properly raised and addressed.
Any concerns related to Anti-Corruption and Bribery policy or suspicions of malpractice are
to be reported as per the Vigil Mechanism/Whistle Blower Policy. Accordingly, the concerns
and suspicions of violation can be reported to managers of all levels and Vigilance and Ethics
officer. The Vigilance and Ethics officer is responsible for monitoring the effectiveness of the
policy and dealing with concerns raised and reports filed. Managers at all levels are responsible
for ensuring that those reporting to them are made aware of and understand this policy,
undertake training on how to implement and adhere to it and also monitor compliance. To make
more effective and controlled mechanism, employees can lodge a Protected Disclosure to the
Chairman’s Office by sending an email to [email protected].
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As specified in the Anti-Corruption and Bribery Policy, as part of ATL’s organisational-level
risk identification and management process, all businesses undertake bribery and corruption
risk assessment periodically, to understand the risks it faces and to ensure that it has adequate
procedures in place to address those risks. The risk assessment is documented, periodically
reviewed and the Board of ATL is updated on a half yearly basis in accordance with applicable
regulations.
In FY 2019-20, no violation of Anti-Corruption and Bribery policy was reported.
5. Public Policy
ATL did not make any contributions to and spending for political campaigns, political
organizations, lobbyists or lobbying organizations, trade associations and other tax-exempt
groups in the reporting period to influence public policy.
6. Responsible Working Practices
Employees are the backbone of ATL’s business and operational excellence. The organisation
respects and values its employees at all levels, encourages diversity, fosters a healthy and safe
working environment that supports professional as well as personal development and a long-
term career growth.
6.1. Protecting Human Rights across value chain
ATL remains committed in supporting and practicing high standards of labour conditions and
human rights in all its operations while conducting business responsibly and with integrity.
ATL’s Human Rights policy and Code of Conduct are based on the framework of the
International Bill of Human Rights and the International Labour Organization’s Declaration of
Fundamental Principles and Rights at Work. Further, to ensure strict adherence and respect for
human rights in its operations, Human Rights issues are also addressed in the Corporate
Sustainability Policy, the effective implementation of these policies is taken care by the CSR
and Sustainability Committee of the Board.
The Dahanu Thermal Power Station of ATL is certified by the social accountability standard
SA8000. All other entities of ATL are currently in the process of implementing systems and
procedures according to the requirement of SA8000 certification.
6.1.1. Communication and Training for Employees
ATL is highly committed to implement highest standards of human rights in its corporate
practice, to achieve this the organization strictly adheres to human rights expectations of the
organisation by clearly communicating the same to all employees and contract workers. Human
rights clauses are part of the employee code of conduct as also employee offer letters and is
regularly communicated via company emails and notices.
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All employees and staff of ATL are trained on the Human Rights Policy established at the time
of induction. Awareness sessions on human rights and associated laws, along with workshops
that include awareness on reporting human rights violation are organized periodically by
utilising the company’s grievance redressal mechanism. In addition, all female employees of
ATL are trained by the POSH committee on the rules and reporting process of Prevention of
Sexual Harassment (POSH) act at workplace. Also, the company have mandated all employee
to complete training on all HR related policy and POSH, the same is supported through digital
platform and online training modules through evidyalaya. Behavioural trainings are conducted
for the entire workforce of ATL each year, which includes topics on practicing Ethics, Integrity,
Human Right, Anti-Corruption, Ethical standards etc. During the reporting period, a total of
34,186 man-hours were spent on Behavioural trainings.
Further, as part of SA8000 in-house trainings have been conducted for all employees of Dahanu
Thermal Power Station, covering various aspects of human rights.
6.1.2. Supplier Screening and Evaluation
ATL’s Supplier Screening and Risk Assessment framework has a comprehensive Supplier Risk
Score Card which is utilised to evaluate the processes and performance of all suppliers under
consideration against several ESG parameters. All of ATL’s suppliers are screened using this
score card. The following are the social criteria evaluated for all suppliers as part of the risk
assessment score card,
• Human Rights Policy
• POSH
• Child Labour Policy
• Social Accountability Certification
• Medical fitness
• Compensation Policy
• Compliance to laws governing child labour, minimum wage etc.
• Labour Policy
• Community Relations
Further, to ensure compliance to the supplier code of conduct, random supplier audits are
conducted by an ATL expert annually, as part of SA8000 certification. This is currently
practiced at the Dahanu Thermal Power Station of ATL and will be adopted by all other entities
as part of the certification pursuance.
6.1.3. Human Rights Risk Assessment
As part of the Social Accountability Standard certification being pursued by ATL, annual
internal audits and continuous workplace monitoring activities are to be carried out to ensure
strict adherence to policy, identify any violations and to take necessary actions.
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In the Dahanu Thermal Power Station of ATL, in accordance to SA8000 certification, periodic
Social Accountability Risk Assessment to identify and prioritise the area of actual or potential
non-conformance to the standard needs to be carried out. The comprehensive list of human
rights risks assessed are as follows,
1. Engagement of child labour
2. Engagement of child labour by suppliers and sub-contractors
3. Engagement of forced labour
4. Non-compliance of EHS guideline
5. Corporal punishment, mental or physical coercion or verbal abuse of personnel
6. Exceeding of working hours
7. Working without giving weekly off
8. Less wage paid
9. Overtime wages not paid in premium rate
10. Discrimination in workplace
Currently, this risk assessment process is only conducted by Dahanu Thermal Power Station
of ATL and will be adopted by all other entities as part of the certification pursuance in the
future.
6.1.4. Child Rights
ATL has established a procedure to ensure no child labour and adolescent labour is employed
in its operations as part of SA8000 requirements and Corporate Policies. During the time of
employment all candidates’ age proof is thoroughly checked before onboarding. No violations
of children rights have been reported in the current reporting period. However, in the unlikely
event that a person classified as a ‘child’ does get employed, the organisation will take complete
responsibility and remedial action to enable such children to attend and remain in school.
Further, ATL has established a Grievance Redressal Mechanism which enables all the
employees to report any violations in human rights. The engineers on site responsible for the
allocation of the day-to-day responsibilities and the employees are trained on the Grievance
Redressal Mechanism reporting procedure.
No human rights violations have been recorded in the current reporting period.
6.1.5. Working Hours and Remuneration
ATL provides fair wages and compensation to all its employees as per the legal and industry
standards covering the basic needs of workers and their families to maintain a reasonable
standard of living. The minimum wage paid by ATL is above the legally mandated minimum
wage and nearer to living wage. The organisation strictly adheres to its remuneration policy
and amends it as and when required. ATL also addresses the concerns if any, through dialogue
and collective bargaining.
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ATL practices the industry standard working hours for all its employees and contract workers
as per regulations. To ensure strict compliance with working hours the organisation supports
the use of ATL’s attendance system which is in force for all employee categories.
In event of any emergency necessitating an employee to work additional hours the organisation
ensures that it does not exceed the stipulated hours under the relevant specified act. The
organisation always remunerates the employees as per the provision of Maharashtra Factories
Rule 1963 if required to work additional hours.
6.1.6. Freedom of Association and Collective Bargaining
ATL respects its employees’ rights to Freedom of Association and Collective Bargaining as
per the provisions of ILO. Accordingly, 25.55% of ATL’s employees are represented by trade
union or covered by collective bargaining agreements.
6.2. Fostering a Diverse and Inclusive Workforce
ATL is committed to promote Diversity and Inclusion amongst its workforce. It believes that
a diverse workforce comprised of individuals of varying gender, religion, race, ethnicity, and
education provides a plethora of benefits at the workplace including new perspectives,
innovation, better employee performance, and increased profits as well.
ATL's Code of Conduct promotes equal opportunities effective beyond gender diversity and
under no circumstances accepts any form of discrimination in the workplace on grounds of age,
race, gender, religion, political opinion, nationality, sexual orientation, social background or
disability.
6.2.1. Gender Diversity
ATL actively promotes equal treatment and opportunities between men and women in its
working environment. In FY 2019-20, 4.98% of the total workforce at ATL were women,
9.81% of whom held top management positions and 12.77% were junior management
positions. In addition, 4.1% of the new hires were women.
Through our Saksham program which is a skill development program to improve the quality
of life of women segment of society, especially those who are economically deprived. ATL has
adopted this to create deep impact on the society considering that there are a smaller number
of women in the workforce of the company.
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Percentage of Women in workforce FY 2019-20
Female share of total workforce 4.98%
Females in all management positions,
including junior, middle and senior
management
10.76%
Junior Management Positions 12.77%
Top Management Positions 9.81%
Gender equality is nurtured at ATL by practicing Gender Pay Parity at all levels of employment
within its workforce. We follow a salary band system for various level of positions, and we
ensure both female and male paid within the salary band and not based on gender the average
salary band for various level as follows,
Employee Level Average Female
Salary (Rs.)
Average Male Salary
(Rs.)
Pay Ratio
Executive level
(Base salary only)
9500000 9500000 1
Management level
(base salary only)
5500000 5500000 1
Management level
(base salary + other
cash incentives)
5500000 5500000 1
Non-management
level
2000000 2000000 1
6.2.2. Inclusion of people with disabilities
ATL strives to create an inclusive working environment that is disabled friendly. All operations
of ATL have wheelchair access, toilets are designed keeping in mind the needs of the disabled
and elderly.
6.3. Employee Engagement
Employee engagement and active participation is critical to ATL’s business to continuously
improve the work culture and to enhance the day-to-day experience of employees. The
company has conducted multiple employee engagement interventions in FY 2019-20.
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6.3.1. Employee Engagement Trends
To assess the effectiveness of employee engagement programs and to measure the level of
engagement achieved, ATL conducts an annual employee engagement survey based on the
Global Standards of Q 12 suggested by Gallup. The Company has adopted the Brukes
Employee Engagement 6 Dimensions Index approach to measure its employee engagement.
To assess the level of engagement influenced the engagement survey is structured based on 5-
point scale system. ATL had set a target for FY 2019-20 to enhancing employee active
engagement by 77%. The performance against this target is as follows,
Employee engagement FY 2019-20
% of actively engaged
employees
75.07%
% of total employees
covered
84.33%
The participation rate was over 85%. The survey score was approximately 75%, which is the
average engagement score for this survey. The score was above 3.95 on a scale of 1 to 5, which
surpassed 62 percentiles for a first-time company. With a engage-disengage ratio that is higher
than the global benchmark, ATL’s result demonstrates favourably engaged workforce.
As a result of the survey, two additional employee engagement interventions were identified
and implemented at organisational level to address bottom three parameter and the other at
manager level to focus on gaps.
ATL has adopted standard industrial practices with respect to workplace environment, rest
periods, maternity protection, occupational health & safety, disciplinary and dismissal
practices, compensation, working time, and welfare matters like safe drinking water, canteens,
crèche, and access to medical services.
7. Enabling a Safe and Healthy workplace
Providing a safe and healthy working environment to all employees and contract workers is
paramount to ATL. The organisation believes that a safe workplace instils a sense of security
and confidence among its workforce which has the potential to significantly enhance its
productivity. ATL strives to create a mature safety culture across its operations and a
behavioural change among employees by engaging the total workforce in safety related
conversations and activities throughout the year.
By means of such initiatives ATL is working towards realising its goal of “No Fatality, No
Injuries and No excuses”
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7.1. Safety for Our Community
“#Safety Culture” is a trending coined by Sh. Anil Sardana, CEO and MD, ATL and Safety
Group Service Head. It is aimed at developing and driving Programs on Safety to inculcate
mass awareness on various Safety themes for the community where we operate. Various
programs under this trending was conducted such as.
1. Safety Symposium & Exhibition during Sep 2020 through CII.
2. Road Safety Week 2021 celebration and awareness drive.
3. National Safety Week 2021 celebration and awareness drive.
Also, ATL has adopted S+5S to create safety and cleanliness awareness to the younger
generation in the tender age. In India, maximum number of fatalities happened due to road
accidents, and seconded by accidents due to electricity. To reduce the number of fatalities and
accidents due to electricity in the country, it is important to inculcate the safety behaviour in
the population.
7.2. Occupational Health and Safety Management
To ensure high standards of Occupational Health and Safety performance, ATL has
implemented ISO 45001:2018 certified Safety Management System across its projects and
O&M as a part of its Integrated Management System, to identify and manage hazards, risks
and emergencies. Policies and procedures adopted and established by ATL which governs the
organisations Health and Safety practices are,
• Safety Code of Conduct
• Corporate Sustainability Policy
• Organization Health and Safety Policy
The CSR and Sustainability committee of the Board oversees the Occupational Health and
Safety performance, as a part of the Sustainability policy, to monitor the effectiveness of the
management system execution and provide data assurance.
7.2.1. Incident Reporting and Investigation
ATL has adopted a group-wide ADANI Safety Standard for Incident Reporting and
Investigation to examine all safety incidents in order to learn from incidents and prevent
reoccurrence. The Safety Incident Reporting, Classification, and Investigation Standard sets
the mandatory, minimum safety requirements of the organisation and has been upheld as Life
Saving Safety Rules.
The incident investigation process contributes to the continuous improvement of Safety
systems and performance by:
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• Identifying and implementing actions to prevent incident recurrence.
• Promoting an atmosphere of openness by improving communications and understanding
about the incident.
• Providing input to the development and improvement of Safety policies, procedures,
guidelines, and standards.
• Identifying and appreciating good actions taken by people, which contributed to reducing the
consequence.
Under the safety standard, the incidents are classified into 5 categories based on the degree of
severity/potential for injury/damage. Each category has defined incident reporting and
investigation procedure established. In line with this, all incidents reported in ATL are
categorised and appropriate detailed investigation is carried out by an experienced cross
functional team.
The OHS committee of each site provides training to site supervisors and relevant employees
on incident response and reporting as per the safety standard.
General Incident Reporting and Investigation Flow
In the current reporting period, ATL recorded 43 lost time incidents and one fatality incident.
All reported incidents were investigated as per the procedure outlined by the Incident Reporting
and Investigation Safety Standard of the group and the immediate cause and root cause were
identified and studied. Based on the incident investigation findings various corrective and
preventive actions were implemented. In the current reporting period, the following incident
response investigations were carried out,
• Establishing SOP for halting of tower erection
Initial Response by site supervisors
First Information Report (FIR)
Reporting into group safety tool
Determining Key Factors, Systems that need to be improved
Forming Investigation Team
Circulation of AlertRecommending Corrective and
Preventive Actions
Doumentation of finding and
communication of Learning
Establishing a follow-up system
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• Electric connections were ensured through 30mA ELCB,
• Old generation hydra is banned,
• 360-degree swivel coupling between tractor and trolley and
• Use of FRP Ladder across all sub-station.
7.2.2. OHS Risk Assessment
ATL employs a HIRA based risk assessment methodology and a safety checklist to assess the
safety parameters of its operations. Accordingly, the organisation conducts regular risk
assessment audits in its operational and construction sites.
The HIRA based risk assessment methodology and checklist is also employed as part of the
OHS due diligence for acquiring of assets.
7.2.3. #Safety Culture
In order to institute a mature safety culture across its operations, ATL endeavours to achieve
active employee involvement, that encourages them to voice their concerns, report any safety
gaps and suggest opportunities for improvement. In line with this, the OHS committees of
ATL’s operations practice a bottom-approach with equal employee representation. Each OHS
committee constitutes of a labour union representative, a site safety representative, a site health
team representative and a management representative. The OHS meetings are conducted on a
monthly basis. Further, contractor participation is ensured at site level contractor safety
committee meetings. ATL has also established a Contractor Safety Management Task Force
for the upliftment of contractor safety and work culture.
All ATL employees are provided training on Occupational Health and Safety at the time of
induction and on a regular basis thereafter. Employees are trained to identify the Near miss,
Unsafe condition, Unsafe act and to report injuries occurred in the workplace. In the current
reporting period, ATL achieved 57,236 Man-Hours of Safety Training.
In addition, ATL ensures the participation of its total workforce in the Health and Safety related
topic discussions through activities such as Safe Connect (Monthly conference call on safety),
Safe Eye (Monthly safety observation quiz) and mock drills throughout the calendar year.
7.2.4. Safety Targets and Performance
ATL has adopted a group-wide year-on-year safety target to achieve Zero Incidence in its
operations. Against this target in the current reporting period, ATL has witnessed 43 lost time
incidents and one fatality incident. ATL recorded a Lost Time Injury Frequency Rate (LTIFR)
of 1.41 per million hours worked covering all its employees. The LTIFR has decreased by
32.8% when compared to the previous financial year.
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Safety Performance
LTFIR (nos/million hours
worked)
FY 2019-20 FY 2018-19
Employees 1.41 2.1
% of employees covered 100 100
In addition, in the current reporting period, ATL has set a target to effectively prevent incidents
by virtue of proactive identification of unsafe conditions with hazard potential. The target is to
identify at least 2 near misses/concerns per employee per month. This accounts to a yearly
target of identifying of at least 49794 near misses/concerns.
7.2.5. Health
As part of the organisation’s Health and Safety strategy, ATL conducts regular health check -
ups for its employees in all its operating sites. The health checks cover 100% of the workforce
and focuses on general health of employees. ATL also conducts general health awareness
programs in all sites covering various global health issues related topic.
In the current reporting period, to combat the spread of COVID-19 pandemic, ATL has
conducted awareness sessions on COVID-19 prevention measures for all employees.
Further, through the company’s Health specific CSR programs, ATL is conducting health
camps and contributed Mobile Health Units (MHUs) for the community that it operates in.
8. Energy Consumption
In FY 2019-20, ATL has consumed 42452 MWh of energy, out of which 5.4% was consumed
from renewable energy sources. ATL has set the following targets to increase the percentage
of energy consumption from renewable energy sources
• 30% renewable energy power procurement for the distribution business by FY22 and
50% by FY25
• 100% auxiliary consumption from renewable sources in transmission business
• Installation of renewable generation capacity ability.
Energy Performance
Source of energy
consumption
FY 2019-20 FY 2018-19
Energy Consumption from
Non-Renewable fuels
7,681,288 MWh 11,101,470 MWh
Non-renewable electricity
purchased
25,798 MWh 27,870 MWh
Renewable energy
purchased/generated
2,732 MWh 2,613 MWh
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Total non-renewable energy
sold
3,026,693 MWh 3,241,000 MWh
Total Non-Renewable
Energy Consumption
4,680,393 MWh 7,888,340 MWh
9. Climate Action
ATL embraces its responsibility not only to power the communities but also to address risks
posed by climate change to its business and operations. As a transmission and distribution
company, ATL’s business is exposed to both physical and transition risk due to climate change.
Therefore, it is critical to take into consideration emerging climate change conditions and its
impact while deciding specific geography, design, construction, operation, and maintenance of
existing infrastructure, new infrastructure, and an effective future policy to tackle challenges
posed by climate.
Being a responsible corporate citizen, ATL recognises its pivotal role in creating a low-carbon
and sustainable economy without compromising collective and holistic growth aspirations.
Therefore, the organisation has become a signatory to the “Declaration of Private Sector on
Climate Change”, pledging to take climate actions to contribute to India’s NDC goals and drive
the country towards achievement of set targets under the Paris Agreement.
Build Resilient Infrastructure - Our goal is to establish stronger transmission networks within
each system and stronger interconnections between systems. To achieve the same out of
various approached during design stage one of our design practices are such that we evaluate
all conditional aspects like wind zones, seismic zones, soil resistivity, water properties,
hydrological assessment, and various other environmental factors. By virtue of this, our towers
hold the capacity to withstand a range of contingencies and adverse conditions.
The Company has taken appropriate insurance for all assets against foreseeable perils. The cost
of repairing and restoring our assets due to any damage caused due to unforeseen conditions
including risk due to climate change are covered under the insurance, this protect the interest
of stakeholders from climate change risk.
9.1. Governance
9.1.1. Board Committee Oversight
ATL’s Board of directors understand the importance of climate change issues, as well as their
significance to its business and its stakeholders. It also recognises as the potential impact and
opportunities climate change could create for the group’s generating and operating
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Given the significance of risks and opportunities posed by climate change on ATL’s business,
including physical, regulatory and market related issues, the Board and its committees are all
actively involved in oversight of climate change issues.
ATL’s Board committees including the Corporate Social Responsibility, Sustainability
committee and the Audit and Risk Management Committee is informed of the identification
of climate risks within the Risk Mangement framework, sustainability policy and management
systems and monitoring results depicting the effectiveness of the management systems as also
the data assurance. The climate-related issues of ATL are addressed by Corporate
Sustainability Policy and the policy deployment is reported to the Board.
9.1.2. Compensation
The Board of Directors has delegated the responsibility for extra-financial disclosures to the
CEO. All strategic and operational responsibilities, including climate change related issues,
sustainability performance, and value creation, are executed by the CEO of ATL.
Corporate action in response to climate change related issues and achievement of the set targets
including implementation of energy efficiency measures is part of the CEO’s key result areas
(KRA) in ATL. In line with the KRA, climate change and sustainability related performance-
based incentives are incorporated in the top management’s compensations plans. In addition,
senior executives including plant heads, energy managers and station heads also have their
remuneration linked to climate change and sustainability related performance-based incentives.
9.2. Climate Change Risk Management Framework
At ATL climate-related risk and opportunities are identified and assessed under two processes
a) Health, Safety, and Environment Management System b) Enterprise Risk Management.
ATL has an established Risk Management framework constituted under the Management Risk
Committee which assesses, manages, and reports on all significant risks, the impact on the
business and mitigation measures. This provides a framework to manage risks while achieving
strategic and operational objectives and continuing to meet the needs of ATLs customers. The
Risk Management Team guided by the Chief Risk Officer is implemented across the company
to enable all employees and business associates to raise any risk identified by them to the next
level. In addition, ATL’s risk management framework is based on COSO (The Committee of
Sponsoring Organizations of the Treadway Commission) framework.
Demonstrating ATL’s commitment to addressing and managing climate change, the
organisation has integrated climate change risks including physical and transition risk as part
of the organisation’s established Risk Management framework. Therefore, as already
mentioned, the climate change related risks are directly overseen by the Audit and Risk
committee of the Board.
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9.3. Strategy
To address the challenges and minimise the impact of climate change in its operations, ATL
has adopted both adaptation and mitigation strategies. ATL’s strategy is to initially evaluate
the impact of climate change on its business and operations in order to adapt its systems to be
more flexible and resilient. Post the impact evaluation, reduce the organisation’s contribution
to climate change by minimising its greenhouse gas emissions by increasing ATL’s percentage
share of renewable energy generation and transmission, actively investing and implementing
energy efficiency measures and pursuing water stewardship.
9.3.1. Key aspects of ATL’s strategy
• Integrating climate considerations into key business decision-making and managing
related risks through ATL’s corporate enterprise risk management system
• Taking an active and constructive role on new climate change policy solutions with
governments, industry associations, environmental organisations, and communities
• Improving emission intensities and operational efficiency at all ATL’s facilities
• Tracking and reporting efforts to increase RE share and reduce energy consumption.
Climate Change Strategy
Adaptation
Building Resilient Infrastructure
Achieve Operational Excellence
Implementation of Energy efficiency
Initiatives
Mitigation
Reducing opertional GHG
emissions
Increasing share of renewable energy
Conservation of resources
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9.4. Climate Change Risk Assessment
As a transmission and distribution company, ATL’s business is exposed to both physical and
transition risks of climate change.
9.4.1. Scenario Analysis
To identify and assess the climate change related risks inherent in ATL’s operations, the
organisation has adopted a climate scenario-based analysis technique. ATL has employed
IPCC’s RCP 4.5 (medium emission) and RCP 6.0 (high emission) pathways (equivalent to 1.7-
3.2℃) to assess its operating site risks and impacts. The climate change issues including
Projected change in Monthly maximum temperature, Monthly rainfall, Severe drought
likelihood, and Land projected to be below annual sea level were studied in this scenario
analysis. The climate projections were carried out for medium-term i.e., for a period covering
2020-2039.
9.4.2. Physical Risk
Physical risks resulting from climate change can be event-driven (acute risks), including
increased severity of extreme weather conditions such as cyclones, hurricanes, floods, etc. or
longer-term shifts (chronic risks) in climate patterns that may cause a change in wind pattern,
hydrological flows, sea-level rise, etc. Physical risks have the potential to impact the
organisation directly damages to assets and indirectly by disruption to the supply chain.
Acute Risk - According to the scenario-based climate risk assessment conducted, it is
identified that ATL’s assets including Rajasthan, Gujarat, Maharashtra, Bihar, Madhya
Pradesh, Haryana, Uttar Pradesh, Chhattisgarh and Jharkhand are prone to acute physical risks
such as flooding, cyclones and earthquakes.
Chronic Risk – Projected increase in temperature dur to climate change can significantly
impact the transmission and distribution networks efficiency and reliability of networks due to
energy losses.
The projected physical risks could significantly damage the ATL’s transmission infrastructure
and impact the grid efficiency.
Although no significant climate change impacts are recorded at present, to address worst-case
scenario and the findings of ATL’s climate projections the sites mentioned above are classified
as critical and appropriate risk management measures are in place.
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Adaptation and Mitigation Measures to address Climate Related Physical Risks
• Building Resilient Infrastructures
ATL constantly strives to establish stronger transmission networks within each system and
stronger interconnections between systems by employing robust tower designs to withstand
extreme weather events. ATL’s infrastructure design practices proactively evaluate all
conditional aspects like wind zones, seismic zones, soil resistivity, water properties,
hydrological assessment, and various other environmental factors. By virtue of this, ATL’s
towers hold the capacity to withstand a range of contingencies and adverse conditions.
• Achieve Operational Excellence
One of the most significant impacts of high temperatures on the transmission and
distribution networks is loss of efficiency and reliability of networks due to energy losses.
ATL endeavours to minimise its energy losses by modernising transmission and
distribution networks and thus achieve excellence in operation.
• Emergency Restoration System (ERS)
ATL’s operational resilience rests on its ability to rapidly recover after an extreme weather
event. Rapid recovery following a transmission or distribution network collapse requires
inspection and replacement or repair of damaged system components. Currently, ATL has
two ERS sets in the central part and one ERS set in the western part of country.
9.4.3. Transition Risks
Transition risks and opportunities created by climate change are driven by shifts in policy,
legal, market, and technology, to address mitigation and adaptation requirements associated
with a low-carbon economy. In this context, ATL has considered the following transition risks
that could significantly impact its business,
Transition Risk Risk Opportunity
Policy and
Regulatory risks
• Pricing of GHG emissions
such as imposing carbon tax
• Enhanced GHG emissions
limiting and reporting
obligations
• Enhanced mandates on
renewable energy share.
• Reducing organisations GHG
emission intensity
• Maximise RE integration
• Implementing energy efficiency
initiatives
Technological
Risk
Shift to low carbon technologies Enhancing renewable power
capacity
38
Market Risk - • Access to new and
emerging markets through
renewable energy mix in
distribution business
• Supporting customers by
facilitating rooftop solar
• EV charging services
9.5. ATL’s Climate Change Mitigation Measures
9.5.1. Reduction of GHG emissions
The GHG footprint of ATL in the reporting period FY 19-20 is 31,87,007.68 tCO2e of Scope
1 emissions and 21,155.04 tCO2e of Scope 2 emissions and 93,796.62 tCO2e of Scope 3
emissions. Currently, the Scope 3 emissions has been accounted for only 3 categories as per
GHG Protocol that is emissions from Employee Commute, Business Travel and contractor
vehicle for transporting material and running machinery. ATL endeavours to report on more
categories of Scope 3 emissions in the coming years.
Direct and Indirect GHG emissions
Scope Unit FY 20 FY 19
Scope 1 tCO2e 31,87,007.68 34,46,189.13
Scope 2 tCO2e 21,155.04 24,078.59
In the current reporting period, ATL has set a target to reduce its greenhouse gas (GHG)
emission intensity (on per ₹ revenue generation) 40-45% by 2023-24 against India’s
National Determined Contribution (NDC).
In line with the target, ATL has disclosed its baseline carbon intensity at 4.58 tCO2e/ lakh ₹
revenue generated in 2018-19 as baseline, As part of the Integrated Annual Report 2019-20
and its first CDP Response in 2020. In the current reporting period, the carbon intensity stood
at 2.74 tCO2e which denotes that ATL has achieved 95% of the target set for FY 23-24 in the
current financial year.
The reduction of GHG emissions achieved is mainly owed to the increase in renewable energy
share and investment in energy efficiency initiatives in the current reporting period as discussed
below.
9.5.2. Maximise Renewable Energy Integration
While climate change poses risk to electric utilities, there are distinct opportunities provided
by the potential carbon pathways for GHG emission reductions. Clean energy integration in
electric networks achieves overall emission reductions and eventually becomes cost-effective
39
for customers. In this context, ATL has set the following targets to increase the share of
renewable energy mix in its operations,
Renewable Energy Target Performance in FY 2019-20
30% renewable energy power procurement
for the distribution business by FY22 and
50% by FY25
• 3% of renewable energy power
procurement from grid
• AEML has signed a PPA with a
hybrid (solar+wind) plant with 700
MW capacity for renewable power
procurement
100% auxiliary consumption from renewable
sources in transmission business
12.93% of power consumed from RE source
in transmission business for auxiliary power
at substation
Installation of renewable generation capacity Renewable power capacity installed: 1.84
MW
ATL has installed a 1.84 MW of solar rooftop capacity to reduce its contribution to climate
change. In the current reporting period, the solar rooftop plant has generated nearly 9,836.25
GJ of clean energy. Out of which ATL consumed 75.43% for business operations and the rest
24.57% was exported to the grid.
9.5.3. Energy Efficiency Programs
During the year, ATL implemented various energy-saving initiatives which helped the
company generate cost savings while reducing the overall impact on the environment. The
organisation has identified several opportunities to further reduce its environmental footprint,
which is planned to be taken up in a phased manner. During the year, the organisation made
various structural changes in its equipment used and replaced parts to plug leakages and reduce
inefficiencies. ATL reduced 45,718 MWH of energy consumption due to structural changes
and another 77.1 MWH due to LED light replacement. This translated to emission reduction
of 37,552 tCO2e.
In addition, with the goal of creating positive climate change impacts in the value chain of
ATL’s business, the organisation has announced a new scheme to provide energy saving ceiling
fans at a 25-30% subsidised cost for 50,000 residential customers in the Mumbai suburbs on a
first come first serve basis.
9.5.4. Carbon Sequestration
To further reduce its impact on climate change, ATL has adopted plantation activities for the
past many years in and around its operations to effectively influence carbon sequestration.
In the current reporting period, ATL planted nearly 41,137 trees in and around its operating
sites. Over the past 20 years, ATL has planted nearly 2,44,67,389 trees in its operations
40
covering 343.3 acres of area under plantation including Full grown forest between 10 to 20
years of age, Grass including 0.5meter subsurface root-system and Mangroves (around Age of
10 to 20 years) helping is in Carbon Sequestration.
In addition, ATL is currently in the process of developing an Internal Carbon Pricing
Mechanism based on its emission intensity. Further demonstrating its commitment to Climate
Change, ATL actively takes part in institutional mechanisms related to climate change. ATL
has participated for the first time in the CDP disclosure of climate change in the current
reporting period and is also a signatory of the Task Force on Climate Related Financial
Disclosures.
10. Biodiversity
ATL understands its role in helping reduce the global declines in biodiversity. As part of its
responsible approach, ATL works to: build partnerships and work constructively with
stakeholders; assess its impacts on key biodiversity issues and make decisions which take
account of these impacts. ATL strengthened its commitment of being a responsible corporate
citizen in the field of Biodiversity by adopting dedicated Biodiversity policy and becoming a
signatory to IBBI. As per the policy, ATL intends to become “Net Positive” in terms of
biodiversity.
In the current reporting period, an internal expert team of ATL assessed the impact of its
operations on Biodiversity in 25 of its substations. The result of the study indicated that there
are no significant impacts to biodiversity in those areas. The company is currently working
towards assessing and mapping biodiversity at its operating sites through third party experts,
to determine the level of biodiversity in the area and to identify the potential impacts of ATL’s
operations. The mapping and assessment of biodiversity at ATL’s locations is expected to be
completed by FY 2022.
ATL interacts with the environment in number of ways and its business is intricately linked
with the ecosystem around which it operates, including the forests, grasslands, and mangroves.
The organisation makes concerted efforts to ensure minimal impact on the environment,
generating least harm to biodiversity through its operations. ATL strictly follows the basic
principles of avoidance, minimisation, and mitigation in dealing with the environment and
biodiversity. It also focuses on avoiding all ecologically sensitive zones for its transmission
line routes, minimising impact on biodiversity by reducing its energy use and restoring habitat
by continuously monitoring the impact. For instance, the 765 kV Fatehgarh-Bhadla
transmission line of ATL, Rajasthan was passing through the Great Indian Bustard (GIB) Arc,
GIB is declared as a critical endangered category under the International Union for
Conservation of Nature (IUCN) and Schedule-1 species under the Wildlife Protection Act
1972. ATL has re-routed this line in consultation with forest authorities, which has led to an
increase in route length by 50%.
41
11. Water Risk
ATL gives utmost importance to sustainable water management and implementation of best
management practices to minimise total water consumption, maximise reuse and recycle, and
address site-specific water-related issues. As thermal power generation is a water-intensive
process, ATL focuses on responsible consumption through optimal utilisation and conservation
of water. Except for the power generation plant, all operating sites of the company are Sub-
Stations and Transmission lines that are not water-intensive locales or do not require water for
activity apart from domestic use. To ensure robust water management, conscious water
consumption, and water risk mitigation process, at ATL self-evaluation is conducted to assess
whether the operating locations are water-stressed areas using various tools such as WBCSD
Global Tool etc.
Water management is fully integrated into ATL’s Risk identification, assessment, and
management processes, which enables us to assess and prioritise all risks, including water. ATL
has a dedicated EHS corporate policy which also emphasizes conserving natural resources such
as water and a well-established Environmental management System. Water management
systems and procedures are well covered under the Environmental Management Plan which
helps in systematic monitoring, controlling, checking, adopting corrective actions, and tackle
water-related risks. The company also ensures systematic tracking and monitoring of water
availability. This is included in the organisation’s risk identification and management process
due to the relevance for its operations. ATL has a comprehensive database-monitoring system
at its facilities to collect data regarding water availability including withdrawals and discharges.
The collected data are compiled at the corporate office and published in the
Sustainability/Integrated Reports. WRI Aqueduct tool is used to assess water availability in the
area of operations and watershed level, to obtain information regarding which sites are operated
in water-stressed areas.
ATL has used the IPCC's RCP 4.5 scenario (equivalent to 1.7-3.2℃) analysis to study various
impacts such as a Projected change in Monthly maximum temperature, Monthly Precipitation,
Severe drought likelihood, and Land projected to be below annual flood level for Period:
Impacts projection during 2020-2039. Water stress analysis is conducted to redefine the present
approach towards water management and drought risk analysis is conducted to estimate the
future changes in water availability to formulate a proactive approach towards future needs
using the WRI - Aqueduct and India Water Tool. ATL had done Water Source Sustainability
Study for its power generation plant which addresses downstream impact assessment and
includes water management and conservation plan. All these identified low impacts are part of
the risk management and business continuity plans (BCP). The event-driven risks including
increased severity of extreme weather events, such as cyclones, hurricanes, or floods, etc. are
covered under the appropriate insurance policies. The scenario analysis allows identification
of operations in water-stressed areas and anticipate any potential water-related conflict as well
as the group of stakeholders that might be involved. Activities are carried out in collaboration
with the local water management authorities, State ground Water Board and Industrial Board
to adopt a shared water resources management strategy that also considers the needs of local
communities.
42
ATL’s legal department assesses the implications of current and upcoming water regulatory
frameworks, which monitor international, national, regional, and local legal requirements that
might become applicable to its operations. All the facilities carry out an analysis of compliance
with environmental regulations. This enables compliance with current regulations and monitor
the upcoming environmental regulations (including water-related laws), to be prepared for
future requirements.
11.1. Water Claim
Adani Transmission Limited recognises the importance of incorporating ‘Responsible
Management of Water resource” in business strategy and risk management approach. ATL’s
systematic approach towards water management strategy and water-related risk helps in
achieving responsible water consumption and sustainable water management practices.
In the current reporting period, ATL has set a target to become “Water Neutral” and replenish
more than 100% of the water use in the company-owned sub-stations under various subsidiaries
of Adani Transmission Limited excluding the sub-stations coming under Adani Electricity
Mumbai Limited, located at diversified water basins.
In line with the target, in FY 2020, ATL has implemented rainwater harvesting structures of
128 million litres capacity at two sub-stations located in Koradi and Akola, against the
cumulative water consumption at 25 sub-stations under various subsidiaries of Adani
Transmission Limited excluding the sub-stations coming under Adani Electricity Mumbai
Limited (72 million litres). ATL as an organisation understands that water recharged at one
water basin will not have direct impact on withdrawal at other water basins, however, it has
started the water stewardship journey with the above approach. In FY 2021, ATL expects its
rainwater harvesting structure to replenish more than 128 million litres of water within the
organisational boundary, resulting in improvement of water quality in the watershed through
aquifer recharge and offsetting more than the total amount of water consumed by its 25 sub-
stations. In addition, ATL is planning to submit CDP response for Water Security in the next
financial year.
As part of automation initiative ATL intends to develop a state of art ENOC (Energy Network
Operations Centre) for its transmission business where, all sub-stations will be operated
remotely from ENOC with unmanned arrangement on deployment of various technological
solutions, security and surveillance systems. The benefits of this initiative are not just limited
to optimize the manpower and economical operation, enhance the reliability and efficiency,
drive high class operational performance as sustainable competitive advantage, it also helps us
to bring down the domestic water consumption at sub-stations and will lead us to achieve net
zero water consumption at our sub-stations.
43
12. Pollution and Resources
ATL’s environmental agenda aims to maximise resource efficiency and mitigate the negative
impact of its operations on the ecosystem. As a Transmission and Distribution company, ATL
does not produce materials amounts of pollution by itself. However, some activities in the
construction phase and operation phase of existing networks do generate direct impacts on the
environment due to the use of resources.
To address the impacts of ATL’s operations on the environment, a robust ISO 14001:2015
certified Environmental Management System and monitoring mechanism for all operations has
been established as a part of the Integrated Management System. ATL’s operations are also
governed by its Sustainability Policy and ADANI group-wide Environmental Health and
Safety policy that specifically addresses the issues of pollution and resource use. Further, all
operations of ATL are in compliance with the CPCB quality standards.
12.1. Air Pollution
ATL’s major source of direct environmental impact is its generating station at Dahanu, which
has been installed with state-of-the-art technologies to limit air and water pollution well below
the compliance requirements. As a forward-looking corporate entity, ATL strives to go much
beyond meeting compliance requirements. This can be witnessed in the operations of ATL’s
thermal generation unit which was awarded 5-star rating by the Maharashtra Pollution Control
Board (MPCB) for low levels of PM10 emissions in the current reporting period.
At ATL’s generating station, the various measures taken to control pollution are as follows.
• To control Particulate Matters generated from the coal burning, Electrostatic
Precipitators (ESP) having four passes with six fields and having an efficiency of
99.91% to collect fly ash have been provided.
• To control the Sulphur Dioxide (SO2) emission, Flue Gas Desulphurization (FGD) unit
having efficiency more than 90 % has been commissioned and is in operation since
October 2007.
• Due to provision of Over Fire Dampers the NOx emission is within limit since
inception, a stack of 275.38 meters height is provided to ensure thin dispersion of the
flue gas over a large area.
• First in India to install FGD to prevent sulphur emissions / acid rain.
• Four Ambient Air Quality Monitoring Stations keeps in check health of local
consumers.
Further, ATL largely focuses on reducing its carbon emissions at the operational level as
discussed under the Climate Change topic.
ATL has set a target to reduce its greenhouse gas (GHG) emission intensity (on per ₹
revenue generation) reduction to 40-45% by 2023-24 against India’s National Determined
Contributions. In line with the target, ATL has disclosed its baseline carbon intensity at 4.58
44
tCO2e/ lakh ₹ revenue generated in 2018-1. In the current reporting period, the carbon intensity
stood at 2.74 tCO2e which denotes that ATL has achieved 95% of the target set for FY 23-24
in the current financial year.
Emissions Data
Emissions by source FY 2019-20 FY 2018-19
Direct NOx emissions 2941.56 metric tonnes 2666.88 metric tonnes
Direct SOx emissions 1069.6 metric tonnes 1004.1 metric tonnes
Direct Mercury emissions* 0.024 metric tonnes 0.034 metric tonnes
Direct Dust emissions* 392.6 metric tonnes 375.7 metric tonnes
% of operations covered 100 100
* Stack flow was considered at maximum at full plant load capacity
12.2. Water Use and Discharge
Responsible consumption and conservation of water resources is a crucial part of ATL’s
environmental management strategy. Owing to the nature of ATL’s operations, the amount of
fresh water consumed for operations is minimal and a large portion of the water is used for
domestic consumption.
Apart from the Dahanu Thermal Power Station, none of the other operating sites of ATL are
water intensive, given that the operations include only substations and transmission
infrastructure. At the thermal power station, the water requirement is mainly managed by
utilisation of the sea water. Therefore, none of ATL’s operating locations are exposed to any
inherent water related risks.
In the current reporting period, nearly 99.4% of the total water consumed was sea water.
ATL water consumption data
Type of Water FY20 FY19
Freshwater 18,16,542 19,37,800
Seawater 37,70,04,155 40,96,98,900
Recycled and Reused water 2,04,494 2,46,226
ATL has set a target to reduce its freshwater consumption year-on-year. This can be
effectively achieved by increasing the percentage of water recycled and reused in the
operations. In line with the target, in the current reporting period, the amount of freshwater
consumed by ATL has significantly reduced by 6.23%.
The sea water consumed is treated as per the regulations and returned to the sea. The domestic
effluent is being treated in ATL’s in-house Sewage Treatment Plants (STP) and the treated
water is utilised for horticulture purpose.
Industrial effluents are only generated by Dahanu Thermal Power Station, which is treated in
the in-house Effluent Treatment Plant (ETP) established and disposed as per CPCB regulations.
45
ATL has also set a target to become “Water Neutral” and replenish more than 100% of the
water use in the company-owned sub-stations under various subsidiaries of Adani
Transmission Limited excluding the sub-stations coming under Adani Electricity Mumbai
Limited, located at diversified water basins. In line with the target, ATL strives to conserve
and replenish water resources by investing in rainwater harvesting systems. As a pilot measure
to evaluate the structure’s feasibility, ATL has installed above ground Rainwater Harvesting
Systems (RWS) at three of its critical regions of operation. The area has the potential to harvest
3,53,077 m3/year, sufficient to meet the organisations needs and recharge the groundwater
table.
12.2. Waste Management
ATL makes focused efforts to practice responsible consumption of resources and circular
economy in waste management to essentially convert responsibility into an opportunity for
value-creation. To facilitate proper waste segregation and resource conservation, ATL has
included a system in its Integrated Management System (IMS) for waste segregation at source
and disposal as per the laws of the land.
ATL, has set a target to achieve ‘Zero Waste to Landfill (ZWL)’ across all its sites by FY
2025. In line with the target, the organisation collects and utilises 100% of the fly ash produced
in its generating station. 100% of electrical waste during the time of set-up gets recycled as per
the industry best-practices. In the current reporting period, 99% of the waste generated from
ATL’s operations were diverted away from landfill. To achieve 100% conformance with the
ZWL target, ATL has conducted an internal gap assessment to identify and implement
measures in the current reporting period. The performance of which will be reported in the next
financial year. In addition, the quantity of hazardous waste generated decreased significantly
by 31.62%.
ATL has set a target to become a “Single Use Plastic (SUP) free company”. In line with the
target, ATL has successfully conducted SUP free certification audit for of its 3 sub-stations on
a pilot basis in the current reporting period.
13. Responsible Supply Chain
All suppliers, contractors and business partners involved in ATL’s supply chain are expected
to share the same values and standards as the organisation with respect to Governance, Social
and Environmental performance. The company is committed to extending these sustainability
criteria throughout its extensive value chain while continuously working together with its
supply chain partners to tackle risks and improve its responsible procurement practices.
ATL has an established Responsible Supply Chain Management policy that effectively governs
the organisations supply chain management practices and its integration with environment,
social and governance aspects.
46
13.1. Supplier Code of Conduct
ATL is committed to conducting its business with high standards of compliance and ethics.
Therefore, ATL endeavours to engage with suppliers who conduct themselves in a lawful and
ethical manner, protecting human and labour rights, health and safety, information security and
the environment. To achieve this, ATL has an established Supplier Code of Conduct which
effectively communicates the company’s expectations, corporate values and culture with its
suppliers and serves as a guideline in evaluating prospective business partners.
The Supplier Code of Conduct inherently embraces environmental, social and governance
standards of operation. The Code’s social compliance criteria covers all essential components
as per global standards such as prevention of child labour and forced labour, human rights,
employee rights to fair wage and working hours, occupational health and safety, freedom of
association, anti-discrimination, community inclusive development and minimizing social
impact of business operations. The environmental provision of the code addresses components
such as compliance with all applicable environmental laws, resource efficiency, climate change
action, biodiversity enhancement and prevention of pollution. Similarly, the code also lays
down governance related provisions such as compliance with all applicable all regulations,
anti-corruption and bribery and business ethics. Therefore, effective ESG integration is
achieved in ATL’s supply chain management. 100% of the exiting suppliers of ATL are
governed by the supplier code of conduct and all potential suppliers are required to comply
with its provisions.
13.2. Supplier Screening and Evaluation Criteria
To evaluate all potential new suppliers, ATL has established a Supplier Screening and Risk
Assessment framework as an integral part of the vendor onboarding process implemented.
Within this framework, the company has developed a comprehensive Supplier Risk
Assessment Score Card which incorporates significant screening/pre-qualification criteria
including ESG aspects, credentials, capability to execute assignments, quality norms and,
compliance to statutory requirements. The Score Card is utilised to evaluate the mechanisms
and performance of all suppliers under consideration against the following listed ESG and
parameters.
Environmental Criteria Social Criteria Governance Criteria
Environment Management
Certification
Energy Management
Certification
Energy and GHG emissions
Human Rights Policy
Health and Safety
POSH
Child Labour Policy
Board Diversity Policy
Code of Conduct
Whistle blower Policy
47
Water Conservation
Land Conservation
Pollution
Green Packaging
Management and disposal of
hazardous substances
Environmental Compliance
Social Accountability
Certification
Medical fitness
Compensation Policy
Compliance to laws governing
child labour, minimum wage etc.
Labour Policy
CSR
Anti-Corruption and
Bribery Policy
Information Security
Certification
ESG reporting
License to operate
Socioeconomic
compliance
100% of ATL’s suppliers are assessed before onboarding Supplier Screening and Risk
Assessment framework.
Once, the supplier is successfully onboarded, suppliers of ATL are audited using the Supplier
Risk Assessment Score Card on a rotational basis. This continuous supply chain risk
management approach enables proactive decision and mitigation measures.
FY 2019-20 Existing Suppliers New Suppliers
Suppliers Screened on ESG
Parameters
1,879 247
Suppliers audited on ESG
Parameters
375 4,696
13.3. Identification of Critical Suppliers and Risk Assessment
In addition to the supplier audit on a rotational basis, ATL has also established a process to
identify its critical suppliers and assess their risks and weaknesses against the listed ESG
parameters on an ongoing basis.
The critical supplier identification methodology is mainly based on identifying ATL’s
dependency on and value generated by a particular supplier i.e.,
1. High-volume suppliers
2. Critical component suppliers
3. Non-substitutable suppliers
48
Type of supplier Absolute number of
suppliers
Share of total procurement
spent (%)
Total tier 1 suppliers 445* 100%
Critical tier 1 suppliers 21* 62%
*This is excluding Adani Electricity Mumbai Limited
The comprehensive supplier risk assessment score card is used to assess the critical supplier’s
performance against periodically to effectively assess the inherent ESG risks and weaknesses
exiting in the company’s value chain. Supplier who attracts a score below 60% in the individual
ESG risk category and an overall score below 70% in the vendor risk assessment score card is
defined as High-Risk Supplier. So far, none of ATL’s suppliers have been categorized as High
Risk.
The ESG risks and weaknesses identified in the supplier’s performance as a result of the risk
assessment and the corresponding corrective action required to mitigate them will be
effectively communicated to the suppliers. Low scale vendors with investment requirements to
ensure compliance and effective performance against environmental and social standards are
supported by ATL through investment and structured collaborations to build capacity and
handhold in their performance improvement endeavours by effectively employing ATL’s
expertise.
14. Cyber Security
According to the International Energy Agency, “Digitalization is already improving the safety,
productivity, accessibility, and sustainability of energy systems. But digitalization is also
raising new security and privacy risks.” ATL’s business processes and day-to-day functions
are highly automated and interconnected through Information Technology. Thus, it is essential
for the organisation to have a capable cyber security/information security system that protects
the company from cyber-attack risks that may jeopardize information privacy and customer
privacy.
For this purpose, ATL has established a strong Cyber Security governance with direct Board
oversight to the security and resilience of network and to prevent IT system failures. The Risk
Management committee of the Board is the highest governing body responsible for the review
of the cyber security function of the organisation. The Chief Executive Officer (CEO) of ATL
has the executive level responsibility for establishing and maintaining the Information Security
strategy and processes that protect information assets.
ATL has established a dedicated Information and Security policy to ensure that all the
information assets including data, intellectual property, computer systems, and IT equipment
are adequately and consistently protected from damage, inappropriate alteration, loss, and
unauthorized use or access. Based on the Information and Security policy, ATL has established
49
information security procedures for all employees to meet all regulatory and statutory
requirements pertaining to information collection, storage, processing, transmittal, and
disclosure.
The Information Security/ Cyber security risk identification, prioritization and management is
effectively integrated within the organisation Risk Management Framework. In addition, ATL
is currently got certified in ISO 27001 certified Information Security Management System
(ISMS) in FY 20-21. However, Adani electricity Mumbai Limited (AEML), a subsidiary of
ATL, has already established ISO 27001 certified ISMS within its operating boundary.
To continuously assess and monitor the resilience of the Information Technology infrastructure
and to proactively identify any potential cyber risks periodic vulnerability analysis including
annual penetration testing is performed for IT infrastructure as well as its associated
applications. In the reporting period, ATL has suffered no incidents to its IT infrastructure and
no security breaches.
15. Customer Satisfaction
Continuous customer feedback and engagement is essential for ATL’s business to understand
changing customer expectations and to enhance service excellence accordingly. For this
purpose, ATL conducts Customer Satisfaction survey periodically to monitor whether the
service is meeting expectations and to identify any gaps.
Customer Satisfaction FY 2019 – 20
Percentage of customers surveyed 0.033
Percentage of satisfied customers 83.75%
15.1. Customer Data Protection
ATL understands that customers are the true owners of their data and without their consent, no
data should be collected, processed or used by any corporate entity. To ensure customer data
protection ATL transparently educates all its customers on its how it used their data such as the
nature and the purpose of customer information captured as well as how the information is
protected. In the reporting period, the company has reported no customer privacy breaches.
16. Stakeholder Engagement Governance
ATL has established effective stakeholder engagement governance with direct Board oversight
through its Stakeholder Relationship Committee. The committee of the Board reviews the
stakeholder engagement activities of the organisation. The Chief Sustainability Officer (CSO)
of ATL has the executive level responsibility for establishing and maintaining the stakeholder
engagement strategy and processes. The Board of Directors are briefed on the effectiveness
and proceedings of stakeholder engagement on quarterly basis.
50
ATL has established detailed procedures for stakeholder identification, prioritization and
engagement. Stakeholder accountability, engagement and grievance redressal mechanisms are
effectively covered under the Integrated Management System of ATL under the requirement
of Clause 4.2 of ISO 9001, 14001, 45001, 27001 standards. The stakeholder identification and
engagement mechanism are also covered under ATL’s CSR policy.
The stakeholders of ATL can directly connect with the company's CSO at
[email protected] to register their suggestions, grievance and queries.
Detailed information on stakeholder engagement is available at ATL Annual Report 2019-20
Following List of documents and Policy related company are available on company
website or Internal Portal.
Document Description
Statutory Policies as per Company Act/ SEBI (LODR) - 14 documents
In Compliance to Companies Act 2013
CSR-Policy
Related Party Transaction-Policy-Framework-Guidelines
Whistle-Blower-Policy-And-Vigil-Mechanism
Risk-Management-Policy
Nomination & Remuneration-Policy-For-Directors
In Compliance to SEBI Guideline
Archival-Policy
Policy on Preservation of Documents
Policy-For-Determining-Material-Subsidiaries
Material Events Policy
ID Terms and Conditions of Appointment
Directors_Familiarization_Programs
51
Code Of Internal Procedures And Conduct For Regulating, Monitoring And Reporting Of Trading By Insiders
Disclosure-Practices for UPSI
Code Of Conduct For Board Of Directors And Senior Management Of The Company
Dividend-Policy
BRR Policies
Sexual-Harass-Policy (POSH) (Workplace Act'2013)
Board Committee Related Charters - 5 Documents
Charter-Of-Audit-Committee
Charter-Of-Nomination-Remuneration-Committee
Charter-Of-Risk-Management-Committee
Charter-Of-Stakeholders-Relationship-Committee
Charter of Corporate Social Responsibility & Sustainability (CSR&S) Committee
Documentation in respect of Policies relevant in pursuit of Good Governance -16 documents
Affirmative-Action-Policy
BCP-Policy
Commodity Price Risk Management Policy
Corporate-Environment- Health-And-Safety Policy
Corporate Sustainability Policy
Customer-Service-Policy
Information-Security-Policy
Quality-Policy
Responsible Supply Chain Management
Safety-Code-Of-Conduct
52
Adani-Code-Of-Conduct Employees
OHS Vision & Mission
ATL-IMS Policy
Anti-Bribery Policy
Anti-Slavery Policy
Human Rights
Employee Social Volunteering Policy
Claw back Policy
Biodiversity Policy
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