Section A : General Disclosures

Message from
Our
Leadership

At the heart of our business lies a deep commitment to building a sustainable future. As we navigate an evolving global landscape, we continue to integrate environmental stewardship, social responsibility, and sound governance into every facet of our operations. Our sustainability strategy is anchored in climate & energy, circular economy, water & nature and people & community growth—ensuring we reduce our carbon footprint, conserve natural resources, empower communities, and uphold the highest ethical standards. Our commitment to ESG principles is demonstrated by continuous enhancement of our ESG scores and strict compliance with global disclosure norms. We are proud of the progress we’ve made, but we recognize that sustainability is a journey, not a destination. Together with our stakeholders, we remain steadfast in our mission to create long-term value while safeguarding the planet for future generations."

VINOD BAHETY,

Whole Time Director & Chief Executive Officer
0

Employees

0

Workers

0million

CSR beneficiaries

1 Corporate Identity Number (CIN) of the Listed Entity L26940GJ1936PLC149771
2 Name of the Listed Entity ACC Limited
3 Year of incorporation 1936
4 Registered office address Adani Corporate House, Shantigram, Near Vaishnodevi Circle, S.G. Highway, Ahmedabad – 382421
5 Corporate address Adani Corporate House, Shantigram, Near Vaishnodevi Circle, S.G. Highway, Ahmedabad – 382421
6 E-mail acc-investorsupport@adani.com
7 Telephone +91-79 2656 5555
8 Website www.acclimited.com
9 Financial year for which reporting is being done April 2024 to March 2025
10 Name of the Stock Exchange(s) where shares are listed BSE
NSE
11 Paid-up Capital ₹1,87,78,72,630
12 Name and contact details (telephone, email address) of the person who may be contacted in case of any queries on the BRSR report Name: Neeru Bansal
Address: Adani Corporate House,
Shantigram, Near Vaishno Devi Circle, S.G. Highway, Ahmedabad – 382421
Contact: +919825386934
Email: neeru.bansal@adani.com
13 Reporting boundary - Are the disclosures under this report made on a standalone basis (i.e. only for the entity) or on a consolidated basis (i.e. for the entity and all the entities which form a part of its consolidated financial statements, taken together). Disclosures made in this report are on a standalone basis for all Integrated Units and Grinding units, mines and bulk cement terminals. Details of subsidiaries and joint ventures are not included here.
14 Name of assurance provider TUV India Private Limited
15 Type of the assurance obtained Reasonable assurance for BRSR Core and Limited Assurance for other parameters as per International Standard Assurance Engagement(ISAE) 3000 (revised) and ISAE (3410)

16. Details of business activities (accounting for 90% of the turnover)

S.
No.		 Description of Main Activity Description of Business Activity % of Turnover of the entity
1. Manufacturing Cement, Clinker 100%

17. Products/Services sold by the entity (accounting for 90% of the entity’s Turnover):

S.
No.		 Product/Service NIC Code % of total Turnover contributed
1. Cement, Clinker 23941 100%

18. Number of locations where plants and/or operations/offices of the entity are situated:

Location Number of plants Number of offices Total
National 17 35 52
International 0 0 0

19. Markets served by the entity:

a. Number of locations

Locations Number
National (No. of States) 29 States and UTs and 565+ districts
International (No. of Countries) 0

b. What is the contribution of exports as a percentage of the total turnover of the entity?

Nil, we are not doing export of our products.

c. A brief on types of customers

ACC Limited is India’s foremost manufacturer of cement and ready mixed concrete with a countrywide network of factories and marketing offices. Its customer includes its channel partners (dealers and retailers), individual home builder, contractors, big housing contractors, Infrastructure companies and government department.

20. Details as at the end of Financial Year:

a. Employees and workers (including differently abled):

Sr.
No. 		Particulars Total
(A)		 Male Female
No. (B) % (B / A) No. (C) % (C / A)
EMPLOYEES
1. Permanent (D) 1,700 1,606 94.47% 94 5.53%
2. Other than Permanent (E) 1 1 100.00% 0 0.00%
3. Total employees (D + E) 1,701 1,607 94.47% 94 5.53%
WORKERS
4. Permanent (F) 1,470 1,460 99.32% 10 0.68%
5. Other than Permanent (G) 0 0 0.00% 0 0.00%
6. Total workers (F + G) 1,470 1,460 99.32% 10 0.68%

b. Differently abled Employees and workers:

S. No. Particulars Total(A) Male Female
No. (B) % (B / A) No. (C) % (C / A)
DIFFERENTLY ABLED EMPLOYEES
1. Permanent (D) 5 3 60% 2 40%
2. Other than Permanent (E) 0 0 0% 0 0%
3.
Total differently abled employees (D + E)
5
3
60%
2
40%
DIFFERENTLY ABLED WORKERS
4. Permanent (F) 0 0 0% 0 0%
5. Other than Permanent (G) 0 0 0% 0 0%
6.
Total differently abled workers (F + G)
0
0
0%
0
0%

21. Participation/Inclusion/Representation of women

Particulars Total
(A) 		No. and percentage of Females
No. (B) % (B / A)
Board of Directors 8 1 12.50%
Key Management Personnel 3 0 0%

22. Turnover rate for permanent employees and workers

(Disclose trends for the past 3 years)

Particulars FY 2024-25
(Current Financial Year) 		FY 2023-24
(Previous Financial Year) 		FY 2022-23*
(Jan' 2022 to Mar' 2023)
Male Female Total Male Female Total Male Female Total
Permanent Employees 20.44% 33.18% 21.20% 28.75% 33.42% 29.04% 23.53% 29.09% 23.89%
Permanent workers 12.05% 11.11% 13.46% 20.30% 14.93% 20.20% 7.23% 0.00% 7.10%

* The Company has changed its financial year end from December to March in FY23. Therefore, the figure for FY23 is for 15 months.

23. (a) Names of holding / subsidiary / associate companies / joint ventures

S. No. Name of the holding /subsidiary/ associate companies / joint ventures (A) Indicate whether holding/ Subsidiary/ Associate/Joint Venture % of shares held by listed entity Does the entity indicated at column A, participate in the Business Responsibility initiatives of the listed entity? (Yes/No)
1. ACC Minerals Resource Limited Subsidiary 100% No
2. Lucky Minmat Limited Subsidiary 100% No
3. Singhania Minerals Private Limited Subsidiary 100% No
4. ACC Concrete South Limited Subsidiary 100% No
5. ACC Concrete West Limited Subsidiary 100% No
6. Asian Concretes and Cements Private Limited Subsidiary 100% No
7. Asian Fine Cements Private Limited Subsidiary 100% No
8. Bulk Cements Corporation (India) Limited Subsidiary 94.65% No
9. OneIndia BSC Private Limited Joint Venture 50% No
10. MP AMRL (Bicharpur) Coal Company Limited Joint Venture 49% No
11. MP AMRL (Semaria) Coal Company Limited Joint Venture 49% No
12. MP AMRL (Marki Barka) Coal Company Limited Joint Venture 49% No
13. MP AMRL(Morga) Coal Company Limited Joint Venture 49% No
14. Aakaash Manufacturing Company Private Limited Joint Venture 40% No
15. Alcon Cement Company Private Limited Associate 40% No
16. Anantroop Infra Private Limited Subsidiary 100% No
17. Eqacre Realtors Private Limited Subsidiary 100% No
18. Krutant Infra Private Limited Subsidiary 100% No
19. Kshobh Realtors Private Limited Subsidiary 100% No
20. Prajag infra Private Limited Subsidiary 100% No
21. Satyamedha Realtors Private Limited Subsidiary 100% No
22. Varang Realtors Private Limited Subsidiary 100% No
23. Victorlane Projects Private Limited Subsidiary 100% No
24. Vihay Realtors Private Limited Subsidiary 100% No
25. Vrushk Realtors Private Limited Subsidiary 100% No
26. Foresite Realtors Private Limited Subsidiary 100% No
27. Trigrow Infra Private Limited Subsidiary 100% No
28. Peerlytics Projects Private Limited Subsidiary 100% No
29. Akkay Infra Private Limited Subsidiary 100% No
30. West Peak Realtors Private Limited Subsidiary 100% No

- Percentage of shares held mentioned in the above table includes both Direct and Indirect holding by listed entity.

24. (i) Whether CSR is applicable as per section 135 of Companies Act, 2013: (Yes/No):

Yes

(ii) Turnover (in `) : 20,594 crore

(iii) Net worth (in `) : 18,271 crore

25. Complaints/Grievances on any of the principles (Principles 1 to 9) under the National Guidelines on Responsible Business Conduct:

Stakeholder group from whom complaint is received Grievance Redressal Mechanism in Place (Yes/No) (If Yes, then provide web-link for grievance redress policy) FY 2024-25
(Current Financial Year) 		FY 2023-24
(Previous Financial Year)
Number of complaints filed during the year Number of complaints pending resolution at close of the year Remarks Number of complaints filed during the year Number of complaints pending resolution at close of the year Remarks
Communities Yes (https://www.adanifoundation.org/Contact-Us) 26 0 0 0
Investors (other than shareholders) Yes
(accinvestorsupport@adani.com) 		0 0 0 0
Shareholders Yes
(accinvestorsupport@ adani.com) 		55 0 44 4
Employees and workers Yes
(https:// www.acclimited. com/assets/new/ pdf/Whistle%20 Blower%20 Policy%20ACC. pdf & https://www. acclimited.com/ assets/new/pdf/ ACC-Employee%20 Grievance%20 Management%20 Policy-new.pdf) 		8 0 11 5
Customers Yes
(acchelp@ adani.com) 		36 1 19 8
Value Chain Partners Yes
(https:// www.acclimited. com/assets/new/ pdf/ Supplier%20 Code%20 of%20 Conduct.pdf) 		4 1 3 2
Other (please specify) Yes
(https://www. acclimited.com/ contact-us) 		28 5 27 13

26. Overview of the entity’s material responsible business conduct issues

Please indicate material responsible business conduct and sustainability issues pertaining to environmental and social matters that present a risk or an opportunity to your business, rationale for identifying the same, approach to adapt or mitigate the risk along-with its financial implications, as per the following format

S. No. Material issue identified Indicate whether risk or opportunity (R/O) Rationale for identifying the risk / opportunity In case of risk, approach to adapt or mitigate Financial implications of the risk or opportunity (Indicate positive or negative implications)
1. Water management Risk and Opportunity Risk – Water being a shared resource, it is essential for business to use it in a responsible way. These risks comprise conflicts with local communities and stakeholders over water rights and usage, potential water scarcity or quality issues due to over-extraction or pollution, and regulatory constraints on water abstraction permits or discharge standards.

Opportunity – By demonstrating commitment to conserving water resources, we can build stronger relationships with local communities and government. This will help us in securing and maintaining social license to operate, especially in water-stressed regions. In future, the company may qualify for government incentives aimed at promoting water conservation and sustainability initiatives. 		We have been investing in rainwater harvesting initiatives, restoring village ponds, construction of check dams, water conservation at closed mines and groundwater recharge for a long time to mitigate the risk of lack of water. As a result, the company is now water positive. The company uses more than 50 % of its water requirements in cement manufacturing from harvested rain water. Negative/ Positive
2. Air quality Risk Exposure to dust, Sox, Nox and other pollutants from cement plants can lead to respiratory issues among employees and nearby communities. This may lead to increased costs associated with healthcare for affected employees, and insurance premiums. The company may also face opposition, protests and even legal restrictions on its operations. We focus on improving air quality in the surrounding environment. We monitor the plants’ stack emissions through the Continuous Emission Monitoring System. We work on upgradation of electrostatic precipitators and replacement of damaged bags to control dust emissions. We take primary and secondary measures to control NOx emissions. Negative
3. Circular Economy Opportunity Circular economy offers great opportunity to lower the use of natural resources and fossil fuels in cement production and reduces carbon emissions. - Positive
4. Climate and Energy Risk and Opportunity Risk – Climate change poses multiple physical risks like flooding, temperature rise, water stress etc. Emerging and potential regulations may introduce or escalate regulatory risks. These extreme weather events can cause infrastructure damage, may hinder the supply chain network affecting timely delivery of raw materials and finished products. It may also cause power outages and affect the manufacturing processes.

Opportunity – Energy cost is a major cost in cement manufacturing. We continuously strive to reduce our specific thermal energy consumption and specific electrical energy consumption to optimise our energy costs. In addition, it is directly related to carbon emissions and by optimising energy consumption, we can lower our carbon emissions. 		The Company has approximately 93% of products in its portfolio which are blended products with lower carbon footprint.

Further, we are investing more and more in renewal energy and green energy from WHRS. In addition, we have set ambitious targets for Thermal Substitution Rates (TSR) by using alternate fuels. 		Negative/ Positive
5. Biodiversity Risk and Opportunity Risk – Land disturbance and habitat fragmentation from operational activities can lead to biodiversity degradation.

Opportunity – Restored ecosystems can provide long-term environmental benefits, including enhanced ecosystem services such as water filtration, carbon sequestration, and soil preservation. These benefits not only contribute to global environmental goals but also can have positive economic implications for the company and local communities in the long run. 		We adhere to Indian national regulations and are a signatory to the India Business and Biodiversity Initiative (IBBI) of the Confederation of Indian Industry (CII), and Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ). We assess the impacts on biodiversity and ecosystem services through set KPIs. This helps in conservation of ecosystem. Negative/Positive
6. Sustainable Construction Opportunity Intervention of sustainable practices and technologies such as substitute cementitious materials, CO2 capture in the built environment, and efficient concrete use help drive down carbon emissions from cement production and hence help to reduce the carbon footprint. - Positive
7. Human Capital Development Opportunity Through continuous learning and development and strengthened employee relations, we can mitigate succession planning risks, address skills gaps and ensure continuity of leadership and expertise. It will also help in being competitive in the marketplace and stay ahead of trends. Human Capital development will also contribute to an overall learning culture in the organisation. - Positive
8. Diversity and Inclusion Opportunity Employee diversity leads to increased creativity and innovation, improved communication and teamwork, and a greater understanding and appreciation of different cultures. Additionally, a diverse workforce can help to attract and retain top talent and can provide a competitive advantage for organisations. - Positive
9. Human Rights Risk and Opportunity Risk – Concerns related to child/forced labour, discrimination or any other human rights-related aspects within the workforce and value chain may lead to statutory violations which may negatively impact the brand image.

Opportunity – Alignment with the human rights principles and procedures safeguard the employees and value chain partners and ensure zero incidents of non-compliance with regards to International and National Human Rights Standards and Regulations. 		We are committed to respecting and promoting human rights across the value chain by inculcating a human rights policy. The policy is in line with The Universal Declaration of Human Rights, Social Accountability 8000 (SA8000) Standard and International Treaties & Conventions related to Human Rights. Negative/Positive
10. Occupational Health and Safety Risk and Opportunity Risk – Failure to protect workers from occupational hazards can result in legal action, fines, and compensation claims against the company. These risks can lead to significant financial liabilities and damage the company's reputation. Also, potential employees may hesitate from joining the company, and current employees may leave if they perceive their health and safety are not adequately protected, leading to challenges in attracting and retaining a skilled workforce.

Opportunity – By prioritising the wellbeing of all employees and workers, the company can enhance its employer brand, making it a more attractive place to work. Employees are more likely to join and stay with a company that prioritises their well-being, leading to lower turnover rates and higher employee satisfaction. 		We have developed safety initiatives including competency development, training, audits, inspections, surveys, We Care initiatives, Critical Control Management to prevent unwanted events, and especial cross-functional teams to drive process safety. Also, we conduct safety audits across our manufacturing sites to ensure that the actions are timely closed and implemented Negative/Positive
11. Community Relations Opportunity Uplifting livelihood opportunities improves community relations which is essential for the social license to operate. Also, a healthy community will ensure availability of strong local labour force, if required at any given point of time. - Positive
12. Customer Relationship Management Opportunity CRM empowers to build a positive customer experience based on relevant, real-time information and customer needs that matters to the business. It would enable data driven decision making, improved customer experience and hence drive growth in business by increasing loyalty and enhancing relations. - Positive
13. Corporate Governance and business ethics Opportunity Effective governance mechanism in the organisation gives an opportunity of building greater trust among the stakeholders and creates long-term value for them. - Positive
14. Risk Management Opportunity Enhanced Risk awareness and in-place emergency preparedness plans help to better foresee risks that may emerge due to climate change, regulations, sustained supply of raw material, funds, etc. and geopolitical developments. This helps to stay one step ahead and ensure business continuity and regulatory resilience. - Positive
15. Sustainable Supply Chain Risk & Opportunity Risk – Improper usage of resources, human rights violations, non-compliance with Supplier Code of Conduct, zero adoption of sustainable practices by suppliers can adversely impact the environment, social wellbeing, value chain and brand image. Additionally, it might also lead to cases of regulatory non-compliances and fines.

Opportunity – The company can leverage suppliers near operations to reduce costs, for greater control, quicker response and helps in cutting down significant emissions related to transportation. 		Supply chain and sourcing process has a direct impact on the environment and communities such as emissions, circular economy, water usage, biodiversity, material usage and human rights. We have taken measures to ensure an optimum supply chain with competent suppliers. Negative/Positive
16. Information technology and data privacy Risk & Opportunity Risk – Instances of information security breaches could lead to loss of sensitive data of customers including personal information. It could also lead to increased media scrutiny resulting in a loss of stakeholder trust, company reputation and regulatory fines or penalties.

Opportunity – In the ever-evolving landscape of digitalisation and innovation, monitoring and analysis of data in real time would lead to quicker identification and resolution of issues. As a result, this will ensure management of systems and processes more effectively. 		With increased digitisation, and heavy dependence on technology systems, it has become critical for us to ensure implementation of SOPs and policies, conduction periodic internal and external (third-party) audits and tests to check the resilience of the IT infrastructure from hackers, cyber-attacks, malware etc. Positive and Negative