Businesses should conduct and govern themselves with integrity, and in a manner that is Ethical, Transparent and Accountable

We promote a culture where ethical leadership is reinforced by personal accountability. Our Business Integrity framework serves as a guiding compass, enabling employees to act with confidence and consistency, rooted in our core values of respect, integrity, responsibility, and a pioneering spirit.

Through well-defined policies, ongoing training, and strong oversight mechanisms, we work to prevent misconduct, identify risks early, and respond effectively to uphold stakeholder trust. This robust ethical foundation safeguards our people and reputation while strengthening our commitment to sustainable and responsible growth.

UN SDGs

Zero Bribery / corruption charges against our BoD / KMPs / employees / workers by law enforcement agency

Zero Corruption/conflicts of interest complaints against the Director/KMPs

Anti-corruption and anti-bribery policy

Whistle Blower Policy

Essential Indicators

Segment Total number of training and awareness programmes held Topics/ principles covered under the training and its impact % age of persons in respective category covered by the awareness programmes
Board of Directors 30 Adani Portfolio Credit Updates 50%
Project Excellence 50%
Elevating Audit Committee Engagement 50%
CRISIL Update - India Infrastructure and RPT Governance 50%
Update on Cement Sector by CLSA 50%
Ametha and Kymore Plant visit and knowledge sharing on Cement Operations 50%
Our Digital Agenda 50%
Changing way we work: Data and Agents 50%
Digital Culture/Talent 50%
Digital and AI in action: sector deep dives 50%
Security as #1: OT 50%
JV for AI: AI Labs 50%
Digital and AI in action: Energy ENOC 50%
Cement (CNOC) 50%
Logistics (CEO's perspective) (LNOC) and Port 50%
How is Digital/AI helping Dharavi redevelopment 50%
H1 FY 26 Update Group Finance Team 43%
Khavda Project Update 43%
ESG - Global Trends & Directors' Liabilities External Expert Speaker 43%
Board Effectiveness - Panel Discussion 43%
Adani Group - Building Sustainable Infrastructure with Financial Discipline and Global Competitiveness 43%
India’s Capex Super Cycle -Created at Scale, Enabling Growth & Delivering Impact 43%
Adani ESG paradigm - Green. Inclusive & Responsible – Adani Commitment 43%
Fireside Chat: Energy Transition, Productivity focus and driving Digital Infra – The Adani Way 43%
Showcase - Digital Transformation 43%
Showcase - Treasury in Action 43%
Update Financing and Capital 57%
Sanctions Compliance 57%
Update on Human Resources 57%
Insider Trading 57%
Key Managerial Personnel 30 Adani Portfolio Credit Updates 67%
Project Excellence 67%
Elevating Audit Committee Engagement 67%
CRISIL Update - India Infrastructure and RPT Governance 67%
Update on Cement Sector by CLSA 67%
Ametha and Kymore Plant visit and knowledge sharing on Cement Operations 67%
Our Digital Agenda 67%
Changing way we work: Data and Agents 67%
Digital Culture/Talent 67%
Digital and AI in action: sector deep dives 67%
Security as #1: OT 67%
JV for AI: AI Labs 67%
Digital and AI in action: Energy ENOC 67%
Cement (CNOC) 67%
Logistics (CEO's perspective) (LNOC) and Port 67%
How is Digital/AI helping Dharavi redevelopment 67%
H1 FY 26 Update Group Finance Team 33%
Khavda Project Update 33%
ESG - Global Trends & Directors' Liabilities External Expert Speaker 33%
Board Effectiveness - Panel Discussion 33%
Adani Group - Building Sustainable Infrastructure with Financial Discipline and Global Competitiveness 33%
India’s Capex Super Cycle -Created at Scale, Enabling Growth & Delivering Impact 33%
Adani ESG paradigm - Green. Inclusive & Responsible – Adani Commitment 33%
Fireside Chat: Energy Transition, Productivity focus and driving Digital Infra – The Adani Way 33%
Showcase - Digital Transformation 33%
Showcase - Treasury in Action 33%
Update Financing and Capital 100%
Sanctions Compliance 100%
Update on Human Resources 100%
Insider Trading 100%
Employees other than BoD and KMPs 17,753 1,500 100%
Workers 8,880 25 100%

Monetary
NGRBC Principle Name of the regulatory/
enforcement agencies/ judicial institutions
Amount
(In INR)
Brief of the Case Has an appeal been preferred?
(Yes/No)
Penalty/ Fine Principle 4 Sub Divisional Judicial
Magistrate, Bargarh
` 35,000 A complaint has been filed against the Occupier and the Factory Manager for violations under the Factories Act. No
Penalty/ Fine Principle 4 Chief Judicial Magistrate, Dhanbad ` 500 A Complaint has been filed under section 28 of the payment of bonus act 1965 and payment of bonus rules,1975 against the Factory Manager. No
Settlement - - - - -
Compounding fee - - - - -
Non-Monetary
NGRBC Principle Name of the regulatory/
enforcement agencies/ judicial institutions
Brief of the Case Has an appeal been preferred? (Yes/No)
Imprisonment Nil
Punishment Nil

Case Details Name of the regulatory/ enforcement agencies/ judicial institutions
Nil Nil

Yes, https://www.acclimited.com/-/media/Project/ACC-Limited/Investor/policies/updated-policy/7-Anti_Corruption_Anti_Bribery_Policy.ashx

We are committed to upholding the highest standards of ethical business conduct and fully comply with all applicable anti-corruption and anti-bribery laws and regulations. Our anti-corruption and anti-bribery policy sets clear expectations for employee behavior, strictly prohibiting any form of bribery, corruption, or unethical practices. We place strong emphasis on accountability and transparency across all aspects of our operations and have established rigorous measures to address and prevent any instances of noncompliance.

FY 2025-26
(Current Financial Year)
FY 2024-25
(Previous Financial Year)
Directors 0 0
KMPs 0 0
Employees 0 0
Workers 0 0

FY 2025-26
(Current Financial Year)
FY 2024-25
(Previous Financial Year)
Number Remarks Number Remarks
Number of complaints received in relation to issues of Conflict of Interest of the Directors 0 NA 0 NA
Number of complaints received in relation to issues of Conflict of Interest of the KMPs 0 NA 0 NA

-Not Applicable as there were no cases.

FY 2025-26
(Current Financial Year)
FY 2024-25
(Previous Financial Year)
Number of days accounts payable 38 33

Parameter Metrics FY 2025-26
(Current Financial Year)
FY 2024-25
(Previous Financial Year)
Concentration of purchases a. Purchases from trading houses as % of total purchases Nil Nil
b. Number of trading houses where purchases are made Nil Nil
c. Purchases from top 10 trading houses as % of total purchases from trading houses Nil Nil
Concentration of Sales a. Sales to dealers /distributors as % of total sales 73% 78%
b. Number of dealers /distributors to whom sales are made 13,973 13,925
c. Sales to top 10 dealers/distributors as % of total sales to dealers/distributors 3% 3%
Share of RPTs in a. Purchases (Purchases with related parties/total purchases) 37% 32%
b. Sales (Sales to related parties/ Total Sales) 20% 20%
c. Loans & advances (Loans & Advances given to related parties/ Total loans & advances) 95% 28%
d. Investments (Investments in related parties/Total Investments made) 99% 46%

Leadership Indicators

Total number of awareness programmes held Topics / principles covered under the training Percentage of value chain partners covered (by value of business done with such partners) under the awareness programmes
31830 (IHB Awareness Programmes) Do's & Don't of Construction, Choosing Right Materials & Practices, Choosing Right Contractor, etc. The programmes covered 739500 no. of Individual house builders
28270 (Contractor Awareness Programmes) Project Management, Steel Estimation & Detailing, Cement Manufacturing and Usage, etc. The programmes covered 785700 no. of contractors
990 (Professional Awareness Programmes) New trends in construction, Advance Construction materials & technology, Sustainability Construction Practices, etc. The programmes covered 30100 no. of professionals
2 (Suppliers Awareness Programme) India NDC, SDG, Climate Change, GHG Inventory, Environmental Management, Human Rights Ethics, Transparency and Accountability The programmes covered 144 no. of suppliers
330 (Dealers Awareness Programme) New trends in construction, Advance Construction materials & technology, Sustainability Construction Practices, etc. The programmes covered 9667 no. of dealers

Yes.

ACC Limited has instituted robust processes to identify, avoid, and manage conflicts of interest involving members of its Board. The Company operates under a comprehensive Code of Conduct for Directors and senior management, which explicitly prohibits situations where personal interests may conflict with fiduciary responsibilities. Directors are required to make timely disclosures of any direct or indirect interests that could influence their judgment or decision-making. In addition, ACC Limited mandates annual compliance confirmations from its Board members and senior executives to ensure adherence to the Code and maintain transparency.

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Section A Management Process

General Disclosures

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Section B Management Process

Management Process and Disclosures

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Principle 2 Management Process

Businesses should provide goods and services in a manner that is sustainable and safe

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Principle 3 Management Process

Businesses should respect and promote the well-being of all employees, including those in their value chains

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Principle 4 Management Process

Businesses should respect the interests of and be responsive to all its stakeholders

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Principle 5 Management Process

Businesses should respect and promote human rights

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Principle 6 Management Process

Businesses should respect and make efforts to protect and restore the environment

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Principle 7 Management Process

Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent

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Principle 8 Management Process

Businesses should promote inclusive growth and equitable development

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Principle 9 Management Process

Businesses should engage with and provide value to their consumers in a responsible manner

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