Social And Environmental Management Policy

I. Introduction

Environmental and Social considerations have become a measure of a company's performance. Such issues are impacting various facets regarding a company such as the bottom line, brand value, competitiveness and long term sustainability. In such a scenario, it is needed to develop appropriate standards that provide a benchmark for company assessment and performance.

Social and environmental opportunities form an integral part of good business. Socially and environmentally responsible businesses can enhance clients' competitive advantage and create value for all parties involved. The Environment and Social Policy (hereafter also referred to as "the Policy") will enable Shubham Housing Development Finance Co. Ltd. (hereafter also referred as "Shubham") to develop processes to recognise the environmental and social facets of its operations and stakeholders.

II. Scope

For the purpose of this policy environmental considerations include:

  1. Pollution (Air, Water, Land, Noise)
  2. Land use, groundwater table, degradation and its contamination
  3. Waste generation and disposal
  4. Natural Resource depletion
  5. Energy use and its Efficiency

Social considerations encompass:

  1. Occupational Health and Safety
  2. Working Conditions
  3. Social Infrastructure
  4. Child Labour
  5. Equal Opportunity
  6. Freedom Of Engagement
  7. Remuneration
  8. Minimum Wages
  9. Discrimination
  10. Indigenous People's Rights
  11. Sustainable Livelihoods
  12. Community Development

III. Objectives

  1. As a part of an on-going effort, we aim to cover all the points mentioned above as we expand and ensure that this policy serves as a guide;
  2. Monitor and evaluate our business portfolio and borrowers/product services for environment and social commitments and their compliance with applicable laws and regulations with integrity;
  3. Focus on effective and efficient utilization of natural resources and prevention of loss where it is technically and economically feasible for all our investments;
  4. Continual improvement in E&S performance of our financing operations and existing monitoring mechanism;
  5. Incorporation of environmental, health and safety and social considerations as a priority in business planning and decision-making processes

IV. Policy directives

Due to the nature of operations that Shubham is currently involved in, there is minimal impact to the environment. As an organisation, the company promotes reduction in wastage across all its branches. Along with this, the company would also enact policies regarding waste generation and disposal.


Shubham does currently ensures that the following directives are met along with the yardstick to measure them:


1. Equal Opportunity:

To offer equality of opportunity to all employees and not to engage in or support discrimination in hiring, compensation, access to training, promotion, termination or retirement based on ethnic and national origin, caste, religion, disability, sex, age, sexual orientation, union membership, or political affiliation.


Shubham would ensure that across all the departments and levels, they would provide access to all without any discrimination on the grounds mentioned above.


Measure: Conduct an Anonymous Employee Satisfaction survey across the entire organisation to certify that no discrimination was incurred under the points mentioned above.


2. Freedom of engagement

To require that all employees enter into employment with the company of their own free will; and not to apply any coercion when engaging employees or support any form of forced or compulsory labor.


In addition to the above, no employee would be forced to stay in the organisation after they have resigned post serving the mandated notice period.


Shubham shall not enforce their employees to partake in any activity of illegal nature and should establish a formal grievance mechanism for its employees.


Measure: Established a grievance redressal committee to look into the concerns of all the employees. An employee can report their grievances through mails / phones, which would be addressed by the concerned authorities


3. Child labor

To ensure that minors are properly protected; and as a fundamental principle, not to employ children or support the use of child labor as per the 'The Child Labour (Prohibition and Regulation) Act, 1986 and Rules'.


Measure: Shubham ensures that no underage labor is employed as per the Child Labour Act 1986 by them as well as their vendor associates.


4. Discrimination

Shubham ensures that no discrimination shall occur due to hiring, promotions, termination and compensation across levels in the organisation.


Measure: Conduct an Anonymous Employee Satisfaction survey across the entire organisation to certify that no discrimination was incurred under the points mentioned above.


5. Minimum Wages

Shubham firmly enforces that Minimum wages are provided to all its employees as per the Minimum Wages Act, 1948.


6. Community Development

As a part of its core service offering, Shubham seeks to address a problem of how a significant portion of the urban working population does not get access to credit for purchase/improvement of dwelling units due to the informal nature of their income.


The company believes that the core to servicing these clients lies in the simplicity of delivery. Our lending model therefore relies on neighborhood branches within relevant catchment areas, a unique budget analysis process allowing recognition of the real income and affordability of households and a transparent interaction at every level with our people thereby promoting development among such communities.

V. Policy applicability

The Policy cannot specifically anticipate and encompass all circumstances and, consequently, it is conceivable that Shubham may approve departures from one or more of the directives in the Policy. In such circumstances, proposals advocating any such departure in either programming or in project development and execution must demonstrate the exceptional characteristics of the situation that justify the departure.