64 Atul Ltd | Annual Report 2021-22 5.2. Code of conduct The code of conduct is available on the website of the Company at www.atul.co.in/investors/polices All the Directors and the Senior Management Personnel have affirmed their compliance with the code of conduct. A declaration to this effect signed by the Chairman and Managing Director forms a part of this report. 5.3. Prevention of sexual harassment of women at workplace Pursuant to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, the Company has framed a policy on prevention of sexual harassment of women at workplace and constituted Internal Complaints Committee. The status of complaints during 2021-22 is as under: Filed during 2021-22 Nil Disposed of during 2021-22 Nil Pending as at the end of 2021-22 Nil 5.4. Related party transactions The Company has formulated a Related Party Transactions Policy and the same is disclosed on the website of the Company at www.atul.co.in/investors/policies 5.5. ‘Material’ subsidiary companies The Company has formulated a policy for determining ‘material’ subsidiary companies and the same is disclosed on the website of the Company at www.atul.co.in/investors/policies 5.6. Familiarisation programs The details of familiarisation programs imparted to Independent Directors are disclosed on the website of the Company at www.atul.co.in/about/directors/ 5.7. Whistleblowing Policy The Company has formulated a vigil mechanism (Whistleblowing Policy) and is displayed on the website of the Company at www.atul.co.in/investors/policies 5.8. Commodity price risk or foreign exchange risk and hedging activities i) Risk management policy on commodities, including through hedging The Company has in place a Risk Management Policy and mechanism to assess risks, periodically review it and steps are taken to mitigate the risks. The Company uses certain raw materials, which are derivatives of various commodities, from various sources, for manufacturing products of the Company. Hedging products are not available for the major chemicals purchased by the Company. However, for minimising procurement risk for short duration, the Company enters into annual purchase contracts for key raw materials linked to input costs | published benchmark prices. ii) Exposure of the Company to commodity and commodity risks faced throughout the year: not applicable iii) Foreign exchange risks are tracked and managed within the risk management framework. Short-term foreign currency asset - liability mismatch is continuously monitored and hedged. The foreign exchange market is highly regulated and the Company ensures compliance with all the regulations. 5.9. Credit ratings Credit Analysis and Research Ltd maintained its credit rating at ‘AA+’ and stable outlook for long-term borrowings and ‘A1+’ for short-term borrowings. 6. Affirmation and disclosure There were no materially significant related party transactions, pecuniary transactions or relationships between the Company and its Directors or the Management and their subsidiary companies or relatives, among others, during 2021-22 that may have a potential conflict with the interests of the Company at large. All details relating to financial and commercial transactions where the Directors may have a pecuniary interest are provided to the Board. The interested Directors neither participate in the discussion nor vote on such matters.
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