Environmental, Social

and Governance (ESG)

Policy
(Effective from April 22, 2023)
1. ESG Policy Statement

ICICI Bank has a rich legacy of innovation, market development, supporting new
technologies and social responsibility, and has always endeavoured to create a
positive impact on the economy, society and the environment. Ensuring the long-term
sustainability of the Bank’s business is a critical strategic objective.

Our Vision: To be the trusted financial service provider of choice for our customers,
thereby creating sustainable value for our stakeholders.

Our Mission: To grow our risk-calibrated core operating profit by

 Delivering products and services that create value for customers.
 Bringing together all our capabilities to seamlessly meet customer needs.
 Conducting our business within well-defined risk tolerance levels.

Our ESG Philosophy: To adopt sustainable business practices that ensure the long-
term success of the organization and have a positive impact on the environment and
society. The Bank endeavours to promote long-term sustainable growth in the
economy through business initiatives and responsible corporate citizenship.

2. ESG governance

The Risk Committee of the Board of Directors will have oversight on ESG in the Bank.
In addition to areas relating to risk management that are directly within the remit of
the Risk Committee, the Committee will review the Bank’s action plan on various
aspects of ESG, external reporting and stakeholder feedback.

Areas that are within the purview of other Board Committees shall continue to be
overseen by the respective Committees. Any updates relevant to ESG in these areas will
be presented to the Risk Committee.

Identification and implementation of ESG related initiatives shall be undertaken by the

Steering Committee comprising representatives of various functions within the Bank,
which shall be chaired by the Group CFO.

2
3. Key focus areas for ESG

A. Responsible financing

ICICI Bank is committed to creating a positive impact through its businesses

founded on the values of respecting human life and addressing the challenges to
the environment. In this regard:

 The Bank supports capacity creation in sustainable sectors like renewable

energy, waste management and energy efficiency, after appropriate risk-return
assessment.

 The Bank’s Social and Environmental Management Framework (SEMF) is used

for screening new project finance proposals. It stipulates environmental and
social due diligence requirements for projects above specific thresholds. It has
an exclusion list of industries not permitted for financing.

 The Bank is in the process of incorporating ESG and climate risk aspects as part
of the credit evaluation process. This will include assessing the ESG profile of
borrowers, their ESG related risks depending on the sector in which they operate
and related maturity in terms of policies and processes deployed to address
these risks.

 The Bank has adopted a Framework for Sustainable Financing to provide broad
guidance on what can be considered by the Bank as ‘Sustainable (Green/Social)’
/ ‘Sustainability-linked’ financing and covers eligibility criteria, process for
assessment and monitoring aspects.

 The Bank is committed to managing climate risks and enhancing related public
disclosures. The Bank’s approach to analysing climate risks would include
developing methods to integrate climate risk in the risk management framework
and begin testing the resilience of the lending portfolio to transition and physical
risks. The Bank will be aligned to national goals and targets in the nation’s
collective transition to a low-carbon economy.

 The Bank would responsibly participate in meetings or committees of trade

associations, industry bodies, government agencies, to facilitate public and / or
regulatory policy.

3
 B. Environmental sensitivity in the Bank’s operations

The Bank is committed to conducting its business sustainably and efficiently,

thereby reducing the environmental impact in its facilities. The key areas of focus
are digitization, minimizing greenhouse gas emissions, energy conservation,
water conservation, waste management and sustainable procurement.

 The Bank invests in providing digital solutions to customers and encourages

their adoption, thereby reducing usage of paper. The Bank also promotes
digitization of internal work and operations.

 The Bank invests in the construction and maintenance of sustainable and green
workplaces that are aligned to Indian Green Building Certification Standards,
wherever feasible.

 The Bank focuses on using energy efficient lighting and equipment at its
branches and offices and deploying equipment capacity optimization measures,
with effective recording, monitoring, audit and benchmarking of energy usage.
The Bank will aim to increase use of renewable energy sources, wherever
feasible.

 The Bank will continue to report Scope 1 and Scope 2 CO2 emissions and
emissions intensity. The Bank will work towards setting a time bound target for
reduction in emissions/reduction in emissions intensity or achieving carbon
neutrality in identified areas of its operations.

 Water conservation is a crucial part of sustainability. The Bank has adopted

measures for effective water management in its operations, including recycling
and reuse, and rainwater harvesting.

 The Bank has a robust process in place for management of waste, including
composting of organic waste in large premises, and recycling or handing over
of e-waste to authorized agencies which helps to comply with national and local
regulations in this regard.

 The Bank will strive to deploy sustainable procurement practices that are
integrated across the organization and across its value chain. This will include
conservation of natural resources, minimum or no use of hazardous or toxic
substances, compliance to local/national/international regulations,
considerations for safety of the user of product, examining recyclability or
reusability of products at the end of life, and promoting green certified/labelled
products.

 The Bank will engage with its suppliers and other vendors to create awareness
on business sustainability and minimizing the environmental impact of products
and services.

4
  The Bank will develop suitable mechanisms for monitoring progress against
approved targets and milestones and report to the relevant internal and
external authorities.

C. Customers

 The Bank is committed to the principle of “Fair to Customer, Fair to Bank” and
strives to ensure transparency in products sold by it.

 The Bank ensures continuous engagement with its customers through multiple
channels including relationship managers, branch employees, surveys, social
media and channels for raising queries and grievances.

 The “Customer Rights Policy” enshrines the five basic rights of customers of the
Bank. It spells out the rights of the customer and the responsibilities of the Bank.
These rights include Right to Fair Treatment; Right to Transparency, Fair and
Honest Dealing; Right to Suitability; Right to Privacy; Right to Grievance Redress
and Compensation.

 The Bank is committed to increased use of technology to provide services and

convenience to its customers. In this regard, the Bank complies with the
“Customer Relations Policy” which covers aspects of customer protection,
mechanism for creating customer awareness on the risks and responsibilities
involved in electronic banking transactions, timelines for effecting compensation
and the customer liability in such scenarios.

 Customer Service is a key focus area of the Bank. It believes that a satisfied
customer is the most important factor in developing our business. The Bank has
a “Customer Grievance Redressal Policy” that outlines the framework for
addressing customer grievances.

 The Bank has a “Customer Compensation Policy” that reflects the Bank’s on-
going efforts to ensure transparency and fairness in the treatment of customers.

D. Employees

The Bank is committed to adoption of fair employment practices. It ensures

diversity of workplace through efforts to recruit, develop and retain the most
talented people from a diverse candidate pool.

 The Bank is committed to a diverse and inclusive working environment across

all its operations. The Bank has a Diversity, Equity and Inclusion policy. The Bank
is an equal opportunity employer and does not differentiate based on cultures,
religions, caste, linguistic background, age, gender, and sexual orientation of
employees. The Bank believes in leveraging the strength of diversity at
workplace. This extends to all employees. Further, those who feel discriminated
are encouraged to raise their concerns through the grievance redressal
framework. The Bank’s commitment towards diversity and inclusivity also
extends to its stakeholders, including suppliers, customers, and vendors.

5
  The Bank believes in enhancing the skills of its employees in relevant areas. The
Bank provides opportunities for training and building talent, which is enabled
through various modes of training.

 Sexual harassment allegations are addressed as per the guidelines set under
the Prevention of Sexual Harassment at Workplace (Prevention, Prohibition &
Redressal) Act. This is imbibed in the Bank’s culture by creating awareness.

 The Bank is committed to a workplace which is free of harassment or

discrimination and has in place a mechanism for dealing with complaints on
harassment or discrimination. All such complaints are addressed with utmost
sensitivity and confidentiality.

 In the endeavour to provide a safe work environment, the Bank has a

comprehensive suite of benefits, including insurance cover to employees, health
and safety mechanisms and specially designed policies to meet the life-stage
needs of women such as child care leave, maternity leave, etc.

 The Bank is committed to maintaining a high standard of ethical and

professional integrity and fairness in all its dealings. We are committed to
promoting and respecting human rights and aim to provide a work environment,
which respects and upholds individual dignity.

 The Bank has policies keeping in mind the principles as laid down by the UN
Guiding Principles on Business and Human Rights, ILO Declaration on
Fundamental Principles and Rights at Work and UN Global Compact.

 The Bank has a succession planning process and measures the depth of
leadership bench at the senior leadership levels. The Bank aims to have a deep
bench for all key positions.

E. Society

 Guided by the principle of inclusiveness and equal opportunity, the Bank has a
long-standing commitment towards creating a positive impact on marginalised
segments of the society. In 2008, the Bank set up the ICICI Foundation for
Inclusive Growth (ICICI Foundation) as its philanthropic arm to have a dedicated
focus on these activities. Through ICICI Foundation, the Bank is engaged in
activities in the areas of skill development, rural livelihoods and value chain
development, creating sustainable economic ecosystems at the village level and
undertaking environmental and social projects that address critical
developmental gaps. The Bank will continue to focus on corporate social
responsibility (CSR) in compliance with applicable laws and regulations.

 Being a provider of financial services, enabling access to finance to the

unbanked and socially marginalised segments of society will continue to be a
priority for the Bank. This includes developing digital solutions for low income
customers along with a network of access points for these customers, as well

6
 as micro finance solutions for women micro entrepreneurs. The Bank also seeks
to improve access to banking and finance for micro, small and medium
enterprises, with significant emphasis on digital solutions for improved ease and
efficiency.

 The Bank strives to ensure that suppliers do not engage in activities that are
related to violation of human rights, child labour or forced labour, discrimination,
etc.

F. Corporate Governance

 The corporate governance framework at the Bank is based on an effective

independent Board, the separation of the Board’s supervisory role from the
executive management and the constitution of Board Committees to oversee
critical areas. Independent Directors constitute a majority on most of the Board
Committees and most Committees are chaired by independent Directors. The
Bank has identified the core skills/expertise/competence of the Board of
Directors as required under Section 10A(2)(a) of the Banking Regulation Act,
1949 in the context of its businesses and the sectors for it to function effectively
and has been in compliance with the same.

 The Bank’s Corporate Governance framework encompasses regulatory and

legal requirements. It includes the following policies, codes and procedures
implemented through its Board Committees, actively monitored by compliance,
risk oversight, and audit supervision.
o Group Code of Business Conduct and Ethics
o Whistle-Blower Policy
o Code of Conduct on Prohibition of Insider Trading
o Group Compliance Policy
o Group Arms-Length Policy in relation to related party transactions
o Anti-Bribery and Anti-Corruption Policy
o Code of Practices and Procedures for Fair Disclosure of UPSI
o Compensation Policy
o Group Anti-Money Laundering Policy

 The Bank advocates high level of risk and compliance culture across its
functions and activities. The Bank endeavours to disclose details of its
governance structure, elements of its key policies to its stakeholders through
secured channels like the Bank’s website, intranet, annual report, etc.

 The Bank will maintain transparency and make appropriate disclosures relating
to ESG, including meeting regulatory disclosure requirements.

7
 G. Cyber security and data privacy governance framework

The Bank’s cyber-security and data privacy governance encompasses

management oversight at various levels through Executive Committees with the
ultimate responsibility assumed by the Board and its Committees as shown in the
below table.

Board Committees IT Strategy Committee, Risk Committee, Audit

Committee

Executive Committees IT Steering Committee, Information and Cyber Security

Committee, Business Continuity Management (BCM)
Steering Committee, and the Privacy Steering
Committee

The Bank is committed to protecting the privacy of individuals whose personal

data it holds, and processing such personal data in a way that is consistent with
applicable privacy laws. Further, the Bank’s Personal Data Protection Standard
sets out how the Bank should handle personal data received from, or about, its
employees (including branch offices), actual or prospective clients, customers and
other third parties.

The Bank follows a comprehensive 360-degree approach to cyber security with

the triad of Confidentiality, Integrity and Availability (CIA) at the heart of the
information security framework. The approach covers all aspects of prevention,
detection and response.

The Bank will, in the best manner deemed feasible, endeavour to disclose the
governance structure and the broad approach adopted to managing risks
associated with cyber and data leakage.

H. Stakeholder engagement and accountability

The Bank believes in maintaining a transparent relationship with its stakeholders

and holds regular interactions with its investors, employees, customers,
regulators and other stakeholders. For the purpose, the Bank has set up suitable
mechanisms and channels for raising queries and grievances. The Bank will seek
to enhance its practices and disclosures on ESG, with a focus on the material
topics identified by stakeholders, on an ongoing basis.