RISK MANAGEMENT

Mitigating risks.
Preserving value.

At JSW Steel, we have established a robust risk management framework to understand the dynamic externalities and devise ways of mitigating them. We follow the globally recognised ‘COSO’ framework of Enterprise Risk Management (ERM), which helps integrate internal controls into business processes. It also allows for a better understanding of the potential upside and downside of factors that can impact the organisation’s ability to create value.

We are cognisant of the fact that the emerging and identified risks need to be managed and mitigated in order to

  • Protect our shareholders and other stakeholder’s interests
  • Achieve our business objective
  • Enable sustainable growth

Pursuant to the requirement of Regulation 21 of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 and Companies Act, 2013, we have a robust risk management framework in place. A sub-committee of Directors oversee the ERM framework to ensure it addresses the following:

  • Intended risks are taken prudently so as to plan for the best and be prepared for the worst
  • Execution of decided strategies and plan with focus on action
  • Unintended risks such as performance, incident, process and transaction risks are avoided, mitigated, transferred (as in insurance) or shared (like through sub-contracting). The probability or impact thereof is reduced through tactical and executive management, policies, processes, inbuilt systems controls, MIS and internal audit reviews, among others.

Strategic risks

R1

The COVID-19 pandemic

Due to the consecutive second and third wave of the COVID-19 pandemic, global and domestic economic revival remained under stress. Human lives continue to be at risk from virus mutation.

Response

We have continued to take precautionary and proactive measures to control the spread of coronavirus among our workforce across all our sites and offices. Various measures are being taken such as:

  • Strict adherence to guideline issued by various Government authorities
  • Compulsory wearing of masks and following COVID appropriate behaviour at plants and offices
  • Random testing of staff returning from outstation travel
  • Setting up quarantine centres across all plant locations

These initiatives have helped us manage the pandemic risk. Vaccination remains key to combating the COVID-19 pandemic. During the year, we organised various vaccination drives across all our plant locations and offices for employees in collaboration with local hospitals. As on date, almost the entire staff, including associates, are fully vaccinated

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R2

Geopolitical scenario – the Russia-Ukraine conflict

Due to the geopolitical tension and war, oil and natural gas prices have increased and are expected to further drive up logistics costs, resulting in higher inflation. Prices of key raw materials such as coking coal, iron ore, ferro alloys and zinc are also expected to increase.

Response

We are continuously monitoring the situation. The risk is being managed by

  • Broadening sourcing options – different geographies, multiple vendors
  • Prudent hedging strategies to mitigate the foreign exchange fluctuation risk
  • Various contract options like long-term contracts and monthly/quarterly/spot contracts for cost effectiveness

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R3

Intensifying competition and ability to market increasing volumes

Steel in India is a highly competitive industry, and we have to compete with other Indian integrated steel manufacturers in varying degrees. Domestic steel producers have responded to competition by raising their manufacturing capacity in the past. Growing consolidation in the steel industry worldwide may lead to global steel producers adding to the competition. Many of these international producers, with ample financial and other resources at their disposal, have announced their intention to establish manufacturing operations in India. The contest, as a result of acquisitions and consolidation in the industry, driven by the IBC process and capacity expansions may result in stressed profitability.

Response

  • The domestic market is likely to see healthy steel demand due to
    • The Government’s thrust on infrastructure development through a capex outlay of ₹7.5 lakh crore, as announced in the Union Budget 2022-23
    • Plans for 25,000 km national highway expansion, affordable housing, manufacture of 400 new Vande Bharat trains, eight ropeway projects and other projects will drive demand

Expanding market share and customer retention through

  • Developing strong customer relationship and gaining brand equity
  • Focus on new product development and value-added special steel segments
  • Exports to various countries across various geographies
  • Focus on high potential areas where our presence via Shoppe Connect can be increased to widen customer base

Leveraging channel financing and micro credits for providing additional liquidity

Continued focus on cost, which has made us one of the lowest conversion cost producers in the world, and timely response on cost control to stay competitive

R4

Competitive dynamics and industry cyclicality

As in the case of most commodity-intensive industries, operating margins in the steel industry are affected by sales realisation and fluctuations in demand and supply of steel products.

Due to the competitive market dynamics, the following reasons can affect sales and margin:

  • Adverse global and domestic demand- supply dynamics
  • Cyclical nature of the steel industry
  • Unfair trade practices resulting in a surge in imports
  • Trade barriers imposed by countries like the US and some European countries

Response

  • Trade sanctions on Russia by the US and EU amid the Russia-Ukraine war would improve export opportunities for the Indian steel industry; EU imports around 30 MnT of steel, of which 20% is from Russia
  • Due diligence review carried out before dealing with unknown markets
  • Better market intelligence with inputs from the marketing team
  • Our agile strategy of switching between exports and domestic sales in line with shifting demand patterns
  • Widening and deepening customer reach in domestic and international markets, which gives the flexibility to switch between domestic to export market and vice versa
  • Expected to achieve 50% of sales from value-added products
  • Competitive strength of our specialised, value-added and branded steel portfolio including tinplate, galvanised, and galvalume among others, together with our responsive credit and pricing policy

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R5

Raw material availability and cost – Iron ore and Coking coal

Our primary raw materials iron ore and coal; our operations also require raw materials such as various types of limestone, alloys, refractories, oxygen, fuel and gas. The price and availability of raw materials may be adversely affected by factors beyond our control, including interruption in production by suppliers, demand for raw materials, change in supplier allocation, price and currency fluctuations, policy changes and transport costs, etc.

The current uncertain external environment, high costs of iron ore and coking coal are impacting our margins. Iron ore and coking coal availability also depends on:

  • Global movement and parity of landed cost considering price, freight, tariff and exchange rates
  • Government policies on mining, allocation and tariff
  • Domestic demand-supply gap, constraints and vendor actions
  • Risk of production stoppage due to non-availability of coking coal as we are solely dependent on coking coal imports
  • Uncertainty in availability given that no major additional capacities are being added globally

Response

Iron ore

  • Iron ore requirement at our Vijayanagar and Dolvi plant is primarily met by iron ore mines owned by us in Odisha and Karnataka; which have significantly reduced our dependence on imported iron ore
  • We are exploring iron ore from different international sources as imported iron ore on value-in-use basis has productivity gains, which to a large extent offset the difference in price

Coking coal:

  • Prices are expected to remain volatile in view of the global geopolitical events
  • Considering buying on Annual Rate Contract where the price is linked to TSI and PLATTS Index
  • Diversifying sources across various geographies to ensure availability of coking coal and minimise the impact of rising prices

R6

Mining

Risk of non-achievement of production target due to over-dependence on Mining Development Operators (MDO)

  • MDO’s work may be impacted by non-availability of finance and workers

Response

We have deployed two different MDOs in four of our mines:

  • The Mining Service Contract (MSC) provides for Risk purchase clause, performance bank guarantees and termination of MDO for poor performance
  • We also have plans to deploy own mining equipment

R7

Foreign exchange and interest rate fluctuations

Foreign exchange rates have been volatile and given that we incur costs in one currency and generate sales in another, our profit margins may be affected by exchange rate changes between two currencies. Interest rate increases in the key global economies could slowdown foreign currency inflows into the country, which could affect the value of domestic currency and interest rates and thus, adversely impact our ability to secure financing on favourable terms. High borrowing cost has the potential to impact profitability.

Response

  • A robust hedging policy in place to mitigate the risk of currency and commodity fluctuations
  • Hedging strategy with a judicious mix of forwards and options
  • Optimum mix of fixed and floating interest rate for borrowings
  • In order to mitigate the risk of increasing interest rate, we have converted some of the floating rate FCL to fixed; accordingly, we have taken the Interest Rate Swap (IRS)

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R8

Mergers and Acquisitions

We continue to explore strategic acquisition opportunities. However, such acquisitions in the future may result in a material increase in debt, may be difficult to integrate, and may not be value accretive. In certain instances, they may have adverse material impact on our financial position or results of operations. We run the following risks:

  • Risk of acquisition at value greater than fair value may impact Return On Capital Employed (ROCE); and thus adversely impact debt and interest servicing
  • Challenges in turn around and scale up or delay may drag the profitability
  • Litigation may impact earnings and erode stake holders value

Response

  • Conduct site visit of targeted acquisition
  • Carry out due diligence that mainly includes finance, tax and legal aspects; this helps identify risks and plan strategies for mitigation
  • Design finance model taking input from strategy, business development to decide on the optimum mix for capital structure
  • We have a very conservative approach in bidding to ensure that the net debt to EBITDA and net debt to equity are maintained below the threshold levels
  • Leverage cost leadership strength in merged entity

R9

Infrastructure and logistics

Disruption in the transportation of goods and supplies, electricity grid, communication systems or any other public facility could impact normal business activity and add to costs by adversely impacting financial condition and cash flows.

Various factors can affect the movement of inbound quality raw materials and outbound goods such as:

  • Port congestion, channel blockage, disrupted unloading/loading infrastructure, rail and road connectivity
  • Storage and material handling (RMHS) system, which protects material from exposure to weather or our metallurgical property, may be disrupted
  • Geopolitical tensions such as that between Russia and Ukraine pose challenges to container availability, resulting in higher freight charges

Response

Infrastructure improvement has been undertaken to ensure seamless flow of inbound material and outbound goods. Some of these are:

  • Higher capacity barges (River Sea vessels or RSV) for transportation of inbound raw material and outbound finished goods; and to ease the logistics constraints on road movement
  • Additional rail/road entry and exit points for enhanced volumes planned at all locations being expanded
  • Bogie Versatile Coil Wagon (BVCW) deployed at Vijayanagar for loading HR/CR Steel Coils (Hot rolled/Cold rolled)
  • Additional storage yards for iron ore fines and coking coal
  • Extension of jetty length and additional barge unloaders at Dharamtar port to cater the additional raw material requirements at Dolvi due to expanded capacity
  • Higher freight charges being addressed through rate negotiation with shipping companies on a quarterly basis and catering export orders by converting container shipments to break-bulk

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Operational risks

R10

Environment protection and climate change

The steelmaking process involves emission of CO2, dust and other co-products gases/waste (slag) that pose a risk to environment and sustainable growth. At the COP26 summit, India has committed to achieve net zero emissions by year 2070. In India, as elsewhere, climate action is intensifying but any drastic change in carbon emission regulations may adversely impact our business and operations.

Compliance with new and more stringent environmental obligations related to greenhouse gas (GHG) emissions may require additional capital expenditure or modifications in operating practices and additional reporting obligations.

Capacity expansion projects require adherence to legal requirements like environmental assessments, environmental impact studies and/or plans of development before commencing work. It has also resulted in water being a risk to our operations. Expiration or delay in approvals could prevent us from carrying out our operations in full.

Response

  • We are complying with all the applicable norms through use of best-in-class technology
  • We select the right equipment, technology, processes, inputs and we track our emissions. Additional capex allocation for advanced technologies like MEROS in sinter to further reduce dust emissions
  • Introduction of innovations such as Carbon Capture and Utilisation and to recover carbon and divert to different applications
  • For our mining operations, we have undertaken comprehensive Reclamation & Rehabilitation (R&R) programmes, in line with government mandates, and ensuring preservation of biodiversity and structural stability, among others
  • Building waste gas recovery plants
  • Deploying highly efficient molecular sieves
  • We regularly track changes in technology and future norms to plan in advance. We are exploring the use of steam box ageing technology to treat BOF slag that would be generated after proposed expansions at Vijayanagar and Dolvi
  • We disclose information related to carbon emissions, renewable energy utilised and circularity of projects under various initiatives such as Carbon Disclosure Programme (CDP) and Dow Jones Sustainability Index (DJSI), along with public disclosures in the annual integrated report
  • We lay thrust on sustainable products that are safe for consumers. We have developed products that are environment friendly and safe for usage like high strength low carbon steel, low thickness steel used in auto sector that makes the vehicle lighter and helps in reducing the carbon footprint as well as safety of travellers.
  • As part of our water stewardship approach, we have implemented water efficient technologies that help us conserve, reuse and recycle water, enabling judicious use of the resource.

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R11

Occupational health and safety

Extensive health and safety laws, regulations and standards are in place for the steel industry. Associated hazards include accidents involving moving machinery, on-site transport, forklifts and overhead cranes; explosions and resulting fires. These may lead to severe damage or destruction of property, equipment and environment and cause personal injury or even fatalities among our personnel. In consequence, there may be temporary or lengthy interruptions in operations, damage to our reputation and corporate image and perhaps even civil and criminal liabilities.

Response

  • Ensuring compliance with local and international laws, regulations and standards with a primary focus on protecting employees and communities from harm and operations from business interruptions
  • Construction guidance notes released for 10 critical activities to improve construction safety
  • Periodic safety training, mandatory usage of safety gadgets such as safety shoes, helmets, hand gloves, masks on shop floor and plants
  • External, detailed Fire Prevention Audit carried out at all downstream units
  • British Safety Council 5 Star Audit Gap analysis conducted at Salem Plant
  • Safety made a mandatory Key Result Area (KRAs up to 15%) for employees, requiring them to undergo mandatory classroom/online learning sessions on safety with an assessment test to check the level of learning
  • Employee Assistance Program (We care) undertaken in partnership with a leading service provider to provide psychological and emotional counselling support to employees
  • Monthly apex safety meetings are held for review of safety aspect, fatal accidents/near miss accidents, if any
  • Medical facilities, mediclaim policy cover for employees and their families; Group insurance policy for employees
  • Strong security arrangements like security check-post, entry pass/identity cards, access control system, CCTVs at critical locations

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R12

Human resources

Human capital with requisite skillset and experience is critical to maintain the current level of operations and upcoming expansion at plants. While we consider our labour relations to be good, we cannot discount future disruptions in operations due to disputes or other problems with employees.

Response

  • Senior leadership support in setting the tone at the top
  • Strong HR policies and processes in place for hiring and retaining talent
  • Robust performance management system to reward performers, which helps attract and retain talent
  • Group-wide employee re-designation exercise done in alignment with the market scenario
  • JSWSL OPJ Samruddhi Plan 2021, our ESOP plan launched for employees to retain talent
  • Candid Conversation programme for enabling greater interaction between employees and senior leaders so as to build strong relationships
  • A separate pool of employees identified across bands for grooming for next level roles through specially designed Future-Fit Leadership Development programmes from IIM Ahmedabad, ISB Hyderabad and Cornell University, US
  • Gender diversity initiative ‘Springboard’ launched for high-performing female employees to encourage leadership development at IIM-Bangalore
  • Online learning courses for employees in collaboration with M/S Skill-soft to develop project management, team building, communication and other skills

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R13

Cyber security

Our extensive digital projects are exposed to a wide array of cyber risks. Digital security is paramount to ensuring seamless operations since a potential breach could lead to loss of process control and impact day-to-day functions.

Cyber security risk could damage reputation and lead to financial loss. Such threats arise from:

  • Theft of corporate information
  • Theft of financial information (e.g., financial results and bank details)
  • Ransomware – cyber extortion
  • Disruption to business (e.g., inability to carry out SAP transactions, online payments)
  • Loss of business or contract

Response

  • All the Information technology management system confirms to ISO 27001:2013
  • Controlling system vulnerability through:
  • Vulnerability assessment and penetration testing for all public facing assets
  • Firewall hardening rule sets implemented
  • Firewall remediation tool deployed and improvements done in identified areas
  • Breach assessment through:
  • Strengthening the cyber security posture; carried out self-assessment and continuous monitoring going on
  • Third-party view and peer comparison undertaken
  • Breach assessment done with subject expert partners
    • Incorporating cyber security and privacy into everyday business decisions and processes
    • Cyber security awareness programme conducted across all the locations in view of growing threats of cyberattacks due to increased online trades and transactions
    • Progress of cyber security roadmap being tracked periodically
    • Monitor threats and respond, investigate and remediate cyber security related incidents and data breaches

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