Independent Assurance Statement

Introduction

GAIL (India) Limited {(hereinafter abbreviated as “GAIL”} has engaged “Bureau Veritas” for carrying out an independent assurance of their Sustainability Report (“Report”) for the reporting period from 1 April 2021 to 31 March 2022. The assurance has been conducted in accordance with the requirements of Assurance Standard AA1000AS-v3 and GRI Standards.

The facilities covered for this assurance are GAIL’s Gas Processing units at five locations (Pata, Vijaipur, Vaghodia, Gandhar), one Petrochemical Plant at Pata, eight Natural Gas Compressor stations (Hazira, Vaghodia, Jhabua, Khera, Vijaipur, Dibiyapur, Kailaras & Chhainsa), ten LPG pumping / receiving stations (Loni, Mansarampura, Nasirabad, Abu Road, Samakhiali, Jamnagar, Kandla, Vizag, G Konduru and Cherlapalli), eight Regional pipeline offices (NCR, Baroda, Mumbai, Puducherry, Rajahmundry, Agartala and DBPL), office buildings at Corporate office New Delhi, two GAIL Training Institute (GTI) (Noida & Jaipur) and Offices at Jubilee Tower, Info-Hub at Noida and Zonal Marketing offices.

Limitations

The assurance is subject to limitations of disclosures other than those mentioned under the scope, data and information outside the defined reporting boundary, data related to Company’s financial performance and strategy and other related linkages expressed in the Report. The scope of assurance does not cover the statements in the Report that describe company’s approach, strategy, aim, expectation, aspiration or beliefs or intentions, competitive claims in the report (“first in India”, “first time in India”, “first of its kind”, etc) if any.

Assurance does not extend to the activities and operations of “GAIL” outside of the scope and geographical boundaries mentioned in this report as well as the operations undertaken by any other entity that may be associated with or have a business relationship with “GAIL”.

Independence

No member of the assurance team has a business relationship with “GAIL”, its Directors, Managers or officials beyond that required of this assignment. We have conducted this verification independently and there has been no conflict of interest. The assurance team has extensive experience in conducting assurance over environmental, social, ethical and health & safety information, systems and processes an excellent understanding of Bureau Veritas standard methodology for the Assurance of Sustainability Reporting.

GAIL’s responsibility

GAIL is responsible for preparing the Report in accordance with GRI Standards and for maintaining effective internal controls over the data and information disclosed.

Verifier’s responsibility

The assurance statement is made solely for “GAIL” as per the governing contractual terms and conditions of the assurance engagement contract between “GAIL” and Bureau Veritas. To the extent that the law permits, we owe no responsibility and do not accept any liability to any other party other than “GAIL” for the work we have performed for this assurance report or for our conclusions stated in the paragraph below.

Scope and level of assurance

BUREAU VERITAS has been engaged to provide Moderate Level Type 2 Assurance for the following:

  • Adherence to the principles of inclusivity, materiality and responsiveness laid out in AA1000AS v3
  • Adherence to the principles of accuracy, balance, clarity, comparability, reliability and timelines laid out in the “In Accordance- Comprehensive” reporting requirements of GRI standards.
  • Adherence to General disclosures and Topic specific disclosures for “In Accordance- Comprehensive” reporting requirements of GRI standards as follows:

General Disclosures and Management approach (GRI 102, GRI 103)

The reported information on General Disclosure along with Management approach as per disclosure requirements for ‘In Accordance’ – Comprehensive option of reporting.

  • Disclosures 102-1 to 102-13 (Organizational profile)
  • Disclosures 102-14 and 102-15 (Strategy)
  • Disclosures 102-16 and 102-17 (Ethics and integrity)
  • Disclosures 102-18 to 102-39 (Governance)
  • Disclosures 102-40 to 102-44 (Stakeholder engagement)
  • Disclosures 102-45 to 102-56 (Reporting Process)
  • Disclosures 103-1 to 103-3 (Management Approach)

Topic Specific Disclosures

Performance Indicators for identified material topics as below:

Economic:

  • Disclosures 201-1 to 201-4 (Economic performance)
  • Disclosures 202-1 and 202-2 (Market Presence)
  • Disclosures 203-1 and 203-2 (Indirect economic impacts)
  • Disclosures 204-1 (Procurement practices)
  • Disclosures 205-1 to 205-3 (Anti- corruption)
  • Disclosures 206-1 (Anti-competitive behavior)

Environmental:

  • Disclosures 301-1 to 301-3 (Materials)
  • Disclosures 302-1 to 302-5 (Energy)
  • Disclosures 303-1 to 303-5 (Water and Effluents)
  • Disclosures 304-1 to 304-4 (Biodiversity)
  • Disclosures 305-1 to 305-7 (Emissions)
  • Disclosures 306-1 to 306-5 (Waste)
  • Disclosures 307-1 (Compliance)
  • Disclosures 308-1 and 308-2 (Supplier environmental assessment)

Social:

  • Disclosures 401-1 to 401-3 (Employment)
  • Disclosures 402-1 (Labour/management relations)
  • Disclosures 403-1 to 403-10 (Occupational health and safety)
  • Disclosures 404-1 to 404- 3 (Training and education)
  • Disclosures 405-1 and 405-2 (Diversity and equal opportunity)
  • Disclosures 406-1 (Non-discrimination)
  • Disclosures 407-1 (Freedom of association and collective bargaining)
  • Disclosures 408-1 (Child labor)
  • Disclosures 409-1 (Forced or compulsory labor)
  • Disclosures 410-1 (Security practices)
  • Disclosures 411-1 (Rights of Indigenous peoples)
  • Disclosures 412-1 to 412-3 (Human right assessment)
  • Disclosures 413-1 and 413-2 (Local communities)
  • Disclosures 414-1 and 414-2 (Supplier social assessment)
  • Disclosures 415-1 (Public policy)
  • Disclosures 416-1 to 416-3 (Customer Health and Safety)
  • Disclosures 417-1 to 417-3 (Marketing and labeling)
  • Disclosures 418-1 (Customer Privacy)
  • Disclosures 419-1 (Socioeconomic compliance)

Activities undertaken

Bureau Veritas undertook the following activities for this assurance:

  • Interviews with relevant environment & sustainability team of GAIL
  • Site visits conducted at following locations – GAIL’s Corporate Office at New Delhi, Jubilee Tower at Noida, GAIL Training Institute (GTI) at Noida, GAIL Training Institute (GTI) at Jaipur, five operational sites located in India i.e. Gas Processing unit and Petrochemical Plant at Pata (UP), Gas Processing Unit and Compressor Stations at Vijaipur (MP) and Vaghodia (Gujarat) and Mansarampura (Rajasthan) and virtual audit conducted at Mumbai and Compressor Station at Hazira (Gujarat).
  • Review of documentary evidence produced by GAIL.
  • Review of performance data provided in the Report and related worksheets on a sampling basis and data trail to its source
  • Review of GAIL’s data and information systems for collection, aggregation, analysis of data.
  • Review of stakeholder engagement activities by a review of the records maintained in respect of the stakeholder engagement workshop facilitated by GAIL.
  • Review of the Report to check alignment of reported data under respective economic, environment & social topics mentioned in GRI Standards.

Conclusion

Based on the Moderate Level Type 2 Assurance procedures conducted and evidence obtained, nothing has come to our attention that causes us to believe that, in all material respects the Report is not in conformance with the reporting requirements of GRI Standards and AA1000AS v3. The report meets the requirement of reporting as specified by GRI Standards “In Accordance Comprehensive” Option.

Observations and Recommendations

  • Principle of Inclusivity: GAIL has applied the principle of inclusivity in engaging with its stakeholders. Different departments engage regularly with their relevant stakeholders through multiple engagement channels.
  • Principle of Materiality: GAIL has followed a structured process of materiality determination to report key material issues.
  • Principle of Responsiveness: GAIL has applied the principle of responsiveness with respect to its stakeholders. Company has well defined system for responding to any concern raised by key stakeholders.
  • Principle of Impact: GAIL has identified, measured and disclosed the impact related with some of the key environmental, social and governance topics.

Without affecting the overall conclusions on the Report, the following recommendations are made:

  • GAIL may consider developing SOPs for regular monitoring of fugitive methane emissions at all sites/ pipeline
  • GAIL may look to reduce its direct NG venting
  • GAIL may consider updating its SOP for GHG emissions calculation to incorporate latest emission factors
  • GAIL may consider updating its data collection software, including template for scope 3 data collection
  • GAIL may consider undertaking climate change analysis (scenario analysis) and risk assessment for all its sites in line with TCFD
  • GAIL may consider conducting independent research on biodiversity and other related topics present in its operational boundaries, including an examination of the species that are on the IUCN List and national conservation lists
  • GAIL may consider conducting life cycle assessment (LCA) of all its products to identify environmental impact and risks associated with its products
  • GAIL may consider developing a framework for conducting routine and systematic environmental and social impact assessments at both the corporate and site levels
  • GAIL may consider developing a standardized manual, for calculations and assumptions regarding water balance calculations. In addition, SOPs for monitoring of quality and quantity of recycled water can also be developed for all sites