Hatsun Agro Products Limited

• No evidence could be found of the company explicitly seeking to address nutrition through its commercial operations.

Aspects to improve • Hatsun is encouraged to develop and publish a clear plan or strategy on how it intends to deliver on contributing to healthy and nutritional diets in India through its commercial operations. For example, it could develop specific plans to improve the nutritional profile of its portfolio by, for example, decreasing average levels of nutrients of concern (sodium, saturated fats, and sugar), increasing levels of positive ingredients (such as whole grains or fruits and vegetables), or fortification of key products.
• To drive progress internally on implementing its nutrition strategy, the company is recommended to develop specific, measurable, and timebound targets encompassing various elements of its approach, and an overall target to increase sales of the products it defines as ‘healthier’.
• Hatsun is recommended to report more comprehensively on all elements of its approach, showing what has been achieved year-on-year across its portfolio or key product categories. Reporting should ideally take the form of quantitative metrics, rather than specific examples only, and progress documented systematically.
• To ensure that the strategy receives strategic direction from the top, the company is recommended to ensure that its nutrition strategy is subject to regular review at the highest levels of the company, and is encouraged to assign formal responsibility for the success of its nutrition strategy to its most senior officials.
• In developing its nutrition strategy and approach, and to ensure that it is maximizing its positive impact on public health, the company is strongly recommended to engage with independent experts/stakeholders, such as independent (i.e. not directly affiliated with industry) public health-oriented civil society organizations, academic institutions, (inter-)national organizations.

Category B2: Portfolio Development

• No evidence could be found of the company setting reformulation targets in India or reporting on these efforts.
• Hatsun did not share information with ATNI regarding its fortification approach in India.

Category B3: Nutrient Profiling

• The company did not provide evidence that it uses a nutrient profile model (NPM) or other objective nutrition criteria to evaluate the nutritional quality of its products to inform new product development or product reformulation.

Aspects to improve Category B2: Portfolio Development

• In order to drive progress on improving the healthiness of its portfolio, the company is encouraged to adopt specific, measurable, and timebound targets to reduce nutrients of concern (sodium, sugar, and saturated fat) across its relevant portfolio. These targets should ideally be aligned with the ICMR/National Institute of Nutrition (NIN) Dietary Guidelines and Recommended Dietary Allowances (RDAs) for Indians, and/or WHO guidelines, and are recommended to be published on the public domain.
• The company is recommended to report progress against all reformulation targets on an annual basis, in a consistent and easily accessible manner, in order to increase transparency and accountability.
• The company is strongly encouraged to produce more fortified products to help address specific micronutrient deficiencies in India (according to government priorities), while ensuring that there are strict internal policies and procedures in place to prevent the fortification or enrichment of unhealthy products (i.e. with high levels of fat, sugar, and/or sodium).

Category B3: Nutrient Profiling

• The company is strongly encouraged to adopt an NPM to determine the relative healthiness of all products in its portfolio.
• Ideally, this should be (or align closely with) an internationally recognized (or, when applicable, government-endorsed) NPM; if developing its own, the company is encouraged to apply stringent thresholds for nutrients of concern that align with (inter)national standards, and use 'per 100g/ml' as the reference unit (to ensure greater objectivity and comparability).
• The company is recommended to disclose all details of the NPM it uses in full, including the algorithm used to define ‘healthier’ products, on the company’s India website and, ideally, in a scientific journal that is peer-reviewed and indexed.

• No evidence of a strategy or approach to address the affordability specifically of its ‘healthier’ products was found on the company’s public domain or shared by the company.

Aspects to improve • To ensure that products that are considered by the company to be ‘healthier’ are being priced affordably for lower-income consumers, the company is recommended to:
- ensure that such products are defined as ‘healthy’ through the use of an NPM (or other clear nutrition criteria) - such that unhealthy products high in fat, salt or sugar (HFSS) are specifically excluded;
- have a clear approach to determining whether a product is ‘affordably priced’; and
- use a formal classification of ‘lower-income consumers’ that it is trying to reach.
• With these definitions and processes in place, the company is encouraged to develop and implement a strategy or approach for ensuring that at least part of its ‘healthier’ (and, ideally, fortified or micronutrient-rich) product portfolio is priced affordably for lower-income consumers, and continually explore new opportunities for delivering ‘affordable nutrition’. Examples of approaches can be found in the methodology and chapter for Category C.
• The company is recommended to publicly disclose information about its affordable nutrition strategies/approaches, including specific definitions, the approaches taken to ensure affordability, and the progress made on implementation.

• No evidence of a specific policy to address the responsible marketing of products to children or general audiences beyond legal requirements could be found on the company’s website.

Aspects to improve • The company is encouraged to develop and publish a comprehensive responsible marketing policy that covers all media channels and audiences, including children under the age of 18 (in line with Central Consumer Protection Authority (CCPA) guidelines).
• The company is encouraged to ensure more responsible marketing to children by adopting:
- audience threshold of 25% for limiting children’s exposure to advertisements on all media;
- specific commitments not to use certain materials and techniques to market their products to children, including celebrities, licensed characters, promotional toys and games, and depicting children on packaging.
• The company is encouraged to commission regular third-party audits of compliance to its responsible marketing policy in India, and to disclose the results of this audit, as well as the response mechanism it has in place to address instances of non-compliance.

• No specific mention of workforce nutrition could be found on the company’s public domain.
• No policy to support breastfeeding mothers in the workplace could be found, nor is it clear whether the company offers paid paternity leave.

Aspects to improve • The company is recommended to develop a workforce nutrition program that includes providing access to healthy food at work, nutrition education, nutrition-related health checks, and breastfeeding support. This program should ideally be available to all employees, including those at manufacturing sites.
• The company is encouraged to develop a clear policy on support extended to breastfeeding mothers at work in order to aid their maternal health; and this should apply equally to all office and production site employees. Support should, at a minimum, include i) Private, hygienic, safe rooms for expressing breastmilk; ii) Refrigerators in place to store milk; and iii) Other flexible working arrangements to support breastfeeding mothers, such as flexible working hours or on-site creche facilities. Furthermore, it is important to foster a workplace culture that is supportive of breastfeeding, for example through awareness campaigns.
• The company is recommended to offer maternity and paternity or second caregiver leave, extending parental leave policies to go beyond current national regulations, and remove limitations based on the number of children born.

• The company displays images of its products on its website showing both front-of-pack (FOP) and back-of-pack (BOP) across its product portfolio. However, these do not have sufficiently high image resolution and lacks zoom functionality, so the labels are too small and low quality to read.
• The company helps external parties find healthier varieties of its products on its website, showing ‘healthy snacking’ and ‘sugar free/ no added sugar’ product categories. However, these are limited in scope and it is unclear how the healthiness of the products shown is determined.

Aspects to improve • Once it is formally enacted by FSSAI, if the Indian Nutrition Rating (INR) FOP labeling system is on a voluntary basis, the company is strongly encouraged to adopt it across their entire portfolios in India.
• Additionally, the company is recommended to add comprehensive nutritional information tables to its product pages.

• The company has a 'Policy on Responsible Advocacy' in place, in which it commits to “Ensure that its advocacy position is consistent with its values… Conduct ethically the policy advocacy.” The Corporate Social Responsibility (CSR) Committee of the Board supervises the implementation of the Policy.
• In its 2021-22 Business Responsibility Report, the company states, in relation to ‘Responsible Advocacy’, that “Hatsun believes that it is our responsibility to help build a better business environment and an overall better world with ample opportunities for everyone. Our Promoters and Directors are constantly taking efforts to improve the general Public welfare.” However, no specific examples are provided, and no equivalent statement was found in its more recent Business Responsibility and Sustainability Report (2022-23).
• The company states that it is a member of only three trade associations (Indian Dairy Association (IDA), Indian Ice Cream Association (IICMA), and Tamil Nadu Chamber of Commerce (TNCC)). It states that the company is part of the governance bodies of several organizations, but does not disclose any specific examples.

Aspects to improve • The company is recommended to enhance its Responsible Advocacy Policy to require that the evidence presented shall always be as independent and representative as possible, and to always consider the wider public health interest in its efforts. It should also clearly define what it defines as advocacy interactions.
• The company is recommended to publish details about the governance of its policy engagement and advocacy in India, including roles and responsibilities within the organization, approval procedures, and tracking mechanisms. If these are not already in place, they should be developed.
• The company is encouraged to keep track of all engagements with policymakers with regards to nutrition-related policy and publish these on the public domain. At minimum, it should disclose specific examples of its “efforts to improve the general Public welfare” through its political engagement.
• The company is encouraged to publicly disclose its policy positions on key nutrition-related policy measures that are under debate or development in India that would likely affect the company (for example, FSSAI’s new FOP labelling system), even if the company is not engaging directly. These disclosures should be either on its website or in its reporting, ensuring that they are as specific and unambiguous as possible. These policy positions should consider the wider public health interest and long-term material implications of rising levels of malnutrition in India.
• The company should also assign to its Board oversight of the company’s advocacy positions and main activities, to further enhance the consistency of and accountability for its advocacy efforts.
• To further enhance transparency and signify to stakeholders which trade associations the company has greater stakes in, it is recommended to disclose which associations for which the company is part of “governance bodies”.