Annexure II

TATA CODE OF CONDUCT (adopted across the Tata Group in1998-99)
(visit www.tatasteel.com for complete CoC)

Clauses pertaining to sustainability from Tata Code of Conduct (25 numbers total) are highlighted below:

National Interest (Clause#1)
A Tata Company shall be committed in all its actions to benefit the economic development of the countries in which it operates and shall not engage in any activity that would adversely affect such objective. It shall not undertake any project or activity to the detriment of the Nation’s interests or those that will have any adverse impact on the social and cultural life patterns of its citizens. A Tata Company shall conduct its business affairs in accordance with the economic, development and foreign policies, objectives and priorities of the Nation’s government and shall strive to make a positive contribution to the achievement of such goals at the international, national and regional level as appropriate.

Competition (Clause#3)
A Tata Company shall fully strive for the establishment and support of a competitive open market economy in India and abroad and shall co-operate in the efforts to promote progressive and judicious liberalization of trade and investment by a country.
Specially, a Tata Company shall not engage in activities, which generate or support the formation of monopolies, dominant market positions, cartels and similar unfair trade practices.
A Tata Company shall market its products and services on its own merits and shall not make unfair and misleading statements about competitors’ products and services. Any collection of competitive information shall be made only in the normal course of business and shall be obtained only through legally permitted sources and means.

Equal-Opportunities Employer (Clause#4)
A Tata Company shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, caste, religion, colour, ancestry, marital status, sex, age, nationality, disability and veteran status. Employees of a Tata Company shall be treated with dignity and in accordance with the Tata Policy to maintain a work environment free of sexual harassment, whether physical, verbal or psychological. Employee policies and practices shall be administered in a manner that would ensure that in all matters equal opportunity is provided to those eligible and the decisions are merit-based.

Gifts & Donations (Clause#5)
A Tata Company and its employees shall neither receive nor offer or make, directly or indirectly, any illegal payments, remuneration, gifts, donations or comparable benefits which are intended to or perceived to obtain business or un-competitive favours for the conduct of its business. However, a Tata Company and its employees may accept and offer nominal gifts, which are customarily given and are of commemorative nature for special events. Policy summarized in Annexure VII.

Political Non-Alignment (Clause#7)
A Tata Company shall be committed to and support a functioning democratic constitution and system with a transparent and fair electoral system in India. A Tata Company shall not support directly or indirectly any specific political party or candidate for political office. The Company shall not offer or give any company funds or property as donations, directly or indirectly, to any specific political party, candidate or campaign.

Health, Safety and Environment (Clause#8)
A Tata Company shall strive to provide a safe and healthy working environment and comply, in the conduct of its business affairs, with all regulations regarding the preservation of the environment of the territory in operates in. A Tata Company shall be committed to prevent the wasteful use of natural resources and minimize any hazardous impact of the development, production, use and disposal of any of its products and services on the ecological environment.

Quality of Products and Services (Clause#9)
A Tata Company shall be committed to supply goods and services of the highest quality standards backed by efficient after sales service consistent with the requirements of the customers to ensure their total satisfaction. The quality standards of the Company’s goods and services should at least meet the required national standards and the Company should endeavor to achieve international standards.