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3. |
Scope |
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a) |
This Policy is
an extension of the Tata Code of
Conduct. The Whistle Blower's role
is that of a reporting party with
reliable information. They are not
required or expected to act as
investigators or finders of facts,
nor would they determine the
appropriate corrective or remedial
action that may be warranted in a
given case. Whistle Blowers provide
initial information related to a
reasonable belief that an improper
or unethical practice has occurred. |
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b) |
Whistle Blowers
should not act on their own in
conducting any investigative
activities, nor do they have a right
to participate in any investigative
activities other than as requested
by the Ethics Counsellor or the
Audit Committee or the
Investigators. |
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c) |
Protected
Disclosure will be appropriately
dealt with by the Management /
Ethics Counsellor / Audit Committee,
as the case may be. |
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4. |
Eligibility |
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a) |
All Employees of
the Company are eligible to make
Protected Disclosures under the
Policy. The Protected Disclosures
may be in relation to matters
concerning the Company. |
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5) |
Disqualifications |
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a) |
While it will be
ensured that genuine Whistle Blowers
are accorded complete protection
from any kind of unfair treatment as
herein set out, any abuse of this
protection will warrant disciplinary
action. |
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b) |
Protection under
this Policy would not mean
protection from disciplinary action
arising out of false or bogus
allegations made by a Whistle Blower
knowing it to be false or bogus or
with a malafide intention. |
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c) |
Whistle Blowers,
who make three or more Protected
Disclosures, which have been
subsequently found to be mala fide,
frivolous, baseless, malicious, or
reported otherwise than in good
faith, will be disqualified from
reporting further Protected
Disclosures under this Policy. In
respect of such Whistle Blowers, the
Company/Audit Committee would
reserve its right to take/recommend
appropriate disciplinary action. |
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6) |
Procedure |
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a) |
All Protected
Disclosures concerning financial /
accounting matters should be
addressed to the Chairman of the
Audit Committee of the Company for
investigation. |
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b) |
In respect of
all other Protected Disclosures,
those concerning the Ethics
Counsellor and employees at the
levels of Vice Presidents and above
should be addressed to the Chairman
of the Audit Committee of the
Company and those concerning other
employees should be addressed to the
Ethics Counsellor of the Company. |
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c) |
The contact
details of the Chairman of the Audit
Committee and of the Ethics
Counsellor of the Company are as
under:
Mr. P.K. Kaul, House No. 225, Sector
15-A, Noida (UP) 201 301.
Mrs. Rekha Seal, Ethics Counsellor,
Tata Steel Ltd. Jamshedpur 831 001.
E-mail adds: ethics.counsellor@tatasteel.com
and mail@ethics.com |
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d) |
If a protected
disclosure is received by any
executive of the company/Vigilance
Group of the Company other than
Chairman of Audit Committee or
Ethics Counsellor, the same should
be forwarded to the Company's Ethics
Counsellor for further appropriate
action. They must take appropriate
care so that the identity of the
Whistle Blower does not get divulged
in the process. |
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e) |
Protected
Disclosures should preferably be
reported in writing so as to ensure
a clear understanding of the issues
raised and should either be typed or
written in a legible handwriting in
English, Hindi or in the regional
language of the place of employment
of the Whistle Blower. |
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f) |
If the protected
disclosure is received by the
Chairman of the Audit Committee, he
shall detach the covering letter and
forward only the Protected
Disclosure to the Ethics Counsellor
of the Company for investigation. |
