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COMPLIANCE AND ETHICS

Built on a strong foundation

Our business actions and practices are underpinned by good governance, ethical practices and effective control and accountability.

Compliance

Tata Steel considers compliance as the foundation of corporate management. Compliance is integral to our value system and Tata Steel takes its compliance obligations with utmost seriousness, as part of its efforts to establish even stronger relationships of trust with society, customers, and stakeholders. The Company endeavours to manage its businesses responsibly and in compliance with the statutory requirements of the locations in which it operates, and the Management envisages to serve as the anchor and play a pivotal role in implementing the compliance interventions.

With Tata Steel set to achieve 40 MnTPA by 2030, the focus is on establishing an integrated compliance programme which will enable us to review business risk to strategy and its execution not just from operations standpoint, but also from compliance perspective. The function has adopted a 10-step holistic Compliance Framework, which brings about a paradigm shift, from monitoring compliance based on compliances listed in the compliance tool, to a business process-driven approach for ensuring compliances. The Compliance Framework is designed to bring forth advanced compliance infrastructure, compliance content that is par excellence, sector specific insights, global trends on managing compliances and keeping the Compliance Management Framework future-ready.

The function is headed by the Company Secretary & Chief Legal Officer (Corporate & Compliance), who is primarily responsible for overseeing and managing regulatory compliances. The function is adequately staffed with compliance managers who are responsible for establishing business and industry-specific standards in all units across the organisation. Adherence to compliance obligations is among the subjects covered in audits by the Tata Steel Internal Audit function. Observations from such audits are placed before the Audit Committee and the Board of Directors.

10-step holistic Compliance Framework

Overarching framework towards achieving Compliance Assurance

Corporate Ethics

Tata Steel strives for global leadership in standards of ethics. We are laying a future-ready culture based on the strong foundation of Tata Values, Tata Code of Conduct (TCoC) and its principles that enable excellence. This involves cultural transformation, focussing on people, digitalisation, innovation, and driving excellence through a performance focus bringing agility at every level for faster decision-making, and strengthening of deployment through effective implementation. TCoC is deployed through a formalised Management of Business Ethics (MBE) framework that reflects our commitment to shared values and principles.

Deployment methods
  • Well-defined vigil mechanism
  • Guidelines and policy formulation
  • Awareness through communication
  • Training
  • Extensive use of IT tools and platforms
  • Feedback-based actions

Leadership Engagement

The Chief Ethics Counsellor has the overall responsibility of driving MBE initiatives and reports to the CEO & MD, who is also the Principal Ethics Officer. Apart from the dedicated ethics department, the extended arms of the Chief Ethics Counsellor include Divisional Ethics Coordinators, Departmental Ethics Coordinators (DECs), and Ethics Champions. Tata Ethics Torch Bearers (TETB) have been identified at TSM and local POSH representatives have been introduced as extended arms of Internal Committee (IC) members. The Senior Leadership Team (SLT) leads in communicating from the front in various forums, addressing different stakeholders across divisions and ensuring open and transparent culture.

Compliance Structure

  • A robust vigil mechanism, where deployment of policies is tracked and reviewed digitally
  • ‘Speak Up’ - a third-party whistle blowing helpline, root cause analysis of identified concerns, and robust Consequence Management Framework (CMF) to ensure stakeholder confidence in the whistle blowing process
  • Mobile-enabled Ethics Compliance Register with annual disclosures questionnaire to mitigate associated risks, declaration of gifts (giving and receiving), hospitality, and travel
  • Onboarding of third party (a subject matter expert) has been done for due diligence of business associates (BA)

The GoodnessXchange

Tata Steel’s first-ever, internal, online auction for charity, auctions gifts received by employees that are beyond the acceptable criteria

Kashmakash

An online platform to resolve ethical dilemma where one may choose to remain anonymous and remain connected for response

Communication & Training

Innovative and diverse approaches/ tools used for communicating policies/ guidelines including Neeti Katha / Neeti Sanchaar snippet stories, quizzes and polls, campaigns, speaker sessions and celebrations. Violation cases are circulated to SLT and open forum discussions are regularly held. Collaborative approach with other teams such as Safety and HRM is also undertaken for communication and Training.

Steel O Sphere

A pan-India distributor meet on ethics and sustainability organised

Measurement of Effectiveness

The effectiveness of the ethics programme is measured by the number of concerns reported, poll surveys, MBE survey, benchmarking exercises and internal MBE assessments. The feedback is incorporated into the annual plan for MBE deployment.

Samman

Initiative launched to address feedback on perceptions of ethics deployment at Tata Steel consisting of various programs and communications.