INDEPENDENT ASSURANCE REPORT

To,
The Board of Directors,
The Tata Iron and Steel Company Limited,
Bombay House, 24 Homi Mody Street,
Mumbai - 400 001
India.

Introduction

We have been asked to provide assurance on selected data, graphs and statements of the The Tata Iron and Steel Company Limited ("Tata Steel") contained in the Corporate Sustainability Report ("Report") for the period 1st April 2003 to 31st March 2004. The scope included providing assurance on:

  1. The scope of the report/stakeholder engagement
  2. Reporting systems and frameworks
  3. Company policies
  4. Governance structure and arrangements
  5. Management systems and processes

The Report of Tata Steel has been produced both electronically and in print. The Corporate Sustainability Report 2003-04 and its contents are the responsibility of the management of Tata Steel, whilst the Independent Assurance Report, based on our assurance work performed, is the responsibility of PricewaterhouseCoopers Private Limited.

Select Sustainability Performance Indicators: Scope of the Review

In keeping with the objectives, we selected sustainability-economic, environmental and social- performance indicators for review by considering the key sustainability risks of Tata Steel and its subsidiary companies as well as by identifying those sustainability indicators most relevant to management and stakeholder-decision making processes. The selection of indicators was further contingent on our experience of the associated sustainability reporting systems and processes. Accordingly, the scope of our review included:

  1. Review of certain statements and data relating to the Tata Steel's operations and to provision of limited assurance in respect of these statements and data;
  2. Review of select on-site data collection process, data management and collation process and the assimilation of this data into the tables, graphs and statements presented in this Report;Checking of the internal control system, including monitoring and reporting procedures and whether it is planned expediently to support reliable disclosure in the Sustainability Report;
  3. Assessment whether the Report provides an appropriate representation of existing policies in the areas of human resources, health, safety, security, environment and community involvement;
  4. Checking of the data stated at the following indicators (collectively referred to as select sustainability performance indicators):
       
    • Total spent on non-core business infrastructure development (EC11)
    • Air emissions by type for Steel Works (EN 10)
    • Hazardous and solid waste for Steel Works (EN 11)
    • Recycling and reuse of water at Steel Works (EN 22)
    • Total environmental expenditures by type (EN 35)
    • Evidence of consideration of human rights impacts as part of investment and procurement decisions, including selection of suppliers/contractors (HR 2)
    • Share of operating revenues from the area of operations that are redistributed to local communities (HR14)
    • Standard injury, lost day and absentee rates and work related fatalities (LA 7)

We planned and performed our work to obtain all information and explanations that we considered necessary to provide sufficient evidence for us to ascertain that the above indicators were consistent with the activities in the plant areas for the financial period; and were documented and stated in accordance with the guidelines stated under their environmental and social policies.

Basis for Assurance

There are no generally accepted international environmental, social and economic reporting standards. However, the contents of this Report have been Generally reported as per GRI Guidelines 2002. Accordingly, the Principles of and Guidelines on Corporate Sustainability Reporting published by Global Reporting Initiative (GRI) formed the basis for providing assurance.

Assurance procedures performed

In the absence of generally accepted international environmental, social and economic reporting standards, our approach was based on emerging best practices and underlying principles within international assurance engagements. In particular, our engagement was planned and conducted to obtain "moderate negative assurance" based on International Standards on Auditing - ISA 910.

Our work consisted of:

  1. interviews with management responsible for environmental, marketing, safety, suppliers/partners, legal, human resource, finance and mining related issues;
  2. examination of documentation on economic, environmental and social policies, practices, performance, governance etc;
  3. a desktop review of external economic, environmental and social issues facing The Tata Iron and Steel Company Limited;
  4. an understanding and assessment of systems for data generation, collection, analysis, consolidation and reporting at site, business unit, divisional and group level;.
  5. review and sample testing of eight of the reported indicators and associated statements presented in the Report at EC11, EN10, EN11, EN22, EN 35, HR 2, HR 14, and LA 7, as mentioned above in light of the findings from the desktop review, site visits, and our cumulative eknowledge of the industry and the Group's operations;
  6. Review of conclusions drawn from data and corresponding statements for select indicators in the context of the robustness of data.

Case studies and major stakeholder groups were not involved in planning and/or during the assurance process.

Parties responsible for Assurance Engagement

Our engagement was carried out by a multi-disciplinary team of requisite skills and experience.

The assurance engagement was led by Dr. P. Ram Babu, a Sustainability Systems expert, employed with PricewaterhouseCoopers Private Limited, with over 25 years experience in Corporate Sustainability Management and Reporting Systems.

The engagement was executed by Mr. Surojit Bose, Dr. Muna Ali and Mr. Ritwik Bhaumik, employed with PricewaterhouseCoopers Private Limited, with 7-10 years of experience.

Conclusions
  1. On the basis of the work undertaken, nothing came to our attention to suggest that the information cited at indicators EC11, EN10, EN11, EN22, EN 35, HR 2, HR 14, and LA 7 in the Report has not been fairly stated.
  2. The Report is generally in line with Global Reporting Initiatives Guidelines of 2002 on preparation of Corporate Sustainability Report.
  3. The internal control and management systems are modeled on best practices and on ISO based quality and environment management system. In general, established data collection, collation and interpretation processes provide basis for credible reporting of performance.
  4. The full time Directors on the Board, Dy. Managing Director (Steel) and Dy. Managing Director (Corporate Services) are responsible providing guidance and review of various aspects of sustainability performance. The Board is regularly informed of the sustainability performance and how the business is addressing the concerns and expectations of stakeholders.
  5. The management has exhibited commitment to progressively ensuring uniformity in reporting entity and period across all indicators in subsequent reports; this is apparent from the consistent coverage of this report over the previous report, for most of the indicators.
  6. Tata Steel has adopted several steps to encourage adoption of sustainability principles across its supply chain. These include mandatory disclosure by suppliers, Supplier Transformation Process, Vendor Bank Financing, Online Acknowledgement of Tata Code of Conduct, etc.

Some opportunities for improvement in future reporting are as follows:

  • While some units showed evidence of integrated electronic data management and communication systems in compiling sustainability performance indicators, others were less advanced in this respect.
  • Hence, completeness of data reported in some instances was found to be impaired due to lack of data availability at various units and accordingly a reporting entity limitation has been resorted to in such cases.
  • Further, in case of some indicators, information reported on gross basis has not been provided for the entire reporting entity. Information in such instances has been provided disaggregated for several of the units of the reporting entity together with an entity limitation.
  • Tata Steel has employed considerable resources for development of non-core business infrastructure development. However, in the absence supporting quantifiable data, this indicator could not be adequately reported.
  • The management has committed to improve monitoring systems to assess adherence to various relevant policies/codes articulated by the company, including the Tata Code of Conduct.
       

Dr. P. Ram Babu

Place: Mumbai, India
Date: 09/12/2004

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