This pillar focusses on setting up direction, governance structure and role modelling. The Chief Executive Officer and Managing Director is the Principal Ethics Officer of Tata Steel Limited. To ensure adherence to the TCoC, monitor concerns and report compliances, the Principal Ethics Officer appoints the Chief Ethics Counsellor (CEC).

Departmental Ethics Coordinators (DECs) are appointed across the organisation for supporting Management of Business Ethics (MBE) deployment. To increase the involvement of frontline employees (employees + contract employees), a team of ‘Ethics Champions’, who are frontline employees, has also been developed and trained.

Tata Network Forum India East - Ethics Conclave FY 2018-19 Brand where Ethics makes a Difference

This pillar focusses on the development and dissemination of policies supporting the TCoC for all stakeholders. All employees are required to read and accept the TCoC and declare their Conflict of Interest (COI) status through the ‘Ethics Compliance Register – DARPAN’, accessible on the Company’s intranet and mobile. To encourage and protect whistle-blowers, the toll-free third-party helpline ‘Intouch’, popularly known as ‘Speak Up’, maintained by an independent UK-based company, has been extended to all stakeholders. The Chief Ethics Counsellor reports the performance of MBE deployment, including TCoC violations, to the Board level (Audit Committee) and Management level committees (Apex Ethics Committee and Ethics Committee).

Policies supporting TCoC:

Tata Steel has always been committed to creating a positive business ecosystem in all the spheres it operates. We are in the process of developing the Anti-Bribery & Anti-Corruption and Anti-Money Laundering (ABAC/AML) policy, which will strengthen our internal and external processes against financial risks.

Communication and training programmes have been designed to raise awareness of Tata values, TCoC and ethical policies and practices among all stakeholders. The senior executives communicate on various forums, such as Group Ethics Conclave, Ethics Town Hall and MD Online, to keep up with the ethical benchmark at Tata Steel and its group companies.

For effective dissemination to the frontline and contractual employees, local languages are also used in communications. To help people relate with practical situations, snippet stories, ‘Neeti Katha’, with various dilemma scenarios were introduced. In Financial Year 2018-19, scenarios on ‘The Ethics of Safety’ and ‘Trust Behaviour’ were communicated.

The senior executives communicated with vendors and suppliers during regular Business Associate’s (BA’s) meets/dialogues. They also accept the TCoC and declare their COI during the registration process.

To assess the level of deployment of various MBE initiatives across the organisation, an MBE assessment framework was developed involving site assessment, which resulted in increased cross learnings between DECs and improved MBE deployment. The MBE survey and assessment by the Tata Business Excellence Group were also conducted in Financial Year 2018-19.

In Financial Year 2018-19, we conducted a benchmarking exercise with GoodCorporation and General Electrics, apart from sharing ethical practices in various international forums such as the Business Ethics Leadership Alliance (BELA) summit and the Ethisphere Summit.