Ethics and Compliance

Tata Steel upholds integrity and transparency, ensuring compliance with laws, to foster a culture of trust and sustainability across its operations.

Ethics

Ethical business conduct forms the core of Tata Steel’s philosophy. The Company has always upheld the highest standards of ethical business practices across its geographically diversified operations.

On December 18, 2023, Tata Steel observed 25 years of institutionalising the Tata Code of Conduct (TCoC). Guided by the TCoC, Tata Steel has deployed the Management of Business Ethics (MBE) framework with the following four pillars:

Leadership

  • The Corporate Governance structure includes Board-level committees and management-level committees, which oversee the deployment of vigil mechanism in the organisation.
  • The Senior Leadership team does role modelling by communicating the values and principles through various forums, addressing different stakeholders across divisions thereby ensuring open and transparent culture.
  • The Chief Ethics Counsellor (CEC) is responsible for driving MBE initiatives and reports to the Chief Executive Officer & Managing Director (CEO & MD), who is also the Principal Ethics Officer. Apart from a dedicated Corporate Ethics department, the deployment is supported by line managers and employees who are nominated and trained as Divisional Ethics Coordinators and Ethics Champions and constitute the Organisation of Ethics Counsellors (OECs). Besides them, local POSH (Prevention of Sexual Harassment) representatives play a pivotal role in connecting with and instilling confidence among the people on shop floors and supporting them in reporting sexual harassment cases.

Compliance structure

  • Various systems and processes are used to ensure a robust vigil mechanism for the deployment of the TCoC and related policies in the organisation.
  • Tata Steel’s in-house IT-enabled digital platform ‘Darpan’ hosts declarations on the TCoC and Conflict of Interest, external assignment declarations, and Gift and Hospitality declarations. Other key IT platforms used by Tata Steel are the Management of Business Ethics Information System for Ethics Counsellor Management, the dilemma portal called ‘Kashmakash’, and the Integrated Concern Management System.
  • Tata Steel also has a third-party whistleblowing helpline facility called ‘Speak Up’, which ensures stakeholders’ confidence in the whistleblowing process. The facilities include a 24/7 toll-free number, web access, postal services, and email.

Communication and training

  • Communication is crucial in deploying the MBE framework across the organisation through various communication platforms, including round-table discussions for employees, business associate meets for vendors, distributors, suppliers, transporters, and service providers, and mass meetings at shop floors to connect with the frontline employees and contract workforce.
  • Customised training programmes on POSH, Respectful Workplace, and Third-Party Due Diligence, amongst other topics, are conducted online, in classrooms, and on web-based mediums.

Measurement

The activities of the OECs are captured in the online Management of Business Ethics Information System.

The effectiveness of the MBE framework deployment is constantly evaluated using the feedback from the MBE Survey and MBE Assessment.

Tata Steel has and will always relentlessly focus on strengthening the ethical culture across all its locations by reinforcing the policies and guidelines, setting high standards of transparency through strong corporate governance practices, and leveraging technology.

Compliance

The steel industry, historically a bastion of rigorous regulatory oversight and scrutiny, finds itself at a pivotal juncture as the global imperative shifts towards sustainability and decarbonisation. Additionally, significant stakeholder expectations, shifts in social attitudes, and public perception, particularly in the Environmental, Social and Governance (ESG) domain, are shaping industry practices and priorities. Given this shift, compliance is at a critical inflexion point as it transcends the traditional boundaries of regulatory adherence and legal conformity. Compliance is now emerging as a strategic function that serves as a cornerstone in supporting the trajectory of the enterprise towards a sustainable future.

The Compliance function at Tata Steel involves a robust and comprehensive programme that focuses on regulatory changes and trends, addresses stakeholder expectations, and facilitates continuous improvement while aligning with the Company’s strategic objectives and values. It plays a pivotal role in fostering a culture that is anchored in integrity, transparency and accountability and prioritises fairness, upholds rights, promotes safety, and advocates ethical conduct.

Acting as a second line of defence, it assesses compliance gaps, guides the implementation of internal controls, and provides critical insights to the management. In addition to ensuring adherence to a myriad of applicable laws and regulations, the function serves as a valued advisor, providing essential guidance, training, and consultation to the business in meeting its compliance obligations.

Last year, the function achieved ISO 9001:2015 standards certification, incorporating rigorous quality management in its compliance practices, crucial for meeting contemporary and ever-evolving regulatory demands effectively. This achievement marks a significant stride in propelling the function towards sustained operational excellence. It is also significant in light of the function’s aspiration to secure ISO 37301:2021 standards certification in the coming years.

Recognising the importance of technology in driving compliance, the function prioritised automating compliance processes to streamline operations, reduce manual effort and minimise human error. Automation was utilised for user follow-ups and generating management reports. The function also introduced modules to its compliance solution for streamlining compliance procedures on user concern management and statutory licences review.

In FY2024-25, the focus would be on enhancing review and testing protocols through compliance audits to assess gaps, ensure coverage, promote awareness, and foster a compliance culture.

In the coming years, the function will continue to develop compliance capabilities across all levels within Tata Steel and across the corporate spectrum, which includes group entities. It will look to extend its monitoring and oversight perimeter to include third parties. It would continue to evaluate and upgrade its technology stack to ensure it meets the emerging compliance demands.

The function is headed by the Company Secretary and 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.

ISO 9001:2015

Certification received by the Compliance function during FY2023-24