Tata Steel code of conduct

The importance of implementing a sustainability protocol is addressed for the first time.

When the revised Code of Conduct is fully implemented throughout the Group, all employees will have a personal
responsibility to uphold the high standards of corporate and personal behaviour it sets
out. Additionally, the Code will extend to contractors and vendors, who must agree to
respect its principles.

Joint ventures controlled by the Tata Steel Group will be encouraged to adopt a Code of Conduct based on the business principles articulated in the Tata Code.

Our Code of Conduct is implemented through a four-pillar concept:

Leadership

Respect for the Code is led from the top. Senior managers must act as role models through their own behaviour and set high ethical expectations of employees.

Systems and process

A structure exists at Board level to address ethics issues, such as whistle-blower concerns or matters relating to the interests of shareholders.

In India, Tata Steel has a central forum for ethics which meets quarterly and holds detailed discussions on the implementation of the Code in the Group companies, measured against the four pillar concept. This forum has proved to be a valuable resource in ensuring that aligned systems and processes are in place to manage business ethics and compliance with the Code of Conduct, while also reflecting local circumstances and requirements.

All new employees are informed during their induction about our expectations of ethical behaviour and the requirements of the Code of Conduct. In India, current employees were also asked to sign up to the revised Code of Conduct during the year under review. In Europe, group senior managers signed up to the Code in advance of its planned roll-out to the rest of the organisation.

Training and awareness

All Tata Steel Group companies developed communication programmes during the year to raise awareness and provide guidance on the revised Code to relevant stakeholders.

The Code has been translated into many national and local languages around the world. For employees in our Indian operations, we have established dedicated sections on the intranet and have held training and awareness sessions within our regular engagement forums such as the Joint Departmental Councils.

Dedicated training programmes have been carried out in Group companies that have recently adopted the Code, with poster and e-mail reminders to reinforce the message in some countries.

Every year in India, Tata Steel marks July as Ethics Month, with a special programme of activities designed to underline the importance of ethical conduct among employees and contractors.

Measurement

In India, we monitor the total number of concerns raised through our ethics management. We also conduct periodic surveys to assess the awareness and perception of ethical behaviour among employees.