As Chief Ethics Officer, the Managing Director is responsible for the deployment of the Tata Code of Conduct. A designated Ethics Counselor assists him in deploying the Tata Code of Conduct through a formal organisational structure. Designated as the Management of Business Ethics, Departmental Ethics Co-ordinators are responsible for implementation of the process. It stands on the four-pillar concepts of Leadership, Communication and Awareness; Compliance Structure; and Evaluation of Effectiveness.
TATA CODE OF CONDUCT
Various systems and processes have been developed and implemented in Tata Steel to improve the implementation of the code, namely: Gift Policy, Whistle Blower Policy, Whistle Blower Reward Policy, Vendors Whistle Blower Policy and Sexual Harassment Prevention and Guidelines. To encourage employee activism against malpractices and to protect the identity of the Whistle Blower a third party operated Whistle Blowing Line was established in 2011-12.
Training and Awareness :
Compliance to the Code is a condition of service for 100 per cent of the employees at Tata Steel as well as a prerequisite for entry and continuation as a supplier to the Company. An integral part of all Employee Induction programmes, relevant sections of the Code are placed on the Company’s e-procurement site and all suppliers are required to make an electronic undertaking of compliance with this Code.
Existing employees undergo periodic refresher programmes, including participation in a theme based Ethics Month. The theme for 2011-12 was “Ethics is your conscience”. Employee unions at various locations have signed a Joint MoU with the Management on behalf of the workers to comply with the provisions of the Code.
Evaluation of Effectiveness :
An evaluation of the MBE Programme is conducted once in two years via employee and supplier perception surveys by an independent third party. The results are analysed for self-evaluation and gaps identified are used for new initiatives.
Any employee can directly raise his concerns with the Ethics Counsellor/ Head Vigilance or escalate it to the level of the Board through the Chairman of the Board’s Audit Committee.
Action for Non-Compliance to the Code
Tata Steel has a zero tolerance policy towards corruption and unethical behaviour. All officers have to submit a Conflict of Interest declaration (COI) on the intranet and update it as and when a new COI situation emerges in their employment period.
The total number of concerns raised in 2011-12 was 209 as opposed to 105 in 2010-11 and 100 in 2009-10 due to special workshops conducted to make employees aware of interpretations with respect to ethical and unethical conduct.
Annual Tata Code of Conduct (TCOC) Compliance Declaration
The Managing Director submits an annual TCOC Compliance declaration to the Chairman disclosing the steps taken in the Company during the year. The Declaration regarding compliance by Board Members and Senior Management Personnel with the Code of Conduct is available in the Annual Report (page 80).
Concerns raised regarding the involvement of its employees or business partners in any act of bribery or corruption are thoroughly investigated and punitive as well as preventive action is taken.
Concerned about protection of female employees from Sexual Harassment in the workplace, Tata Steel has constituted a Sexual Harassment Redressal Committee.
Tata Steel, including its profit centres collectively and individually, anticipate and address public concerns. The Company also proactively seeks information on issues of public concerns, tracks Government notifications, changes effected in developed economies including product related risks and concerns in order to develop such compliance in advance.
No fines were imposed during the year for non-compliance with applicable laws or provisions.
The Company received 28 communications from statutory authorities pertaining to its operations covering broadly 14 issues during 2011-12. All three issues of significance pertained to perceived environmental non-compliance.
Tata Steel honours all non-disclosure/confidentiality agreements with customers. No complaints were received or recorded regarding breach of customer privacy and loss of customer data in 2011-12.