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Sharing of Best Practices on Values and Ethics in the Workplace

Presentation To Civil Service College

Putting Values and Ethics into Practice in NatSteel

16 October 2014

Content

Overview Of Tata Group & NatSteel

Tata Values & The Tata Code of Conduct

Tone From The Top

Ethics Office (Structure & Roles)

Implementing The Code of Conduct

Tata Sons Ultimate Holding Company Of Tata Group Companies

Present In More Than 100 Countries

Revenue Over USD100 Billion

Over 500,000 employees

66% Equity Held By Philanthropic Trusts Endowed By Members Of The Tata Family (One Of The Largest Charities In The World)

National Institutions For Science And Technology, Medical Research, Social Studies And The Performing Arts

Aid And Assistance To Non-government Organisations Working In The Areas Of Education, Healthcare And Livelihoods

Tata Companies Also Extend Social Welfare Activities To Communities Around Their Industrial Units

Source : www.tata.com

Our Purpose

At the Tata Group we are committed to improving the quality of life of the communities we serve. We do this by striving for leadership and global competitiveness in the business sectors in which we operate.

Our practice of returning to society what we earn evokes trust among consumers, employees, shareholders and the community. We are committed to protecting this heritage of leadership with trust through the manner in which we conduct our business.

NatSteel - A Tata Steel Enterprise

Became a part of Tata Steel Ltd in February 2005 Operations in China, Vietnam, Thailand, Malaysia and Singapore Produces rebars, wire rods and value added steel construction products Revenue of SGD 2.5 billion Over 3,000 Employees

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NatSteel - Our Vision And Values

We Are Driven By Our Five Core Values Of Integrity, Understanding, Excellence, Unity and Responsibility

Tata Code of Conduct - We Conduct Our Business To The Highest Ethical Standards

Our Vision Is To Be The Global Steel Industry Benchmark For Value Creation And Corporate Citizenship

We make the difference through:

Our People By fostering teamwork, nurturing talent, enhancing leadership capability and acting with pace, pride and passion.

Our Offer By becoming the supplier of choice, delivering premium products and services and creating value for our customers.

Our Innovative Approach By developing leading edge solutions in technology, processes and products.

Our Conduct By providing a safe workplace, respecting the environment, caring for our communities and demonstrating high ethical standards.

Tone From The Top Tata Group Chairmen - Past & Present

Responsibility The most significant contribution an organised industry can make is by identifying itself with the life and problems of the community to which it belongs, and by applying its resources, skills and talents, to the extent that it can reasonably spare, to serve and help them. Integrity I have often thought about that. If we had done some of the things that some other groups have done, we would have been twice as big as we are today. But we didnt and I would not have it any other way JRD Tata

We do not claim to be more unselfish, more generous or more philanthropic than other people. But we think we started on sound and straightforward business principles, considering the interest of the shareholders as our own and the health and welfare of the employees the sure foundation of our prosperity. Jamsetji Tata (Founder)

I want the legacy to say we achieve the growth and the prosperity with the value system and ethical standards that we have tried to retain, and not succumb to the subjective pressures that exist to get things

done. Ratan Tata

.the core of the Tata Group must and will remain unchanged. Our commitment to maintaining the highest ethical standards in the conduct of our enterprises, our continuous emphasis on business excellence and managerial competence, our belief in our employees and their well-being, our sense of obligation to the customers we serve, our responsibilities towards the environment and the communities that we touch, and the greater good of the countries we operate in - without this core DNA that is uniquely Tata, there is nothing to differentiate us from our peers. Cyrus Mistry

Tone From The Top Tata Group Chairmen - Past & Present

Our Values Integrity

Conduct our business fairly, with honesty and transparency Everything we do must stand the test of public scrutiny

Understanding Caring, show respect, compassion and humanity towards our stakeholders

Work for the benefits of the countries that we operate in

Excellence Strive to achieve the highest possible standards in our day-to-day work and

in the quality of goods and services we provide.

Unity Work cohesively with our stakeholders. Build strong relationship based on

tolerance, understanding and mutual co-operation.

Responsibility Be responsible and sensitive to countries, communities and environments in

which we work Ensuring what comes from the people goes back to the people many times

over

Our Values

TATA CODE OF CONDUCT

STAKEHOLDERS Shareholders, Employees, Partners (Vendors/Customers/JV), Community

VALUES

Integrity Understanding Excellence Unity Responsibility

TRUST GOODWILL

TATA BRAND

Tata Code of Conduct (TCOC)

Adopted by NatSteel Board in April 2005

- First Board Meeting after acquisition of NatSteel

Applicable to Employees & Third Parties Suppliers, Contractors and other Vendors.

The Code is designed to:

- Uphold the highest standards of corporate and personal conduct

- Guide and support decision-making be the guiding force on ethical issues

- Deter wrongdoings, promote honest and ethical conduct and ensure compliance with laws, rules & regulations.

- Help promote a unifying sense of values across the Tata Group

- Encourage and govern prompt internal reporting of potential violations and ensure accountability.

1998 First Code

2008 Revised

2014 Revision

Management Of Business Ethics (MBE) - Enabler for the implementation of the TCoC in all business

transactions / interactions - Guide leaders and ethics counsellors on how to ensure that

the tenets of ethical code of conduct are practiced by all employees in the group

4 Pillars Of MBE

Leadership

Creating and nurturing an environment for ethical conduct

Setting direction for MBE implementation plan.

Periodically reviewing and communicating the plan.

Making MBE Plan an integral part of Annual Business Plan (ABP)

Implementation & Compliance Structure

Roles of Leadership in Guiding & Driving

Facilitation (Structure/Process/Ethics Team/Lady Counsellor)

Participation of Stakeholders

Communication & Training

Internal/External Training & Dialogue, Web Based Training

Knowledge Portals/MBE Reference Manual

Measurement

Assurance Surveys And Other Survey / Assessment

KPIs (Number of WB reports, Training Hrs, Dialogue Attendance, etc)

Action Plan Based Upon Findings Annual Report To NSH Chairman & Chief Ethics Officer

Leadership & Implementation Structure

Group Chairman

Brand Custodian & Chief Ethics Officer (Member of Group Executive Council)

Chief Executive Officer

Audit Committee

Country/Location Ethics Officers

Council of Practitioners

Chief Ethics Counsellor

Emphasis On The TCOC

High Level Support/Representation

Group Chairman Takes Direct/Personal Interest

Chief Ethics Officer is Member of Group Executive Council

Reviews At The Highest Levels

Annual Report to NSH Chairman & Chief Ethics Officer (Group Chairman's Office)

Benchmarking Questionnaire to Chief Ethics Officer

Quarterly Report to NSH Audit Committee

Monthly Tele-conference of Council of Practitioners

Regular Reviews with Chief Executive Officer

Annual MBE Plan

Policies/Guidelines

Right Ethical Environment (Confidentiality, Transparency, Protection)

Easy to set Policies. Harder to Implement

ETHICS - A WAY OF LIFE - Values & Code of Conduct

do not exist in isolation. - They have to be an integral

part of the Company's existence & activities.

- It's our DNA

Ethics Office

Country Ethics Counsellors (Thailand/Vietnam/China)

Chief Ethics Counsellor

Ethics Coordinators (Singapore)

Location Ethics Officers Location Ethics Officers

- All the officers of the Ethics Office have full time day jobs e.g. HODs, HR Officers, Engineers, Production Officers, etc

- Many touch-points within the organisation & the Ethics Office interfaces with many departments especially HRD for the roll-out of initiatives

Ethics Office Education/Feedback Training/Refresher Courses

Dialogues sessions/Feedback

Monthly Ethics Coordinators Meetings

Discuss issues including feedbacks

Develop Knowledge Base and Case

Business Ethics Policies/Guidelines Develop & Propose Policies/Guidelines to Support Business Activities

Consolidate Awareness And Enhance Understanding Of TCoC Communication (Bulletin/Intranet/Dialogue)

Outreach (Multi Lingual/Corp Intranet/Customers/Vendors)

Competitions (Quiz/Poster/Quotes/Skits)

Survey (TCoC Awareness/Understanding/Perception)

Whistle Blower Scheme and Concern Resolution Deploy TCoC, Whistle Blower Scheme and Concern Resolution Mechanism

Investigate Concerns & Recommend Corrective/Preventive Actions

Educate and promote Whistle Blowing

References & Tools

- Reference Manual - Implementation Booklet - Implementation Grid - Compendium of Promising Practices

Priority - What To Do

Segment - Who Needs What

Message/Content - Same Values,

Different Implications

Delivery - Reaching The

Folks

Survey - Outcome & Improvement

COMMUNICATION

Prioritisation

Entire Code is relevant

Which aspects do we focus first (useful for new companies/agencies)

Quarterly Themes

Target Segments (Relevance)

Function Relevant

Finance, Purchase, Sales, Logistics, etc

High Risk Operations

Customer/Vendors

Customised Messages (Level of Comprehension/Language Capability)

Managers/Executives

Shop-floor & Contract Workers

Different Languages

COMMUNICATION

Delivery (Media Channel/Language Capability)

Formal Training & Informal Dialogue Sessions

Classroom Training/Train The Trainer Programme

Web-based Training

Videos

Department Level Dialogue Sessions

Dialogue With Vendors/Customers

Competitions & Quizzes

Photography - Ethics In Action

Quiz

Internal Mass Media (Print & Online)

Company Bulletin

Intranet

Pop-up Screen

Chatter

COMMUNICATION

Sample Communication Material In Bengali

COMMUNICATION

TCoC Clause (Brief Description) (Examples) Clause 4 Equal

Opportunities

[4]

, , , ,

1.

Clause 5 Gift &

Donation

[5]

, , , ( ) /

1. /

2. -

(Clause 4) Equal Opportunities Employer

Learn and respect the cultures in which we work

Value and demonstrate respect for individuals

Provide equal opportunities

Irrespective of race, religion, marital status, gender and age

Protection Against Sexual Harassment

We have employees from different nationalities, religions, cultures, languages working together at the same production lines.

Pop-up Screens During Log-in

(Clause 5) Gifts/Hospitality and Donations

Employees should not accept personal gifts, services, entertainment or other items of value in exchange for special treatment by the company.

Likewise, employees should not give or offer to give personal gifts, services, items of value to employees of other organization to gain favorable business decision.

Any gifts or entertainment provided/received should always be appropriate to the circumstances.

Always seek clarification if unsure.

Clause 6 Government Agencies - Donations to any government agency directly or through intermediaries Clause 7 - Political Non-Alignment

Extract from MBE Reference Manual

(Clause 5) Gifts and Donations (Contd)

Ask these five questions before you give/receive Gifts and Hospitality

1. Is it legal?

2. Am I comfortable if made public?

3. Am I setting a good example?

4. Does it feel right?

5. Is it consistent with our values and code?

Integrity - Do the Right Thing

(Clause 20) Conflict of Interest

Conflict of interest arises when a personal interest interferes with the best interest of the company:

- Family members and significant relationships - Outside employment and other activities - Clause 19 Concurrent Employment - Giving/accepting/soliciting gifts and entertainment - Clause 5 Gifts and Donations - Insider information and Securities Trading - Clause 21 Securities Transactions & Confidential Information

- Dealings on behalf of the Company - Clause 17 Ethical Conduct

Act in the interest of the company

Ensure business or personal association does not involve a conflict of interest with the operations of the company

No acceptance of position in any other company or not-for-profit organization without authorization

Survey (Awareness, Understanding & Perception)

Company wide & covers all employees

Multi Lingual

Assess the success level of MBE implementation

Inputs for MBE Plan (Intervention/Improvement)

Results shared with employees

31 people died and 28 hurt in the terrorist attack on Taj Mumbai on 26 Nov 2008 Guests were overwhelmed by employees dedication to duty, their desire to protect

guests without regard to personal safety, and their quick thinking Restaurant and banquet staff rushed people to safe locations Telephone operators stayed at their posts, alerting guests to lock doors and not step out Kitchen staff formed human shields to protect guests during evacuation attempts

As many as 11 Taj Mumbai employeesa third of the hotels casualtieslaid down their lives while helping between 1,200 and 1,500 guests escape

Rohit Deshpande and Anjali Raina (Harvard Business Review - December 2011)

The Taj employees actions werent prescribed in manuals. No official policies or procedures existed for an event such as 26/11

Contextual factors could have had a bearing e.g. Indias ancient culture of hospitality, the values of the House of Tata and the Taj Mumbais historical roots in the patriotic movement for a free India

We believe that the unusual hiring, training, and incentive systems of the Taj have combined to create an organizational culture in which employees are willing to do almost anything for guests. recruitment system that hires for character and not for grades training programmes that not just mentor employees but empower them to take decisions a reward programme that recognises employees on a real-time basis

The Taj Story

What Tata Group did following the 26 Nov 2008 terrorist attack at Taj Mumbai Hotel,

Relief and assistance was extended to all including people in the surrounding area

Employee outreach centers were opened (1600 employees - All categories)

Provide all help, food, water, sanitation, first aid and counseling

One to one mentor for single window clearance for any help required.

Full salaries sent to all employees during the time that the hotel was closed

A psychiatric cell was established in collaboration with Tata Institute of Social Sciences

Dependents of employees flown to Mumbai and accommodated in Taj President for 3 weeks.

A new trust was created for the purpose of relief of employees within 20 days.

Ratan Tata personally visited the families of the 80 affected employees. Senior Managers including Ratan Tata visited funeral to funeral over the 3 days following the incident

Non Tata Employees - the railway employees, the police staff, those nearby were covered by compensation. Subsistence allowance of Rs. 10K per month for 6 months

Generous cash settlement for every deceased staff member plus the following benefits:

Full last salary for life for the family and dependents

Complete responsibility of education of children and dependents

Full Medical facility for the whole family and dependents for rest of their lives

All loans and advances were waived off irrespective of the amount

Counselling facility at Tata Groups cost for life for each person

Source: http://rotaryclubofbombay.org/

The Taj Story

R Gopalakrishnan - Exec Director, Tata Sons Source: CPA Australia Journal (12/2009)

Thank You

Chuah Yak Ngi Chief Internal Auditor Chief Ethics Counsellor

NatSteel Holdings Pte Ltd

6660 7921 cyn@natsteel.com.sg