Written by: Soni, Shalini Sulakshana, and Ammi Kumari, Ethics Team, Tata Steel

In this article, the Tata Steel ethics team outlines the new challenges posed for the ethics and compliance function due to the ongoing pandemic and aligning the company’s deployment strategy to address the same.

Tata Steel’s reputation is built on the strong foundation of Tata Values and the Tata Code of Conduct (TCoC), and this is what guides us during any crisis. The COVID-19 pandemic disrupted our lives at every level. These were the most difficult times in memory for many across the organisation. People were perpetually in crisis management mode, facing new challenges, technology and market disruptions, safety concerns, etc. There were multiple challenges being faced by the organisation to keep business operations running during these tough times. There was a paradigm shift in the way we were operating, with most employees working from their homes, rapid digitalisation, multiple changes/modification in the standard operating procedures (SOPs) to address the exceptional situations, new safety guidelines and protocols to combat COVID-19, etc.

Introduction

Corporations came under enormous strain in 2020. One primary source of that strain was the pandemic, but a more destructive aspect was the Pandora’s box of other risks that the pandemic opened: cybersecurity, supply chain, health and safety, financial fraud, third party risk, and regulatory compliance as well. The challenges and risks posed by the business environment call for reshaping the way organisations manage the ethics and compliance function. At Tata Steel, during any crisis, we have remained guided by our fundamental values that are about caring for our people, stakeholders, and our community and treating them with respect and dignity. We realised that while core values and principles prevails as it is, there was a need to realign the management of business ethics with the current challenges to achieve business continuity. Ethical decision-making and leadership with trust have always been our core strengths, and in order to facilitate the same during testing times, we reassessed our promotion strategies and identified our strengths and areas of vulnerability.

Some of our key challenges were:

• A mixed work environment, where some people were working from home and others were coming to the plant daily. Both groups had their own sets of challenges and concerns.

• A larger group of contract employees who were not technology savvy, and hence reaching out to them was a challenge.

• During the lockdown period, there was a change in our third-party helpline services and our policies on anti-bribery and anti-corruption, anti money laundering were introduced.

• People were depressed, fearful, and exhausted, as all were directly or indirectly impacted by COVID. To address these challenges, we reprioritised our strategies and focused on the basics: Connecting with people & uplifting their morale: People were anxious and stressed out, struggling to balance the demands of remote working and the home front. All of us have seen how stress can alter behaviour, but a little assurance, compassionate listening, and a conscious effort to understand people’s fear and confusion go a long way in rebuilding people’s morale and transforming the remote workplace.

We realised the importance of staying connected with our different stakeholders, talking to them, listening to their concerns, and uplifting their spirits. We used multiple communication channels, such as virtual meeting platforms like MS Teams, short communication videos through group chats, web-based training modules, and in-person sessions about maintaining COVID protocols for people on the shop floor. Every year, we celebrate July as Ethics Month at Tata Steel in remembrance of JRD Tata. The theme for the Annual Ethics Month celebration in the last two years (during the pandemic) has been “Responsible ME, Responsible We” and “Resilience with Empathy and Kindness,” which focused on supporting each other, behaving responsibly, being tolerant and patient, and helping people heal and return to normalcy. This message was spread around the organisation and across the stakeholder groups by engaging senior leadership in virtual town halls and roundtable sessions with employees and business associates and launching communication campaigns on relevant subjects associated with the theme with snippet stories, video bites on leadership messages, posters, etc. Multiple contests, initiatives, and sessions were designed to keep the interest of different stakeholder groups, such as training sessions on a respectful workplace and building a resilient organisation, debates, photography contests, stories on resilience and ethics, a team video challenge, etc.

These kinds of programs garner more attention than the regular awareness sessions, keep the enthusiasm of the people, and help them understand the underlying message far more deeply. The communication on the theme and the contests were done via internal newsletters, intranet, ethics microsite, and Yammer. Knowing that most employees were working out of their homes and there was a need to engage with the families, the activities and contests were designed for the employees’ families too, such as posters, essays, and poem competitions. In order to promote positivity among employees and help them break free from the mundane workplace routine, an online musical evening was organised with participation from employees across the organisation.

Revisiting our communication strategy: With people suffering from online fatigue and an overdose of communication from HR, safety, and procurement, it was important for us to revisit our communication strategy, which was largely based on classroom sessions and web-based modules and focused on covering the entire stakeholder base. We moved from a push-based approach to more of a pull-based and customised approach. The content was modified to build in business needs and issues, with case studies relevant to the function. From long classroom sessions, we moved to short subject/policy-based modules that were widely communicated through various modes such as WhatsApp messages, departmental morning meetings, and mass meetings. Introducing policies and guidelines to address the risks associated with the changed workplace: While remote working led to our work-from-home policy being exercised based on trust, the changed scenario also posed new risk and dilemmas, such as sexual harassment during online meetings, emergency procurements leading to process lapses, violations of COVID guidelines leading to health risks, etc. With people largely confined to their homes during lockdowns, more and more people pursued their hobbies and interests, and their participation on social media increased. Hence, it was important to communicate and clarify policy and guidelines related to employees’ engagement in areas of their personal interest other than their professional work (potential conflict of interest), social media guidelines, and the do’s and don’ts of POSH in a work-fromhome environment. Since reaching out in person became restricted, to help people connect with us to resolve their dilemmas, an online portal for dilemma resolution called “Kashmakash” was launched. The portal enabled any employee to post their dilemma directly to the ethics team for resolution, with the option of remaining anonymous. The online portal is a tool that enables the employee to make ethical decisions and mitigate potential risks of ethical violations. These dilemmas, along with their clarification, are later published as FAQs for general viewing.

Online surveys and assessments to understand the pulse of the organisation: Surveys and assessments are important tools to measure the effectiveness of the deployment strategy. During the pandemic, in order to understand the issues and concerns, we launched the online MBE (Management of Business Ethics) survey for employees and vendors and carried out pulse surveys during the various roundtable sessions. We used these inputs to customise our communication plan and reprioritise our strategies. Tata Steel has developed an in-house MBE assessment process to gauge the level of deployment of MBE at workplace. As per the process, a group of assessors carry out site visits, interact with people, and accordingly evaluate the MBE deployment maturity of the departments. It was first launched in FY17, and since then there have been three cycles of assessments. During FY21, as the lockdown happened, we not only converted the site-based approach to an online mode of assessment, but the questionnaire too underwent changes to complement the change in mode and simplify the process. Leveraging the support of our ethics coordinators and champions (part-time representatives from the line function): The ethics coordinators and the ethics champions are part of Organisation of Ethics Co-ordinators (OEC) fraternity. To achieve our objective of an ethical and compliant culture companywide, we need to collaborate with our OEC fraternity members, who help us deploy the initiatives on the shop floor. We leveraged this network to help us communicate with people across locations and levels. With restricted travel and shop floor movement, they were the bridge connecting us to people across all locations, communicating the concerns and issues being faced by people on the ground and helping us understand business challenges. This helped us customise the content of our training and communication and design our programs accordingly.

Businesses continue to face ethical issues, some of them arising out of the current challenges of the pandemic. It’s a proven fact that unethical conduct can damage a firm’s reputation and adversely impact its financial performance. In order to address the risks posed by the ever-changing business environment, the ethics and compliance function needs to redefine its approach, modify or create new policies and guidelines, and customise their training and communication to address the business challenges. There is a need to adopt innovative approaches to reach out to people, make them aware of the risks and challenges, and help them in ethical decision-making. It is this blended approach of innovation with basic values and principles that will enable us to remain contemporary at all times, as we facilitate the deployment of our code of conduct and organisational values.

 


About the Experts:

Ms. Soni serves as Chief Ethics Counsellor at Tata Steel Limited. She has over 24 years of experience. She is a Chemical Engineer and holds an Executive Diploma in General Management, specializing in Operations and Finance from XLRI.  She has worked in different areas: a) R&D as a Researcher, b) Total Quality Management and was responsible for driving implementation of Daily Management, Small Group Activities & Quality Management System, and  Theory of Constraint in Supply Chain & Operations across Tata Steel and c) Corporate Strategy and Planning: Long term and Annual plans.

Ms. Shalini Sulakshana is Head Corporate Ethics at Tata Steel and TIS Group Companies at Tata Steel. She has done Bachelor of Engineering – BE, Electronics and Communications Engineering Birla Institute of Technology, Ranchi India. She has more than 20 years of experience with Tata Steel. She has worked as  Electrical and electronics maintenance Officer in  Steel Making and Slab Caster (LD2 and SC)at Tata Steel India and as Process Control engineer at Rod Mill, Scunthorpe, United Kingdom. Worked as Senior Manager at TQM looking after Daily Management,

Ammi Kumari:  Currently working as Manager, Corporate Ethics, Tata Steel. She has seven years of experience spanning from Communications, HR to Business Ethics. Prior joining to Tata Steel, have been associated for a year with Times of India (a reputed Indian Print Publication) as a journalist covering various segments including Health, Art & Culture & City events. Ammi has completed Graduation and Post-Graduation in Political Science. Thereafter completed Post Graduate Diploma in Journalism  I believe that Communication & Ethics go hand-in-hand to generate awareness and paves the way to empowerment.