Ethical, transparent and accountable

We also report on sustainability indicators to the World Steel Association (worldsteel).

Ethical, transparent and accountable business

Tata Steel Limited is a public limited company with 857,041 shareholders as at 31 March 2009 – the vast majority individuals. T ata Sons Limited is the largest single shareholder, with a shareholding of just over 31%. Around 66% of all profits received by Tata Sons from this shareholding are invested in philanthropic activities to benefit society, through the Sir Dorabji Tata Trust, Sir Ratan Tata Trust and other trusts.

Corporate governance

The Board of Tata Steel considers itself a trustee of its shareholders and has robust systems in place to deliver its responsibilities for creating and protecting shareholder wealth, while ensuring the interests of other stakeholders in our businesses are safeguarded.

Accountability for sustainability issues The Board takes responsibility for sustainability issues and monitors compliance with the law on related matters such as emissions and safety regulations. The Board also regularly monitors performance on key indicators related to our corporate citizenship philosophy and corporate goals for 2012.

These are implemented through integration into the business plans of our companies, with associated targets for individual business units and departments. Reporting mechanisms are in place to ensure that associated performance data from all companies is reported and monitored from operational levels though to Tata Steel Group Board level.

Transparency and accountability

The Board promotes full transparency and accountability in all its transactions, in order to protect the interests of all our stakeholders.

We prepare and maintain our accounts in accordance with the relevant accounting and financial reporting standards that represent the generally accepted guidelines, principles, standards, laws and regulations of the countries in which we conduct our business. Our internal accounting and audit procedures reflect fairly and accurately all of our business transactions and activities, and we have controls to provide this assurance to our Board and shareholders.

Assurance

We have adequate internal control systems to review compliance and, through the audit committee of the Board, to ensure that effective external audit procedures are performed by external auditors. The audit committee reviews the financial results of the Group before submission to the Board and makes recommendations to the Board on any matter relating to the financial management of the Group.

Internal assurance is provided across the Group companies through a dedicated function which aims to maintain strong, effective internal control systems and, among other things, to ensure the integrity of financial information.

External assurance is applied through our financial auditors and accredited certifiers via standards such as ISO 9001 and ISO 14001.

Managing risk

The process of managing risk has been reviewed in light of the increasingly global nature of Tata Steel Group’s operations, and we are enhancing our risk management system to address the complexities of the risks we face across the Group.

Our risk management process is assured through the Group’s corporate assurance and risk management function, reporting to the Group chief financial officer and the audit committee of the Board.

Business ethics

We do not tolerate corrupt or fraudulent practices. We expect honesty, integrity and transparency in all aspects of our business from our employees, contractors and other business counterparts.

Ethical behaviour is central to our business. Our ethical philosophy is part of our legacy, set out more than a century ago by Jamsetji Nusserwanji Tata, founder of the Tata Group, who believed that business must operate in an ethical way that respects the rights of all its stakeholders and creates an overall benefit for society.

Since 1998 these ethical principles have been articulated in the Tata Code of Conduct, which applies in all Tata companies. In 2008, in line with changing expectations within society and the increasingly global scale of the Tata Group’s activities, the Code was updated in consultation with Corus and other Tata Steel Group companies. The revised Code of Conduct was adopted by the Tata Steel Group Board in October 2008 and now applies in all our companies.