At Tata Communications, our corporate governance framework is meticulously crafted to achieve sustainable business outcomes, fulfil stakeholder expectations and ensure compliance with all applicable laws and regulations.

We operate with a clear focus on maintaining transparency, accountability, and high ethical standards. This approach to corporate governance aligns with our long-term business success and the trust that we have built with our stakeholders. We place significant emphasis on ethics, anti-corruption initiatives and governance policies as part of our ever-evolving corporate governance framework. Our comprehensive training programmes and robust third-party compliance mechanisms ensure that we operate with integrity in every facet of our business.

Governance framework

Tata Communications operates under the robust governance structure defined by the Tata Code of Conduct (‘TCOC’). The TCOC serves as the cornerstone policy, guiding the conduct of all companies within the Tata Group. Tata Communications’ internal policies are aligned with the guiding principles laid out in the TCOC.

Policy updates

To ensure continuous compliance with evolving laws and regulations, our Legal Compliance team reviews and updates our policies and procedures as needed.

Role of the Board and Management

The Board of Directors is responsible for overseeing the implementation of strategy, governance, and performance of the Management. They exercise independent judgment and play a vital role in monitoring the Company’s affairs. To comply with statutory requirements and fulfill their obligations, the Board has established various committees that oversee specific areas, including risk management, corporate social responsibility, financial controls, remuneration, safety, and sustainability. Each committee has a defined charter outlining their roles and responsibilities.

At Tata Communications, we have established a Global Management Committee (‘GMC’), comprising leaders from all functions within the organisation. The GMC acts as the driving force behind the growth, transformation, and value creation for all stakeholders. Supported by the Leadership Forum, the GMC upholds the organisation’s values and principles.

Anti-corruption commitment

Tata Communications maintains a zero-tolerance approach towards corruption. Tata Communications is committed to upholding the highest moral and ethical standards as a responsible corporate citizen. This commitment is evident in our comprehensive anti-corruption framework, which includes an Anti-corruption policy, Third Party Intermediary Due Diligence policy, Corporate Hospitality and Gifts policy, and Conflict of Interest policy, among others. We expect all our employees, contractors, suppliers, and business partners to adhere to similar anti-corruption standards; and we enforce them through rigorous systems and controls to ensure compliance with all applicable anti-corruption laws and regulations. Any violation of our policies or guidelines can result in disciplinary actions.

Vendor and third-party compliance

Our commitment to upholding the highest ethical standards extends to our business partners as well. Tata Communications enforces a Supplier Code of Conduct that aligns with our corporate values, mandating adherence to ethical practices, respect for human rights, health and safety standards, environmental protection, and effective management practices. This is reinforced through contractual assurances and our due diligence framework.

Employee training and awareness

We place high value on the importance of adherence to our established policies and guidelines. We believe that continual learning and development are crucial to fostering a workplace culture that is steeped in ethical conduct and compliance with all pertinent policies and applicable law.

Ethics Week

2,388

Measure of Active Engagement (MAE Score)

6

Virtual Contests

499

Participants

1,080

Average Views - Messages / Posts

E-Learning

3,665

New hires trained

38

Initiatives through digital platforms

As part of our commitment to this ethos, we have implemented a series of regular training and awareness initiatives. These include unique events such as:

'Ethics Week'

A week-long event focused on activities emphasising the importance of ethical behaviour and the application of our Code of Conduct.

Annual Code of Conduct E-Learning

A yearly online course on the Code of Conduct, which includes an assessment and a certification upon completion.

Insider Trading Training

Periodic training conducted on the Code of Conduct for Prevention of Insider Trading.

Interactive Workshops

In-person and virtual sessions to facilitate discussion, share experiences, and address any queries.

Continuous Learning Opportunities

Encouragement for employees to attend industry conferences, seminars, and online courses for professional development.

New Employee Orientation

Mandatory training modules for new hires that outline their roles, responsibilities and duties under our company policies.

Policy-Specific Training by Legal Compliance Team

Training provided by the Legal Compliance Team and Compliance Counsels on specific company policies.

Corporate Law Guidance

Guidance sessions on relevant corporate laws for specific employee functions.

Digital Learning Platforms

Webinars, podcasts and video tutorials for flexible, self-paced learning.

Partner Training

Training and resources for business partners, suppliers and other stakeholders to implement our Code of Conduct effectively.

Implementation of ethics policy and code of conduct

The TCOC serves as the bedrock of our ethical standards, with all employees, partners and third parties expected to adhere to its principles. We ensure its implementation through mandatory annual e-learning modules and assessments on TCOC for all employees. Knowledge on TCOC is imparted through various channels, including policy-specific trainings, an annual Ethics Week event, and a stringent consequence matrix for non-compliance.

Coverage of ethics training

Mandatory annual e-learning modules on TCOC and the Global Dignity in the Workplace Policy are extended to all employees, including contractors. This ensures a comprehensive understanding of our ethical standards and guidelines. The enforcement of these guidelines is further strengthened through a consequence matrix, which withholds annual bonus and / or sales commissions until mandatory training is completed.

Employee training and awareness

We place a high value on the importance of adherence to our established guidelines and codes of conduct. We believe that continual learning and development are crucial to fostering a workplace culture that is steeped in ethical conduct and compliance with all pertinent policies.

Responsibility for business ethics and corruption issues

Tata Communications has a dedicated Legal Compliance Team responsible for managing business ethics and corruption issues. The team, empowered by qualified attorneys, are experts in key areas of legal compliance, working towards ensuring compliance with our Anti-Corruption policy and other related laws and regulations.

Compliance

The Legal Compliance Team leverages its expertise in critical compliance areas such as anticorruption, antitrust, competition laws, sanctions, data privacy and modern slavery to develop and deliver relevant training to the employees. This not only helps foster a culture of compliance within the organisation, but also equips our employees to effectively mitigate potential risks.

Vendor and third-party compliance

Our commitment to upholding the highest ethical standards extends to our business partners as well. Tata Communications enforces a Supplier Code of Conduct that aligns with our corporate values, mandating adherence to ethical practices, respect for human rights, health and safety standards, environmental protection, and effective management practices. This is reinforced through contractual assurances and our due diligence framework.

Ongoing monitoring and evaluation

We have established robust mechanisms for the ongoing monitoring and evaluation of our corporate governance policies and anti-corruption initiatives. Regular audits are conducted to ensure adherence to these policies, and any deviations are addressed promptly and effectively.

Glimpse of the Panel Discussion on ‘Ethics and Good Governance’ which was followed by a townhall interaction with the MD & CEO