Human Rights

Conducting Business with Integrity

Respect for human rights, and incorporation of ethically and environmentally sound business practices as well as fair and safe working conditions and employees’ wellbeing, are fundamental parts of our culture and identity.

Tata Communications is dedicated to ensuring that the fundamental rights of people involved in its operations throughout the value chain are never violated. Our Company has a zero tolerance policy for illegal and immoral practices, such as child labour, forced labour, and modern slavery, including human trafficking, as stated in our Code of Business Conduct and Ethics, and Business Human Rights Policy

Business and Human Rights Policy

To enhance the integration and linkage between Business & Human Rights (BHR), and our existing company’s policies and practices with reference to BHR salient elements relevant for our stakeholders, this year we published our comprehensive Business and Human Rights Policy which shows our commitment to operating our businesses while conforming to the highest moral and ethical standards.

The Policy is aligned and follows various national & international frameworks on Human Rights such United Nations Universal Declaration of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, Modern Slavery Act 2015, Tata Code of Conduct, Tata Affirmative Action Policy (TAAP), Tata Group Business and Human Rights Guidelines and UN Sustainable Development Goals 2030.

The Policy is relevant and applicable to all our rightsholders (employees, contract workforce, communities, consumers/ customers, value chain partners, etc.) as identified by the Company and encompasses various business human rights salient elements like Anti-bribery and Anti-corruption, Acceptable Use, Equal Opportunity, Fair Competition, Community, Dignity & Respect, Fair wages, Freedom of Association and Collective Bargaining, Right to Privacy, Integrity of Information and Assets, Freedom of Expression, H&S, Product & Services, Trafficking, Modern Slavery and Child Labour, Data Privacy & Security etc.

Governance and Management Oversight

We have set out clear roles and responsibilities within our Company to ensure respect and oversight on human rights and its salient elements is reflected across our business. The Board level CSR, Health and Safety and Sustainability Committee reinforces this by overseeing the mechanism and performance with reference to Business Human Rights and its related issues such as privacy, freedom of expression, etc. as identified, The Committee comprises two Non-Executive Independent Directors and one Executive Director along with participation of relevant cross functional team.

Business & Human Rights Assessment

This year the company undertook a deep dive assessment of the human rights issues potentially present within its value chain & stakeholders through a detailed human rights salience assessment. The need for this has emerged from the increased scale of operations, the complex value chain that makes up our Company, the emerging importance by investors and customers on adhering to certain standards regarding human rights, the emergence of legislature related to business and human rights, and existing policies at Tata Communications which aim to protect human rights and prevent violations.

The scope of the gap (salience) assessment mainly included review of company’s existing literature (policies, SOP’s & performance), mapping of existing policies against global policies and guidelines, understanding and identifying key rightsholder concerns and challenges concerning human rights risks. The assessment was conducted to basically understand the actual and potential human rights relevant to the company’s business activity and its relationships against the UNGP salience criteria, as well as the Ranking Digital Rights (RDR) Corporate Accountability Index Research Indicators, and the Tata Group Business Human Rights standard.

The assessment was carried out in a consultative and participatory approach, while engaging with relevant stakeholders. Based on the discussions with the stakeholders, peer analysis, compliance with the international and national level commitment to human rights, a human rights salience matrix was developed that covers risk rating for relevant BHR areas as per the extent of control and risk exposure. The company to work upon the identified gaps and will continue to enhance its disclosures over the years.

Awareness and Training

We periodically review and revise Human Resources policies including the Whistleblower Policy, Sexual Harassment Charter (India), Dignity in the Workplace policy, Leave Policy – India and Global, Work-from-Home policies, including our Tata Code of Conduct based on feedback received through various communication forums and also evaluate them against industry standards and best practices. Our Company provides supplementary trainings to employees and contractors on specific ethics and compliance subjects, throughout the year. This includes topics on how employees should treat everyone in the workplace, freedom of expression, information, data privacy, etc. In addition, our Company’s contractual employees are also trained on Prevention of Sexual Harassment (POSH), Dignity in the Workplace, Information Security Awareness, etc. 490 Security personnels were trained in Human Rights across our facilities in India

96%

Employees undertook training on the Tata Code of Conduct, and Global Dignity in the Workplace policy

Child and Forced Labour

Our human resource policies also ensure that our employees and contractors are hired and treated fairly and humanely while working or contracting with Tata Communications. When recruiting and providing employment, our Company does not use deception, fraud, or coercion. It also does not employ recruiters, who violate labour laws or charge recruitment fees in countries that violate the law. Further the company has rolled out a Sustainability Supply Chain Framework encompassing Supplier Code of Conduct and Sustainable Supply Chain Policy which need to be adhered and implemented as part of contractual agreement with all the suppliers. The framework requires that suppliers act with integrity and comply with laws and conform to the principles related to Ethics & Transparency, Labour & Human Rights, Environment, Health & Safety, Anti-corruption & Anti Bribery and Information Security. None of our operations and suppliers in all geographies are deemed to pose a significant risk of child labour or forced labour incidents. In addition, we have not received any complaints or claims regarding a child or forced labour in our operations, and supply chain from internal and external stakeholders.

Zero

cases of Child, Forced or Bonded labour

Freedom of Association and Collective Bargaining

All our employees have the right to join associations or engage in civil or public affairs in accordance with local law. Our employees are expected to confirm with the Management Team the formation of unions in the workplace, under the ‘Conflicts of Interest’ clause in our Code of Conduct.

None of our operations and suppliers are at risk where freedom of association and collective bargaining are not allowed. All employees are free to choose to join, not join or leave unions and associations and choose their representatives in accordance with local and international practice. We encourage active and open communication and dialogue with our employees and/ or their representatives. We understand the importance of collective bargaining in avoiding labour disputes and maintaining peace, and we encourage unions at all our sites. If necessary, our Company also ensures that the employment contract and other related labour documents are drawn up in the employee’s local language and informs him/her of his/her rights and remedies, according to the applicable laws. Any modifications to the conditions of service and employability are the subject of prior discussions with employee representatives and unions. All these changes and their impact will then be evaluated and, accordingly, final changes will be communicated to employees within a period of 2 to 3 weeks, before the changes are implemented.

We encourage active and open communication and dialogue with our employees and/or their representatives.

Grievance Redressal for Human Rights Issues

The Company does not tolerate any malpractice, impropriety, statutory non compliance, or wrongdoing with reference to Human Rights and its salient elements. To that end, in addition to the relevant policies identified above, the Company has adopted an exhaustive grievance redressal and remedial framework consisting of its Whistle-blower policy.

The Policy provides and addresses concerns or complaints regarding any reportable matters defined in the Policy, including but not limited to infringement of human rights including privacy rights and freedom of expression, disclosure matters, anticorruption, or any other company matters involving fraud, employee misconduct, illegality or health and safety and environmental issues which cannot be resolved through normal management channels. The Whistle blower policy intends to encourage and enable Personnel and any person other than Personnel to pro-actively raise concerns regarding any such instances without fear of reprisal, discrimination or adverse employment consequences. They may do this through the Company’s “Ethics Helpline”, managed by an independent third party which enables a Whistle-blower to report a potential wrongdoing through various channels such as phone, email, web portal, fax and PO Box.

Anyone who suspects or is aware of a violation of the Code and other Tata Communications policies may raise a concern through any of the various channels outlined in our whistle-blower policy. This includes the ability to report concerns confidentially and, if desired, anonymously to our third-party whistle blower hotline, available in multiple languages. Employees and external stakeholders can also raise a grievance related to our Sustainability practices or any issue with reference to Human Rights via our “Get in touch with us” section on our Website