TRL Krosaki Refractories Limited is committed towards sustainable development. It seeks to address social, environmental and economic aspects in all its activities. To achieve this, it strives to:
- Work with its customers to provide sustainable solutions.
- Protect the environment by preventing pollution.
- Ensure efficient use of natural resources and bring improvement wherever practical.
- Partner with local communities for long-term mutual benefits.
- Employ shareholders’ capital effectively and efficiently.
- Comply with all applicable laws, regulations & corporate requirements.
- Provide safe & healthy working environment to all its employees.
- It shall report its economic, social and environmental performance in its Annual Report.
TRL Krosaki Refractories recognizes that its employees are the core assets to drive the Company’s progress .
- We are committed to equal opportunities for employment and growth for all. We shall seek to attract the best available talent and enhance their potential through a learning environment.
- We shall pursue management practices to enrich the quality of life of our employees.
- We shall also pursue a policy of transparency and fairness in our dealings with employees.
TRL Krosaki Refractories will strive continuously to foster a climate of mutual trust and teamwork.
INTEGRATED MANAGEMENT SYSTEM (IMS) POLICY
We at TRL Krosaki Refractories dedicate ourselves to Total Quality in the management of our business and are committed to the following in respect of quality, environmental and occupational health & safety:
- Enhancing customer satisfaction on a continuous basis through implementation of an effective Quality Management System.
- Conducting all our operations in an environmentally responsible manner through conservation of natural resources such as raw materials, water and energy by minimizing their waste, preventing pollution and promoting recovery, recycling and reuse in a sustainable manner.
- Ensuring compliance with statutory regulations and applicable legal & other requirements to which the organization subscribes.
- Protecting and promoting health and welfare of its employees through prevention of accidents, incidents, injury, ill health and loss of property.
- Setting and reviewing objectives and targets at regular intervals.
- Enhancing awareness, knowledge and skill of employees of all categories on relevant issues of quality, environment, occupational health and safety.
Continual improvement, credibility, consistency and concern shall be our guiding values.
ANTI SEXUAL HARASSMENT INITIATIVE (ASHI) – POLICY
TRL Krosaki Refractories Limited (TRL Krosaki) is committed to providing a place of work that is free of sexual harassment and all forms of intimidation or exploitation of women.
TRL Krosaki shall provide healthy working environment that enables everyone to work without fear of prejudice, gender bias, sexual harassment and all forms of intimidation or exploitation. The Company believes that all stakeholders, irrespective of their gender, have the right to be treated with dignity.
In continuation with the Company’s endeavor towards improved gender diversity and inclusion along with creating a safe, fair and just workplace, this policy, called Anti Sexual Harassment Initiative (ASHI), is put in place.
In accordance with this policy, a committee and detailed guidelines have been formed to deal with issues of sexual harassment of women at work place. All women employees (permanent, temporary, contract) as well as trainees, women visiting our office premises or women service providers are covered under this policy.
All are advised to refer to the guidelines on Anti Sexual Harassment Initiative (ASHI) and report to the Internal Complaints Committee, in case any act of Sexual harassment to women employees comes to their notice.
INFORMATION SECURITY MANAGEMENT SYSTEM (ISMS) – POLICY
The security of information and information processing assets of TRL Krosaki is of paramount importance to its business and therefore confidentiality, integrity and availability of these assets shall be maintained at all times through deployment of appropriate controls and by promoting awareness amongst the users.
SAFETY AND HEALTH POLICY
At TRL Krosaki Refractories Limited, Safety, Health & Environment considerations form integral part of all its activities. It endeavors to:
- Conduct all its operations in a responsible manner with due attention to Safety, Health and Environmental aspects
- Comply with all applicable statutory regulations and wherever possible, exceed the standards by continual improvement
- Ensure implementation of sound Safety & Health practices by all its employees and all those who are required to work inside the premises
- Provide training on Safety & Health to employees and all those who work inside the premises to enhance knowledge and commitment
- Implement, maintain and continuously monitor Health & Safety management system to improve performance The Company shall report its Safety & Health performance in its Annual Report.
Managing Director & Occupier
WHISTLE BLOWER POLICY FOR DIRECTORS AND EMPLOYEES
- The Company believes in the conduct of the affairs of its constituents in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behaviour. Towards this end, the Company has adopted the Tata Code of Conduct (“the Code”), which lays down the principles and standards that should govern the actions of the Company and their employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern for the Company. The role of the employees in pointing out such violations of the Code cannot be undermined. There is a provision under the Code requiring employees to report violations, which states:
“Clause 25. Reporting Concerns”
Every employee of TRL Krosaki shall promptly report to the management any actual or possible violation of the Code or an event he becomes aware of that could affect the business or reputation of his or any other Tata Company.
- Companies Act, 2013 provides that companies belonging to the following class or classes shall establish a “Vigil mechanism / Whistle Blower Policy for their directors and employees to report their genuine concerns or grievances of unethical behavior, actual or suspected, fraud or violation of the Company’s code of conduct or ethics policy –
- the Companies which accept deposits from the public;
- the Companies which have borrowed money from banks and public financial institutions in excess of fifty crore rupees.
- Accordingly, this Whistle Blower Policy (“the Policy”) has been formulated with a view to provide a mechanism for directors and employees of the Company to approach the Ethics Counsellor / Chairperson of the Audit Committee of the Company.
The definitions of some of the key terms used in this Policy are given below. Capitalized terms not defined herein shall have the meaning assigned to them under the Code.
- “Audit Committee” means the Audit Committee constituted by the Board of Directors of the Company in accordance of the Companies Act, 2013 & any amendment / enactment thereon.
- “Employee” means every employee of the Company (whether working in India or abroad), including the Directors in the employment of the Company.
- “Code” means the Tata Code of Conduct.
- “Investigators” mean those persons authorized, appointed, consulted or approached by the Management / Audit Committee and include the Vigilance Dept, auditors of the Company and the police.
- “Protected Disclosure” means any communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity.
- “Senior Management” means; all the KW-4 level executives in the company, who constitute the Senior Executive Members (SEM) team.
- “Subject” means a person against or in relation to whom a Protected Disclosure has been made or evidence gathered during the course of an investigation.
- “Whistle Blower” means an Employee making a Protected Disclosure under this Policy.
- “Whistle Blower Protection Committee” means a Committee constituted by the Management from time to time to examine the grievances of Whistle Blower about the victimization allegedly suffered by him / her.
- This Policy is an extension of the Tata Code of Conduct. The Whistle Blower’s role is that of a reporting party with reliable information. They are not required or expected to act as investigators or finders of facts, nor would they determine the appropriate corrective or remedial action that may be warranted in a given case. Whistle Blowers provide initial information related to a reasonable belief that an improper or unethical practice has occurred.
- Whistle Blowers should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested by the Ethics Counsellor or the Audit Committee or the Investigators.
- Protected Disclosure will be appropriately dealt with by the Management / Ethics Counsellor / Audit Committee, as the case may be.
All Employees of the Company are eligible to make Protected Disclosures under the Policy. The Protected Disclosures may be in relation to matters concerning the Company.
- While it will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action.
- Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide intention.
- Whistle Blowers, who make three or more Protected Disclosures, which have been subsequently found to be mala fide, frivolous, baseless, malicious, or reported otherwise than in good faith, will be disqualified from reporting further Protected Disclosures under this Policy. In respect of such Whistle Blowers, the Management / Audit Committee would reserve its right to take/recommend appropriate disciplinary action.
- All Protected Disclosures concerning financial / accounting matters should be addressed to the Chairperson of the Audit Committee of the Company for investigation.
- In respect of all other Protected Disclosures, those concerning the Ethics Counsellor and employees at the levels of KW-3 and above should be addressed to the Chairperson of the Audit Committee of the Company and those concerning other employees should be addressed to the Ethics Counsellor of the Company.
- The contact details of the Chairperson of the Audit Committee and of the Ethics Counsellor of the Company are as under:
Chairperson of the Audit Committee:
Mr. V. S. N. Murty,
Tata Steel, Tata Centre,
1st Floor, 43, J. L. Nehru Road,
Kolkata – 700 071,India.
Phone No. : 033-22882684 , email : email@example.com
TRL Krosaki Refractories Limited,
Belpahar, Odisha-768218, India.
Phone No : 06645 – 258430 , Email id :
- If a protected disclosure is received by any executive of the Company, other than Chairperson of Audit Committee or Ethics Counsellor, the same should be forwarded to the Company’s Ethics Counsellor for further appropriate action. They must take appropriate care so that the identity of the Whistle Blower does not get divulged in the process.
- Protected Disclosures should preferably be reported in writing so as to ensure a clear understanding of the issues raised and should either be typed or written in a legible handwriting in English, Hindi or in the regional language of the place of employment of the Whistle Blower.
- If the protected disclosure is received by the Chairperson of the Audit Committee, he/she shall detach the covering letter and forward only the Protected Disclosure to the Ethics Counsellor of the Company for investigation.
- Protected Disclosures should be factual and not speculative or in the nature of a conclusion, and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern and the urgency of a preliminary investigative procedure.
- The Whistle Blower must disclose his/her identity in the covering letter forwarding such Protected Disclosure.
- All Protected Disclosures reported under this Policy will be thoroughly investigated by the Ethics Counsellor/Audit Committee of the Company in accordance with the normal procedure. The Ethics Counsellor / Audit Committee may at its discretion, consider the involvement of any investigators for the purpose of investigation.
- The decision to conduct an investigation is not an accusation and is to be treated as a neutral fact-finding process. The outcome of the investigation may not support the conclusion of the Whistle Blower that an improper or unethical act was committed.
- The identity of a Subject will be kept confidential to the extent possible given the legitimate needs of law and the investigation.
- Subjects will normally be informed of the allegations at the outset of a formal investigation and have opportunities for providing their inputs during the investigation.
- Subjects shall have a duty to co-operate with the Ethics Counsellor / Audit Committee or any of the Investigators during investigation to the extent that such co-operation will not compromise self-incrimination protections available under the applicable laws.
- Subjects have a right to consult with a person or persons of their choice, except Ethics Counsellor / Investigators and/or the Audit Committee and/or the Whistle Blower. This may involve representation including legal representation. Subjects shall be free at any time to engage counsel at their own cost to represent them in the investigation proceedings.
- Subjects have a responsibility not to interfere with the investigation. Evidence shall not be withheld, destroyed or tampered with, and witnesses shall not be influenced, coached, threatened or intimidated by the Subjects. If he / she is found indulging in any such actions, will make themselves liable for disciplinary actions. Under no circumstances, subjects should compel investigator to disclose the identity of the Whistle Blower.
- Unless there are compelling reasons not to do so, Subjects will be given the opportunity to respond to material findings contained in an investigation report. No allegation of wrongdoing against a Subject shall be considered as maintainable unless there is good evidence in support of the allegation.
- Subjects have a right to be informed of the outcome of the investigation. If allegations are not sustained, the Subject should be consulted as to whether public disclosure of the investigation results would be in the best interest of the Subject and the Company.
- The investigation shall be completed normally within 45 days of the receipt of the Protected Disclosure.
- No unfair treatment will be meted out to a Whistle Blower by virtue of his/her having reported a Protected Disclosure under this Policy. The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against the Whistle Blowers. Complete protection will be given to the Whistle Blowers against any unfair practice. The Company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus, if the Whistle Blower is required to give evidence in criminal or disciplinary proceedings, the Company will arrange for the Whistle Blower to receive advice about the procedure, etc.
- The Whistle Blower shall be protected from any retaliation, threat or intimidation of termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, or the like including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his / her duties/functions including making further Protected Disclosure.
- The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. Whistle Blowers are cautioned that their identity may become known for reasons outside the control of the Ethics Counsellor /Audit Committee (e.g. during investigations carried out by Investigators).
- Any other Employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.
The Company has constituted the Whistle Blower Protection Committee under the Chairmanship of a person from senior management and Ethics Counsellor as Convener.
In case a Whistle Blower feels that he/she has been victimized in employment related matters because of reporting about the violation of the Code, he/ she can submit a “Grievance” to the Ethics Counsellor, giving specific details of nature of victimization allegedly suffered by him/her. All such grievances will be forwarded to the aforesaid committee. The Committee will meet at regular intervals and examine the grievances on their merits. The Committee will also conduct necessary investigation of the concern and recommend appropriate action as the case may be.
While Management is determined to give appropriate protection to the genuine Whistle Blower, the employees at the same time are advised to refrain from using this facility for furthering their own personal interest. If proved, such cases may be referred to the Whistle Blower Protection Committee for disciplinary action.
- Investigators are required to conduct a process towards fact finding and analysis related to alleged improper or unethical activities. Investigators shall derive their authority and access rights from the Company/Audit Committee when acting within the course and scope of their investigation.
- Technical and other resources may be drawn upon as necessary to augment the investigation. All Investigators shall be independent and unbiased both in fact and as perceived. Investigators have a duty of fairness, objectivity, thoroughness, ethical behavior, and observance of legal and professional standards.
- Investigations will be launched only after a preliminary review which establishes that:
i The alleged act constitutes an improper or unethical activity or conduct, and
ii Either the allegation is supported by information specific enough to be investigated, or matters that do not meet this standard may be worthy of management review, but investigation should not be undertaken as an investigation of an improper or unethical activity.
If an investigation leads the Ethics Counsellor/ Audit Committee to conclude that an improper or unethical act has been committed, the Ethics Counsellor/Audit Committee shall recommend to the Management to take such disciplinary or corrective action as they deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures.
The Ethics Counsellor shall submit a report on a quarterly basis to the Audit Committee regarding total number of disclosures received in previous quarter, nature of complaint, outcome of investigation, actions recommended by the Ethics Counsellor/Audit Committee and implementation of the same. The Ethics Counsellor should also report to the Audit Committee the concern raised for victimization for employment related matters by the Whistle Blower and action taken by the Whistle Blower Protection Committee. Such Reports on the above shall be reviewed and recorded by the Audit Committee.
12. Retention of documents
All Protected Disclosures in writing or documented along with the results of investigation relating thereto shall be retained by the Company for a minimum period of seven years.
The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification will be binding on the Employees unless the same is notified to the Employees in writing.
This supersedes our earlier Whistle Blower Policy.
WHISTLE BLOWER PROTECTION POLICY FOR VENDORS
In compliance with Clause 25 of Tata Code of Conduct and in furtherance with the Company’s policy to encourage and protect genuine Whistle Blowing by Vendors, a Vendors Whistle Blowing Protection Policy has been developed.
- “Vendor Whistle Blower” means a person/organization registered in Vendor Data Base of the Company, making a Protected Disclosure and thereafter extending whatever assistance required in establishing the facts mentioned in the Disclosure.
- “Protected Disclosure” means any communication in relation to matters concerning the Company, which is made in good faith that discloses information that may evidence demand for illegal gratification and/or unethical or improper activity of serious nature by any other person or vendor.
- Protected Disclosures should preferably be reported in writing i.e. in ink or electronically and should be factual (not speculative) so as to ensure a clear understanding of the issues raised by the Whistle Blower.
- Misconducts, those concerning the Ethics Counsellor and employees at the levels of KW-3 and above should be addressed to the Chairperson of the Audit Committee of the Directors of the Company and those concerning other employees should be addressed to the Ethics Counsellor of the Company.
- The contact details of the Chairperson of the Audit Committee of Directors and of the Ethics Counsellor of the Company are as under:
Chairperson of the Audit Committee:
Mr. V. S. N. Murty,
Tata Steel, Tata Centre,
1st Floor, 43, J.L.Nehru Road,
Kolkata – 700 071, India. Phone No. : 033-22882684 , email : firstname.lastname@example.org
TRL Krosaki Refractories Limited,
Phone No : , Email id :
Protection to the Whistle Blower:
- The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair practice being adopted against the Whistle Blowers while conducting business with the Company.
- The Whistle Blower shall be protected from any retaliation, threat or intimidation of untimely termination/suspension of their contracts/orders, refusal of issuing ‘RFQ (Request For Quotation)’ to them, or any direct or indirect use of authority to obstruct the Whistle Blower to continue to execute their jobs including making further Protected Disclosure.
- GM (MMD), Divisional Heads and Departmental Heads of the concerned user departments shall ensure that the Vendor is provided all assistance required to execute the existing orders.
- Identity of the Whistle Blower shall be kept secret and under no circumstances, the investigator shall be compelled by anybody to disclose the identity of the Whistle Blower.
Any abuse of this protection by vendors will warrant disciplinary action.
Vendor Whistle Blower Protection Committee:
The Company shall constitute a Vendor Whistle Blower Protection Committee. In case a Whistle Blower feels that they have been victimized because of reporting about an unethical act then they can submit a “Grievance” to the Ethics Counsellor / Managing Director, giving specific details of nature of victimization allegedly suffered by them. All such grievances will be forwarded to the Committee for their examination. The Committee may conduct necessary investigation of the concern and recommend appropriate action as the case may be.
The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever.
Notification to this Policy:
Departmental Head – Materials Management shall ensure that the approved copy of this policy and its subsequent amendments if any are notified to all the Vendors engaged in business with the Company.
AFFIRMATIVE ACTION POLICY
TRL Krosaki Refractories Limited believes in social equity. It is committed to undertake and support initiatives to ensure an equal footing for socially and economically disadvantaged sections of the society in general and the Scheduled Caste and Scheduled Tribe community in particular. Towards this, the Company affirms that
- It shall assist members from these communities for employment opportunities on the basis of equal merit
- It shall continue to support skill development programmes aimed at creating and enhancing employability amongst youth from these communities
- It shall encourage business entrepreneurs from these communities through training, mentoring and by inclusion in supply chain on the basis of equal merit, quality and cost
- It shall continue to assist the talented youth from these communities by increasing their access to quality education through its scholarship and support schemes
The company will report its Affirmative Action initiatives in its Annual Report.
Managing Director & Occupier