Policy

We do not tolerate corrupt or fraudulent practices and expect transparency, integrity and honesty in all aspects of our business, from our employees, contractors and other business counterparts. The tone is set through the commitment made by our most senior management and is integrated into the induction of new employees.

Code of Conduct and Anti-Fraud Programme

Our work on producing a new Company wide Code of Ethics for Corus in 2007 was refocused following the acquisition of Corus by Tata Steel UK Ltd. We are now, in partnership with our new parent company, supporting the development of, and implementation plans for the roll-out of a new Tata Steel Group Code of Conduct. 

We have also updated our Anti Fraud and Prevention of Corruption policies and worked on developing on-line training modules, customised to the practical needs of our businesses, in support of communication. Integration of our Anti-Fraud and Prevention of Corruption policies with the values and principles of our new Code is key to the foundation of our business principles and we plan to align communication to the new Tata Steel Group Code of Conduct 2008 as soon as it is finalised.

Competition Compliance programme

Corus’ first competition compliance programme was launched in 2005 and was fully implemented in 2006. During 2007/08, we continued to ensure induction of all new employees and those who moved post to areas where this training was relevant to the fundamentals of the programme, and also worked to create new refresher competition compliance programmes for roll-out to employees in 2008/09. Our development work included updating all of our policy documents and on-line training programmes.

The on-line training programmes are updated versions of the original competition compliance programme and will continue to be made available in the major European languages: English, Dutch, French and German. Each programme contains real business situations in practical case studies to ensure that they are truly meaningful for individuals and for the Company’s operations as a whole.

In 2008/09, two new, shorter on-line training programmes will be made available to Corus employees; “General Competition Compliance” and “Audit and Refresher”, and participants will have a choice of which programme to undertake. Participants are required to complete a certification page as a measure of compliance and to ensure that they have understood the importance of competition compliance.

Our on-line programme is simple to use, effective and with the ability to reach a diverse employee base. It allows monitoring of compliance awareness and knowledge, and is an effective instrument in auditing the overall programme.

Seminars and workshops on competition compliance continue to be offered to all our businesses, as a support and follow up to the overall programme and on-line training. In addition, throughout 2007 we continued to provide training sessions within Corus to personnel who may have responsibility for dealing with regulatory investigations. This training included “mock” exercises.

Export compliance programme

In 2007, we reviewed and strengthened our export compliance policy and guidance. We developed an intranet based resource centre and relevant training. We also began development of an on-line training package customised to our Company’s particular needs, to support our network of export control co-ordinators and their teams within our businesses. 

Suppliers and contractors

We encourage our suppliers and contractors to operate to the same standards as Corus.

Whistleblowing system.

Corus wants to hear employee concerns (including issues relating to contractors) and we are committed to addressing them fairly, properly and with integrity. Therefore our confidential reporting line (whistleblowing) still continues to be used as an effective tool for employees to report any concerns.

Integrity and honesty are at the heart of our business dealings. We continue to raise employee awareness of the whistleblowing line through publications in internal magazines and on our intranet. New initiatives planned for this year include launching a question & answer document on the whistleblowing line, issuing every Corus employee with a personalised wallet card giving details of our confidential reporting line and a poster communication for raising awareness at all Corus sites.

We have further advanced the confidential reporting line this year by introducing a confidential web-based reporting system where employees can report concerns in confidence by email. Like the phone system, using the email service is extremely easy and anonymity is guaranteed. Employees do not need to leave their name and emails cannot be traced.

Whistleblowing matters continue to be investigated by the Asset Protection units or Internal Audit. Matters are reported quarterly at our cross functional asset protection meetings, to the Corus Executive Committee and to our Board Audit Committee. All matters reported are reviewed to ensure we adopt key lessons and recommendations arising from any incidents.

Political activities and contributions

We do not contribute to political parties or funds, nor do we take part in party politics.

Risk management

We take an integrated approach to the management of the diverse risks which might affect our business. Potential risks are identified through techniques such as auditing, near-miss reporting and risk assessments. The process of minimising and managing risks is built into our management and reporting systems.

Our internal audit programme, our policies and our standards provide a framework for a healthy compliance culture.

Assurance

Internal assurance is achieved through an audit process aimed at strengthening our controls and ensuring the completeness and accuracy of information. External assurance is obtained through our financial auditors, through accredited certifiers in relation to standards such as ISO 9001 and ISO 14001 and through the validation of this report by Enviros Consulting Limited.