Anyone can report a wrongdoing committed by TSN. Anyone can also report a wrongdoing committed by another party if this can damage TSN's reputation. The reporting method differs for employees and external parties.

A wrongdoing exists in the event of a violation of laws or regulations and/or the internal rules of TSN described above and/or if the public interest is at stake. A more detailed explanation of what constitutes a wrongdoing can be found in the Confidential Reporting Policy.

For concerns about an imminent threat of bodily injury or damage to property or persons, contact local security or emergency services immediately. Never use the channels listed below for this.

Complaints about commercial decisions/activities
Reports made to challenge commercial decisions/activities or to obtain confidential company information cannot be reported in this way and will therefore not be handled. We have a separate complaints procedure for customers, they can contact their account team.

Personal complaints about a decision/treatment in the employee-employer relationship
Employees can best report personal complaints about the employee-employer relationship (related to, for example, selection procedures, job evaluation, personal performance evaluations) via the appropriate HR procedures in the HR-portal. We, in principle, forward reports of such HR-related issues to HR.

Reports of undesirable behaviour in your area
Undesirable behaviour in your area can be reported using a separate HR procedure to optimally address these concerns. See the HR-portal. When such issues are reported through the channels listed below, we will also, in principle, forward them to HR.

You can make a formal report through one of the internal reporting channels listed below:

a. through the Integrity Line reporting system (for anonymous and non-anonymous reports); or  
b. to the Director Legal & Compliance TSN; or
c. to the Managing Director of Tata Steel Nederland Services BV in the position of Director Integrity & Asset Protection TSN. 

Below is more information about use of the Integrity Line. Contact details for (b) and (c) can be found on the TSN Intranet. Reports to (b) and (c) can be made in writing or by telephone. You can also request a meeting. In the case of an oral report, a written report of the meeting will be drawn up, which we will submit to you for correction (if necessary) and signature.

An internal report via the channels mentioned above is preferred because this means that wrongdoings can be dealt with in a timely manner.

You can also report a wrongdoing externally. You can make a formal report to an external agency that you believe is the most appropriate.  How to make an external report can be found on the website of the relevant authority. If necessary, you can obtain advice about making an external report and choosing the competent authority from the external agency.

You are also free to decide to report wrongdoings to your line manager or other TSN manager, either verbally or in writing. In certain countries, you have the opportunity to consult a confidential adviser in confidence about a suspicion of wrongdoing. A confidential adviser can advise a person intending to make a report about the possible procedures they can follow internally or externally and about the protective measures that can be implemented. See the HR-portal The legal protection of whistleblowers by the respective applicable laws in your country, however, only applies to formal reports made via the above-mentioned internal reporting channels or via an external agency.

You can report a wrongdoing committed by TSN via the Integrity Line reporting system (for anonymous and non-anonymous reports). Below is more information about use of the Integrity Line. You can also report a wrongdoing to your respective line manager or other TSN manager. The legal protection of whistleblowers by the respective applicable laws in your country, however, only applies to formal reports made via Integrity Line reporting system.

The Integrity Line reporting system is managed by an external, independent party. Via the free telephone service or the internet, you can report a wrongdoing at any time of the day in your preferred language. In the case of a telephone report, a written record of the conversation will be drawn up and submitted to you for correction (if necessary) and signature. It is important that you provide sufficient details so that the report can be thoroughly investigated. Providing supporting evidence is therefore highly appreciated.

Anonymous report
Starting point of the Integrity Line is that the report is anonymous. TSN employees handling the report do not have access to the phone number or email address used for the report; they only have access to the content of the report itself. They will only contact the person who made the report based on the reference number through the feedback process of the confidential reporting system. The TSN employees involved will make every effort to ensure your anonymity. However, it is possible that the TSN employee who handles your report can deduce from the report and/or the investigation who the source of the information is.

Non-anonymous report
It is advisable to indicate in your report that you do not wish to remain anonymous and that you agree to the use of another means of communication. It is more difficult to properly investigate an anonymous report and in some cases even impossible. 

Confidentiality
Regardless of how you make the report: all reports will be handled confidentially. TSN employees who handle and/or investigate the report only share the report with other persons if it is really necessary to determine an appropriate course of action and to conduct a proper investigation (if applicable) and for corporate reporting purposes. In some cases, these individuals may also be third parties, such as TSN's external auditors or outside legal counsel and are subject to equivalent rules concerning confidentiality.

In all cases, the TSN employee handling the report will not disclose your identity to others without your consent. The TSN employee handling the report will also do everything possible to ensure that other parties involved in an investigation do not learn the identity of the person who made the report. Nevertheless, it is possible under certain circumstances that other parties involved in an investigation may suspect the identity of the person who made the report. If the TSN employee concerned is legally obliged to communicate the identity of the person who made the report, which may be the case in the event of an investigation by an authority or legal proceedings, they will, in principle, inform you in writing with an explanation. This is only different if this could jeopardise the relevant investigation or legal proceedings.

If you are concerned about possible retaliation should your identity become known or if it were to be deduced from the investigation, we encourage you to state this in your report.

Who handles and investigates my report?
After an initial assessment of a report, it is decided whether further investigation is required and, if so, who the right person is to conduct the investigation into the wrongdoing. These investigations are conducted in compliance with group policies, operational guidelines and rules of procedure, as well as the legal requirements of the country in question. They are carried out with due care and in a confidential manner.

You will be kept informed via the person/system where the report was made. You will receive a confirmation of receipt of the report within seven days. You will then receive information about the assessment of the report and, where applicable, the follow-up to the report, including planned measures and those already taken, as well as reasons for these, within a reasonable period of no more than three months after the confirmation of receipt. Due to its confidential nature, it is possible that not all specific details of the investigation will be disclosed. For example, no information is provided about disciplinary or criminal action taken against anyone, unless required by law. Also, no confidential company information and personal data are provided.

TSN does not tolerate any form of disadvantaging towards persons who report a wrongdoing and will take appropriate measures to protect individuals who make a report in good faith against any adverse consequences. This also applies to those who assist the person making the report. Persons who make a report or persons assisting a person who makes a report who believe they have been disadvantaged by TSN must report this to HR. Anyone who threatens retaliation or actually retaliates against a person making a report will be subject to disciplinary or other action within the capabilities of TSN. 
Disciplinary or other action will be taken if the system were to be misused to knowingly report false, spurious or malicious complaints.