Securities transactions and confidential information

An employee of a Tata company and his or her immediate family shall not derive any benefit or assist others to derive any benefit from access to and possession of information about the company or the Group, which is not in the public domain and thus constitutes insider information.

An employee of a Tata company shall not use or proliferate information which is not available to the investing public and which therefore constitutes insider information for making or giving advice on investment decisions on the securities of the respective Tata company on which such insider information has been obtained.

Such insider information might include the following:

acquisition and divestiture of businesses or business units;

financial information such as profits, earnings and dividends;

announcement of new product introductions or developments;

asset revaluations;

investment decisions/plans;

restructuring plans;

major supply and delivery agreements;

raising finances.

Protecting company assets

The assets of a Tata company shall not be misused but shall be employed for the purpose of conducting the business for which they are duly authorised. These include tangible assets such as equipment and machinery, systems, facilities, materials and resources as well as intangible assets such as proprietary information, relationships with customers and suppliers, etc.

Citizenship

An employee of a Tata company shall in his or her private life be free to pursue an active role in civic or political affairs as long as it does not adversely affect the business or interests of the company or the Group.

Integrity of data furnished

Every employee of a Tata company shall ensure, at all times, the integrity of data or information furnished by him or her to the company.

Reporting concerns

Every employee of a Tata company shall promptly report to the management any actual or possible violation of this code, or an event he or she becomes aware of that could affect the business or reputation of his/her or any other Tata company.