U. S. Steel Canada Code of Ethical Business Conduct - EthicsPoint

ApplicationThe U. S. Steel Canada Inc. Code of Ethical BusinessConduct (Code) applies to all of us — directors,officers, and full-time and part-time employees ofU. S. Steel Canada. Throughout the Code, when werefer to employee or employees, we also mean directorsand officers. In addition to this Code, we are requiredto comply with all applicable U. S. Steel Canadapolicies, procedures, plant work rules and plant rulesof conduct. Failure to follow them subjects us todisciplinary action, up to and including suspension ortermination of employment. U. S. Steel Canada forbidsretaliation against anyone who in good faith reports asuspected ethics or compliance violation.

Table of ContentsA Message From the Chairman of United States Steel 2Our Commitment 3Know the Right Thing to Do 4Principle 1 - Take Responsibility for the Safety of Yourself and Others 6Principle 2 - Treat Others with Dignity and Respect 8Principle 3 - Protect the Environment 10Principle 4 - Conduct Business with Utmost Integrity and Only forthe Benefit of U. S. Steel Canada 12Business ConductConflicts of InterestGifts and EntertainmentInsider TradingPrinciple 5 - Assure Financial Reports are Accurate and SafeguardConfidential Information 14Financial Reporting and Internal ControlsConfidential InformationDisclosures of Information Outside of United States SteelPrinciple 6 - Protect and Properly Use Company Assets 16Records and Information ManagementCorporate Information ResourcesCopyrighted MaterialCorporate IdentityPrinciple 7 - Conduct Business Fairly and Lawfully 18AntitrustAnti-Bribery and Anti-CorruptionFair DealingGovernmental ContactsCampaign and Election ActivitiesSanctions and Trade EmbargoesAnti-Slavery and Human TraffickingImport ComplianceDo the Right Thing 22The Ethics LineOur Ethics and Compliance Program and ResourcesAdministration 24Disclosure 24The Gary Principles 24A Message From the United States Steel Compliance Officer 25Do What’s Right 1

Know the Right Thing to DoThe Code sets forth the company’s expectations for our behavior to meet the ethicaland legal standards that keep our company competitive. Every day, we makedecisions that affect our company’s relationships with customers, suppliers, investorsand communities; our own relationships with co-workers; and U. S. Steel Canada’sreputation. The Code cannot specifically address every conceivable situation we mayencounter in our business activities, but that does not relieve us of responsibility fordoing the right thing. When we are uncertain of what action to take, the Code providesguidance and resources to assist us in choosing the proper course. We must alwayscomply with the spirit as well as the letter of the Code.Certain conduct clearly steps over the line between right and wrong, violates companypolicy and is prohibited by our Code. Sometimes, however, the proper choices anddecisions are not clear because the ethical considerations in a particular situation aresubtle or complex. If we ignore such issues and make awrong decision, both the company and we as individualsmay face serious consequences.To help us determine the right thing to do, we shouldask ourselves the following questions before acting:• Do I consider whether I am treating others the waythey would like to be treated?• Do my actions meet the letter and spirit ofapplicable laws?• Are my actions in compliance with the company’spolicies and procedures?• Are my actions in the company’s best interests?• What would my supervisors, co-workers, family andfriends think of my actions?• How would my actions look in the headline of anewspaper or sound to a jury?Each of us plays an important role in the success of ourcompany. The principles set forth on the following pageswill guide us in making the right decisions.4 Code of Ethical Business Conduct

Assess the SituationI cut my hand on the job and I thinkit just needs a bandage. If I reportit to my supervisor, it will hurt ourdepartment’s safety performance.What should I do?Report this injury to your supervisorand he or she will assure that youobtain proper medical attention. Allinjuries, incidents and potentiallyunsafe conditions, no matter howminor they may seem to be, mustbe reported immediately. Yoursupervisor is also responsible topromptly investigate the incident andremedy any unsafe condition. Yourprompt report will assure that youget any required medical treatmentand may prevent someone else fromsustaining a similar injury.■ ■ ■The back-up alarm on my forklift isnot functioning properly. The forkliftoperates well otherwise, and I canstill move the material without thealarm. What should I do?Stop using the forklift immediatelyand report the malfunction to yoursupervisor. The supervisor hasthe responsibility to ensure thatthe equipment has been removedfrom service and that alternativeequipment is available to perform thework in a safe manner. The supervisormust also verify that the necessaryrepairs have been completed beforethe equipment is returned for use.1TAKE RESPONSIBILITY FOR THE SAFETYOF YOURSELF AND OTHERS.PrincipleU. S. Steel Canada operates under the guiding principle that all incidents can beprevented and the firm belief in personal responsibility.Safety is our primary core value. Each of us wants to return home from work safely atthe end of every day. Ensuring a safe workplace improves productivity, quality, reliabilityand financial performance. “Safety First” means taking personal responsibility to followsafe work practices and ensure safe working conditions for everyone. This safetymindset is as essential to our success as the tools and technologies we use on the job.Safety must be a way of life for us, our families and our co-workers.Our company’s safety processes explain the rules, procedures, laws and regulationsthat protect our health and safety, and training programs guide us on how to comply.The success of our safety and health program always rests with us. Our responsibilityis to know and follow the rules and procedures for working safely, such as:• Eliminate or safeguard against all workplace hazards.• Keep our workplaces free of alcohol and illegal drugs as well as the effects oftheir use (including the inappropriate use of prescription drugs).• Immediately report to our supervisors all injuries, incidents, illnesses andunsafe conditions.• Obtain immediate medical attention for all injuries.• Wear all required personal protective equipment at all times.If an incident occurs, supervisors are required to ensure that anyone who is injuredreceives prompt medical attention, that the incident or unsafe condition is investigatedand remedied, and that the event is reported properly and in a timely manner.6 Code of Ethical Business Conduct

How to Report a Safety Incident:If you are aware of a safety incident, you shouldreport it to your supervisor or the Safety andIndustrial Hygiene Department immediately.You may also raise safety concerns through theU. S. Steel Safety Hotline in any of thefollowing ways:• Telephone: 1-877-723-3967• Internet: www.ussteel.com/corp/SafetyHotline• U. S. Steel Intranet: Click on “Safety Hotline”under “Employee Links”For more information, consult U. S. SteelCanada Policy 2008-C – Safety and IndustrialHygiene and U. S. Steel Canada Policy5303-C – Alcohol and Drug Policy.Assess the SituationI think someone on my team mayhave violated a safety rule andcovered it up. He said it was veryminor and nothing to worry about.I don’t want to get involved butshouldn’t somebody hear about this?What should I do?If you have any concerns aboutsafety issues, or suspect a violationof our Safety Program or any lawsand regulations, you should reportit promptly to your supervisor, tothe Safety and Industrial HygieneDepartment or the Safety Hotline.Examples include, but are notlimited to:• Violation of a LifeThreatening Program• Unsafe Work Conditions• Housekeeping Issues• Personal Protective Equipment(PPE) Concerns• Procedure or Practice Violation• Improperly or Poorly MaintainedTools and Equipment• Inadequate TrainingNever assume that your departmenthead already knows about theviolation. When in doubt, it is best tospeak up.Do What’s Right 7

Assess the Situation:My supervisor is sending me e-mailsthat comment on my physicalattractiveness and clothing and makeme uncomfortable. I’m so worriedabout this that it is starting to affectmy work. I have asked her to stop,but she said that I’m being “toosensitive.” What should I do?Report the behavior to yoursupervisor’s direct supervisor, orif you are not comfortable doingthat, report it to your EmployeeRelations or Human Resourcesrepresentative or the U. S. SteelEthics Line. Inappropriate andunwelcome advances of this kindare unacceptable and may be aform of sexual harassment becausethey create a hostile workingenvironment and interfere with yourwork performance.2TREAT OTHERS WITH DIGNITY AND RESPECT.PrincipleWe must treat others with dignity and respect in the workplace, which means embracingthe strengths and unique differences each of us brings to our work. We must understandand appreciate the importance of diversity and inclusion, fostering an environment thatvalues individual differences and encourages every employee to reach his or her fullpotential at our company.We value a work environment free of offensive, insulting, hostile or intimidating behaviorof any type, including words, actions, documents or pictures. We must conduct ourselvesin the workplace without regard to race, ancestry, place of origin, colour, ethnic origin,citizenship, creed, sexual orientation, age, record of offences, marital status, family statusor disability.We will not tolerate discrimination or sexual harassment, whether committed by ouremployees or by employees of suppliers, contractors or customers. If you experiencediscrimination or sexual harassment, or if you believe a co-worker is experiencingdiscrimination or harassment, you have both a right and a duty to report it promptly tomanagement. You can report such harassment to your supervisor, your supervisor’sdirect supervisor, your Employee Relations or Human Resources representative, or to theU. S. Steel Ethics Line (as described on page 22). For more information on discriminationand sexual harassment, consult U. S. Steel Canada Policy 5003-C – Sexual Harassmentand U. S. Steel Canada Policy 5004-C – Harassment and Discrimination.We should all be able to work in an environment free from violence and threats ofviolence. We will not tolerate any act of workplace violence on our property by anyindividual. If you are aware of a workplace violence incident or a potential threat, youmust immediately report such acts or situations to management. If the situation involvesyour direct supervisor, you must report the matter to your supervisor’s direct supervisor,your Employee Relations or Human Resources representative, or to the U. S. Steel EthicsLine. For more information on workplace violence, consult U. S. Steel Canada Policy2008.1-C – Prevention of Workplace Violence Policy.We will also not tolerate retaliation in any form against anyone who raises a good faithconcern about discrimination, sexual harassment or workplace violence.8 Code of Ethical Business Conduct

Assess the Situation:One of my co-workers told methat some of the other people inour department have been makingderogatory comments abouthomosexuality in his presence. Hesays it doesn’t bother him and he’sused to it. He wants me to stay out ofit. What should I do?Our company does not toleratediscrimination, and you have a dutyto report these incidents even if yourco-worker asks you not to do so.Refer your co-worker to U. S. SteelPolicy 5004-C and encourage him toreport these incidents.■ ■ ■A co-worker was disciplined recentlyby our supervisor. He told me that hewas angry about it and that “the bossshould watch his back” becausehe was going to “get him.” I amconcerned that he is serious aboutharming our supervisor. What shouldI do?For the safety of your co-workers,immediately report your concern toyour supervisor and to the SecurityDepartment at your location. Neverassume that someone else will speakup. Do what’s right and take action.Do What’s Right 9

3PROTECT THE ENVIRONMENT.PrincipleEnvironmental stewardship is a core value of our company. This means reducing emissions,conserving energy and other resources, reusing or recycling byproducts, as well asinvolvement in community partnerships that protect and preserve natural resources.Assess the SituationIt’s the last day of the month and weneed a big production day at the cokeplant to meet our Business Plan. Ifour operators push the coke early(when it’s green), we can maximizeour output. That will mean moreemissions and it doesn’t complywith established operating andenvironmental standards. Couldn’tI push green coke just this once, sothat I can meet the Business Plan?Each employee has a personal responsibility to comply with all environmental laws andregulations as well as our environmental policies, practices, procedures and initiatives.Failure to do so may result in both fines and penalties for our company as well as fines orimprisonment for individual employees.We are required to report immediately any actual or potential violation of environmentallaws or regulations to our supervisors and to the Environmental Control Department at ouroperating facilities. You may also contact the U. S. Steel Ethics Line. For more information,consult U. S. Steel Policy Canada 2007-C – Environmental Management.NO. Do not push the green coke. Wemust never operate plant facilitiesin violation of established standardsfor protection of the environment,and we should never violate anylaw, regulation, company policy,or standard work practice in orderto meet business plans, forecastsor performance goals. If you areinstructed or pressured by yoursupervisor or anyone else to violateany law, regulation or companypolicy, you must report this either toyour supervisor’s direct supervisor orto the U. S. Steel Ethics Line.10 Code of Ethical Business Conduct

Assess the SituationA 220-litre drum of hazardous wastespilled onto the ground. We promptlyaddressed the spill and made allthe necessary verbal notificationsto the provincial Ministry of theEnvironment, but regulations requireus to submit a written follow-upletter to the Ministry within ten daysof the spill. The Ministry official towhom I initially reported the spill,however, told me over the phonethat he does not see the need forthe written report since the spill wasrelatively small and has already beenaddressed. Do I still need to send thewritten follow-up report?Yes. You must still send thewritten follow-up report. A Ministryofficial may tell you that a writtenfollow-up report is not required forminor reportable events, especiallyif the official has a long and goodrelationship with the facility’senvironmental personnel. However,U. S. Steel Canada could bepotentially subject to enforcementby the provincial Ministry of theEnvironment or Environment Canadaif your facility does not submit thereport. We must meet all regulatoryobligations even if an agency officialsuggests otherwise.Do What’s Right 11

Assess the SituationI’ve built an online business that’sgrown rapidly. When requests forinformation come in, I need torespond quickly. Is it all right to dothis from work?No. Your primary responsibility,allegiance, and attention while atwork must be to your assigned dutiesat U. S. Steel Canada. The situationyou describe would definitely detractfrom your ability to do so. Any useof company property to conductthis business violates our policy. Inaddition, your business must notconflict or compete with U. S. SteelCanada, or appear to be a conflictunder U. S. Steel Canada Policy2002-C.■ ■ ■My son just took a job with acompany that supplies services toU. S. Steel Canada. His job is purelytechnical and it will involve no directcontact with our company. Do I needto report this as a conflict of interest?4CONDUCT BUSINESS WITH UTMOSTINTEGRITY AND ONLY FOR THE BENEFITOF U. S. STEEL CANADA.PrincipleBusiness ConductWe must perform our job responsibilities ethically, lawfully, and only in the best interestof the company. We must conduct ourselves in a manner that reflects positively onU. S. Steel Canada and refrain from behavior that would harm the company’s reputationor commercial advantage. We must devote our efforts at work to achieving the company’sbusiness goals. Behavior that creates the perception that our decisions and actions aremotivated by personal relationships or for personal gain violates our standards of conduct.For more information, consult U. S. Steel Canada Policy 0002-C – Business Conduct.Conflicts of InterestA conflict of interest exists if our personal financial interests or activities or those ofa family member influence or interfere with our obligation to perform our jobs in thebest interests of the company or if they appear to do so. In addition, participation in apersonal business, public office, or in some cases, a not-for profit organization that mayprevent the required commitment of time and effort to our jobs can also be a conflictof interest. We must promptly disclose any situation that may be or may appear to bea conflict of interest. For more information and for forms and guidance for disclosingpotential conflicts, consult U. S. Steel Canada Policy 2002-C – Conflicts of Interest andU. S. Steel Canada Policy 2003-C – Participation in Businesses Other Than U. S. SteelWhere No Conflicts of Interest Exist.Yes. Under U. S. Steel Policy 2002-C– Conflicts of Interest, you mustpromptly disclose this situation asa potential conflict of interest. TheConflicts Committee will determinewhether a conflict actually existsbased on your particularcircumstances and provideappropriate guidance.12 Code of Ethical Business Conduct

Gifts and EntertainmentWe are discouraged from accepting significant or frequent gifts or entertainment fromcustomers, suppliers or others with whom U. S. Steel Canada does business or may dobusiness in the future. We must avoid any situation where the acceptance of a gift orentertainment would be — or could appear to be — inappropriate or in conflict with thebest interests of U. S. Steel Canada. We may accept infrequent gifts and entertainmentthat support our business relationships provided they are approved as required. We maynever solicit gifts or entertainment nor accept gifts of cash or cash equivalents suchas gift cards, stocks, bonds, loans, or commissions. We must always respect the giftsand entertainment policies of our business partners that may be the same or morerestrictive than our own. For more information, consult U. S. Steel Canada Policy 0006-C– Gifts and Entertainment.Insider TradingInsider trading is trading in stock or other securities on the basis of material, non-publicinformation and is illegal. In the course of doing our jobs, we may have or have access toinformation — such as earnings, dividend changes, mergers or acquisitions, or significantcontracts — that is not yet available to the public. This information might affect themarket value of United States Steel stock, or might be considered to be important by aninvestor in making an investment decision. As a result, we must not trade in securities ofUnited States Steel or any other company if we have of material, non-public information.In addition, we must not disclose such information to others, a practice known as“tipping.” You may be subject to penalties under the insider trading laws if you provideor receive a tip, even if you did not trade on the inside information. For more information,consult U. S. Steel Canada Policy 2005-C – Confidential Treatment and ExternalCommunication of Corporate Information. If you are unsure whether you are permitted totrade securities based on the information you have, contact the Law Department.Assess the SituationMy spouse and I were invited bythe president of an engineering firmwith whom U. S. Steel Canada isconsidering doing business to beguests in his firm’s private box ata professional hockey game. Hisinvitation includes tickets to thegame, a parking pass, food anddrinks. He told me that otherU. S. Steel Canada employees(including my general manager) andtheir spouses also have been invited.May I accept the invitation?You must get approval from yoursupervisor before accepting theinvitation. The value of theentertainment most likely will exceed$200. The fact that other U. S. SteelCanada employees have also beeninvited does not relieve you from theresponsibility of obtaining yoursupervisor’s written approval. Inaddition, you should consider whatperceptions accepting this invitationmay leave with your co-workers,subordinates and other U. S. SteelCanada suppliers. As a rule, it isa good idea to discuss anyentertainment and gifts, regardlessof value, with your supervisor beforeaccepting them.Do What’s Right 13

Assess the SituationMay I accept a trade association’sinvitation to give a presentationabout U. S. Steel Canada at anupcoming meeting?You should discuss this invitationwith your supervisor and get theappropriate approvals including fromPublic Affairs before agreeing tospeak at the meeting.■ ■ ■Can I e-mail financial information toan external business partner?Yes. But only if approved. Youmust use the ‘Secure Mail’ functionavailable in Lotus Notes and youmust ensure that you send onlyfinancial information necessaryto the business relationship. Filesincluded as attachments to theemails should be password protectedwith the password provided to therecipient in a separate e-mail. If youare unsure whether the informationis confidential, please consult yoursupervisor, the Law Department, orU. S. Steel’s Compliance Officerfor guidance.5ASSURE FINANCIAL REPORTS AREACCURATE AND SAFEGUARD CONFIDENTIALINFORMATION.PrincipleUnited States Steel was the first company in the United States to hold an annualmeeting of shareholders and to publish an annual report. Business has grown morecomplex since the beginnings of our company, but the principles by which we dobusiness have never changed.Financial Reporting and Internal ControlsUnited States Steel is required by law to disclose accurate and complete informationregarding its financial condition and results of operations. We are also requiredto maintain an adequate structure of processes and procedures controlling theeffectiveness of accounting and financial reporting activities. We must maintain accuratebooks and records reflecting our business transactions and activities of the company,and perform our responsibilities in compliance with the company’s internal controls.Inaccurate, incomplete or untimely record keeping and reporting may violate the law andresult in liability to the company and individual employees. Employees, especially thoseinvolved in accounting or financial reporting activities in the investment community, mustunderstand and comply with all applicable accounting standards, laws and regulations,including but not limited to U.S. Generally Accepted Accounting Principles, U.S. securitieslaws and regulations, and the Sarbanes-Oxley Act of 2002. If you are aware of or suspectany situation involving the disclosure or recording of false, misleading, or confidentialinformation, you should report it to the U. S. Steel Ethics Line. For more information,consult U. S. Steel Canada Policy 6007-C – Receipt, Retention & Treatment of ComplaintsRegarding Accounting, Internal Control & Auditing Matters.14 Code of Ethical Business Conduct

Confidential InformationWe must safeguard and protect all confidential information in our possession or to whichwe have access, such as financial, operating, personnel, medical, legal, technical, orcommercial information, as well as information provided in confidence to U. S. SteelCanada by others. We must not:• Use confidential information outside our job responsibilities or for personal benefit.• Discuss confidential information with anyone outside of the company, includingfamily members, nor with other employees except on an as-needed basis.• Provide confidential information about the company to any third party unlessspecifically authorized.• Have access to, or use the confidential information of others, including formeremployers, unless U. S. Steel Canada has entered into a written agreement withrespect to such information and, only then, for agreed-upon business purposes.Correct safeguarding includes identifying information as “confidential,” securing itwhen not in use, refraining from discussing it in public areas, and taking precautionswhen transmitting it. In addition, we must protect the privacy and confidentiality ofcertain personal information, including employee records, protected health information,Social Insurance numbers, and other personal identifiers in the manner described inthe company’s policies and procedures. If you are uncertain as to a particular piece ofinformation, presume it is confidential and safeguard it appropriately.Our obligation to protect confidential information continues throughout our employmentand even after it ends. For more information, consult U. S. Steel Canada Policy 2005-C –Confidential Treatment and External Communication of Corporate Information;U. S. Steel Canada Policy 2009-C – Protection of Confidential and Trade SecretInformation; U. S. Steel Canada Policy 5107-C – Personal and Employment InformationPractices; U. S. Steel Canada Policy 5108-C – Protected Health Information; andU. S. Steel Canada Policy 5109-C – Privacy of Social Insurance Numbers.Assess the SituationA vendor has asked me to providenon-public financial data related tooperational costs, including coststo produce finished materials, tohelp that company obtain contractsunrelated to U. S. Steel Canada. Can Iprovide this information?No. Non-public financial datais confidential and may not beprovided to vendors for purposesunrelated to their relationship withU. S. Steel Canada.■ ■ ■It is month end, and I have alreadyspent or accrued up to my budgetedamounts. Can I hold a vendor invoiceor otherwise not account for knownliabilities until the following month?No. Excluding known liabilitiesduring a month results in thecompany’s liabilities beingunderstated. This could cause thecompany to restate its financialstatements. If you have anyquestions about how to account fortransactions, please contact yourlocal accounting representative.Disclosures of Information Outside of United States SteelOnly certain officers of United States Steel, its manager of Investor Relations and PublicAffairs and Governmental Affairs personnel, including U. S. Steel Canada’s Director ofGovernment and Public Affairs, are authorized to communicate with investment analysts,investors, the news media, government agencies, trade associations or other thirdparties. If you receive a request for financial, operating or other confidential information,you should not respond but should refer the request to Investor Relations, Public Affairs,or the Law Department. Any presentation proposed for non-U. S. Steel audiences mustbe provided to Public Affairs with adequate time for review and approval. The disclosureof confidential information through any form of social media such as blogs, networkingsites, or comment threads is prohibited. For more information, consult U. S. Steel CanadaPolicy 1804-C – Compliance with SEC Regulation FD; and U. S. Steel Canada Policy2005-C – Confidential Treatment and External Communication of Corporate Information.Do What’s Right 15

Assess the SituationI want to download free open sourcesoftware from the Internet. I thinkU. S. Steel Canada would approvebecause it will make me moreproductive. Can I do this?No. U. S. Steel Canada policy doesnot permit you to download freesoftware or shareware from theInternet. These may have backdooraccess points for worms and virusesthat can compromise the securityof our network. Also, software thatis freely available to an individualoften requires a license for use by anenterprise or organization.■ ■ ■I’d prefer to not carry my laptopwhen I travel, or to bring work home.May I save company documents to apersonal mobile device?No. You may use only U. S. SteelCanada approved and issuedcomputer equipment or mobiledevices such as: thumb drives,mobile phones or tablets to store,access, compile, or maintainU. S. Steel Canada businessinformation.■ ■ ■May I access company informationremotely?You may access some companyinformation, provided that you doit through the company-approvedconnection or a company-approvednetwork or source, such as iNotes.Even then, you must not save anycompany information on non-U. S. Steel Canada equipment.6PROTECT AND PROPERLY USECOMPANY ASSETS.PrincipleWe must use U. S. Steel Canada’s assets efficiently and for legitimate business purposesonly, and protect them against loss, damage, misuse, and theft. Company assets includeproperty, operating facilities, equipment, and accounts receivable, but also include ourcorporate identity, confidential information, trade secrets, business records, corporateinformation resources and copyrighted material. All of these assets enable us to compete,work productively, and maintain confidence in U. S. Steel Canada’s reputation.Records and Information ManagementOur company must create and maintain appropriate, accurate, complete, and timelybusiness records and information. These corporate records are critical to meet ourbusiness needs and any falsification is a serious offense. All business informationmaintained in any medium, including paper and electronic, is the property of U. S. SteelCanada. We may not store or maintain company records away from company facilities,including in our homes. We are required to retain business records and information forthe period required by the company. This includes retaining records and information inaccordance with hold notices issued by the company for litigation matters. We must alsocomply with applicable laws and company policy governing the destruction of businessrecords and documents after the required retention period has expired. We must alsofully cooperate with requests by internal and external auditors, Corporate Security, theLaw Department, and other authorized personnel to access company records. For moreinformation, consult U. S. Steel Canada Policy 2010-C – Records Management.Corporate Information ResourcesU. S. Steel Canada provides us with computers, software and other communication andinformation resources, such as mobile devices, to perform our jobs. We must protectthese resources and use them appropriately, responsibly, and for business purposes.We must protect the confidentiality, integrity, and security of the company’s computernetworks, applications, and data. We must not share our user accounts and passwordswith others and must safeguard them from disclosure. U. S. Steel Canada retains allrights to data, material and other information stored, processed or transmitted on itscomputers, mobile devices, or networks. None of us should expect that such data,material or other information is private. The establishment or usage of any non-approvedinternal network is prohibited and when connecting to external networks, you must usethe approved connection to the U. S. Steel Canada network. Personal use of companyprovidedresources is permitted but must be of reasonable duration and frequency, andmust not support a personal business, adversely affect U. S. Steel Canada, or interfere16 Code of Ethical Business Conduct

with job performance. We are prohibited from using the company’s resources to create,access, store or transmit pornographic, hostile, discriminatory, offensive or otherinappropriate material. The usage of unauthorized, unlicensed, or unapproved software,data, and other third party proprietary materials can cause liability to the company andyou. We must ensure that all software, data, and other third party proprietary materialsloaded on or accessed by our computers is authorized, licensed and approved for use.For more information, consult U. S. Steel Canada Policy 4302-C – Communication andInformation Resources, and U. S. Steel Canada Policy 0007-C – Employee Privacy andConfidentiality Related to the Use of Company Property.Copyrighted MaterialThe Internet, email and photocopy machines have made it extremely easy andconvenient to download, copy or reproduce articles, newsletters and other publicationsand to forward them in whole or in part to others. However, these actions may violatecopyright laws or license agreements.Always assume that articles, books, magazines, newspapers, trade journals, newsletters,photographs, technical drawings, and other publications — whether hard copy orelectronic — and all computer software, are protected by copyright law.U. S. Steel Canada has obtained a company-wide business license with an independentcopyright licensing agency that permits U. S. Steel Canada employees to engage inlimited copying of some protected works. This license does not, however, permit usto photocopy, download, print, or distribute entire publications; change or alter copiedarticles; e-mail online articles to individuals outside of the company; or post articles onany public website. Consult the Law Department to determine if a particular publicationor work is covered by U. S. Steel Canada’s license.Assess the SituationA favorite trade journal of minehas an online edition. We havealways circulated the printed journalthroughout the department using arouting list. Is it all right to forwardthis online edition to others?No. Always assume that copyrightlaw protects a particular work.U. S. Steel Canada’s copyrightlicense does not permit cover-tocoverphotocopying, downloading,printing, or distribution of entirepublications, either hard copy oronline. You may be able to sharea particular article electronically.However, you should not copy ordistribute paper copies or electronicversions of articles or other workswithout first determining if suchactions are permitted by law or byour license.Computer software is usually protected by copyright or license, even if a copyrightsymbol is not displayed. We must comply with all restrictions on copying, using anddistributing computer software sold to or licensed to the company. We must also ensurethat others who contract to provide services to U. S. Steel Canada comply with copyrightsand software licenses applicable to the services they provide to U. S. Steel Canada. Foradditional information, consult U. S. Steel Canada Policy 4301-C – Legal Protection ofComputer Software.Corporate IdentityUnited States Steel’s and U. S. Steel Canada’s trade names, trademarks, and servicemarks are the graphic identity of the products and services that our customers recognizeand rely on worldwide. We must protect the integrity of these identifiers by using themconsistently, uniformly and in compliance with U. S. Steel Canada policies. We must respectthe trademark rights of others and must not use the corporate logos or marks of othercompanies without the prior written approval of the owner. We must also ensure that thirdparties do not use our logos or marks without the prior written approval of U. S. SteelCanada. For more information, contact Public Affairs and consult U. S. Steel Canada Policy1101-C – Trademark, Service Mark and Trade Name Usage; and U. S. Steel Canada Policy1102-C – Corporate Identification Program.Do What’s Right 17

7CONDUCT BUSINESS FAIRLYAND LAWFULLY.PrincipleAssess the SituationMy supervisor has encouragedme to attend a $1,000 per personcampaign fundraiser for a Canadianfederal politician who has been verysupportive on issues important toU. S. Steel Canada. Is it all right toattend and put this on my businessexpense report?No. Canadian federal lawprohibits corporate contributions,directly or indirectly, to federalpolitical candidates or parties. Yourattendance is voluntary and yourpersonal choice. If you decide toattend, the cost of the event is atyour own expense and you may notask U. S. Steel Canada to reimburseyou. Consult U. S. Steel CanadaPolicy 0004-C – Public Affairs andPolitical Action for more guidance onthis subject.Each of us has a duty to conduct businessfairly and lawfully within U. S. SteelCanada and with our customers, suppliersand competitors. We must never takeadvantage of or provide special advantageto anyone – or even appear to do so –through manipulation, concealment, abuseof privileged information, misrepresentationof material facts, or any other unfairpractices. Fraud, theft, embezzlement,false or inflated billings, falsified expensereports, and payment of kickbacks forobtaining business are all examples ofillegal and unacceptable behavior. For moreinformation, consult U. S. Steel CanadaPolicy 0002-C – Business Conduct.Our duty also extends to complying with all applicable laws and regulations. Violations,even unintended ones, expose our company to serious criminal and civil penaltiesand fines, as well as penalties, fines, and even imprisonment for individuals. The legaldefense of claims, even when successful, squanders resources and compromises thereputation of U. S. Steel Canada. We should not engage in personal political activities oncompany time and we must observe gift rules associated with government officials.Antitrust and Competition LawU. S. Steel Canada must not engage in any understandings or agreements withcompetitors to restrain trade and we must avoid even the appearance of such conduct.We must compete independently in the marketplace in compliance with domestic andinternational laws. Examples of competition and antitrust violations are: price fixing;bid rigging; allocation of markets or customers; agreements to manipulate productionvolumes and group boycotts. If you have sales or marketing responsibilities orcommercial contacts, or if you attend trade association or industry meetings, you mustbe particularly aware of these prohibitions. If you have questions about the applicationof the antitrust laws, consult the appropriate contact in the Law Department beforetaking any action. Contact information is available on the Ethics and Compliance homepage on the U. S. Steel intranet.18 Code of Ethical Business Conduct

Assess the SituationWhen I attended a recent industryassociation dinner, I was seated witha competitor’s employees, one ofwhom began to talk about industrypressures and the possible effectsthey may have on her company’sprices. Could I have discussedU. S. Steel Canada’s concerns aboutthe same industry pressures?No. Even though you are membersof the same trade association, shestill represents a competitor andcompetition and antitrust lawsapply. Be aware that anticompetitiveactivity can occur even in casualsettings like the one you describe. Ifa conversation with an employee ofa competitor drifts into a potentiallyunlawful topic, you should removeyourself from the conversation andnotify the Law Department.Anti-Bribery and Anti-CorruptionEmployees and other representatives of U. S. Steel Canada may not directly orindirectly bribe or improperly influence any government official in Canada, the UnitedStates or in any other country or give the appearance of such conduct. Likewise, wemust not bribe or otherwise attempt to improperly influence private individuals orrepresentatives of other companies. We must also take appropriate measures to ensurethat agents, representatives and others working on the behalf of U. S. Steel Canada orits affiliates comply with all anti-corruption laws. Bribery or improper influence includesdirectly or indirectly giving, or promising to give, anything of value to any governmentemployee, official or representative, or political party employee, official, candidate orrepresentative for the purpose of obtaining a business advantage. Lavish entertainmentor travel might also be considered bribery.Anti-corruption and anti-bribery laws are often difficult to understand and apply.Employees who conduct business outside Canada should carefully review U. S. SteelCanada Policy 2015-C – Dealing with Foreign Governments and Agents and consult theLaw Department for further guidance. You can find contact information on the Ethicsand Compliance home page on the U. S. Steel intranet.■ ■ ■At the same event, an employee of acompetitor said that our respectivebusinesses would do better if wereduced production for one of theproduct lines we have in common.We weren’t discussing prices, so isthat an appropriate conversation?No. U. S. Steel Canada mustmake unilateral decisions aboutits business operations, includingproduction levels, and anycoordination with a competitor onthat topic would be unlawful. Donot engage in this discussion andcontact the Law Department.Do What’s Right 19

Fair DealingWe must deal fairly with suppliers, customers and other established or potential businesspartners. This means that we must provide only honest and accurate information regardingproducts or services, avoid any misleading statements to business partners to gaincompetitive advantage, and not make disparaging or untrue statements about competitors.Governmental ContactsWhen representing U. S. Steel Canada, our contacts with government officials andpersonnel, both in this country and abroad, must comply with all applicable laws andregulations to avoid even the appearance of impropriety or improper influence. Any support,assistance or entertainment that we provide when representing U. S. Steel Canada togovernment officials or personnel, either directly or indirectly, must be consistent with legaland ethical business practices. Even legitimate payments can appear suspicious whenhandled outside normal business channels and practices. If you have questions aboutcontacts with government officials or personnel, consult Governmental Affairs or the LawDepartment for guidance before taking any action. You can find contact information under“Corporate Links” on the U. S. Steel intranet home page.Assess the SituationI plan to meet with a vendor in acountry where it is customary toexchange gifts. The company isowned by that country’s government.May I provide a gift to my contact?In many parts of the world, it isstandard practice to exchangebusiness courtesies. However, anyemployee of a state-owned companymay be considered to be a “foreignofficial” under many anti-corruptionlaws. You should discuss thissituation with the Law Departmentbefore giving or receiving any giftsfrom a government official.20 Code of Ethical Business ConductCampaign and Election ActivitiesU. S. Steel Canada’s support for political candidates and parties may be provided onlythrough limited corporate contributions at the provincial or municipal level where permitted,and with the approval of U. S. Steel Canada’s Director of Government and Public Affairs.Federal law prohibits company contributions, either directly or through employees, tofederal political parties or candidates. We must not engage in any personal political activityon company premises or while otherwise engaged in company business, or use companyresources (computers, phones, copy machines, etc.) for personal political activities. Inaddition, we must not create the appearance that our personal political activities are acts ofor are sponsored by U. S. Steel Canada. If we participate in personal political activities, wemust do so on our own time and at our own expense. U. S. Steel Canada will not reimbursepersonal contributions to political parties or candidates. For more information, consultU. S. Steel Canada Policy 0004-C – Public Affairs and Political Action.Sanctions and Trade EmbargoesBoth the United States and Canadian governments use economic sanctions and tradeembargoes to further foreign policy and national security objectives. As both a Canadiancompany and a subsidiary of United States Steel, U. S. Steel Canada and its employeesmust, in our business dealings, abide by all sanctions and embargoes that may be ineffect. Also, we may not comply with a boycott imposed by a foreign country against acountry friendly to Canada or the United States. In most cases, the sanctions, boycottsand embargoes imposed by the two countries will be similar and compliance with one willamount to compliance with the other. However, as there are some differences between thetwo countries in these areas, be sure to consult the U. S. Steel Canada Law Departmentif you have a question as to whether a particular transaction is subject to a sanction orembargo or if you are asked to comply with a foreign boycott.Anti-Slavery and Human TraffickingU. S. Steel Canada does not engage in or support child labor, human trafficking or slavery, orknowingly support companies that utilize any form of child labor, slavery or human traffickingand we expect the same of our suppliers. If you have questions regarding anti-slavery andhuman trafficking laws, please consult the Law Department. Contact information is availableon the Ethics and Compliance home page on the U. S. Steel intranet.

Import ComplianceU. S. Steel Canada must fully comply with the laws and regulations governing theimportation of goods into Canada. This includes all facets of the importation processfrom sourcing merchandise through final payment. Compliance safeguards theability of U. S. Steel Canada to compete effectively in the domestic and internationalmarketplace. Laws and regulations governing the importation of goods are enforcedby, among others the Canada Border Services Agency and the Canadian InternationalTrade Tribunal. All U. S. Steel Canada employees, agents and contractors must fullyobserve these laws and regulations. Consult the Customs Compliance Specialist or theLaw Department if you have a question regarding import compliance on a particulartransaction or your role in the process.Do What’s Right 21

Assess the SituationI’m in the union; may I submit a reportthrough the Ethics Line?Yes. The Ethics Line is available toanyone to raise good faith concernsabout suspected illegal or unethicalconduct. However, the Ethics Lineis not a substitute for the grievanceprocedure provided by the applicablecollective bargaining agreementfor matters such as pay andscheduling disputes.■ ■ ■I prepare my supervisor’s expensestatements and I noticed that hehas been duplicating the same cashexpenses from previous reports. WhenI brought this matter to his attentionhe instructed me not to say anythingand put the cash expenses through.My co-worker told me not to getinvolved. What should I do?You should report this immediatelyto your supervisor’s direct supervisoror Internal Audit. In addition to thosereporting resources, you can alwaysraise your concern through theU. S. Steel Ethics Line.Do the Right ThingWe don’t have to go it alone if we face an ethical dilemma or need guidance on anethics or compliance issue. Using the resources described in this Code can help us withtough decisions or simply give us assurance that we are on the right ethical track. Wecan also raise concerns with our supervisors, Ethics and Compliance Managers, theEthics and Compliance Group in the Law Department, United States Steel’s ComplianceOfficer or the U. S. Steel Ethics Line. In addition, many of the policies discussed in thisCode provide specific procedures for reporting matters to the appropriate people.You can find all contact information on the Ethics and Compliance home page on theU. S. Steel intranet. These resources can help if you:• Have questions about the Code, policies or procedures.• Have concerns about unethical or illegal activities.• Need advice about an ethical dilemma.The Ethics LineIf you are aware of or suspect illegal or unethical conduct, you should promptly reportsuch conduct. The company has established the following convenient (and, if you prefer,anonymous) ways to raise good faith concerns through the U. S. Steel Ethics Line:• Telephone: 1-800-288-1307• Internet: www.ussteel.com/corp/EthicsLine• U. S. Steel Intranet: Click on “Ethics Line” under “Employee Links”• Mail: U. S. Steel Ethics Line, P. O. Box 2226, Pittsburgh, PA 15230-2226The Ethics Line is available 24 hours every day and is managed by an outside serviceprovider, independent of U. S. Steel.22 Code of Ethical Business Conduct

U. S. Steel Canada forbids retaliation against anyone making a good faith reportof suspected illegal or unethical conduct. For more information on the company’spolicies pertaining to the reporting of suspected illegal or unethical behavior, consultU. S. Steel Canada Policy 6006-C – Reports by Employees of Illegal or UnethicalConduct; U. S. Steel Canada Policy 6007-C – Receipt, Retention & Treatment ofComplaints Regarding Accounting, Internal Control & Auditing Matters, and relatedCompliance Tips.Our Ethics and Compliance Program and ResourcesThe Code of Ethical Business Conduct is an important component of U. S. Steel Canada’sEthics and Compliance Program. Doing what’s right must be embedded in the way weconduct business. All of us should share the same commitment in promoting a positiveethical culture to maintain the long-term success of our company. Along with the Code,the Ethics and Compliance Program provides us with the following additional resources:Corporate PoliciesGoing directly to the policies that address our questions will provide us with guidanceon what is expected of us and will help us determine the right thing to do. Currentversions of all company policies are available on the U. S. Steel intranet home page.Compliance TipsU. S. Steel Canada’s Compliance Manager periodically issues tips on laws, policies, andother ethics and compliance issues. These tips are intended to raise our awareness andprovide guidance on what we must do to comply. The Compliance Tips Index providesa listing of current tips and is accessible on the U. S. Steel intranet home page. If youdo not have access to the U. S. Steel Intranet, contact your Ethics and ComplianceManager to obtain a copy of a tip.Assess the SituationI’m not certain that what I witnessedis illegal or unethical conduct. Whatshould I do?When in doubt it is best to reportyour concern. As a guide, askyourself.• Does it appear to be a violationof the company’s policies orprocedures?• Does it appear to be dishonest?• If I were doing this, would I beembarrassed to tell my familyor friends?• Could this harm the company inany way?If you answered yes to any of thesequestions, you should speak up andreport your concern.Do What’s Right 23

The Gary PrinciplesI believe that when a thing is right, it willultimately and permanently succeed.The highest rewards come from honestand proper practice. Bad results comein the long run from selfish, unfair anddishonest conduct.I believe in competition…that the raceshould be won by the swiftest, and thatsuccess should come to him who is mostearnest and active and persevering.I believe that no industry can permanentlysucceed that does not treat its employeesequitably and humanely.Ethics and Compliance ManagersEthics and Compliance Managers at each operating facility, business unit, salesoffice and headquarters staff group serve as facilitators of the Ethics and ComplianceProgram in their areas. We can consult our Ethics and Compliance Managers regardingcompliance resources and guidance for resolving specific compliance-relatedquestions. Issues that cannot be resolved by the Ethics and Compliance Managershould be referred to the United States Steel Compliance Officer or a member of theEthics and Compliance Group in the Law Department.TrainingIn-person presentations provide in-depth training and discussion on a wide variety ofethics and compliance topics. Our Ethics and Compliance Managers are responsiblefor arranging these presentations for their areas of responsibility. In addition, the Ethicsand Compliance Group periodically launches web-based training on specific ethicsand compliance issues. If you believe that your area needs a particular compliancepresentation, please contact your Ethics and Compliance Manager.You can find links to all of these resources on the Ethics and Compliance home page onthe U. S. Steel intranet.I believe thoroughly in publicity. Thesurest and wisest of all regulation ispublic opinion.If we are to succeed in business, we mustdo it on principles that are honest, fair,lawful and just.We must put and keep ourselves on aplatform so fair, so high, so reasonable,that we will attract the attention and inviteand secure the approval of all who knowwhat we are doing.We do not advocate combinations oragreements in restraint of trade, nor actionof any kind which is opposed to the lawsor to the public welfare.AdministrationUnited States Steel’s Compliance Officer, supported by the Ethics and ComplianceGroup in the Law Department, administers this Code of Ethical Business Conduct.The Code provides general principles to guide employees in making ethical decisionsand is not intended to address every possible situation. In addition, the discussionsof laws, regulations and U. S. Steel Canada policies are not intended to providea complete review of their requirements. Please direct any questions regardingthe Code or any company policy to the United States Steel Compliance Officer atcomplianceofficer@uss.com.DisclosureNothing in the Code prohibits or restricts U. S. Steel Canada from taking anydisciplinary action on any matter pertaining to employee conduct, whether or not it isexpressly discussed in the Code..We must never forget that our rights andinterests are and should be subservientto the public welfare, that the rights andinterests of the individual must alwaysgive way to those of the public.24 Code of Ethical Business Conduct

A Message from United States Steel’s Compliance OfficerNow that you’ve read the U. S. Steel Canada Code of Ethical Business Conduct, you can see that living our values must be an ongoingpart of our work routine. With so many people located in so many sites around the world, it’s important to have this set of standards toguide each of us in doing what’s right at all times.The responsibility for maintaining our ethical performance lies with each one of us – from the executive offices to the plant floor. We eachmust take ownership of the company’s principles for ethical business conduct, and demonstrate them daily. I encourage you to use theresources listed in this Code when you need guidance on an ethical question, including contacting me at complianceofficer@uss.com.I join John Surma in assuring you that you can raise a good faith concern about suspected illegal or unethical conduct without fear ofretaliation or other disadvantage in your career at U. S. Steel Canada.Thank you for taking the time to read the Code and for all your efforts to foster the ethical culture of our company. We want U. S. SteelCanada to be one of the most respected and ethically strong companies in the world. Let’s work together to make that happen.Gregory A. ZovkoVice President & Controller, United States SteelUnited States Steel Compliance OfficerDo What’s Right 25

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