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

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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
Page 2 and 3: ApplicationThe U. S. Steel Canada I
Page 6: Know the Right Thing to DoThe Code
Page 9 and 10: How to Report a Safety Incident:If
Page 11 and 12: Assess the Situation:One of my co-w
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Page 17 and 18: Confidential InformationWe must saf
Page 19 and 20: with job performance. We are prohib
Page 21 and 22: Assess the SituationWhen I attended
Page 23 and 24: Import ComplianceU. S. Steel Canada
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