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

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