U. S. Steel Canada Code of Ethical Business Conduct - EthicsPoint
U. S. Steel Canada Code of Ethical Business Conduct - EthicsPoint
U. S. Steel Canada Code of Ethical Business Conduct - EthicsPoint
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Assess the SituationWhen I attended a recent industryassociation dinner, I was seated witha competitor’s employees, one <strong>of</strong>whom began to talk about industrypressures and the possible effectsthey may have on her company’sprices. Could I have discussedU. S. <strong>Steel</strong> <strong>Canada</strong>’s concerns aboutthe same industry pressures?No. Even though you are members<strong>of</strong> 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 <strong>of</strong>a competitor drifts into a potentiallyunlawful topic, you should removeyourself from the conversation andnotify the Law Department.Anti-Bribery and Anti-CorruptionEmployees and other representatives <strong>of</strong> U. S. <strong>Steel</strong> <strong>Canada</strong> may not directly orindirectly bribe or improperly influence any government <strong>of</strong>ficial in <strong>Canada</strong>, the UnitedStates or in any other country or give the appearance <strong>of</strong> such conduct. Likewise, wemust not bribe or otherwise attempt to improperly influence private individuals orrepresentatives <strong>of</strong> other companies. We must also take appropriate measures to ensurethat agents, representatives and others working on the behalf <strong>of</strong> U. S. <strong>Steel</strong> <strong>Canada</strong> orits affiliates comply with all anti-corruption laws. Bribery or improper influence includesdirectly or indirectly giving, or promising to give, anything <strong>of</strong> value to any governmentemployee, <strong>of</strong>ficial or representative, or political party employee, <strong>of</strong>ficial, candidate orrepresentative for the purpose <strong>of</strong> obtaining a business advantage. Lavish entertainmentor travel might also be considered bribery.Anti-corruption and anti-bribery laws are <strong>of</strong>ten difficult to understand and apply.Employees who conduct business outside <strong>Canada</strong> should carefully review U. S. <strong>Steel</strong><strong>Canada</strong> 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. <strong>Steel</strong> intranet.■ ■ ■At the same event, an employee <strong>of</strong> acompetitor said that our respectivebusinesses would do better if wereduced production for one <strong>of</strong> theproduct lines we have in common.We weren’t discussing prices, so isthat an appropriate conversation?No. U. S. <strong>Steel</strong> <strong>Canada</strong> 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