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

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