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. <strong>Steel</strong> <strong>Canada</strong>, our contacts with government <strong>of</strong>ficials andpersonnel, both in this country and abroad, must comply with all applicable laws andregulations to avoid even the appearance <strong>of</strong> impropriety or improper influence. Any support,assistance or entertainment that we provide when representing U. S. <strong>Steel</strong> <strong>Canada</strong> togovernment <strong>of</strong>ficials 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 <strong>of</strong>ficials 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. <strong>Steel</strong> 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 <strong>of</strong> the world, it isstandard practice to exchangebusiness courtesies. However, anyemployee <strong>of</strong> a state-owned companymay be considered to be a “foreign<strong>of</strong>ficial” under many anti-corruptionlaws. You should discuss thissituation with the Law Departmentbefore giving or receiving any giftsfrom a government <strong>of</strong>ficial.20 <strong>Code</strong> <strong>of</strong> <strong>Ethical</strong> <strong>Business</strong> <strong>Conduct</strong>Campaign and Election ActivitiesU. S. <strong>Steel</strong> <strong>Canada</strong>’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 <strong>of</strong> U. S. <strong>Steel</strong> <strong>Canada</strong>’s Director <strong>of</strong> Government and Public Affairs.Federal law prohibits company contributions, either directly or through employees, t<strong>of</strong>ederal 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 <strong>of</strong>or are sponsored by U. S. <strong>Steel</strong> <strong>Canada</strong>. If we participate in personal political activities, wemust do so on our own time and at our own expense. U. S. <strong>Steel</strong> <strong>Canada</strong> will not reimbursepersonal contributions to political parties or candidates. For more information, consultU. S. <strong>Steel</strong> <strong>Canada</strong> 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 <strong>of</strong> United States <strong>Steel</strong>, U. S. <strong>Steel</strong> <strong>Canada</strong> 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 <strong>Canada</strong> 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. <strong>Steel</strong> <strong>Canada</strong> 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. <strong>Steel</strong> <strong>Canada</strong> does not engage in or support child labor, human trafficking or slavery, orknowingly support companies that utilize any form <strong>of</strong> child labor, slavery or human traffickingand we expect the same <strong>of</strong> 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. <strong>Steel</strong> intranet.
Import ComplianceU. S. <strong>Steel</strong> <strong>Canada</strong> must fully comply with the laws and regulations governing theimportation <strong>of</strong> goods into <strong>Canada</strong>. This includes all facets <strong>of</strong> the importation processfrom sourcing merchandise through final payment. Compliance safeguards theability <strong>of</strong> U. S. <strong>Steel</strong> <strong>Canada</strong> to compete effectively in the domestic and internationalmarketplace. Laws and regulations governing the importation <strong>of</strong> goods are enforcedby, among others the <strong>Canada</strong> Border Services Agency and the Canadian InternationalTrade Tribunal. All U. S. <strong>Steel</strong> <strong>Canada</strong> 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
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