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bold spirit - ArcelorMittal South Africa

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86<br />

<strong>ArcelorMittal</strong> <strong>South</strong> <strong>Africa</strong><br />

Annual Report 2010<br />

Business ethics<br />

There were no reported instances of contravention of ethical<br />

or anti-corruption guidelines during the year.<br />

Our approach to managing business<br />

ethics and corruption is guided by<br />

the <strong>ArcelorMittal</strong> Group Code of<br />

Business Conduct (see page IV of the<br />

annual report) and Anti-corruption<br />

Guidelines. Both policies form part of<br />

our compliance programme.<br />

The Group anti-corruption guidelines<br />

establish procedures for handling<br />

concerns around possible corrupt<br />

practices and provide guidelines on<br />

how to fight and prevent corruption.<br />

All senior executives as well as staff<br />

in relevant sections of the business<br />

are required to be trained in the<br />

application of these guidelines. To<br />

date 686 employees out of a total<br />

of 983 requiring anti-corruption<br />

training have been trained in our anticorruption<br />

policies and procedures.<br />

Fraud risks relating to corruption are<br />

included in the annual internal audit<br />

plan to be covered during a year as<br />

part on the internal audit work.<br />

<strong>ArcelorMittal</strong>’s anti-corruption<br />

policy provides guidelines with<br />

regard to payment to political parties<br />

or government officials. Political<br />

contributions may be made only in<br />

accordance with applicable laws and<br />

are subject to prior written approval<br />

of the local legal department. No<br />

gifts and gratuities may be offered<br />

to government officials except for<br />

promotional items of little value and<br />

provided they are not offered with a<br />

corrupt intent.<br />

There were no reported instances<br />

of contravention of ethical or anticorruption<br />

guidelines during the year.<br />

There were also no significant cases<br />

of fraud or other misdemeanours<br />

reported.<br />

Anti-competitive behaviour<br />

Anti-competitive behaviour<br />

is monitored according to the<br />

<strong>ArcelorMittal</strong> Group Anti-trust<br />

Guidelines which we have an obligation<br />

to observe. The anti-trust guidelines<br />

explain the basic principles of anti-trust<br />

and competition law. The guidelines<br />

require absolute avoidance of any<br />

conduct which violates underlying<br />

principles of competition laws. All senior<br />

executives as well as staff in relevant<br />

sections of the business are trained in<br />

the application of these guidelines.<br />

Competition Authority<br />

investigations<br />

The group is currently the subject<br />

of a number of investigations by the<br />

Competition Authority expanded on in<br />

the ‘Finance report’ on page 23.

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