Assess the SituationMay I accept a trade association’sinvitation to give a presentationabout U. S. <strong>Steel</strong> <strong>Canada</strong> at anupcoming meeting?You should discuss this invitationwith your supervisor and get theappropriate approvals including fromPublic Affairs before agreeing tospeak at the meeting.■ ■ ■Can I e-mail financial information toan external business partner?Yes. But only if approved. Youmust use the ‘Secure Mail’ functionavailable in Lotus Notes and youmust ensure that you send onlyfinancial information necessaryto the business relationship. Filesincluded as attachments to theemails should be password protectedwith the password provided to therecipient in a separate e-mail. If youare unsure whether the informationis confidential, please consult yoursupervisor, the Law Department, orU. S. <strong>Steel</strong>’s Compliance Officerfor guidance.5ASSURE FINANCIAL REPORTS AREACCURATE AND SAFEGUARD CONFIDENTIALINFORMATION.PrincipleUnited States <strong>Steel</strong> was the first company in the United States to hold an annualmeeting <strong>of</strong> shareholders and to publish an annual report. <strong>Business</strong> has grown morecomplex since the beginnings <strong>of</strong> our company, but the principles by which we dobusiness have never changed.Financial Reporting and Internal ControlsUnited States <strong>Steel</strong> is required by law to disclose accurate and complete informationregarding its financial condition and results <strong>of</strong> operations. We are also requiredto maintain an adequate structure <strong>of</strong> processes and procedures controlling theeffectiveness <strong>of</strong> accounting and financial reporting activities. We must maintain accuratebooks and records reflecting our business transactions and activities <strong>of</strong> the company,and perform our responsibilities in compliance with the company’s internal controls.Inaccurate, incomplete or untimely record keeping and reporting may violate the law andresult in liability to the company and individual employees. Employees, especially thoseinvolved in accounting or financial reporting activities in the investment community, mustunderstand and comply with all applicable accounting standards, laws and regulations,including but not limited to U.S. Generally Accepted Accounting Principles, U.S. securitieslaws and regulations, and the Sarbanes-Oxley Act <strong>of</strong> 2002. If you are aware <strong>of</strong> or suspectany situation involving the disclosure or recording <strong>of</strong> false, misleading, or confidentialinformation, you should report it to the U. S. <strong>Steel</strong> Ethics Line. For more information,consult U. S. <strong>Steel</strong> <strong>Canada</strong> Policy 6007-C – Receipt, Retention & Treatment <strong>of</strong> ComplaintsRegarding Accounting, Internal Control & Auditing Matters.14 <strong>Code</strong> <strong>of</strong> <strong>Ethical</strong> <strong>Business</strong> <strong>Conduct</strong>
Confidential InformationWe must safeguard and protect all confidential information in our possession or to whichwe have access, such as financial, operating, personnel, medical, legal, technical, orcommercial information, as well as information provided in confidence to U. S. <strong>Steel</strong><strong>Canada</strong> by others. We must not:• Use confidential information outside our job responsibilities or for personal benefit.• Discuss confidential information with anyone outside <strong>of</strong> the company, includingfamily members, nor with other employees except on an as-needed basis.• Provide confidential information about the company to any third party unlessspecifically authorized.• Have access to, or use the confidential information <strong>of</strong> others, including formeremployers, unless U. S. <strong>Steel</strong> <strong>Canada</strong> has entered into a written agreement withrespect to such information and, only then, for agreed-upon business purposes.Correct safeguarding includes identifying information as “confidential,” securing itwhen not in use, refraining from discussing it in public areas, and taking precautionswhen transmitting it. In addition, we must protect the privacy and confidentiality <strong>of</strong>certain personal information, including employee records, protected health information,Social Insurance numbers, and other personal identifiers in the manner described inthe company’s policies and procedures. If you are uncertain as to a particular piece <strong>of</strong>information, presume it is confidential and safeguard it appropriately.Our obligation to protect confidential information continues throughout our employmentand even after it ends. For more information, consult U. S. <strong>Steel</strong> <strong>Canada</strong> Policy 2005-C –Confidential Treatment and External Communication <strong>of</strong> Corporate Information;U. S. <strong>Steel</strong> <strong>Canada</strong> Policy 2009-C – Protection <strong>of</strong> Confidential and Trade SecretInformation; U. S. <strong>Steel</strong> <strong>Canada</strong> Policy 5107-C – Personal and Employment InformationPractices; U. S. <strong>Steel</strong> <strong>Canada</strong> Policy 5108-C – Protected Health Information; andU. S. <strong>Steel</strong> <strong>Canada</strong> Policy 5109-C – Privacy <strong>of</strong> Social Insurance Numbers.Assess the SituationA vendor has asked me to providenon-public financial data related tooperational costs, including coststo produce finished materials, tohelp that company obtain contractsunrelated to U. S. <strong>Steel</strong> <strong>Canada</strong>. Can Iprovide this information?No. Non-public financial datais confidential and may not beprovided to vendors for purposesunrelated to their relationship withU. S. <strong>Steel</strong> <strong>Canada</strong>.■ ■ ■It is month end, and I have alreadyspent or accrued up to my budgetedamounts. Can I hold a vendor invoiceor otherwise not account for knownliabilities until the following month?No. Excluding known liabilitiesduring a month results in thecompany’s liabilities beingunderstated. This could cause thecompany to restate its financialstatements. If you have anyquestions about how to account fortransactions, please contact yourlocal accounting representative.Disclosures <strong>of</strong> Information Outside <strong>of</strong> United States <strong>Steel</strong>Only certain <strong>of</strong>ficers <strong>of</strong> United States <strong>Steel</strong>, its manager <strong>of</strong> Investor Relations and PublicAffairs and Governmental Affairs personnel, including U. S. <strong>Steel</strong> <strong>Canada</strong>’s Director <strong>of</strong>Government and Public Affairs, are authorized to communicate with investment analysts,investors, the news media, government agencies, trade associations or other thirdparties. If you receive a request for financial, operating or other confidential information,you should not respond but should refer the request to Investor Relations, Public Affairs,or the Law Department. Any presentation proposed for non-U. S. <strong>Steel</strong> audiences mustbe provided to Public Affairs with adequate time for review and approval. The disclosure<strong>of</strong> confidential information through any form <strong>of</strong> social media such as blogs, networkingsites, or comment threads is prohibited. For more information, consult U. S. <strong>Steel</strong> <strong>Canada</strong>Policy 1804-C – Compliance with SEC Regulation FD; and U. S. <strong>Steel</strong> <strong>Canada</strong> Policy2005-C – Confidential Treatment and External Communication <strong>of</strong> Corporate Information.Do What’s Right 15