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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 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>

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