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

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. SteelCanada by others. We must not:• Use confidential information outside our job responsibilities or for personal benefit.• Discuss confidential information with anyone outside of 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 of others, including formeremployers, unless U. S. Steel Canada 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 ofcertain 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 ofinformation, 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. Steel Canada Policy 2005-C –Confidential Treatment and External Communication of Corporate Information;U. S. Steel Canada Policy 2009-C – Protection of Confidential and Trade SecretInformation; U. S. Steel Canada Policy 5107-C – Personal and Employment InformationPractices; U. S. Steel Canada Policy 5108-C – Protected Health Information; andU. S. Steel Canada Policy 5109-C – Privacy of 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. Steel Canada. Can Iprovide this information?No. Non-public financial datais confidential and may not beprovided to vendors for purposesunrelated to their relationship withU. S. Steel Canada.■ ■ ■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 of Information Outside of United States SteelOnly certain officers of United States Steel, its manager of Investor Relations and PublicAffairs and Governmental Affairs personnel, including U. S. Steel Canada’s Director ofGovernment 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. Steel audiences mustbe provided to Public Affairs with adequate time for review and approval. The disclosureof confidential information through any form of social media such as blogs, networkingsites, or comment threads is prohibited. For more information, consult U. S. Steel CanadaPolicy 1804-C – Compliance with SEC Regulation FD; and U. S. Steel Canada Policy2005-C – Confidential Treatment and External Communication of Corporate Information.Do What’s Right 15