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

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7CONDUCT BUSINESS FAIRLYAND LAWFULLY.PrincipleAssess the SituationMy supervisor has encouragedme to attend a $1,000 per personcampaign fundraiser for a Canadianfederal politician who has been verysupportive on issues important toU. S. Steel Canada. Is it all right toattend and put this on my businessexpense report?No. Canadian federal lawprohibits corporate contributions,directly or indirectly, to federalpolitical candidates or parties. Yourattendance is voluntary and yourpersonal choice. If you decide toattend, the cost of the event is atyour own expense and you may notask U. S. Steel Canada to reimburseyou. Consult U. S. Steel CanadaPolicy 0004-C – Public Affairs andPolitical Action for more guidance onthis subject.Each of us has a duty to conduct businessfairly and lawfully within U. S. SteelCanada and with our customers, suppliersand competitors. We must never takeadvantage of or provide special advantageto anyone – or even appear to do so –through manipulation, concealment, abuseof privileged information, misrepresentationof material facts, or any other unfairpractices. Fraud, theft, embezzlement,false or inflated billings, falsified expensereports, and payment of kickbacks forobtaining business are all examples ofillegal and unacceptable behavior. For moreinformation, consult U. S. Steel CanadaPolicy 0002-C – Business Conduct.Our duty also extends to complying with all applicable laws and regulations. Violations,even unintended ones, expose our company to serious criminal and civil penaltiesand fines, as well as penalties, fines, and even imprisonment for individuals. The legaldefense of claims, even when successful, squanders resources and compromises thereputation of U. S. Steel Canada. We should not engage in personal political activities oncompany time and we must observe gift rules associated with government officials.Antitrust and Competition LawU. S. Steel Canada must not engage in any understandings or agreements withcompetitors to restrain trade and we must avoid even the appearance of such conduct.We must compete independently in the marketplace in compliance with domestic andinternational laws. Examples of competition and antitrust violations are: price fixing;bid rigging; allocation of markets or customers; agreements to manipulate productionvolumes and group boycotts. If you have sales or marketing responsibilities orcommercial contacts, or if you attend trade association or industry meetings, you mustbe particularly aware of these prohibitions. If you have questions about the applicationof the antitrust laws, consult the appropriate contact in the Law Department beforetaking any action. Contact information is available on the Ethics and Compliance homepage on the U. S. Steel intranet.18 Code of Ethical Business Conduct
Assess the SituationWhen I attended a recent industryassociation dinner, I was seated witha competitor’s employees, one ofwhom began to talk about industrypressures and the possible effectsthey may have on her company’sprices. Could I have discussedU. S. Steel Canada’s concerns aboutthe same industry pressures?No. Even though you are membersof the same trade association, shestill represents a competitor andcompetition and antitrust lawsapply. Be aware that anticompetitiveactivity can occur even in casualsettings like the one you describe. Ifa conversation with an employee ofa competitor drifts into a potentiallyunlawful topic, you should removeyourself from the conversation andnotify the Law Department.Anti-Bribery and Anti-CorruptionEmployees and other representatives of U. S. Steel Canada may not directly orindirectly bribe or improperly influence any government official in Canada, the UnitedStates or in any other country or give the appearance of such conduct. Likewise, wemust not bribe or otherwise attempt to improperly influence private individuals orrepresentatives of other companies. We must also take appropriate measures to ensurethat agents, representatives and others working on the behalf of U. S. Steel Canada orits affiliates comply with all anti-corruption laws. Bribery or improper influence includesdirectly or indirectly giving, or promising to give, anything of value to any governmentemployee, official or representative, or political party employee, official, candidate orrepresentative for the purpose of obtaining a business advantage. Lavish entertainmentor travel might also be considered bribery.Anti-corruption and anti-bribery laws are often difficult to understand and apply.Employees who conduct business outside Canada should carefully review U. S. SteelCanada Policy 2015-C – Dealing with Foreign Governments and Agents and consult theLaw Department for further guidance. You can find contact information on the Ethicsand Compliance home page on the U. S. Steel intranet.■ ■ ■At the same event, an employee of acompetitor said that our respectivebusinesses would do better if wereduced production for one of theproduct lines we have in common.We weren’t discussing prices, so isthat an appropriate conversation?No. U. S. Steel Canada mustmake unilateral decisions aboutits business operations, includingproduction levels, and anycoordination with a competitor onthat topic would be unlawful. Donot engage in this discussion andcontact the Law Department.Do What’s Right 19
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Page 9 and 10: How to Report a Safety Incident:If
Page 11 and 12: Assess the Situation:One of my co-w
Page 13 and 14: Assess the SituationA 220-litre dru
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Page 27 and 28: A Message from United States Steel

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