Supplier Requirements Manual - AK Steel

18Chapter 18: AK Steel Corporate Policy 3.15 Entertainment & GiftsOrigination Date: 09/30/2004 Version: 4 Revision Date: 08/27/2012PURPOSE1. To establish the policy to be followed throughout AK Steel Corporation for offering andaccepting gifts and entertainment.DEFINITIONS2. For purposes of this Corporate Policy, the term “AK Steel” and, when capitalized, the term“Company” shall include AK Steel Holding Corporation and AK Steel Corporation, as well astheir subsidiaries. The terms “Representative” and “You,” when capitalized, shall refer to allemployees of the Company (salaried, whether exempt or nonexempt, and hourly), as well asits agents, legal representatives and consultants. The term “Nominal Value,” whencapitalized, means a fair market value of $75.00 or less.POLICY3. AK Steel’s policy is to follow ethical standards of behavior in all of its business dealings. Thisrequires, among other things, that AK Steel employees act in a fair and impartial mannerwhen dealing with its suppliers, service providers and customers.4. AK Steel Corporation values its relationship with its suppliers, service providers andcustomers and encourages appropriate social interaction to help build those relationships.Gifts and Entertainment may be used occasionally in recognition of the value of such abusiness relationship. They may not be used to curry favor or to influence decisions. No giftor entertainment should be offered or accepted where any obligation might be incurred orimplied or to induce improper action by the recipient.5. Gifts of Nominal Value or less, and routine business entertainment, thus are permissiblewhen freely offered by or to a supplier, service provider or customer and in accordance withnormally accepted business practices and legal and ethical standards. Gifts in excess ofNominal Value may be permissible under appropriate circumstances, but must be promptlydisclosed on an Entertainment and Gifts Reporting Form.6. Certain gifts and entertainment are strictly prohibited. This includes any gift of cash, gifts orentertainment that violate the recipient’s policy and gifts and entertainment from the samesupplier, service provider or customer that in any one calendar year, individually orcollectively, have a value in excess of $500.7. Specific laws apply to business interactions with both domestic and foreign governmentofficials, agents and employees. You must consult with General Counsel before offering anygift or entertainment to any government official, employee or agent.AK Steel Supplier Requirements Page 53 of 55Revised 01/13