U. S. Steel Serbia Code of Ethical Business Conduct

• I. Statement of Purpose
• II. Standards of Conduct


• A. Safety and Health
• B. Discriminatory Harassment
• C. Sexual Harassment
• D. Environmental
• E. Antitrust
• F. Fraudulent or Deceptive Practices
• G. Political Campaign Matters
• H. Governmental Contacts
• I. Foreign Governmental Contacts
• J. Misuse of Confidential Information
• K. Software Copyrights
• L. Maintenance of Accurate and Complete Records
• M. Conflicts of Interest




• 1. Financial Interests
• 2. Outside Activities
• 3. Gifts and Entertainment
• 4. Transactions Involving U. S. Steel Serbia
• 5. Misappropriation of Corporate Opportunities and Intellectual Property


• III. Employees Covered
• IV. Guidance Available
• V. Administration and Reporting

I. Statement of Purpose

This Code reaffirms the commitment of U. S. Steel Serbia to conduct its business in accordance with all applicable laws and the highest standards of business ethics and to ensure that all employees are aware of such standards, both legal and ethical. This Code shall apply to all employees of U. S. Steel Serbia and all employees of its affiliated companies in Serbia (which for convenience, throuhout this Code shall collectively be referred to as "U. S. Steel Serbia, d.o.o.". ).

II. Standards of Conduct

U. S. Steel Serbia requires each employee to discharge all responsibilities in accordance with the highest standards of business ethics and all applicable legal requirements. In order to meet this requirement, all employees must be aware of, and comply with, certain standards of conduct applicable to the workplace. In order to help understand these standards, brief summaries of some of the more significant requirements applicable to employee conduct follow. If at any time an employee is uncertain regarding any such requirement or the application of a law or regulation, he or she should seek guidance as described under Part IV "Guidance Available".

A. Safety and Health

The safety and health of all employees is of paramount importance to U. S. Steel Serbia . Company policies, along with the laws of Serbia, have been enacted to protect employees' safety and health. U. S. Steel Serbia will undertake to ensure that employees are aware of applicable regulations and that employees receive appropriate training concerning safety and health requirements. It is the employee's responsibility, for the employee's own benefit and for the benefit of all other employees, to be aware of and comply with all applicable safety and health requirements. Dangerous or unsafe conditions should be immediately reported to the appropriate management personnel. Further, Employees shall not come to work in an impaired or intoxicated state or abuse drugs or alcohol on company premises.

B. Discriminatory Harassment

Employees in the workplace are prohibited from engaging in certain types of discriminatory harassment. An employee must not engage in any threatening, intimidating or hostile activity , or use epithets or slurs that relate to race, color, religion, sex, national origin, age, veteran status, disability or political opinion. Likewise, an employee may not send to any co-employee or display or circulate in the workplace any written or graphic material that indicates or shows hostility toward an individual or group because of that individual's or group's race, color, religion, sex, national origin, age, veteran status, disability or political opinion or take any action adverse to any other employee, vendor, supplier, contractor or customer on that basis. A complaint procedure has been established and any complaint should be directed to the appropriate member of management, the U. S. Steel Serbia Law Department, or the Ethics Confidental Line telephone numbers.

C. Sexual Harassment

Sexual harassment in the workplace is expressly prohibited by U. S. Steel Serbia. It will not be tolerated. Sexual harassment is defined as an unwelcome sexual advance, any request for sexual favors, or any other unwelcome verbal or physical conduct of a sexual nature in the workplace as well as any similar conduct that creates a hostile work environment. U. S. Steel Serbia does not condone sexual harassment whether committed by U. S. Steel Serbia employees or by employees of vendors, suppliers, contractors and/or customers; such persons will be subject to appropriate corrective action for violations. A complaint procedure has been established and any complaint should be directed to the appropriate member of management, the U. S. Steel Law Department, or the Ethics Confidental Line telephone numbers.

D. Environmental

U. S. Steel Serbia requires its employees to comply with all environmental laws and regulations applicable to their activities in the workplace. Environmental compliance is everyone's responsibility. An employee is responsible for understanding the environmental consequences of his or her job and performing it in an environmentally safe manner. Questions, concerns or suggestions about environmental programs should be directed to supervisors. If an employee becomes aware of any actual or potential adverse environmental impacts caused by our operations, he or she should promptly advise an appropriate individual in Plant Management or Environmental Affairs, so that any necessary corrective action can be taken.

E. Antitrust

Antitrust laws are intended to preserve independent competition among competitors and prohibit activities that are unreasonable restraints of trade. Certain types of restraints are always considered to be unreasonable while others depend on injury to businesses or commerce. Some clear examples of antitrust violations are: price fixing, bid rigging, market or customer allocation, production allocation and group boycotts such as joint refusals to deal. If an employee violates the antitrust laws, U. S. Steel Serbia may be exposed to liability. The defense of an antitrust claim, even when successful, can be time consuming, burdensome and extremely expensive for U. S. Steel Serbia. Accordingly, an employee should not engage in any such activity and should strive to avoid even the appearance of a possible violation. Employees with sales or marketing responsibilities, commercial contacts or those who attend trade association or industrial group meetings, should be particularly aware of these obligations under the antitrust laws.

F. Fraudulent or Deceptive Practices

Employees must not participate in any fraudulent or deceptive activities involving U. S. Steel Serbia, its customers, suppliers, contractors, co-workers, or anyone else with whom U. S. Steel Serbia associates or does business. Some examples of fraudulent or deceptive activities include:
1. Theft, fraud or embezzlement;
2. False or inflated billings;
3. Improper or unauthorized offering or receipt directly or indirectly of money, goods or services; and
4. Submission of expense accounts for amounts other than the amount actually spent on U. S. Steel Serbia business.

G. Political Campaign Matters

Involving the reputation, interests or property of U. S. Steel Serbia in the support of any particular political party or political movement is not acceptable. Nor is it permitted to engage in political activity in the work place. At the same time, U. S. Steel Serbia expects that political sympathy or membership of an employee in any political party or political movement shall not have any negative impact whatsoever on the proper and honest course of the employee’s work for U. S. Steel Serbia.

H. Governmental Contacts

Contacts of U. S. Steel Serbia with government officials and personnel, both in this country and elsewhere, must be conducted in compliance with all applicable laws and regulations and in such a way as to avoid even the appearance of impropriety. U. S. Steel Serbia seeks to develop and maintain good relationships and effective communication with officials at all levels of government.

However, contacts and relationships with government personnel must never be illegally fostered, suggest improper influence upon such persons, or compromise the integrity of U. S. Steel Serbia. Assistance or support by U. S. Steel Serbia to government officials or personnel must be made in a manner consistent with applicable law and ethical business practices. This requirement also applies to direct or indirect contributions or expenditures made by employees, agents or other representatives. Likewise, any entertainment of government officials should be conducted within the bounds of all applicable laws, sound business discretion, and the highest ethical standards.

I. Foreign Governmental Contacts

U. S. Steel Serbia has strict rules regarding any and all contacts by U. S. Steel Serbia with officials of foreign states, or officials of companies owned in whole or in part by foreign governments. It is prohibited to provide any payments of, promises to pay, or authorizations to pay, money, gifts or anything of value to officials of foreign governments, to foreign political candidates or to officials of companies owned in whole or in part by foreign governments, in order to "obtain or retain" business. Payments or gifts to a third party, such as an agent or sales representative, while knowing (or having reason to know) that all or part of the money or gift will be offered or given to such an official, are also prohibited. If employees violate this provision, the violation may create criminal and civil liability for themselves and civil liability for U. S. Steel Serbia. As a result, caution is required when doing business through foreign consultants, commercial representatives or agents, or with businesses that are owned, in whole or in part, by foreign governments or that have personal or family ties to government officials. In such instances, the U. S. Steel Serbia Law Department should be consulted for specific advice.

J. Misuse of Confidential Information

It is the policy of U. S. Steel Serbia to maintain the confidential treatment of its financial, operating and other corporate information, and to prohibit the misuse of any such information obtained during employment. It is a violation of the law for any employee to trade in shares of any class of U. S. Steel stock or securities, or the stock or securities of other companies, on the basis of non-public material information, including unannounced earnings or operating results, merger discussions, and possible acquisitions or divestitures. If an employee has knowledge of confidential or non-public material information, they may not use such information (or pass on such information to any other persons) for personal gain, directly or indirectly, through the purchase or sale of securities, before such information is disclosed to the public. Engaging in insider trading will subject an employee to both civil and criminal penalties and may also create civil liability for U. S. Steel Serbia. In addition, upon leaving employment (for any reason) each employee must return all company documents, books, records, files and identifications.

K. Software Copyrights

Employees should not reproduce or copy software that is protected by copyright, unless appropriate authorization has been obtained. International law provides protection to owners of copyrights to prevent unauthorized copying of their works in any material form including computer software, unless the owners agree otherwise. Unauthorized copying of computer software can create significant liability for U. S. Steel Serbia, as well as personal criminal liability for an employee in the case of willful infringement. The absence of a copyright notice does not necessarily mean that the owner does not claim a copyright in the software, so an employee should make sure that all software utilized is either owned by U. S. Steel Serbia or covered by a written license agreement with U. S. Steel Serbia.

L. Maintenance of Accurate and Complete Records

Accurate and reliable corporate records must be maintained at all times and any falsification of corporate records is a serious offense. All payments of money, transfers of property, furnishing of services and other transactions must be reflected in appropriate detail in the accounting and other business records of U. S. Steel Serbia and must be approved in accordance with U. S. Steel Serbia policy. All employees are required to make full disclosure of all relevant information and must cooperate with internal and external auditors, corporate security and legal counsel in the course of audits or investigations. Employees should use U. S. Steel Serbia property and equipment, including computers or any other electronic or mechanical messaging equipment, only for business purposes.

M. Conflicts of Interest

Employees must not engage in activity that creates a conflict of interest, or the appearance of a conflict of interest. Employees should conduct themselves in an ethical manner, without conflict of interest, and must not seek or accept improper personal gain. A conflict exists whenever personal interests or activities improperly influence or interfere with the performance of one's duties for U. S. Steel Serbia. U. S. Steel Serbia has the right to investigate relationships of, and conduct by, its employees, which create the appearance of impropriety.

It is impossible to list all situations or relationships that might create, or appear to create, a conflict of interest. Since each situation must be evaluated on its own facts, prompt disclosure should be made of any circumstances that might constitute a conflict of interest. Employees are expected to determine if a conflict exists or appears to exist and, if so, how it should be resolved. Employees are encouraged to obtain assistance, guidance, and any necessary approval from the U. S. Steel Serbia Law Department in such situations. Failure to disclose circumstances that could constitute a conflict of interest will, in and of itself, constitute improper conduct. In order to assist employees in determining when conflicts may exist, some guidelines follow:

1. Financial Interests

A conflict may exist when an employee, or a member of the employee's family (spouse, parents, brothers, sisters or children of employee or spouse) directly or indirectly:
(a) owns or engages in the same or similar kind of business in which U. S. Steel Serbia engages, or
(b) owns a significant beneficial interest in a competitor or concern which does or seeks to do business with U. S. Steel Serbia.

2. Outside Activities

A conflict may exist when an employee or a member of the employee's family serves as a director, officer, employee, or agent of an organization which is a competitor or which has a current or prospective business relationship with U. S. Steel Serbia. A conflict may also exist if an employee engages in a personal business venture or any other activity that prevents devotion of the time and effort expected by U. S. Steel Serbia. A conflict may exist if an employee participates in a charitable or civic organization or serves in public office, if the activities of the organization or public body involve the business interests of U. S. Steel Serbia.

3. Gifts and Entertainment

United States Steel Corporation Policy limits the acceptance by employees of gifts and/or entertainment from anyone having or seeking a business relationship with the Company. Policy guidelines will be developed which identify the type and establish the value of gifts and/or entertainment that may be accepted by an employee without supervisor approval. Gifts in the form of cash, gift certificates or other cash equivalents, stocks, bonds, commissions or similar types of negotiable items are not permitted under any circumstances. As a general rule, a supervisor should not authorize the acceptance by an employee of entertainment offered by the same host more than once during any month irrespective of the cost to the host.

4. Transactions Involving U. S. Steel Serbia

A conflict may exist if an employee or a member of the employee's family:
(a) engages in the sale, rental, or purchase of any type of property or services to or from U. S. Steel Serbia other than a routine sale of products through normal sales outlets, or through normal surplus property procedures, or
(b) benefits personally from any such sale, rental or purchase or derives personal gain from any transaction to which U. S. Steel Serbia is a party.

5. Misappropriation of Corporate Opportunities and Intellectual Property

An employee is required to disclose to U. S. Steel Serbia all business opportunities that come to an employee's attention during the course of the employee’s work for U. S. Steel Serbia. An employee should not personally, or on behalf of any other person or organization, receive any personal benefit from any such business opportunity. The trademarks, trade names and trade secrets of United States Steel Corporation, including U. S. Steel Serbia are valuable property that must be protected from any improper use or misappropriation.

III. Employees Covered

This Code applies to all full-time and part-time employees of U. S. Steel Serbia and those of its affiliated companies. In addition to this Code, employees are subject to the provisions of applicable policies, procedures and work rules and regulations. Employees who engage in prohibited conduct are subject to appropriate disciplinary action, including discharge. Appropriate cases may also be called to the attention of governmental enforcement agencies.

IV. Guidance Available

This Code does not reference all laws, policies, rules or regulations or standards applicable to conduct by U. S. Steel Serbia employees. Requirements not referenced in this Code may apply to specific work activity. Many laws to which U. S. Steel Serbia is subject, including those referenced in this Code, are complex and their application to U. S. Steel Serbia business practices or activities can at times be unclear. Appropriate guidance should be sought regarding any proposed action that raises questions or creates uncertainty with respect to compliance with laws or regulations. Employees should seek the advice and guidance of the U. S. Steel Serbia Law Department with regard to any and all transactions that may have legal implications. Periodic legal and ethical compliance presentations will be made throughout the year. Employees are expected to attend as requested and to follow the advice given at these presentations.

V. Administration and Reporting

Administration of this Code is under the direction of the General Director of U. S. Steel Serbia. An employee is encouraged to report any suspected illegal or unethical conduct connected with or affecting the business of U. S. Steel Serbia or its affiliated companies. Such a good faith report should be made to the U. S. Steel Serbia Law Department or to the Ethics Hotline telephone number. U. S. Steel Serbia, to the extent possible, will keep confidential the identity of anyone making such a report. Further, due to the importance of this reporting procedure, any willfully false report shall be, in and of itself, considered a violation of this Code and will not be tolerated. Employees who make a willfully false report will be subject to disciplinary action, including discharge.