Throughout our history, U. S. Steel has demonstrated an unwavering commitment to doing business ethically and in compliance with applicable laws and regulations

In the early 1900s, our co-founder and first chairperson, Judge Elbert Gary, developed what is widely considered to be the first-ever corporate code of ethics, known as the Gary Principles. Those nine simple statements emphasizing integrity, fairness and accountability underlie the S.T.E.E.L. Principles that reflect our core values today. In turn, our S.T.E.E.L. Principles integrate ethics and compliance in our daily business activities. As a reflection of our commitment, we were named one of the World’s Most Ethical Companies® by Ethisphere in 2024 for the third consecutive year. Once again, we are the only integrated steel producer among this year’s 136 honorees. We are proud of the recognition that our world-class ethics and compliance program has earned.

We reinforce our principles through a comprehensive ethics and compliance program with support from the Board of Directors and senior management. The General Counsel and Chief Ethics & Compliance Officer administers the program with oversight and guidance from the Audit Committee. Our ethics and compliance program is designed and implemented to focus on the particular risks we face. Through risk assessments, we continuously adapt and enhance our program to ensure that risk areas remain appropriately addressed as our footprint and operations change over time. We also recognize the importance of continuous improvement and regularly benchmark our program against leading compliance practices and conduct other assessments, such as employee surveys, to identify ways to further strengthen our culture and enhance our ethics and compliance program. To ensure the foundation of our corporate governance remains solid, we review and update our policies every three years and have done so in 2023. Our success in ethics and compliance, as in all we do, is tied to the passion, commitment and excellence of our people.

“World’s Most Ethical Companies” and “Ethisphere” names and marks are registered trademarks of Ethisphere LLC.

U. S. Steel was named one of the World’s Most Ethical Companies by Ethisphere
in 2024 for the third consecutive year, the only integrated steel
producer among this year’s 136 honorees.



Duane Holloway

Senior Vice President, General Counsel & Chief Ethics and Compliance Officer

In 2023, Duane Holloway, U.S. Steel’s Senior Vice President, General Counsel, and Chief Ethics & Compliance Officer, was honored as a “Legend in Law” by the Burton Awards and named General Counsel of the Year by the African American Managing Partners and General Counsel Network.