POLICIES, TRAINING AND COMMUNICATION

U. S. Steel has adopted a Code of Ethical Business Conduct and corporate policies and procedures to help ensure that the S.T.E.E.L. Principles and our overarching commitment to responsible business conduct are embedded throughout the company and our activities. Our key ethics and compliance policies and related resources can be found on our website. Through our annual policy certification process, employees certify their ongoing compliance with the Code, our Anti-Corruption and Antitrust Compliance policies and several other key compliance policies each year. U. S. Steel’s internal audit function periodically audits activities addressed in our Code and/or policies and reviews completion data for the annual policy certification process through which employees certify their ongoing compliance with our Code of Ethical Business Conduct and key compliance policies.

To help ensure our employees understand the company’s expectations and applicable rules, U. S. Steel provides them with ethics and compliance training applicable to their jobs each year. Among the topics covered in these courses are our Code of Ethical Business Conduct, prevention of discrimination and harassment, and processes for compliance with relevant laws and regulations. We also distribute a series of training videos, called “Rewind,” inspired by Ethics and Safety Line reports. The videos depict ethical dilemmas faced by our employees and discuss whether the actions they took were aligned with our S.T.E.E.L. Principles or what they should have done differently.