ATI expects all of our suppliers to conduct their business ethically and with integrity and to comply with the basic principles set forth in
ATI’s Corporate Guidelines for Business Conduct and Ethics. This includes compliance with all applicable local, national, and international laws and regulations.
If you have a concern related to any ATI business activity, including suspected violations of the law, suspected violations of
ATI’s Corporate Guidelines for Business Conduct and Ethics, or suspected violations of any ATI Policy, you can report your concern to ATI’s Chief Compliance Officer via email at
ChiefComplianceOfficer@ATImaterials.com. You may also report your concern through ATI’s Ethics HelpLine. ATI’s Ethics HelpLine is available 24 hours a day 7 days week and reports can be made by phone toll-free in the U.S. at
1-800-777-8767 or on-line at
www.ATIEthicsHelpLine.ethicspoint.com. International dial-in instructions are also available on-line at
www.ATIEthicsHelpLine.ethicspoint.com.
B. Safety, Health, & Environmental Compliance
At ATI, safety, health, and environmental compliance are the pre-requisites to all operations. We are committed to providing a safe workplace and our goal is to finish each day incident- and injury –free. We are also committed to maintaining and operating our businesses in full compliance with all applicable environmental laws, regulations and rules.
ATI expects its suppliers to commit to operating a safe workplace and to follow and proceed with using all applicable safety, health and environmental laws, regulations, and rules.
C. Anti-Corruption & Anti-Bribery Compliance
ATI is committed to doing business ethically and in compliance with all laws that apply to our businesses throughout the world. Consistent with our values, ATI has a no tolerance policy towards bribery and corruption in all aspects of our business and in all countries in which we operate. ATI will comply with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and the anti-corruption and anti-bribery laws of all countries in which we operate or do any business.
ATI expects its suppliers to comply in all respects with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and all other anti-corruption and anti-bribery laws and regulations applicable throughout the world.
D. Human Rights
ATI’s policy is to comply with all applicable employment and labor laws and to conduct its business activities in a manner that respects human rights and does not in any way contribute to or support human rights abuses. ATI is committed to compliance with all applicable laws, rules and regulations related to the protection of human rights and prevention of human rights abuses, including, but not limited to, U.S. Government Federal Acquisition Regulation clauses related to Combatting Trafficking in Persons, the California Transparency in Supply Chain Act, the U.K. Modern Slavery Act, the Dodd-Frank Act Conflict Minerals Rule, and all prohibitions against trafficking in persons, slave labor, child labor, or the support of illegal armed groups.
D.1. ATI’s Policy Regarding Combatting Trafficking in Persons
ATI’s policy reflects our commitment to protecting human rights and is designed to support compliance with applicable laws and regulations such as the United States Government’s Federal Acquisition Regulations clauses related to combating trafficking in persons and the UK Modern Slavery Act.
ATI Policy Regarding Combatting Trafficking in PersonsATI Statement Regarding the California Transparency in Supply Chains ActATI Statement Regarding the UK Modern Slavery Act
ATI expects all of its suppliers to conduct business in a manner that respects human rights and to comply with all local, national and international laws, regulations and standards related to employment and labor practices and the prohibition of human trafficking and slave labor. ATI also expects all of its suppliers to comply with the basic principles and standards of the ATI Policy Regarding Combatting Trafficking in Persons. ATI reserves the right to immediately suspend or discontinue engagement with suppliers and will take appropriate action if we suspect any supplier has violated any law or regulation related to prohibition of human trafficking and slave labor or has not met the standards of the ATI Policy Regarding Combatting Trafficking in Persons.
D.2. Conflict Minerals
Section 1502 of the Wall Street Reform and Consumer Protection Act, known as the Dodd-Frank Act, directs the Securities and Exchange Commission (SEC) to impose reporting requirements on publicly-traded companies whose products contain “conflict minerals” which are defined as tantalum, tin, tungsten and gold. Specifically, the Dodd- Frank Act requires publicly-traded companies to disclose their use of conflict minerals originating from the Democratic Republic of the Congo (DRC) and adjoining countries that are “necessary to the functionality or production” of a product. Mining and transportation of conflict minerals is a significant source of funding for armed groups that fuel conflict and commit human rights abuses in the DRC. Section 1502 was enacted to address these humanitarian concerns and reduce this source of funding for the armed groups in this region.
ATI is committed to full compliance with the Dodd-Frank Act. ATI’s policy is to only purchase materials from legitimate and reputable suppliers, and to maintain a sustainable and responsible supply chain that does not in any way contribute to human rights abuses, fuel conflict, or benefit illegal armed groups. In accordance with this policy, ATI has implemented internal risk-based due diligence procedures designed to provide transparency to the origin of conflict minerals in our supply chain in compliance with the Dodd-Frank Act. ATI will communicate as appropriate with its suppliers regarding these procedures.
ATI expects all of its suppliers to conduct business in a manner that respects human rights and not to support sources or parties that contribute to human rights abuses. ATI expects its suppliers to be aware of the requirements of the Dodd-Frank Act, and to fully support ATI’s Dodd-Frank Act compliance efforts by providing transparency into the supply chain from the original source to ATI. ATI will immediately suspend or discontinue engagement with any supplier where we have identified that such supplier is sourcing from, or linked to, any party that supports illegal armed groups, fuels conflict, contributes to human rights abuses, or is not in compliance with the rules promulgated under the Dodd-Frank Act.
