Corporate Compliance

Whistleblowing Channel
The whistleblowing channel is a communication tool available to all employees and stakeholders to report behavior that breaches the Code of Conduct and Good Practices in force in our organization.
The whistleblowing channel guarantees:
- Confidentiality of the whistleblower’s data.
- The absence of reprisals against those who report suspected breaches in good faith.
- Respect for the rights of those allegedly involved in a possible breach.
- Comprehensive analysis of the information on the basis of which it promotes its performance.
- North American Stainless has established the following whistleblowing channels:
- A whistleblowing channel on its corporate website. Whistleblowing Channel & Communication
- A phone number (213-279-1015 Pin# 4591).
Data Protection Official of North American Stainless:
North American Stainless: Attention: Compliance Manager
6870 US Highway 42 East, Ghent, KY 47045
E-mail: Compliance Manager
Tel.: (502) 347-6232
Code of Conduct and Good Practices
North American Stainless has a Code of Conduct and Good Practices, approved by the Board of Directors on 25 October 2016, which contains standards and criteria for action in professional matters that are mandatory for all employees and managers of the Group and on all activities. The objective of the Code is:
- To regulate the permitted and prohibited conduct of the Acerinox Group.
- Establish the ethical principles and general rules that must guide the actions of the Group, the employees and the directors among themselves and in their relations with their stakeholders, with whom the Group, directly or indirectly, interacts.

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
Acerinox Group companies, including North American Stainless, are committed to fair employment practices and complying with employment law at all its operations including those prohibiting child or forced labor. Acerinox Group periodically evaluates the risk that its product supply chains may involve human trafficking and slave labor using internal resources rather than third parties. Acerinox Group does not at the present time believe that a substantial risk exists that its product supply chains involve human trafficking or slave labor. Accordingly, Acerinox Group does not currently (1) engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery; (2) conduct audits of suppliers to evaluate supplier compliance with standards for trafficking and slavery in supply chains; (3) require direct suppliers to certify that materials incorporated in to our products comply with the laws regarding slavery and human trafficking of the countries in which Acerinox Group does business; (4) maintain internal accountability standards and procedures for employees or contractors failing to meeting standards regarding slavery and human trafficking; or (5) provide training regarding human trafficking and slavery to employees and management having direct responsibility for supply chain management. This statement is made in compliance with the California Transparency in Supply Chains Act of 2010 and is not directed nor is it to be interpreted under any other law or regime.