Ethics and Compliance

Overview
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 cofounder 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 2025 for the fourth consecutive year. We were the only company in the metals, minerals and mining industry among the 136 honorees. We are proud of the recognition that our world-class ethics and compliance program has earned.

We reinforce our S.T.E.E.L. Principles through a comprehensive ethics and compliance program with support from the Board and senior management. Our General Counsel and Chief Ethics & Compliance Officer administers the program with oversight and guidance from the Audit Committee. We have designed and implemented our ethics and compliance program 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, regularly benchmarking our program against leading compliance practices and conducting 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 ethical culture remains solid, we review and update our Code of Ethical Business Conduct (Code) every three years, including most recently in 2024. The updated and modernized Code is more interactive and user-friendly, with links to policies, procedures and training to provide employees with guidance on demand. In addition, it places a renewed emphasis on the important role of managers in fostering our ethical culture.
Policies, Training and Communication
U. S. Steel’s Code and corporate policies and procedures help ensure that the S.T.E.E.L. Principles are embedded throughout the Company and our activities. 
 
Key ethics and compliance policies and related resources can be found on our website. 
 
To ensure that employees understand the Company’s expectations and all applicable rules, we provide annual ethics and compliance training to all employees and issue communications about various compliance topics, senior management messages underscoring the importance of doing business with integrity, and summaries of current events that demonstrate the need for lawful business practices. 
 
In addition, through our annual policy certification process, non-represented employees in the United States, U. S. Steel Košice (USSK) employees, and members of our Board certify their ongoing compliance with our Code. 
 
U. S. Steel’s internal audit function periodically audits activities addressed in our Code and policies and reviews completion data for our annual policy certification process. 

In 2024, 100% of U. S. Steel employees and members of our Board received Code of Ethical Business Conduct training. 

Human Rights

As set forth in our Human Rights and Indigenous Rights Policy, U. S. Steel is committed to respecting the human rights of all people, consistent with the principles of individual dignity and respect that underlie the Universal Declaration of Human Rights. Included in our commitment is respect for the rights of indigenous people, including women and children. We recognize that our continued success depends on fostering a workplace culture that is rooted in fairness and mutual respect. To that end, we strictly prohibit any form of discrimination or harassment. We also respect our employees’ right to freedom of association, including the right to choose whether to join a trade union. We honor the terms of collectively bargained agreements and comply with applicable laws regarding fair wages, hours of work and benefits.

Notably, we were the first North American steel producer to join ResponsibleSteel™, a global multistakeholder initiative that establishes and certifies members’ conformance with human rights, safety and environmental standards developed for the steel industry, including standards designed to help eliminate child labor and human trafficking. In April 2022, Big River Steel received site certification following an independent third-party audit that confirmed its compliance with the ResponsibleSteel™ standards.

The U. S. Steel Ethics and Safety Line
To further foster a strong ethical culture characterized by transparency and accountability, U. S. Steel encourages employees to seek guidance, raise concerns and report suspected wrongdoing without fear of retaliation. Employees may do so by contacting their manager, Human Resources, the Legal Department or any other appropriate company resource. Concerns can also be raised anonymously through the U. S. Steel Ethics and Safety Line, which is managed by an outside service provider and available 24 hours a day, seven days a week. Importantly, contact information for the Ethics and Safety Line is available on our website, so external stakeholders, including our business partners and members of the public, can use it to raise concerns related to our business. U. S. Steel strictly prohibits retaliation — including termination, demotion, discipline or harassment — against anyone who raises a concern in good faith and will take appropriate action against anyone found to have engaged in such retaliation. 
 
We take all Ethics and Safety Line reports seriously and have adopted investigation protocols to ensure that all reports alleging misconduct are reviewed, escalated as needed and investigated thoroughly. The protocols cover every step of the investigation process in detail, from receiving and assigning each report to conducting and documenting an appropriate investigation. Notably, a cross-functional committee reviews the results of investigations, including any remedial actions, before they are closed to ensure that each report is handled appropriately. 
 
To promote transparency and the efficacy of the Ethics and Safety Line, we regularly disclose to employees the number and types of reports received, the types of actions taken in response to substantiated allegations, and anonymized summaries of select cases. The Audit Committee receives additional data about the number of reports received, closed cases, and significant allegations and investigations to facilitate its oversight of the ethics and compliance program. 

Supporting the innocent: Since 2022, the U. S. Steel Legal Department has volunteered time and resources to support the Pennsylvania Innocence Project’s efforts to exonerate innocent people of crimes they did not commit. 

Report Intake

Reporter contacts Ethics and Safety Line (phone/online) or raises concern to an Internal resource that enters report into case management system

Immediate safety Issues and threats elevated to Safety & Security

Internal Audit has access to all reports

Review and Assignment

Legal Department reviews report, acknowledges receipt and assigns it to appropriate Investigator

Significant issues elevated to Audit Committee; regular updates provided, as necessary

Investigators Include trained personnel In Human Resources/Labor Relations, Safety & Security, Internal Audit and Legal

Investigation

Investigator conducts appropriate Investigation and prepares written report documenting findings and any remedial measures

Investigation may include document review, Interviews and other relevant steps

Confidentiality maintained to the extent possible

Case Closure

Cross-functional Case Closure Committee reviews Investigation process, findings and conclusions

Committee consists of Legal, Human Resources, Safety & Security, Internal Controls and Internal Audit

Investigation closed only if there is consensus by Case Closure Committee

Reporter advised that Investigation is complete, and that appropriate action has been taken, if applicable

Reporting Out

Employees receive overview of Ethics and Safety Line activity and sample cases Audit Committee receives detalled quarterly reports:

Updates regarding significant reports and Investigations

Data and trends on new reports (by location, Issue, anonymity of reporter)

Data and trends on closed cases (remedial actions, substantiation rates)

Business Partners
Beyond our employees, we expect our business partners to share our values and act in accordance with the S.T.E.E.L. Principles. Our standard contractual terms and conditions and Supplier Code of Conduct, which are published on our website and provided to suppliers, establish our requirements for ethical and lawful business practices, human rights and working conditions, and environmental stewardship throughout our supply chain. We require our suppliers to cascade our standards to any parties they use to support U. S. Steel’s business, maintain documentation demonstrating compliance with our standards, honor our periodic requests to formally audit them, and promptly inform us of any potential violations of the Supplier Code of Conduct. 
 
In addition, we actively vet and monitor our business partners to identify and address any ethics and compliance issues. We screen our business partners against lists of sanctioned and denied parties, conduct additional reviews of higher-risk counterparties to identify past misconduct or other compliance-related risks, and take additional steps to prevent human trafficking and forced and child labor in our supply chain. Among other things, we regularly train employees on human rights topics, conduct periodic risk assessments to identify supply chain risks, and actively work with suppliers to evaluate their sustainability performance, including with respect to human rights. We also regularly verify that certain goods are not sourced from sanctioned parties and that any conflict minerals used in our products are not sourced from the Democratic Republic of Congo or its adjoining countries. All these steps help ensure that our business partners act in accordance with our S.T.E.E.L. Principles and the laws that apply to our business. In addition, in August 2024, Big River Steel Works received the world’s first certification for ResponsibleSteel™ Certified Steel, showing, among other things, a demonstrable commitment to responsible sourcing of input materials.