Culture of integrity
Since 2007, the ArcelorMittal Group has been developing actions to encourage a global corporate culture of ethics to meet expectations of the new social dynamics. In that year, the Integrity Program was launched, based on the best practices of governance and compliance. The commitment is to use Group’s leadership role and its presence in more than sixty countries to promote an ethical, fair and equitable behavior, both inside and outside the company.
The Program essentially seeks to reinforce the ArcelorMittal Group’s strong commitment to integrity and corporate responsibility. It means that, no matter what location or economic or financial context the XX Group operates in, all decisions and businesses must be in line with the highest ethical and legal standards.
Each year, the ArcelorMittal Group makes new efforts to develop a broader and more comprehensive strategy, establishing a culture of integrity essential for the construction of an environment conducive to businesses based on ethical principles. Such culture goes beyond the organization’s walls, reaching all of those the ArcelorMittal Group interacts with.
In December 2014, the Chairman and CEO of the ArcelorMittal Group, Lakshmi Mittal, launched the development plan of the culture of integrity at global level, showing that the top management should be the advocate of such culture and should personally be involved with its dissemination.
The culture of integrity is based on three fundamental pillars:
- Pilar 1: Honesty and transparency: in every gesture, action and word, both inside and outside the Company, we comply with the rules of legislation, standards and ethics. We neither use shortcuts nor improvise. Our indicators, statements and reports are clear and objective, demonstrating the Company's alignment with compliance at all levels.
- Pilar 2: Respect and dignity: we seek innovation to always do the best for people and communities. Our performance values the respect and dignity of the human being, environment and assets. Our relations with all audiences focus on the long term, we respect contracts and confidentiality.
- Pilar 3: Exemplarity: individual action is always an example for collective action. ArcelorMittal Group leads by example, as well as each of its employees. Transparent and objective communication of our values and commitments will promote positive influence in the corporate environment and in our relationships, leading to recognition.
In line with this culture and the history of the ArcelorMittal Group, those pillars, as well as internal policies and standards, must be understood and practiced by all employees, advisors and directors in order to become increasingly solid.
The principles of the culture of integrity are constantly disseminated by the ArcelorMittal Group in a wide range of communication channels, through videos, screen rests, banners, e-mails, articles, presentations and internal newsletters.
ArcelorMittal Brazil follows the ArcelorMittal Group integrity model, transcending the formal requirements internationally established. The main guidelines are ethics, transparency and quality in stakeholder relations.
The good practices adopted aim to guarantee organizational success, as well as to establish strategic guidelines and monitor business development. They are aligned with the principles of the ArcelorMittal Group, guided by three values: Sustainability, Quality and Leadership.
In addition, it is worth mentioning that the Integrity Program has several policies and procedures in which all employees, advisors and directors defined as target audience are periodically trained (every three years). The program aims to ensure an ethical performance, observing legal requirements, reducing risks of exposure for the Group companies and their employees and complying with the best practices of conduct and the interests of the ArcelorMittal Group's stakeholders. The Company also has a periodical certification process to evaluate the implementation and effectiveness of the Program, and audits to detect its effective compliance.
ArcelorMittal Group also has a global annual certification process (Annual Certification of Compliance) evaluate the implementation and effectiveness of the Program, as well as audits to detect its effective compliance. The Annual Certificates of Compliance have as final recipient the Chairman and CEO of the ArcelorMittal Group. In order to support such certificates, the CEO of ArcelorMittal Brazil receives several subsidiary certificates forwarded by General Managers and Officers of the areas involved, including relevant information for the final certificates to be forwarded to the Chairman and CEO of the ArcelorMittal Group.
Among the policies comprising the scope of the program, it is worth stressing:
Code of Conduct: Launched along with the Integrity Program in 2007, the ArcelorMittal Group Code of Conduct sets out mandatory general guidelines which must be observed by all counselors, directors, officers, employees and business partners (including customers and suppliers) of the ArcelorMittal Group.
Instruction for Statement of Potential or Real Conflicts of Interest: Launched in 2013, this instruction establishes a set of basic guidelines applicable to the entire ArcelorMittal Group aiming at promoting transparency, improving governance, and guiding employees on issues of conflict of interest and related party transactions.
In order to carry out this instruction, the ArcelorMittal Group makes use of an electronic system called Conflict of Interest, through which annual statements of potential or actual conflicts of interest are made. Such statements shall be made by directors, managers and employees defined in a matrix based on a risk assessment, which also includes senior level professionals in the finance, supply, commercial, logistics, internal assurance and legal areas. It is worth noting that the rules on conflicts of interest apply to all employees. Therefore, even those not included in the defined target audience should inform their immediate superiors, the Compliance Officer or the Legal Department of any situation in which their personal interests conflict or may conflict with their obligations to the ArcelorMittal Group, so that appropriate measures are taken, according to each concrete situation.
- Instruction for Statement of Potential or Real Conflicts of Interest: Launched in 2013, this instruction establishes a set of basic guidelines applicable to the entire ArcelorMittal Group aiming at promoting transparency, improving governance, and guiding employees on issues of conflict of interest and related party transactions.
- Insider Dealing Policy: In 2007, the Insider Dealing Policy was launched establishing guidelines aimed at ensuring the proper handling of Insider Information, i.e., those which, if publicly disclosed, could significantly affect the price of ArcelorMittal Group securities or the decision of an investor to buy or sell securities. In addition to listing in detail the obligations of each insider category, or people who have access to such information, whether regularly or permanently, this policy provides data on the Closed Periods defined as those in which securities trading of the ArcelorMittal Group is prohibited to anyone in possession of such information. The Closing Period dates are posted on the ArcelorMittal Group website: http://corporate.arcelormittal.com/investors/investor-calendar.
Guidelines on Compliance with Competition Law: Launched in 2007, the Guidelines for Compliance with Competition Laws set out rules to prevent any conduct that infringes or may appear to infringe the fundamental antitrust laws and principles. Therefore, the Guidelines establish precautions and clear measures to be observed by employees in case they are in contact with competitors, carrying out benchmarking, taking part in class associations, among other situations.
- Procedure for statistical collection and disclosure of information by Class Associations: Set out in 2011, this procedure aims to establish specific rules applicable to employees of the ArcelorMittal Group, for the provision of commercially sensitive information to class associations, in compliance with the applicable legislations.
- Instruction on Search and Seizure: This instruction, set out in 2007, establishes Guidelines that employees of ArcelorMittal Group companies must adopt to ensure compliance with applicable laws during any antitrust investigation.
- Whistleblowing Policy: Launched in 2007, it establishes the guidelines for identifying any serious concerns with regard to irregularities in terms of accounting, auditing, finance, bribery, or any violations of the Program and applicable legislation.
- Anti-fraud Policy: Launched in 2008, this policy aims to reinforce the commitment to integrity, expressly stating that the ArcelorMittal Group is ruled by zero tolerance regarding the practice and concealment of fraudulent or illegal acts. Therefore, the essential principles guiding this commitment to integrity are clearly described in the referred document. Furthermore, the policy points out that, in order to conduct any eventual actions and investigations, the ArcelorMittal Group has an internal assurance and forensic investigation team, which has free and unrestricted access to all ArcelorMittal Group data and premises, confidentially treating all information received.
Anti-corruption Policy: This policy was introduced in 2009 following international best practices and establishing guidelines for dealing with issues related to corruption practices. Its purpose is to ensure that, while conducting business, employees and/or any third party acting on behalf of the ArcelorMittal Group comply with the highest standards of integrity. This commitment to take all possible measures to pursue integrity and ethical behavior precedes the Brazilian Anti-Corruption Law, which was published in 2013. In addition to expressly prohibiting corruption involving public entities, the Anti-Corruption Policy is even more comprehensive, expressly forbidding corruption also among private parties.
Based on the Anti-Corruption Policy, the ArcelorMittal Group launched the following specific procedures which aim to establish precise rules, internal controls and indicators to increase the effectiveness, transparency and security of the Program:
Procedure for Receiving and Offering Gifts and Entertainment: The Company understands that the exchange of gifts and entertainment can strengthen business relationships, but in some cases, it may create improper influences or seem to create improper influence. Thus, the Code of Business Conduct of the ArcelorMittal Group establishes that gifts or entertainment, when accepted or offered, must be of a modest nature, eventual, and shall have the real aim of facilitating the achievement of business objectives. Therefore, in 2013, this specific procedure was created and it clearly states (i) which gifts or entertainment are usually acceptable, regardless of prior approval; (ii) which ones should never be accepted; and (iii) which ones require prior approval from the immediate superior, or even from the Vice President responsible for the area that receives/offers the gift or entertainment.
The procedure also establishes that Directors and General Managers of ArcelorMittal Brazil must keep an updated Register of Gifts and Entertainment, including all gifts and entertainment eventually offered or received, in compliance with limits and rules.
Anti-Corruption Audit Procedure: The ArcelorMittal Group believes that the Culture of Integrity flourishes only in a healthy and authentic environment, and that should encompass all of those the organization relates with. Thus, the Group seeks to prioritize commercial partners, both in the public and private sectors, individuals and legal entities, who also work based on ethics and morals, thus avoiding the involvement and contracting of people who act differently. According with this procedure, audits must be conducted every three years, and all information and records should be kept for a period of at least 10 years.
The objective is to know the commercial partners and to mitigate the risks the ArcelorMittal Group would be exposed to in its relationship with them, especially those who act on behalf of the Company before public agencies.
Through this procedure, suppliers are classified as per the risk they represent. Each one is given a score, from 0 to 3, with level 3 being the most exposed to corruption. The ranking of suppliers is carried out based on objective criteria determined in a risk matrix.
Finally, with regard to mergers and acquisitions (M&A) involving the ArcelorMittal Group companies, the procedure provides for a more careful and specific audit to avoid the risk of companies subject to the transaction being directly or indirectly involved in corrupt activities
- Instruction on Political Contributions: Launched in 2012, this Instruction aims to ensure that political contributions eventually accomplished by the ArcelorMittal Group follow internal reporting procedures and are properly monitored in compliance with the Anti-Corruption Policy. In accordance with this procedure, all requests for political contributions, whether approved or not, must be included in the Register Table.
In Brazil, since September 2015, legal entities are not allowed to make political contributions.
- Procedure for Receiving and Offering Gifts and Entertainment: The Company understands that the exchange of gifts and entertainment can strengthen business relationships, but in some cases, it may create improper influences or seem to create improper influence. Thus, the Code of Business Conduct of the ArcelorMittal Group establishes that gifts or entertainment, when accepted or offered, must be of a modest nature, eventual, and shall have the real aim of facilitating the achievement of business objectives. Therefore, in 2013, this specific procedure was created and it clearly states (i) which gifts or entertainment are usually acceptable, regardless of prior approval; (ii) which ones should never be accepted; and (iii) which ones require prior approval from the immediate superior, or even from the Vice President responsible for the area that receives/offers the gift or entertainment.
- Diversity and Inclusion: Launched in 2009, the Policy aims to reinforce that the ArcelorMittal Group is convinced that the diversity of its team is a wealth, for it brings new ideas, perspectives and experiences into a welcoming environment and strengthens our values of Leadership, Sustainability and Quality. The Policy also emphasizes that the ArcelorMittal Group seeks to create a work environment where everyone has the opportunity to fully take part in creating business success and where all employees are valued for their skills, experiences and perspectives.
- Human Rights Policy: Launched in 2010, it stablishes the essential principles to keep an environment where human rights are respected in terms of health and safety, labor and local communities. This document is based on the following Declarations: (i) The United Nations (UN) Universal Declaration of Human Rights; (ii) International Covenants making up the International Bill of Human Rights; (iii) The International Labor Organizations’ (ILO) Declaration of Fundamental Principles and Rights at Work; and (iv) United Nations Global Compact.
Guidelines on Economic Sanctions: Established in 2011, the Economic Sanctions Guidelines establish the procedure to ensure compliance with the laws applicable to wherever ArcelorMittal Group operates, thus avoiding conducts that violate economic sanctions laws or programs. In light of this Policy, the Company advises its employees, notably in the commercial and procurement areas, to consult with the Economic Sanctions Lists available in the World Check system, a database used worldwide by the Group, prior to the execution of commercial transactions, so that necessary measures are taken to mitigate the risk of infringement of sanction laws and programs.
In the case of countries which are the target of specific sanctions, such as Sudan, Cuba and North Korea, this policy also provides for the need for prior analysis and approval by a specialized internal body, ArcelorMittal's Commercial and Marketing Coordination Department.
- Code for Responsible Sourcing: This procedure, launched in 2011, is applicable to all ArcelorMittal’s suppliers, their subcontractors and affiliated entities, as well as to all products and services purchased by the ArcelorMittal Group. In compliance with this procedure, the Company should strongly encourage its suppliers to collaborate with ArcelorMittal so as to identify further opportunities to improve business practices in the areas of health and safety, human rights, ethics and environment, along the entire supply chain.
- Data Protection Policy: Launched in 2013, this policy establishes uniform, adequate and comprehensive standards for the protection of personal information of employees, customers and suppliers involved with the ArcelorMittal Group.
Our Compliance policies are available to all employees in an exclusive page on the internet, in various languages, and written in a clear and accessible manner; such measures ensure that policies are consistent, easy to implement, and always updated.
Code of conduct
Our Code of Business Conduct governs the way we do business. Applying to all directors, employees, and third parties acting on behalf of the company, it stresses the importance of absolute compliance with all relevant laws, and also gives employees advice about avoiding potential conflicts of interest, ensuring fair relationships with customers and suppliers, protecting data, and using and safeguarding company assets. We also have more detailed policies and procedures covering specific topics such as human rights, anti-trust, anti-corruption, insider dealing, economic sanctions and data protection.
Click here to read our Code of Business Conduct.
Our Anti-Corruption Guidelines are designed to ensure that everyone at ArcelorMittal observes the highest levels of integrity and is not involved in any corrupt activities. The guidelines make it clear that the company, and its individual directors, officers, employees and subsidiaries, could be held liable for any direct or indirect involvement in corrupt practices, including facilitation payments. Employees can report any breaches of these standards via our confidential whistleblowing website system at corporate and local levels.
While ethics and integrity are universal values, it can be challenging to develop a culture of integrity that goes beyond mere compliance, and some environments are more challenging than others. Where we believe there may be a need to strengthen our programme, as a result of compliance risk assessments or internal audit, we develop an action plan to address those risks. This might involve organising workshops or events, developing an awareness campaign or enhancing compliance monitoring.
We have developed a number of procedures to complement our anti-corruption guidelines, such as procedures on political donations and lobbying, and on charitable contributions. In 2013, we introduced two more: a procedure for the giving and receiving of gifts and entertainment, and a procedure for declaration of conflict of interests that requires employees in nominated roles to declare any real or potential conflict of interest.
In 2014, it was published ArcelorMittal’s Anti-Corruption Due Diligence Procedure, which aims to assess and mitigate the risks that ArcelorMittal is exposed due to the relationship with our business partners, especially those acting on behalf of the Company. The risk assessment determines the level of the due diligence that will be conducted and it is based in criteria such like (i) time of relationship with ArcelorMittal; (ii) the size and type of company; (iii) the country’s score in International Transparence’s Corruption Perception Index; (iv) the partner main business activity; and (v) if the partner intracts with public officials or other entities on behalf of ArcelorMittal. The preliminary risk assessment is a required condition for the celebration of any agreement, which should include specific anti-fraud and anticorruption provisions determining the adoption of high standards of integrity and the commitment towards fighting corruption in the business relations.
Click here to read our Anti-Corruption Guidelines.
Human Rights Policy
Our Human Rights Policy draws on the UN Universal Declaration of Human Rights, the International Bill of Human Rights, the core conventions of the International Labour Organisation, and the UN Global Compact. It includes commitments to our workforce, local communities and business partners, and covers health and safety, labour rights and the rights of indigenous peoples.
The policy was developed in collaboration with non-governmental organisations, investors, and academic experts with experience in business and human rights and was published in 2010. This was followed by an intensive programme of communications and training – the biggest such initiative we had ever run – to raise awareness about human rights issues and ensure our employees understand what human rights means for their own specific roles.
The policy applies to every employee, and we have a compulsory training programme which has to be renewed every three years. It is available online, in local languages, with face-to-face support if there are particular issues to address.
We are integrating our human rights policy into our everyday governance and business practices through training, workshops, assessments, grievance mechanisms, audits and reporting.
The human rights policy sits alongside other specific policies in areas like health and safety, environment and anti-corruption. Since it was launched, we have introduced other more detailed policies in areas such as the use of force, arms and firearms by our security personnel.
We have developed an in-house human rights assessment tool, which allows our own sites to undertake an analysis of their situation as part of the implementation of the Human Rights Compliance Programme.
As well as self-assessments by our sites, we have extended our internal audit programme to cover aspects of human rights. We also assess the countries we operate in as part of our standard due diligence process to determine any risks posed to our employees, contractors and sites.
Click here to read our Human Rights Policy.
Data Protection Procedure
Risks relating to data protection are no higher in our industry than in others. We nonetheless deal with a lot of personal data, for example, from our employees and customers.
At the start of 2013, we launched a new data protection programme, based on our own procedure. This has been formally validated by the European Data Protection Authorities, enabling us to transfer data outside of the EU without the need for further data transfer agreements.
Our Data Protection Procedure applies to the whole group and is part of our compliance programme. We provided training to key managers with responsibilities in areas considered relevant from a personal data protection perspective, such as human resources and information technology.
Click here to read our Data Protection Procedure.
Anti-Fraud Policy and Whistleblowing Policy
Fighting fraud is a priority in the ArcelorMittal Group, which adopts a zero tolerance policy for fraudulent or illegal acts.
For whistleblowing on matters of ethical or financial misconduct or of corruption, the Company asks that the situation is reported to the immediate manager or, as a second instance, to the top management levels, such the Board of Directors and Board of Officers, as well as to the Internal Audit. The Company protects the authors of the whistleblowing and do not allow any kind of retaliation.
The Company has implemented a Whistleblowing channel, which aims to ensure the confidentiality of the case and the anonymity of the whistleblower, avoiding that complaints are not informed as a result of fear of negative exposure and/or retaliation.
If you want to inform us about any misconduct, you may do it through:
The Integrity Committee of ArcelorMittal Brazil was created in 2015, aiming at ensuring improvement and adaptation of its Integrity Program at all units of ArcelorMittal Brazil, in addition to advising and guiding top management in their mission of managing the Company in line with the values of the Group. The Integrity Committee comprises members of the Legal and Compliance Officer; Control, Risk and Compliance of the various business segments; Internal Controls, and SOX Compliance.
This Committee advises the Directors so as to maintain management in line with the values, policies and practices of the Group, conducting regular risk and company exposure analysis, and assessing the effectiveness of actions of the Integrity Program.
Through this channel, anyone can report situations of non-compliance they are aware of. Denunciations may, at the discretion of the whistleblower, be received anonymously; they are evaluated and investigated, ensuring the confidentiality of the issues and the protection of the whistleblower against eventual retaliation for the denunciations made. Those involving fraud are assessed by the forensic investigation department, while the others, usually involving labor issues, bullying, customer claims or conflict of interest, are coordinated by the Legal Department and Compliance Officer.
In order to ensure the continuous improvement of the Program, privileging those who believe in the Culture of Integrity and ensuring that appropriate measures are taken to avoid new occurrences, ArcelorMittal Brazil carries out several internal campaigns to encourage the whistleblowing.
- Toll free number: 0800-891-4311
- Internet: www.arcelormittal.alertline.com
- Mail: Internal Assurance – Forensic Services – Avenida Carandaí, nº 1115, 15th floor, Funcionários, CEP: 30.130-915, Belo Horizonte/MG.