We are present in over 60 countries, which means that we work within many different cultures and business environments. This makes it all the more important that we are clear about the standards of behaviour we expect from our employees. We have embodied these principles in our code of business conduct and anti-corruption guidelines.
We aim to be respectful of local customs and circumstances, but we must also ensure that we observe high standards of integrity and business ethics and apply those standards consistently anywhere in the world.
Compliance and ethics
Our code of business conduct governs the way we do business, and there are more detailed policies and procedures in place covering specific issues such as human rights, anti-trust, anti-corruption, insider dealing, and economic sanctions. These policies are supported by compulsory training for employees, which takes place through face-to-face and online sessions and has to be repeated every three years*. We also have a dedicated intranet site for the compliance programme. The group compliance function is supported by a network of compliance officers at segment level or in significant business units who have responsibility to monitor the implementation of the compliance programme. Quarterly compliance certificates are completed by each business unit to report the status of compliance training and any non-compliances.
Our anti-corruption guidelines are designed to ensure that directors, officers, employees of ArcelorMittal and all ArcelorMittal subsidiaries acting on our behalf observe the highest levels of integrity and are not involved in any corrupt activities. These guidelines make it clear that both the company and its individual directors, officers, employees, subsidiaries could be held liable for any direct or indirect involvement in corrupt practices, which includes facilitation payments. Compliance with our anti-corruption guidelines is regularly monitored through internal assurance reviews and our confidential whistle-blowing systems, and in some high-risk countries we also carry out specific reviews or organise ethics and compliance workshops or events – for example, an Ethics and Compliance Day was held in Ukraine last year on December 11, coinciding with the United Nations Anti-Corruption Day. It is important that we demonstrate that our business is awarded on merit, that corruption is not acceptable, and that no improper influence should be exerted on government officials or private individuals.
Governments and regulators
We engage in policy debates on topics that are of legitimate concern to the group, or to our employees and the communities in which we operate. The role of the group's government affairs activities is to understand regulatory objectives, explain our position on these issues to policy-makers and stakeholders, and to work with other players in our industry to anticipate regulatory changes. We engage directly with governments in Europe, the North American Free Trade Agreement (NAFTA) region, South Africa and other countries on policy issues, such as climate change regulation, that we believe are essential to the future of the steel industry.
ArcelorMittal lobbies in an open and transparent way. For instance, ArcelorMittal has signed up to the European Commission’s Register of Interest Representatives , which provides further information on the work we do with European institutions, and information on the money we spend on lobbying and other public policy work. In the US, ArcelorMittal files a quarterly Lobbying Disclosure Report with Congress disclosing the company’s federal lobbying activities, including the total amount spent on lobbying and the issues and agencies lobbied. The policy issues that are most important to us in this respect are the environment and climate change, trade, social policy, and research and development.
We work closely with the European Steel industry association (EUROFER) and with other local trade associations to promote a fair and competitive marketplace in Europe. We believe that free trade helps to support our industry and encourage economic growth, and we support EUROFER in asking governments to secure more free trade agreements around the world. We also work actively with national steel associations around the world, such as in South Africa, Poland, Brazil, Mexico and the Ukraine, to express concerns about the impact that the increase on electricity and natural gas prices is having on the sustainability and competitiveness of our industry. We are taking an active part in supporting the European Commission Action Plan on the future of the European steel industry.
Corporate governance
There is more detail about our approach to corporate governance on pages 37 - 71 of our 2012 annual report available on www.arcelormittal.com in the in the Investors section of the site. This includes information on the composition and operation of the board of directors, the Group Management Board and the management committee, as well as the remuneration of senior management. In 2012 our board of directors introduced new policies on term limits and caps on the numbers of other directorships, claw backs on bonuses and performance related income under specific circumstances and guidelines on share ownership for directors.
This web-page was part of Deloitte's CR report assurance scope. View Deloitte LLPs assurance statement.
*Regular briefings and updates are given by the Group General Counsel and the Compliance Programme Officer to Senior Management, Board members, in particular members of Audit Committee (on a quarterly basis). The Audit Committee is responsible for supervising and reviewing the compliance programme (including anti-corruption) within the Group with a view to ensuring the adequacy, suitability and effectiveness of the programme and making recommendations for improvement if need be.