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Business ethics and a culture of compliance are essential factors in the Acerinox Group’s activities and that of all the members of its organization, extending to its relations with business partners and third parties

“At the Acerinox Group, we believe that success depends not only on achieving our goals, but also on the path we choose to achieve them. There are no shortcuts or alternative routes to success unless they are
firmly grounded on integrity and an absolute adherence to rules. This philosophy has allowed us to establish ourselves as a leader in the stainless steel industry and will guide us to a sustainable and responsible future.

Bernardo Velázquez Herreros.
Chief Executive Officer of Acerinox.

Code of Conduct

The Code of Conduct, approved by the Board of Directors, is the highest-level standard that guides the actions of all members of the Acerinox Group organization, including its governing bodies, members of Senior Management, executives, employees, workers pursuant to collaboration agreements, volunteers and trainees, regardless of their position, geographical location or functional dependence, and the Acerinox Group entity or company where they provide their services.

Trust, a good reputation and the protection of the company’s image are essential factors in the Group’s internal and external relations.

The principles of this Code must govern, guide and inspire the conduct of all those to whom it is addressed, as well as the implementation of the Group’s activities and internal rules.

Non-negotiable rules and regulations

fondo
We do not “buy” business
through corrupt practices
fondo
Honesty and candor
is the rule, not the exception
fondo
We do not compromise
the safety of people
fondo
Act always with
ethics and integrity
fondo
We do not do harm to our interest groups,
communities or reputations
fondo
Questions and issues are discussed with total respect
for freedom of expression
fondo
We do not alter
objective reports of results
fondo
We adhere to and enforce our
Code of Conduct
fondo
We do not compromise the quality
of our products
fondo
We do not bully
or victimise others
fondo
Each individual is accountable
for what they do
Fondo
We speak up and
report any wrongdoing

Compliance management system

The wide range of activities carried out by ACERINOX, the different geographical areas in which it operates and its ongoing relationship with third parties means that the Company is subject to a variety of regulations in different jurisdictions and is exposed it to a wide range of risks.

In accordance with this principle, together with the Company’s values and the Code of Conduct, ACERINOX has implemented a Compliance Management System based on the principles of transparency and due control, which can be summarized as follows:

1

The responsibility for Compliance is generally shared by all members of the Company, in their own areas and with a focus on risk, and specifically in accordance with the internal structure of functions and responsibilities established by the Company.

2

It reflects the commitments made by the Company in its regulations, which comprises the policies, standards, procedures and controls that enable and facilitate its effective implementation.

3

The existence of safeguards, such as the Compliance Function, whose responsibilities include ensuring knowledge, understanding, and compliance with the Company’s commitments as laid down in its policies, regulations, and procedures.

4

The establishment of a procedure for handling reports and inquiries regarding irregularities or beaches of the Code of Conduct and its underlying rules and policies.

Whistleblower channel

What is it?

The Acerinox Whistleblower Channel, also known as the Internal Reporting System, is a communication tool accessible to all employees and stakeholders to report behaviors that may constitute serious criminal or administrative violations and possible violations of the Code of Conduct or any other internal rules of the Group.

Purpose of the Whistleblower Channel:

  • Securely report acts or omissions that violate internal rules or applicable laws.
  • Protect both the whistleblower and related third parties in good faith by ensuring the confidentiality of the data and avoiding retaliation.
  • Ensure that the rights of the individuals allegedly involved are protected.
  • Carry out a thorough analysis of the information received.

Communication channels

Acerinox fosters a free environment where you can escalate any breach or non-compliance to your manager, Human Resources or the Compliance Department. In addition, the Internal Reporting System has several channels to facilitate the reporting of violations, adapted to local needs in each jurisdiction. Complaints may be made anonymously or with personal identification, in writing or verbally, through the following channels:

web_page1 Corporate websites: Whistleblower Channel

open_mail1Email information

write_letter1Mailing address: Complaints Committee, Acerinox S.A., Santiago de Compostela 100, 28035 Madrid, Spain.

telephone1Telephone numbers enabled in the different countries.

The Whistleblower Channel or Internal Reporting System is the primary channel for reporting acts or omissions that may constitute a crime or a serious or very serious administrative offense.

We encourage the responsible use of our Whistleblower Channel (IRS) by protecting all whistleblowers and informants, both anonymous and confidential, through the following guarantees:

archive_padlock1Confidentiality of information.

person_padlock1Protection of identity.

info_padlock1Absence of any form of retaliation for reporting or providing information through this Channel.

Supply chain compliance

As a leading company in the stainless steel sector, Acerinox is committed to sustainability, respect and defense of human rights and promotes an integrative corporate culture committed to diversity, equity and inclusion.

The Code of Conduct for Business Partners include the requirements we have established for our suppliers.

The requirements are updated periodically to ensure that they include the most up-to-date best practices and are aligned with our performance.

GOSUPPLY

Digital platform focused on supply chain risk management that enables effective assessment, monitoring and management of commitment and deployment of ESG policies and measures.

ASSESSMENT AND PERFORMANCE

Supplier performance is assessed annually through quality and delivery times, customer service, product/service competitiveness, continuous improvement evaluations and compliance with ESG criteria.

AUDITS

As part of responsible procurement management, Acerinox can request on-site and online audits, which may be carried out either by the company itself or by accredited external auditors. These
audits will focus on compliance with ESG standards and/or analysis of capacity verification, operational flexibility, quality management system, etc.

Compliance Indicators

Our figures

Interventions
+20
Interventions

with Senior Management

Actions
+4000
Actions

involving Communication, Awareness and Training

Annual
+1400
Annual

third-party assessments

Workforce
+95%
Workforce

trained in Ethics and Compliance

Complaints
+50
Complaints

received and managed

Documentation