Business ethics and compliance
We aim to be respectful of local customs and circumstances wherever we operate, while ensuring that we observe the same high standards of integrity and business ethics across the world. We believe that all business contracts should be awarded on merit, that corruption is not acceptable, and that no improper influence should be exerted on government officials or private individuals.
We operate 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 directors, officers, and employees, and anyone who acts on our behalf. We have incorporated these principles into our code of business conduct and anti-corruption guidelines.
ArcelorMittal’s Compliance Programme
In 2007, ArcelorMittal implemented its Compliance Programme, which has becoming more mature since then, with the creation of new policies and procedures, the adoption of effective monitoring and controlling mechanisms and the increasing involvement of employees and managers.
All relevant employees are required to undergo training relating to these policies every three years. Members of the Board of Directors also signed the company’s appointment letter in which they acknowledged their duties and obligations.
Each business segment reports on the status of its compliance training and on possible exceptions or non-compliances on a quarterly basis. These reports are collected, reviewed and reported to the audit committee of the Board of Directors on a quarterly basis. In addition, our compliance programme in different countries is audited by our internal assurance team.
The group compliance function is supported by a network of compliance officers across the group, who are responsible for monitoring and supporting the implementation of our compliance programme and related initiatives.
Our compliance policies are available to employees on a dedicated intranet site, in a number of different languages, and written in an accessible and clear style, which ensures that they are consistent, easy to implement and up to date.
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: