Political Activity/ Lobbying

The ANSA McAL Group encourages personal participation in the political process in a manner consistent with all relevant laws and Company guidelines. You may support the political process through personal contributions or by volunteering your personal time to the candidates or organizations of your choice but may not make or commit to political contributions on behalf of the ANSA McAL Group.

These activities, however, must not be conducted on Company time or involve the use of any Company resources such as telephones, computers, or supplies. If you wish to express personal views in a public forum (such as a letter to the newspaper), do not use Company letterheads, Company e-mails, or reference your Company address or title. Senior Managers and Executives particularly must avoid openly aligning themselves with any political party. In addition, the following rules apply:

The Company will not reimburse employees for personal political activity.

Your job will not be affected by your personal political views or your choice in political contributions.

Do not use the Company’s reputation or assets, including your time at work, to further your own political activities or interests.

If you plan to seek or accept a public office, you must advise your Managing Director or General Manager immediately prior to any formal announcement.

If you intend to become involved in political campaigning, in your pursuit for public office, you must proceed on approved leave from the Company and may utilize any outstanding vacation leave. Where more time is required, you must proceed on approved “no-pay” leave, the amount to be determined by the circumstances. In no case, is such leave, in total, to exceed one month.

If you are elected or nominated to part time or full-time public office which requires you to perform political/official duties during work hours, such time is considered a direct conflict with your responsibilities to the Company and as such, you will be required to make a choice between your continued employment and your political career.

Charitable Contributions

We support community development throughout the world. The ANSA McAL Group employees may contribute to these efforts, or may choose to contribute to organizations of their own choice. However, as with political activities, you may not use Company resources to personally support charitable or other non-profit institutions not specifically sanctioned or supported by our Company. You should consult the Group Corporate Communications Department if you have questions about permissible use of Company resources.

Truth in Advertising/ Marketing

It is our responsibility to represent accurately the ANSA McAL Group and our products in our marketing, advertising and sales materials. Deliberately misleading messages, omissions of important facts or false claims about our products, individuals, competitors or their products, services, or employees are inconsistent with our values. Sometimes it is necessary to make comparisons between our products and our competitors. When we do we will make factual and accurate statements that can be easily verified or reasonably relied upon.

Competitive Intelligence

Gathering competitive intelligence is a legitimate business practice. Whilst maintaining our competitiveness, we never use any illegal or unethical means to get information about other companies. Legitimate sources of competitive information include publicly available information such as news accounts, industry surveys, competitors’ displays at conferences and trade shows, and information publicly available on the Internet. Competitive information is also appropriately gained from customers and suppliers (unless they are prohibited from sharing the information) and by obtaining a licence to use the information or actually purchasing the ownership of the information. These principles apply to working with consultants, vendors and other partners.