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loeckner Metals and Klöck- ees may contact the Compliance
ner & Co. adopted a Com- Officer directly regarding any compli-
pliance Guideline in 2008 to ance issues which you may not wish to
facilitate and formalize busi- discuss with your supervisor or other
Kness practices and corporate member of management. Either way,
governance. The Guidelines were re- the company is committed to follow
placed in April of 2010 with the Code up such concerns raised by employees
of Conduct. In addition, supporting or business partners, without retalia-
compliance “Guidelines” on specific tion.
compliance topics are included on this
site, under the “Guidelines and Proce- The National Compliance Officer con-
dures” section. The information and tact information is:
COMPLIANCE
materials in this Compliance Portal Jeff Friedman
support those corporate initiatives. National Compliance Officer | Kloeck-
ner Metals Corporation
Our business is built on trust and our 500 Colonial Center Parkway Suite 500
success is closely related to our repu- Roswell, GA 30076
tation. At Kloeckner Metals, we believe Direct | 678.318-1142
integrity is the foundation of any
successful and sustainable business. If you are unable to discuss a violation
of the Code of Conduct or a Fraud or
To that end, compliance is to take Theft, with your Supervisor, and/or the
precedence over short-term gains. National Compliance Officer, then, as
Even if compliance might cost us a last resort please use the Ethics Line
revenues and earnings, we would anonymous reporting tool.
GUIDELINE
choose compliance over revenues and
earnings. In short, we will follow all To reach the Ethics Line phone
regulations, rules, laws and the Cor-
porate Code of Conduct & Guidelines 1-800-500-0333
(Codes) which govern our business. A report will then be created by an in-
dependent Ethics Line representative.
If you have a compliance or ethics All Ethics Line reports will be directed
question, Kloeckner Metals encour- to the National Compliance Officer for
ages you to seek the counsel of your confidential review and resolution.
immediate supervisor. However, we
also understand that in some instanc- Kloeckner Metals and Klöckner Metals
es you might hesitate to go to your has zero tolerance for non-compli-
supervisor. As an alternative employ- ance. We expect and appreciate your
cooperation.

KMC NEWSLETTER 23