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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 the
Kloeckner SharePoint - Comliance Tab, The National Compliance Officer con-
under the “Guidelines and Procedures” tact information is:
COMPLIANCE
section. The information and materi- Jeff Friedman
als in this Compliance Portal support National Compliance Officer | Kloeck-
those corporate initiatives. ner Metals Corporation
500 Colonial Center Parkway Suite 500
Our business is built on trust and our Roswell, GA 30076
success is closely related to our repu- Direct | 678.318-1142
tation. At Kloeckner Metals, we believe
integrity is the foundation of any If you are unable to discuss a violation
successful and sustainable business. of the Code of Conduct or a Fraud or
Theft, with your Supervisor, and/or the
To that end, compliance is to take National Compliance Officer, then, as
precedence over short-term gains. a last resort please use the Ethics Line
Even if compliance might cost us anonymous reporting tool.
GUIDELINE
revenues and earnings, we would
choose compliance over revenues and To reach the Ethics Line phone
earnings. In short, we will follow all
regulations, rules, laws and the Cor- 1-800-500-0333
porate Code of Conduct & Guidelines A report will then be created by an in-
(Codes) which govern our business. dependent Ethics Line representative.
All Ethics Line reports will be directed
If you have a compliance or ethics to the National Compliance Officer for
question, Kloeckner Metals encour- confidential review and resolution.
ages you to seek the counsel of your
immediate supervisor. However, we Kloeckner Metals and Klöckner & Co.
also understand that in some instanc- has zero tolerance for non-compli-
es you might hesitate to go to your ance. We expect and appreciate your
supervisor. As an alternative employ- cooperation.

KMC NEWSLETTER 23