Compliance with the following Supplier Expectations and Supply Chain Policies is a fundamental requirement of conducting business with ATI. In the event a supplier fails to comply with any of these Supplier Expectations and Supply Chain Policies, ATI reserves the right to take appropriate action, which may include, without limitation, suspension and/or termination of engagement with the supplier.
Integirty & Ethics
ATI is committed to more than just compliance with all laws and regulations. Our commitment is to reflect the highest level of integrity and ethics in our dealings with each other, our customers, our suppliers, our stockholders, the public, and the government agencies with whom we engage.
ATI’s Corporate Guidelines for Business Conduct and Ethics describe this commitment and our core values and set forth the basic principles, policies, and standards of conduct that apply throughout ATI’s global operations.
ATI expects all of our suppliers to conduct their business ethically and with integrity and to comply with the basic principles set forth in
ATI’s Corporate Guidelines for Business Conduct and Ethics. This includes compliance with all applicable local, national, and international laws and regulations.
If you have a concern related to any ATI business activity, including suspected violations of the law, suspected violations of
ATI’s Corporate Guidelines for Business Conduct and Ethics, or suspected violations of any ATI Policy, you can report your concern to ATI’s Chief Compliance Officer by phone at
412-394-2835 or via email at
ChiefComplianceOfficer@ATImetals.com. You may also report your concern through ATI’s Ethics HelpLine. ATI’s Ethics HelpLine is available 24 hours a day 7 days week and reports can be made by phone toll-free in the U.S. at
1-800-777-8767 or on-line at
www.ATIEthicsHelpLine.ethicspoint.com. International dial-in instructions are also available on-line at
Safety, Health, & Environmental Compliance
At ATI, safety, health, and environmental compliance are the pre-requisites to all operations. We are committed to providing a safe workplace and our goal is to finish each day incident- and injury –free. We are also committed to maintaining and operating our businesses in full compliance with all applicable environmental laws, regulations and rules.
ATI expects its suppliers to commit to operating a safe workplace and to follow and proceed with using all applicable safety, health and environmental laws, regulations, and rules.
Anti-Corruption & Anti-Bribery Compliance
ATI is committed to doing business ethically and in compliance with all laws that apply to our businesses throughout the world. Consistent with our values, ATI has a no tolerance policy towards bribery and corruption in all aspects of our business and in all countries in which we operate. ATI will comply with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and the anti-corruption and anti-bribery laws of all countries in which we operate or do any business.
ATI expects its suppliers to comply in all respects with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and all other anti-corruption and anti-bribery laws and regulations applicable throughout the world.
Section 1502 of the Wall Street Reform and Consumer Protection Act, known as the Dodd-Frank Act, directs the Securities and Exchange Commission (SEC) to impose reporting requirements on publicly-traded companies whose products contain “conflict minerals” which are defined as tantalum, tin, tungsten and gold. Specifically, the Dodd-Frank Act requires publicly-traded companies to disclose their use of conflict minerals originating from the Democratic Republic of the Congo (DRC) and adjoining countries that are “necessary to the functionality or production” of a product. Mining and transportation of conflict minerals is a significant source of funding for armed groups that fuel conflict and commit human rights abuses in the DRC. Section 1502 was enacted to address these humanitarian concerns and reduce this source of funding for the armed groups in this region.
ATI is committed to full compliance with the Dodd-Frank Act. ATI’s policy is to only purchase materials from legitimate and reputable suppliers, and to maintain a sustainable and responsible supply chain that does not in any way contribute to human rights abuses, fuel conflict, or benefit illegal armed groups. In accordance with this policy, ATI has implemented internal risk-based due diligence procedures designed to provide transparency to the origin of conflict minerals in our supply chain in compliance with the Dodd-Frank Act. ATI will communicate as appropriate with its suppliers regarding these procedures.
ATI expects all of its suppliers to conduct business in a manner that respects human rights and not to support sources or parties that contribute to human rights abuses. ATI expects its suppliers to be aware of the requirements of the Dodd-Frank Act, and to fully support ATI’s Dodd-Frank Act compliance efforts by providing transparency into the supply chain from the original source to ATI. ATI will immediately suspend or discontinue engagement with any supplier where we have identified that such supplier is sourcing from, or linked to, any party that supports illegal armed groups, fuels conflict, contributes to human rights abuses, or is not in compliance with the rules promulgated under the Dodd-Frank Act.
The California Transparency in Supply Chains Act
The California Transparency in Supply Chains Act requires companies like ATI that conduct business in California to disclose efforts to eliminate slavery and human trafficking in supply chains. All ATI employees are required to comply with all laws, rules and regulations in the jurisdictions in which we conduct our business, including laws related to the prohibition of trafficking and slave labor. Due to the nature of ATI's products, and the nature of items and services purchased, ATI believes the risk of slavery and human trafficking in its supply chains is low. Accordingly, ATI does not currently engage in verifications of product supply chains to evaluate and address risks of human trafficking and slavery; conduct audits of suppliers to evaluate supplier compliance with standards for trafficking and slavery in supply chains; require direct suppliers to certify that materials incorporated in to our products comply with the laws regarding slavery and human trafficking of the countries in which ATI does business; maintain internal accountability standards and procedures for employees or contractors failing to meet standards regarding slavery and human trafficking; or provide training regarding human trafficking and slavery to employees and management having direct responsibility for supply chain management.
ATI expects all of its suppliers to conduct business in a manner that respects human rights and to comply with all local, national and international laws and regulations related to the prohibition of human trafficking and slave labor. ATI reserves the right to immediately suspend or discontinue engagement with suppliers and will take appropriate action if we suspect any supplier has violated any law or regulation related to prohibition of human trafficking and slave labor.