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Code of Conduct

This document outlines Reliance's code of conduct for employees. It emphasizes integrity, leadership, diversity, people, service, and partnership. The code discusses acting with integrity, avoiding conflicts of interest, and treating all people fairly. Employees must comply with the code, which aims to ensure ethical business practices and sustainable profitability through honest and fair dealings.

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0% found this document useful (0 votes)
76 views16 pages

Code of Conduct

This document outlines Reliance's code of conduct for employees. It emphasizes integrity, leadership, diversity, people, service, and partnership. The code discusses acting with integrity, avoiding conflicts of interest, and treating all people fairly. Employees must comply with the code, which aims to ensure ethical business practices and sustainable profitability through honest and fair dealings.

Uploaded by

Yonas Kena
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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EMPLOYEE CODE OF CONDUCT

AC TING WITH INTEGRIT Y


CORPORATE VALUES

LEADERSHIP DIVERSITY
We believe that leadership is a team effort built upon We value diversity in our people, products, and
the mutual respect and fair treatment of employees, services. Reliance is rooted in the unique and diverse
customers, and suppliers along with strong community cultures within our Family of Companies. This
relationships, all developed through honesty and diversity of skills, services, knowledge, and ideas is
accountability. By demonstrating integrity, humility, cultivated to generate new solutions and processing
and trustworthiness our companies stand apart capabilities that enable us to adapt, innovate, and
from our peers and make positive impacts in our rapidly respond to the evolving and precise needs
communities. Everyone in the organization has the of our customers. We also continue to focus on what
opportunity to lead by example: showing respect we do well, where we do it best, and maintaining a
in all interactions, taking responsibility for their strong local presence in our markets. We maintain
own actions, inspiring trust through honesty, and our unique company culture and core values despite
contributing to the success of our company. external pressures.

PEOPLE INTEGRITY
We have a personal and professional commitment to We expect our employees to conduct themselves
protecting the health and safety of our employees, with honesty and integrity in all of their dealings
customers, suppliers, service providers and the people with customers, suppliers, service providers, and
in the communities in which we operate. Reliance the people in the communities in which we operate.
believes that one person can make a difference, but that Our responsibility and accountability to stockholders
ongoing success requires a diverse team of dedicated requires a diligent commitment to excellence and
people and companies working together to make a ethical business practices, ensuring sustainable
significant difference. Both the individual and combined profitability. Committed to honesty and fair dealings,
strengths of our Family of Companies make Reliance we set the highest standards for business practices,
the industry leader. adhere to applicable regulations, give back to our
communities, and ensure a safe and productive
SERVICE workplace for our employees.
Our aim is to deliver value to our customers by
providing the highest service levels possible. We PARTNERSHIP
deliver what we promise when we promise it, while Success is grounded in loyal and trusting partnerships
always striving to improve and exceed customer with our customers, suppliers, and communities.
expectations. Serving customers the right way is the Building and maintaining strong relationships is
only way we operate. Our customers, no matter their critical to the way we operate and it is our goal
size, end market, or unique supply requirements, to always develop and respect collaborative
will never receive less than our absolute best effort partnerships. Partnership means being committed to
to deliver excellence on all measures of quality and fair and trustworthy relationships with our customers,
service. We strive to always be flexible and agile in suppliers, and communities so they may be the best
servicing our customers’ needs. they can be.

EMPLOY EE CO DE OF CON DUC T 2


DEAR RELIANCE COLLEAGUE,

Reliance’s long-term success is founded on our ability to conduct our business activities and
transactions with the highest level of integrity and ethical standards, and in compliance with
all applicable laws, rules, and regulations. Whatever your position is at Reliance, our Company,
stockholders, and creditors depend on you to perform your duties to the highest standards of
ethics and judgment.

The attached Code of Conduct does not cover every issue that may arise, but it is an important
resource that sets forth the core principles that govern all Reliance employees and how we do
business. I ask that you read and understand the Code of Conduct and comply with any specific
policies and practices that apply to your job. If you have any questions, please contact your
supervisor or our General Counsel, Will Smith.

Our history is the key to writing the story of our future. We strive to be the market leader,
committed to setting industry leading standards in all measures of business performance and
customer service. We encourage all of our employees to exhibit the highest levels of personal
integrity, teamwork, and appreciation for our diverse individual and company cultures.
We believe in always treating people fairly, whether employee, supplier, service provider,
or customer, while always looking for ways to improve our service and contribution to the
communities in which we live and work.

Our daily behavior shapes Reliance’s reputation and value as an employer, a valued member of
the community, and a responsible corporate citizen. We believe our people and diversity are
the foundation of our success and we are committed to doing the right thing. Both what you
do and how you do it are critical to our collective success.

Sincerely,

James D. Hoffman
President and Chief Executive Officer

AC TING WITH INTEGRIT Y 1


CODE OF CONDUCT

1 WHO MUST COMPLY WITH THIS CODE OF CONDUCT?


Everyone at all levels of Reliance Steel & Aluminum Co. and its subsidiaries (“Reliance” or the
“Company”) has an obligation to know and follow this Code of Conduct (the “Code”), including:
• All members of the Reliance Board of Directors.
• All employees and officers of the Reliance Family of Companies.

In addition to governing conduct by employees, this Code governs conduct between employees
and customers, competitors, and the numerous business providers (including suppliers, service
providers, vendors, contractors, and agents) who assist Reliance every day. Because we want
our business providers, customers, and investors to understand how we do business and what
they can expect of us, this Code appears on the Reliance website and is available to the public.

To reaffirm their commitment to Reliance’s corporate values, Reliance requires that all employees
sign and acknowledge this Code of Conduct at least once every two years.

If you are a manager or supervisor, you are responsible for leading by example and making sure
your employees understand and comply with the Code.

2 CONFLICT OF INTEREST
Employees are expected to remain loyal to Reliance and avoid conflicts of interest. Generally,
a conflict of interest occurs when a personal or family interest interferes with our ability to
perform our jobs effectively and objectively.

Any situation that might put us in such a position or create the appearance of bias should be avoided.

YOUR RESPONSIBILITIES
All conflicts of interest, including potential conflicts of interest, must be disclosed to your
manager and the Corporate Legal Group at codeofconduct@rsac.com. You must comply with
this Code as well as any local conflict of interest policies that apply to your role, which may be
more restrictive than this corporate policy.

Any outside employment, business ventures, or financial activities cannot interfere with the
performance of your duties to Reliance.

In avoiding conflicts of interest, you must comply with the following principles:

• Do not hold a financial interest in or accept employment from an entity doing business with
Reliance if it would or could conflict with the performance of your duties at Reliance.
• Do not take any business related action for your personal benefit.
• Do not use Reliance equipment and resources for personal use.
• Protect Company assets as if they were your own.
• Do not take for yourself any opportunities that are discovered or advanced through the use
of your position with Reliance or any of Reliance’s property or information.
• No family member should report directly to another family member.

EMPLOY EE CO DE OF CON DUC T 2


1
• Do not facilitate a conflict with one of our suppliers, service providers, customers, or any
government official, for example, by making a payment to an individual when you know the
funds should go to his or her employer.

DISCLOSING AND ADDRESSING POTENTIAL CONFLICTS OF INTEREST


Reliance requires that you disclose, in writing, any personal, business, or other relationship
that might constitute a conflict of interest or could potentially create a conflict of interest. Our
policy is one of disclosure and review of potential conflicts and prohibition of actual conflicts
of interest. In some cases, disclosure may be all that is required. In other cases, however,
the facts may require additional action(s) to correct or avoid a conflict of interest. Some matters
may require periodic monitoring by local management to ensure transactions remain at arm’s
length. In all cases, however, you MUST disclose all actual and potential conflicts of interest.

Below we have listed certain activities and interests that present conflicts of interest or potential
conflicts of interest that would have to be disclosed. This list is not exhaustive, and you must
also disclose any other personal interests that may give rise to a conflict of interest. Because
it is impossible to describe every possible conflict of interest, Reliance relies on your good
judgment to seek advice when appropriate and to adhere to high ethical standards in the
conduct of your professional and personal affairs.

FINANCIAL CONFLICTS OF INTEREST


• Having a financial or management interest (as an employee, officer, or director) in any
customer, supplier, service provider, competitor, or any enterprise that you know or
reasonably believe has or may have a business relationship with Reliance. A financial interest
need not be disclosed if it involves less than 1% of the stock of a publicly held company,
unless it constitutes a significant portion of your net worth.
• Engaging in business with, or as a customer, service provider, or supplier of, Reliance, other
than in the ordinary course, as an employee or a public consumer.
• Competing with Reliance.
• Maintaining concurrent employment with Reliance and with any other organization.

EXAMPLE DISCLOSURE REQUIRED?


I...
All of these situations would require disclosure.
A personal business, part-time job, or director
position for another company may interfere
...have (or am starting) my own business with an employee’s duties to Reliance.

We need to conduct a conflict of interest


review to be sure your business, part-time
...want to take a part-time job
job, or directorship position does not involve
a competitor, supplier, service provider,
or customer or otherwise create issues of
...have been asked to serve as a director concern. If there are no issues, or if any
on the board of another company concerns can be effectively addressed, this
would likely be approved.

AC TING WITH INTEGRIT Y 3


1
PERSONAL RELATIONSHIPS WITH PARTIES IN
COMPANY-RELATED TRANSACTIONS
• FAMILY MEMBERS: Members of your immediate family (your spouse, domestic partner, minor
children) or, to your knowledge, your adult children, parents, or siblings are employed by Reliance,
a customer, supplier, service provider, or competitor of Reliance. If you disclose this type of conflict
of interest, you should also report any later change in the reported relationship that puts you in a
greater position to influence or be influenced by your relative’s employment.

• Arranging or facilitating any business transaction between any of your relatives and Reliance
or between any of your relatives and any customer, supplier, service provider, or competitor
of Reliance.

EXAMPLE DISCLOSURE REQUIRED?


I...
These situations require disclosure. If an
employee’s family member works for a
Reliance customer, supplier, service provider or
...have a family member who works for competitor, there is a risk that this relationship
Reliance may affect the employee’s business judgment.
The family member’s employment must be
disclosed so that the facts can be analyzed to
...have a family member who works for
a customer, supplier, service provider, or determine if a conflict exists.
competitor of Reliance
Disclosure of family members who work for
...have a family member who owns real Reliance allows the Company to ensure that no
estate leased by Reliance conflict of interest, such as directly supervising
a family member, exists.

GIFTS, FEES, OR OTHER PERSONAL BENEFITS


• Accepting fees, commissions, or any other personal benefit (other than as permitted in the
bullets below) from any person or business involved in any business with Reliance.
• Accepting any of the following from a current or would-be customer, supplier, service provider, or
competitor of Reliance: excessive entertainment, meals, gifts, discounts, services, transportation,
or favors that: (i) obligate you or influence your decision-making in any way, regardless of value;
or (ii) might create the appearance of undue influence, unfairness, or impropriety.
• Offering or supplying entertainment, meals, transportation, gifts, or other favors to any
person in a business relationship with Reliance, other than what is reasonable and appropriate
for the individuals involved and the business at hand.
• Soliciting or accepting money (or cash equivalents such as gift cards) for your personal
benefit in any amount from a current or potential customer, supplier, service provider, or
competitor of Reliance.
• Accepting an offer to participate, through a special allocation of shares, or otherwise receiving
terms or benefits not generally available to the public in an offering of securities of, or underwritten
by, any current or prospective customer, supplier, service provider, or competitor of Reliance or a
firm that provides or may provide investment banking, financial advisory, underwriting, or other
similar services to Reliance or any other entity with which Reliance has a business relationship.

EMPLOY EE CO DE OF CON DUC T 4


EXAMPLE DISCLOSURE REQUIRED?
I... This does not need to be included on the Disclosure
Form but you should disclose this to your supervisor
.…have been invited to Las at the time the invitation is extended and they will
Vegas by a supplier to stay at determine if you can accept.
a resort and play golf.
Your supervisor will consider the value of the invitation
and whether business will be conducted on the trip.

…am responsible for You must disclose this relationship prior to selecting
selecting a product or a supplier. You should consult your manager and the
service supplier for the General Counsel. The best course of action is either for
Company. One of the you not to be involved in the selection process or for your
suppliers being considered daughter’s business to be eliminated from consideration.
is a company owned by my
daughter. If ultimately your daughter’s company is selected as
a supplier, this would need to be included on the
Disclosure Form.

SAFETY
Safety is one of our core values at Reliance and that includes providing a safe and secure
work environment. Maintaining a safe working environment is of the utmost importance and is
everyone’s responsibility.
3
YOUR RESPONSIBILITIES
• All employees must familiarize themselves and comply with Reliance’s posted safety rules
and directives.
• Do not undertake work you are not qualified to perform.
• Observe all safety rules and procedures when operating machinery and equipment.
• Always wear Reliance-approved personal protective equipment (PPE) whenever required.
• Immediately report workplace accidents, injuries, illnesses, and unsafe conditions to your
supervisor to ensure prompt medical attention (if necessary), help prevent future incidents,
and ensure timely regulatory reporting (if required).
• Report all non-work-related injuries and illnesses that may affect the safe performance of
your job prior to performing any work.
• Communicate our safety and health requirements to anyone coming onto Reliance property,
including visitors, customers, suppliers, service providers, workers, and contractors

AC TING WITH INTEGRIT Y 5


4 ANTI-BRIBERY AND ANTI-CORRUPTION
The legal requirements of every country where Reliance does business prohibit improper
payments to government officials. In addition, this Code prohibits Reliance employees and
anyone acting on the Company’s behalf from offering, giving, accepting, or receiving a bribe
to/from anyone. We have built a reputation as a company that operates ethically and honestly,
and bribery and corruption have no place in our business. Bribery and corruption can cause
irreparable harm to our good name, our business, and the communities where we do business.

YOUR RESPONSIBILITIES
• Reliance employees may never offer, promise, or give anything of value that could appear
to be a payment — something that might encourage or reward someone for a decision to
retain or obtain business.
• All Reliance employees required to complete anti-corruption training must become familiar
and comply with the Company’s Anti-Bribery and Anti-Corruption Policy, which provides
more detail on the Company’s policies regarding anti-bribery and anti-corruption. Any
questions regarding such policies should be directed to the Company’s Corporate Legal
Group at codeofconduct@rsac.com.

5
FRAUD, DISHONESTY OR CRIMINAL CONDUCT
Reliance does not permit fraud, dishonesty, or criminal conduct. We value ethics and integrity
and will not tolerate fraud, dishonesty, or criminal conduct.

YOUR RESPONSIBILITIES
• We place a great deal of trust and confidence in our employees. In return, we expect you
to act ethically and honestly in everything you do. Any use of fraudulent or illegal tactics
violates that trust and carries potentially severe consequences, including discipline, up to
and including termination. Reliance will also cooperate with authorities to prosecute any act
of fraud, dishonesty, or criminal conduct.
• Reliance prohibits fraud or dishonesty in connection with Company business, including taking
unfair advantage of anyone through manipulation, concealment, abuse of privileged information,
misrepresentation of material facts, or any other unfair dealing practice, criminal conduct, or any
violent activity on Company premises or while performing work for the Company.
• If any fraud, dishonesty, or criminal conduct is detected or suspected of any employee or
anyone doing business with the Company, such activities should be reported to the General
Counsel or the Reliance Ethics Hotline (see Section 16).

EMPLOY EE CO DE OF CON DUC T 6


SAFEGUARDING CONFIDENTIAL INFORMATION
Information is one of our most valuable assets. Business records, customer information, financial
information, and intellectual property are Company assets that are essential to our operations.
This information is not available to the public and includes sensitive business information
6
(customer, supplier, service provider and financial information) which has been entrusted to us.
We all are responsible for keeping this information confidential.

YOUR RESPONSIBILITIES
• You may not use any information belonging to Reliance for your own personal gain.
Confidential information may only be shared with Reliance employees, officers, and directors
who need the information in order to do their job.
• Confidential information must not be shared outside Reliance without a confidentiality
agreement approved by the Corporate Legal Group. Confidentiality obligations continue
even after you leave Reliance.
• Any unauthorized disclosure of confidential information, whether unintentional or not, must
be reported immediately to the Corporate Legal Group at codeofconduct@rsac.com.
• This policy and the other provisions of this Code are not intended to prevent or dissuade
employees from engaging in communications or activities protected by state or federal law,
such as discussing wages, benefits, or other terms and conditions of employment. This policy
also does not prevent employees from disclosing confidential information when required by
law or legal process.

AC TING WITH INTEGRIT Y 7


7 SECURITIES TRANSACTIONS
In the course of performing your job duties, you may occasionally obtain material information
about Reliance that has not yet been made available to the public. When you are aware of
material non-public information, it is a violation of United States federal securities laws to
purchase or sell Reliance securities (including stock). This activity is called insider trading, and
it is both illegal and against Company policy. The penalties for insider trading violations can
include criminal fines and/or a jail term of up to 20 years for each violation. In addition, penalties
can require repayment of unlawful profits and include a penalty of up to three times the ill-
gotten profits. These penalties are in addition to the Company’s disciplinary actions, which can
include termination of employment.

YOUR RESPONSIBILITIES
• Until Reliance has made important information about the Company public, employees must
keep it confidential and are forbidden from using it for personal gain.
• It is illegal to share material non-public information with anyone to help them gain some
advantage, either by buying or selling Reliance securities. This includes sharing or giving
“tips” to spouses, brokers, friends, or family members.
• You may not trade in the securities of another company (including Reliance customers,
suppliers, service providers, or business partners) if you obtained material non-public
information about them in the course of performing your duties at Reliance.
• Never disclose any non-public information without a legitimate business purpose and proper
prior authorization.
• Certain employees who regularly have access to non-public information have additional
obligations, including not trading during quarterly trading “blackouts” and/or an obligation
to clear trades with the Corporate Legal Group. These obligations — and more information
about trading in general — are provided in the Reliance Insider Trading and Securities
Compliance Policy.

EMPLOY EE CO DE OF CON DUC T 8


TRADE PRACTICES
Antitrust and competition laws protect free enterprise. Reliance is committed to free and fair
competition and complying with all applicable antitrust laws.
8
YOUR RESPONSIBILITIES
• It is your responsibility to be aware of the anti-trust laws and their implications, including how
they apply in the countries in which you do business. While these laws are often complex and
difficult to summarize, at a basic level they prohibit agreements between Reliance and our
competitors that affect prices, terms or conditions of sale or fair competition.
• Use care in your relations with competitors. You might interact with competitors through
industry meetings, conferences, and other events. When you do, be careful not to make
inappropriate agreements. Never engage in practices such as price fixing, customer or
market allocation, or bid rigging.
• Trade association meetings and other industry gatherings can pose certain risks, as they
bring together competitors who might discuss matters of mutual concern and potentially
cross the line of non-compliance with competition laws. Even joking about inappropriate
topics, such as marketing or pricing strategies, could be misinterpreted and misreported. If
any kind of anti-competitive discussion arises, you should refuse to discuss the matter and
leave the conversation immediately.
• No employee may share any sensitive Reliance business information (prices, costs, margins,
research and development efforts, strategic plans, etc.) with any third party, including actual
or potential competitors.
• Employees will consult with the General Counsel before making any joint bids with
competitors.
• If any inappropriate or illegal competition or antitrust conduct is detected or suspected
of any employee or anyone doing business with the Company, such activities should be
reported in accordance with Section 16 of this Code (see below).

No employee may share any sensitive Reliance business information with any third party,
including actual or potential competitors.

INTERNATIONAL TRADE LAWS


We abide by the trade laws of all countries in which we operate, including economic sanctions
and import and export laws. Most countries in which Reliance operates impose restrictions on
the movement of products across borders.
9
YOUR RESPONSIBILITIES
• Trade sanctions, including financial sanctions, are complex. If you are involved in international
transactions, such as business dealings with a sanctioned country, entity, or person, you
must ensure compliance with applicable trade laws.
• Products intended for import or export, including equipment, software, and technology,
must be classified in advance and all required labelling, documentation, licenses and
approvals must be completed.
• Any questions about export regulations should be addressed to your local export
compliance manager or Erick Wallace, Reliance’s Corporate Export Compliance Manager
(email: ewallace@rsac.com or telephone: 253-732-8119).

AC TING WITH INTEGRIT Y 9


10 EMPLOYMENT PRACTICES
At Reliance, our employees are individuals with different abilities, backgrounds, and
experiences. We believe that every employee should have the opportunity to fully contribute
and the Company forbids employment discrimination or harassment based on race, color, sex
(including pregnancy, childbirth, and related medical conditions), national origin, religion, age,
disability, genetic information, veteran status, sexual orientation, marital status, or any other
characteristic protected by applicable law.

YOUR RESPONSIBILITIES
• Reliance employees must treat each other with respect and dignity.
• Value the contributions of others as Reliance does, and listen to their viewpoints.
• Maintain fairness in all relationships.
• Never discriminate against anyone — including fellow employees, customers, suppliers,
service providers, partners, or any other person.
• All employees who believe that discrimination or harassment has occurred should report the
incident, even if they are not the target of such discrimination or harassment.
• Reliance prohibits retaliation against any individual who reports discrimination or harassment
or participates in an investigation relating to alleged discrimination or harassment pursuant
to the applicable procedures.
Reliance employees must treat each other with respect and dignity.

11 INTERACTIONS WITH OUTSIDE PEOPLE AND


ORGANIZATIONS
• All investor or media inquiries regarding Reliance should be referred to or discussed with the
Chief Executive Officer and/or the Chief Financial Officer.
• Only the CEO and CFO are authorized to address the media and our investors.
• Each of the CEO and the CFO may grant certain Reliance employees permission to address
the media and/or our investors under certain limited circumstances.

EMPLOY EE CO DE OF CON DUC T 10


DISCLOSURE
Reliance is committed to providing stockholders, governmental agencies, and creditors with
timely and accurate information about our results of operations. All public disclosures, including
forecasts, press releases, speeches, and other communications, will be honest, accurate, timely
12
representations of the facts. If any reports are not accurate and truthful, our reputation could
be damaged and we could face fines and penalties.

YOUR RESPONSIBILITIES
• Make sure that any business information you report is accurate, complete, and timely. Be
certain that any document you prepare or sign is correct, complete and truthful. Providing
false or misleading records or altering records is always wrong and can be a serious violation
of the law.
• To ensure compliance with all applicable securities laws and regulations, each employee
involved in Reliance’s disclosure process, including the Chief Executive Officer and the
Chief Financial Officer, is required to be familiar with and comply with Reliance’s disclosure
controls and procedures and internal control over financial reporting.
• Each employee that has direct or supervisory authority regarding securities filings or
Reliance’s other public communications concerning its general business, results, financial
condition, and prospects should consult with other Company officers and employees with
the goal of making full, fair, accurate, timely, and understandable disclosure.
• Each employee who is involved in the Company’s disclosure process must: (a) familiarize himself
or herself with the disclosure requirements applicable to Reliance as well as our business and
financial operations; (b) not misrepresent, or cause others to misrepresent, facts about Reliance
to others, including to Reliance’s independent auditors, governmental regulators, and self-
regulatory organizations; and (c) properly review and critically analyze proposed disclosure for
accuracy and completeness (or, where appropriate, delegate this task to others).
• Promptly report suspicious transactions or activities and refer questions relating to these
topics to the Internal Audit Department or the Reliance Ethics Hotline (see Section 16).

AC TING WITH INTEGRIT Y 11


13 PRIVACY
Reliance respects the confidentiality of the personal information of its employees, customers,
suppliers, and service providers. Colleagues, customers, suppliers, service providers, and
many others entrust Reliance with personal information and it is our responsibility to keep this
information confidential.

YOUR RESPONSIBILITIES
• Do not provide confidential or proprietary information to third parties, including business
partners and vendors, without appropriate authorization and a valid confidentiality
agreement. If in doubt, check with your manager or the Corporate Legal Group.
• Be careful when using electronic means of storing and sending information.
• Do not discuss confidential information in places where you might be overheard.
• Secure all confidential information when working in an open environment.
• Properly dispose of confidential or proprietary information.
• Beware of informal telephone or email requests from outsiders seeking personal or
confidential information (commonly known as “phishing”).
• All computers, electronic equipment, electronic data and records, Company issued
phones, physical files, lockers, desks, and other furniture are the property of the Company.
Employees are not entitled to, and should have no expectation of, any right of privacy as to
any materials, communications, information, or files maintained, transmitted, or stored using
the Company’s property and systems regardless of the nature of any such communication,
material, information, or file.

14
INTELLECTUAL PROPERTY
Intellectual property that is designed, created, developed, or modified while performing work-
related duties is Company property.

YOUR RESPONSIBILITIES
• Employees may not copy software provided to Reliance by vendors unless the Company
is licensed to make copies and the employee has received written permission from the
Corporate Legal Group, or Reliance corporate senior management.

EMPLOY EE CO DE OF CON DUC T 12


ENVIRONMENTAL RESPONSIBILITY
Employees should conduct Reliance business in compliance with all applicable environmental
laws and regulations. If you believe that an environmental hazard exists, that there has been a
release of any hazardous substance, or that environmental guidelines are not being followed,
15
you must immediately report the situation to your manager.

REPORTING AND ACCOUNTABILITY


Making proper decisions can be difficult in our complex business environment. You may
occasionally need to seek advice or assistance in order to resolve an issue. You are encouraged
to seek information or guidance about our ethics and compliance standards. Reliance is a non-
16
retaliatory environment, making it safe for employees to raise ethics and compliance concerns
in good faith. Our non-retaliation policy is actively supported by our board of directors and
senior management.

YOUR RESPONSIBILITIES
• Seek help if you are ever unsure on a course of action.
• NO ONE, even senior officers, has the authority to tell you to do something illegal or
unethical.
• Raise concerns about any violations of our Code that you see or suspect.
• Never retaliate against anyone who makes a good faith report of suspected misconduct.
• Cooperate fully and honestly in any internal investigation of alleged misconduct.

ETHICS AND COMPLIANCE HOTLINE


To promote ethical behavior and a culture of compliance, Reliance offers Compliance Hotline
phone and web-reporting tools. These tools provide all Reliance employees a way to report
concerns or get information or advice (where available and permitted by law). Both the
telephone hotline and the web-reporting tool are operated by specially trained third-party
representatives and are available 24 hours a day, 7 days a week, 365 days a year. All information
reported through the telephone hotline and the web-reporting tool is forwarded to Reliance
personnel responsible for administration of the Code. You can request to receive information
about the Company’s response to your concerns.

You are encouraged to identify yourself when using the Compliance Hotline as this information
often helps promote a thorough response or investigation. However, certain jurisdictions,
including the United States, allow anonymous Compliance Hotline reports.

Reliance Telephone Hotline: Tel: 877-318-9185 or 866-384-4277

Reliance Web-reporting Tool: www.reliance.ethicspoint.com

WAIVERS
All employees, officers and directors are required to follow this Code. Waivers of this Code
for employees and officers of the Reliance family of companies must be approved by the
General Counsel. Waivers of this Code for board members or executive officers must be ap-
17
proved by the Board or a Committee of the Board and promptly disclosed to Reliance stock-
holders, if required.

AC TING WITH INTEGRIT Y 13


350 South Grand Avenue, Suite 5100
Los Angeles, CA 90071
213-687-7700 | www.rsac.com

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