Code of Conduct
Code of Conduct
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.
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
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.
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.
• 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.
…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.
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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
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.
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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).
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.
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.
No employee may share any sensitive Reliance business information with any third party,
including actual or potential competitors.
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.
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).
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.
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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.
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.
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.
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-
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proved by the Board or a Committee of the Board and promptly disclosed to Reliance stock-
holders, if required.