Insider Dealing Regulations

To comply with Transparency Laws applicable to listed companies, the board of directors of Aperam has adopted the insider dealing regulations, which apply throughout the Aperam group in every geographical location where Aperam employees are based. These regulations are designed to ensure the appropriate treatment of inside information in the company and avoid insider dealing and market manipulation.

Insider Dealing Regulations


Aperam Code of business conduct

Our Code of Business Conduct governs the way we do business. Applying to all directors, employees, and third parties acting on behalf of the company, it stresses the importance of absolute compliance with all relevant laws, and also gives employees advice about avoiding potential conflicts of interest, ensuring fair relationships with customers and suppliers, protecting data, and using and safeguarding company assets. We also have more detailed policies and procedures covering specific topics such as human rights, anti-trust, anti-corruption, insider dealing, economic sanctions and data protection. All relevant employees are required to undergo training relating to these policies every three years. The group compliance function is supported by a network of compliance officers across the group, who are responsible for monitoring and supporting the implementation of our compliance programme and related initiatives. Our compliance policies are communicated to all employees with CEO Messages and are available together with relevant training material to employees on a dedicated Aperam Corporate Governance and Compliance site.

Code of Business Conduct 

Anti corruption and bribery policy

Aperam’s anti-corruption and bribery policy is designed to ensure that everyone at Aperam observes the highest levels of integrity and is not involved in any corrupt activities. The policy make it clear that the company, and its individual directors, officers, employees and subsidiaries, could be held liable for any direct or indirect involvement in corrupt practices, including facilitation payments.



For whistleblowing on matters of financial misconduct, individuals or groups may use an anonymous facility via the whistleblowing hotline. During 2013, there were 10 complaints relating to fraud, which were referred to the Company’s Combined Assurance Department for investigation. At the end of 2013, 8 forensic cases had been finalized and 2 were in progress. Following review by the Audit and Risk Management Committee, none of the 8finalized cases were found to be significant.

Link to the Whistleblower 


Aperam’s anti-trust policy has been communicated to all Aperam employees. It is mandatory for relevant employees to be trained in anti-trust policy.


Data privacy

Aperam’s  data privacy policy applies to the whole group and is part of the Company’s compliance programme. Training is mandatory to key managers with responsibilities in areas considered relevant from a personal data protection perspective, such as human resources and IT and the Company  will continue its  efforts with a view to training all relevant employees in 2014.