Corporate Policies

This page lists Aperam's corporate policies.

Ethics & Governance
Code of Business Conduct

Aperam’s Code of Business Conduct helps us better understand our ethical and legal obligations when conducting company business. Although this Code of Conduct does not cover every possible issue, its intent is to establish guidelines that we can refer to in situations where the proper course of conduct is not immediately clear.

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Anti-Corruption and Bribery Policy

Aperam has a Zero Tolerance approach to any acts or attempted acts of corruption or bribery. This Policy is applicable to all staff, including management and directors, and all of its subsidiaries and in all geographical locations that Aperam does business. The Policy is also applicable to any third party acting on behalf of or in the interest of Aperam and/or its subsidiaries, including joint ventures with another company or organisation. In addition to this Policy, Aperam has adopted a number of related internal company procedures e.g., Whistleblowing Procedure.

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Gift Policy

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Risk Management Policy

Aperam’s Risk Management Policy establishes a set of effective processes that are embedded within our organisational culture. The Policy is a key element to ensuring the company’s competitiveness and sustainability via operational effectiveness and by creating wealth for all stakeholders.

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Anti-Money Laundering / Counter-Terrorism Financing Policy

This Policy implements the principles and standards adopted by the company to prevent instances of money laundering and terrorist financing. This Policy is applicable to all Aperam staff, including management and directors, and all subsidiaries.  

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Group Tax Policy

In order to implement a sustainable Group Tax Policy, this policy applies to all tax professionals dealing with significant Aperam operations and transactions having tax implications and, in particular, to all finance directors.

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Prevention of misconduct and whistleblowing Policy

Aperam aims to conduct its business activities in compliance with applicable laws and regulations, and in a fair and transparent manner by adopting the highest standards of professionalism, honesty and integrity. Aperam is committed to create an environment within which everyone can bring to the attention of the Company, concerns and complaints about particular incidents of wrongdoing involving Aperam employees and, subject to contractual relations, involving also to stakeholders, vendors, contractors, outside agencies and any other party having a business relationship with the Aperam Group - this, without fear of criticism, dismissal or retaliation of any kind.

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Antitrust Compliance Policy

This Policy outlines Aperam’s commitment to strictly observe the competition laws of the countries in which it does business and to avoid any conduct that could be considered illegal. This Policy is applicable to all Aperam staff, including management and directors, and all subsidiaries.

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Insider Dealing

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Privacy Policy for third parties

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Environment
Environmental Policy

The Environmental Policy promotes key principles for achieving environmental excellence and advice on incorporating these principles into all Aperam activities.

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Energy Policy

Aperam’s Energy Policy promotes the efficient use of energy as a means of lowering costs and achieving our environmental commitments.

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Code for Sustainable Sourcing and Purchasing

With the aim of promoting sustainable business practices by its suppliers, this Code communicates how Aperam works with our suppliers and sets out our expectation that they meet the minimum standards set out in our Health and Safety, Human Rights, Ethical and Environmental policies. Aperam encourages its suppliers to work with us in identifying and developing ongoing performance improvements to our sustainable procurement programme.  

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Transport Charter

In line with our values and commitments for sustainability, Aperam aims to reduce its impact while maintaining customer satisfaction and cost-­effectiveness thanks to the implementation of this Freight Transport Policy.

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Social
Human Rights Policy

Our Human Rights Policy expresses Aperam’s respect and commitment to all human rights, with a focus on the areas our industry has identified as priorities,especially Gender Diversity, for which a policy comes as an appendix to the main document. 

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Health and Safety Policy

Aperam’s commitment to Health and Safety as a core component of its “Made for Life” brand promise is found in this Policy.

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Code for Sustainable Sourcing and Purchasing

With the aim of promoting sustainable business practices by its suppliers, this Code communicates how Aperam works with our suppliers and sets out our expectation that they meet the minimum standards set out in our Health and Safety, Human Rights, Ethical and Environmental policies. Aperam encourages its suppliers to work with us in identifying and developing ongoing performance improvements to our sustainable procurement programme.  

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