Anti-corruption Policy

NLMK USA considers any form of bribery or corruption unacceptable and a violation of the Code of Ethical Business Conduct. NLMK USA employees are prohibited from direct or indirect involvement in any form of bribery or corruption including but not limited to cash payments, kickbacks, political contributions, charitable contributions, social benefits or gifts, travel, hospitality and reimbursement of expenses. The Company is committed to full compliance with all applicable anti-bribery and anti-corruption laws, including the Foreign Corrupt Practices Act (“FCPA”).

Established in 2013, the NLMK USA Corporate Compliance Committee administers the Code of Ethical Business Conduct. The Committee is responsible for monitoring performance under this Code and for resolving ethical concerns. Tom Taborek, VP of Human Resources & Labor Relations for NLMK USA is responsible for implementing the Company’s Anti-Bribery and Anti-Corruption Policy.

NLMK stock is not traded in the USA. The trading of NLMK stock is governed by law in countries where such trading occurs, and the NLMK Group seeks to comply fully with such law.

Feedback channels

Any violations of NLMK USA Anti-Bribery and Anti-Corruption Policy may be reported through one of the following feedback channels:

Concerns may be addressed to:

NLMK USA Corporate Compliance Committee

15 Roemer Boulevard

Farrell, Pennsylvania 16121

• Reports may be submitted online at nlmk.alertline.com
• Reports may be made by using NAVEX Global Compliance toll free number 1-877-874-8416.