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Board/ Committee Self-evaluation
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We have an annual
self-evaluation process for the Board and for each standing committee of the Board.
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Director and NEO Stock Ownership
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Each director is
expected to own at least 10,000 shares of our common stock.
Executives are expected to own ATI common stock with a value equivalent to:
CEO: 6
times base salary;
Executive Vice Presidents and the Chief Financial Officer: 3 times base salary;
and
Senior Vice Presidents: 2 times base salary.
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Ethics/Corporate Responsibility
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Our
Corporate
Guidelines for Business Conduct and Ethics
, as well as the Companys attention to environmental, social and governance issues, are disclosed on our website.
The Company has an active ethics and compliance program that includes regular
employee training.
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Corporate Governance Guidelines
ATIs Board of Directors has adopted Corporate Governance Guidelines that are designed to assist the Board in the exercise of its duties and responsibilities to the
Company. The Guidelines reflect the Boards commitment to monitor the effectiveness of decision making at the Board and management levels, with a view to achieving ATIs strategic objectives. The Guidelines are subject to modification by
the Board at any time.
Corporate Guidelines for Business Conduct and Ethics
Our
Corporate Guidelines for Business Conduct and Ethics
(our Code of Ethics) apply to all directors, officers and employees, including our principal
executive officer, our principal financial officer, and our controller and principal accounting officer. We require all directors, officers and employees to adhere to our Code of Ethics in addressing legal and ethical issues encountered in their
work.
Our Code of Ethics requires that our directors, officers and employees avoid conflicts of interest, comply with applicable laws, conduct business in an honest
and ethical manner, and otherwise act with integrity and honesty in all of their actions by or on behalf of the Company. It includes a financial code of ethics specifically for our Chief Executive Officer, our Chief Financial Officer, and all other
financial officers and employees, which supplements the general principles in the Code of Ethics and is intended to promote honest and ethical conduct, full and accurate reporting, and compliance with laws, as well as other matters.
Only the Audit Committee of the Board can amend or grant waivers from the provisions of the Code of Ethics relating to the Companys executive officers and
directors, and any such amendments or waivers will be promptly posted on our website at
ATImetals.com
. To date, no such amendments have been made or waivers granted.
Mandatory Employee Training
All employees are provided with a copy of the
Code of Ethics. Each year, we require all officers and managers to certify as to their understanding of and compliance with the Code of Ethics. In addition, all directors, officers and other employees must annually complete an interactive online
ethics course addressing the Code of Ethics. This course is part of ATIs broader ethics and compliance program, which includes online ethics training that is administered by a third party. In 2018, ATIs online ethics courses addressed
the protection of confidential information, the prevention of workplace violence, careful communication practices, information security threat awareness, sexual harassment and respect in the workplace, supporting human rights and insider trading.
We encourage employees to communicate concerns before they become problems. We believe that building and maintaining trust, respect and communication between
employees and management and between fellow employees is critical to the overriding goal of efficiently producing high quality products, providing the maximum level of customer satisfaction, and ultimately fueling profitability and growth.
The ATI Ethics Helpline provides confidential, secure, and anonymous reporting available 24 hours a day. Additionally, our Chief Compliance
Officer and ethics officers at our operating companies also provide confidential resources for employees to surface their concerns without fear of reprisal.