RESILIENT WORKPLACE

Integrity, Ethics & Compliance

Integrity is more than a priority at Schnitzer—it is one of our Core Values. Working with integrity compels us to do the right thing even when no one is watching, or when it would be more convenient or advantageous to take another approach.

Our Core Value of Integrity underscores our commitment to operating from an ethics-based approach, which is why our program goes beyond ensuring compliance with the law to establishing and maintaining the framework for how we treat one another and our stakeholders. By integrating ethically sound behaviors, we establish an expectation of personal and organizational responsibility and build trust.

Maintaining a positive workplace and conducting business according to our Core Values requires a common set of ethical rules, which we present in our Code of Conduct. We recently refreshed and updated the Code to improve readability and accessibility, and to upgrade the content to further communicate the ways our shared values are reflected in our ethical standards and expectations for how we operate every day. We also have a Supplier Code of Conduct to communicate ethical guidelines and establish parameters governing our relationships with those in our supply chain. Our Codes drive our culture of compliance, ethical decision-making, and accountability.

As a business that engages in commercial transactions throughout the world, we have a responsibility to respect human rights everywhere we operate. Schnitzer’s Human Rights Policy reinforces our commitment to upholding the internationally recognized human rights as set forth in the United Nations’ Universal Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

Ethics Program

Schnitzer has an independent Ethics and Compliance function, governed by a charter. Our Chief Ethics and Compliance Officer, who reports to the CEO and also to the Board of Directors through its Audit Committee, leads this function. Schnitzer’s Ethics and Compliance Program promotes the Code of Conduct, communicates and educates employees on the importance of making ethical decisions, and helps foster an environment where employees feel comfortable reporting concerns.

Across our workforce, 23 percent of employees belong to unions. All Schnitzer employees, both union and non-union, participate in annual training on our Company’s Core Values, which includes instruction on our Code of Conduct and ethical behavior. The training includes deep dives on important topics such as reporting misconduct, our prohibition against retaliation, unconscious bias, and diversity and inclusion. Because of the COVID-19 pandemic, we revised our fiscal 2020 training plan to align with the evolving situation, opting for streamlined courses complete with employee-provided videos.

Schnitzer’s employee community is rich in diversity and full of talented people with varied backgrounds and experiences, many of whom speak multiple languages. An ongoing emphasis of our Ethics and Compliance Program is ensuring that communications are inclusive and accessible to all. To this end, we make training content available in both English and Spanish, offer it in both written and audio formats, and produce communications such as posters and flyers to convey bilingual messages clearly.

We empower employees to raise issues and concerns regarding compliance with our Code of Conduct and the law by offering multiple reporting channels, including a third-party, confidential, multi-lingual hotline, where employees may choose to remain anonymous. No matter how employees choose to report concerns, we ensure all reports are promptly investigated.

Anticorruption Program

An essential part of operating ethically is ensuring that we follow anticorruption and antibribery laws and regulations. We scrutinize all our operations for corruption risks and constantly evolve our program to address those risks. In addition to our Code of Conduct, we have a comprehensive Anticorruption Policy available to all employees that details prohibitions against bribery, money laundering, and engaging with terrorists or other sanctioned entities. The policy prohibits facilitation payments and also requires that Schnitzer maintain accurate books and records.

Our Anticorruption Handbook, Anticorruption Internal Controls, and other reference guides help employees understand these prohibitions and requirements and, for those whose job functions are critical to our Anticorruption Program, specifies roles and responsibilities in order to create accountability. Our International Anticorruption Council, chaired by the Chief Ethics and Compliance Officer and comprising senior leaders in operations, finance, legal, sales, procurement, IT, and internal audit, monitors the execution of Schnitzer’s Anticorruption Program and promotes it within the organization.

Global Recognition

2020 was the sixth consecutive year in which Schnitzer was named one of the World’s Most Ethical Companies® by the Ethisphere Institute.* This prestigious award is given to companies that foster a culture of ethics and transparency at every level of the Company. Specifically, winners must demonstrate leadership in five key categories: ethics and compliance; environmental and societal impacts; culture of ethics; governance; and leadership and reputation.

Through the annual process of applying for this award and analyzing our scores across all categories, we gain significant insight into current best practices and can plan and implement improvements to our Company-wide communications and training programs accordingly across all departments and functions.

*“World’s Most Ethical Companies” and “Ethisphere” names and marks are registered trademarks of Ethisphere LLC.

Ethics in Action Award

Behaving ethically requires courage and a commitment to doing what’s right. Schnitzer’s Ethics in Action award program recognizes employees who demonstrate ethical behavior in general or specific instances of ethical deeds. Recent honorees were celebrated for attributes like consistent ethical leadership, willingness to speak up and alert others to a potential hazard, and going above and beyond normal duties to help out another facility that was facing a staffing shortage. Employees can nominate their colleagues year-round using an online portal.