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ELGILOY SPECIALTY METALS

Code of Conduct

Code of Conduct

Our Code of Conduct

This Code of Conduct represents the commitment of Combined Metals of Chicago, LLC, its divisions, subsidiaries and affiliates, to uphold the highest standards for ethical and proper behavior, including respect for laws and people, in all that we do. The diverse group of men and women who work for Combined Metals of Chicago, LLC are our most important resource. In recognition of their contributions, we have developed policies and programs designed to ensure that our employees enjoy the protection afforded by the principles expressed in this Code. While these principles are not new to Combined Metals of Chicago, LLC, they are vitally important to what we stand for as a company. Consequently, we have chosen to summarize them here in an expression of our global commitment.

The diverse world in which Combined Metals of Chicago, LLC operates requires that a Code such as this be general in nature. Our employees, and those we do business with, are expected to abide by both the letter and the spirit of the ethical standards described in this Code. In certain situations, local requirements, collective bargaining agreements and agreements freely entered into by employees may supersede portions of this Code. Nevertheless, we believe this Code affirms important universal values that serve as the cornerstone of our relationship with our employees and our business partners, including our customers, vendors, and suppliers.

We recognize that it is not possible for any document or training program to address every situation that may arise during the course of your career with us. In any activity, action or decision, ask the following questions to help you determine whether you are doing the right thing. READ MORE

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COVID-19 Update March 20, 2020

March 20, 2020

Subject:  COVID-19 Executive Order and War Powers Act

To Our Valued Supplier,

Combined Metals of Chicago LLC (CMC) and Elgiloy Specialty Metals (ESM) continue to closely monitor the COVID-19 pandemic.

CMC/Elgiloy will continue to operate within the guidelines of the War Powers Act.  We operate several divisions as part of the “Critical Manufacturers Sector”.  We supply materials to the medical, defense, transportation, oil and gas, and agricultural industry.  For more information, please visit https://www.cisa.gov/critical-infrastructure-sectors.

We value you as a supplier and we will work hard to provide you with adequate notification for supplies we require.  Like you, we do not want disruption to the supply chain vital to our nations most critical sectors in dealing with this virus.

We have taken additional precautions to protect our employees including social distancing and thorough multiple daily cleaning operations.  We take this pandemic very seriously.  At this time and equally important is our ability to provide and deliver critical materials to all our customers.

If you have any questions regarding CMC/Elgiloy, please contact your purchasing representative. They will ensure you get answers quickly. In closing, I wish the best to you, your families, and your employees.

Respectfully,

Jim Darrow

President

CMC/Elgiloy

COVID-19 Update March 17, 2020

March 17, 2020

To Our Valued Customers;

As the novel COVID-19 virus continues to impact everyone’s lives, the Elgiloy family is taking unprecedented measures to help control its spread. We have implemented very specific procedures for cleaning office spaces and common areas, machine controls, lunchrooms and bathrooms. Our janitorial agency is in daily contact with our Safety Director on their recommendations for further curtailment. At this time, we have suspended all travel and walk-in traffic. Visitors, who meet the requirements of our questionnaire and who have been approved by the divisional manager, are still permitted entry. We have established teleconferencing for sales, management and others as needed to ensure no delays in customer service or business continuity.

We have implemented a work from home policy to reduce contact with others. We have specific procedures in place in the event that an employee has symptoms or test positive for the virus. We take our employees’ health very seriously and we are sparing no cost in dealing with this pandemic.

Our Suppliers: Elgiloy purchases the majority of its raw material from domestic suppliers. At this time, they are reporting no issues with supply. Some elements that make up the chemistry of the different grades is purchased from around the world. They are reporting they have adequate supply through September and do not anticipate a shortage.

Finished Goods: For the foreseeable future we have increased our stocking levels to deal with any impacts from suppliers, labor or an increase in demand.

Transportation: We are working closely with our freight forwarders to ensure we have uninterrupted service. We will continue to monitor this closely. Transportation is one area of concern and may lead to delays and higher rates.

Labor Force: Elgiloy has five divisions most with overlapping capabilities. There has been well-defined cross-training to ensure business continuity in the event of a natural disaster or in this case, a pandemic. We will move material or personnel around as needed to maintain operations.

Elgiloy is committed to its employees, stakeholders and most importantly our customers. Of utmost importance to us is you and your family. We are all deeply concerned about the current state of the pandemic. It affects lives in so many ways, but with us all working together we will get through this and be stronger for it.

As new information becomes available, we will update you through email, direct calling and social media.

Respectfully,

Jim Darrow

President CMC / Elgiloy / ESM