AC T I N G W I T H I N T E G R I T Y 9 TRADE PRACTICES Antitrust and competition laws protect free enterprise. Reliance is committed to free and fair competition and complying with all applicable antitrust laws. YOUR RESPONSIBILITIES • It is your responsibility to be aware of the anti-trust laws and their implications, including how they apply in the countries in which you do business. While these laws are often complex and difficult to summarize, at a basic level they prohibit agreements between Reliance and our competitors that affect prices, terms or conditions of sale or fair competition. • Use care in your relations with competitors. You might interact with competitors through industry meetings, conferences, and other events. When you do, be careful not to make inappropriate agreements. Never engage in practices such as price fixing, customer or market allocation, or bid rigging. • Trade association meetings and other industry gatherings can pose certain risks, as they bring together competitors who might discuss matters of mutual concern and potentially cross the line of non-compliance with competition laws. Even joking about inappropriate topics, such as marketing or pricing strategies, could be misinterpreted and misreported. If any kind of anti-competitive discussion arises, you should refuse to discuss the matter and leave the conversation immediately. • No employee may share any sensitive Reliance business information (prices, costs, margins, research and development efforts, strategic plans, etc.) with any third party, including actual or potential competitors. • Employees will consult with the General Counsel before making any joint bids with competitors. • If any inappropriate or illegal competition or antitrust conduct is detected or suspected of any employee or anyone doing business with the Company, such activities should be reported in accordance with Section 16 of this Code (see below). No employee may share any sensitive Reliance business information with any third party, including actual or potential competitors. INTERNATIONAL TRADE LAWS We abide by the trade laws of all countries in which we operate, including economic sanctions and import and export laws. Most countries in which Reliance operates impose restrictions on the movement of products across borders. YOUR RESPONSIBILITIES • Trade sanctions, including financial sanctions, are complex. If you are involved in international transactions, such as business dealings with a sanctioned country, entity, or person, you must ensure compliance with applicable trade laws. • Products intended for import or export, including equipment, software, and technology, must be classified in advance and all required labelling, documentation, licenses and approvals must be completed. • Any questions about export regulations should be addressed to your local export compliance manager or Erick Wallace, Reliance’s Corporate Export Compliance Manager (email: ewallace@rsac.com or telephone: 253-732-8119). 8 9