AC T I N G W I T H I N T E G R I T Y 3 • Do not facilitate a conflict with one of our suppliers, service providers, customers, or any government official, for example, by making a payment to an individual when you know the funds should go to his or her employer. DISCLOSING AND ADDRESSING POTENTIAL CONFLICTS OF INTEREST Reliance requires that you disclose, in writing, any personal, business, or other relationship that might constitute a conflict of interest or could potentially create a conflict of interest. Our policy is one of disclosure and review of potential conflicts and prohibition of actual conflicts of interest. In some cases, disclosure may be all that is required. In other cases, however, the facts may require additional action(s) to correct or avoid a conflict of interest. Some matters may require periodic monitoring by local management to ensure transactions remain at arm’s length. In all cases, however, you MUST disclose all actual and potential conflicts of interest. Below we have listed certain activities and interests that present conflicts of interest or potential conflicts of interest that would have to be disclosed. This list is not exhaustive, and you must also disclose any other personal interests that may give rise to a conflict of interest. Because it is impossible to describe every possible conflict of interest, Reliance relies on your good judgment to seek advice when appropriate and to adhere to high ethical standards in the conduct of your professional and personal affairs. FINANCIAL CONFLICTS OF INTEREST • Having a financial or management interest (as an employee, officer, or director) in any customer, supplier, service provider, competitor, or any enterprise that you know or reasonably believe has or may have a business relationship with Reliance. A financial interest need not be disclosed if it involves less than 1% of the stock of a publicly held company, unless it constitutes a significant portion of your net worth. • Engaging in business with, or as a customer, service provider, or supplier of, Reliance, other than in the ordinary course, as an employee or a public consumer. • Competing with Reliance. • Maintaining concurrent employment with Reliance and with any other organization. EXAMPLE DISCLOSURE REQUIRED? I... All of these situations would require disclosure. A personal business, part-time job, or director position for another company may interfere with an employee’s duties to Reliance. We need to conduct a conflict of interest review to be sure your business, part-time job, or directorship position does not involve a competitor, supplier, service provider, or customer or otherwise create issues of concern. If there are no issues, or if any concerns can be effectively addressed, this would likely be approved. ...have (or am starting) my own business ...want to take a part-time job ...have been asked to serve as a director on the board of another company AC T I N G W I T H I N T E G R I T Y 1