ETHICS AND COMPLIANCE

                                  Making sure we do what we say.

                                  The Alcoa Value of Integrity guides our business above all. Our company-wide Ethics and Compliance Program is the tool we use to make sure we keep that promise every day, in every decision we make.

                                  Every Alcoan, worldwide, is required to understand what it means to act with integrity, to adhere to our policies and procedures, and to comply with all applicable laws and regulations.

                                  To make this part of every Alcoan's daily work discipline, our Ethics and Compliance Program uses the following elements:

                                  Code of Conduct



                                  Global Network of Integrity Champions

                                  • Ensure that ethics and compliance are an integral part of business
                                  • Promote a culture of integrity
                                  • Raise awareness of the role of ethics
                                  • Serve as a trusted advisor and resource

                                  Anti-Corruption Program

                                  • Anti-Corruption Policy
                                  • Due Diligence and Contracting Procedure for Intermediaries
                                  • Gifts, Hospitality and Travel Procedure
                                  • Charitable Contributions Procedure
                                  • In person and web-based training
                                  • Monitoring, audit and assessment

                                  Trade Compliance Program

                                  Integrity Line

                                  • For employees, suppliers and general public
                                  • 24 hours a day, 7 days a week in 8 languages
                                  • Confidential and protected

                                  Call the Integrity Line

                                  If you have questions or concerns about something we're doing, use this confidential contact line to report it.

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