AGM questions 

As outlined in our first Climate Action report, we are committed to the Paris agreement, and yet delivering the deep reductions in carbon emissions envisaged by Paris will depend both on our ability to progress breakthrough technologies, and the policies to support their acceleration. In devising any CO2 reduction target, we need to consider both these factors.

Our European target was set on the basis of both the good technical progress of our innovation programme, and the prospects of supportive policy being introduced with the new EU Green Deal. By setting this target, we are also communicating to the European Commission the potential that the right policy can unlock.

The target was first reviewed at the European Management Committee level, and subsequently with the CEO of ArcelorMittal Europe, who is also President of the Group and a member of the CEO Office. The ARCGS committee and the full board was kept informed of the work being done and the target that was announced. There was a half day carbon review with the Appointments, Remuneration & Corporate Governance and Sustainability Committee (ARCGS) in December 2019.

We will elaborate further on our roadmap to 2030 in our forthcoming Climate Action in Europe report.

ArcelorMittal is committed to the goals of the Paris agreement and to making significant reductions in our carbon footprint. We aim to announce a groupwide target within our second Climate Action report. Inevitably the work on this has been delayed by the COVID-19 crisis, but we remain committed to this objective, and aim to publish by the end of the year.

We are actively engaged in a sector-wide conversation on the methodology to assess targets for steel companies in line with the trajectory needed to achieve net zero, since the current ‘science based target’ methodology is not workable. This dialogue is aimed at enabling the steel sector to support the achievement of the Paris objectives through a credible, well informed sectoral decarbonisation accounting methodology. There will be a multi-stakeholder consultation process, not only with investors, civil society, customers and thinktanks. We expect this initiative to make good progress on this in 2020, though the impacts of COVID-19 on all the players involved has delayed some aspects.

We see this as one of three stages in a continuum to 2050 that all need to use the same accounting methodology. a GHG performance standard for today; an SBT/net zero pathway methodology; and a net zero definition.

The achievement of the Paris agreement will not be possible without steel: steel for wind turbines, solar arrays, green hydrogen electrolysers and zero emissions mass transit systems, for example. But that steel needs to be made with substantially less carbon emissions to be in line with the Paris agreement.

The global production of steel has the potential to be compatible with the Paris agreement and indeed be net zero by 2050. Many of the technologies already exist. However, vital to realising this potential is the right policy support: the additional costs of transition are so substantial and cannot be undertaken by industry alone.

ArcelorMittal is committed to this end and is working on a wide and flexible low emissions portfolio of innovative technologies, and with other stakeholders to ask for the right policy support (see question below).

On a day to day basis, all our large capex projects are assessed for their impact on CO2 emissions. In 2019, we allocated over $700m to projects with significant impacts on energy efficiency and CO2. In the light of the COVID-19 crisis, ArcelorMittal decided to reduce its capex spend in 2020, but made the decision to retain key CO2 projects including investment in the Carbalyst (formerly Steelanol) project in Ghent, Belgium.

The level of investment needed to enable our operations to align with the Paris agreement are on a fart higher large scale, however, and remain largely commercially unviable, however. So our priority is to work to achieve a supportive policy framework that would change the business case for such investments.

With the right policies, we envisage a ‘Globally Accelerate’ scenario in which the right policies exist to support the acceleration of low carbon technologies for steelmaking across the world. Only in such a scenario can the steel sector reduce its emissions sufficiently to achieve the goals of the Paris agreement.

We outlined this as one of four scenarios in our Climate Action report 1.

We are working collaboratively and in partnership on all our breakthrough projects. Today we are working in partnership with Renewi on the conversion of waste wood for use in the blast furnace using the Torero technology; with Lanzatech and Primetals to convert waste gas into ethanol using the on Steelanol/Carbalyst process; and with others to reform gas for the blast furnace using the IGAR technology. ArcelorMIttal is also a member of the Northern Lights consortium in order to try to move CCS demonstration projects ahead in 2021, with a pilot to capture CO2 from our Dunkirk steel plant.

For hydrogen, we are currently evaluating business models for the green or blue hydrogen routes with a several interested suppliers of renewable energy, electrolysers, and industrial gas, with an initial scale of 100MW. The key challenge is cost: to be competitive the hydrogen cost should be in the range of 0.6-0.8 USD/kg - where currently the costs are between five and ten times higher.

Given the range of technologies we are working on, the potential for partnership is extensive and we are actively exploring further collaborations relating to CO2 and hydrogen. In Q1 we held four technology days with large suppliers of industrial gas to explore ideas.

We are open to aligning remuneration with those aspects that are within our control, Already, those in charge of delivering on specific aspects of our climate action programme are incentivised through the balanced scorecard that generates their annual performance targets. This includes certain R&D, Innovation, and energy teams on the achievement of their climate-related projects, and for the European target, site management relating to performance, and our government affairs team relating to supportive European policy. However, we cannot expect our people to deliver on all the external factors that are not within their control, so we do not have incentives linked to the achievement of the entire target itself.

For the CEO office, senior management and across the board, it should also be noted that there are universal performance targets within remuneration plans that are based on financial performance. In Europe, these indirectly incentivise CO2 reduction, since achievement of our CO2 target will reduce EU ETS costs for our European business, and so contribute to financial performance.

Once we have set our global target, we will also consider how to create further alignment of remuneration incentives.

With regards the role of the ARCGS committee of the board on remuneration, its primary function is to assist the board of directors and, in particular, without being exhaustive to:

• Review and approve corporate goals and objectives relevant to the executive officers and senior management’s compensation, and evaluate performance in light of these goals;

• Make recommendations to the board with respect to incentive compensation plans and equity-based plans;

• Make recommendations to the board on the company’s framework of remuneration for the executive officers and such other members of the executive management as designated by the committee to consider.

• Review the company’s sustainable development plan and associated management systems and ensure the group is well positioned to meet the evolving expectations of stakeholders, including investors, customers, regulators, employees and communities.

Our policy priorities are outlined in our Climate Action report 1, which we published last year. The cornerstone of these is a carbon border adjustment for Europe, to create a level playing field between steel made outside the EU and steel made within the EU, and so drive the decarbonisation of both. To further this objective we are working with other European steel companies through Eurofer, and engaging with other interested stakeholders of the steel industry, such as the Energy Transition Commission (of which we are members) and the Institutional Investor Group on Climate Change. Even in the context of a post-covid recovery stimulus, a carbon border adjustment remains our key priority.

Also vital to our transition is funding. The additional costs of new technologies are very high, so we are encouraging the European Commission both to enhance several funding streams for technology innovation, and to enable a Contract for Difference mechanism to compensate steelmakers for the higher structural costs of rolling out low carbon steelmaking technologies.

At the same time, we are also working with other steel sector stakeholders to create a workable methodology for measuring a company’s emissions in relation to their target and trajectory towards carbon neutral steelmaking.

Another aspect is the need for the market to support low carbon steel. The Climate Group and ResponsibleSteel, of which ArcelorMittal is a founder member, have recently formed Steel Zero - a dialogue between customers of steel - to design such a mechanism.

We have recently published our preliminary report on the climate-related policy positions of ArcelorMittal’s membership associations on our website. Please see this page.

Our mapping of those associations of which we are a member has shown us that almost all are aligned or neutral on the policy areas of priority for ArcelorMittal. Where organisations are aligned with us and bring us high levels of value, we tend to already be collaborating on climate-related policy issues, and we will continue this. NB we see a particularly high degree of alignment amongst European organisations, where we are most active on climate policy.

We will continue to collaborate with those organisations in Europe with whom we are aligned on climate policy to drive the support frameworks we need to enable the steel sector’s transition. And in publishing the report we will be signalling to our membership organisations marked as ‘neutral’ that we anticipate greater clarity in their disclosures of their policy positions.

Our government affairs network were central to this mapping exercise and will be involved in a periodic review, with oversight from our group climate change committee, and the sustainability committee of the board of directors, to ensure our memberships are increasingly aligned with our climate related policy positions.

The methods for assessing financial risk from climate related events are in their infancy, and ArcelorMittal is on a journey to develop its own models to understand and provide fair assessments of medium- and long-term risk. We estimate the financial risk arising from the increasing probability of different physical impacts of climate change in different regions in the medium term (to 2030), by using an in-house financial model, management assumptions, internal intelligence, and available literature. The combined financial value of these risks over the next ten years has not been considered high and is disclosed in our CDP climate survey response each year, along with calculation methodologies, processes and estimated costs of managing these risks.

Climate-related acute and chronic physical risks are assessed internally, through statistical models simulating more frequent, more acute and chronic extreme weather events happening to our plants and supply chains globally. The models provide estimations of expected cumulated production losses to 2030 based on today's risk profile and most current internal perception of what the future can be under different global warming temperature scenarios.

Findings are reviewed by the head of finance, and members of the climate change and environment committee, chaired by the Executive Officer responsible for climate change.

Our sites have very variable exposure to biodiversity. Our more sensitive sites are linked with our mining operations. Our mine in Liberia sits close to important rainforests in the Nimba mountains, so we have developed biodiversity plans that were created with the help of local and international partners, and we have reported on this in detail in the past, and you can see the most recent case study here. Given the complexity of these ecosystems and our operations, giving of simple list of the top 5 impacts is not straight forward. At our mines, our focus will be waterways, habitat protection in general and special measures for endangered species. For steelmaking, again water protection is key but often steel sites can have areas of unused land that in many cases become high quality nature reserves. We are now working with international standard setters to agree with stakeholders the standards both our mines and steelmaking sites should work to. The ResponsibleSteel standard has requirements on biodiversity, and the mining certification schemes TSM and IRMA both have detailed standards on biodiversity. For more on these schemes, please see below.

ArcelorMittal played a leading role in developing ResponsibleSteel™ in 2015. ResponsibleSteel™ is the steel industry’s only global multi-stakeholder certification initiative with has 70 members including steel producers, mining companies, NGOs, steel-consuming customers, financial institutions, and industry bodies. It enables steel producers to prove their production processes and products meet rigorously defined standards across a broad range of social, environmental and ethical criteria. It also improves responsible sourcing of the raw materials used in steelmaking and aims to reduce supply-chain risk. In November 2019, following a robust accreditation process, ResponsibleSteel™ launched its first site certification standard. The standard presents 12 principles underpinned by over 50 criteria and over 200 auditable requirements, addressing: health and safety, human rights, local communities, biodiversity and GHG among other sustainability and assurance issues.

Out timeline for achieving site-based certification started last year. ArcelorMittal has carried out readiness assessments against the ResponsibleSteel™ site standard across nearly all its European flat products production sites, and at sites in the U.S. and Brazil, with positive results. It is currently working on a site assessment and verification plan and, before Covid19, was on track to seek certification for its European Flat sites this year. Naturally Covid-19 slowed down progress but our commitment remains solid.

ArcelorMittal also plays a leading role in the wider movement towards establishing social and environmental standards for mining that stakeholders recognize and value. As a member of the IRMA (the Initiative for Responsible Mining Assurance) steering committee, ArcelorMittal participates in the multi-stakeholder expert panels shaping its standards. We have already achieved Mining Association of Canada’s Towards Sustainable Mining initiative at its mines in Canada and are intending to seek IRMA for other marketable mines. We have also started dialogue with our key mined raw material suppliers to understand and seek their commitment to certification.

We are very aware of the impacts that the coronavirus crisis is having on both our customers and our suppliers. For existing contracts with suppliers that pre-date the crisis, there have been no changes to our corporate payment terms and we aim to honour these as per business as usual. New contracts, meanwhile, are generally subject to additional levels of scrutiny before approval in order to protect cash flow given the current economic climate.

In 2019, ArcelorMittal formulated its core purpose: inventing smarter steels for a better world. Linked to this, we also launched our new Employee Value Proposition and with it our employer promise ‘Make your world’. Together, these communicate the values, culture and unique set of benefits ArcelorMittal offers to its employees in return for their skills, capabilities and experience, in order to pursue our core purpose.

We are committed to attracting and supporting diverse talent globally. As our business evolves, we have a growing requirement for new talent and skillsets, especially regarding new and digital technologies. To be competitive in these new fields, we need to ensure that we are continuing to access and support the full range of available talent – irrespective of gender, culture, ethnicity, or social and country background.

You can read more about our diversity, leadership development and STEM education programmes in our 2019 Integrated Annual Review: Building a workplace for tomorrow, pg 60-63.

At ArcelorMittal we pay competitive wages. the nature of our workforce means we need to attract skilled talent and to attract the best talent, we must pay competitively. The vast majority of our sites are unionized, leading us to engage in regular and continuous dialogue, regarding wages as well as other working conditions.

Strictly speaking, ArcelorMittal does not have a “living wage” policy but we are following the development of this relatively new concept and language of “living wage”. We understand that while certain countries have adopted the “living wage” concept and are currently translating this into law, not all countries are at this same stage which makes application complex.

Similarly, the ResponsibleSteel site certification standard, developed through a multistakeholder process and launched in 2019 (Criterion 4.8) requires the site to “pay at least the applicable legal minimum wage to all workers or the wage set through a collective agreement, whichever is higher. Where there is no legal minimum wage and no collective agreement, the site pays the prevailing industry standard”.

Most of our operations are in middle and high-income countries, where salaries are set at levels that would cover a reasonable cost of living, in liaison with our social partners. One country where we have taken additional measures is Venezuela, where we were sensitive to the economic situation causing hyperinflation and resulting in the cost of living exceeding normal wages. ArcelorMittal looked to support our employees in this difficult situation and issued special payments to employees that allowed them to purchase basic goods such as food, medicine, school uniforms and hygiene products.

For our supply chain, we take a proactive approach to identifying social and environmental risks. We are currently focusing our attention on our raw materials supply chain and assessing where the most likely risks to people and the environment could be. This will inform the areas of the supply chain we engage more closely with on such topics. This also supports our commitment to oppose the use of forced or compulsory labour, human trafficking and all forms of human rights violations known as ‘modern slavery’, within our own operations and through our supply chain.

Several of ArcelorMittal’s policies, including our human rights policy and code for responsible sourcing, promote fair wages and compensation and we will monitor how the “living wage” concept supports this further.

The ARCGS committee on behalf of the board of directors is continuously looking at the full scope of the remuneration policy and its alignment with the legal requirements and prevailing standards.

Employees benefit from performance bonuses which are usually based on balanced scorecards which normally includes social and environmental aspects, including Health & Safety. For the CEO office, 10% of the annual performance bonus formula is based on the achievement of group health and safety targets.

Fund options offered to employees for their pensions are decided upon at country level and we do not track these at corporate level. However in many countries we are aware that ESG fund options are available as part of a range of pension investment options.

Inclusion is about creating a work environment where everyone has the opportunity to fully participate in creating business success and where all employees are valued and respected for their distinctive skills, experiences and perspectives.

Employee engagement is key, and feedback is integrated into action plans, to address employees’ concerns. Every two years, a company-wide engagement survey gauges employees’ opinions, attitudes and levels of satisfaction. This ‘SpeakUp!’ survey seeks feedback in a range of areas, including organizational direction, leadership and professional deployment and development. It allows employees to relay feedback anonymously to the executive leadership and the Company to build specific action plans to address employee’s concerns. The Speak Up! survey took place in 2019. More than 33,000 employees were invited to anonymously give their feedback and honest opinion. The survey showed a global favourability rate at 70%, stable compared to the 2017 results. Concrete action plans to address employees’ concerns identified in 2019 survey have been put in place at all levels of the organization and are regularly followed-up on to ensure implementation of the improvement initiatives.

We aim to operate grievance mechanisms at each site that operate according to our internal guidelines. These enable any stakeholder, whether a contractor, employee or community member, to raise complaints about the behaviour of the company. We are working to strengthen the internal reporting from such mechanisms in order to detect any persistent issues that contradict any aspect of our policies, including diversity and inclusion. Our pursuit of ResponsibleSteel site certification via third party auditors will ensure that these systems are reviewed.

In ArcelorMittal we are convinced that the diversity of our workforce is an asset, bringing fresh ideas, perspectives and experiences in a welcoming environment which supports our values of Leadership, Sustainability and Quality. For ArcelorMittal, diversity means a workforce reflective of different cultures, generations, genders, ethnic groups, nationalities, abilities, social backgrounds and all the other unique differences that make each of us individuals.

For ArcelorMittal, and the steel sector as a whole, gender is one aspect of diversity that has been particularly challenging to improve. We introduced a target to ensure women made up 33% of our Board of Directors, and achieved this in 2015. We are now pursuing greater female participation across the organisation, and track and report the following gender diversity KPIs:

• Women in management positions (manager & above positions): % of Managers and above positions where women are currently in the role;

• Women on key positions succession plans (general managers and above positions): % of women amongst all potential successors for General Managers and above positions.

• Women recruited (exempt population): % of women recruited externally;

We also make great efforts to broaden the participation of children, particuarly girls, in the science/technology/engineering/maths subjects with an extensive programme of STEM initiatives with schools and universities across the world.

The remuneration committee on behalf of the board of directors is continuously looking at the full scope of the remuneration policy and its alignment with the legal requirement and prevailing standards.

In order to improve gender diversity across ArcelorMittal, we have outlined our approve above.

ArcelorMittal is a company with industrial footprint in more than 18 countries. In each country the Company is present, it contributes economically to the society by paying taxes on the extracted resources, assets owned, people employed, or profits made, always maintaining the highest standards of compliance with local regulations.

On an annual basis we report on our 10 Sustainable Development outcomes including the “Contribution to society measured, shared and valued”, where we quantify our consolidated tax contribution to the societies. It is part of our wider approach to reporting at a global and local level, supported by reports that provide details on specific areas of our work or are designed for the use of specific stakeholder groups. We seek to follow best practice in reporting. We draw on the standards of the Global Reporting Initiative and the Sustainability Standards Accounting Board, as well as industry guidelines from the World Steel Association. In addition, during 2019 we published 16 country-level corporate responsibility/sustainability reports.

The Group also reports its tax payments in the consolidated report on payments to governments with respect to its extractive activities in accordance with the European Union ‘transparency’ directives, which is available in our Reports and policies section.

The Group already contributes to the development of tax transparency by engaging with respected platforms and initiatives. For example, we support the Extractive Industry Transparency Initiative (EITI), since we believe that this initiative will strengthen governance, foster socio-economic development and help the overall business climate to become more open, fair and competitive.

At the same time, the Company recognizes that the reporting on the geographical distribution of an organization’s financial, economic and tax data, should be a global, mandatory requirement, providing an equal, unbiased footprint for economic competitiveness across different geographies it operates in.

We consult with all our key stakeholder groups throughout the year, and any material topics for the ArcelorMittal group are reported in the Integrated Annual Review. Material issues at country level are reported in our country sustainability reports.

The AGM 2020 format follows Luxembourg emergency legislation in the context of COVID-19. As remote and virtual meetings are not normally allowed under Luxembourg law, no infrastructure is in place. As the emergency legislation expires in September 2020 is this a one-off procedure.

Taking into account that ArcelorMittal shares are listed on eight separate stock exchanges, this leads to complexity and the infrastructure to allow for digital meetings in this context does not currently exist.

In 2021 the COVID-19 emergency legislation will have expired. The default position is a physical meeting at the Company’s offices in May 2021. We are reviewing possibilities to organize a hybrid meeting in the future. Current legislation will require a physical meeting and in even in a hybrid meeting, the process would follow the physical meeting closely because of these constraints.

ArcelorMittal has not engaged in “pro-cyclical M&A” over the last years. On the contrary the Company’s acquisition strategy can be described as “counter-cyclical”. For example, the agreements to acquire ILVA and Votorantim were made at low points in the steel cycles of Europe and Brazil, respectively. The acquisition of ESIL (Essar Steel India Limited), in partnership with Nippon Steel, was the culmination of a long-term strategic objective to enter the high-growth Indian steel market. The timing of this acquisition was determined by the IBC (Indian Insolvency and Bankruptcy Code) process.

Regarding CapEx-spending, ArcelorMittal continues to demonstrate flexibility in its CapEx plans to achieve its strategic objectives. When the operating environment dictates, the Group reduces CapEx, including some investment deferrals, in order to optimize the business' cash needs.

In the case of ILVA, the Company negotiated the deal during a relatively weak point in the European steel cycle. The acquisition cost on a per-tonne basis was appropriate, and the transaction was structured to include a significant deferral of the acquisition price.

The acquisition of Votorantim was in the form of a merger. It involved no up-front cash, but instead an agreed put-option to the seller with a valuation based on the future performance of the business.

For ESIL, the timing of this acquisition, made in partnership with Nippon Steel, was driven by the IBC (The Indian Insolvency and Bankruptcy Code) process. Valuation of the asset compares well to replacement cost or the cost to build a similar business on a greenfield basis.

The Group employs a disciplined and consistent approach to investments, applying a stringent risk-adjusted return model. The Company has not concluded any M&A process without expecting it to achieve an appropriate rate of return.

The Company has appropriately adapted its CapEx investment plans in light of the impacts of the COVID-19 pandemic on the operating environment.

The priority for CapEx in this environment is the appropriate maintenance of the Company’s operating assets and protecting its strategic investment options. All non-essential CapEx is on hold, while the Mexico hot strip mill project, agreed spend on Italian investments, and certain CO2 emissions reduction projects continue.

Current CapEx levels are not reflective of a normalized environment, when a level more in line with depreciation would be appropriate to maintain the Company’s future earnings capacity.

On March 4, 2020, ArcelorMittal announced that AM InvestCo and the Ilva Commissioners had signed an amendment (the ‘Amendment Agreement’) to the original lease and purchase agreement for Ilva. The Amendment Agreement outlines the terms for a significant investment by Italian state-sponsored entities into AM InvestCo, thereby forming the basis for an important new partnership between ArcelorMittal and the Italian government. The equity investment by the Italian Government in Ilva, to be captured in an agreement (the ‘Investment Agreement’) to be executed by November 30, 2020, will be equal to AM InvestCo’s remaining liabilities against the original purchase price for Ilva. The Amendment Agreement is structured around a new industrial plan for Ilva, which involves investment in lower-carbon steelmaking technologies. In the event that the Investment Agreement is not executed by November 30, 2020, AM InvestCo has a withdrawal right, subject to an agreed payment. Final closing of the lease and purchase agreement is now scheduled by May 2022, subject to various conditions precedent.

As mentioned in the question above, the Company continues with the investment projects it has previously committed to in Italy.

Regarding management resources, ArcelorMittal’s Italian business has a highly capable CEO in place to lead the negotiations, with support from the ArcelorMittal Corporate Office, and manage the day to day operations and turnaround strategy.

The asset portfolio optimization plan, as announced with 2Q 2019 results, seeks to unlock $2 billion of value from the asset portfolio by mid-2021. The Company has made good progress to date, including the sale of the remaining Gerdau stake ($0.1 billion) and a 50% interest in the shipping business ($0.5 billion net debt impact). Despite the challenges caused by COVID-19, the program continues to progress. With suitable and viable buyers having expressed definitive interest in certain assets, the Company remains confident in completing the program as expected by Mid-2021.

The capital increase fortifies the ArcelorMittal balance sheet and complements the significant actions already taken to minimize the impacts of the COVID-19 pandemic on profitability and cash flows. The Company now has the capital structure and liquidity position to navigate this crisis environment with certainty regardless of its potential duration. The capital increase accelerates the achievement of the $7 billion net debt target, which, when the operating environment normalizes, will lead to the Company returning a proportion of free cash flow annually to its shareholders.

That is not correct, ArcelorMittal’s decision to issue additional equity capital was taken to fortify its balance sheet and augment its liquidity position. The additional capital led to a proportionate cancellation of commitments under its credit facility.

The Company has taken the appropriate actions to strengthen and protect its balance sheet. The capital increases referenced need to consider the circa $25 billion net debt reduction that has been achieved over the period referenced.

ArcelorMittal believes that a net debt of $7bn is the right level for the Company considering the cyclicality of its business, supporting appropriately conservative leverage ratios and interest coverage, and investment credit metrics through the cycle. Assuming economies recover from the impacts of COVID-19, then the Company expects profitability to move back into its previous cyclical range.

The capital issuance has accelerated the attainment of the Company's $7bn net debt target. As part of the 1Q'20 results published 5th May, the Company updated its Capital Allocation policy (slide 15). This policy reflects the intention to return a proportion of free cash flow annually once the net debt target is achieved.

The 2019 annual report included a mandatory impairment test of goodwill (as prescribed by IFRS). Going forward, at each reporting date, the Company assesses indicators of impairment of property, plant and equipment. As indicated in footnote 12 of the 1Q'20 earnings release, the Company considered the impact of the COVID-19 outbreak as an impairment indicator as of 1Q'20 for its main steel operations. Accordingly, it updated future cash flow projections to reflect latest forecasts available for 2Q'20 and 3Q'20 and, as a result, concluded that no impairment charge was required as of March 31, 2020.

Please see above

ArcelorMittal reported its most recent results on May 5, 2020. Had it been necessary under IFRS accounting standards then the Company would have taken the appropriate charges at that time.

The Company’s assets are well invested and competitive in both a regional and global context. The question of permanent closures will be dictated by the extent to which COVID-19 impacts the medium-term demand for steel in the Company’s core markets. At this stage, it is too early to draw any conclusions in this regard.