Code of Conduct | Professional Standards & Ethics

1. Independence Policy

Complete Freedom from Commercial Conflicts: We maintain absolute independence from organisations that could compromise our analytical objectivity. This independence enables us to provide unbiased advice to governments, investors, and legal proceedings.

We Have No Ties To:

• Steel producers and steelmakers – No ownership interests, board positions, or consulting retainers with steel manufacturing companies.
• Steel trading companies and distributors – No commercial relationships with steel traders or service centres.
• Raw material suppliers – No affiliations with iron ore miners, coal producers, or scrap metal suppliers.
• Equipment manufacturers and technology suppliers – No ties to steelmaking equipment vendors or technology providers.
• Banking and financial institutions – No investments or partnerships with institutions having steel sector exposure.
• Industry associations with member interests – No memberships that could create conflicts with specific steel producers.

Why Independence Matters:

Our freedom from commercial conflicts enables us to:

• Provide objective government policy advice without producer bias.
• Conduct unbiased due diligence for investment decisions.
• Offer credible expert witness testimony in legal proceedings.
• Perform comprehensive competitive intelligence without restrictions.
• Deliver analysis that serves only our clients' interests.

2. Confidentiality & Information Security

Protecting Client Information: All client information is treated as strictly confidential unless explicitly authorised for disclosure. We maintain rigorous protocols to protect sensitive commercial, technical, and strategic information.

What We Never Disclose:

• Project details and outcomes – Strategic advice and recommendations remain confidential.
• Proprietary data and analysis – Cost structures, competitive positions, investment plans.
• Commercial negotiations – M&A discussions, pricing strategies, contract terms.
• Technical information – Process details, operational data, plant performance metrics.
• Strategic insights – Market intelligence, expansion plans, technology assessments.

Information Security Measures:

• Consulting files maintained separately from public content with secure access controls.
• Non-disclosure agreements executed before confidential discussions commence.
• Secure Italian data centre hosting with SSL/TLS encryption (see Security page).
• Automated regular backups to protect historical client data.
• 25-year operational history with zero security breaches.

3. Conflict of Interest Management

Systematic Conflict Screening: We screen all potential engagements for conflicts of interest before accepting work. Where conflicts exist, we either decline the engagement or implement appropriate safeguards.

Conflict Identification Process:

1. Initial Assessment – Review proposed scope against existing client relationships and prior work.
2. Geographic & Sectoral Review – Identify potential conflicts in same markets or product segments.
3. Competitive Sensitivity Check – Assess whether engagement involves direct competitors.
4. Disclosure to Client – Full transparency about any potential conflicts identified.
5. Mitigation or Declination – Implement Chinese walls or respectfully decline the engagement.

When We Decline Work:

• Engagements that would compromise objectivity in existing client relationships.
• Projects requiring us to take advocacy positions contrary to our independent analysis.
• Work where our prior knowledge creates unfair advantage or competitive harm.
• Assignments that would undermine credibility for future expert witness testimony.

4. Professional Competence & Quality

Delivering Expert Analysis: We commit to providing services only in areas where we possess appropriate expertise, experience, and knowledge. Our work meets professional standards expected of senior industry consultants.

Quality Assurance Framework:

• Expertise Matching – Assignments undertaken only where team possesses requisite technical knowledge.
• Methodology Transparency – Clear documentation of research approaches, data sources, and analytical methods (see Methodology page)
• Editorial Independence – Our news aggregation operates under a formal Editorial Policy that separates commercial and editorial functions and documents our source attribution standards.
• Peer Review – Critical review of complex analysis by senior consultants before client delivery.
• Data Verification – Cross-referencing information against multiple authoritative sources.
• Continuous Learning – Ongoing professional development through industry engagement and project work.
• Quality Documentation – Comprehensive records enabling audit trail and knowledge retention.

Technical Expertise Spans:

• Ironmaking & Steelmaking – Blast furnace, BOF, EAF, induction furnaces, continuous casting processes.
• Rolling & Finishing – Hot strip mills, plate mills, bar mills, coating operations.
• Raw Materials – Iron ore, coking coal, scrap metal, alloys, and refractories.
• Market Analysis – Supply/demand forecasting, competitive positioning, trade flow analysis.
• Distribution – Optimisation of routes to market.
• Economics & Finance – Cost modelling, investment appraisal, valuation methodologies.
• Strategic Planning – Restructuring, capacity optimisation, modernisation programmes.

5. Expert Witness Standards

Duty to the Court: When providing expert witness services, our overriding duty is to the court or tribunal rather than to the instructing party. We maintain the highest standards of objectivity and independence required for legal testimony.

Expert Witness Protocols:

• Duty to Court Paramount – Obligation to assist court supersedes duty to client.
• Civil Procedure Rules Compliance – Full adherence to CPR Part 35 (England & Wales) and equivalent jurisdictional requirements.
• Independence from Outcome – No financial interest in litigation result; fees never contingent on verdict.
• Evidence-Based Opinions – All conclusions supported by documented facts, data, and methodology.
• Balanced Presentation – Fair representation of contrary views and uncertainties in analysis.
• Scope Limitations – Clear statement of areas outside expertise or available evidence.
• Transparency of Assumptions – Full disclosure of key assumptions underlying opinions.

Areas of Expert Testimony:

• Steel market conditions and competitive dynamics.
• Product quality including compliance with standards.
• Plant valuation and asset assessment.
• Feasibility of proposed projects or investments.
• Industry standards and best practices.
• Economic damages and lost profits.
• Technical causation in plant design and / or operational failures.

For detailed information about our expert witness credentials and experience, please visit SteelExpertWitness.com or review our Expert Consultants page.

6. Accuracy, Honesty & Transparency

Truthful Representation: We commit to honesty in all professional communications—in the services we offer, the knowledge we claim, and the experience we present.

Our Commitments:

• Accurate Credentials – Truthful representation of qualifications, experience, and project history.
• Honest Capabilities – Clear communication about what we can and cannot deliver.
• Data Integrity – Careful sourcing, verification, and attribution of information.
• Limitation Disclosure – Transparent about data gaps, assumptions, and analytical constraints.
• Error Correction – Prompt acknowledgment and correction of mistakes identified.
• Methodology Transparency – Documentation of research approaches and data sources.

What We Do Not Do:

• Overstate our capabilities or experience to win work.
• Guarantee outcomes beyond our control.
• Misrepresent data sources or analytical rigour.
• Claim expertise in areas where we lack substantive experience.
• Hide uncertainties or limitations in our analysis.

7. Fair Dealing & Respect

Professional Conduct: We treat all parties - clients, competitors, suppliers, and industry participants - with courtesy, fairness, and respect. We compete on merit rather than through disparagement or unfair practices.

Our Approach:

• Respectful Competition – We compete based on expertise and service quality, not through denigration of competitors.
• Fair Pricing – Transparent fee structures and honest discussions about costs before engagement.
• Intellectual Property Respect – We honour others' proprietary methodologies, databases, and research.
• Attribution Standards – Proper credit given when using others' data, analysis, or concepts.
• Professional Courtesy – Respectful engagement with all industry participants regardless of commercial relationship.

Prohibited Practices:

• Making false or misleading statements about competitors.
• Obtaining competitors' confidential information through improper means.
• Misappropriating proprietary methodologies or databases.
• Soliciting another firm's employees for the purpose of harming that firm.
• Using client relationships to unfairly disadvantage competitors.

8. Legal & Regulatory Compliance

Adherence to Law: We comply with all applicable laws, regulations, and professional standards in every jurisdiction where we operate. Our work spans multiple countries with varying legal frameworks.

Key Compliance Areas:

9. Social & Environmental Responsibility

Responsible Advisory: We consider the broader social and environmental implications of our work, particularly when advising on steel sector restructuring, plant closures, or major investment decisions.

Our Commitments:

• Just Transition Considerations – When advising on restructuring, we consider employment impacts and community effects.
• Environmental Impact Assessment – Analysis where possible of emissions, resource efficiency, and environmental compliance in feasibility studies.
• Green Steel Expertise – Supporting clients navigating decarbonisation through objective technology and economics analysis, including the use of best available techniques.
• Knowledge Sharing – Contributing to industry advancement through educational resources and academic collaboration.