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Any waiver of the Code for employees must be submitted in writing to ATI’s Chief Compliance Officer. Requests for waivers for executive officers or directors must be submitted to the Chair of the Audit and Risk Committee of ATI’s Board of Directors. No such waivers have been granted to date, nor does ATI anticipate that any such waivers will be granted. Any waiver of the Code will be promptly disclosed to the public.

ATI supports an employee’s right to speak out publicly about matters of public concern and to participate in concerted activities and communications related to terms and conditions of employment. Nothing in any section of our Code or in any of our policies is intended to limit or interfere with that right.

Compliance with the Code and other Company policies is a condition of employment. Nothing in the Code or any Company policy creates a contract or promise for continued employment with ATI.

Our Code and the policies it references may be modified from time to time without prior notice. For the most current version, please see our ATI website.