Code of Business Conduct and Ethics

The Company ensures that executives and employees comply with legal, regulatory, and ethical principles outlined in this Code by providing regular information and training about the Haynes Code of Business Conduct and Ethics and through routine audits of the Ethics program.

As of the most recent three-year period ended September 2022, there have been five complaints through Whistleblower reports and other channels. 100% of the reports received through the Whistleblower Hotline and other channels were investigated by the Internal Audit Manager, and results of the investigations were reviewed with appropriate executive management and the Audit Committee.

It is the Company’s policy to maintain open communication channels to encourage reporting of all potential violations of the policy and prohibit retaliation against reporters.