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Phoenix Services LLC is an affiliate of the Apollo funds dedicated to sustainable solutions and maximizing efficiency for the global steel industry with minimal environmental impact, and always with a personal touch.

Reporting Unethical, Unlawful, or other Inappropriate Activity

Phoenix Services LLC (“Phoenix”) is committed to lawful and ethical behavior in all of its activities. It requires its directors, officers and employees to conduct themselves in a manner that complies with all applicable laws and regulations. If, at any time, you have a concern regarding the propriety or legality of any past, present, or impending activity relating to Phoenix Services LLC to be in compliance with law or appropriate ethical standards, you can inform us via this confidential whistleblower form, or address the issue directly and in confidence by talking with the Chief Executive Officer, Kip Smith.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense and could result in termination of employment.


Under this policy, those who report illegal or improper activity will be protected. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Phoenix Services LLC will make efforts to treat a report of unethical or illegal conduct as confidential, consistent with the need to investigate and prevent or correct the action. Reporting individuals may be expected to cooperate in internal investigations of misconduct.

No Retaliation

An individual making a report will not be discharged, threatened, harassed, or discriminated against for reporting in good faith what he or she perceives to be wrongdoing, violations of law, or unethical conduct or for taking part in an investigation of such activity. Any person who retaliates against an individual for reporting or participating in an investigation of illegal or improper activity will be subject to disciplinary action.

The below form is anonymous unless you choose to disclose your identity to help with the investigation.