Proven to perform.

2021 ESG REPORT

 Our Commitment to Environmental Corporate
Message from CEO Report Highlights Who We Are Our Approach Social Engagement Framework Charts
Climate Action Sustainability Governance

MESSAGE FROM CEO

At ATI, we believe a company should be defined not only by near-term financial results, but also by
its values and the way in which those values inform its actions. Woven into our mindset, our core
values set the foundation of everything that we achieve. They ensure that we keep our people safe,
protect the environment while delivering for our customers, create the diverse and inclusive culture
we aspire to lead, and support the communities in which we operate.
Last year marked a significant turning point for ATI, defined by crucial transformation of our business that sharpened our focus on the demanding, high-value
products and markets where our unique materials science capabilities set us apart. Despite rapid change and significant uncertainty, we evolved and strengthened
our business while maintaining our steadfast commitment to environmental stewardship, social engagement and strong corporate governance. In 2022, we are
poised for growth and energized by many opportunities to promote these principals while delivering for our investors. Robert S. Wetherbee
In particular, we are excited about the many opportunities the “greening” of the global economy presents to our business. Our products are indispensable to our Board Chair, President and
Chief Executive Officer
customers’ efforts to meet the challenges of the world’s rapidly evolving and demanding sustainability needs and expectations. ATI’s innovative and exacting
products and services are helping to solve the world’s climate and other environmental challenges through materials science, with applications ranging from lighter,
more fuel efficient, longer-lasting jet engines, to renewable and other carbon-free energy production, to pollution control and wastewater treatment.
We do what we say we are going to do, when we say we are going to do it, and we do it the right way. We are committed in our own operations to achieving
our stated environmental goals, improving the diversity of our workforce, cultivating an inclusive corporate culture, fostering local community involvement and
sustaining our long and proud tradition of robust corporate governance. As an industry leader, and as reflected in this Report, we’ve succeeded in advancing each
of these priorities, and we look forward to continuing progress.
To that end, I am pleased to report that – as promised – we adopted the Task Force on Climate-Related Financial Disclosures (“TCFD”) reporting framework for
2021 and published our inaugural stand-alone TCFD Report, which you can find at https://www.atimetals.com/aboutati/Pages/safety-sustainability.aspx. This
effort reflects our ongoing commitment to addressing the impacts of climate change as part of our broader ESG vision.
Thank you for your support as we look forward to discovering new ways to solve the world’s challenges through materials science.

OUR CORE VALUES

Integrity Safety & Sustainability Accountability Teamwork & Respect Innovation
We do the right things the right way; it’s We are committed to a Zero Injury We do what we say we are going to do. We seek and celebrate diverse views, We embrace change and unique
the cornerstone of our relationship with Culture, protecting our people and the We set a standard for excellence and capabilities and experiences to power our perspectives to create sustainable value,
every stakeholder. planet through our products and the hold ourselves and our team accountable collaborative work environment. acting with urgency and taking calculated
way we operate. for our actions, results and delivering risks to learn and continuously improve.
value for our customers.

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 Our Commitment to Environmental Corporate
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REPORT HIGHLIGHTS
More than

45% 7 BILLION TABLE OF

decline in Green House Gas (GHG)
emissions including all of our manufacturing facilities, since 2018
gallons of water recycled
by our manufacturing facilities in 2021
CONTENTS
2. Message from CEO

3. Report Highlights
More than

43.1%
of 2021 new hires were
Enterprise-wide target for 80% of all open job slates to

include a minimum of 62%

4. Who We Are

6. Our Commitment to
recycled materials
diversity/inclusion
candidates
30% DIVERSE used in production
Climate Action

CANDIDATES 7. Our Environmental, Social and

Governance (ESG) Approach

8. Environmental
Sustainability

WORLD-CLASS TCFD 13. Social Engagement

SAFETY RECORD REPORT 19. Corporate Governance

53% decline in lost time rate, and First stand-alone report 25. Sustainability Disclosure Topics
48% decline in recordable incident published in April 2022 & Accounting Metrics
rate, since 2018

ATI 2021 ESG REPORT | 3

 Our Commitment to Environmental Corporate
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WHO WE ARE
Our Vision: Solving the World’s Challenges Solving the World’s Climate Challenge
through Materials Science. ATI’s innovating and exacting products and processes are helping to solve the
world’s climate challenges by supporting the transition to a low-carbon economy.
ATI is a $3 billion global producer of high-performance materials and Customers rely on ATI for materials with enhanced corrosion and/or heat
resistance, strength, and other properties for a wide array of applications that
solutions. We are a leader in high-value markets that require suppliers to promote green-house gas reduction and environmental sustainability, including
have deep materials science expertise, significant know-how, stringent alloys and components that:

product qualifications and strong customer and supplier relationships.

► help produce next generation aircraft that save fuel, reduce
emissions, reach new levels of efficiency and reliability, and
Through our extraordinary materials science and advanced, integrated process excellence, we
safely carry millions of air travelers every single day;
create new specialty materials, then shape them to meet our customers’ needs for ultimate
performance, efficiency and long-term value. Whether the challenge is searing heat, crushing
stress, blistering corrosion or all the above, our technologies make amazing achievements possible.
Our materials play a critical role in delivering: ► improve the performance of Land Based Gas Turbines;

► Every new generation of aircraft in the last 50 years, including airframes and jet engines that
continue to safely push the limits of power, fuel efficiency and reliability; ► support sustainable nuclear energy applications and fuel
cell interconnects and solid oxide fuel cells used for on-site
► Clean energy solutions such as materials for green hydrogen production, geothermal power generation;
applications, nuclear power generation, energy storage and pollution control;

► Next-generation defense systems and armor for protecting people and equipment from the ► help enable electrolyzers used in the production of
ever-evolving threat of deadly explosive weapons; and hydrogen from water;

► Medical advances ranging from superconducting MRI machines to implantable stents and
artificial joints that save and improve thousands of lives every day.
► are used in solar and geothermal power applications; and
Our rapidly evolving world requires robust and versatile materials and components produced in
an ecologically sustainable manner, and at ATI, we are determined to help meet that need. We’re
investing in the capabilities and science that will enable customers to sustainably tackle the next
generation of life-changing challenges, whatever they may be. ► are essential to pollution control equipment in power plants
and ships and treatment of ship ballast water.

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2021 FINANCIAL PERFORMANCE HIGHLIGHTS

For ATI, 2021 was a year of marked achievement and accelerating Sales of $2.8 billion compared to $3.0 billion in the prior year, notwithstanding our
exit from standard stainless production
recovery following the profound impact of the global pandemic
► Reflects building momentum in commercial aerospace markets and the acceleration of
in 2020 and the sweeping challenges it presented to the global high-value product sales, consistent with our strategy as we emerge from the pandemic-
related downturn a stronger, more focused business
community and economy. Although the pandemic continued to
impact our business throughout the year, we began to benefit in 2021 ► Includes fourth quarter revenue of $765 million (a 16% year-over-year improvement) and
third quarter revenue of $726 million (up 18% sequentially and 21% year-over-year)
from meaningful improvement in customer demand from our most
Gross profit of $333 million compared to $293 million in 2020
significant end-markets, including the commercial aerospace industry.
Net loss attributable to ATI of $38.2 million, compared to a net loss attributable
At the same time, we continued to successfully execute our strategy, positioning our business for to ATI of $1,573 million in 2020, which included $1,507 million in restructuring and
recovery and growth. In December 2020, we announced plans to exit production of low-margin other charges, net of associated tax impacts
standard stainless sheet products, streamline the operations of our Specialty Rolled Products ► Reflects return to profitability in the third quarter of 2021
(“SRP”) business, and redeploy capital to invest in our specialty capabilities, sharpening our
focus on higher-margin opportunities, including in aerospace and defense. We succeeded in this Preserved strong liquidity and cash position
transformation during 2021, in spite of the ongoing challenges to our business; we no longer ► Refinanced $500 million in long-term debt at meaningfully improved interest rates
produce the low-margin standard stainless sheet products that we committed to exiting and are
on track to complete our plans to streamline operations within our SRP business. ► Significantly reduced our net pension obligations, ending the year at 84% funded status
compared to 75% at year-end 2020, representing a $278 million, or 41%, year-over-year
Moreover, as demonstrated in this Report, we continued to make progress toward our previously- improvement
established environmental and safety goals, as well as on other ESG-related fronts.
► Ended the year with total liquidity of over $1 billion, including $688 million of cash on
Our business returned to profitability in the third quarter of 2021, more quickly than we had hand at December 31, 2021
anticipated, and we believe that the strategic and operational changes we have achieved and
continue to pursue are positioning our business for success in 2022 and beyond. Positioned our business for future recovery and growth
► Exited production of low-margin standard stainless steel sheet products, streamlined the
There are data points in this report that may ultimately appear different or unique operations of our SRP business and redeployed capital
for 2020 and/or 2021 because of the impacts of the COVID-19 pandemic and other
recent challenges on our industry and business. Where possible, we will provide Returning capital to stockholders.
additional information and explanation. ► In early 2022, announced a $150 million share repurchase program

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OUR COMMITMENT TO CLIMATE ACTION

Consistent with our values – Integrity; Safety & Sustainability;
Accountability; Teamwork & Respect; and Innovation – we believe that
long-term excellence and profitability require us to operate in ways that
promote environmental and social sustainability, supported by appropriate
governance structures and enterprise risk oversight practices. We are
committed to protecting our people, our communities and our planet
through our products and the way we operate.

We support the principles of the Paris Accord and global efforts to reduce GHG emissions and that climate change and the transition to a low-carbon economy present to our business,
understand that businesses such as ours have an active role to play in identifying and implementing and our expectations about the extent to which and time horizon over which those risks and
solutions to the challenges posed by climate change. We first publicly articulated climate-related opportunities may impact our business.
targets for reducing GHG emissions and energy intensity, among other sustainability metrics, in
2017 and since then, have periodically reported on our steady progress in achieving, or exceeding, Ultimately, our operations, and those of our customers and suppliers, produce GHG emissions.
the reduction targets that we set. Recognizing that our investors and other stakeholders benefit Although we produce some specialty steel products, we do not burn any coal in our own
from the transparency and comparability of disclosure across business and industries that operations, in contrast to integrated carbon steel producers, generally. Additionally, as discussed
commonly-accepted reporting frameworks can drive, we aligned our 2020 ESG Report with the elsewhere in this report, we make extensive use of recycled scrap material in our production
Sustainability Accounting Standards Board (“SASB”) standard. This year’s report also aligns with processes. Nevertheless, producing the highly-specialized alloys and other critical products that
the SASB standard, and we intend to continue that practice in future reports. we provide to the commercial aerospace, defense and other markets requires that we melt raw
materials at very high heat and engage in other processes that consume energy. While a significant
For 2021, we adopted the Task Force of Climate-related Financial Disclosures (“TCFD”) reporting portion of those processes are fueled by electricity, a substantial portion of which is sourced from
framework in further recognition of our stakeholders’ growing interest in gaining a deeper carbon-free generators, the majority use natural gas. We believe we have made important strides
understanding of the climate-related risks and opportunities that climate change presents to in addressing our environmental impact, including as it pertains to GHG emissions. Work remains,
our business. Coincident with the publication of this ESG Report, we published our first, stand- however, as we continue to address the risks and opportunities that climate change presents to
alone TCFD Report, which is available at https://www.atimetals.com/aboutati/Pages/safety- our business.
sustainability.aspx.
As we continue to identify, assess and manage climate-related risks over the course of 2022,
To support the development of our TCFD Report, we established a cross-functional working we intend to re-evaluate our previously-articulated environmental sustainability goals, including
group drawn from leadership in relevant portions of our organization. As discussed in greater our specific goals pertaining to GHG reductions, to ensure that our goals are aligned with, and
detail in the Report, the team broadly considered both the physical risks that climate change meaningful in the context of, changes in our business and the evolving expectations of our
poses to our business, as well as the risks and opportunities that global efforts to transition to stakeholders. Additionally, in 2021, we exited production of standard stainless steel products
a low-carbon economy present to our business. Our 2021 TCFD report describes the team’s and began efforts to streamline our production footprint by consolidating certain parts of our
processes and analysis, the governance structures that we have in place to enable appropriate operations, which remains on track for completion. These changes are expected to create
risk oversight as it pertains to climate change matters, the principal risks and opportunities additional operational efficiencies and may also drive changes to our previously-articulated goals.

ATI 2021 ESG REPORT | 6

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OUR ENVIRONMENTAL, SOCIAL AND We are Committed to:

► Conducting business in accordance with

GOVERNANCE (ESG) APPROACH applicable laws, regulations, permits and ATI’s

Corporate Guidelines for Business Conduct and
Ethics;

► Respecting the rights of people affected by our

At ATI, we recognize that long-term excellence activities and fostering a respectful dialogue with
and profitability require that we operate in them;

ways that promote environmental and social ► Supporting local communities and contributing
to their sustainability through measures such as
sustainability, supported by appropriate locally sourcing goods and services and employing
governance structures and enterprise risk local people;

oversight practices. One of our core values is ► Establishing non-discriminatory conduct

in the workplace, hiring practices and
Safety & Sustainability, and we’re committed to career advancements. Ensuring that hiring,
protecting our people and our planet through our advancements and promotions are unbiased and
► Social Engagement. Attracting, retaining, developing and based on merit and ability;
products and the way we operate. We continually ensuring the safety and wellbeing of a talented and diverse
workforce is key to the sustainability of our business. This report ► Continually improving safety, health and
refine our efforts to enrich the communities in describes the human capital management initiatives we have environmental policies, management systems and
which we operate, lessen our environmental in place to meet these challenges, including the cultivation of a controls so they are fully integrated into company
diverse workforce and inclusive culture and engagement in our local activities;
impact, improve the health and safety of our communities. Additionally, as described in this report, we are deeply ► Promoting a culture of safety and continually
employees, and ensure the sustainability and committed to workplace safety and have an outstanding enterprise- reinforcing company-wide safety efforts and
wide safety record. To that end, we are progressing toward our goal maintaining programs that effectively address
quality of our workforce. of obtaining ISO 45001 certifications at each of our manufacturing workplace hazards and monitor and protect
facilities, one component of our comprehensive efforts to ensure employee health and safety;
► Environmental Sustainability. As described in this report, continued workplace safety and promote a zero-injury work
we continue to make progress toward established performance environment. ► Conducting operations in a sound environmental
targets for reductions in energy intensity, Green House Gas manner and seeking to continually improve
(GHG) emissions and freshwater intake, as well as targets for ► Corporate Governance. ATI has a long tradition of strong performance;
full ISO 14001 certification at each of our facilities and increases corporate governance that extends to the governance and
► Promoting the efficient use of energy and material
in our already extensive production use of recycled materials. oversight of ESG matters. We have a diverse, highly credentialed,
resources in all aspects of our business; and
This report addresses our progress toward these targets in 2021 highly experienced and highly engaged Board that guides the
and provides additional disclosures on other air emissions, water strategic direction of our business. This report addresses our history ► Practicing product stewardship and promoting
management and waste management efforts. As discussed of Board leadership and diversity, our practices associated with risk research to enhance the benefits of our products
elsewhere in this Report, we have aligned our disclosures with management and oversight, the governance of our ESG initiatives to society.
both the SASB and, in relation to climate-change matters, TCFD and related matters, including our cybersecurity initiatives and
We ensure that all ATI employees are involved in the
reporting frameworks. ethics and compliance programs.
enhancement of health and safety initiatives.

ATI 2021 ESG REPORT | 7

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ENVIRONMENTAL SUSTAINABILITY
At ATI, we are committed not only to maintaining and operating our businesses in full
compliance with all applicable environmental laws, regulations, and rules, but also to
strong ESG practices and effectively managing and reducing our environmental impact.

A Legacy of Investment in Impact Reduction

Goals for Reducing Our
► The wastewater treatment facility at our Brackenridge, PA facility, installed in 2007, recycles water up to three times,
which reduces the volume of water withdrawn from navigable water.
Environmental Impact
We have established the following near- and longer-term goals relating
► A separate facility related to our Brackenridge operations recycles pallets, crates and other wooden packaging material. to reductions in energy intensity, GHG emissions and water intake, as
► A deionization system installed at our Richburg, SC facility in 2018 enables that facility to reuse water in its largest well as targets for increases in our already extensive production use of
cooling tower multiple times. recycled materials.

► In 2020, we completed a LED lighting retrofit at our operations in Cudahy, WI, reducing annual energy usage at that Performance Targets*
facility by 8.4 million kWh. This reduction is equivalent to, for example, the aggregate GHG emissions of more than 1,200
passenger cars driven for one year or the GHG emissions avoided by recycling more than 2,000 tons of waste or the
2022 2025* 2030*
carbon sequestered by nearly 100,000 tree seedlings grown for 10 years. A similar investment at our facility in Remscheid
Germany achieved a reduction in energy usage equivalent to a 45% reduction in CO2 emissions by that facility.
Include all
► Our Millersburg, OR facility recovers aqueous ammonia at over 99.5% efficiency, allowing for the recovery and reuse of Reduce Energy Reduce Energy
manufacturing
up to 4 million pounds of aqueous ammonia annually. Intensity 5% Intensity 7%
facilities in metrics
► Through a program that returns oily absorbent materials to a processing center that cleans and recycles them for
reuse, our participating facilities have diverted more than 15,000 pounds of oily waste from landfills in just the last Reduce CO2e/ Reduce CO2e/
two years. GHG emissions GHG emissions
intensity by 5% intensity by 7%
► In 2010, in partnership with the cities of Albany and Millersburg, OR, we developed the “Talking Water Gardens,” an
innovative water discharge and treatment system using constructed wetlands to cool and safely return treated water to
Reduce freshwater Reduce freshwater
the Willamette River, helping to protect the river’s sensitive habitat.
intake intensity by intake intensity by
► A partnership between Harrison Township, PA, ATI and Western Pennsylvania Conservancy resulted in planting trees on 5% 8%
ATI’s property to provide a barrier between the industrial site and the community and enhance stormwater collection.

► In 2021, We Energies and ATI launched the largest solar power project in the history of Cudahy, WI. ATI’s vacant Increase recycled Increase recycled
land is now home to WE Energies’ 7,000 solar panels that provide carbon-free power to homes across Wisconsin. materials used in materials used in
production to 80% production to 83%
► In 2022, we replaced the argon recapture units in two locations, achieving 90% recapture efficiency.

*Using 2018 as baseline year.

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Our 2021 Performance and Progress Toward Our Goals

In 2018, we began annually reporting on our progress toward our goals, based on data that generally included our largest domestic manufacturing operations. Consistent with our goal for 2022, we have
included all of our manufacturing facilities in our performance target reporting for 2021, expanding beyond our seven largest facilities. Our metrics now include data from our 19 manufacturing locations
including facilities.

The following tables summarize our recent performance relative to our other environmental sustainability goals for our manufacturing sites. Our data for 2018 has been adjusted to
include the 19 locations mentioned above and is presented as adjusted and compared to 2021. As illustrated below, we have made significant progress toward our goals since 2018,
including meaningful reductions in GHG emissions from both an absolute “location based” standpoint and from a “market based” standpoint giving effect to our zero-emission nuclear
generation supply contract.

2018 Intensity 2021 Intensity

2018 2021
Metric Units % Change unit/ton of unit/ton of % Change
Performance Performance
production production
Energy Consumed Gigajoules 13,878,230 12,047,835 -13.2 3.57 3.77 7

CO2e Emissions *
Metric tons of CO2e 1,188,409 659,942 -44.5 0.31 0.21 -13.8

Fresh Water Intake Kilo-gallons 5,298,885 4,136,532 -22.0 1.36 1.31 -3.8
*
See additional Scope I and Scope II detail below

2018 Intensity 2021 Intensity

2018 2021
Metric (CO2e Emissions Detail) % Change unit/ton of unit/ton of % Change
(MT CO2e) (MT CO2e)
production production
Scope I Emissions 506,660 430,192 -15.1 0.13 0.14 -4.6

Location-based Scope 2 Emissions 681,750 401,605 -41.1 0.18 0.13 -27.7

Market-Based Scope 2 Emissions† 681,750 229,751 -66.3 0.18 0.07 -58.5

Total Location-Based Emissions 1,188,409 831,797 -30 0.3 0.26 -13.3

Total Market-Based Emissions† 1,183,668 659,942 -44.5 0.3 0.21 -3

†
Reflects impact of carbon-free electric power sourcing beginning in 2019

2018 Recycled Materials Used in 2021 Recycled Materials Used in

Metric* 2018 Tons Recycled 2021 Tons Recycled
Production Production
Material Recycled 26,235 98,145 approximately 63% 62%
*
“Recycled Materials Used in Production” refers to the percentage of raw materials used in our production of specialty materials that is sourced from scrap metal, either purchased or originating from our
own manufacturing processes.
In 2018, we also set a goal for all of our manufacturing facilities to be ISO 14001 certified by the end of 2022. We have made significant progress toward this goal in spite of the pandemic and ongoing
business transformation efforts, but are re-evaluating it as part of our decision to revise our goals in 2022.

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Greenhouse Gas (GHG) Emissions

Our GHG emissions (which as reported include gross global Scope 1 emissions and Scope 2 emissions) for 2021 were significantly lower
than our base year 2018 emissions. Year-over-year total emissions decreased by approximately 45% in 2021 compared to 2018, primarily
attributable to increased purchases of carbon-free electric generation. Although our performance in 2021 was also impacted by lower
production activity, we believe that this represents meaningful progress toward our goals for 2025 and beyond.

Our short-term strategy to manage Scope 1 emissions (those occurring directly from sources we own or control) includes:

Energy Intensity Short-Term (1-3 years): Medium-Term (4-8 years): Long-Term (beyond 8 years):
For 2021, our energy consumed by our 19 ► installation of low emission sources ► installing equipment powered ►E
 mploy alternate energy sources
manufacturing facilities was lower than our 2018 in new equipment installations by electricity rather than like hydrogen and renewable
baseline year. Specifically, energy consumed ► install LED lighting natural gas where feasible natural gas
declined from approximately 13.8 million GJ in 2018 ► maximizing the efficiency of our ► enhancing emission capture
to approximately 12.0 million GJ in 2021. However, production and operations if possible
this decline may be attributable, at least in part, to
► energy auditing
lower production volumes primarily as a result of
the COVID-19 pandemic. When operating at lower
volumes, our facilities are less efficient, resulting To manage Scope 2 emissions (purchased energy and fuels) we have implemented a strategy focused on purchasing carbon-free
in an increase in energy intensity of 0.22 GJ/tons sources of power. We are evaluating options for battery storage systems, and constructing renewable energy sources. Developing overall
produced in 2021 compared to 2018. emissions reduction targets and analyzing performance against those targets assists in achieving desired reductions. A significant portion
of our electricity is sourced through a zero-emission EFEC supply contract. We continue to evaluate options for installing or purchasing
Our strategic plans for reducing energy power from renewable sources, including solar and hydropower and other emission-free electricity sources, as well as adding emission
intensity and carbon emissions to achieve
reducing equipment as we upgrade or replace equipment in our facilities.
our performance goals include:
Short term:
► Purchasing carbon-free energy where available
Energy Type 2021 GJ 2021 % Total Electricity as a % of Total Energy: 30.8%
► Conducting energy audits
► Investing in new technology 19.0% Nuclear Electricity as a % of Total Electricity: 38%
Grid Electricity (GJ) 2,293,978
► Installing energy efficient lighting Covered under emissions-limiting regulations: 0%
Nuclear Electricity (GJ) 1,421,471 11.8%
Medium term: Longer term, we continue to evaluate options for
Natural Gas Use (GJ) 7,792,601 64.7%
► Replacing and/or optimizing compressors installing or purchasing power from renewable
► Maximizing production capabilities and Fuels (GJ) 450,746 3.7% sources, including solar and wind and other
schedules to reduce waste emissions-free electricity sources, as well as adding
Steam (GJ) 89,039 0.8%
emission reducing equipment as we upgrade or
Long term: 100%
Total Energy Use (GJ) 12,047,835 replace equipment in our facilities.
► Purchasing RECs
► Installing carbon-free power sources

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Water Intake Material Recycled

Our facilities use water for various purposes, and our sources of water vary from We use scrap metal, among other raw materials, in the production of our specialty materials. We
location to location, including withdrawals from navigable waters and municipal supplied have an interest in recycling the scrap we generate in our production and endeavor to recover as
sources. Generally, our operations are located in areas where water stress is not an issue. much material as we can and return it to our processes. Approximately 62% of the feedstock we
Nevertheless, we are focused on reducing use of fresh water in our operations, and water used in production for 2021 was scrap, compared to 62% in 2020, 77% in 2019 and 75% in our
reclamation and reuse is paramount to our water use reduction strategy. base year 2018. Our transformed business and sharpened focus on the demanding, high-value
products and markets where our unique capabilities give us a durable competitive advantage
At our 19 manufacturing facilities, we recycled over seven billion gallons of water in 2021. have impacted the extent to which we use scrap metal. Currently, the use of recycled materials
Historically we made significant investments in water reclamation equipment at our is less feasible in the production of some of our highly-specialized products than in, for example,
Brackenridge, PA hot rolling and processing facility, and in 2019, our Richburg, SC facility the production of low-margin standard stainless sheet, which we exited in 2021. Nevertheless,
added a water treatment unit and other equipment to allow water reuse prior to discharge, we consistently evaluate opportunities to recycle scrap generated in our production back into our
resulting in a 3.6 million gallon reduction of freshwater usage in 2019 compared to 2018. processes and outlets to recycle materials we cannot use directly.

Year-over-year total water intake by our 19 manufacturing facilities declined 22% in 2021
compared to our base year 2018. Although our performance in both 2020 and 2021 was
impacted by COVID-related declines in production activity, we believe that year-over-year
trends reflect meaningful progress toward our goal for 2025 and beyond.

ISO 14001
At the end of 2021, we had 34 operating facilities, including manufacturing and service centers,
18 of which had obtained ISO 14001 certification of their environmental management programs.
In light of the pandemic and the ongoing consolidation and restructuring of our facilities, we are
re-evaluating our ISO 14001 certification goal as part of our decision to revise our goals in 2022.

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Additional Environmental Efforts

Waste Management Toxic Air Emissions Environmental Compliance and Risks

We strive to improve the handling of waste and endeavor to Many of our facilities measure and report air emissions of We consider environmental compliance to be an integral part
recycle, reuse and reclaim waste generated in the course of the following parameters. Of those facilities that report, of our operations. All of our operations have a comprehensive
our processes. Our expectation is that sustainability is every the following is an aggregate of emissions in 2021.  environmental management and reporting program that
employee’s job and that they will react when faced with focuses on compliance with applicable federal, state, regional
an opportunity to eliminate or reduce waste. Some of our PARAMETER 2021-tons/yr. and local environmental laws and regulations. Each system
byproducts are sold to customers who reclaim them into useful includes mechanisms for regularly evaluating environmental
products. Some of our material is returned to our process CO (carbon monoxide) 1,730.28 compliance and managing changes in business operations while
and others are recycled by third parties. We are mindful that NOx (nitrous oxides excluding assessing potential environmental impact. Annual Report
materials disposed of in landfills are wasted resources and we 465.81
nitrous dioxide)
aim to reduce the input to landfills where possible. ATI had no significant issues with environmental
SOx (sulfur oxide) 29.77 compliance in 2021.
In areas that provide access to adequate recycling, we
Particulate Matter 187.18 We are subject to various domestic and international
manage and recycle business waste including metals, acids,
oils, packaging materials, wood, office paper and cardboard. MnO (manganese) 7.54 environmental laws and regulations that govern the discharge
Approximately 133,400 tons of materials were recycled in of pollutants and disposal of wastes, and which may require
Pb (lead) 0.33
2021, including revert material, wood wastes, and by-products that we investigate and remediate the effects of the release or
sold to third parties, but excluding scrap metal purchased VOCs (volatile organic disposal of materials at sites associated with past and present
271.17
for production. compounds) operations. We could incur substantial cleanup costs, fines
and civil or criminal sanctions, third party property damage
PAHs (polycyclic aromatic
Many of our facilities are required to have a spill prevention 0.66 or personal injury claims as a result of violations or liabilities
hydrocarbons)
control and countermeasure plan if they meet specific volume under these laws or non-compliance with environmental
thresholds for oil or oil products. Plans include employee permits required at our facilities. We are currently involved in
training on spill prevention and response. We use internal the investigation and remediation of a number of our current
protocols, procedures and processes to prevent spills and to and former sites as well as third party sites. We also could be
quickly respond in the event a spill does occur. Employees are subject to future laws and regulations that govern greenhouse
trained to internally respond to and report spills outside of a gas emissions and various matters related to climate change and
designated containment area as part of our environmental other air emissions, which could increase our operating costs.
management system. We had zero reportable spills in 2021.

Significant spills in 2021 = zero

Tailing waste ponds and underground
injection of waste = zero

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SOCIAL ENGAGEMENT
Ensuring Workplace Safety and a Zero-Injury Culture
Our Safety Record and Certification Goal

Safety is one of our core values. We strive for a Zero Injury Culture committed to the safety of our
people, our products, and the communities in which we operate.

As shown in the table below, our outstanding recent safety record consistently reflects meaningful
year-over-year improvement:

2021 2020 2019 2018

Awards
Fatalities=0 Fatalities=0 Fatalities=0 Fatalities=0
ATI Specialty Materials won the N.C.
Recordable Recordable
Recordable Recordable
Department of Labor Safety Gold
Incident Rate Incident Rate
=0.85 =0.87
Incident Rate =1.14 Incident Rate =1.63 Award for outstanding on-the-job safety
achievements during 2021.
Lost Time Rate = Lost Time Rate = Lost Time Rate = Lost Time Rate =
0.16 0.21 0.21 0.34 The Gold Award is based on the days away, restricted,
transferred (DART) rate, which includes cases of days
away from work, restricted activity or job transfer.
Per 200,000 hrs. worked

As of December 31, 2021, 85% of our operating facilities had obtained OSHAS 45001 certification of Facility Consecutive Wins
their safety management program.
Bakers North 17 years
Our Pandemic Response

Our immediate and thorough response to the COVID-19 pandemic throughout 2020 and 2021 enabled Bakers Powder 6 years
us to quickly extend our existing safety culture and outstanding safety record to management of the
pandemic and its impact on our people and business. Monroe 46 years

Although we sadly experienced some COVID-related employee deaths in the latter part of 2021, as a
Bakers South 12 years
result of the collective actions of our dedicated workforce we experienced very limited known work-
place transmission of the virus.
East 13 years

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Promoting Effective Human Capital Management

We believe that world-class leadership and fostering a culture

that enables us to build and grow a talented team through career
development and opportunities is foundational to our vision.
Attracting, retaining and developing members of our workforce
is key to the sustainability of our business. As the economy and
our business grow, so do both demand for qualified candidates
and the retirement rate for older workers; hence we are always
competing for talent in an environment of increasingly challenged
supply. To that end, we have developed — and continue to
enhance and refine — a robust and comprehensive talent
management program that spans from recruitment and selection Professional Development
to performance management, career development and retention ► Global Leadership Development Program (GLDP). The GLDP is our Company-wide,
flagship program designed to build the skills of our employees across each level of leadership.
of our top talent and, ultimately, to succession planning across It includes a series of multi-day training programs tailored to reach and serve a broad range of
our organization. current and potential leaders across the ATI organization.

► Business Acumen Series. This more narrowly focused leadership education program is
Talent Acquisition designed to develop skills in key areas, such as finance. The purpose of this program is to
facilitate a common framework and understanding of financial business acumen to improve
► Partner closely with a targeted number of colleges and universities specifically known for decision making critical to the sustainable success of our business.
programs that are relevant to our business in order to identify materials science, STEM
expertise and other relevant talent, and have developed similar partnerships with high ► Early Career Leadership Development Program. Our selective Early Career Leadership
schools and relevant trade schools. Program is designed for high-potential and motivated college graduates. This five-year
program, which is designed to prepare our future leaders, accelerates participants’ professional
► Engage with external professional recruiting firms to enhance our recruiting efforts for development by rotating them through a variety of business-critical assignments and
key positions. development opportunities.

► Use pre-employment assessment tools to identify candidates who we believe would ► Insights Discovery Program. This program, which we incorporate as an element of our
adapt well to our culture and be most suited to a particular opportunity. other professional development programs, is designed to support employees in exploring
and developing targeted competencies such as self-awareness, communication, conflict
► Actively engage with campus and professional diversity groups.
management, giving and receiving feedback, influencing others and other skills.

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Engagement and Performance Management

► Senior Leader Communication and Transparency. We actively seek opportunities for regular
engagement and communication by our CEO and other senior executive leaders with our
broader employee population. For example, we hold a quarterly CEO Review that follows
the release of our quarterly earnings and is accessible to hundreds of employees across the
Company. These reviews provide an opportunity for our CEO and other senior leaders to
communicate their perspectives on our recent financial results, as well as financial education
and enterprise-level education on topics such as global commercial and other growth initiatives,
cybersecurity, ethics and compliance, talent and development programs, opportunities for
community engagement and safety.

► Annual Employee Engagement Surveys. Annually, we conduct a confidential company-wide

employee engagement survey. Feedback from these surveys provides our management team
with valuable information about our workplace culture. It is reviewed with our Board and used
to develop and refine other aspects of our overall human capital management and other growth
strategies.

► Performance Management Framework. We maintain a robust annual performance management

process across the organization. Together with their supervisors, employees identify annual
goals and, at the end of the year, provide their own self assessments as to goal achievement and
defined core competencies. Employees are reviewed based on the same criteria by both their
managers and a second-level reviewer. The results of each annual assessment inform short term
incentive compensation and career advancement decisions and are reviewed with employees in
one-on-one sessions with their managers.

Succession Planning

► We maintain a formal succession planning process and career mapping framework that is
designed to work in concert with our performance management processes and ensure a
systematic and ongoing dialogue regarding career development and succession planning at both
the individual employee level and more broadly at an enterprise level. We believe that the robust
and systematic nature of these programs is critical to optimizing our talent management and
ensuring sustainably high-quality management of our business over the long term.

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Fostering Diversity and Inclusion

Ultimately, continuing ATI’s long tradition of innovation and Gender and Ethnic Diversity

operational excellence demands the contributions of leaders We recognize that the proportions of women and ethnic and racial minorities included in
our leadership and total workforce do not reflect the composition of the general population.
and other team members with a wide array of characteristics,
However, we have long benefited from gender diversity on our Board, and women contribute
backgrounds, experiences, knowledge and skills. One of the principal to our business at the highest levels of senior leadership. In fact, we have been recognized
for at least ten consecutive years by 2020 Women on Boards for having a Board comprised
aspirations of our comprehensive human capital management effort
at least 20% of women. From May 2019 to May 2021, when she retired from our Board, Diane
is the cultivation of a workforce that is diverse in every sense and a Creel served as our first Independent Board Chair, following her multi-year service as our Lead
Independent Director. Additionally, two of the seven current members of our Executive Council,
climate of inclusion that promotes the development, advancement
including our Executive Vice President and Chief Operating Officer and our Chief Human
and well-being of our key talent. Simply put, for our business to Resources Officer, are women.
continue thriving, we must attract, coach and retain the best. That
Our most recent employee engagement survey results demonstrated year-over-year
requires a commitment to workforce diversity. improvement in employee perceptions of the diversity and inclusiveness of our corporate culture.
A majority of respondents agreed that as an organization we value diversity and cultivate a work
To identify opportunities to improve our recruiting efforts and enhance the inclusiveness of our environment that is accepting of individual differences. However, our ultimate goal is that all
workplace culture, we collect and regularly review with our senior leadership various diversity respondents take a positive view of our efforts to promote diversity and inclusion.
statistics relating to gender, ethnicity, age, military service and other attributes, some of which
are illustrated below. We also use our annual Employee Engagement Survey to solicit employee Veterans
perceptions of the diversity and inclusiveness of our company-wide culture. Quantitative
analysis of our employee population, coupled with a more qualitative understanding of how we Understanding that we have many opportunities to improve our diversity initiatives, we believe
are perceived and of the particular challenges we may face as a manufacturing company in the that ATI stands out in its efforts to support and provide career opportunities to veterans of
specific regions in which we operate, helps to inform our policy decisions and initiatives related the U.S. armed forces. More than 5% of our senior leadership and more than 8% of our total
to workforce diversity. employee population are military veterans. The defense market is critical to ATI and is a growing
component of our business, and we have a formal company-wide strategy and commitment
We are committed to increasing the representation of women and of racial and ethnic minorities to the recruitment, career development and retention of veterans and the extended military
and military veterans of all backgrounds among our employee ranks. To support this objective, community. We value the contributions of our military community members and recognize the
we have an enterprise-wide target for 80% of all job candidate slates to include a technical and leadership skills earned through the devotion to our company and country.
minimum of 30% diverse candidates.

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Diversity & Inclusion in Leadership Employee and New Hire Diversity & Inclusion
Board of Directors Women Military Veterans

22.2% Women 10.3% 8.7%

44.4%
11.1% Ethnic/Racial Minority Total D&I 17.1% 5.9%
11.1% Military Veterans
Ethnic/Racial Minorities Total Diversity & Inclusion
Senior Leadership 16.7% 32.2%
25% Women 27.6% 48.4%
32.8%
8.3% Ethnic/Racial Minority Total D&I

5.5% Military Veterans Total Employee Population 2021 New Hires

► Additionally, we are making extensive efforts to identify and attract diverse candidates through
comprehensive recruiting strategies that include, among other initiatives, campus partnerships
with female and minority student chapters of targeted professional groups, such as the Society of
Women Engineers, Society of Hispanic Engineers, and Society of Asian Scientists and Engineers at
our partner universities and increased outreach through engagement with additional networking
groups, such as the National Society of Black Engineers, the National Association of Black
Accountants and the Association of Latino Professions in Accounting and Finance.

► We believe that we are seeing the impact of our diversity initiatives. Notably, our 2021 new hire
statistics outpace the composition of our existing employee base for both women and ethnic
minorities. While military veterans as a proportion of our total workforce exceeds the percentage
of veteran new hires in 2021, at 5.9% of 2021 new hires, our success in recruiting veterans during
2021 is consistent with the representation of military veterans in the general U.S. population.
Military veterans comprise more than 8% of our total workforce, or nearly 50% higher than their
proportion of the general U.S. population.

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Human Rights Community Involvement

ATI is committed to conducting its business activities in a manner that respects In 2021, We Energies and ATI cut the ribbon on the
human rights and in compliance with applicable local, national and international largest solar power project in the history of Cudahy,
laws and regulations related to the protection of human rights including prohibition Wisconsin. ATI’s vacant land is now home to We
of human trafficking and slave labor. ATI’s Human Rights policy, which applies Energies’ 7,000 solar panels, which provide carbon-free
to employees, contractors, suppliers and agents, supports ATI’s commitment to power to homes across Wisconsin. The Solar Array
protecting human rights and is designed to support compliance with applicable project also won the inaugural ATI CEO Award for
laws and regulations such as the United States Government’s Federal Acquisition Safety and Sustainability.
Regulations clauses related to combating trafficking in persons and the UK
Modern Slavery Act. Also in 2021, a partnership between Harrison Township,
PA, ATI and Western Pennsylvania Conservancy
planted trees on ATI’s property, providing a barrier
between the industrial site and the community and
enhancing stormwater collection.

ATI is a proud supporter of United Way and through

its employee campaigns contributed over $300,000
to United Way Chapters throughout the United
States in 2021.

All of our business units are engaged with their

communities through monetary donations, food
bank drives, school supplies and toy drives for the holidays. Our extremely generous employees deserve
special recognition for all the time, effort and resources they committed to charitable causes, even during
a global pandemic.

Located less than 90 miles from the Ukrainian border, our 400+ colleagues at ATI Forged Products
in Stalowa Wola, Poland, together with their community, are embracing and supporting refugees
displaced by the Russian invasion. In support of their efforts, we contributed a total of $50,000 to Polish
Humanitarian Action (PAH), which supports emergency response to refugees, including providing shelter
and access to food and necessities.

Each year, ATI SM employees and their families help those in need in our community during United Way’s
Day of Caring. The Day of Caring projects involve activities such as lawn care, weeding flowerbeds,
pruning shrubs, picking up trash, washing windows, and light painting. The majority of project sites are at
the homes of the elderly.

ATI participated in Partner4Work’s Learn & Earn Summer Youth Employment Program (Learn & Earn)
that is designed to provide meaningful work experiences and career exposure to low-income young adults
residing in Allegheny County, Pennsylvania.

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CORPORATE GOVERNANCE
We are committed to a strong self-governance program. Our corporate Governance Highlights
governance practices are designed to maintain high standards of oversight, Our commitment to good corporate governance is
compliance, integrity and ethics, while promoting growth in long-term illustrated by the following practices:

stockholder value. The role of our Board of Directors is to ensure that ATI is
► Board independence (8 out of 9
managed for the long-term benefit of our stockholders and other stakeholders. directors are independent)

Each year, we review our corporate governance and compensation policies and practices and engage with our ► Lead Independent Director
stockholders. In our ongoing effort to ensure that our governance policies and practices consistently reflect best ► Independent directors regularly meet in
practices, we take suggestions from our stockholders into consideration, along with developments and evolving trends executive sessions without management present
reflected in the standards established by proxy advisory firms, as well as in the policies, practices and disclosures of
other public companies. In this way, we affirm our commitment to performance and innovation by continually evolving ► 100% independent Audit & Risk, Personnel
our programs to benefit all of our stakeholders. You can learn more on our website ATImetals.com & Compensation, and Nominating
& Governance Committees

► Annual Board and committee self-assessments

► Strong corporate governance

guidelines and policies

► Majority voting/director resignation

policy for uncontested elections

► Board diversity (female and minority directors

comprise over 30% of our current Board)

► Mandatory director retirement age

► Proxy access

► Limits on future severance arrangements

► Robust stock ownership guidelines for

directors and executive management

► Intensive succession planning for our

Board and executive leadership

► Well-established Board strategic

and risk oversight function

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OUR BOARD ATI Board Of Directors

Robert S. Wetherbee
Board Chair, President and Chief Executive Officer, Allegheny Technologies
ATI has a diverse, highly credentialed and highly experienced Board. Incorporated
Our directors possess a variety of tenure, qualifications, backgrounds, J. Brett Harvey
skills and experiences contributing to a Board that is well-rounded and Lead Independent Director of ATI. Retired Chairman and Chief Executive Officer
of CONSOL Energy, Inc., a leading diversified energy company in the United
well-positioned to effectively oversee our business and promote the States.
interests of our stakeholders.
Leroy M. Ball
President and Chief Executive Officer, Koppers Holdings, Inc., a leading
Highly Engaged Board Guides the Strategic Direction of Our Company
integrated global provider of treated wood products, wood treatment chemicals
► Actively oversees long-term strategic planning and capital allocation decisions, including through and carbon compounds
an annual, multi-day strategic planning meeting in addition to regular quarterly and other Board
Herbert J. Carlisle
meetings.
President and Chief Executive Officer of the National Defense Industrial
► Regularly assesses and oversees management and mitigation of known and emergent risks to Association (NDIA), and retired four-star general from the United States Air
our business. Force (USAF)

► Conducts site visits at our facilities throughout the United States. Though our recent ability to Carolyn Corvi
conduct these visits has been curtailed by the ongoing COVID-19 pandemic, they are a valuable Retired Vice President, General Manager of Airplane Programs of The Boeing
component of our normal governance practices; visiting our facilities allows our directors to meet Company
with management and other employees and to gain both firsthand exposure to the technologies
James C. Diggs
that drive our success and deeper knowledge of the strengths and challenges of our business
Retired Senior Vice President and General Counsel of PPG Industries, Inc., a
and how they tie to our near and long-term strategic goals.
producer of coatings, glass and chemicals
► Actively and continuously engages in robust Board and senior management succession planning.
David P. Hess
► 93% overall attendance rate for Board and Committee meetings during 2021, and more than Retired EVP and Chief Customer Officer for Aerospace, United Technologies
96% over the last three years. Corporation, a global leader in aerospace and technology; formerly President,
Pratt & Whitney
► Market-driven stock ownership guidelines.
Marianne Kah
Retired Chief Economist for ConocoPhillips and current adjunct senior research
scholar at Columbia University’s Center on Global Energy Policy

David J. Morehouse
Chief Executive Officer and President of Pittsburgh Penguins LLC, which owns
and operates the Pittsburgh Penguins National Hockey League team

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Focused and Thoughtful Board Refreshment

Board Refreshment & Independence
►O
 ur Board routinely engages in succession planning and adds new members

+5 -7
on an opportunistic basis when it identifies candidates whom it believes
have experience, skill sets and other characteristics that will enhance Board
directors added directors retired over the last 5 years
effectiveness.

►W
 e have a mandatory retirement age, and our Board engages in recruitment as ► 3 longer-tenured directors retired concurrently with our 2021 Annual Meeting.
appropriate to support its refreshment efforts. ► All non-management Directors (89% of our directors) are independent.

►O
 ur annual Board evaluation process assesses the Board’s existing skill sets and
the need or desirability of adding members; the Board can appoint new members
when presented with candidates who fill a particular need or otherwise would
serve as an asset to the Board. Diversity of Experience

100% executive leadership 9

Diversity of Background
89% industry/manufacturing knowledge 8

33% 67% 67% 100% financial 9

3 are women/
minority
5 are current or
former CEOs
5 currently serve
on other public
67% operational or technical 6
company boards

► 1 completed nearly 40 years of military service

► 1 qualifies as an audit committee financial expert
Director Tenure
► 4 have extensive experience related to aerospace/defense
►2
 served as senior executives in the commercial aerospace
industry, our largest end market
► 2 have extensive executive experience in energy markets
5
2
1-5 years

11 years+
7.7 years
Average tenure
2 6-10 years

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ESG Governance and Oversight

Our Board is elected by our stockholders to safeguard their interests through oversight of Social Responsibility
management and the good faith exercise of its members’ business judgment. At the same The Personnel and Compensation Committee assists the Board in its oversight responsibility
time, our Board recognizes that the long-term interests of ATI are advanced by recognition concerning executive compensation and management organization matters generally. Among other
of the concerns of other constituencies, including employees, customers, suppliers and the specific matters, it monitors and encourages the development of intellectual capital and oversees
communities in which ATI operates. Accordingly, while not involved in our day-to-day operations, the Company’s human capital management policies and procedures, including its workforce and
our Board actively oversees matters of key importance to the overall conduct of our business, professional development and diversity and inclusion initiatives, the impact to the Company of
including among other matters, our financial performance and expectations, development and current or anticipated political, legislative or regulatory trends or developments regarding human
implementation of our strategic plans, capital structure and allocation, matters impacting our capital management, including without limitation diversity and inclusion in the workplace, and
corporate governance and culture, and the identification and mitigation of known and emergent management’s efforts to mitigate any resulting risks to the Company.
enterprise risks and opportunities, including those pertaining to environmental, workforce and
community safety and sustainability. Governance

Our Board has four standing committees, its: Audit and Risk Committee; Nominating and The Nominating and Governance Committee assists the Board in overseeing the Company’s
Governance Committee; Personnel and Compensation Committee; and Technology Committee. corporate governance practices and profile, including as appropriate, the legal standards, prevailing
Each standing committee of the Board is comprised entirely of independent directors, and each recommended practices, investor views and potential benefits and risks associated with or
has a written charter that describes its responsibilities. Among other matters, each Committee impacting such governance practices and profile. It leads the Board’s director succession planning
assists the full Board in its oversight of ESG matters as follows: and recruitment efforts and makes recommendations to the Board concerning its committee
structure, the membership of committees of the Board and the chairpersons of the respective
Environmental Sustainability committees, including committee member qualification, appropriate delegations of authority to its
various committees, and exercise of its oversight function with regard to ESG matters through the
The Audit and Risk Committee is broadly responsible for assisting the Board in overseeing risks
operation of its committees.
associated with climate change and other environmental compliance and sustainability matters.
The Committee regularly discusses with management the Company’s significant risk exposures
and the steps management has taken to monitor and control such exposures, including the
Company’s risk assessment and risk management guidelines and policies. Cybersecurity
The Technology Committee is responsible for assessing the technical capabilities of the Company Our Chief Information Security Officer leads a dedicated cybersecurity team that drives a global
in all phases of its activities and the risks and opportunities such capabilities present in relation program based on risk management and defense-in-depth strategies. We place a high priority on the
to corporate strategies and plans. Among other matters, it is charged with assisting the Board in security of our information and operational technologies in each of our global business units. We focus
identifying and analyzing significant emerging scientific, technological, and product or process- on continuous improvement to meet and exceed industry and regulatory cybersecurity standards
related innovations and current or emerging industry or geopolitical developments regarding the to protect our personnel, our intellectual property, and our customers’ sensitive data. We protect,
same, that could disrupt or present opportunities to the Company’s overall business strategy. From control, monitor, and test our systems by leveraging governance processes, and both proactive and
an ESG perspective, it is expected in particular that the Technology Committee’s work will enhance reactive technology. We also closely track national vulnerability databases and threat intelligence
that of the Audit and Risk Committee in overseeing the impact of, and the Company’s response to, reporting from several national, international, public, and private organizations. Our employees are
the many challenges and opportunities presented by climate change. trained to be an additional line of defense through education and awareness training programs and
regular phishing exercises to have a “healthy sense of paranoia” against cyber threats.

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Ethics and Compliance

ATI is committed to more than just adherence to laws and regulations. All employees are provided with a copy of the Code of Ethics. Each year, we require all officers
and managers to certify as to their understanding of and compliance with the Code of Ethics. In
Our commitment is to reflect the highest level of integrity and ethics addition, all directors, officers and other employees must annually complete an interactive online
in our dealings with each other, our customers, our suppliers, our ethics course addressing the Code of Ethics. This course is part of ATI’s broader ethics and
compliance program, which includes online ethics training that is administered by a third party.
stockholders, the public, and the government agencies with whom
In 2021, ATI’s online ethics courses addressed:
we engage. ATI’s Corporate Guidelines for Business Conduct and
Ethics (our “Code of Ethics”) are a reminder and summary of key ► Anti-corruption/anti-bribery
► Cybersecurity
Company policies applicable to the conduct of all of our employees in ► Protecting intellectual property
every part of the world. ► Sexual harassment
► Diversity and inclusion
Our Corporate Guidelines for Business Conduct and Ethics (our “Code of Ethics”) apply ► Reporting ethical concerns
to all directors, officers and employees, including our principal executive officer, our principal
We encourage employees to communicate concerns before they become problems. We believe
financial officer, and our controller and principal accounting officer. We require all directors,
that building and maintaining trust, respect and communication between employees and
officers and employees to adhere to our Code of Ethics in addressing legal and ethical issues
management and between fellow employees is critical to the overarching goal of efficiently
encountered in their work. Ongoing training and annual compliance questionnaires ensure
producing high quality products, providing the maximum level of customer satisfaction, and
compliance and diligence.
ultimately fueling profitability and growth.
Our Code of Ethics requires that our directors, officers and employees avoid conflicts of interest,
The ATI Ethics Helpline provides for confidential, secure, and anonymous reporting and is available
comply with applicable laws, conduct business in an honest and ethical manner, and otherwise
24 hours a day. Additionally, our Chief Compliance Officer and ethics officers at our operating
act with integrity and honesty in all of their actions by or on behalf of the Company. It includes a
companies also provide confidential resources for employees to surface their concerns without
financial code of ethics specifically for our Chief Executive Officer, our Chief Financial Officer, and
fear of reprisal.
all other financial officers and employees, which supplements the general principles in the Code
of Ethics and is intended to promote honest and ethical conduct, full and accurate reporting, and Additionally, we have joined the Business Ethics Leadership Alliance which has over 330 member
compliance with laws, as well as other matters. companies and focuses on leadership in ethics.

Only the Audit Committee of the Board can amend or grant waivers from the provisions of
the Code of Ethics relating to the Company’s executive officers and directors, and any such
amendments or waivers will be promptly posted on our website at ATImetals.com. To date, no
such amendments have been made or waivers granted.

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Supply Chain Responsibility and Supplier Expectations Responsible Procurement/Ethical Sourcing

Compliance with our Supplier Expectations and Supply Chain Policies is a fundamental requirement ATI’s policy is to only purchase materials from legitimate and reputable suppliers, and to maintain a
of conducting business with ATI. In the event a supplier fails to comply with our Supplier Expectations sustainable and responsible supply chain that does not in any way contribute to human rights abuses,
and Supply Chain Policies, ATI reserves the right to take appropriate action, which may include, without fuel conflict, or benefit illegal armed groups. In accordance with this policy, ATI has implemented
limitation, suspension and/or termination of engagement with the supplier. ATI’s Supplier Expectations internal risk-based due diligence procedures designed to provide transparency to the origin of conflict
and Supply Chain Policies are outlined on our public website and address the following: minerals in our supply chain. These procedures are based around three main elements:

A. Integrity + Ethics - ATI expects all of our suppliers to conduct their business ethically and with 1. Product Risk Assessment
integrity and to comply with the basic principles set forth in ATI’s Corporate Guidelines for Business
Conduct and Ethics. This includes compliance with all applicable local, national, and international 2. Supplier Risk Assessment
laws and regulations.
3. Reasonable Country of Origin Inquiry
B. Safety, Health, & Environmental Compliance - ATI expects its suppliers to commit to
In accordance with these procedures, for products that we manufactured in 2021, the responses to
operating a safe workplace and to follow and proceed with using all applicable safety, health and
ATI’s Reasonable Country of Origin inquiry during the 2021 calendar year reporting period gave ATI
environmental laws, regulations, and rules.
no reason to believe that any tin, tungsten, tantalum or gold not from scrap or recycled sources that
C. Anti-Corruption & Anti-Bribery Compliance - ATI expects its suppliers to comply in all respects are intentionally added and necessary to the functionality or production of our products (“necessary
with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and all other anti-corruption and conflict minerals”) originated in the Democratic Republic of the Congo or adjoining countries (the
anti-bribery laws and regulations applicable throughout the world. “Covered Countries”).

D. Human Rights –

a. ATI’s Policy Regarding Combatting Trafficking in Persons - ATI expects all of its suppliers
to conduct business in a manner that respects human rights and to comply with all local, national
and international laws, regulations and standards related to employment and labor practices
and the prohibition of human trafficking and slave labor. ATI also expects all of its suppliers
to comply with the basic principles and standards of the ATI Policy Regarding Combatting
Trafficking in Persons. ATI reserves the right to immediately suspend or discontinue engagement
with suppliers and will take appropriate action if we suspect any supplier has violated any law
or regulation related to prohibition of human trafficking and slave labor or has not met the
standards of the ATI Policy Regarding Combatting Trafficking in Persons.

b. Conflict Minerals - ATI expects all of its suppliers to conduct business in a manner that
respects human rights and not to support sources or parties that contribute to human rights
abuses. ATI expects its suppliers to be aware of the requirements of the Dodd-Frank Act and to
fully support ATI’s Dodd-Frank Act compliance efforts by providing transparency into the supply
chain from the original source to ATI. ATI will immediately suspend or discontinue engagement
with any supplier where we have identified that such supplier is sourcing from, or linked to, any
party that supports illegal armed groups, fuels conflict, contributes to human rights abuses, or is
not in compliance with the rules promulgated under the Dodd-Frank Act.

See more at ATIMetals.com About ATI-Suppliers.

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TABLE 1. SUSTAINABILITY DISCLOSURE TOPICS &

ACCOUNTING METRICS
Under the Sustainability Accounting Standards Board (“SASB”) sustainable industry classification system, we fall within the Iron & Steel
Producers industry classification. We do not engage in integrated steelmaking. Although our operations include Electric Arc Furnaces (EAFs),
which use scrap steel, we do not melt carbon steel or operate iron and steel foundries, nor is our production limited to ferrous products. Our
operations could also be included within the Aerospace and Defense category on the basis of the SASB standards and inclusion of certain value-
added processing of aerospace materials. Accordingly, the following also references certain components of the Aerospace and Defense SASB
reporting framework.

TOPIC ACCOUNTING METRIC CATEGORY 2021 - UNIT OF MEASURE CODE REPORT LOCATION

Greenhouse Gas Gross global Scope Quantitative 430,192 Scope 1 and EM-IS-110a.1 Environmental Sustainability
Emissions 1 and 2 emissions, 229,751 Scope 2 Metric - Our 2021 Performance
percentage covered tons (MT) CO2e (-15% and and Progress Toward Our
under emissions-limiting -53%, respectively, compared Goals
regulations to 2018) 0% covered under - GHG Air Emissions
emissions-limiting regulations

Discussion of long-term Discussion and Analysis n/a EM-IS-110a.2 Environmental Sustainability

and short-term strategy - GHG Air Emissions
or plan to manage Scope
1 emissions, emissions
reduction targets, and an
analysis of performance
against those targets

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TOPIC ACCOUNTING METRIC CATEGORY 2021 - UNIT OF MEASURE CODE REPORT LOCATION

Air Emissions1 Air emissions of the Quantitative Metric tons (t) EM-IS-120a.1 Environmental Sustainability
following pollutants: - Additional Environmental
(1) CO, (2) NOx (excluding See in body of report for Efforts
N2O), (3) SOx, (4) detail on 2021 Performance
particulate matter (PM10),
(5) manganese (MnO),
(6) lead (Pb), (7) volatile
organic compounds
(VOCs), and (8) polycyclic
aromatic hydrocarbons
(PAHs)

Energy Management Energy Management (1) Quantitative 12,047,835 EM-IS-130a.1 Environmental Sustainability
Total energy consumed, (2) - Our 2021 Performance
Gigajoules (GJ) consumed
percentage grid electricity, and Progress Toward Our
(3) percentage renewable 19% grid electricity Goals
Using a market based grid - Energy Intensity
mix for 2021 12% of total
energy consumed was
purchased from renewable
sources, including nuclear
power

(1) Total fuel consumed, Quantitative Total Fuel consumed (other EM-IS-130a.2 N/A
(2) percentage coal, (3) than electricity)
percentage natural gas, (4) 8,243,347 MMbtu
percentage renewable
0% coal,
0% renewable

1
Data includes facilities that are otherwise required to report

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TOPIC ACCOUNTING METRIC CATEGORY 2021 - UNIT OF MEASURE CODE REPORT LOCATION

Water Management (1) Total fresh water Quantitative (1) A

 pproximately 4.1 EM-IS-140a.1 Environmental Sustainability
withdrawn, (2) percentage million kilo-gallons - Our 2021 Performance
recycled, (3) percentage (2) Not reported and Progress Toward
in regions with High or (3) 0% Our Goals
Extremely High Baseline - Freshwater Intake
Water Stress

Waste Management (1) Amount of waste Quantitative 165,501 Metric tons (t) of EM-IS-150a.1 Environmental Sustainability
generated, (2) percentage waste was generated and - Material Recycled
hazardous, (3) percentage disposed of in 2021, of
recycled which 2% was hazardous
waste and 81% was
recycled

Workforce Health & (1) Total recordable incident Quantitative (1) 0.85 per 200,000 hours EM-IS-320a.1 Social Engagement -
Safety rate (TRIR), (2) fatality worked Ensuring Workplace Safety
rate, and (3) near miss (2) 0 and a Zero-Injury Culture
frequency rate (NMFR) for (3) Not reported
(a) full-time employees and
(b) contract employees

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TOPIC ACCOUNTING METRIC CATEGORY 2021 - UNIT OF MEASURE CODE REPORT LOCATION

Product Safety Number of recalls issued; Quantitative 0 RT-AE-250a.1 N/A

total units recalled

Number of counterfeit Quantitative 0 RT-AE-250a.2 N/A

parts detected; percentage
avoided

Number of Airworthiness Quantitative 0 RT-AE-250a.3 N/A

Directives received, total
units affected

Total amount of monetary Quantitative 0 RT-AE-250a.4 N/A

losses as a result of legal
proceedings associated
with product safety

Data Security (1) Number of data Quantitative 0 RT-AE-230a.1 N/A

breaches, (2) percentage
involving confidential
information

Description of approach to Qualitative N/A RT-AE-230a.2 Corporate Governance -

identifying and addressing Cybersecurity
data security risks in (1)
company operations and
(2) products

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