ArcelorMittal S.A.

Company Overview

Business Model: ArcelorMittal operates as one of the world’s leading integrated steel and mining companies, primarily engaged in the manufacture, processing, and marketing of a comprehensive range of steel products and the mining of iron ore. Its core value proposition lies in providing essential materials to diverse industries, including automotive, appliance, engineering, construction, and machinery. Revenue is primarily generated through the sale of flat products (sheet, plate), long products (bars, rods, structural shapes), and pipes and tubes, as well as various iron ore products from its captive and seaborne mining operations.

Market Position: ArcelorMittal holds a leading global position as the largest steel producer in Europe and among the largest in the Americas, with a growing presence in Asia, notably through its joint venture AMNS India. The Company maintains a significant market share of approximately 16% in the worldwide automotive market. Its integrated model, encompassing both steel-making and mining operations, provides a competitive advantage in raw material sourcing, with 72% of its iron ore sourced internally in 2025.

Recent Strategic Developments:

• Acquisitions: Completed the acquisition of Nippon Steel Corporation’s 50% equity stake in AMNS Calvert (renamed ArcelorMittal Calvert) in June 2025 for approximately $0.9 billion in cash and loans receivable, recognizing a $1.9 billion acquisition gain. Also acquired Tuper S.A. and Tekno S.A. - Indústria e Comércio in Brazil, and increased interest in ArcelorMittal Tailored Blanks Americas in 2025.
• Divestments: Completed the sale of its operations in Bosnia and Herzegovina (ArcelorMittal Zenica and ArcelorMittal Prijedor) to Pavgord Group in October 2025, resulting in a non-cash loss on disposal of approximately $0.2 billion. The Long Steel Business wind-down in ArcelorMittal South Africa was completed by January 2026.
• Decarbonization Initiatives: Announced plans to construct an advanced manufacturing facility for non-grain-oriented electrical steel (NOES) in Calvert, Alabama, with an estimated net capital expenditure of $1.3 billion, anticipated production in H2 2027. Initiated several renewable energy projects in India, including a 975 MW solar and wind project for AMNS India and three new 1GW solar and wind projects, totaling $1.6 billion in anticipated capital expenditure. Post-year end, announced a strategic €1.3 billion investment for a 2-million-tonne Electric Arc Furnace (EAF) at Dunkirk, France, scheduled for start-up in 2029.
• Post-Year End Developments: Signed an amendment to the Mineral Development Agreement with the Republic of Liberia, extending its duration to 2050, with a $200 million payment to the Government of Liberia. The Board recommended increasing the base annual dividend to $0.60 per share for 2026.

Geographic Footprint: ArcelorMittal's steel-making operations span 14 countries, with 34 integrated and mini-mill facilities. Its mining operations, including captive mines, are located in North America, South America, Africa, and Europe. The Company sells its products to customers in approximately 126 countries. In 2025, crude steel production was approximately 40% in the Americas, 53% in Europe, and 7% in other countries (South Africa, Ukraine).

Cross-Border Operations: ArcelorMittal is incorporated in the Grand Duchy of Luxembourg. Its international presence is extensive, with significant operations and investments across multiple continents. Key international subsidiaries include ArcelorMittal Calvert (USA), ArcelorMittal Dofasco (Canada), ArcelorMittal Mexico, and ArcelorMittal Tubarão (Brazil). The Company engages in strategic joint ventures such as AMNS India (India), VAMA (China), NEMM (China), Borçelik (Turkey), Al Jubail (Saudi Arabia), Ventos de Santo Antonio (Brazil), and Tameh (Poland). Associates include Vallourec (France), China Oriental (Bermuda), DHS Group (Germany), Gonvarri Steel Industries (Spain), and Baffinland (Canada). These multi-jurisdictional operations necessitate compliance with diverse regulatory frameworks, including trade tariffs, environmental regulations, and tax policies across the EU, North America, South America, Asia, and Africa.

Financial Performance

Revenue Analysis

Profitability Metrics (2025):

• Gross Margin: 7.13%
• Operating Margin: 5.91%
• Net Margin: 5.14%

Investment in Growth:

• R&D Expenditure: $335 million (0.55% of sales)
• Capital Expenditures: $4.3 billion
• Strategic Investments: Major capital expenditures in 2025 included 42% for the Liberia expansion project, 22% for the EAF and electrical steels facility at ArcelorMittal Calvert, and 13% for Mardyck electrical steels in France. Decarbonization capital expenditures amounted to $0.3 billion in 2025.

Currency Impact Analysis: ArcelorMittal has significant exposure to foreign exchange fluctuations, particularly with the Euro, Brazilian real, Canadian dollar, Indian rupee, South African rand, Mexican peso, Polish zloty, Argentine peso, and Ukrainian hryvnia against the U.S. dollar. In 2025, foreign exchange gains contributed $256 million to net financing costs, a significant reversal from a $565 million loss in 2024. The Company applies hyperinflationary accounting for its operations in Argentina, which experienced a 31.5% general price index change in 2025.

Business Segment Analysis

North America

Financial Performance:

• Sales: $12.335 billion (+3.7% YoY)
• Operating income: $2.205 billion (+68.3% YoY)
• Crude steel production: 7.755 million tonnes (+2.9% YoY)
• Total steel shipments: 10.283 million tonnes (+2.2% YoY)
• Average steel selling price: $1,014/tonne (+2.9% YoY) Key Growth Drivers: The acquisition of the remaining 50% equity stake in AMNS Calvert in June 2025 significantly boosted performance, contributing a $1.9 billion acquisition gain to operating income. The commissioning of a new 1.5 million tonnes EAF and caster at ArcelorMittal Calvert in June 2025, and plans for a new 150,000 tonnes/year NOES facility by H2 2027, are key strategic investments. Product Portfolio: Flat products from integrated and mini-mill sites, long products, and tailored blanks (ArcelorMittal Tailored Blanks Americas). Market Dynamics: The segment operates under the influence of U.S. Section 232 measures, which imposed a 50% tariff on all steel imports from June 2025. U.S. import penetration decreased to approximately 18% in 2025.

Brazil

Financial Performance:

• Sales: $11.172 billion (-9.9% YoY)
• Operating income: $608 million (-56.5% YoY)
• Crude steel production: 14.350 million tonnes (-1.3% YoY)
• Total steel shipments: 13.949 million tonnes (-0.9% YoY)
• Average steel selling price: $736/tonne (-9.8% YoY) Key Growth Drivers: Strategic acquisitions in 2025 included Tuper S.A. (Brazilian pipe producer) and Tekno S.A. - Indústria e Comércio (coil coating). A new sections mill at Barra Mansa was completed in H2 2025, increasing capacity by 0.3 million tonnes/year. The Serra Azul mine facilities, designed to produce 4.5 million tonnes/year of DRI quality pellet feed, commenced commissioning in Q4 2025. Product Portfolio: Flat products from two integrated sites and long products from six integrated and mini-mill sites. Market Dynamics: Brazil experienced 5% inflation and a slowed GDP growth of 2.6% in 2025, impacting steel demand and pricing.

Europe

Financial Performance:

• Sales: $28.793 billion (-3.9% YoY)
• Operating income: $522 million (+35.2% YoY)
• Crude steel production: 29.166 million tonnes (-6.6% YoY)
• Total steel shipments: 28.408 million tonnes (-0.9% YoY)
• Average steel selling price: $894/tonne (-1.8% YoY) Key Growth Drivers: Decarbonization investments are a major focus, including a €1.2 billion investment in a first EAF in Dunkirk (post-year end, confirmed €1.3 billion for a 2-million-tonne EAF by 2029) and a €500 million new electrical steels production unit in Mardyck (expected to produce first coils in 2026). The Company acquired Flémalle production facilities in April 2025. Product Portfolio: Flat products from eight integrated and mini-mill sites and long products from eight integrated and mini-mill sites. Market Dynamics: The European market is characterized by a ~21% import penetration in 2025. The EU-ETS and the Carbon Border Adjustment Mechanism (CBAM), which became financially binding from January 1, 2026, are significant regulatory factors impacting operational costs and competitive dynamics.

India and JVs

Financial Performance:

• Income from investments: $635 million (-18.5% YoY) AMNS India (100% basis):
• Crude steel production: 7.219 million tonnes (-4.5% YoY)
• Steel shipments: 7.863 million tonnes (-0.9% YoY)
• Sales: $6.026 billion (-7.5% YoY) Key Growth Drivers: AMNS India is undergoing a Phase 1 expansion with $7.7 billion in capital expenditures to increase Hazira facility production to 15 million tonnes of rolled products by H2 2026. Plans for a greenfield integrated steel plant (8.2 million tonnes annual capacity) at Rajayapeta, Andhra Pradesh, aim to scale total steelmaking capacity to 40 million tonnes per annum. A 975 MW solar and wind project started providing clean electricity to AMNS India in Q2 2025, reducing carbon emissions by 1.5 million tonnes per year. Product Portfolio: Integrated flat steel production, iron ore pellets. Market Dynamics: India's GDP grew by 7.7% in 2025, with apparent steel consumption growing by approximately 8%, indicating strong market demand.

Sustainable Solutions

Financial Performance:

• Sales: $10.501 billion (-2.1% YoY)
• Operating income: $142 million (+149.1% YoY) Key Growth Drivers: This segment focuses on circular economy solutions, including recycling (approximately 1 million tonnes combined collection capacity) and renewable energy projects. The Wire Solutions business was transferred to this segment in H2 2025. Product Portfolio: Specialized steel products (Industeel), recycling services, and renewable energy solutions. Market Dynamics: Operates across more than 60 countries, addressing growing demand for sustainable products and services.

Mining

Financial Performance:

• Sales: $3.232 billion (+21.4% YoY)
• Operating income: $789 million (+2.5% YoY)
• Iron ore production: 35.3 million tonnes (+26.5% YoY)
• Iron ore shipments: 36.3 million tonnes (+37.5% YoY) Key Growth Drivers: The Liberia mine expansion project, with a revised capital expenditure of $1.8 billion, is commissioning to reach 20 million tonnes per year by 2026. The Serra Azul mine in Brazil is also undergoing commissioning for DRI quality pellet feed production. Product Portfolio: Iron ore lump, fines, concentrate, pellets, and sinter feed. Market Dynamics: Global iron ore market reference prices averaged $101.87/tonne in 2025. ArcelorMittal sourced 72% of its iron ore internally in 2025.

International Operations & Geographic Analysis

Revenue by Geography:

International Business Structure:

• Subsidiaries: ArcelorMittal operates numerous wholly-owned and majority-owned subsidiaries globally, including ArcelorMittal Dofasco (Canada), ArcelorMittal Mexico, ArcelorMittal Tubarão (Brazil), and ArcelorMittal Calvert (USA). These entities manage local production, sales, and distribution.
• Joint Ventures: Strategic partnerships are crucial for market access and growth. Key JVs include AMNS India (60% interest), VAMA (China, 50%), NEMM (China, 50%), Borçelik (Turkey, 50%), Al Jubail (Saudi Arabia, 33.34%), Ventos de Santo Antonio (Brazil, 55%), and Tameh (Poland, 50%). These JVs often involve shared capital, technology, and market expertise.
• Licensing Agreements: Not explicitly detailed in the filing.

Cross-Border Trade:

• Export Markets: Export sales to the U.S. amounted to $6.9 billion in 2025. The Company sells products to customers in approximately 126 countries.
• Import Dependencies: ArcelorMittal sources 72% of its iron ore internally and 91% of its coke internally, reducing external import dependencies for these key raw materials. However, it relies on external scrap and DRI, sourcing 55% externally.
• Transfer Pricing: Transfer pricing policies are in place for inter-company transactions, subject to international tax regulations and BEPS compliance.

Capital Allocation Strategy

Shareholder Returns:

• Share Repurchases: $0.3 billion in 2025. Under the current program (announced April 7, 2025, for up to 10 million shares), 2 million shares were repurchased for $58 million by December 31, 2025. From 2020 to 2024, $11.1 billion of shares were repurchased.
• Dividend Payments: $421 million in 2025 ($0.55 per share), paid in two installments.
• Dividend Yield: Not explicitly stated, but based on 2025 dividend and share price increase, it would be calculated from the $0.55/share dividend.
• Future Capital Return Commitments: The Company expects to pay a base annual dividend (progressively increased over time). A minimum of 50% of free cash flow (after base annual dividend) is allocated to a share buyback program, provided net debt to EBITDA is not greater than 1.5x. The Board recommended increasing the base annual dividend to $0.60 per share for 2026.

Balance Sheet Position (as of December 31, 2025):

• Cash and Equivalents: $5.392 billion
• Total Debt: $13.4 billion
• Net Debt: $7.9 billion
• Credit Rating: Standard & Poor's upgraded to 'BBB' (June 9, 2025); Moody’s upgraded to ‘Baa2’ (December 4, 2025).
• Debt Maturity Profile:| Type of indebtedness | 2026 ($ billions) | 2027 ($ billions) | 2028 ($ billions) | 2029 ($ billions) | 2030 and beyond ($ billions) | Total ($ billions) | |:---------------------|:------------------|:------------------|:------------------|:------------------|:-----------------------------|:-------------------| | Bonds | 1.1 | 1.2 | 0.6 | 0.5 | 4.5 | 7.9 | | Commercial paper | 0.9 | — | — | — | — | 0.9 | | Lease liabilities and other loans | 0.7 | 0.4 | 0.8 | 0.3 | 2.4 | 4.6 | | **Total gross debt** | **2.7** | **1.6** | **1.4** | **0.8** | **6.9** | **13.4** | The average debt maturity was 7.7 years as of December 31, 2025.

Cash Flow Generation:

• Operating Cash Flow: $4.808 billion
• Free Cash Flow: Approximately $0.508 billion (Operating Cash Flow of $4.808 billion minus Capital Expenditures of $4.3 billion).
• Cash Conversion Metrics: Operating working capital release of $0.5 billion in 2025. The Company relies on its true sale of receivables programs, with $5.0 billion of trade receivables sold at December 31, 2025.

Currency Management: The Company's cash holdings are diversified across major currencies, though specific breakdowns are not provided. The net debt translation impact table (provided in the Financial Performance section) illustrates the sensitivity of net debt to currency fluctuations, particularly for the Euro. Financial hedging instruments and strategies are employed to manage foreign exchange risk, as evidenced by the significant foreign exchange gains in 2025.

Operational Excellence

Production & Service Model: ArcelorMittal employs an integrated steel and mining production model. In 2025, approximately 41.2 million tonnes of crude steel were produced through the basic oxygen furnace (BOF) process, and 14.4 million tonnes through the Electric Arc Furnace (EAF) process, totaling 55.6 million tonnes against an achievable capacity of 74.6 million tonnes. The Company's operational philosophy emphasizes internal sourcing of key raw materials, with 72% of iron ore and 91% of coke consumed sourced internally in 2025.

Global Supply Chain Architecture: Key Suppliers & Partners:

• Slab Supply: Nippon Steel Corporation - provides slabs to ArcelorMittal Calvert under a new seven-year domestic slab supply agreement, averaging 750,000 metric tonnes per year.
• Energy Supply: EDF - signed an agreement in December 2025 for long-term low-carbon electricity supply to French operations.
• Renewable Energy Partners: Greenko Group, Atlas Renewable Energy, Casa dos Ventos - strategic collaborations for developing and supplying renewable electricity to operations in India and Brazil.

Facility Network:

• Manufacturing: Operates 34 integrated and mini-mill facilities in 14 countries. Key production locations include ArcelorMittal Calvert (USA) with a new 1.5 million tonnes EAF, ArcelorMittal Tubarão (Brazil), ArcelorMittal Dofasco (Canada), and various sites across Europe (e.g., Dunkirk, Mardyck, Gijón).
• Research & Development: Maintains 14 research sites across 9 countries, focusing on sustainable products, low-CO2 steel production, and advanced manufacturing processes.
• Distribution: Supported by a network of 18 deep-water port facilities globally, facilitating efficient raw material imports and product exports.

Operational Metrics (2025):

• Crude Steel Production: 55.6 million tonnes (74.6 million tonnes achievable capacity)
• Steel Shipments: 54.0 million tonnes
• Iron Ore Production: 48.8 million tonnes
• Iron Ore Consumption: 69.3 million tonnes (49.9 million tonnes sourced internally)
• Coke Consumption: 15.8 million tonnes (14.4 million tonnes sourced internally, 91%)
• Scrap & DRI Consumption: 24.8 million tonnes (13.6 million tonnes sourced externally, 55%)
• Ukraine Operations (ArcelorMittal Kryvyi Rih): Open pit mines operated at 73% capacity, steel facilities at 35% capacity.

Market Access & Customer Relationships

Go-to-Market Strategy: Distribution Channels:

• Direct Sales: ArcelorMittal primarily sells its products in local markets to customers in approximately 126 countries, leveraging regional sales forces and direct customer relationships.
• Channel Partners: While not explicitly detailed, the Company's extensive network of joint ventures and associates (e.g., Gonvarri Steel Industries for steel processing, VAMA for automotive steel finishing) suggests a reliance on strategic partnerships for market penetration and specialized product distribution.
• Digital Platforms: Not explicitly detailed in the filing.

Customer Portfolio: Enterprise Customers:

• Tier 1 Clients: The Company serves major customers in the automotive, appliance, engineering, construction, and machinery industries globally. Its 16% market share in the worldwide automotive market highlights strong relationships with leading automotive manufacturers.
• Strategic Partnerships: Collaborations with entities like Nippon Steel Corporation for slab supply to ArcelorMittal Calvert demonstrate strategic customer-supplier relationships.
• Customer Concentration: The construction market represented 20% of revenue in 2025, and automotive and mobility represented 17% of revenue, indicating significant, but diversified, customer segments.

Regional Market Penetration: ArcelorMittal maintains leading market positions in Europe and the Americas, supported by its extensive operational footprint and sales network. Its growing presence in Asia, particularly through AMNS India, targets high-growth emerging markets. The Company's ability to sell products in 126 countries underscores its broad global market penetration.

Competitive Intelligence

Global Market Structure & Dynamics

Industry Characteristics: The global steel industry in 2025 was characterized by broadly stable apparent steel consumption (ASC) globally, with a ~2% decline in China offset by ~1.5% growth ex-China and ~8% growth in India. Global steel production declined by ~2% year-on-year. The market is influenced by significant trade measures, including U.S. Section 232 tariffs (50% on most steel imports from June 2025), EU safeguard measures, and the implementation of the Carbon Border Adjustment Mechanism (CBAM). Raw material prices (iron ore, coking coal, scrap) and energy costs (natural gas, electricity, CO2 emission allowances) are key drivers of profitability. Chinese finished steel exports continued to rise, reaching 119 million tonnes in 2025, intensifying global competition.

Competitive Positioning Matrix:

Direct Competitors

Primary Competitors: The filing does not explicitly name direct competitors. However, ArcelorMittal operates in a highly competitive global market with numerous regional and international steel producers. Its competitive landscape is shaped by global market share dynamics, regional strengths of other major players, and the impact of trade policies.

Regional Competitive Dynamics: Competitive dynamics vary significantly by region. In the U.S., the 50% Section 232 tariffs from June 2025 create a distinct competitive environment. In Europe, the EU-ETS and CBAM regulations impose specific cost structures and compliance requirements, influencing the competitive landscape. The growing presence in India positions the Company against local and international players in a rapidly expanding market. Chinese finished steel exports, reaching 119 million tonnes in 2025, exert global competitive pressure.

Risk Assessment Framework

Strategic & Market Risks

Global Market Dynamics: The Company is exposed to fluctuations in global GDP growth (estimated 2.9% in 2025), apparent steel consumption (broadly stable globally in 2025), and steel prices, which are influenced by regional supply-demand balances and trade flows. Increased import penetration in key markets (e.g., EU at ~21% in 2025) and rising Chinese finished steel exports (119 million tonnes in 2025) pose competitive threats. Technology Disruption: The steel industry is undergoing a significant decarbonization transition. Failure to successfully develop and implement low-carbon iron-making technologies (expected to be viable at scale after 2030) or adapt to evolving customer demands for sustainable products could impact long-term competitiveness. Customer Concentration: While diversified across industries, significant revenue contributions from construction (20%) and automotive (17%) segments imply exposure to downturns in these sectors.

Operational & Execution Risks

Global Supply Chain Vulnerabilities: Despite high internal sourcing of iron ore (72%) and coke (91%), reliance on external scrap and DRI (55% externally sourced) exposes the Company to raw material price volatility and supply chain disruptions. Regional Disruptions: Operations in Ukraine (ArcelorMittal Kryvyi Rih) continue to be impacted by geopolitical conflict, operating at reduced capacities (73% for open pit mines, 35% for steel facilities). Operations in Mexico are exposed to drug-related violence. Trade Restrictions: The Company faces risks from evolving trade policies, including U.S. Section 232 tariffs (50% from June 2025), Canadian surtaxes and Tariff-Rate Quotas, and EU safeguard measures, which can restrict market access and increase costs.

Financial & Regulatory Risks

Currency & Financial Risks: Exposure to multiple currencies (EUR, BRL, CAD, INR, ZAR, MXN, PLN, ARS, UAH against USD) creates foreign exchange risk, impacting net debt translation and earnings. The Company's net debt increased to $7.9 billion in 2025. Reliance on true sale of receivables programs ($5.0 billion sold in 2025) could pose liquidity risks if market conditions deteriorate. Regulatory & Compliance Risks: Operating in numerous jurisdictions necessitates compliance with a complex array of environmental (e.g., EU-ETS, CBAM, IED 2.0), trade (e.g., export controls, sanctions), and tax regulations (e.g., Pillar Two Model Rules, transfer pricing). Non-compliance or changes in regulations can lead to significant costs, penalties, or operational restrictions.

Geopolitical & External Risks

Country-Specific Risks:

• Political Risk: Geopolitical instability, such as the conflict in Ukraine, directly impacts operations and asset values. The ongoing arbitration with the Republic of Italy regarding Acciaierie d'Italia S.p.A. highlights risks associated with government intervention.
• Economic Risk: Economic instability in key markets, such as inflation in Brazil or currency devaluation in Argentina, can affect local demand and profitability.
• Regulatory Changes: Frequent changes in local laws, such as new environmental standards in Brazil or mining regulations in Mexico, require continuous adaptation and investment.

Innovation & Technology Leadership

Research & Development Focus: ArcelorMittal maintains a robust R&D program with an expenditure of $335 million in 2025. The focus areas include developing sustainable products and solutions for sustainable lifestyles, construction, infrastructure, and energy generation. Key initiatives include low-CO2 steels (reducing carbon footprint by up to 65%), XCarb® recycled and renewably produced solutions (10 new products commercialized in 2025), and advanced electrical steels (e.g., 420Save 27-14).

Global R&D Network:

• R&D Centers: The Company operates 14 research sites across 9 countries, fostering a global approach to innovation.
• Innovation Pipeline: Significant projects in the pipeline include the Volteron™ iron electrolysis project (successfully operated 1:1 vertical cell pilot), Green Blast Furnace Top Gas Recycling (techno-economic feasibility validated), and advanced models for improving energy efficiency across its furnace network (implemented in 14 furnaces, achieving up to 7% higher output). New EAFs are being developed and commissioned in Gijón, Spain (2026), and Dunkirk, France (2029).

Intellectual Property Portfolio: ArcelorMittal holds a substantial intellectual property portfolio, comprising more than 16,000 patents and patent applications, organized into over 1,015 patent families. In 2025, 128 new inventions were newly protected, demonstrating continuous innovation.

Technology Partnerships:

• Strategic Alliances: Collaborations with partners like EDF for low-carbon electricity in France and Greenko Group for renewable energy projects in India are critical for advancing decarbonization goals.
• Research Collaborations: The Company engages in research collaborations to develop new technologies, such as the new route for tire-cord with 50-100% scrap developed at European plants.

Leadership & Governance

Executive Leadership Team (as of December 31, 2025)

International Management Structure: The Company employs a decentralized management structure with regional leadership for key segments such as North America, Brazil, Europe, Mining, Ukraine, and AMNS India. This structure allows for local market responsiveness while maintaining centralized oversight from the Executive Office.

Board Composition: As of December 31, 2025, the Board of Directors comprises 9 directors, with 6 identified as independent. The Board has an average age of 62 years and an average serving period of 11 years. Four of the nine Board positions are held by women. Key committees include the Audit & Risk Committee (4 members, 100% independent, chaired by Patricia Barbizet), the Appointments, Remuneration and Corporate Governance (ARCG) Committee (3 members, 100% independent, chaired by Karyn Ovelmen), and the Sustainability Committee (3 members, 67% independent, chaired by Clarissa Lins). The Company adheres to a director share ownership policy and an independent director term limit of 12 consecutive years.

Regulatory Environment & Compliance

Multi-Jurisdictional Regulatory Framework: ArcelorMittal operates under a complex and evolving multi-jurisdictional regulatory framework across its global footprint. Primary Regulatory Environments:

• EU: Subject to the EU-ETS (Phase IV, 2021-2030), Carbon Border Adjustment Mechanism (CBAM, financially binding from January 1, 2026), Industrial Emission Directive (IED 2.0), Corporate Sustainability Reporting Directive (CSRD), and Corporate Sustainability Due Diligence Directive (CSDDD). Free ETS allocations will phase out from 2026 through 2034.
• Canada: Subject to Ontario Emissions Performance Standards (EPS) carbon pricing (CAD$50/t CO2e to CAD$170/t by 2030), Quebec’s GHG emission reduction targets, and Clean Fuel Regulations. Also impacted by Canadian surtaxes on Chinese steel and aluminum, and a steel Tariff-Rate Quota (TRQ) system.
• U.S.: Governed by comprehensive environmental laws including the Clean Air Act, Clean Water Act, and RCRA. New source performance standards for EAFs were finalized in 2024.
• Brazil: Subject to new environmental licensing laws, national maritime policy, and incentives for industrial decarbonization.
• India: Operations are governed by the Environment Protection Act, 1986, and various social and labor laws.
• Mexico: Subject to new wastewater discharge standards, reforms to the National Mining Regulation, and state-level green taxes on CO2 emissions.
• Ukraine: Operations are impacted by the State Environmental Policy Strategy, updated Nationally Determined Contribution (NDC), and new laws on pollutant release and industrial pollution control.

Cross-Border Compliance:

• Export Controls: The Company navigates various export controls, including EU bans on Russian and Belarusian steel products and technology transfer restrictions.
• Sanctions Compliance: Compliance with multi-jurisdictional sanctions regimes is critical, particularly concerning operations in regions like Ukraine.
• Anti-Corruption: The Company's Insider Dealing Regulations, updated in 2023, apply worldwide, and it maintains compliance programs to address anti-bribery laws.

International Tax Strategy:

• Transfer Pricing: Inter-company pricing policies are in place to comply with international tax regulations and documentation requirements.
• Tax Treaties: The Company leverages tax treaties to manage its global tax burden, though specific planning opportunities are not detailed.
• BEPS Compliance: ArcelorMittal adopted Pillar Two Model Rules, effective January 1, 2024, and is subject to minimum tax regulations. The statutory tax rate in Luxembourg, its jurisdiction of incorporation, is 23.87%.

Environmental & Social Impact

Global Sustainability Strategy: ArcelorMittal is committed to a decarbonization strategy with an objective of achieving net zero by 2050. This strategy involves significant investments in low-carbon iron-making technologies and renewable energy.

Environmental Commitments:

• Climate Strategy: The Company aims for net zero by 2050. For AMNS India, a target to reduce carbon intensity by 20% by 2030 (against a 2021 baseline) is in place, supported by renewable energy projects.
• Carbon Neutrality: The long-term goal is net zero by 2050, with interim targets and investments in decarbonization projects across its global operations.
• Renewable Energy: Significant investments are being made in clean energy. In 2025, a 975 MW solar and wind project in India started providing clean electricity to AMNS India. Three new renewable energy projects in India totaling 1GW were announced, doubling the Company’s renewable energy capacity in India to 2GW and increasing global capacity to 3.3GW by 2028. Renewable energy projects are also under development in Brazil and Argentina.

Regional Sustainability Initiatives:

• EU: The Company is actively engaged with the EU's "Fit for 55" package, EU-ETS, and CBAM, which drive decarbonization efforts and compliance costs in Europe.
• Supply Chain: While not explicitly detailed, the Company's sustainability report (expected Q2 2026) is likely to cover global supplier ESG requirements.

Social Impact by Region:

• Community Investment: The Company engages in local community programs, though specific regional priorities are not detailed in the filing.
• Labor Standards: ArcelorMittal operates under numerous Collective Labor Agreements (CLAs) globally, covering a significant portion of its workforce in North America (45%), South America (most employees), Europe (e.g., 99% in Poland, ~100% in Spain), and South Africa (70%). The Company maintains employment and wages in Ukraine despite reduced production capacity due to conflict.
• Health and Safety: In 2025, the Lost Time Injury Frequency Rate (LTIFR) was 0.65x (down from 0.70x in 2024), and there were 6 fatalities (down from 14 in 2024). The Fatality Frequency Rate (FFR) was 0.014x (down from 0.035x). Safety performance is a key metric in executive incentive plans.
• Diversity & Inclusion: Women held 20.5% of management positions in 2025 (up from 19% in 2024), and four of the nine Board of Directors positions. An Equal Opportunity and Non-Discrimination Policy is scheduled for launch in 2026.

Currency Management & Financial Strategy

Multi-Currency Operations: ArcelorMittal conducts operations in numerous currencies, leading to significant currency exposure. Its Euro-denominated debt was €4.0 billion and Euro-denominated investments were €8.5 billion as of December 31, 2025. The Company's financial results are sensitive to exchange rate movements, particularly for the Euro, Brazilian real, Canadian dollar, Indian rupee, South African rand, Mexican peso, Polish zloty, Argentine peso, and Ukrainian hryvnia against the U.S. dollar.

Currency Exposure (Net Debt Translation Impact for 10% change in 2025, $ millions):

Hedging Strategies: While specific details on hedging instruments are not extensively disclosed, the Company's financial results reflect the impact of foreign exchange gains and losses within its net financing costs. The significant foreign exchange gain of $256 million in 2025 (compared to a $565 million loss in 2024) suggests active currency management or favorable market movements. The Company's operational diversification across multiple geographies may also provide a natural hedge against certain currency exposures.