SEC Company Response from NATIONAL STEEL (SID) — Dec 8, 2011
NATIONAL STEEL CO
Date: Dec. 8, 2011 · CIK: 0001049659 · Accession: 0001292814-11-003093
AI Filing Summary & Sentiment
Referenced dates: November 23, 2011
Letter
December 8, 2011 Via E-mail and EDGAR Transmission Mr. Terence O’Brien Accounting Branch Chief Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-4631
Re: National Steel Company Form 20-F for the fiscal year ended December 31, 2010 Filed June 20, 2011 File No. 1-14732 Response to Staff Comment Letter dated November 23, 2011
Dear Mr. O’Brien:
Companhia Siderúgica Nacional (the “Company”) received a comment letter from the staff of the United States Securities and Exchange Commission (the “Staff”) on November 23, 2011, concerning the Company’s annual report on Form 20-F filed on June 20, 2011 (the “2010 Form 20-F”). This letter provides the Company’s responses to the Staff’s comments. For your convenience, we have reproduced below in italics the Staff’s comments numbered 1 through 25 and have provided responses immediately below such comments. All page numbers referred to herein are to the 2010 Form 20-F.
SEC Comment No. 1.
Information on the Company, page 15
Business Overview, page 17
1) We note your disclosure of sales of steel products by geographic region for 2009 and 2010 on page 39. In future filings, please provide the breakdown of total revenues by category and geographic market for each of the last three financial years. Please also provide this information for your other business segments in future filings. Refer to Item 4.B.2 of Form 20-F.
Response to Comment No. 1.
We note the Staff’s comment and will include the information requested in future filings.
Companhia Siderúrgica Nacional
Escritório Central
Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center
Cep: 04538-132 - São Paulo - SP
SEC Comment No. 2.
2) In future filings, please provide the information required by Item 4.B of Form 20-F for your cement segment.
Response to Comment No. 2.
We note the Staff’s comment and will include the information requested in future filings.
SEC Comment No. 3.
3) We note your disclosure of proven and probable resources in this section. The provisions in Industry Guide 7 preclude the use of any terms other than proven or probable reserves for disclosure in SEC documents. Please correct or remove this terminology from your filing in future filings.
Response to Comment No. 3.
We note the Staff’s comment and will revise our future filings to correct our use of terminology where applicable and remove information and terms not permitted under Industry Guide 7.
SEC Comment No. 4.
Mineral Resources, page 33
4) Within your filing, you use the term resources in reference to quantity (tonnage) estimates. The provisions in Industry Guide 7 preclude the use of any terms other than proven and/or probable reserves for disclosure in SEC documents. However, you may disclose quantity estimates for mineralized material referencing mineralization that has been sufficiently sampled at close enough intervals to reasonably assume continuity between samples within the area of influence. In this instance, you would need to disclose that such material would not qualify as a reserve, until a comprehensive evaluation based upon unit cost, grade, recoveries, and other material factors concludes both legal and economic feasibility. Mineralized material should only be reported as an in place tonnage and grade, and should not be disclosed as units of product, such as ounces of gold or pounds of copper, as these can be confused with reserves. Please note that mineralized material does not include material reported as reserves or tonnage and grades estimated by using geologic inference, which are sometimes classed as inferred resources or possible reserves by some evaluators.
Companhia Siderúrgica Nacional
Escritório Central
Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center
Cep: 04538-132 - São Paulo - SP
· Remove the terms measured, indicated, inferred mineral resources, and associated estimates from your future filings.
· If the quantities associated with the above terms meet the requirements of mineralized material, disclose the estimates as mineralized material in your future filings.
· Please do not disclose estimates based on geologic inference, such as inferred resources or possible reserves in your future filings.
Response to Comment No. 4.
We note the Staff’s comment and will revise our future filings to correct our use of terminology where applicable and remove information and terms not permitted under Industry Guide 7.
SEC Comment No. 5.
5) Please disclose the following information within or adjacent to your reserve tables in your future filings:
· A statement clarifying the extent to which your reserve estimates incorporate losses for mine dilution and mining recovery.
· The cutoff grade
· The metallurgical recovery factor for each of your mines.
· All historic three-year average commodity prices and currency conversion factors that were used to estimate your reserves.
· The percentage of your ownership of each mine and a statement clarifying whether quantities disclosed are for the entire mine/deposit or just your share.
· A statement indicating whether your resource estimates are inclusive or exclusive of your reserve estimates.
Response to Comment No. 5.
We note the Staff’s comment and will include the information requested adjacent to our reserve tables in future filings.
Companhia Siderúrgica Nacional
Escritório Central
Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center
Cep: 04538-132 - São Paulo - SP
SEC Comment No. 6.
6) Proven and probable reserves are disclosed for your property. Please forward to our engineer as supplemental information and not as part of your filing, your information that establishes the legal, technical, and economic feasibility of your Casa de Pedra and Santa Barbara mines which you have designated as reserves, as required by Section C of Industry Guide 7 or Rule 12b-4 of the Exchange Act. The information requested includes, but is not limited to:
· Property and geologic maps
· Description of your sampling and assaying procedures
· Drill-hole maps showing drill intercepts
· Representative geologic cross-sections and drill logs
· Description and examples of your cut-off calculation procedures
· Cutoff grades used for each category of your reserves and resources
· Justifications for the drill hole spacing used to classify and segregate proven and probable reserves
· A detailed description of your procedures for estimating reserves
· Copies of any pertinent engineering or geological reports, and executive summaries of feasibility studies or mine plans which including the cash flow analyses
· A detailed permitting and government approval schedule for the project, particularly identifying the primary environmental or construction approval(s) and your current location on that schedule.
To minimize the transfer of paper, please provide the requested information on a CD, formatted as Adobe PDF files and provide the name and phone number for a technical person our engineer may call, if he has technical questions about your reserves.
In the event your company desires the return of this supplemental material, please make a written request with the letter of transmittal and include a pre-paid, pre-addressed shipping label to facilitate the return of the supplemental information. Please note that you may request the return of this information pursuant to the provisions of Rule 418(b).
If there are any questions concerning the above request, please phone Mr. George K. Schuler, Mining Engineer at (202) 551-3718.
Companhia Siderúrgica Nacional
Escritório Central
Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center
Cep: 04538-132 - São Paulo - SP
Response to Comment No. 6.
As suggested in the Staff’s comment letter we have contacted the Staff’s engineer to discuss the materials requested. We are in the process of compiling the relevant documents and, as discussed with the Staff’s engineer, will provide them within the next few days. We will provide you with a copy of our correspondence with Mr. Schuler.
SEC Comment No. 7.
7) We note the disclosure of your Santa Barbara tin mine reserves are stated as million cubic meters and your grade is a recoverable tonnage. In future filings please provide the dry density conversion factor or convert these reserves to a tonnage and provide the average tin grade. Please note that proven reserves presented in accordance with Industry Guide 7 may be combined with probable reserves only if the difference in the degree of assurance between the two classes of reserves cannot be readily defined and a statement to that effect in included within the filing. Absent this condition, proven and probable reserves should be segregated.
Response to Comment No. 7.
We note the Staff’s comment and will revise our future filings to include the information requested and correct our use of terminology where applicable.
SEC Comment No. 8.
8) Please disclose whether or not a reserve audit has been performed over the last three years in your future filings.
Response to Comment No. 8.
We note the Staff’s comment and will include the information requested in future filings, clarifying that we have not performed any reserve audit since 2006.
In March 2010, we began the process of performing drilling campaigns to perform a new audit of our reserves for our Casa de Pedra mine. In October 2011, we began a similar process for our Santa Barbara mine. We expect that these processes and the resulting comprehensive audit reports will be concluded by early 2014 for Casa de Pedra, and late 2014 for Santa Barbara.
We have no reason to believe that the conclusions of these audits will indicate a reserve amount lower than the amounts currently reported.
Companhia Siderúrgica Nacional
Escritório Central
Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center
Cep: 04538-132 - São Paulo - SP
SEC Comment No. 9.
Production, page 35
9) Please disclose your annual production as required by Regulation S-K, Instructions to Item 102, Part 3 for all your mines in future filings. Provide a table showing the last three years annual production for each of your mines, which would include your tonnage, grade, and salable products, along with the weighted average prices received for your materials. A mine site may be defined as all the mines that supply a single wash plant or processing facility, if that is applicable.
Response to Comment No. 9.
We note the Staff’s comment and will include the information requested in future filings.
SEC Comment No. 10.
Intellectual Property, page 41
10) In future filings, please expand your disclosure in this section to disclose the extent to which the company is dependent, if at all, on patents or technical cooperation agreements. Refer to Item 4.B.6 of Form 20-F.
Response to Comment No. 10.
We note the Staff’s comment and will include the information requested in future filings, clarifying that we are not dependent on any patents or technical cooperation agreements.
SEC Comment No. 11.
Government Regulation and Other Legal Matters, page 43
11) In future filings, please identify all applicable regulatory bodies for each governmental regulation. Refer to Item 4.B.8 of Form 20-F. For example, we note that you are subject to Brazilian federal, state, and municipal environmental laws and regulations, however, you do not identify the regulatory bodies charged with enforcing these laws and regulations.
Companhia Siderúrgica Nacional
Escritório Central
Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center
Cep: 04538-132 - São Paulo - SP
Response to Comment No. 11.
We note the Staff’s comment and will include the information requested in future filings.
SEC Comment No. 12.
Environmental Expenditures and Claims, page 43
12) Your provision for environmental liabilities was R$278.1 million at December 31, 2010, as compared to R$ 116.5 million in the prior year. Please tell us and revise future filings as appropriate to explain the reason for the significant increase during fiscal 2010. We note the disclosure on the bottom of page 43 regarding the term of undertaking (TAC) signed in 2010. Also tell us and disclose: i) where the provision is included in your statements of income, and ii) the impact of the R$260.0 million required investment pursuant to the TAC for the current period and for the next three years.
Response to Comment No. 12.
We note the Staff’s comment and will include the information requested in future filings.
For clarification purposes, we note that the changes in the provision for environmental liabilities on our financial statements are as follows:
Amounts
(in millions of R$)
December 31, 2009
116.5
Landfills(1)
116.7
Term of Undertaking (TAC)(2)
34.7
Other
10.2
December 31, 2010
278.1
_________________
(1) During 2010 we concluded certain environmental investigations of landfills and, therefore, were able to have an estimate calculation of remediation costs and recorded the related provision for those landfills with probable remediation obligations.
(2) Refers to environmental compensation agreed in the TAC but not related to investments in equipments.
We would further like to clarify that the provision is included in our other operating (expenses) income and that the impact of the R$260 million required investment pursuant to the TAC for the current period and for the next years was as follows:
Companhia Siderúrgica Nacional
Escritório Central
Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center
Cep: 04538-132 - São Paulo - SP
Year
Amounts
(in millions of R$)
57.8
46.2
65.8
53.4
28.9
7.9
Total
260.0
During the course of 2011 we continued the process of obtaining more accurate cost estimates for the full implementation of the measures agreed to in the TAC. Although we have not yet concluded this process, we expect that the investments required will exceed the original R$260 million estimate agreed to in the TAC. Once we conclude this process we will update our future disclosure.
SEC Comment No. 13.
Capital Expenditures, page 52
13) We note that you disclose capital expenditures occurring in 2009 and 2010. In future filings, please disclose your capital expenditures since the beginning of your last three financial years. Refer to Item 4.A.5 of Form 20-F.
Response to Comment No. 13.
We note the Staff’s comment and will include the information requested in future filings.
SEC Comment No. 14.
Operating and Financial Review and Prospects, page 55
Operating Results, page 55
14) We note your disclosure on page seven that the Brazilian government frequently intervenes in the Brazilian economy and occasionally makes significant changes in policy and regulation. In future filings, please provide information regarding any governmental economic, fiscal, monetary or political policies or factors that have materially affected or could materially affect, directly or indirectly, the company’s operations or investments by host country shareholders. Refer to Item 5.A.4 of Form 20-F.
Companhia Siderúrgica Nacional
Escritório Central
Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio
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CORRESP 1 filename1.htm sid20111208_corresp.htm - Generated by SEC Publisher for SEC Filing December 8, 2011 Via E-mail and EDGAR Transmission Mr. Terence O’Brien Accounting Branch Chief Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-4631 Re: National Steel Company Form 20-F for the fiscal year ended December 31, 2010 Filed June 20, 2011 File No. 1-14732 Response to Staff Comment Letter dated November 23, 2011 Dear Mr. O’Brien: Companhia Siderúgica Nacional (the “Company”) received a comment letter from the staff of the United States Securities and Exchange Commission (the “Staff”) on November 23, 2011, concerning the Company’s annual report on Form 20-F filed on June 20, 2011 (the “2010 Form 20-F”). This letter provides the Company’s responses to the Staff’s comments. For your convenience, we have reproduced below in italics the Staff’s comments numbered 1 through 25 and have provided responses immediately below such comments. All page numbers referred to herein are to the 2010 Form 20-F. SEC Comment No. 1. Information on the Company, page 15 Business Overview, page 17 1) We note your disclosure of sales of steel products by geographic region for 2009 and 2010 on page 39. In future filings, please provide the breakdown of total revenues by category and geographic market for each of the last three financial years. Please also provide this information for your other business segments in future filings. Refer to Item 4.B.2 of Form 20-F. Response to Comment No. 1. We note the Staff’s comment and will include the information requested in future filings. Companhia Siderúrgica Nacional 1 Escritório Central Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center Cep: 04538-132 - São Paulo - SP SEC Comment No. 2. 2) In future filings, please provide the information required by Item 4.B of Form 20-F for your cement segment. Response to Comment No. 2. We note the Staff’s comment and will include the information requested in future filings. SEC Comment No. 3. 3) We note your disclosure of proven and probable resources in this section. The provisions in Industry Guide 7 preclude the use of any terms other than proven or probable reserves for disclosure in SEC documents. Please correct or remove this terminology from your filing in future filings. Response to Comment No. 3. We note the Staff’s comment and will revise our future filings to correct our use of terminology where applicable and remove information and terms not permitted under Industry Guide 7. SEC Comment No. 4. Mineral Resources, page 33 4) Within your filing, you use the term resources in reference to quantity (tonnage) estimates. The provisions in Industry Guide 7 preclude the use of any terms other than proven and/or probable reserves for disclosure in SEC documents. However, you may disclose quantity estimates for mineralized material referencing mineralization that has been sufficiently sampled at close enough intervals to reasonably assume continuity between samples within the area of influence. In this instance, you would need to disclose that such material would not qualify as a reserve, until a comprehensive evaluation based upon unit cost, grade, recoveries, and other material factors concludes both legal and economic feasibility. Mineralized material should only be reported as an in place tonnage and grade, and should not be disclosed as units of product, such as ounces of gold or pounds of copper, as these can be confused with reserves. Please note that mineralized material does not include material reported as reserves or tonnage and grades estimated by using geologic inference, which are sometimes classed as inferred resources or possible reserves by some evaluators. Companhia Siderúrgica Nacional 2 Escritório Central Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center Cep: 04538-132 - São Paulo - SP · Remove the terms measured, indicated, inferred mineral resources, and associated estimates from your future filings. · If the quantities associated with the above terms meet the requirements of mineralized material, disclose the estimates as mineralized material in your future filings. · Please do not disclose estimates based on geologic inference, such as inferred resources or possible reserves in your future filings. Response to Comment No. 4. We note the Staff’s comment and will revise our future filings to correct our use of terminology where applicable and remove information and terms not permitted under Industry Guide 7. SEC Comment No. 5. 5) Please disclose the following information within or adjacent to your reserve tables in your future filings: · A statement clarifying the extent to which your reserve estimates incorporate losses for mine dilution and mining recovery. · The cutoff grade · The metallurgical recovery factor for each of your mines. · All historic three-year average commodity prices and currency conversion factors that were used to estimate your reserves. · The percentage of your ownership of each mine and a statement clarifying whether quantities disclosed are for the entire mine/deposit or just your share. · A statement indicating whether your resource estimates are inclusive or exclusive of your reserve estimates. Response to Comment No. 5. We note the Staff’s comment and will include the information requested adjacent to our reserve tables in future filings. Companhia Siderúrgica Nacional 3 Escritório Central Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center Cep: 04538-132 - São Paulo - SP SEC Comment No. 6. 6) Proven and probable reserves are disclosed for your property. Please forward to our engineer as supplemental information and not as part of your filing, your information that establishes the legal, technical, and economic feasibility of your Casa de Pedra and Santa Barbara mines which you have designated as reserves, as required by Section C of Industry Guide 7 or Rule 12b-4 of the Exchange Act. The information requested includes, but is not limited to: · Property and geologic maps · Description of your sampling and assaying procedures · Drill-hole maps showing drill intercepts · Representative geologic cross-sections and drill logs · Description and examples of your cut-off calculation procedures · Cutoff grades used for each category of your reserves and resources · Justifications for the drill hole spacing used to classify and segregate proven and probable reserves · A detailed description of your procedures for estimating reserves · Copies of any pertinent engineering or geological reports, and executive summaries of feasibility studies or mine plans which including the cash flow analyses · A detailed permitting and government approval schedule for the project, particularly identifying the primary environmental or construction approval(s) and your current location on that schedule. To minimize the transfer of paper, please provide the requested information on a CD, formatted as Adobe PDF files and provide the name and phone number for a technical person our engineer may call, if he has technical questions about your reserves. In the event your company desires the return of this supplemental material, please make a written request with the letter of transmittal and include a pre-paid, pre-addressed shipping label to facilitate the return of the supplemental information. Please note that you may request the return of this information pursuant to the provisions of Rule 418(b). If there are any questions concerning the above request, please phone Mr. George K. Schuler, Mining Engineer at (202) 551-3718. Companhia Siderúrgica Nacional 4 Escritório Central Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center Cep: 04538-132 - São Paulo - SP Response to Comment No. 6. As suggested in the Staff’s comment letter we have contacted the Staff’s engineer to discuss the materials requested. We are in the process of compiling the relevant documents and, as discussed with the Staff’s engineer, will provide them within the next few days. We will provide you with a copy of our correspondence with Mr. Schuler. SEC Comment No. 7. 7) We note the disclosure of your Santa Barbara tin mine reserves are stated as million cubic meters and your grade is a recoverable tonnage. In future filings please provide the dry density conversion factor or convert these reserves to a tonnage and provide the average tin grade. Please note that proven reserves presented in accordance with Industry Guide 7 may be combined with probable reserves only if the difference in the degree of assurance between the two classes of reserves cannot be readily defined and a statement to that effect in included within the filing. Absent this condition, proven and probable reserves should be segregated. Response to Comment No. 7. We note the Staff’s comment and will revise our future filings to include the information requested and correct our use of terminology where applicable. SEC Comment No. 8. 8) Please disclose whether or not a reserve audit has been performed over the last three years in your future filings. Response to Comment No. 8. We note the Staff’s comment and will include the information requested in future filings, clarifying that we have not performed any reserve audit since 2006. In March 2010, we began the process of performing drilling campaigns to perform a new audit of our reserves for our Casa de Pedra mine. In October 2011, we began a similar process for our Santa Barbara mine. We expect that these processes and the resulting comprehensive audit reports will be concluded by early 2014 for Casa de Pedra, and late 2014 for Santa Barbara. We have no reason to believe that the conclusions of these audits will indicate a reserve amount lower than the amounts currently reported. Companhia Siderúrgica Nacional 5 Escritório Central Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center Cep: 04538-132 - São Paulo - SP SEC Comment No. 9. Production, page 35 9) Please disclose your annual production as required by Regulation S-K, Instructions to Item 102, Part 3 for all your mines in future filings. Provide a table showing the last three years annual production for each of your mines, which would include your tonnage, grade, and salable products, along with the weighted average prices received for your materials. A mine site may be defined as all the mines that supply a single wash plant or processing facility, if that is applicable. Response to Comment No. 9. We note the Staff’s comment and will include the information requested in future filings. SEC Comment No. 10. Intellectual Property, page 41 10) In future filings, please expand your disclosure in this section to disclose the extent to which the company is dependent, if at all, on patents or technical cooperation agreements. Refer to Item 4.B.6 of Form 20-F. Response to Comment No. 10. We note the Staff’s comment and will include the information requested in future filings, clarifying that we are not dependent on any patents or technical cooperation agreements. SEC Comment No. 11. Government Regulation and Other Legal Matters, page 43 11) In future filings, please identify all applicable regulatory bodies for each governmental regulation. Refer to Item 4.B.8 of Form 20-F. For example, we note that you are subject to Brazilian federal, state, and municipal environmental laws and regulations, however, you do not identify the regulatory bodies charged with enforcing these laws and regulations. Companhia Siderúrgica Nacional 6 Escritório Central Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center Cep: 04538-132 - São Paulo - SP Response to Comment No. 11. We note the Staff’s comment and will include the information requested in future filings. SEC Comment No. 12. Environmental Expenditures and Claims, page 43 12) Your provision for environmental liabilities was R$278.1 million at December 31, 2010, as compared to R$ 116.5 million in the prior year. Please tell us and revise future filings as appropriate to explain the reason for the significant increase during fiscal 2010. We note the disclosure on the bottom of page 43 regarding the term of undertaking (TAC) signed in 2010. Also tell us and disclose: i) where the provision is included in your statements of income, and ii) the impact of the R$260.0 million required investment pursuant to the TAC for the current period and for the next three years. Response to Comment No. 12. We note the Staff’s comment and will include the information requested in future filings. For clarification purposes, we note that the changes in the provision for environmental liabilities on our financial statements are as follows: Amounts (in millions of R$) December 31, 2009 116.5 Landfills(1) 116.7 Term of Undertaking (TAC)(2) 34.7 Other 10.2 December 31, 2010 278.1 _________________ (1) During 2010 we concluded certain environmental investigations of landfills and, therefore, were able to have an estimate calculation of remediation costs and recorded the related provision for those landfills with probable remediation obligations. (2) Refers to environmental compensation agreed in the TAC but not related to investments in equipments. We would further like to clarify that the provision is included in our other operating (expenses) income and that the impact of the R$260 million required investment pursuant to the TAC for the current period and for the next years was as follows: Companhia Siderúrgica Nacional 7 Escritório Central Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio Financial Faria Lima Center Cep: 04538-132 - São Paulo - SP Year Amounts (in millions of R$) 2010 57.8 2011 46.2 2012 65.8 2013 53.4 2014 28.9 2015 7.9 Total 260.0 During the course of 2011 we continued the process of obtaining more accurate cost estimates for the full implementation of the measures agreed to in the TAC. Although we have not yet concluded this process, we expect that the investments required will exceed the original R$260 million estimate agreed to in the TAC. Once we conclude this process we will update our future disclosure. SEC Comment No. 13. Capital Expenditures, page 52 13) We note that you disclose capital expenditures occurring in 2009 and 2010. In future filings, please disclose your capital expenditures since the beginning of your last three financial years. Refer to Item 4.A.5 of Form 20-F. Response to Comment No. 13. We note the Staff’s comment and will include the information requested in future filings. SEC Comment No. 14. Operating and Financial Review and Prospects, page 55 Operating Results, page 55 14) We note your disclosure on page seven that the Brazilian government frequently intervenes in the Brazilian economy and occasionally makes significant changes in policy and regulation. In future filings, please provide information regarding any governmental economic, fiscal, monetary or political policies or factors that have materially affected or could materially affect, directly or indirectly, the company’s operations or investments by host country shareholders. Refer to Item 5.A.4 of Form 20-F. Companhia Siderúrgica Nacional 8 Escritório Central Av. Brigadeiro Faria Lima, 3400 – 20º andar - Edificio