Victaulic Code of Conduct

Trade Sanctions and BoycottsAbout Trade Sanctions:• Because trade sanctions aredriven by political events, theychange frequently. If you havequestions, please call the LegalDepartment• The trade sanctions regulationsprohibit actions, exports andtransshipments to or from theU.S. and E.U. to prohibitedcountries and specificallydesignated nationals (“SNDs”)• Never attempt to directly orindirectly get around a tradesanction or export restriction• Liability for violations ofthe trade sanctions is serious– it can apply civil fines andcriminal penalities to both theCompany and to individualsAbout Export Controls:• Be aware that the export ofproducts to some countries isrestricted or prohibited• Be aware of “red flags” such ascomplex shipping or financialarrangements when exportingproductsTrade SanctionsThe U.S. Government maintains a list of countries andindividuals with which U.S. companies may not do businessbecause of trade sanctions. Similar lists are also producedby the European Union. We are also prohibited from doingbusiness with citizens, agents or representatives of thosecountries. For an up-to-date list of these countries andindividuals, contact the legal department.BoycottsU.S. law prohibits U.S. companies from participating inany boycott or restrictive trade practices against countriesconsidered “friendly” to the United States and againstcompanies that are “blacklisted” by other countries orfirms. For example, some companies in the Middle Eastmay seek to include language in contracts that prohibitsVictaulic from doing work in Israel. U.S. law will not allowsuch language to be included or enforced in a contract.Any request to participate in a boycott must be promptlyreported to your manager and the legal department, even ifVictaulic decides not to bid the project. Victaulic is requiredto report all such requests to the U.S. Government.Export ControlsCertain products and technologies may also be subject toexport control restrictions.If you have any questions about whether a sale or shipmentof a product or technology may be restricted, please contactyour regional compliance officer or the legal department.Victaulic awareness lineRefer to the ‘Our Company’section of Victaulic.com forspecific contact information.An Example of Improper Compliance with TradeSanctions and Boycotts:A Victaulic distributor places an order to fill a bill ofmaterial. Our salesman knows that the distributor intendsto ship the material to Iran. This order is suspect but thesalesman does not report this to his manager.[ 8 ] www.victaulic.com