Victaulic Code of Conduct

Political ActivityPolitical contributions may includeany of the following:• Contributing to a local, state orfederal political candidate onbehalf of the company• Purchasing tickets for apolitical fund raising event withcompany funds• Providing anything of valueincluding meals, goods,services, travel accommodationsor tickets for sporting andentertaining events• Loaning personnel or othercorporate resources duringworking hours for political fundraising activities• Paying for politicaladvertisements or othercampaign expensesI accepted an invitation toQ: attend a fundraiser for myhometown congressman. I cannotattend but want to send in a check.May my assistant overnight apersonal check to the campaign?Yes, provided that the costA: of the overnight postage isreimbursed to the company.Lobbying and political activity are an important part ofdemocratic (political) process, but strict rules govern whatcorporations may and may not do in this arena. Victaulicis active in establishing good relationships with electedofficials to enhance the company’s business environment.However, in nearly all the countries in which Victaulicoperates, there are stringent legal restrictions on whata company can contribute, offer, promise or give to anelected official and their staff.Employees may not give, offer or authorize to offercompany funds or other company assets (directly orindirectly) for political purposes without consulting thelegal department who will seek approval of the chairmanand CEO.A political contribution could be construed as a bribe ifit is done, directly or indirectly, in exchange for an actionby the government official. This can be direct, such asrecommending Victaulic’s selection on a procurementdecision or other similar acts, or indirect, such aspromising to include Victaulic in the list of approved – oreven possible – vendors for a current or future payment.Personal Political ActivityVictaulic encourages political activity by employees insupport of candidates or parties of their choice. However,you cannot use company time, property or equipmentfor your own political activities. Personal participation inpolitical activities is an employee’s choice and must betotally voluntary.Victaulic awareness lineRefer to the ‘Our Company’section of Victaulic.com forspecific contact information.[ 22 ] www.victaulic.com