Victaulic Code of Conduct

About the CodeEmployee responsibilities:• Understand the laws and regulations that apply to your job and follow them• Read, understand and follow the Code• Seek guidance from your manager, legal department or other resources if you are uncertainabout the proper way to act on behalf of Victaulic• Participate in compliance training• Promptly report any suspected violations of the law or Code to your manager, legal departmentor the Victaulic awareness line• If a concern you raise is not resolved, pursue the issue and raise it up through another channel• Cooperate in investigations related to the CodeAnnual Electronic Code of Conduct CertificationEach year employees are required to acknowledge that they have read, understood, and compliedwith the Code, as well as recognize their continued obligations, which includes the obligationto report violations or suspected violations by completing an annual electronic certification.Employees are required to understand their obligations under the Code and acknowledge they havecomplied with its requirements. As part of this certification process, employees have the opportunityto request training or clarification or disclose a potential situation. Employees should includeany activity that might in any way be deemed to constitute such a conflict and doubts should beresolved in the favor of disclosure so that an informed judgment can be made.Getting Help and Reporting a Suspected ProblemEmployees should always try to resolve or remedy the situation in a manner consistent with theCode. If possible, discuss your question or concern directly with the person involved, then contact yoursupervisor. If you believe your supervisor’s response is not adequate contact one of the followingalternatives:• Your manager• Your human resource manager• Mark Van De Voorde, chief legal and administrative officer, + 1 610 923 3190• Your regional compliance officer:Asia Pacific: Gordon Lu, glu@victaulic.com, +86 21 6170 1222 x333Canada: Mario D’Ambrosio, mdambrosio@victaulic.com, +1 905 780 4855Europe, Middle East, Africa & India: Alex Golabek, Alex.golabek@victaulic.be, +32 93811 519U.S.: Joe Savage, jsavage@victaulic.com, +1 610 838 8949Mexico, Caribbean, South America: Rocio Mancinas, rmancinas@victaulic.com.+1 521 6141761070• The Victaulic awareness line is a multi-lingual, toll-free service available 24 hours a day,seven days a week. Like most companies, Victaulic uses a third party to answer calls andtranscribe reported information. Toll-free numbers and web reporting options are availableon the Victaulic website under the ‘Our Company’ tab.[ 4 ] www.victaulic.com