Social Responsibility at
PETOL®

PETOL® is committed to maintaining a work environment that respects and supports the fundamental human rights of all of our employees. We will not employ underage children or forced laborers and we prohibit physical punishment or abuse. We comply with all employment laws in every market where we operate. We promote, protect and help ensure the equal enjoyment of human rights by all persons, including those with disabilities.

We recognize that one of our greatest strengths lies in the talent and ability of our employees. Employees are expected to hold themselves accountable to the highest professional standards, with mutual respect being the basis of all professional relationships. Human resource goals have been established to guide company activities in employee relations. It is the company’s policy:

• to deal fairly with employees;
• to provide equal opportunity for all in recruiting, hiring, developing, promoting and compensating without regard to race, religion, color, age, gender, disability, genetic information, military or veteran status, sexual orientation, gender identity, citizenship, national origin, or other legally-protected status;
• to maintain a professional, safe and discrimination-free work environment;
• to recognize and compensate employees based on their performance; and
• to provide a competitive array of benefits.

Sexual, racial, ethnic, religious or any other type of harassment has no place in the PETOL work environment. Racial, ethnic and religious harassment includes such conduct as slurs, jokes, intimidation or any other verbal or physical attack upon a person because of race, religion or national origin. Sexual harassment includes unwelcome sexual advances or other verbal or physical conduct of a sexual nature.

It is PETOL® ’s goal not to purchase product materials containing minerals whose sale financed armed conflict in the Democratic Republic of the Congo (DRC) or any adjoining country. We expect our suppliers (and their suppliers) to exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten and gold used in components or products they supply to us. This said, we recognize that the global supply chain for these minerals is complex, and tracing minerals to their source is a challenge. PETOL is working diligently with our suppliers to improve and systematically address the process for sourcing minerals that are “conflict-free.”

As a privately-owned company, PETOL is not subject to the SEC’s filing requirements on conflict minerals. Nevertheless, since our company was founded in 1927, we have been committed to serving our customers’ needs. We have made it a top priority to assure that our supply chain is transparent and conflict-free, and to provide our customers who are subject to SEC reporting requirements with all the information they need from us.

PETOL has engaged independent consulting firm Resource Global Professionals LLC (RGP) to develop an OECD-compliant framework to determine whether PETOL products contain tin, tungsten, tantalum or gold (“3TGs”) and, if so, to ensure these metals are not sourced from the DRC or any adjoining country. We have made substantial progress and will not stop until we have determined that all of our products are conflict-free.

Our Conflict Minerals Reporting Template (CMRT) is available to our customers upon request.

PETOL® has established an OECD-compliant conflict minerals program to identify and assess risks in our supply chain by requesting smelter-level information related to conflict minerals in our products. We are actively working to identify any products that may contain conflict minerals. We have adopted a three-step due diligence process to determine the source and chain of custody of conflict minerals in our supply chain.

Step One: Establish Strong Company Management Systems. PETOL’s Conflict Minerals Policy and Code of Conduct state our goal to identify and eliminate any content in our supply chain tainted with forced labor or human rights abuses in the procurement of parts for manufacture, including conflict minerals that fund armed groups in the Democratic Republic of the Congo (DRC) or any adjoining country. We have established a Conflict Minerals Compliance Team, led by the General Counsel of the company, to develop and maintain policies, standards and processes that relate to the management of conflict minerals risk in the supply chain. We have instructed our direct material suppliers to ensure their products are in line with our policy.

Step Two: Identify Conflict Minerals Risk in the Supply Chain. In order to determine the source and chain of custody of any tin, tungsten, tantalum or gold (3TG) used in our products, we first identified “at-risk” direct purchases – parts that we know contain or are likely to contain 3TG. Next we identified the suppliers of those parts. These “at risk” parts and suppliers formed the basis of our Reasonable Country of Origin (RCOI) process for identifying the smelter-level information for any 3TGs these parts contain.

We contacted each of our direct materials suppliers, asking if any of the parts we purchase from them contain 3TG. Some suppliers provided definitive written assurance that the parts we purchase from them do not contain 3TG. We asked the remaining suppliers to complete a Conflict Minerals Reporting Template in order to confirm the presence of 3TG, determine the smelter/refinery, and confirm the country of origin if possible. As supplier reporting templates were received each response was tabulated and reviewed for completeness and sufficiency.

As part of our process we reviewed the supplier-provided smelter information in order to identify potential “red flags” as defined by the OECD guidance. If a “red flag” was identified we conducted follow-up actions with the supplier and smelter in order to validate the information and to determine whether our purchases of 3TG directly or indirectly benefited armed groups in the DRC or adjoining countries. At the conclusion of the RCOI process, we assigned each supplier response a status code.

Step Three: Determination of Conflict Status. Based on the collection of supplier surveys and review of listed smelters, we then made a summary determination as to the status of conflict minerals in our supply chain, and drafted our company-level Conflict Minerals Reporting Template (CMRT), which we provide to our customers upon request.

In addition to performing supply chain due diligence, we are in the process of implementing additional processes and controls to better manage conflict minerals risk and make our program sustainable.

We are firmly committed to conduct all of our business activities in a socially responsible manner, ensuring:

• the health and safety of our employees
• the protection of the people and companies who use our products
• the protection of the environment

We constantly work to:

• Reduce waste and materials consumption
• Reduce energy consumption and greenhouse gas emissions
• Reduce water consumption and enhance water re-use
• Reduce the total environmental impact of our products
• Create a safe operating environment for our co-workers

A Message from PETOL®

Since 1927, PETOL® has been committed to the highest standards of business conduct. We base our relationships with employees, and with suppliers, contractors and consultants (collectively, “Suppliers”), on efficient, fair and lawful practices.

In recent months, as a result of the passage of the US Dodd-Frank Act, a number of our customers have asked us to formally adopt a Code of Conduct (“Code”) and to distribute it throughout our supply chain. We ask that you review the following Code, and ensure that you and your employees, representatives and subcontractors comply with it. Please contact us if you have any questions.

PETOL® Code of Conduct.

1.  Ethical Principles. It is important to us that we, our employees and our Suppliers:
   1.  Obey applicable laws and regulations governing our business conduct.
   2. Be honest, fair and trustworthy in our activities and relationships.
   3. Avoid all conflicts of interest between work and personal affairs.
   4. Encourage fair employment and workplace safety practices.
   5. Protect the environment.
   6.  Encourage a culture where ethical conduct is recognized and valued.
2.  Requirements for PETOL Employees. All PETOL employees are required to comply with these requirements:
   1.  Improper Payments.
      1. Always adhere to the highest standards of honesty and integrity in all contacts on behalf of PETOL. Never offer bribes, kickbacks, illegal political contributions or other improper payments to any customer, government official or third party. Follow the laws of the United States and other countries relating to these matters.
      2. Do not give gifts or provide any entertainment to a customer or supplier without prior approval of PETOL management. Make sure all business entertainment and gifts are lawful and disclosed to the other party’s employer.
      3. Employ only reputable people and firms as PETOL representatives, and understand and obey any requirements governing the use of third party representatives.
   2. International Trade Controls.
      1. Understand and follow US international trade control and customs laws and regulations, including those relating to licensing, shipping and import documentation and reporting, and record retention requirements.
      2. Never participate in boycotts or other restrictive trade practices prohibited or penalized under United States or applicable local laws.
   3. Money Laundering Prevention. Follow all applicable laws that prohibit money laundering and that require the reporting of cash or other suspicious transactions.
   4. Privacy.
      1. Never acquire, use or disclose individual information in ways that are inconsistent with applicable privacy and data protection laws, regulations and treaties.
      2. Maintain secure business records containing personal identifying information, which is protected by applicable privacy regulations. This provision applies irrespective of the form or medium in which the records are stored.
   5. Supplier Relationships.
      1. Only do business with suppliers who comply with local and other applicable legal requirements and this Code.
      2. Follow applicable laws and government regulations covering supplier relationships.
      3. Provide a competitive opportunity for suppliers to earn a share of PETOL’s purchasing volume, including small businesses and businesses owned by the disadvantaged, minorities and women.
   6. Regulatory Excellence.
      1. Be aware of US regulatory requirements applicable to our business.
      2. Gain a basic understanding of the key regulators and the regulatory priorities that affect our business.
      3. Promptly report any red flags or potential issues that may lead to a regulatory compliance breach.
      4. Always treat regulators professionally and with courtesy and respect.
      5. Assure that coordination with business or corporate experts is sought when working with or responding to requests of regulators.
   7. Complying with Competition Laws.
      1. Never propose or enter into any agreement or understanding with a PETOL competitor to fix prices, terms and conditions of sale, costs, profit margins or other aspects of the competition for sales to third parties.
      2. Do not enter into any agreements or understandings with others to allocate markets.
      3. Do not enter into any agreements or understandings with PETOL customers restricting resale prices.
      4. Never propose or enter into any agreements or understandings with suppliers that restrict the price or other terms at which PETOL may resell or lease any product or service to a third party.
   8. Environment, Health & Safety.
      1. Conduct your activities in compliance with all relevant environmental and worker health and safety laws, regulations, policies and guidelines.
      2. Ensure that all new product designs or changes or service offerings are reviewed for compliance with PETOL guidelines.
      3. Use care in handling hazardous materials, or operating processes or equipment that use hazardous materials, to prevent unplanned releases into the workplace or the environment.
      4. Report to PETOL management all spills of hazardous materials, any concern that PETOL products are unsafe, and any potential violation of environmental, health or safety laws, regulations or company practices.
   9. Fair Employment Practices. Extend equal opportunity, fair treatment and a harassment-free work environment to all employees, co-workers, consultants and other business associates without regard to their race, color, religion, national origin, sex (including pregnancy), sexual orientation, age, disability, veteran status or other characteristic protected by law.
   10. Security and Crisis Management.
       1. Implement plans to address security of employees, facilities, information, IT assets and business continuity.
       2. Protect access to PETOL facilities from unauthorized personnel.
       3. Protect IT assets from theft, misappropriation or unauthorized disclosure.
       4. Create and maintain a safe working environment.
       5. Ensure proper business continuity plans are prepared for emergencies.
       6. Report any apparent security lapses.
   11. Conflicts of Interest.
       1. Financial, business or other non-work related activities must be lawful and free of conflicts with one’s responsibilities to PETOL.
       2. Report all personal or family relationships, including those of significant others, with current or prospective suppliers you select, manage or evaluate.
       3. Do not use PETOL equipment, information or other property (including office equipment, e-mail and computer applications) to conduct personal or non-PETOL business without prior permission from the appropriate PETOL manager.
   12. Controllership.
       1. Keep and report all PETOL records, including any time records, in an accurate, timely, complete and confidential manner. Only release PETOL records to third parties when authorized by PETOL.
       2. Follow PETOL policies and generally accepted accounting principles, standards, laws and regulations for accounting and financial reporting of transactions, estimates and forecasts.
       3. Financial statements and reports prepared for or on behalf of PETOL must fairly present the financial position, results of operations and/or other financial data for the periods and/or the dates specified.
   13. Insider Trading or Dealing and Stock Tipping.
       1. Never buy, sell or suggest to someone else that they should buy or sell stock or other securities of any company while you are aware of significant or material non-public information (“inside information”) about that company. Information is significant or material when it is likely that an ordinary investor would consider the information important in making an investment decision.
       2. Do not pass on or disclose inside information unless lawful and necessary for the conduct of PETOL business—and never pass on or disclose such information if you suspect that the information will be used for an improper trading purpose.
   14. Intellectual Property. Identify and protect PETOL intellectual property in ways consistent with the law.
       1. Consult with PETOL counsel in advance of soliciting, accepting or using proprietary information of outsiders, disclosing PETOL proprietary information to outsiders or permitting third parties to use PETOL intellectual property.
       2. Respect valid patents, trademarks, copyrighted materials and other protected intellectual property of others; and consult with PETOL counsel for licenses or approvals to use such intellectual property.
   15. Responsible Sourcing of Minerals. Reasonably ensure that any tantalum, tin, tungsten or gold in products manufactured by PETOL do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Exercise due diligence to ascertain the source and chain of custody of these minerals. Make due diligence measures reasonably available to customers upon customer request. See our Conflict Minerals Policy.
3. Requirements for Suppliers, Contractors and Consultants (collectively, “Suppliers”). PETOL adheres to the following policies, and will only do business with Suppliers that do the same.
   1. Forced Labor. Avoid using forced, prison or indentured labor. Workers should not be subject to any form of compulsion, coercion or trafficking in persons in violation of the U.S. Government’s zero tolerance policy or other applicable laws or regulations.
   2. Minimum Age. Avoid employing workers younger than sixteen (16) years of age or the applicable required minimum age, whichever is higher. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is deemed hazardous or is likely to jeopardize the health or safety of young workers.
   3. Human Rights.
      1. Respect employees’ human rights.
      2. Observe applicable laws and regulations governing wages and hours.
      3. Prohibit unlawful discrimination, harassment and retaliation.
   4. Health & Safety. Provide workers a workplace that meets applicable health, safety and security standards.
   5. Environmental Compliance. Observe applicable environmental laws and regulations.
   6. Lawful Business Practices. Maintain and enforce policies requiring the company and its employees to adhere to lawful business practices, including a prohibition against bribery of government officials.
   7. Business Practices and Dealings with PETOL. Never offer or provide, directly or indirectly, anything of value, including cash, bribes, gifts, entertainment or kickbacks, to any PETOL employee, representative or customer or to any government official in connection with any PETOL purchase, transaction or business dealing. Such prohibition includes the offering or providing of any consulting, employment or similar position by a Supplier to any PETOL employee (or their family member or significant other) involved with a PETOL purchase. PETOL also prohibits a PETOL Supplier from offering or providing PETOL employees, representatives or customers or any government officials with any gifts or entertainment, other than those of nominal value to commemorate or recognize a particular PETOL Supplier business transaction or activity. In particular, a PETOL Supplier shall not offer, invite or permit PETOL employees and representatives to participate in any Supplier or Supplier-sponsored contest, game or promotion.
   8. Business Entertainment of PETOL Employees and Representatives. Respect and comply with the business entertainment (including travel and living) policies established by PETOL and governing PETOL employees and representatives. A PETOL Supplier is expected to understand the business entertainment policies of PETOL before offering or providing any PETOL employee or representative any business entertainment. Business entertainment should never be offered to a PETOL employee or representative by a Supplier under circumstances that create the appearance of impropriety.
   9. Collusive Conduct and PETOL Purchases. Do not share or exchange any of PETOL’s price, cost or other competitive information, or undertake any other collusive conduct with any other third party concerning any proposed, pending or current PETOL purchase.
   10. Intellectual Property and Other Data and Security Requirements. Respect the intellectual and other property rights of others, especially PETOL. In that regard, a PETOL Supplier shall:
       1. Only use PETOL information and property (including tools, drawings and specifications) for the purpose for which they are provided to the Supplier and for no other purposes.
       2. Take appropriate steps to safeguard and maintain the confidentiality of PETOL proprietary information, including maintaining it in confidence and in secure work areas and not disclosing it to third parties (including other customers, subcontractors, etc.) without the prior written permission of PETOL.
       3. If requested by PETOL , only transmit information over the Internet on an encrypted basis.
       4. Observe and respect all PETOL patents, trademarks and copyrights and comply with such restrictions or prohibitions on their use as PETOL may from time to time establish.
       5. Comply with all applicable rules concerning cross-border data transfers.
       6. Maintain all personal and sensitive data, whether of PETOL employees or its customers in a secure and confidential manner, taking into account both local requirements and the relevant PETOL policies provided to the Supplier.
   11. Trade Controls and Customs Matters. Never transfer any PETOL technical information to any third party without the express, written permission of PETOL. Comply with all applicable trade control laws and regulations in the import, export, deemed export, re-export or transfer of goods, services, software, technology or technical data, including applicable licensing requirements and any restrictions on access or use by unauthorized persons or entities. Ensure that all invoices and any customs or similar documentation submitted to PETOL or governmental authorities in connection with transactions involving PETOL accurately describe the goods and services provided or delivered and the price thereof.
   12. Responsible Sourcing of Minerals. Reasonably ensure that any tantalum, tin, tungsten or gold in products manufactured by PETOL do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Exercise due diligence to ascertain the source and chain of custody of these minerals and make these due diligence measures reasonably available to customers upon request. (For more information, see PETOL’s Conflict Minerals Policy.)
   13. Use of Subcontractors or Third Parties to Evade Requirements. The use of subcontractors or other third parties to evade legal requirements applicable to the Supplier and any of the standards set forth in this Code is prohibited.
4. Raising an Integrity Concern. Subject to local laws and any legal restrictions applicable to such reporting, each PETOL Supplier is expected to promptly inform PETOL of any Integrity concern involving or affecting PETOL , whether or not the concern involves the Supplier, as soon as the Supplier has knowledge of such Integrity concern. A PETOL Supplier shall also take such steps as PETOL may reasonably request to assist PETOL in the investigation of any Integrity concern involving PETOL and the Supplier.
5. Additional Provisions.
   1. The foregoing standards are subject to modification at the discretion of PETOL. Please contact us if you have any questions about these standards and/or their application to particular circumstances.
   2. Each PETOL Supplier is responsible for ensuring that its employees and representatives understand and comply with these standards. PETOL will only do business with those Suppliers that comply with applicable legal and regulatory requirements and reserve the right, based on its assessment of information available to PETOL , to terminate, without liability to PETOL , any pending purchase order or contract with any Supplier that does not comply with the standards provided in this Code.
   3. This Code is not intended to create any rights for third parties, including workers.