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Fedders Corporation
Code of Business Conduct and Ethics

Table of Contents

Section One

• PUTTING THE CODE OF BUSINESS CONDUCT AND ETHICS TO WORK
  • About the Code of Business Conduct and Ethics
  • Meeting Our Shared Obligations
• RESPONSIBILITY TO OUR ORGANIZATION
  • Conflicts of Interest
    • Improper Personal Benefits from the Company
    • Financial Interests in Other Businesses
    • Business Arrangements with the Company
    • Outside Employment or Activities With a Competitor
    • Outside Employment With a Customer or Supplier
    • Family Members Working In The Industry
  • Corporate Opportunities
  • Entertainment, Gifts and Gratuities
  • Protection and Proper Use of Company Assets
  • Company Books and Records
  • Record Retention
  • Confidential Information
  • Trademarks, Patents, Copyrights and Other Intellectual Property
    • Trademarks and Patents
    • Copyright Compliance
    • Intellectual Property Rights of Others
  • Computer and Communication Resources
  • Insider Trading
  • Responding to Inquiries from the Press and Others

Section Two

• FAIR DEALING
• RESPONSIBILITY TO OUR PEOPLE
  • Respecting One Another
  • Employee Privacy
  • Equal Employment Opportunity and Nondiscrimination
  • Sexual and Other Forms of Harassment
  • Safety in the Workplace
    • Weapons and Workplace Violence
    • Drugs and Alcohol

Section Three

• INTERACTING WITH GOVERNMENT
  • Prohibition on Gifts to Government Officials and Employees
  • Political Contributions and Activities
  • Lobbying Activities
  • Bribery of Foreign Officials

Section Four

• IMPLEMENTATION OF THE CODE
  • Responsibilities
  • Seeking Guidance
  • Reporting Violations
  • Investigations of Suspected Violations
  • Discipline for Violations
  • Waivers of the Code
  • No Rights Created
  • Remember