General Cable Code of Ethics and Compliance Guidelines

Code of Ethics andBusiness ConductWIRED AS ONECOMPANY • VISION • VALUES

Core ValuesDear Fellow General Cable Employees,Every day, we are faced with choices about how to operate our company successfully. The decisions we make impactthe Company’s reputation and reflect on each of us as individuals. Our Code of Ethics and Business Conduct emphasizesour values and summarizes the policies and principles that we must continue to follow. Our commitment is to responsiblyWe behave safely inall that we do.conduct business with integrity, and our values-based Code is designed to help us accomplish that. By embracing anddemonstrating our values (Customer Responsiveness, Integrity, People, Respect, Responsibility and Safety) and theprinciples within our Code, we will be WIRED AS ONE SM .We act responsibly forour individual andcollective actions andresults.We anticipate andrespond tocustomer needs.Our Code highlights each of our values and provides guidance on the expected behaviors that are necessary to embraceand demonstrate them. In many cases, our Code may refer to a more detailed compliance policy with more specificguidance on that topic area. In addition, many examples throughout the Code illustrate possible situations where you couldbe faced with an ethical dilemma. Please review these examples, as they will guide each of us to the appropriate actionshould one of these situations occur.We respect eachother and succeedas One Company.WIRED AS ONECOMPAN Y • VISION • VALUE SWe work together withintegrity and speakwith truth and candor.Our Code is designed to provide guidance, but by its very nature, it cannot address every possible situation that may arise.When our Code does not address a concern, or if it is not clear how a particular situation should be handled, then weshould always seek guidance from Company resources, which include, among others, local and regional leaders, humanresource leaders and our Global Legal Team.I am committed to our employees, officers and directors using sound judgment and operating our business consistentwith our values: Customer Responsiveness, Integrity, People, Respect, Responsibility and Safety. We are each responsiblefor knowing the expectations set forth in our Code and demonstrating a personal commitment to our values and ethicalprinciples. In addition to being responsible for our own behaviors, we are also expected to raise questions and report anypotential violations of our Code. If we are uncomfortable with the guidance we receive, then we are expected to elevate ourconcerns to a regional or global leader or utilize our ethics hotline.We value peopleand their collectiveknowledge, skillsand expertise.With our commitment to our values and Code, we uphold our philosophy of operating as One Company, WIRED AS ONE.At General Cable, we live a common set of value-based principlesthat guide our behaviors in our performance-driven culture.1

Table ofContentsCustomerOur Code of Ethics 5Responsibility 6Reporting Concerns 7and Seeking GuidanceNon-Retaliation Policy 7Violations 8Expectations for Leaders 8Certification 8Integrity 10Conflicts of Interest 11Confidentiality and 13Public DisclosureInsider Trading 15Accurate Records 16Proper Use of 17Company AssetsAnti-Corruption 17Competition Laws 18International Business 20Anti-Money Laundering 21Conflict-Free Minerals 21Safety 22Quality and Safety 23Health and Safety 23Environment 23Responsiveness 24Government Customers 25Quality Products 25Fair Marketing 25Accurate Billing 25Internet and E-mail Usage 27Respect 28Diversity 28Harassment 29Corporate Social 29ResponsibilityHuman Rights 29People 30Attracting, Developing 30and RetainingEmployee Personal 31InformationCommunity and Political 31InvolvementIntellectual Property 31Conclusion 32Our Commitment 32Our Code 32Ethical Behavior Tree 33Waivers & Amendments 34Conflicts with Local Laws 34Resource List 35Contact Information 36Ethics Hotline 362 3

Our Codeof EthicsOurCode of Ethics and Business Conduct(“Code”) sets forth the principles andbehaviors that are expected of GeneralCable employees in our performancedrivenculture. These principles, combinedwith our values, guide us in how to operateas One Company. And as One Company,we are each expected to conduct our businessin accordance with the principles andbehaviors set forth in our Code, including:At General Cable, we have one Codeof Ethics that applies to all employees,officers and directors in North America,Latin America, Europe, Africa and Asia-Pacific. As a global company, we haveoperations in numerous countries spreadacross six continents, and regardless ofwhere an employee resides, we all areobligated to comply with both our Codeand local law. If our Code conflicts withlocal or any applicable law, we must• Customer Responsiveness:Anticipate and respond to customerneeds.• Integrity: Work together with integrityand speak with truth and candor.comply with the applicable law. Anyadditional expectations in our Code thatdo not violate local laws are expected tobe followed, even if our Code conflictswith local custom or business practice.• People: Value people and their collectiveknowledge, skills and expertise.• Respect: Respect each other andsucceed as One Company.• Responsibility: Act responsibly inour individual and collective actionsand results.• Safety: Behave safely in all that we do.While our Code sets forth expectationsof our individual behaviors and violationsof the Code may result in disciplineor even termination of employment, itdoes not create a contract, guaranteeof employment, or convey any specificemployment rights for any period of time.Wired As One…Company…Vision…Values45

ResponsibilityWe act responsibly for our individual and collective actions and results. We embrace teamworkand assume responsibility for our actions and their consequences, both to the company andthe communities in which we operate. We strive to perform, take ownership for successesand failures, and learn through continuous improvement. We represent the company withprofessionalism, and we create long-term shared value for our company and the communitieswhere we live and work.Reporting Concernsand Seeking GuidanceDuring the course of business, we will likelyface a situation in which we are uncertainabout the right course of action. Our Codeis designed to provide guidance, but byits very nature, it cannot address everypossible situation that may arise. When ourCode does not address a concern, or if it isnot clear how a particular situation shouldbe handled, then we should always seekguidance from Company resources, whichinclude:• Local leadersOur Ethics Hotline is a 24-hour phoneline and website maintained by ourGlobal Legal Team and administered byan independent third-party provider. It isavailable to all General Cable employees,suppliers, customers, contractorsand agents to seek guidance or raiseconcerns about potential violations ofour Code, as permitted under local laws.Reports may be made anonymously inthe United States and wherever local lawsallow. Calls to the Ethics Hotline are nottraced or recorded, and all reports will bekept confidential to the maximum extentpossible, consistent with local law.Non-RetaliationPolicyWe should each feel comfortable seekingguidance and reporting potential violationsof our Code. Retaliation for reportingconcerns in good faith is against ourvalues and will not be tolerated. Reportingconcerns in good faith means the reportwas truthful, sincere and complete to thebest of the reporting person’s knowledge.Any act of retaliation is a violation of ourCode and should be reported immediately.Retaliation is when an employer orsupervisor takes an adverse action• Human Resource leaders• Regional leaders• Global Legal TeamIn addition, we are expected to report anyknown or suspected violations of our Codeor applicable law to Company Resources orthrough our Ethics Hotline.Our Ethics Hotline is available by:PHONE:• U.S.: +1 877-256-8862 (toll-free) or+1 770-582-5269 (direct)• Non-U.S.: Use the toll-free numberbased on the country from which youare calling. For a list of country-specificphone numbers, see the Ethics Hotlinesection at the end of our Code.against an employee for engaging ina legally protected activity, such asreporting a compliance or ethical concernor participating in an investigation.Examples of retaliation may include anadverse job action, such as demotion,discipline, termination, salary reduction,or job or shift reassignment whenmotivated by the protected activity.WEB:• www.wiredasone.comQ.Lin, a female accountant, reported being harassed by the VP of Manufacturing. The local HR Manager investigated her complaint,and while the VP’s behavior was not harassment under the law, his behavior was inappropriate under Company policy, and he wasdisciplined. Prior to the investigation, Lin’s male supervisor, the Plant Controller, would have private lunches with each of his direct reports.After the investigation, Lin’s supervisor decided to only go to lunch with two or more direct reports at a time to avoid the appearance ofinappropriate behavior. Is this retaliation?A. Yes, the supervisor has changed his lunch meetings as a result of Lin’s complaint and decreased their interactions due to her report.B. No, the supervisor can change his lunch habits provided he is not discriminating against Lin for filing a complaint.6Answer: B. In this case, the supervisor changed his behavior to prevent the appearance of inappropriate behavior, and such changeimpacts all employees equally.7

IntegrityWe work together with integrity and speak with truth and candor. We demonstrate teamworkand collaboration, and encourage the sharing of diverse opinions, ideas and views. We takepersonal responsibility to act with integrity, inspire trust with our colleagues, and exhibit thecourage to speak up and do the right thing.Conflicts of InterestAs General Cable employees, we owe aduty of loyalty to General Cable and mustact in the best interest of our Companywithout having any improper conflictsof interest. A conflict of interest occurswhen our personal interest interferes – orappears to interfere – in any way with theinterests of the Company as a whole orwith our ability to perform our jobs withoutbias. For example, conflicts of interestarise when an employee, director, or amember of his or her family receives animproper personal benefit as a result ofsuch employee’s or director’s positionwith the Company. Conflicts of interestalso may arise when an employee ordirector takes action or has interests thatmay make it difficult to make objectivedecisions on behalf of the Company or toperform his or her duties objectively andeffectively.to possible conflicts of interest, somecommon areas where conflicts of interestoccur are set forth below.Gifts and EntertainmentAt General Cable, we have strongrelationships with our business partners,and business courtesies such as gifts,favors and entertainment are commonamong some of our business partners.However, giving and receiving businesscourtesies can raise the appearance, if notthe reality, of a conflict of interest. It mayalso present concerns under anti-briberyand corruption laws. We must alwaysexercise good judgment, modesty anddiscretion when giving and receiving gifts.As a general rule, we must not accept,directly or indirectly, or solicit for ourbenefit or the benefit of a colleague, familymember or friend any of the following, allof which are treated as “gifts” under thisGenerally, “token value” means anaggregate value less than $200 (orsmaller, depending on what is customaryin the local community where the giftis given) from the same person orbusiness entity in any year. “Excessiveentertainment or travel opportunities”means travel, hospitality, and meals orentertainment which cannot be viewed asreasonable and customary in a businesscontext. When in doubt about a gift orwhether proposed travel or entertainmentis excessive, or upon the receipt of a giftof more than token value, please ask ourGlobal Legal Team for guidance.This general rule is applicable to all ofour business relationships, whetherwith private entities or with governmentbodies or officials. In certain limitedcircumstances, exceptions to our gift andentertainment rules may be granted bythe Global Legal Team, provided thereBeing involved in a potential conflict ofinterest does not violate our Code, butfailing to disclose it or delaying disclosureis a serious violation. When a potentialconflict of interest arises, it is importantthat we immediately disclose all facts andcircumstances of the potential conflict toour manager and our Global Legal Team.Our Global Legal Team will evaluate thepotential conflict of interest and advisehow to manage the conflict.policy:• Gifts of more than token value• Excessive entertainment or travelopportunities• Loans (other than from establishedfinancial institutions on the same termsthat are currently available to othercustomers similarly situated)• Other substantial favors for personalbenefit from any business that doesor is seeking to do business with ouris a legitimate business reason for theexception and the Regional LeadershipTeam supports such exception. It isimportant to note that there are stricterrules regarding the giving of or offering togive gifts, favors and entertainment to anypublic government official or their familiesas well as state-owned or -controlledcompanies. Refer to the Anti-Corruptionand Government Customers sections ofour Code for more information.While it is impossible to describeevery circumstance that may give riseCompany or is a competitor of ourCompany1011

IntegrityAn example of asignificant potentialconflict is when thespouse of the plant’sfinancial controlleris being consideredfor an accountingposition at thesame plant.Related EmployeesEmployee referrals of former colleagues,friends and family members are welcomeand appreciated at General Cable.However, due to the appearance of aconflict of interest, or more specificallyfavoritism, the proposed hiring of a familymember must be proactively discussedwith local HR and approved by theRegional Chief Executive Officer in chargeof the business function for which theperson is being hired.To avoid any conflict of interest, GeneralCable prohibits the employment offamily members in all circumstanceswhere one family member is under thedirect or indirect supervision of anotherfamily member, or where one familymember would have direct influenceover the conditions of the employmentrelationship with the other family member.This includes, but is not limited to,hiring, promotion, performance reviews,compensation, benefits, training andcareer opportunities.Under our Code, the term “familymember” includes, but is not limited to:• Spouse, registered partner, domesticpartner, unmarried couple, romanticrelationship• Child, stepchild, grandchild, nieceor nephew• Parent, stepparent, grandparent, auntor uncle• Siblings (brother or sister) or cousins(first or second)• In-laws (father, mother, sister, brother,son, daughter)• Other relationships established byblood, marriage or legal actionIn certain situations, due to thesignificance of the potential conflict,approval from our Global Legal Team willalso be required.Outside Employment, FinancialInterest and DirectorshipsAs General Cable employees, we areeach expected to devote our full workingtime to the duties of our positions withthe Company and not to have any outsidefinancial or employment interests thatinterfere with our work responsibilitiesor General Cable’s best interests. Thismeans that we must not:• Work for another employer that in anyway limits our ability to fulfill the dutiesof our General Cable position• Own a substantial financial interest inany business that we know or havereason to believe may have a currentor future business relationship with, oris a competitor of, our Company• Own or engage in business activitiesthat compete with, sell or buy fromGeneral Cable• Use General Cable tangible orintangible property, know-how,information technology assets,facilities or intellectual property toconduct non-General Cable business• Serve as a director in for-profitcompanies unrelated to GeneralCable or trade organizations unlessapprovedin advance by our GlobalLegal Team and the Regional ChiefExecutive OfficerA substantial financial interest is whenthe value of the beneficial ownership ofany class of stock or securities (besidesour Company stock) is more than 25%of your annual salary. The ownershiprestrictions do not prohibit the acquisitionor ownership of less than 1% of anycorporation’s equity securities traded on anational securities exchange or the NYSEor quoted on the NASDAQ.Exceptions to these restrictions, otherthan those permitted by local law, mustbe discussed with a member of yourleadership team and approved in advanceby our Global Legal Team and theRegional Chief Executive Officer or theirlocal designee.As employees committed to the successof General Cable, we should never takefor ourselves any business or investmentopportunity that we learn of through ourrelationship with our Company. In addition,we must never help anyone else, includingfamily and friends, take such business orinvestment opportunity for personal gain.Personal LoansGeneral Cable does not provide personalloans, guarantees or other extensionsof credit to any director or executiveofficer, regardless of whether doing so ispermitted by local law.Confidentiality andPublic DisclosureWe must always protect Companyconfidential information and may neverreveal such information to any outsideparties unless properly authorized orlegally required to do so. Disclosureor unauthorized use of our Company’sconfidential information concerningany aspect of our business, finances,operations or intellectual property ofthe Company such as business plans orstrategies, new product developmentplans or drawings, price and cost dataor costs of doing business is prohibited.Similarly, disclosure or use of confidentialinformation obtained about companiesthat General Cable is or is consideringdoing business with is prohibited. Thisinformation remains confidential until theCompany has disclosed it or made itotherwise generally available to the publicthrough the press, periodicals, financial orbusiness publications or similar sources.We are expected to take all appropriateprecautions to safeguard confidential andproprietary information under our control.For example, we must keep it in a securelocation and limit disclosure to only thoseemployees with a business purpose forknowing such information. Our obligationto protect such confidential informationcontinues indefinitely, whether or not weremain employees of the Company, untilour Company publicly discloses it.When we have a business need todisclose such information to a third party,a confidentiality agreement (also knownas a nondisclosure agreement) must beentered into that requires the third partyto keep the information confidential beforeany disclosure of Company informationoccurs.What should we do if there is aninadvertent disclosure?As soon as an inadvertent disclosure ofconfidential information is discovered, it iscritical to contact our Global Legal Teamso that actions may be taken to furtherprotect such information and comply withany necessary disclosure requirements.Q.Ahmed recently heard that General Cable was considering purchasing a certain property not too far from his parents’ home.May he or a family member buy the property in hopes of reselling it to General Cable? Does the answer change if Ahmed and/ora family member wants to buy the property and use it to farm?We work together with integrity and speakwith truth and candor.Answer: Ahmed may not buy the property with the hopes of selling it to General Cable, because this would be taking a corporateopportunity. If Ahmed purchased the land to use as a farm, this would need to first be offered to the Company, because Ahmed learnedof the opportunity due to his position at General Cable, and he would be taking that opportunity from the Company.12 13

IntegrityWe also may not directly or indirectlymake, promise, offer, or authorize themaking of any improper payment toany person if the purpose or intent isto obtain an unfair business advantage.Improper payments can include any giftof money or anything of value, as well asany other illegal or improper inducement.Particular caution is required whenoffering any payment, donation or anygift (including travel expenses, hospitalityand entertainment) to a local or overseaspublic official. A public official is generallya national, local or overseas governmentofficer or employee, member of a politicalparty, party official, candidate for politicaloffice, employee of government-ownedor -controlled entities or their familymembers or designees.In certain limited situations, we may makefacilitating payments to speed up theperformance of a routine governmentalaction. However, such facilitating paymentmust be small, infrequent payments andonly made if clearly permissible underlocal law. Facilitating payments are illegalin a number of the places where GeneralCable does business around the world,and we must not assume that they arepermitted. In addition, all facilitatingpayments must be properly recordedin the Company’s financial statements,and supporting documentation should bemaintained for all facilitating payments.Therefore, you must contact the GlobalLegal Team before making a facilitatingpayment.In a situation where you believe that yourlife or safety is in danger, General Cable’santi-corruption and related policies do notapply, and you can provide the personmaking the demand or threat whatever isrequired to ensure your safety. Once youreach safety and conclude that you are nolonger in danger, you must immediatelyreport the situation to our Global LegalTeam. Your report should include detailsconcerning the location of the incident,the name and position (if available) of theperson making the demand, the demand,and what you provided to meet thatdemand. If cash or a cash equivalent wasprovided, please report the value. Suchexpense is reimbursable, provided youfollow this process.Please refer to our FCPA and Anti-Corruption Policy for more information.Competition LawsIn order to achieve our businessobjectives, our Company competesaggressively and creatively in themarketplace. We strictly comply with allcompetition laws designed to protectcompetition and free enterprise, includingU.S. antitrust laws, European competitionlaws and other competition laws in effectin the countries where we do business.Discussions with competitors regardingfixing prices, allocating markets, dividingcustomers, or otherwise restrictingcompetition are not consistent with ourvalues and violate laws designed toensure fair competition. We may not,directly or indirectly, enter into formalor informal agreements with customers,suppliers, or other business partnersthat may limit competition, such asagreements to tie products, fix resaleprices, or divide markets or customers.There are severe penalties for both theCompany and individuals for violationof these competition laws, includinglarge fines and possible imprisonment.In addition to criminal punishment,individuals can face costly and timeconsumingpersonal liability.Q.Parker, the Vice President of Sales, sees Elizabeth, a former colleague, while attending NEMA, an annual industry event.Elizabeth, who now works for a competitor, tells him that her company is interested in allocating markets to help both companiesbe more profitable. Can Parker agree to this? What should he do?18Answer: Parker cannot make this agreement, as it would be inconsistent with our values and is a violation of our Code and local law. Heshould tell Elizabeth that he cannot agree with a competitor to limit competition. In addition, Parker should report the competitor’s requestto the Global Legal Team.19

IntegrityInternationalBusinessTrade ComplianceWe are expected to comply with applicableinternational trade laws and regulations, aswell as U.S. trade restrictions.Exports are goods or services thatoriginate from a location in one countryand are then shipped to another country.Re-exports are goods that have beenimported and, after some manufacturingor additional processing, are exportedto another country, whether or not theoriginating country. Due to various traderegulations, it is against Company policyto transact business with any customer,supplier or any type of potential businesspartner with any presence in Cuba or Iran.In addition, the Company follows tradelaws that limit trade with customers inrestricted countries such as but not limitedto Belarus, Burma, Cote d’Ivoire, Liberia,Libya, North Korea, Sudan, Syria, andZimbabwe.• Obtain and comply with all necessarylicenses• Verify that the recipient and all endusers are eligible to receive thesegoods and obtain all required end-usercertifications• Ensure no products are being shippedto prohibited countries, such as Cuba orIran, or prohibited persons• Confirm that no product is beingshipped by either export or re-export toa prohibited customer or to a customerlocated in a restricted country inviolation of U.S. law if done by a U.S.person (even if the shipping is beingdone by a non-U.S. person or entity)• Screen all parties to internationaltransactions and all notified end usersagainst the current worldwide listprohibited parties, including customers,shipping companies, freight forwarders,agents, intermediate consignees,banks, etc.It is our responsibility to report anyconcerns we may have about violationsaccurate payments of duties, taxes, andother applicable fees. We must also complywith all end-user restrictions. Please notethat the Company does not accept importsof cassiterite or tin from the DemocraticRepublic of Congo or the surrounding regionsthat are determined to be conflict regions.We each have a duty to report to our GlobalLegal Team any suspected violations ofapplicable import and/or export laws andregulations by any General Cable companiesor our customers.Anti-BoycottsSome countries attempt to controlcommercial relations by requiring a pledgeto abstain from conducting business withthe government of or businesses locatedin certain countries, with U.S. citizens,or with U.S. companies based on race,religion or national origin. In these cases,we follow all U.S. laws as well as any otherapplicable anti-boycott laws that prohibitcooperating with boycotts not sanctionedby the U.S. or applicable government.Anti-MoneyLaunderingOur Company is committed to taking allreasonable steps necessary to complywith applicable laws that prohibit moneylaundering or financing for illegal, illegitimateor criminal purposes. Money laundering isthe concealment of the proceeds of illegalactivities or trying to make the sources ofthe illegal funds look legitimate.“Red flags” typically associated with moneylaundering include but are not limited to:• Unusual requests to exchange funds viaoffshore accounts• Supplier or customer requests forcash payments• Unusual payment terms, includingpayments to unrelated third partiesdesignated by suppliers or customersWe must ensure that we are conductingbusiness with respectable customers forlegitimate business purposes. As such,we should report any “red flags” to ourGlobal Legal Team or our Ethics Hotline.Conflict-FreeMineralsWe do not manufacture any productscomprised of columbite-tantalite, alsoknown as coltan (tantalum), gold orwolframite (tungsten). In certain products,General Cable uses tin, which is extractedfrom cassiterite. We are committedto sourcing tin from suppliers who donot obtain cassiterite or tin from theDemocratic Republic of Congo or thesurrounding regions that are determinedto be conflict regions. At any time in thefuture, if we were to manufacture productscomprised of any of these minerals ortheir derivatives, we would not obtain suchminerals from conflict regions.Please refer to our Conflict Minerals Policyfor more information.When we engage in exporting goods,we must always:of export laws and restrictions to ourCompany Resources.Under applicable laws, we must report anyrequests to participate in an illegal boycott.Consequently, all boycott requests, whether• Understand any restrictions whichspecifically apply to the export orre-export of the particular goods beingexported or re-exportedImports are goods or services originatingin a foreign country that are shipped intoyour location. With regard to importedgoods, we must abide by all licensingand customs requirements and declareor not U.S.-sanctioned, must be reportedimmediately to our Global Legal Team.Please refer to our Policy on InternationalBusiness Dealings for more information.the proper value amounts to ensure20We work together with integrity and speakwith truth and candor.21

SafetyWe behave safely in all that we do. We are committed to the safety of our people — at all times.We understand and follow all safety rules and practices, and we highlight deficiencies we see.We assume personal responsibility for our individual safety as well as for the safety of others.We act safely on and off the job, and continuously recognize the positive impact of safebehavior on business results and on our personal well-being.Quality and SafetyWe are committed to providing safe,innovative products to our customers;manufacturing our products in compliancewith all applicable laws and regulations; andconforming to all contract specifications.Consistent with our own safety expectations,we select suppliers who are equallycommitted to producing safe, qualityproducts. We expect our suppliers toensure the safety and performance oftheir products and services. With this jointcommitment by General Cable and oursuppliers, we provide safe, quality productsto our customers.Please refer to our Policy and Guidelineson Environment, Health and Safety formore information.Workplace ViolenceOur Company expressly prohibits any acts orthreats of violence by any current or formeremployee or business partner against anyother employee or business partner in oraround the workplace or elsewhere at anytime. It is the personal responsibility ofeach of us to contribute to a safe workingenvironment.In addition, our Company strictly prohibitsemployees from possessing firearms of anyprescription medicine when conductingbusiness on behalf of our Company. Beingunder the influence of such substancescan create a serious risk to our safety andthe safety of others and will be regardedas serious misconduct. However, there isa limited exception for responsible use ofalcohol at business dinners or authorizedCompany events, provided all applicablelaws are followed.EnvironmentWe are committed to producing andmarketing products in an environmentallysound and responsible mannerand complying with all applicableHealth and SafetyWorkplace SafetyWe each have a right to work in a safeworkplace. To ensure our workplace is safe,we each have a personal responsibility toconduct our work in a safe manner and towatch out for and immediately report anyunsafe actions and/or conditions. If we areever asked to do a job that appears to beunsafe or that we have not been properlytrained to perform, we must notify ourimmediate supervisor or human resourceleader. Also, if we are taking medicationthat may impair our ability to work safely,we must notify our immediate supervisor orhuman resource leader.type, including those for which they have alegal permit, while on Company property ordriving Company vehicles, at any time.We are responsible for reporting violenceor threats of violence to our immediatesupervisor or to the human resourceleader. Also, we have a duty to inform ourimmediate supervisor or human resourceleader of any activity in the workplaceinvolving current or former employees,customers, visitors, suppliers, or otherpeople that we believe will likely resultin violence.Drug and Alcohol UseWe all must be free from the influenceenvironmental laws. As a global leaderin the wire and cable industry, werecognize our role and responsibility inpromoting sustainability. We focus oncontinuous improvement in all areas of ouroperations. Across our many businesses,the quest to introduce new and betterproducts through continuous improvementin environmental designs reflects ourcommitment to achieving industry-leadingstandards and responding proactivelyto global environmental issues. We areproud to be the first cable manufacturerto obtain certification for an environmentalmanagement system, in accordance withthe ISO 14001 and EMAS standards.of alcohol, drugs and improperly usedWe behave safely in all that we do.2223

Customer ResponsivenessGovernment CustomersOur Company regularly sells its products togovernment entities, including governmentownedor -controlled companies. When• Engage current or former governmentemployees in discussions aboutpotential job opportunities without firstconsulting our Global Legal TeamFair MarketingWe speak with truth and candor whenrepresenting our Company and maintainhigh standards of fairness and honestyWe anticipate and respond to customer needs. We view all we do through the eyes of ourcustomer, continuously striving to understand their business and anticipate and address theirevolving needs. We focus on being value-added, innovative, timely and responsive with ourcustomers and we sell, produce and deliver with quality.working with government customers, wemust be aware of and abide by the strictlaws, regulations and procedures that applyto government contract work. For those of uswho sell to or service government customers,we have an even greater responsibilityShould we have any questions or beunsure as to what rules apply, weshould seek guidance from our GlobalLegal Team as well as our governmentcustomer.when engaging in all aspects ofbusiness, including our sales, marketing,promotional and advertising pursuits. Ourproducts are of the highest quality, andwe market strictly on the merits of ourproducts and services. We should neverto know and follow these often complexgovernment contracting rules. These rulesare often more strict and complex than therules governing our dealings with commercialcustomers.While we are committed to conducting all ofour business with integrity, it is critical thatwe understand that we must never:• Make any representations, whether verbalor written, including pricing, bids, invoicesor billing information, that are untruthful orincomplete• Take actions that would create anunfair competitive advantage, such asobtaining or using sensitive or confidentialprocurement informationPlease refer to our policies on GovernmentContracting for more information.Quality ProductsWe strive to exceed our customers’expectations for quality and performancein all of our products. At General Cable,quality is not something that is achievedand then forgotten, but somethingthat we work to improve every dayby continuously focusing on design,manufacturing, technology, and control.We apply Lean Sigma company-wide,seeking innovative ways to differentiateour products and services and to serveas our customers’ most valued businesspartner.misrepresent the quality, features oravailability of our products and services.Accurate BillingWe are committed to accurately reflectingthe price and quantity of our productson all invoices and bills. Our customersare a critical component of the successof our Company, and fairly representingthe terms of sale on all records,including billing, time cards, invoices andquality testing reports, is required of allemployees. We should never falsify anyrecords and must give proper notificationwhen any terms are modified from theoriginal agreement. It is our responsibilityto understand any contracts for saleof our products and to comply with the• Offer, solicit, promise, give or accept anynegotiated terms and conditions. Pleaseform of bribe or kickback to or from anconsult with our Global Legal Team withactual or potential government customerany questions regarding accurate billing• Use any agents or consultants inprocedures pursuant to a written contract.government contracting other than forlegitimate business purposesWe anticipate and respond to customer needs.2425

Customer ResponsivenessInternet andE-mail UsageE-mail UsageOur e-mail communications are one of themany ways we respond to our customers’needs. It is important that our e-mailcommunications are courteous, professionaland businesslike. When communicating viae-mail, we should provide timely, valueaddedresponses and carefully consider therecipients, message content and need forattachments. Where permissible under locallaws, all e-mails using Company resourcesare subject to monitoring and could be readby someone other than the recipient.Internet UsageWe must use the Internet in an ethicalmanner for business purposes. Whileoccasional personal use is permitted, weshould know that our Company reservesthe right to monitor all use, except whenprohibited from doing so by law. Suchpersonal use should be minimal, notinterfere with our job responsibilities andnot be contrary to the Company’s interests.We may not use the Internet for recreational,unauthorized, illegal, or unethical purposes,or to view, upload or download any sexuallysuggestive or explicit materials.Please refer to the Policy on ElectronicCommunications and the Internet for moreinformation.Social MediaWe recognize and respect that ouremployees have a right to use socialmedia for personal expression. However,along with social media’s benefits comesadded responsibility to use these sitesappropriately. Social media often blurspersonal and professional personas.General Cable technological equipmentor e-mail addresses should not be usedin connection with social media otherthan professional sites. It is inappropriateto reveal any confidential Companyinformation, customer data, trade secrets,private information about colleagues andany other material covered by Companypolicies on a social media site. Inconnection with social media, we must berespectful, courteous and professional toour fellow employees, business partnersand competitors.Q.Carmen and Jose are collaborating on a company project. One afternoon, Jose walks into Carmen’s office without knocking andnotices that she is shopping on the Internet during business hours. This is the third time Jose has personally witnessed Carmenshopping during business hours. What should Jose do?A. Nothing, what Carmen does in her office is none of his business.B. Confront Carmen on her activities that clearly have nothing to do with their project or other company-related business.C. Report the incident to Carmen’s supervisor immediately.D. Either B or C26Answer: D. While occasional personal use of the Company’s equipment is permitted, such use should be limited in nature.Regularly shopping on the Internet during business hours is not minimal and should be reported to Carmen’s supervisor.27

RespectHarassmentWe are committed to a workplacefree from intimidation and harassmentCorporate SocialResponsibilityWe believe corporate social responsibilityHuman RightsWe strive to be a positive presence inthe communities where we work. Ourthat encourages each of us to seek tois about creating shared value. ThisCompany is committed to following allWe respect each other and succeed as One Company. We work together, with a sharedmindset, toward a common goal. We seek to understand, demonstrate empathy, and embracethe diverse opinions and cultures of others. We have the courage to constructively disagree,yet support the final decision even if different than our own.understand and demonstrate empathytowards one another. Harassment is anyform of misconduct, whether verbal,physical, or visual, towards another personthat creates hostile and intimidatingmeans keeping a dual focus in ourbusiness decisions by considering whatis good for our Company as well aswhat contributes to the greater goodof the communities where we live andapplicable labor laws, promoting humanrights wherever applicable, and providingfair and equitable wages. We do notemploy children (or anyone under theage of 14) and follow all applicable lawsDiversityworking conditions and undermines theintegrity of the employment relationship,work. We accomplish this through safety,sustainability, innovation, and citizenship.regarding these standards. We expect oursuppliers and other business partners toA great deal of our innovative success is due to the value we place on the knowledge, skills and expertise of our employees. We respect ourincluding harassment based on race,We have a safety goal of Zero & Beyond,comply with applicable labor and humandiverse workforce and are committed to making all employment decisions based on merit and without regard to race, color, national origin,color, national origin, religion, gender, age,and we are committed to continuousrights laws. Our Company does not usereligion, gender, age, marital status, disability, veteran status, pregnancy or maternity, sexual orientation or any other protected characteristic.marital status, disability, veteran status,improvement in environmental designsforced, indentured or involuntary labor,We feel that our workforce diversity makes us a stronger and more competitive global company working to succeed as One Company.pregnancy or maternity, sexual orientationin order to respond proactively to globaland we do not tolerate human traffickingor any other protected characteristic underenvironmental issues. We also strive tofrom any of our suppliers or businesslocal law.make a difference in our communitiespartners.through volunteer activities and financialRegardless of whether harassment issupport. By working together and usingactionable under local law in the countryour collective ingenuity, innovation andwhere you are operating, we will notcreativity, we can reach our common goaltolerate behavior that creates a hostile andof being the most highly regarded andintimidating work environment. We havesuccessful wire and cable company in theestablished procedures to report suchworld with both green constructions andinappropriate behaviors to our Humandesigns for the ever-growing renewableResource leaders.energy market.Q.Maria is a receiving clerk who manages the shipments of raw materials that are delivered to the loading dock. Each time a deliveryis made, she meets with the truck driver to go over the paperwork and review the goods. Whenever Steve makes a delivery for XYZTrucking, he likes to flirt with Maria by bringing her a rose. He often comments on her appearance or clothing, and once even pinched her whenshe was bending over to pick up a package. If Maria’s supervisor witnesses Steve’s behavior or Maria reports it, her supervisor should:A. Treat Maria’s report as one for sexual harassment under our Code and take steps to investigate it and correct it.B. Contact XYZ Trucking and let them know that their driver is harassing one of his associates.C. Tell Maria that she should contact XYZ Trucking, because Steve does not work for him and there is nothing he can do about it.D. Both A and B.28Answer: D. Sexual harassment at the workplace is not consistent with our values and will not be tolerated. It includes unwelcome sexualadvances, requests for sexual favors and other unwelcome verbal or physical conduct of a sexual nature. Maria’s supervisor should discussthe matter with Human Resources and then address the matter with XYZ Trucking.29

We believe people are the differentiatingbusiness. When any of us are involved in theWe also need to be mindful of ourPeoplefactor in gaining a competitive advantage.We recruit and retain talented people whocollection, storage, modification, transfer,blockage, erasure, or use of personal data,activities and whether or not theyconstitute lobbying. If we engage in anbring specialized knowledge in such areaswe must know and comply with applicableactivity that involves communicating withWe value people and their collective knowledge, skills and expertise. We hire the best peopleas manufacturing excellence, technology,quality, safety, management, purchasing,privacy laws. It is important that we protectemployee data and follow all applicablegovernment officers or legislators in anattempt to influence policy making orfor the job, empower them to perform and provide performance-driven training, development,sales and accounting. As with everythinglaws with regard to international privacy,administrative decisions, we would beongoing coaching and feedback. We recognize and celebrate accomplishments and pay forwe do, we are committed to the continuouseven when this may limit our ability to sendengaging in lobbying. Any and all lobbyingperformance. We demonstrate value for others through words and actions.Attracting, Developing and RetainingAt General Cable, we strongly believe that there is no greater strength than the collective force of skilled, motivated and engaged employeesimprovement of our talented workforce. Wesubscribe to the 70/20/10 developmentmodel, which states that 70% of personaldevelopment comes from on-the-jobemployee data across country borders.Community andPolitical Involvementactivities need to be discussed with ourGlobal Legal Team prior to engaging insuch activities to ensure that all applicablelaws are being followed.who understand our business, improve each day, and strive to meet our continuously increasing expectations. As such, we are committedto attracting, developing and retaining people who are passionate about delivering results and producing high-quality products for ourexperience, special assignments, androtations; 20% comes from mentoring; andWe are encouraged to become activelyinvolved in the communities in which weIntellectual Propertycustomers.We offer our employees opportunities to sharpen their skills every day through rich assignments, focused performance-driven10% from formal training. We recognizelive and work, including participating inWe encourage our employees to betraining and a highly interactive team environment. Our employees are exposed to a wide range of experiences and are encouraged toand celebrate accomplishments of ourCompany-sponsored events. However,innovative and to develop novel inventionsexpress their ideas for continuous improvement.employees and pay for performance.we may not use General Cable’s name orand manufacturing methods that can beRecruiting and developing a local workforceresources in our individual participation inprotected by patents or as trade secretsis part of our commitment to creatingcommunity and charitable events withoutto create a commercial advantage for ourshared value in the communities in which weprior leadership approval. Participation inCompany. As General Cable employees,do business.We strive to hire and developpolitical activities is a personal choice thatunless local law requires otherwise, welocal candidates whenever possible.should only be conducted outside of workrecognize that all of our work producthours and should not use any Companybelongs to our Company, including butBy paying for performance and encouragingresources. In promoting our individualnot limited to any inventions, ideas,the development of our employees, webeliefs or political views, we should neverdiscoveries, improvements, artwork,strive to retain our employees and promoteindicate or suggest that such views areprocesses, designs, software, hardware,from within.being made on behalf of General Cable oror any other materials we may help toEmployee PersonalInformationthat the Company supports such views. Weshould never feel pressured or led to believethat our position at General Cable or thediscover, create or author in connectionwith our work. In addition, we are urgedto report or disclose any invention relatedWe protect employee personal informationchance for future advancement is related into our business to our supervisor or theby following all applicable privacy andany way to our personal support of politicalGlobal Legal Team to ensure its protectiondata protection laws wherever we door charitable causes.as intellectual property.30We value people and their collective knowledge,skills and expertise.31

ConclusionOur CommitmentWe are committed to using sound judgment and operating our business consistently with our values: Customer Responsiveness, Integrity,People, Respect, Responsibility and Safety.Our CodeOur Code of Ethics sets forth the principles and behaviors that we are expected to use in our business operations. These principles, combinedwith our values, guide us in how we want and need to operate as One Company. When our Code does not address a concern, or it is not clearSeeking Help &Reporting ConcernsETHICAL BEHAVIOR DECISION TREEStop. I must takeresponsibility for my actionsand their consequences.on how a particular situation should be handled, we should always seek guidance from our Company Resources. In addition, we are expectedto report any known or suspected violations of our Code or applicable law to our Company Resources or the Ethics Hotline.Don’t do it!noAm I acting responsibly?yesStop. I need to behavesafely in all that I do.nonoAm I complyingwith the lawand ourCompany policy?yesyesAm I behavingsafely?Am Idemonstratingour values?yesWIRED AS ONECOMPAN Y • VISION • VALUE SyesAm I beingrespectful?nonoStop. Our Company’ssuccess depends on eachof us being Wired as One.Stop. Seek to understand,demonstrate empathy andwork together as a team.NOT SURE? Seek guidance when needed.3233

ConclusionWaivers and AmendmentsAny waiver of the provisions of this Code for executive officers or directors of the Company may be made only by our Board of Directorsor a designated Board Committee.Conflicts with Local LawsIf any portion of our Code conflicts with local laws, we should immediately notify our Global Legal Team and be sure to obey the local lawsResource ListResource Contact Information ScopeYour manager, local leaders,or regional leadersEnvironmental, Health andSafety (EH&S)Local or Regional EH&S LeadersAsk questions, raise issues, seek guidanceor raise concernsEnvironmental, health and safety matters, includingcompliance programs and management systemsabove our Code. Nonetheless, if our Code conflicts with local custom or business practice, we must comply with the Code. Any additionalexpectations in our Code that do not violate local laws are expected to be followed. If we have any questions regarding a conflict betweenour Code and our local laws, we should contact our immediate supervisor, human resource leader, or our Global Legal Team.Ethics and Compliance 859.572.8000legal@generalcable.comEthics Hotline:• U.S.: +1 877-256-8862 (toll free)or +1 770-582-5269 (direct)• Non-U.S.: Use the toll-freenumber based on the countryfrom which you are calling. Fora list of country-specific phonenumbers, see the Ethics Hotlinesection at the end of our Code.• www.wiredasone.comGlobal Finance 859.572.8000finance@generalcable.comAsk questions, raise issues, seek guidance or raiseconcerns about any issue, including our Code, valuespolicies and any other ethics or compliance concernsAsk questions, raise issues, seek guidance or raiseconcerns about accounting policies and practices, internalcontrols, financial reporting or other ethical mattersGlobal Trade 859.572.8000 Import, export and boycott issuesHuman ResourcesLocal or Country HR ManagerRegional HR DirectorGlobal HR859.572.8000humanresources@generalcable.comEmployment matters (e.g., harassment, workplaceviolence, substance abuse)Internal Audit 859.572.8000internalaudit@generalcable.comInvestor Relations 859.572.8684info@generalcable.comLegal 859.572.8000legal@generalcable.comAsk questions, raise issues, seek guidance or raiseconcerns about internal controls, auditing or otherethicalmattersShareholder or analyst inquiries or issuesInterpretation of local laws, questions regarding giftsand entertainment, bribery and corruption prevention,fair competition, trading in stock, antitrust, healthcarefraud and abuse, interactions with customers, recordmanagement, intellectual property, consultants, agents orany other legal issue, concern or questionCorporate Communications 859.572.8000 Media inquiries or issuesAudit Committee of theBoard of DirectorsAudit Committee of the Boardof Directors, 4 Tesseneer Drive,Highland Heights, KY 41076 USAauditcommittee@generalcable.comWritten concerns regarding accounting, internal controls,financial reporting, auditing or other ethical matters3435

ConclusionContact InformationGlobal Legal Team:legal@generalcable.comEthics Hotline• U.S.: +1 877-256-8862 (toll-free) or+1 770-582-5269 (direct)• Non-U.S.: Use the toll-free number based on the countryVice President of Internal Audit:internalaudit@generalcable.comfrom which you are calling. For a list of country-specificphone numbers, see the Ethics Hotline section onthis page.Audit and Finance Committeeof the Board of Directors:• Web: www.wiredasone.comauditcommittee@generalcable.comCountry/ProviderAccess Code*Toll-Free NumberCountry/ProviderAccess Code*Toll-Free NumberAngola808 00 011877-256-8862Guatemala – All Carriers138-120877-256-8862Australia – Telstra1-800-881-011877-256-8862Honduras800-0123877-256-8862Australia – Optus1-800-551-155877-256-8862India000-117877-256-8862Australia – OptusN/A1-800-041-856India – BhartiN/A000-800-100-1558Brazil0-800-890-0288877-256-8862MexicoN/A770-582-5269Brazil0-800-888-8288877-256-8862New Zealand000-911877-256-8862Brazil – EmbratelN/A0800-892-1885New Zealand – Telecom New ZealandN/A0800-453166Chile – EntelN/A1230-020-5506Norway800-190-11877-256-8862China – Netcom GroupN/A10-800-711-1244Norway – TelenorN/A800-11222China – Telecom SouthN/A10-800-110-1165Panama – English800-0109877-256-8862Colombia – English01-800-911-0010877-256-8862Panama – Spanish800-2288877-256-8862Colombia – Spanish01-800-911-0011877-256-8862Panama – Cable & WirelessN/A001-877-256-8862Colombia – OrbitelN/A01-800-5-1-82626Peru – Telephonica0-800-50-288877-256-8862Costa Rica0-800-011-4114877-256-8862Peru Americatel0-800-70-088877-256-8862Costa Rica – I.C.E.N/A0-800-011-1254Peru Telephonica0-800-50-000877-256-8862Ecuador – Andinatel1-999-119877-256-8862Philippines – PLDTN/A1-800-1-111-0737Ecuador – Pacifictel1-800-225-528877-256-8862Portugal800-800-128877-256-8862Ecuador – Pacifictel1-800-999-119877-256-8862Portugal – Portugal TelecomN/A800-8-11484Egypt – Cairo2510-0200877-256-8862Puerto RicoN/A877-256-8862Egypt – Outside Cairo02-2510-0200877-256-8862South Africa0-800-99-0123877-256-8862El Salvador – English800-1288877-256-8862South Africa – Telkom South AfricaN/A0800-999-846El Salvador – Spanish800-1785877-256-8862Spain900-99-0011877-256-8862El Salvador – CTEN/A800-6916Spain – TelefonicaN/A900-97-1215Fiji004-890-1001877-256-8862Thailand1-800-0001-33877-256-8862France Telecom0-800-99-0011877-256-8862Thailand001-999-111-11877-256-8862France TelecomN/A0800-91-7450Thailand – CATN/A001-800-11-002-3195France Telecom Development0805-701-288877-256-8862United StatesN/A877-256-8862Germany0800-225-5288877-256-8862US Virgin IslandsN/A877-256-8862Germany – Deutsche TelekomN/A0800-183-0892Venezuela – English0-800-225-5288877-256-8862Guatemala999-9190877-256-8862Venezuela – Spanish0-800-552-6288877-256-8862GuatemalaGuatemala138-126999-9190877-256-8862877-256-8862Venezuela – CANTVZambiaN/AN/A0800-102-9197011-770-582-5269(Not Toll-Free)* For the most current list of AT&T Access Codes, visitwww.business.att.com/bt/access.jspWired As One…Company…Vision…Values3637

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