General Cable Code of Ethics and Compliance Guidelines

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