General Cable Code of Ethics and Compliance Guidelines

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