General Cable Code of Ethics and Compliance Guidelines

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