Code of Conduct - crown.com

1 CODE OF CONDUCT2 CODE OF CONDUCTCONTENTS Letter From crown s President ..3 Introduction ..4 Our Values ..4 Global Compliance Policy ..51. Compliance with Laws, Rules and Regulations ..62. People and Safety ..7 Respect for the Individual Health and Safety Environmental Stewardship3. Maintaining Integrity ..8 Integrity and Anti-Corruption Avoiding Conflicts of Interest4. Ethical Business Conduct ; National and International Trade ..10 Fair Dealing Importing and Exporting5. Safeguarding Company Information and Property.

2 11 Protection of Confidential and Proprietary Information Communication Equipment Record Creation and Retention Protecting Assets Corporate Opportunities6. Acknowledgment and Violations of the Code; Non-Retaliation ..12 Acknowledgment Violations of the Code Non-Retaliation7. Further Information and Advice ..13 Connect with Crown3 crown s reputation for integrity is built not only on the quality of crown s products and services but also on crown s employees history of honest, ethical and fair relations with all its business partners.

3 As crown continues to expand worldwide, crown s commitment to integrity remains as strong as ever. Everyone at crown shares in the credit for making integrity a key component of crown s culture and in the responsibility for upholding this the Code of Conduct that follows, you will see the values crown s leadership expects all members of our organization to uphold. Every crown Leader, employee and representative is expected to adhere to this Code of Conduct . If you suspect any violations of the Code of Conduct or any other crown policy, you are encouraged to report such activity to your supervisor or department manager, Human Resources, Compliance & Ethics, or through Connect With crown .

4 Please review this document. If you have questions, please contact your supervisor. Jim Dicke IIIP residentCODE OF CONDUCTLETTER FROM crown S PRESIDENT4 INTRODUCTIONThis Code of Conduct (the Code ) describes the standards of Conduct required of each officer, director and employee of crown Equipment Corporation and its networks of subsidiaries, affiliates and branches around the world ( crown ). The Code sets forth the basic guiding principles and values of crown and all members of the crown organization, which are intended to assist officers, directors and employees in conducting crown s affairs in accordance with law and the highest standards of business ethics.

5 However, the Code is not intended to provide a comprehensive description of all of crown s policies and practices. A copy of the Code is available on crown s website at Other crown policies and procedures are available in the employee manual or can be provided by your supervisor or department members of the crown organization must familiarize themselves with the principles and guidelines contained in the Code and are expected to Conduct their activities on behalf of crown in accordance with the Code. CODE OF CONDUCTOUR VALUESH onesty and opennesswith customers, fellow employees, supervisors, dealers, suppliers and the company as a our products, our processes, and how we all go about our and team spiritin order to improve all company products, services and company standardCompleting all work to the highest companystandard while respecting our fellowemployees efforts to do the , innovation, and qualityin all the work we , punctuality, and engagement in our OF CONDUCTGLOBAL COMPLIANCE POLICYAs a global company.

6 crown and its employees must operate in strict compliance with all laws and regulations applicable to crown s activities around the world. In addition, crown and its employees must adhere to the moral and ethical standards of the individual countries in which crown does previously approved by crown s Chief Compliance Officer, where the Code is more restrictive than local law or practice, crown employees are required to follow the Code, and where applicable laws are more restrictive than the Code, crown employees are required to follow applicable laws.

7 Further, where any provision of the Code requires or permits Conduct that would be in violation of any applicable law for that area, employees must always comply with all applicable OF CONDUCT1. COMPLIANCE WITH LAWS, RULES AND REGULATIONSO beying the laws, both in letter and spirit, is the foundation on which crown s ethical standards are built. All employees must comply with all applicable laws, rules and regulations. Employees must promptly report any violation or suspected violation of law by crown or any crown employee to his or her supervisor or seek guidance as described in Further Information and Advice OF CONDUCT2.

8 PEOPLE AND SAFETYRESPECT FOR THE INDIVIDUALC rown is committed to developing and maintaining a diverse workforce and adheres to the principle of equal employment opportunities for all applicants and employees. Unlawful discrimination in the hiring, promotion, compensation or retention of employees is strictly prohibited. Abusive, harassing or offensive Conduct is not permitted, whether verbal or physical. Examples include unwelcome sexual advances and derogatory ethnic or racial comments. Retaliation against any employee for reporting discrimination or harassment will not be AND SAFETYC rown is committed to ensuring its work environments meet the highest standards in protecting the health and safety of crown s employees, customers, suppliers and guests.

9 Each employee has responsibility for maintaining a healthy workplace for all employees by following health and safety rules and practices and by reporting accidents, injuries, and unsafe equipment, practices or conditions. Members of the crown organization must comply with applicable health and safety regulations and crown s policies, procedures and safety initiatives and must immediately report any unsafe working conditions to their supervisor or as described in Further Information and Advice protect the health and safety of its employees, crown prohibits the use, sale, possession, or being under the influence of alcohol, illegal drugs, or controlled substances (except when permitted by company policy)

10 By employees while performing work duties, while using crown vehicles, or when using personal vehicles in the course of conducting business on behalf of crown . ENVIRONMENTAL STEWARDSHIPC rown takes pride in its industry-leading environmental stewardship and sustainability record, policies and initiatives. crown is proud to provide an environmentally friendly and safe work environment. For these initiatives to be effective, employees must follow all laws, regulations, policies, and procedures that apply to their respective facilities, including record-keeping and reporting requirements.