CAMPEON ROOFING CODE OF CONDUCT

Human Resources

It is Campeon’s commitment that all employees and job applicants will be afforded equal opportunity for employment and advancement at every level of employment without regard to race, color, religion, pregnancy, ancestry, age, gender, national origin, sexual orientation, mental or physical disability, marital status, or status as a disabled veteran or Vietnam-era veteran, and to conform to all applicable employment-related laws and regulation.

Workplace Environmental, Health and Safety

Campeon is committed to the safety and health of its employees and to complying with all applicable health, safety and environmental laws and regulations wherever it does business. The Company has an Environmental, Health, & Safety Committee made up of a representative group of its senior managers to oversee compliance with its policies and to identify opportunities for continuous improvement in these areas. All employees are obliged to report any violation of health, safety, or environmental laws, and are encouraged to identify ways to conduct business which help to minimize these issues at Campeon’s facilities and all of its customer’s facilities.

Advertising, Marketing and Promotion

It is Campeon’s policy to be truthful, fair, and honest in the advertising, marketing, and promotion of its products. Advertising and promotion of Campeon products and services complies with all applicable laws and regulations.

Antitrust and Competition Law

Campeon employees must abide by all antitrust and competition laws in each. Applicable laws vary from jurisdiction to jurisdiction, but the following types of behavior are almost universally prohibited: agreements with competitors to fix prices or to boycott specified suppliers or customers, agreements with competitors to allocate products, markets or territories, and certain types of behavior which constitute an attempt to monopolize.

Fair Dealing

Campeon expects all its personnel to deal honestly and fairly with the Company’s customers, suppliers, competitors, and fellow employees. It is unacceptable to take advantage of third parties through manipulation, fraud, concealment, abuse of confidential or privileged information, misrepresentation of material facts, or any other unfair dealing or practice.

Financial Integrity

Campeon maintains its books and records in a manner that provides for a reliable and auditable record of its financial transactions, in conformity with generally accepted accounting principles. The Company devotes substantial internal and external resources to assure the accuracy of its financial statements and the entries and transactions underlying those statements. It also places significant focus and attention on assuring that all disclosure requirements are met in every jurisdiction where those requirements apply.

Implementation

All Campeon employees and officers are provided with specific guidance on the company’s expectations and requirements for ethical conduct. Employees are expected to participate in periodic training with respect to safety, customer relations and ethical conduct.