The "CODE"

The President and owner of Warmelin Precision Products, LLC (WPP) has adopted the following Code of Ethical Business Conduct (the "Code") for directors, managers and employees of WPP. This Code is intended to focus the directors, managers and employees of WPP on areas of ethical risk, provide guidance to help them continue to effectively recognize and deal with ethical issues, enhance existing mechanisms to continue the reporting of unethical conduct, and help to continue to foster and sustain a culture of honesty and accountability. Each director, manager and employee of WPP must comply with the letter and spirit of this Code. No code or policy can anticipate every situation that may arise. Accordingly, this Code is intended to serve as a source of guiding principles. Directors, managers and employees of WPP are encouraged to bring questions about particular circumstances that may implicate one or more of the provisions of this Code to the attention of the President and owner of the Company.

1. Conflict of Interest

Directors, managers and employees of WPP must avoid any conflicts of interest between them and WPP. Any situation that involves, or may reasonably be expected to involve, a conflict of interest with WPP, should be disclosed promptly to their immediate supervisors.

A "conflict of interest" can occur when a d irector, managers and employee‘s personal interest is adverse to -- or may appear to be adverse to -- the interests of the Company as a whole.

This Code does not attempt to describe all possible conflicts of interest that could develop. Some of the more common conflicts from which d irectors, managers and employees of WPP must refrain, however, are set out below.

  • Relationship of Company with third parties . Directors, managers and employees of WPP may not engage in any conduct or activities that impair WPP's relationship with any person or entity with which WPP has or proposes to enter into a business or contractual relationship.
  • Personal use of Company assets . Directors, managers and employees of the WPP may not use WPP’s assets, labor or information for personal use.

2. Corporate Opportunities

Directors, managers and employees of WPP are prohibited from: (a) taking for themselves opportunities related to WPP’s business; (b) using WPP’s property, information, or position for personal gain; or (c) competing with WPP for business opportunities.

3.0 Confidentiality

Directors, managers and employees of WPP shall maintain the confidentiality of information entrusted to them by WPP and any other confidential information about WPP that comes to them, from whatever source, in their capacity as a Director, manager or employee, except when disclosure is authorized or legally mandated. No directors, managers and employees of WPP shall use confidential information for his or her personal benefit or to benefit persons or entities outside WPP. For purposes of this Code, "confidential information" includes all non-public information relating to WPP. For full details of WPP confidentiality guidelines refer to WPP employee handbook.

4.0 Encouraging the reporting of any illegal or unethical behavior

Directors and managers of WPP shall continue to promote ethical behavior and take steps to ensure that WPP continues to: (a) encourage employees to talk to supervisors, managers when in doubt about the best course of action in a particular situation; (b) encourage employees to report violations of laws, rules, regulations or WPP’s Ethical Business Conduct Guidelines to their immediate supervisors and managers; (c) inform employees that WPP will not allow retaliation for reports made in good faith; and (d) inform employees that, under no circumstances, record dimensional values on various documents if not properly measured by the employees.

5.0 Compliance Procedures

Any suspected violations of this Code should be reported through WPP website under Code of Conduct.

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