HAYMAN-WOODWARD

Hayman-Woodward values and is seriously vigilant of its business ethics, corporate governance and transparency of operations. Our board of directors created a Ethics and Compliance program, which is led by our general counsel.

Our program is designed to:

• Observe the highest ethical standards amongst Hayman-Woodward's personnel.

• Effectively prevent, detect, report and address any allegation of misconduct and/or violations of any laws by Hayman-Woodward's personnel.

• Ensure full compliance with government standards, including those set forth in the US Sentencing Commission's Federal Sentencing Guidelines for Organizations. Hayman-Woodward's Standards of Federal Business Ethics and Conduct apply to Hayman-Woodward's employees in every country, as well as third parties when they are acting on Hayman-Woodward's behalf.
   

Our Ethics & Compliance program includes written standards and procedures; training and communications; visible support of senior leadership; appropriate oversight and delegation of authority; auditing and monitoring; consistent enforcement and discipline; and response and prevention.

Hayman-Woodward Code of Business Ethics

The Hayman-Woodward Code of Business Ethics has been was initially adopted in the company's inception in August of 2003, and its current version has been in place since March of 2009.

The new Code is designed to:

• place more emphasis on Hayman-Woodward 's core values.
• give practical examples to our people of what these values mean in their everyday work life.
• accommodate new legal and regulatory developments.
• make the Code more user friendly.
   

The new version of the Code is a result of the joint effort and work by many of our people across geographies and functions. In particular, consultations were held with our country operations and management in order to best accommodate local needs and legal requirements. One very visible aspect of the Ethics and Compliance program is our Code of Business Ethics, which all employees must read and follow. Currently available in 16 languages, the English version was distributed in electronic form to all employees. The Code emphasizes critical areas particular to our organization and business model while highlighting aspects of conduct that are imperative for all employees. Our Code does not incorporate or refer to all policies, but acts as a synthesis of the key policies and principles that should govern all employees' conduct. Our employees periodically certify their compliance with our Code of Business Ethics.