PennEngineering®
Code of Conduct1

Dear Colleagues,
PennEngineering has a proud 80-year history, and we recognize that our
future success will be both achievable and sustainable only if we always act
in a manner consistent with our Core Values of Customer-Focus, Innovation,
Respect, Collaboration, and Integrity. We expect our managers to actively
foster and model the Core Values within our teams, and each one of us,
regardless of position, must always comply with all laws, regulations, andcompany policies. We expect a similarly high standard of integrity from thevendors, suppliers, and business partners with whom we work.
How you act at work matters. The Global Code explains PennEngineering’s
expectations of you and will help ensure each of us do the right thing at all
times, everywhere we operate. Please take time to read this Code, keep itin mind and use it, along with your local policies and procedures, to guide
your decisions and actions.
If you have questions about what’s right, seek guidance, whether withyour manager, your local HR manager, PennEngineering’s General Counsel,
or our Vice President of HR and Talent. Similarly, you can submit an email
to speakup@pemnet.com with any concerns you may have about potential
misconduct. PennEngineering® will undertake the appropriate review orinvestigation, and we will not permit any reprisal against you for a report
made in good faith.
Through these actions, we intend to protect our reputation and maintain thetrust of all of our stakeholders including employees, customers, regulators,
and shareholders.
Thank you for joining me in an unwavering commitment to our Core Values.
Pete George, CEO2

PennEngineering Code of Conduct
INTRODUCTION
Our Core Values and Behaviors
Four Questions
SECTION 1: A SAFE AND RESPECTFUL WORKPLACE
Safe and Healthy Workplace
A Respectful Workplace
SECTION 2: DELIVERING PRODUCT QUALITY
Product Safety, Quality and Security
Delivering Innovative ValueSECTION 3: LAWFUL AND ETHICAL BUSINESS PRACTICES
Bribery and Corruption
Conflicts of Interest
Fair Competition and Business Intelligence
International Trade
Financial Integrity and Fraud
SECTION 4: PROTECT COMPANY ASSETS AND INFORMATION
Company Assets and Information
Data Protection
Protect Data Privacy
Careful Communications and Records Management
SECTION 5: GOOD CORPORATE CITIZEN
Social Responsibility
Environment
Human Rights and Fair Labor Practices
SECTION 6: ASKING QUESTIONS AND RAISING CONCERNS
Use Good Judgment and Seek Advice
Recognize and Respond to Incorrect Behavior

3PennEngineering Core Values and Behaviors
Our Core Values are the beliefs and principles we share. These are the elements that best
describe the type of company we are and strive to be. Our Behaviors are the expression of
Our Core Values through our day-to-day actions. When there is alignment between Our Core
Values and Behaviors, our company culture flourishes. At PennEngineering, Our Core Values
and Behaviors ensure a common understanding of who we are and what we stand for all over
the world.
Our code of conduct serves as our guide to ethical and responsible business conduct.
What sets PennEngineering apart is our passion for what we do and our shared standard of
excellence.
As our business evolves over time, our Core Values remain constant. We know it’s not justabout what we do but how we do it.
We know the way we work matters because what we do matters.

WHY DO WE HAVE A CODE?
To remind ourselves, as our work environment becomes increasingly global and competitive,
we must continue to be stewards of our business and run them with integrity.
Through our work and dedication, each of us contributes to the good reputation of
PennEngineering in society and in the industry. This can only happen if our stakeholders
trust us and our products. We must earn and renew this trust every day.

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WHO MUST FOLLOW THE CODE?
We are all accountable to take responsibility, to show integrity and to do the right thing.
Our code of conduct applies equally and without exception to all of us. Only by combining
our success in business with a responsible approach can we meet our objective of developing
and offering products that delight our customers.
HOW SHOULD I USE THE CODE?
This document reflects Our Core Values, internal policies, voluntary commitments andprinciples, and national and international laws.
WHAT HAPPENS IF SOMEONE VIOLATES THE CODE?
Incorrect behavior by any individual can threaten our relationships with stakeholders.
It can break trust with customers and with the public. A violation of the global code may
be addressed by further education, or it can lead to corrective action up to termination.
Where violating the global code is also a violation of law, doing so may also lead to finesand claims for damage.

Our core values are
the glue that drive
us as a company,
through expansion
and change, andmake us who weare today.

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A Safe and Respectful Workplace
SAFE AND HEALTHY WORKPLACE
Occupational health and safety is our number one priority. We take steps to prevent
accidents and occupational illnesses in the workplace, and we want our employees to workin an ergonomic environment where good health and wellness is promoted.
To do this we:• Use good judgment and act in a manner that is safe for you and others.
• Report safety concerns and work-related injuries or illnesses.
• Never joke about violence and report any violent threats or warning signs from others.
• Comply with applicable health and safety regulations.
A RESPECTFUL WORKPLACE
Dignity and mutual respect are at the heart of our interactions with each other, business
partners and anyone we encounter in a business setting. We do not allow harassing behavior
or discrimination based on personal characteristics like gender, age, nationality, ethnicity,
skin color, political views, sexual orientation, religious beliefs, social background, or physicalability. We want a healthy and encouraging work environment that is inclusive of all individuals
and where our colleagues are embraced regardless of their beliefs and cultures. Disrespectful
behavior can lead to disciplinary action, up to and including termination.
To do this we:• Treat colleagues, customers and business partners with courtesy, dignity, and respect.
• Show appreciation for diversity of people, views, and work styles.
• Never discriminate against job candidates or employees.
• Avoid speaking generally about groups, including specific racial, gender, or religious groups.
• Avoid forcing political views on colleagues, customers, and business partners.
• Forbid harassment and encourage employees to speak up if they see harassment take place.
• Acknowledge the influence of different cultures or values and behaviors.
• Take actions to prevent bias from influencing our behavior.
RETALIATION IS NOT TOLERATED
PennEngineering has a no retaliation policy. No one can take action against you for asking aquestion or raising a concern in good faith. If you feel that you are being retaliated against,
report it immediately.
SPEAK UP
PennEngineering maintains a dedicated Reporting Hotline at +1-215-766-1000 or
speakup@pemnet.com for employees, contractors and third parties to safely voice
concerns relating to our business or people. All reports will be handled as confidentiallyas possible while still allowing PennEngineering to perform a proper investigation.

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Delivering Product Quality
PRODUCT SAFETY, QUALITY AND SECURITY
PennEngineering stands for high-quality products and services.
Our quality management processes and procedures help us comply
with international standards and continually improve our products,
services and processes. We follow the PennEngineering Quality
Policy and all applicable subsidiary Quality policies and procedures
to maintain and improve the effectiveness of our quality management
system in full conformance with regulatory and other applicable
program requirements. We strive to achieve outstanding customer
satisfaction and employee safety.
To do this we:• Follow internal quality procedures, processes, and requirements
to help ensure the quality, safety and efficacy of our products
and services.
• Timely notify the customer of any changes in material,
manufacture location, outside suppliers and process changeson all product.
• Completely and accurately report quality testing results – neverfalsify, change or conceal a finding.
• Speak up if we discover any actual or potential product quality
or safety issue, including reporting all adverse events or
product quality complaints immediately to our Quality Assurance
department and others required by local regulations.

Quality Policy
PennEngineering commits totimely deliver products withthe highest level of quality,
performance, a continuous
improvement mindset, anda solution to customer
application concerns. To
achieve this, PennEngineering
will strive every day forcontrols compliance and wewill engage with employees
to have the voice of thecustomer in mind with eachpart we make and deliver.

DELIVERING INNOVATIVE VALUEAt PennEngineering, we are pioneers that look beyond the present
to deliver future value to our customers and stakeholders.
To do this we:• Stay aware of trends around the world and pursue businessideas in tune with customer needs and desires.
• Strive to develop and provide safe, high-quality products
and services that are meaningful to customers.

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Lawful and Ethical Business Practice
BRIBERY AND CORRUPTION
We conduct business fairly and with a high level of integrity.
We do not tolerate corruption or bribery in our company.
To do this we:• Never offer, give, or accept bribes or payoffs, either directly or
through a third party. Report in writing to your local manager
and PennEngineering’s general counsel or speakup@pemnet.com
if a facilitation payment is requested.
• Avoid even small gifts if they are intended to influence therecipient to provide a service in return. Don’t offer or promise
anything of value to national, local, or foreign public officials,
their families, or friends. This PennEngineering requirement
applies even where local custom would otherwise allow suchactions or payments.
CONFLICTS OF INTEREST
At work, we expect you to disclose any possible conflict between
your private interests and those of PennEngineering. This includes
if you work with friends or family or hold a financial interest in
a company with which we do business. Clearly communicating
any possible conflicts can help ensure that there is no actual or
perceived influence on business decisions as a result of suchcollaboration.
To do this we:• Recognize that employees owe a duty of loyalty to the company.
• Watch for conflicts of interest – including situations where others
may perceive a conflict.
• Disclose any conflicts of interest that exist when you come to work
at PennEngineering or that may emerge later.
• Work with the company to address and resolve any conflicts.
This might involve removing yourself from decision making related
to the conflict.
If you think you have a conflict of interest, disclose it by talking to yourmanager or Human Resources. Many conflicts can be addressed andresolved without serious issue.

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The following situations canlead to conflicts of interest:• Financial interests andinvestments: For example,
you or a relative has anownership interest in an
PennEngineering supplier,competitor, service provider
or customer.
• Family members and close
personal relationships: For
example, you hire, evaluate
or manage a family member,close friend or romantic
partner.
• Outside involvements:
For example, you take apolitical or charitable roleoutside of work that interferes with the company’s
best interest or your job
duties.

FAIR COMPETITION AND BUSINESS INTELLIGENCE
PennEngineering makes decisions regarding its commercial
strategies independently. Our business relations are based on free
and fair competition. We do not apply unfair business practices
with our customers, suppliers, and competitors, and we adhere to
all laws concerning the restriction of competition. Violations ofcompetition or antitrust laws can lead to large fines and penalties
for the company and may also apply to employees.
To do this we:• Are careful when communicating with competitors – especiallyduring informal discussions.
• Openly identify ourselves as employees of PennEngineering.
• Never discuss confidential topics with competitors, such as
pricing, sales volumes or the type and quantity of products
sold or produced.
• Never talk to competitors about dividing markets or suggest
ruling out business with certain customers.
• Never fix or discuss fixing sales prices with competitors.
• Compete fairly and avoid conduct that constitutes or may
appear to be manipulation of a tender or bidding process.

Simply, we do not makeagreements with competitors
on topics like:• Prices• Coordinating of bids
• Terms or conditions of sale
• Research/development plans• Market division or customer
allocation• Production volumes

INTERNATIONAL TRADE
We are required to adhere to import and export laws governing
cross-border trade and to play an active role in control measures.
To do this we:• Never do business, directly or indirectly, with restricted parties,
countries, or entities.
• Provide accurate and truthful information to customs andregulatory agencies.
• Comply with applicable trade laws and regulations.

9FINANCIAL INTEGRITY AND FRAUDAt PennEngineering, we practice transparency at every level and make it a priority to preventand detect fraud. We know our shareholders require honest and accurate information toevaluate our financial and company performance. We show integrity with our reporting,following all required accounting standards.
To do this we:• Report and record all financial data, including revenue and expense transactions,honestly, accurately, completely and in the proper accounting period.
• Comply with applicable tax laws and regulations.
• Never make false reports or expense claims. Never intentionally record incorrect
information or manipulate accounting information or financial statements to secure
profits, achieve sales budgets, fulfill budgeted expenses, or for any other reason.
• Follow all reporting and disclosure requirements and cooperate with any internal orexternal auditors.

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Protect Company Assets and Information
COMPANY ASSETS AND INFORMATION
We are all responsible for protecting PennEngineering’s assets.
To do this we:• Only use company resources for legitimate business purposes–
for example, capital, personnel, software, or work equipment.
• Never use company assets for personal use.
• Take care of material assets, like equipment and buildings.
• Never sell, pledge, loan, transfer or modify our assets in a waythat reduces their value, unless you have reasonable businessgrounds and your manager’s approval.
DATA PROTECTION
PennEngineering holds a great deal of valuable information on
our company networks and servers, some of which is confidential
or sensitive. We all share a responsibility to help protect thisinformation and avoid taking actions that could lead to theinformation being lost, stolen, or accidentally.
To do this we:• Take appropriate measures to practice good cyber hygiene:
protect our computers, devices, and company networks.
• Use strong passwords and do not share passwords.
• Store confidential information exclusively on authorizedcompany networks and systems.

Our company’s competitive
advantage is based on
confidential and proprietary
information, including intellectual property like productschematics or manufacturing
technology. Improperly
revealing this information
could seriously damage ourbusiness.
If you work with informationthat is not generally known
to the public, like our trade
secrets or other product orprocess information, takecare to protect it.
Protect Company documents
and avoid working on confidential matters in public, anddo not discuss details where
you might be overheard.

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PROTECT DATA PRIVACY
Safeguarding personal information is fundamental to PennEngineering’s commitment toemployees, customers, and business partners. We show respect for people’s privacy bysafeguarding personal information and protecting it from unauthorized or unlawful disclosureor misuse. In addition, we observe all company guidelines and applicable privacy laws when
we collect, store, use and share personal information about individuals, whether they are
employees, customers, or others.
To do this we:• Never access personal information stored on our systems, unless our job requires it
and its’ use is in line with the original purpose for which the information was collected.
• Periodically review the information we hold and discard any personal information
we no longer need.
CAREFUL COMMUNICATIONS AND RECORDS MANAGEMENT
Written communication be it on paper, in electronic documents, in e-mails, or on social media,
requires special attention. If approached by journalists, you should refer them without delay
to the senior management of your business unit. Statements can be taken out of context andsuddenly express something completely different from what was originally intended. Always
communicate professionally, recognizing that it’s possible for any communication to be
retrieved and read in the future, without the benefit of your intentions or the original context.
To do this we:• Are open and honest – we ensure communication is always fact-based, objective,
transparent, professional, and honest.
• Always retain documents as required by company records retention schedules.
We never destroy records that are, or could be, relevant to a potential or impending
official investigation or court case.

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Good Corporate Citizen
SOCIAL RESPONSIBILITY
PennEngineering regards itself as a citizen in the communities where employees live andwork. We will always respect the culture and practices of the countries and regions where
the company engages in business.
To do this we:• Remain mindful of the impact our decisions may have on our broader communities.
• Strive to develop mutual understanding with people living in the countries andregions where we conduct business.
• Support community projects that reflect positively on our business with charitableorganizations.
• Draw on our own skills and expertise to volunteer in society.
ENVIRONMENT
Conservation of the global environment is our responsibility. We are responsible in using
natural resources and employ sustainable technologies whenever possible at our production
sites to develop environmentally friendly products for our customers. We take action to
improve our carbon footprint year after year, with the aim of being a valued member of thelocal economy, community, and society, including by becoming more carbon-neutral in thelong term.
To do this we:• Follow applicable environmental laws and regulations, as well as stringent internal standards.
• Avoid use of materials or methods that create environmental or health risks when suitable
alternatives are available.
• Efficiently utilize resources, promote recycling, use renewable resources where possible,
and optimize company processes to be more efficient.
HUMAN RIGHTS AND FAIR LABOR PRACTICESIn all corporate activities, PennEngineering will respect internationally recognized humanrights and will prohibit forced labor, child labor and illegal discrimination. We perform due
diligence to avoid using suppliers that offer unsafe products and services, violate applicablelaw, use child workers, or forced labor or subject employees to corporal punishment.
To do this we:• Support basic human rights, respect labor laws, and do not use any form of forced,
compulsory or child labor.
• Know the signs of human trafficking and forced labor and report human rights
abuse immediately.
• Never work with or encourage, either directly or indirectly, antisocial organizations
that threaten the order and safety of society.

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Asking Questions And Raising Concerns
USE GOOD JUDGMENT AND SEEK ADVICENo Code of Conduct can cover every imaginable situation you may encounter. Every decision andsituation that you face requires good personal judgment and thoughtful consideration.
Be prepared to question yourself and your actions. If you are in any doubt, seek help
from others and take advice.
RECOGNIZE AND RESPOND TO INCORRECT BEHAVIOR
We are open when dealing with mistakes. Be transparent with the company and seek
assistance if you make a mistake or witness the mistakes of others. Only by discussing
problems can we find solutions and improve as a team.
At PennEngineering we all share a responsibility to speak up if ever we have a question
about the Core Values or this code of conduct, or think it they may have been violated. If you
become aware of a breach or potential breach of this code, or other legal requirements,
you must report it immediately – whether it relates to you, your manager, or anyone else.
By speaking up, you will help prevent damage to PennEngineering.
We understand it is not always easy to raise concerns about possible misconduct, but
we encourage you to come forward and report any concern to your manager. If you areuncomfortable addressing these topics with your manager, you should report your concern
to your HR Manager, PennEngineering’s Vice President of HR and Talent, or General Counsel.
You may also report it via email to speakup@pemnet.com. PennEngineering is committed toinvestigating all potential breaches. Complaints will also be investigated in confidence, and in afair and responsible way.

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