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                                                                    EXHIBIT 99.3


                        American Building Control, Inc.

     DISCLOSURE COMMITTEE CHARTER. This Disclosure Committee Charter (this
"Charter") has been adopted by the Chief Executive Officer and Chief Financial
Officer (the "Senior Officers") of American Building Control, Inc. The
Disclosure Committee (the "Committee") shall review and reassess this Charter
annually and recommend any proposed changes to the Senior Officers for approval.

     I. PURPOSE

     It is the Company's policy that all disclosures made by the Company to its
     security holders or the investment community should be accurate and
     complete and fairly present the Company's financial condition and results
     of operations in all material respects, and should be made on a timely
     basis as required by applicable laws and stock exchange requirements.

     The Committee shall assist the Senior Officers in fulfilling their
     responsibility for oversight of the accuracy and timeliness of the
     disclosures made by the Company by being responsible for the following
     tasks, in each case subject to the supervision and oversight of the Senior
     Officers;

          o    Design and establish controls and other procedures (which may
               include procedures currently used by the Company) that are
               designed to ensure that (1) information required by the Company
               to be disclosed to the Securities and Exchange Commission ("SEC")
               and other written information that the Company will disclose to
               the investment community is recorded, processed, summarized and
               reported accurately and on a timely basis and (2) information is
               accumulated and communicated to management, including the Senior
               Officers, as appropriate to allow timely decisions regarding such
               required disclosure ("Disclosure Controls").

          o    Monitor the integrity and effectiveness of the Company's
               Disclosure Controls.

          o    Review and supervise the preparation of the Company's (i)
               periodic and current reports, proxy statements, information
               statements, registration statements and any other information
               filed with the SEC, (ii) press releases containing financial
               information, earnings guidance, information about material
               acquisitions or dispositions or other information material to the
               Company's security holders, and (iii) correspondence containing
               financial information broadly disseminated to shareholders
               (collectively, the "Disclosure Statements") and review disclosure
               policies for financial information displayed on the Company's
               corporate/investor relations website.

          o    Evaluate the effectiveness of the Company's Disclosure Controls
               within 30 days prior to the filing of the Company's Annual Report
               on Form 10-K and each Quarterly Report on Form 10-Q
               (collectively, the "periodic reports").

          o    Discuss with the Senior Officers all relevant information with
               respect to the Committee's proceedings, the preparation of the
               Disclosure Statements and the Committee's evaluation of the
               effectiveness of the Company's Disclosure Controls.

          o    Provide a certification to the Senior Officers prior to the
               filing with the SEC of each periodic report as to (i) the
               Committee's compliance with its policies and procedures and
               proper performance of the responsibilities that have been
               assigned to it and (ii) the Committee's conclusions resulting
               from its evaluation of the effectiveness of the Disclosure
               Controls.

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     In discharging its duties, the Committee shall have full access to all
     Company books, records, facilities, and personnel, including the internal
     auditors.

     II. ORGANIZATION

     The membership of the Committee shall initially consist of the Company's
     Controller, General Counsel, Treasurer, Vice-President of Finance and Human
     Resources Director. The Internal Auditor shall serve as a de-facto,
     non-voting member. Such members may be replaced, or new members added, at
     any time and from time to time by the Senior Officers. Notwithstanding the
     foregoing, the Senior Officers at their option may at any time assume any
     or all of the responsibilities of the Committee identified in this Charter,
     including, for example, approving Disclosure Statements when time does not
     permit the full Committee to meet.

     One member of the Committee shall be appointed by the Senior Officers as
     chair. The chair shall be responsible for scheduling and presiding over
     meetings and preparing agendas. Any question of interpretation of this
     Charter or the Committee's procedures shall be determined by any Senior
     Officer or, in their absence from any meeting, the chair.

     Promptly after the date hereof, the Committee shall meet with the Senior
     Officers and submit for their approval an initial set of Disclosure
     Controls, including policies and procedures of this Committee, as well as
     policies and procedures to test the effectiveness of the Disclosure
     Controls. The Committee shall meet as frequently as circumstances dictate
     to (i) ensure the accuracy and completeness of the Disclosure Statements
     and (ii) evaluate the Disclosure Controls and determine whether any changes
     to the Disclosure Controls are necessary or advisable in connection with
     the preparation of the Company's upcoming periodic reports or other
     Disclosure Statements, taking into account developments since the most
     recent meeting, including changes in the Company's organization and
     business lines and any change in economic or industry conditions.

     III. OTHER RESPONSIBILITIES

The Committee shall also have such other responsibilities as the Senior Officers
may assign to it from time to time.

Adopted by the Senior Officers of American Building Control, Inc. on March 25,
2003.



 /s/ BRYAN C. W. TATE
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By:  Bryan C. W. Tate
Its: Chief Executive Officer




 /s/ CHRIS SHARNG
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By:  Chris Sharng
Its: Chief Financial Officer