**Exhibit 14**

 

**Cascade Corporation**

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**Code of Ethics & BusinessResponsibilities for Directors, Officers and Employees**

 

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**Letter from the CEO**

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**Dear Fellow Employees**

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**Since its inception Cascade Corporation hasbeen committed to conducting business in accordance with the highest ethicaland legal standards.  All of us can takepride in our Company and each of us bears a personal responsibility to insurethese standards are continually upheld and unethical business practices are nottolerated under any circumstances or for any reason.  Failing to do so puts Cascade’s name, reputation, integrity andbusiness at risk.  While Cascade strivesto achieve market leadership and business success, Cascade cannot and will nottolerate the use of unethical business practices to achieve these objectives.**

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**I am pleased to provide you this Code ofEthics and Business Responsibilities to help us all better understand ourcommitment.  This Code applies to all ofus:  officers, Directors and employeesof Cascade.  It also applies toconsultants, agents and other Cascade representatives.  The Code provides employees and Directors,as well as Cascade’s suppliers, contractors and other business partners, withguidance and perspective in understanding Cascade’s emphasis on business ethics.**

** **

No code of conduct can spell out the appropriate moral conduct andethical behavior for every situation we face. In the final analysis, you mustapply your own good business judgment – and you should not hesitate to seekguidance from others within Cascade or external resources available to you asoutlined in the Code.  Employees seekingethical guidance will be protected from retaliation.  This protects employees from harm for reporting concerns wherethey have done nothing wrong.

 

Please take the time to become familiar with Cascade’s Code and be sureto let any management team member know if you have questions or comments orneed clarification as to any of the issues discussed.  Where Cascade has adopted specific policies on matters alsocovered by the Code, those policies supplement the Code and remain in effect.

 

As President and CEO, I am personally committed to abiding by andcarrying out this Code.  The Board ofDirectors is equally committed.  We askthat you share that commitment.  We areconfident that with guidance from this Code and sound judgment on the part ofall of us, Cascade will continue to enjoy an excellent business reputation.

 

Sincerely,

 

Robert C. Warren

President and Chief Executive Officer

 

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**Table of Contents**

** **
| INTRODUCTION                                                        |   |
|---------------------------------------------------------------------|--------|
| ETHICAL DECISION MAKING                                             |   |
| POINTS OF CONTACT FOR QUESTIONS, CONCERNS  OR POSSIBLE VIOLATIONS   |   |
| REPORTING VIOLATIONS                                                |   |
| VIOLATIONS OF THE CODE                                              |   |
| WAIVERS                                                             |   |
| RESPONSIBILITIES TO SHAREHOLDERS                                    |   |
| FINANCIAL INTEGRITY                                                 |   |
| INSIDER TRADING                                                     |   |
| EMPLOYEE CONDUCT                                                    |   |
| E-MAIL AND INTERNET                                                 |   |
| ANTITRUST ACTIVITIES                                                |   |
| CONFLICTS OF INTEREST                                               |   |
| RESPONSIBILITIES TO CASCADE BUSINESS  OPPORTUNITIES                 |   |
| COMPANY RESOURCES                                                   |   |
| CONFIDENTIAL INFORMATION AND INTELLECTUAL  PROPERTY                 |   |
| RESPONSIBILITIES TO EACH OTHER                                      |   |
| RESPECT FOR EMPLOYEES                                               |   |
| HEALTH & SAFETY                                                 |   |
| ALCOHOL & DRUGS                                                 |   |
| PRIVACY OF INFORMATION                                              |   |
| RESPONSIBILITIES FOR PRODUCT QUALITY                                |   |
| SALES, MARKETING & ADVERTISING                                  |   |
| INTERNATIONAL OPERATIONS                                            |   |
| TRADE CONTROLS (IMPORT AND EXPORT)                                  |   |
| BOYCOTTS                                                            |   |
| THE FOREIGN CORRUPT PRACTICES ACT (“FCPA”)                |   |
| RESPONSIBILITIES TO BUSINESS PARTNERS,  CONTRACTORS & SUPPLIERS |   |
| GIFTS & ENTERTAINMENT                                           |   |
| RESPONSIBILITIES TO OUR COMMUNITIES:  ENVIRONMENTAL PROTECTION      |   |
| NEWS MEDIA INQUIRIES                                                |   |
| GOVERNMENT INQUIRIES                                                |   |
| PUBLIC ACTIVITIES                                                   |   |
| CODE OF ETHICS CONTACTS                                             |   |

 

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**Cascade Corporation**

# **Codeof Ethics & Business Responsibilities For Directors, Officers and Employees**

#### **March 1, 2004**

 

 

### **INTRODUCTION**

 

Cascade Corporation has adopted this Code of Ethics & BusinessResponsibilities (the “Code”) to give employees, officers and Directorsguidance in their efforts to meet and protect high standards of conduct duringthe course of business and other activities.

 

This Code will be available in many languages on the Cascade intranetand internet.  Updates to the Code willbe made to the electronic version.  Youshould always check the electronic version for the latest updates.  Manual copies of the Code will be availableat each location’s Human Resources Department.

 

This Code is intended to provide general guidance to all Cascadeemployees and representatives.  Wherethere are differences between this Code and any local policy, regulation,Cascade employee handbook provision, or posted Cascade policy the requirementcontaining the higher standard of ethical conduct shall apply.

 

Cascade reserves the right to update or otherwise change this Code ofEthics and Business Responsibilities at any time by action of its Board ofDirectors.

 

 

### **ETHICAL DECISION MAKING**

 

Cascade recognizes that all employees encounter ethical challenges intheir work.  This Code is intended tohelp you to both recognize and resolve those challenges.

 

When faced with a business decision that seems to have ethicalovertones, here are several questions you should ask yourself to determine ifyour actions are proper:

 

1.               Am I adhering tothe spirit and overall values, as well as the letter, of any applicable law orCascade policy?

2.               Would I want myactions reported on the front page of a newspaper?

3.               What would myfamily, friends or neighbors think of my actions?

4.               What would I tellmy child to do?

5.               Would I becomfortable testifying about my decision under oath?

6.               Will there be anydirect or indirect negative consequences for Cascade?

7.               Would I becomfortable describing my decision at an all-employee meeting?

 

If you remain uncertain about what to do, stop and ask for help.  Speak with your supervisor or, if youprefer, communicate with any of the other points of contact listed in this Code.

 

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### **POINTS OF CONTACT FOR QUESTIONS, CONCERNS ORPOSSIBLE VIOLATIONS**

 

Your supervisor is normally the first person you should contact if youhave questions about anything in this Code or if you have any issue related tothe Code or possible violations. If you feel more comfortable discussing thematter with someone other than your supervisor, you may utilize the followingpoints of contact:

 

•                  Yourlocation’s Human Resource Department

•                  Yourlocation’s General Manager

•                  Cascade’sOfficers

•                  Cascade’sCorporate Legal Counsel

 

Cascade promotes an open-access or open-door policy and encouragesemployees to contact any Cascade officer or member of senior management withpotential concerns.

 

If you are not comfortable with any of the above points of contact, theCascade Corporation Compliance Website is available to you.  The Website is a simple, risk-free way foryou to anonymously report activities that may involve unethical or criminalconduct.  In addition, a ComplianceHotline is also available for employees without internet access.  A report received on the Website orTelephone Hotline is totally confidential and administered by third partiesindependent of the Company’s officers and employees.

 

Contact information for the above resources is located in the “CompanyCode of Ethics Contacts” section at the back of this Code.

 

 

### **REPORTING VIOLATIONS**

 

As previously noted, Cascade employees have many options for seekingcompliance advice or fulfilling their obligation to report possiblemisconduct.  Employees can contact theirsupervisor, Human Resources Department, General Manager, a Cascade officer,Cascade’s Corporate Legal Counsel or the Compliance Website/Hotline.  Compliance advice will be provided aspromptly as practical following a request. Reports of possible misconduct will be investigated and appropriateaction taken as warranted.

 

Anyone who seeks advice, raises a concern, or reports misconduct isfollowing the requirements of this Code. Employees seeking ethical guidance or reporting ethical concerns orviolations of the Code will be protected from retaliation.  The use of the Compliance Website or Hotlineallows you to report suspected violations related to Cascade’s Code on atotally anonymous basis.

 

 

### **VIOLATIONS OF THE CODE**

 

Persons found to have violated this Code will be subject todisciplinary action, up to and including termination of employment.  Where conduct involves possible violationsof law, those involved may also be referred to appropriate authorities forpotential criminal prosecution.

 

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In addition, retaliation against anyone who makes a good faith reportof misconduct will not be tolerated. Cascade will take appropriate disciplinaryaction, including termination of employment and referral for potential criminalprosecution, against individuals engaging in any retaliatory conduct. If yoususpect that you or someone you know has been retaliated against for reportingpossible misconduct, you should contact your supervisor, Human ResourcesDepartment, General Manager, a Cascade Corporation Officer, Cascade’s CorporateLegal Counsel or the Compliance Webiste/Hotline immediately.

 

 

### **WAIVERS**

 

Only Cascade’s Board of Directors may waive of any provision ofCascade’s Code for officers or Directors. Any waivers will be promptly disclosed as required by law or by theSecurities and Exchange Commission or the New York Stock Exchange.  No waiver shall be effective unless recordedin the minutes of the Board of Directors or, in the case of employees orbusiness partners other than officers and Directors, put in writing and signedby the Chief Executive Officer or Chief Financial Officer.

 

 

### **RESPONSIBILITIES TO SHAREHOLDERS**

 

Cascade is committed to advancing the long-term interests of itsshareholders and to protecting and improving the value of their investment byapplying the highest standards of ethical and legal conduct to all businessdealings.  Cascade conducts itsoperations in accordance with accepted principles of good corporate governance.

 

 

### **FINANCIAL INTEGRITY**

 

Cascade adheres to the highest standards of honesty.  It is essential that the internal andexternal reports and documents we create, make public, or provide to thegovernment, constitute full, fair, accurate, timely and understandabledisclosures.  In addition, accuraterecording and reporting of financial information is necessary in order to makeresponsible business decisions. All financial books, records and accounts mustaccurately reflect transactions and events and conform to generally acceptedaccounting principles and to Cascade’s system of internal controls.  If you are unsure about how to representinformation or transactions in a Cascade report or document, contact one of thelisted points of contact for guidance.

 

Part of our commitment to honesty is the assurance that all ofCascade’s financial transactions are lawful and are made for the purposesstated and as authorized by Cascade. Examples of unethical financial or accounting practices include:

 

•                  Makingfalse entries that intentionally hide or disguise the true nature of anytransaction.

•                  Improperlyaccelerating or deferring the recording of revenues or expenses to achievefinancial results or goals.

•                  Maintainingany undisclosed or unrecorded funds or “off the book” assets.

•                  Establishingor maintaining improper, misleading, incomplete or fraudulent accountdocumentation or financial reporting.

 

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•                  Processinga sale or shipping product prior to receipt of a valid, customer suppliedpurchase order or other documentation.

•                  Makingany payment for purposes other than those described in documents supporting thepayment.

•                  Signingany documents believed to be inaccurate or untruthful.

 

The above items only represent a partial list of potentially unethicalfinancial or accounting practices.  Ifyou have a concern about a particular transaction or practice contact one ofthe listed points of contact for guidance.

 

Any questions or concerns regarding Cascade’s financial accounting,record keeping or auditing policies can be addressed to the Chief FinancialOfficer or Vice President – Finance. Questions or concerns can also be submitted on a confidential basisthrough Cascade’s Compliance Website/Hotline.

 

 

### **INSIDERTRADING**

 

It is illegal to buy or sell securities (either personally or on behalfof others) on the basis of material, nonpublic information.  It is also illegal to communicate (i.e., to“tip”) material, nonpublic information to others so that they may buy or sellsecurities on the basis of that information. If you know material, nonpublic information about Cascade or any othercompany, including contractors, suppliers or business partners, you areprohibited from trading (directly or indirectly) or tipping others to trade inthe securities of that company.

Material, nonpublic information is factual information that areasonable investor would want to know before making an investment decision.Examples of material, nonpublic information include:

 

•                  Quarterlyor annual financial results

•                  Financialforecasts

•                  Significantfinancial or business developments

•                  Possiblemergers, acquisitions, joint ventures or divestitures

•                  Significantproduct developments

 

These prohibitions continue for as long as the information you knowremains material and nonpublic. They apply as well to shares you may hold in401(k) Plan accounts.  If you havequestions or need guidance regarding any specific transactions, contactCascade’s Corporate Legal Counsel in advance of the transaction.

 

Cascade imposes a periodic blackout period during which officers,managers and Directors cannot purchase or sell Cascade shares to assurecompliance with U.S. securities laws. Cascade’s officers and Board members may only purchase or sell sharesduring the 30 day period after the third working day following the quarterlyearnings release.  All other managersmay buy or sell shares up to 60 days after the third working day following theearnings release, but not beyond the following quarterly close.

 

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### **EMPLOYEECONDUCT**

 

The strength and character of the relationship with our employees is ofparamount importance.  Cascade strivesto treat every employee ethically, to provide a safe working environment and tocompensate employees fairly for their contributions.  In return, Cascade expects every employee to contribute theirbest efforts and to focus their full energy and attention to their individualjob responsibilities.

 

 

### **E-MAIL ANDINTERNET**

 

Cascade’s e-mail systems and internet connection are primarily intendedto be used for Cascade business purposes only. Employees should not abuse Cascade’s e-mail systems or internetconnection for personal purposes.

 

E-mail systems are not entirely secure and may be susceptible tointerception.  Unlike a spokenconversation, e-mail creates a permanent record.  Any e-mail you send may be printed by the recipient or forwardedby the recipient to others, and will probably be retained on company computersfor a substantial period of time. Exercise the same care, caution and etiquette in sending an e-mailmessage as you would in any other written business communication.

 

Employees must exercise common sense and good judgment about what is appropriatevs. inappropriate e-mail message content. Make sure your Cascade e-mail is professional and appropriate to thecircumstances.  All forms of electroniccommunication should reflect favorably upon not only the individual employee,but upon Cascade as a whole.

 

Cascade will not tolerate abusive, obscene, offensive or profane e-mailor the use of internet access to download any data that is unprofessional,inflammatory, or inappropriate for business use.  Keep in mind that what you personally may consider inoffensivemay in fact be quite offensive to someone else.

 

E-mail and internet records are subject to disclosure to lawenforcement and government officials, or other third parties through subpoenaor other legal processes.  Consequently,you should take care to always ensure the business information included ine-mail and internet messages complies with this Code.

 

All e-mail and internet records or communications that originate from,or reside on, Cascade’s electronic communications systems are consideredcompany records.  Cascade may, incertain circumstances, have a need to examine and, therefore, reserves theright to read, view and copy any e-mail communications and monitor internetactivity.

 

Cascade internal computer sign-ons and passwords may not be shared withany third party.

 

These guidelines apply to all Cascade employees, contract employees,persons doing business with Cascade in a consultant capacity, officers of thecorporation and Directors in their electronic communications and electronicbusiness dealings.

 

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### **ANTITRUST ACTIVITIES**

 

The free enterprise system rests on the proposition that free and opencompetition is the best way to ensure an adequate supply of goods and servicesat reasonable prices.  The antitrustlaws of the United States of America (U.S.) as well as those of the EuropeanUnion (E.U.) and other areas in which Cascade does business are intended toprotect and promote vigorous and fair competition.

 

No matter what position you hold, you must adhere strictly to U.S. andE.U. antitrust laws and to all laws governing competition in any country inwhich Cascade does business.  Violationof antitrust laws can result in severe civil and criminal penalties, includingimprisonment for individuals, and Cascade can be subjected to substantial finesand damage awards.

 

The following agreements, arrangements or understandings withcompetitors, whether oral or in writing, must not occur:

 

•                  Agreementsto fix prices or boycott specified suppliers or customers

•                  Agreementsto allocate products, territories or markets

•                  Agreementsto exchange competitively sensitive information, especially prices

•                  Agreementsthat limit the production or sale of products

•                  Tyingarrangements, reciprocal dealing, unfair trade practices and other matterswhich have competitive significance

 

Contacts with competitors are sensitive and risky, since courts caninfer an agreement or collusion from such contacts when they are followed bycommon action or behavior.  In contactswith competitors, you must not discuss:

 

•                  Prices

•                  Tradeallowances or rebates

•                  Costs

•                  Competition

•                  Marketingplans or studies

•                  Productionplans and capabilities

•                  Anyother confidential information

 

In the U.S., E.U. countries and many other jurisdictions, conspiraciesbetween competitors to fix prices or otherwise violate antitrust laws can giverise to large damage awards against companies and possible criminal chargesagainst individuals.  To play it safe,do not discuss pricing practices with a competitor.  If a competitor tries to bring up pricing or other competitivepractices, change the subject or excuse yourself from the conversation.  If you have any questions aboutcommunications with a competitor, get in touch with the Chief ExecutiveOfficer, Chief Financial Officer, Vice President – Finance, or the CorporateLegal Counsel.

 

In addition, you should not imply that Cascade’s sales or purchaseswould be based on anything other than quality, technical excellence, price,delivery, adherence to schedules, product or service suitability, maintenanceof adequate sources of supply or similar considerations.

 

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Cascade’s customers are free to establish their own resale prices forCascade products. While you may suggest or recommend resale prices, you mustnot take coercive action to require customers to comply with such suggestionsor recommendations.

 

You should obtain advice from appropriate points of contact concerningany conduct or practice that you suspect could possibly involve antitrust laws.

 

 

### **CONFLICTS OF INTEREST**

 

Integrity in a business relationship means that all participants areworking together for the common good and are not making decisions based onself-interest.  You have aresponsibility to conduct your personal and business affairs so as to avoidsituations and relationships that involve actual or potential conflicts ofinterest, or even the appearance of a conflict of interest.

 

If you act, or appear to be acting in your own self-interest, or in theinterest of a Cascade competitor, you lose the trust of customers, consumersand business partners, and Cascade’s reputation is damaged.

 

Generally, a conflict of interest arises whenever an employee’spersonal or financial interests differ or could potentially differ from his orher responsibilities to Cascade or from Cascade’s best interests.  In some cases, the activities of a spouse,domestic partner or an immediate family member can also create a conflict ofinterest.  Put another way, a conflictof interest is created whenever an activity, association or relationship mightimpair your independent exercise of judgment in Cascade’s best interest.

 

Conflicts of interest are not permitted.  Examples of situations that could be perceived as conflicts ofinterest and which therefore must be avoided include:

 

•                  ConductingCascade business with a firm owned, partially owned or controlled by anemployee or an employee’s relatives.

•                  Owninga financial interest in Cascade’s vendors, customers or competitors (ownershipof less than 1% of the stock of a publicly traded company that competes or doesbusiness with Cascade is permissible).

•                  Performingwork, with or without compensation, for a competitor, governmental orregulatory entity, customer or supplier of Cascade, or doing any work for athird party that may adversely affect your performance or judgment on the jobor diminish your ability to devote the necessary time and attention to yourduties.

•                  UsingCascade property, materials, supplies, funds or other resources for personalpurposes.

 

These situations, and others like them, where loyalties to Cascadecould be compromised, must be avoided. Similarly, Cascade cannot make loans to,or guarantee loans to, any officer, Director or employee. If you believe you orothers are involved in a potential conflict of interest, you must discuss itwith one of the points of contact noted in this Code.

 

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### **RESPONSIBILITIES TO CASCADE BUSINESS OPPORTUNITIES**

 

You are responsible for advancing Cascade’s business interests when theopportunity to do so arises. You must not:

 

•                  Usecorporate property, information or your position at Cascade for personal gain.

•                  Turnto your own advantage or divert to others any business opportunity or idea inwhich Cascade is or might potentially be interested, or that is discoveredthrough the use of your Cascade position or Cascade property or information.

•                  Competewith Cascade in any way.

 

 

### **COMPANYRESOURCES**

 

Protect Cascade’s assets as you would your own.  Effective use of corporate resources iscritical to Cascade’s financial well being. These resources include company travel expenses, computers, telephones,internet access, reproduction equipment and facsimile systems.

 

Cascade maintains these resources and technologies for legitimatebusiness activities and to support a positive, professional businessclimate.  You are personally responsiblefor corporate assets placed in your control and are expected to use suchresources and technology responsibly and professionally at all times.

 

•                  Exercisegood business judgment with respect to expenses while traveling.

•                  Useof Cascade-provided technologies and property for calls, emails or othercommunications of a personal nature should be on an infrequent basis.

•                  Youmust not use Cascade assets to display, transmit or store inappropriatematerials at any time.

•                  Youare responsible for protecting these resources from damage, destruction,viruses, alteration, theft, fraudulent manipulation and unauthorized access,disclosure or use.

 

 

### **CONFIDENTIAL INFORMATION AND INTELLECTUALPROPERTY**

 

Cascade’s success depends upon protecting Cascade’s confidentialinformation and intellectual property. Confidential information and intellectual property include anyinformation that gives Cascade a competitive edge in the marketplace or thatcould harm Cascade’s business or personnel if disclosed publicly, such asinventions, research and technical data, formulas, discoveries, designs, improvements,ideas, manufacturing directives, computer programs, trademarks, patents,copyrights, unpublished financial or pricing information, other confidentialinformation and all related documentation.

 

Confidential information also includes customer, sales, marketing andother corporate databases, marketing plans, employee personnel records andbusiness proposals and strategies.  Youshould consider all information gained through your work at Cascade asconfidential Cascade information.

 

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If you have access to Cascade confidential information or intellectualproperty, you are obligated to protect and maintain it and act responsibly withthe sensitive information of competitors, customers, suppliers, contractors andother business partners, as well as former employers and competitors.

 

Cascade employees, suppliers and contractors may be required to signagreements regarding the use of Cascade confidential information andintellectual property. Upon leaving Cascade, you are prohibited from copying orretaining any documents or other materials that contain confidentialinformation.  Former employees are stillbound to maintain the confidentiality of information learned during theiremployment at Cascade.  Products,improvements and ideas for products or improvements developed during yourCascade employment are the property of Cascade.

 

 

### **RESPONSIBILITIES TO EACH OTHER**

 

We each have a responsibility to one another to report any actions oractivity that could be viewed as illegal or unethical or which could violateany provision of this Code.  Even if youare not directly involved, you are responsible for reporting any conduct whichmight be a violation of the Code.

 

 

### **RESPECT FOR EMPLOYEES**

 

Cascade is committed to upholding the legalworkplace rights of our employees at all times.  Cascade respects the individual dignity of each of its employees,and believes that every employee should be free from disruptive, offensive or abusivebehavior while at work.  Every employeeshould conduct himself or herself with this belief in mind.  Cascade handbooks describe specific equalopportunity and non-harassment policies at many locations.  You should consult your manager, the SeniorVice President – Human Resources, or any other contact point if you havequestions concerning Cascade’s policy or are aware of disrespectful conduct atwork by fellow employees or third parties at any location.

 

 

### **HEALTH &SAFETY**

 

Cascade is committed to providing a safe and healthy work environment.  Each of us must be attentive to hazardprevention and the avoidance of accidents and injuries.  You are responsible for observing the safetyand health rules and practices that apply to your job.  You are also responsible for takingprecautions necessary to protect yourself and your co-workers, includingwearing appropriate clothing and protective equipment and immediately reportingaccidents, injuries and unsafe practices or conditions to your location’sSafety Manager, Plant Manager or other appropriate management personnel.

 

 

### **ALCOHOL &DRUGS**

 

Cascade has a responsibility to provide a safe work environment.  Cascade reinforces its commitment byprohibiting employees from using, possessing, distributing or being under theinfluence of illegal drugs or alcohol while working for Cascade during businesshours.  In

 

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addition, alcohol is not permitted on Cascade premises.  Cascade is obligated to deal with drug andalcohol problems in compliance with all applicable laws on this subject.  Make sure you are familiar with the specificCascade drug and alcohol policy in effect at your work location.

 

 

### **PRIVACY OF INFORMATION**

 

Cascade’s intent is to create an environment of confidence andtrust.  It is Cascade’s policy toacquire and retain only accurate, factual, job-related employee informationrequired for the effective operation of Cascade’s business or required by lawin the jurisdictions in which Cascade operates.  Cascade intends to keep employee information confidential andrelease it only to authorized personnel with a clear need for such informationor if compelled by law.

 

Customer and consumer information enables Cascade to better understandand meet customer and consumer needs. Cascade informs customers and consumers about the use and handling ofthe information they provide, including informing customers and consumers aboutthe information collected, how such information is used and the choices theyhave concerning further uses of the information.

 

 

### **RESPONSIBILITIES FOR PRODUCT QUALITY**

 

Cascade’s success depends upon consumer trust and satisfaction.  Cascade’s commitment to quality, value andsafety is essential to its continued growth and success. Cascade is committedto provide products that offer value to consumers and to maintain consumertrust in its products based on product quality, performance and safety.  Cascade is committed to the followingprinciples related to product safety:

 

•                  Productswill be safe when used as intended.

•                  Safetytesting will conform to industry and regulatory standards and promote and helpassure safe products.

•                  Productswill comply with all legislative and regulatory requirements with respect toproduct development and labeling.

 

 

### **SALES, MARKETING & ADVERTISING**

 

Cascade’s success in the marketplace is based on the value that itsproducts provide to consumers, as well as the truthfulness and accuracy ofproduct and sales presentations and advertising.  Cascade will not use false or deceptive advertising to promoteits products, and will not give untrue assurances about product performance.

 

Advertising, packaging, promotional materials, and any verbal orwritten claims and descriptions of Cascade products must be accurate andfactual.  Claims that favorably compareCascade products with those of competitors must be factual and based upon prioradequate substantiation.  Deliberatelymisleading messages, omissions of important facts or false claims aboutcompetitors’ products are not acceptable.

 

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### **INTERNATIONAL OPERATIONS**

 

As a global company, Cascade must know and comply with the letter andspirit of the laws of all countries where we do business and that affect ourinternational operations.  We must alsobe sensitive to the cultures and customs of the countries where we operate.

 

Most governments have laws and regulations that restrict trade andbusiness transactions.  This isparticularly true for trade in goods and services that cross borders.  You should be aware of situations that maybe regulated by relevant governments and comply with those laws andregulations.  Contact Cascade’s ChiefFinancial Officer, Vice President – Finance, or Corporate Legal Counsel if youhave any questions.

 

 

### **TRADE CONTROLS (IMPORT AND EXPORT)**

 

All governments regulate trade through restrictions on exports (e.g.,license requirements) and imports (e.g., payments of duties) of goods,technology, and services.  Some are morerestrictive than others.  For example,the U.S. government has significant restrictions on trade in military andrelated goods, technology, and services, and trade with certain countries(Special Trade Controls).  Under theseregulations exports include transfers to citizens of countries other than theU.S. even if they occur entirely within the U.S. or between countries outsideof the U.S. if the export contains certain goods or technology that originatedin the U.S.

 

Cascade will fully comply with all applicable laws and regulationsgoverning exports and imports of goods and services including Special TradeControls.  Each Cascade location shouldevaluate its customers and suppliers to ensure that they are not included inany government lists of parties restricted from trade.  For advice about any issues covered in thissection, contact Cascade’s the Chief Financial Officer, Vice President –Finance, or Corporate Legal Counsel.

 

You should immediately report any investigation or inquiry by anygovernment organization regarding alleged trade control violations orirregularities to the Chief Financial Officer or Vice President – Finance priorto taking any action.

 

 

### **BOYCOTTS**

 

To boycott a country is to refrain from buying from or dealing withthat country as a means of protest. U.S. government regulations prohibit all company operations, includingthose outside of the U.S., from participating in trade and related boycotts ofspecified countries’ goods and services. Participation by any Cascade location in a specified boycott is aviolation of law and would subject us to fines and other penalties.

 

Cascade cannot agree to a contract, document or oral request containinglanguage that could be interpreted as an attempt by any country to enforce aboycott.  This requirement includes notonly specific agreements, but also declining, for boycott reasons, to considera financial or commercial opportunity in a boycotted country.  Even providing information on businessrelationships with the country being boycotted may constitute a violation ofU.S. law.

 

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Cascade must immediately report boycott requests even when we do notrespond.  You must immediately reportany request for boycott-related information or receipt of boycott-relateddocuments to the Chief Financial Officer or Vice President – Finance.

 

 

### **THE FOREIGN CORRUPT PRACTICES ACT (“FCPA”)**

 

The Foreign Corrupt Practices Act (“FCPA”) applies to businesstransactions both inside the U.S. and in other countries.  Its requirements relate to accurate andcomplete financial books and records, transactions with foreign governmentofficials and prohibitions from directly or indirectly offering to pay, orauthorizing payment to, foreign government officials for the purpose ofinfluencing the acts or decisions of foreign officials. Violation of the FCPAcan bring severe penalties and it is mandatory that all employees living orworking in foreign countries or dealing with foreign entities become familiarwith the FCPA and its requirements.  Youshould immediately report any questions relating to these matters to Cascade’sChief Financial Officer, Vice President – Finance or Corporate Legal Counsel.

 

 

### **RESPONSIBILITIES TO BUSINESS PARTNERS,CONTRACTORS & SUPPLIERS**

 

Contractor and supplier relationships must be maintained in a mannerconsistent with all applicable laws, as well as with good businesspractices.  Cascade is committed toseeking strong, mutually rewarding business relationships with companies andindividuals who can enhance the quality of its products.  Cascade encourages fair competition amongpotential suppliers, contractors and other vendors, and treats each company orindividual with fairness, integrity and without discrimination. The selectionof subcontractors, suppliers and vendors must be made on the basis of objectivecriteria, including quality, technical excellence, price, delivery, adherenceto schedules, product or service suitability, maintenance of adequate sourcesof supply and Cascade’s purchasing policies and procedures.

 

Individuals who are involved in proposals, bid preparations or contractnegotiations must be certain that all statements, communications andrepresentations are accurate and truthful. You must always employ the highest ethical standards in businesspractices regarding source selection, negotiation, determination of contractawards, the administration of all purchasing activities and performance incompliance with specifications, requirements and clauses of contracts.

 

 

### **GIFTS & ENTERTAINMENT**

 

To maintain trust in Cascade’s business relationships, you must alwaysact with integrity. The giving or acceptance of inappropriate gifts canundermine business relationships, hurt Cascade’s reputation and put Cascade inlegal jeopardy.

 

You have a responsibility to make sure that all decisions regarding thepurchasing of materials, supplies and services are made on the basis ofcompetitive price, quality and performance, and in a way that preservesCascade’s integrity. Giving or accepting anything of value is inappropriate ifit could be reasonably interpreted as an effort to influence a businessrelationship or decision.

 

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The difference between a gift and a bribe is a question of intent. Itis impermissible to accept or request any form of kickback or bribe.  A bribe or a kickback includes any item orfavor provided for the purpose of improperly obtaining favorable treatment orseeking a competitive advantage.

 

In certain situations or on certain occasions, small gifts of nominalvalue may be presented by Cascade employees to suppliers, customers orpotential customers, such as specialty advertising items bearing the corporatelogo, tickets to local sports, civic or cultural events, restaurant meals orrefreshments.

 

Standards governing the acceptance of gifts from suppliers or theiragents mirror those relating to the giving of gifts to Cascade customers andpotential customers, in that acceptance of a significant gift could beconstrued as improperly influencing the selection of a vendor or the awardingof a contract.  It is not necessary togive gifts in order to do business with Cascade.  Gifts of nominal value may be accepted on an infrequent basis,such as during the holiday season, as a reasonable business courtesy.  Routine entertainment by suppliers that isbusiness related - such as business meals, entertainment, recreation, sportsoutings or cultural events - is acceptable; however, you must obtain yoursupervisor’s approval.  It is notacceptable to solicit gifts, gratuities or business courtesies for personalbenefit or the benefit of a Cascade employee, family member or friend.  Gifts should not be accepted from a supplieror potential supplier during, or in connection with, contract negotiations.  Accepting cash or cash equivalents -including checks, money orders, vouchers, gift certificates, loans, stock orstock options - is not acceptable.

 

If you receive gifts or favors, you must immediately notify yoursupervisor or other points of contact. In some circumstances, you may be required to return the gift with aletter explaining Cascade policy or, if a gift is perishable or impractical toreturn, you may be required to distribute it to employees or donate it tocharity, with a letter of explanation to the donor.

 

Employees who do business in certain countries often become aware ofcustoms involving the exchange of gifts or the payment of certain fees.  It is Cascade’s policy to comply with allapplicable laws on these matters, particularly the Foreign Corrupt PracticesAct.  This law restricts payments to officialsof foreign governments, political parties and candidates for office.

 

Ultimately, you must exercise prudent business judgment in decidingwhich situations are unacceptable.  Ifthere is ever any doubt as to the acceptability of any gift or entertainmentactivity, consult your supervisor or other points of contact.

 

Further guidance regarding gifts and entertainment can be found in theCompany’s Travel and Expense Policy.

 

 

### **RESPONSIBILITIES TO OUR COMMUNITIES:ENVIRONMENTAL PROTECTION**

 

Cascade is an environmentally responsible company and operates itsfacilities in compliance with applicable environmental, health and safetyregulations and in a manner that has the highest regard for the safety and wellbeing of its employees and the general public.

 

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Necessary permits, approvals and controls are maintained at all Cascadefacilities and Cascade strives to improve products, packaging and manufacturingoperations to minimize their environmental impact.

 

You are responsible for complying with all applicable environmentallaws, regulations and Cascade policies and to diligently follow the properprocedures with respect to the handling and disposal of hazardousmaterials.  Cascade insists that itssuppliers and contractors also follow appropriate environmental laws andguidelines.  If you have questions orconcerns relating to Cascade’s environmental compliance requirements oractivities, you should contact your local Safety/Environmental Manager, PlantManager, or any point of contact listed at the back of this Code.

 

 

### **NEWS MEDIA INQUIRIES**

 

Providing clear and accurate information to the media and generalpublic maintains Cascade’s integrity in its relationships with the public.  Requests for financial or businessinformation about Cascade from the media, press, financial community or thepublic must be submitted in writing for review and approval to the ChiefFinancial Officer or Vice President - Finance. Requests for information or other contacts from the Securities &Exchange Commission, the New York Stock Exchange or other regulators must allbe referred to Cascade’s Corporate Legal Counsel, Chief Financial Officer andVice President - Finance.  It iscritical that you not respond to any such inquiry or contact yourself becauseany inappropriate or inaccurate response, even a denial or disclaimer ofinformation, may result in adverse publicity and could otherwise seriouslyaffect Cascade’s legal position.

 

Requests for interviews relating to Cascade or its affairs, or theissuance of any press releases, must be reviewed and approved in advance by theChief Financial Officer.

 

 

### **GOVERNMENT INQUIRIES**

 

Cascade occasional receives requests for information from governmentagencies.  It is Cascade’s policy toanswer all proper inquiries promptly and truthfully.  Any information request from someone representing a governmentagency must be referred to your Plant or General Manager and to theChief Financial Officer or Vice President – Finance.

 

 

### **PUBLICACTIVITIES**

 

Cascade is committed to understanding the particular needs of thecommunities in which it operates and is proud of its contribution to theeconomic and social development of those locations.  Cascade encourages its employees to become actively involved in thelife of the communities in which Cascade operates.  Cascade employees are free to:

 

•                  Supportcommunity, charitable, religious or political organizations

•                  Supportcauses of their choice

•                  Endorsean event, product or service

 

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•                  Providetestimonials

 

You must not use your job title or affiliation in connection with suchsupport, endorsement or testimonial without approval from the Chief OperatingOfficer or Chief Financial Officer.  Youalso must make it clear that your views and actions do not necessarilyrepresent those of Cascade.  If youauthor an article or other publication and plan to be identified as a Cascadeemployee, you must submit a written copy of the article or publication forreview and approval from the Chief Operating Officer or Chief FinancialOfficer.  No Cascade employee maypressure another employee to express a view that is contrary to a personalbelief or to contribute to or support a political, religious or charitablecause.

 

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### **CODE OF ETHICS CONTACTS**

 

 

**Cascade Corporation Officers**

** **
| **Corporate Address:** |   | **2201 N.E. 201st Avenue** |
|------------------------|--------|----------------------------|
|                   |   | **Fairview, Oregon 97024** |

** **

**Robert C. Warren, President and ChiefExecutive Officer**

**Telephone: (503) 669-6725**

**Email: rwarren@cascorp.com**

** **

**Terry H. Cathey, Chief Operating Officer**

**Telephone: (503) 669-6793**

**Email: tcathey@cascorp.com**

** **

**Richard S. Anderson, Chief Financial Officer**

**Telephone: (503) 669-6329**

**Email: aanderso@cascorp.com**

** **

**Gregory S. Anderson, Senior Vice President –Human Resources**

**Telephone: (503) 669-6708**

**Email: ganderso@cascorp.com**

** **

**Joseph G. Pointer, Vice President – Financeand Secretary**

**Telephone: (503) 669-6727**

**Email: jpointer@cascorp.com**

** **

**Jeffrey K. Nickoloff, Vice President –Corporate Manufacturing**

**Telephone: (503) 669-6223**

**Email: jnickolo@cascorp.com**

** **

**Charlie S. Mitchelson, Vice President andManaging Director – Europe**

**Telephone: 011-31-36-549-2911**

**Email: cmitchel@cascorp.com**

** **

**Anthony F. Spinelli, Vice President – OEMProducts**

**Telephone: (519) 763-3675**

**Email: aspinell@cascorp.com**

** **

**Michael E. Kern, Corporate Vice President MHPMarketing and Sales**

**Telephone: (503) 669-6790**

**Email: mkern@cascorp.com**

** **

**John A. Cushing, Treasurer**

**Telephone: (503) 669-6705**

**Email: jcushing@cascorp.com**

 

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**Cascade’s Corporate Legal Counsel**

** **

**Jack B. Schwartz**

**Newcomb, Sabin, Schwartz & Landsverk**

**111 S.W. Fifth Avenue, Suite 4040**

**Portland, Oregon 97204**

**Telephone: (503) 228-8446**

**Email: jschwartz@nsslaw.com**

** **

** **

**Cascade’sCompliance Website (1):**

** **

**www.Ethicspoint.com**

** **

**Cascade’s Compliance Telephone Hotline (1)**

** **

**888-662-7878(available 24 hours a day, 7 days a week, toll free)**

 

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**(1)Information relating to the Compliance Website or Telephone Hotline can be obtainedon the Cascade Corporation website at www.cascorp.com or from your HumanResources Department.**

 

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