Exhibit
10.34


 


 


ACCURIDE
CORPORATION


 


 


CODE OF
CONDUCT


 


 

















 


PREFACE


 


 


ACCURIDE CORPORATION
and its subsidiaries (“Accuride” or the “Company”) are committed to
conducting its business in conformance with the highest ethical standards and
in compliance with all relevant legal and regulatory requirements.  Every Accuride employee has an obligation to
ensure that his or her personal conduct complies with the Code of Conduct.  Each employee also has an obligation to
ensure that fellow employees abide by the Code of Conduct and to report known
or suspected Code of Conduct violations.


 


The importance of
complying with the Code of Conduct and legal and regulatory requirements cannot
be over-emphasized.  Compliance is a
priority to Accuride.  The commitment of
all employees to the standards and principals reflected in the Code of Conduct
is needed to ensure that the reputation of Accuride continues to be one of its
most valuable business assets.


 


“Our business dealings
will be based on integrity and responsible action.  We expect our people, and those that they deal with, to act
honestly, with respect for others, and in accordance with all laws.”  (Accuride Value Statement)


 


Accuride’s integrity and business reputation are two of its most
important assets.  This Code of Conduct
embodies this philosophy.  There are no
circumstances in which straying from the Code of Conduct will benefit our
Company.


 


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ACCURIDE
VISION


 


Our vision is to be a global leader in the
design, manufacture, supply and service of wheel systems and other components
to the transportation industry.


 


Utilizing our core competencies and competitive strengths, we will
expand into new markets in which we can create increased value.


 


We intend to have Accuride products in every country, on every road!


 


 


ACCURIDE MISSION


 


Our mission is to provide exceptional value to
our customers and stakeholders.


 


This will be accomplished through an organizational culture focused on:
customer satisfaction, integrity, continuous improvement, people, innovation,
technology, speed and performance.


 


 


ACCURIDE VALUES


 


•                  Satisfied
customers are the foundation of our business. We will work closely with them to
ensure their satisfaction and our mutual success. We embrace new customers.


 


•                  Our business
dealings will be based on integrity and responsible action. We expect our
people and those they deal with to act honestly, with respect for others, and
in accordance with all laws.


 


•                  The expectations
of our customers are constantly increasing. We therefore recognize our need and
ability to continuously improve everything we do.


 


•                  Our people are
our most valuable resource, and are bonded by a common interest. Our work
environment must foster their involvement, development and co-operation.


 


•                  Opportunities to
improve and develop our business are constantly being formed. We encourage
creativity, flexibility and innovation in order to identify and capture them.


 


•                  As an industry
leader, we will actively seek and develop new technology. We will apply
technology to create breakthrough improvements in our products and processes.


 


•                  We recognize
speed as an essential and significant factor in performance. We will simplify
our business and manufacturing processes and reduce the time needed to do them.


 


•                  Success is
measured by our performance, and meeting aggressive goals is the basis on which
we will operate. We strive to be the best.


 


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QUICK REFERENCE POLICY
SUMMARIES


 


The following
descriptions provide a brief summary of each business policy in the Code of
Conduct and a general overview of its contents.  These summaries are intended only to serve as a convenient
reference, not to cover all the details of each policy.  For more complete information, refer to the
policy statements beginning on page 5.


 


Policy On
Antitrust Compliance 


 


It is the policy of Accuride to comply with the
antitrust laws of the United States and with the laws regulating competitive
practices in all other locations where we do business.  This policy identifies and discusses how
employees can avoid illegal and unethical interactions with customers,
suppliers, and/or competitors in situations involving unlawful agreements,
discriminatory, and predatory pricing, reciprocity, etc.


 


Policy On Freedom
From Discrimination, Harassment, And Other Abusive Situations


 


It is the policy of Accuride to provide equal
employment opportunity for all employees based solely on the qualifications of
each individual.  This policy describes
and prohibits any form of discrimination, harassment, or retaliation based on
race, color, religion, age, sex, national origin, veteran status, or
disability.  The policy emphasizes that
all such discrimination is unacceptable in the workplace.


 


Policy On
Environment, Health, And Safety 


 


It is the policy of Accuride to establish and maintain
a safe and healthy workplace and to protect the environment.  This policy covers the responsibility of
management and employees to assure compliance with all environmental laws and
to provide a hazard-free workplace by using appropriate processes, practices
and methods, and by providing timely education and training.


 


Policy On Freedom
From Conflicting Interests


 


It is the policy of Accuride to prevent situations in
which an employee’s interests are in conflict with those of the Company.  This policy explains the responsibility of
employees and their family members to avoid any action that may interfere with
the employee’s primary duty to serve the Company at all times.


 


Policy To Conduct
Business Legally And Ethically And To Maintain Accurate And Meaningful
Financial Records


 


It is the policy of Accuride to conduct its business
both ethically and legally and to present its financial information in a manner
that will not mislead or misinform those who receive and use it.  This policy proscribes improper use of
Corporate funds to gain favorable treatment by regulatory authorities, and
describes the requirements for maintaining and reporting financial information.


 


Policy On
Political Contributions And Public Service


 


It is the policy of Accuride to encourage employees to
be actively involved in the civic affairs of the communities in which they
live.  This policy discusses
restrictions on political contributions and provides guidance for individuals
who speak on behalf of the Company.


 


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Policy On Foreign
Corrupt Practices Act


 


It is the policy of Accuride to conduct operations and
activities outside the United States in complete compliance with the letter and
spirit of the Foreign Corrupt Practices Act. 
This policy discusses that no Company officer, employee, or agent shall
offer payments to a foreign official to induce that official to affect any
government act or decision in a manner that will assist the Company to obtain
or retain business.


 


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POLICY ON ANTITRUST COMPLIANCE


 


It is the policy of Accuride to comply with antitrust
laws of the United States, and with the laws regulating competitive practices
in all other locations where we do business.


 


Impermissible Agreements


 


United States antitrust laws forbid, among other
things, agreements that restrain trade or unduly limit competition.  The following actions constitute clear
violations:


 


Agreements with Competitors:


 


•                  To agree with
one or more of our competitors to fix prices, toll or service charges, whether
at existing levels, higher levels, or lower levels.


•                  To agree with
one or more of our competitors on what to bid, i.e., any form of bid rigging.


•                  To agree with
one or more of our competitors to fix other terms and conditions of sale, such
as credit terms, quantity discounts, freight, packaging, etc.


•                  To agree with
one or more of our competitors on allocation of customers or markets, whether
geographically or otherwise.


•                  To agree with
one or more of our competitors to fix levels of production or production
quotas.


 


Agreements with Customers:


 


•                  To obtain the
agreement of any customer (i.e., any entity who purchases from the Company) to
fix resale prices, or other terms and conditions of resale.


 


The following actions may
be considered in violation of the antitrust laws, depending on the
circumstances in which they occur. 
Employees should seek the advice of legal counsel before taking any of
the following actions:


 


•                  To agree with
our competitors or customers not to deal with any other person, whether that
person is a supplier or customer, i.e., a group boycott.


•                  To obtain the
agreement of any customer that it will not resell to a particular person or
class or in a particular area or territory.


•                  To force any
customer to buy a product as a condition of buying another product (i.e., a
tie-in sale); to obtain the agreement of the customer that it will buy all of
its product requirements from the Company; or to refuse to sell a product to
any customer unless it buys another product or all of its product requirements
from the Company.


•                  To purchase
goods or services from a supplier on the condition that it will purchase other
goods or services from Accuride, i.e., a reciprocal agreement.


 


Evidence of
Agreements with Competitors or Customers


 


Employees should know that even though they clearly
understand and follow these antitrust guidelines, actions taken in good faith,
with no intent to violate the law, may nevertheless be construed to be
violations.  Findings of illegal
agreements have been based on circumstantial evidence in some situations.  Even innocent facts may suggest an illegal
conspiracy to a judge or jury.


 


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The following two rules
of thumb should be followed in everyday business situations:


1.               Do not discuss
prices, costs, or customers with a competitor.


2.               Do not pressure a
customer on its resale prices and do not discuss another customer’s resale
prices with a customer.


 


Employees should avoid not only any action that may
violate the antitrust laws, but also any action that may give the appearance of
doing so.


 


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POLICY ON FREEDOM FROM DISCRIMINATION, HARASSMENT,


AND OTHER ABUSIVE
SITUATIONS


 


It is the policy of Accuride to provide equal
employment opportunity for all employees based solely on the basis of the
qualifications of each individual.


 


Accuride is also committed
to providing its employees with a work environment that is safe and free from
discrimination.  This includes freedom
from all forms of harassment based upon race, color, religion, age, sex, sexual
preference, national origin, veteran status, or disability.  Discrimination against or harassment of
employees is prohibited and may result in disciplinary action up to and
including termination of employment.


 


No manager or
supervisor may threaten or suggest, either explicitly or implicitly, that an
employee’s submission to or rejection of sexual advances or requests for sexual
favors will either enhance or adversely affect the employee’s employment,
evaluation, compensation, advancement, assigned duties, or any other terms or
conditions of employment.


 


Certain other
actions occurring in the workplace also are prohibited, whether committed by
managers, supervisors, or non-supervisory personnel.  These include derogatory, degrading, or demeaning words,
gestures, actions, or similar types of conduct concerning an employee’s race,
color, religion, age, sex, national origin, veteran status, or disability.  Other prohibited actions include unwelcome
sexual advances, requests for sexual favors, and other verbal or physical
conduct of a sexual nature.


 


No manager or
supervisor will request a loan from any subordinate or any other favor of
significant value.


 


Employees who
believe they have been subjected to discrimination or harassment should
promptly report the conduct to their supervisor, on-site Ethics Officer, Human
Resources Manager, or through the Ethics Helpline.  A thorough investigation will be conducted.  If the investigation confirms the
allegations, prompt corrective action will be taken.  Regardless of the outcome of the investigation, the employee making
the complaint will be informed of its results. 
If the investigation indicates there is no merit to the complaint or no
action is required, and if the employee requests in writing a review of the
decision, the matter will be reviewed by the senior manager at the
location.  No reprisal will be taken
against an employee as a result of a complaint made responsibly and in good
faith.


 


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ENVIRONMENTAL HEALTH AND SAFETY
POLICY


 


The protection of
the environment and the health and safety of our employees, customers,
suppliers, and the communities in which we work, are among Accuride’s most
critical concerns.


 


We will provide a
safe and healthful workplace, protect the environment and ensure that pertinent
environmental, health and safety issues are incorporated in the planning and
execution of the Company’s business.  We
will conduct our business in compliance with Company and all other applicable
environment, health and safety (EHS) regulations.


 


Compliance with
this Policy is the responsibility of every Accuride employee.


 


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POLICY ON FREEDOM FROM CONFLICTING
INTERESTS


 


Each Accuride
employee has a duty to be free at all times from any influence that might
conflict or that appears to conflict with the interests of the Company, or that
might deprive the Company of the undivided loyalty of the employee in business
dealings.  To this end, an employee
should not become involved in any situation that may create a personal interest
in the situation, or place the employee under an obligation that may interfere
with his or her primary duty to serve the Company at all times to the best of
his or her ability.  Employees who
should be especially mindful of this duty include all who may:


 


•                  have authority to purchase or sell property, goods or services on
behalf of the Company;


 


•                  recommend or influence decisions with respect to purchases or sales; or


 


•                  have knowledge of or access to the Company’s confidential information,
processes, or activities.


 


It is impossible
to present an exhaustive list of actions that might give rise to a conflict of
interest or the appearance of a conflict of interest.  The following guidelines should help to indicate areas where conflicts
of interest could most likely arise.


 


1.                                       Bribes, Kickbacks, and Other Payments


 


An employee will not offer or pay any bribe, kickback,
or illegal gratuity or payment, directly or indirectly, to any person,
organization, or governmental representative. 
An employee will not accept any bribe, kickback, or other payment or
illegal gratuity directly or indirectly, from any person, organization or
governmental representative.  All
transactions must be recorded in the Company’s books of account.


 


2.                                       Financial Interests in Suppliers, Customers, or
Competitors


 


A conflict of interest may exist where an employee or
a close relative of an employee has a financial interest in, or is engaged,
directly or indirectly, in the management of an organization that deals with
the Company as a supplier, contractor, purchaser, or distributor of the
Company’s products, or is a competitor of the Company.  The term “financial interest” means any
interest, direct or indirect, in the financial success or failure of an
enterprise, regardless of the nature of that interest or the manner of its
acquisition.  It includes, for example,
owning stock, being a partner, being a creditor, or any other arrangement in
which an employee or a close relative of an employee has an interest in or
claim on the assets or income of an enterprise.


 


A conflict of interest is unlikely, however, if the
financial interest is insubstantial and consists solely of stocks or bonds
listed on a national security exchange or customarily bought and sold in an
over-the-counter market.  A financial
interest may be considered “substantial” if it represents more than 1 percent
of the common stock of the enterprise in which the investment is made or if it
is a significant part of an employee’s assets.


 


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3.                                       Transactions or Competition with the Company


 


A conflict of interest may exist where an employee or
a close relative of an employee buys, sells or leases any kind of property,
facilities, or equipment from or to, or in competition with, the Company.  A conflict may also exist where any close
relative of an employee renders services to the Company other than as an
employee, or where an employee seeks to direct Company purchases or sales to or
through a close relative.


 


4.                                       Transactions with Persons Doing or Seeking to do
Business with the Company or in Competition with the Company


 


A conflict of interest may exist where an employee or
a close relative of an employee buys, sells or leases any kind of property,
facilities, or equipment from or to any organization or individual who is doing
or seeking to do business with the Company or is a competitor of the Company,
or where he or she accepts commissions, a share in profits, or compensation in
any form from any such organization or individual.


 


5.                                       Rendering of Services to Other Organizations or
Individuals


 


A conflict of interest may exist where an employee, without consent of
the Senior Vice President of Human Resources and Senior Vice President –
General Counsel, renders services to another organization or individual as an
employee, agent, consultant, or director if the organization or individual is
doing or seeking to do business with the Company or is a competitor of the
Company, or if the outside employment interferes with the employee’s performance
of duties for the Company.


 


6.                                       Gifts or Loans


 


An employee should not accept gifts or favors of
significant value or borrow money (other than from an established banking or
financial institution), directly or indirectly, from any organization or
individual that is doing or is seeking to do business with the Company or is a
competitor of the Company.  Any gift of
significant value must be returned promptly to the donor with an appropriate
explanation.  A gift to a close relative
of an employee is also treated as a gift to the employee.


 


7.                                       Corporate
Opportunities


 


An employee should not
directly or indirectly take advantage of any business opportunity that may be
of interest to the Company without first obtaining written authorization from
the President of the Company or his or her designee after full disclosure of
the material facts.  The fact that a
particular business opportunity is closely related to an existing line of
business of the Company, or represents a desirable avenue of expansion of the
Company’s activities, is a strong indication that the Company would be
interested in the opportunity.


 


8.                                       Confidential
Information and Trade Secrets


 


                Some
of the Company’s most valuable assets include business concepts, trade secrets,
trade names and trademarks, ideas, lists of leads or prospects, business and
product plans, information about our business methods, computer programs,
customer information, and a host of other information the Company maintains in
confidence.  Employees must safeguard
any 


 


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business information that is proprietary or
confidential to the Company.  Employees
also are obligated to protect confidential information offered by any supplier
or would-be supplier, including prices, terms and names of other sources of
supply.  Except as may be specifically
authorized by management pursuant to established policies and procedures,
employees are restricted from disclosing to any outside party any confidential
business information they have acquired during their employment with Accuride.
This obligation continues even after termination of employment.  Further, upon termination of their
employment, employees may not copy or retain any documents or other materials
containing any such confidential information or trade secrets.


 


9.                                       Trading
Securities on Inside Information


 


If at any time an
employee possesses material inside information about the Company (or any other
Company, particularly another Company with which Accuride does business), he or
she must refrain from trading the Company’s securities until the information
has been disseminated to the general public and absorbed by the
marketplace.  This prohibition on
trading securities includes indirect as well as direct transactions, puts, calls
or any other interest in the securities. 
Material information means information that a reasonable investor might
consider important in deciding whether to buy or sell the securities involved.  Insider trading carries potential criminal
and civil penalties.


 


It is recognized that in
particular cases it may be very difficult to determine what information is
considered material.  As a result, any
questions regarding the possession of material information should be asked prior
to any purchase or sale and should be brought to the attention of the General
Counsel.  Under no circumstances may an
employee give inside information to any other person, either specifically or in
the form of a general “tip”.  This does
not apply to an employee who provides this type of information to other
employees or outside advisers of the Company during the regular course of his
or her duties.


 


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POLICY TO CONDUCT BUSINESS LEGALLY AND ETHICALLY AND
TO


MAINTAIN ACCURATE AND MEANINGFUL FINANCIAL RECORDS AND
REPORTS


 


It is the policy of Accuride to conduct its business
both ethically and legally and to present its financial information, internally
and externally, in a manner that will not mislead or misinform the user.  In accordance with this policy, but without
limiting its generality, the following rules are to be applied:


 


1.                    The use of
Company funds or assets for any unlawful or unethical purpose is prohibited.


 


2.                    The
establishment of any undisclosed or unrecorded fund or asset is prohibited.


 


3.                    The making of
any false or misleading entry on the Company’s books or records is prohibited.


 


4.                    The making of
any payment or other disbursement to any third party for any purpose other than
as stated on the voucher is prohibited.


 


5.                    The written or
oral distribution of any false or misleading financial information or report,
whether internal or external, is prohibited.


 


6.                    Accuride
maintains pension and welfare programs that are subject to governmental
statutes.  As a result, Accuride has an
obligation to comply with these laws and all filings required by statute must
be timely, accurate, and complete.


 


7.                    In the course
of its business, Accuride is required to file tax forms with the proper
authorities in many jurisdictions. 
Accuride policy is to ensure that each such filing is accurate,
complete, and timely made.  Employees
will not take any action to evade taxes payable by the Company.  In addition, employees will not aid or
facilitate others, including Accuride employees, vendors, customers, or
subcontractors, in misrepresenting or evading taxes of any kind.


 


All Corporate books, records, and accounts are to be
kept in reasonable detail.  They must
accurately and fairly reflect Corporate transactions and use of Corporate
assets in a manner that will assist in the preparation of complete and accurate
financial reports.


 


Each employee of the Company, including those without
financial reporting or accounting responsibilities, is required to understand
and comply with this policy as it relates to individual job duties.


 


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POLICY ON POLITICAL CONTRIBUTIONS AND PUBLIC SERVICE


 


Accuride does not, directly or
indirectly, make contributions or other payments or provide property or
services to any candidate for public office or to any political party.  Any employee who makes a political
contribution personally should ensure that he or she does not imply that it is
a contribution from the Company.


 


Accuride encourages its employees to
be actively involved in the civic affairs of the communities in which they
live.  When speaking on public issues,
however, employees should do so only as individual citizens of the community,
and must be careful not to create the impression that they are acting on behalf
of or representing the views of Accuride. 
The only exception to this is employees who have appropriate
authorization to speak on behalf of the Company.


 


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POLICY ON COMPLIANCE WITH THE FOREIGN CORRUPT PRACTICES
ACT


 


Introduction


 


It is the policy of Accuride to
conduct operations and activities outside the United States in complete
compliance with the letter and spirit of the Foreign Corrupt Practices Act
(FCPA).  No Company officer, employee,
or agent shall offer payments to a foreign official to induce that official to
affect any government act or decision in a manner that will assist the Company
or any of its subsidiaries or divisions to obtain or retain business.  Furthermore, every officer, employee, and
agent is obligated by Company policy and federal law to keep books, records,
and accounts that accurately and fairly reflect all transactions and
disposition of Company assets.


 


The
Statutory Framework


 


The FCPA prohibits payments to
foreign officials that are made or offered corruptly.  Corrupt payments for purposes of the act are payments intended to
induce a foreign official to misuse his or her official position or to fail to
perform an official function in a manner that will assist a company to obtain
or retain business or otherwise benefit such company’s business.  Payments include gifts of substantial value,
lavish entertainment, and loans.


 


                Payments to
attorneys, consultants, advisors, suppliers, and customers of the Company
violate the FCPA if made while knowing that all or a portion of such payments
will be offered, given, or promised to foreign officials for any of the
prohibited purposes stated above.  A
person’s state of mind is knowing when that person is aware of or has a firm
belief that a prohibited transaction is substantially certain to occur.  Thus, mere negligence or foolishness is
insufficient to form a basis for liability. 
Liability cannot be avoided, however, by willful disregard or deliberate
ignorance of the facts.  Large fees paid
to a foreign consultant for efforts to persuade foreign government officials to
take actions favorable to the Company’s future business operations are likely
to raise questions where it is common knowledge that officials of that
government typically expect payments before taking favorable action, even if
the fees are mutually understood to be for the exclusive benefit of the
consultant or agent.


 


                There is an
exclusion from coverage under the FCPA for so-called grease or facilitating
payments, which are payments to expedite or secure the performance of routine
government actions.  Such actions
include obtaining permits, licenses, or other official documents; processing
governmental papers, such as visas and work orders; providing police
protection, mail pickup and delivery; loading and unloading cargo; and actions
of a similar nature.


 


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COMPLIANCE WITH
OUR CODE OF CONDUCT


 


The Ethics
Committee has been created by the Board of Directors to implement and supervise
the compliance program at all levels of the Corporation.  Specifically, the Ethics Committee has
overall responsibility for approving and modifying the Code of Conduct,
establishing training programs designed to educate all employees about the Code
of Conduct, providing legal guidance regarding the meaning and application of
the Code of Conduct, monitoring compliance with the Code of Conduct, reporting
known violations of law to appropriate governmental authorities, and providing
periodic reports to the Board of Directors on the effectiveness of the Code of
Conduct.


 


The Ethics
Committee has appointed Ethics Officers at each of our operating
facilities.  These Ethics Officers will
serve as front-line sources for Code of Conduct information, including
answering questions about the meaning and application of the Code of Conduct;
receiving reports, complaints or allegations concerning possible Code of
Conduct violations; and generally serving as informational resources for
employees in matters dealing with business ethics and conduct.  Additionally, each Ethics Officer will be
responsible for educating and training all current and new employees on the
meaning and application of the Code of Conduct.  The Ethics Officers will report directly to the Ethics Committee.


 


Finally, to the
extent an employee feels uncomfortable consulting initially with his or her
supervisor, an on-site Ethics Officer, or an Ethics Committee member concerning
the meaning or application of the Code of Conduct or an actual or suspected
Code violation, employees are encouraged to use a newly-established ethics
“Help Line” (1-800-626-7096, Ext. 4222). 
This “Help Line” will connect an employee with a confidential voice mail
which is regularly monitored by the Ethics Committee and on which the employee
can leave an anonymous confidential message.


 


It is the
responsibility of every employee to report any actual or suspected violation of
the Code of Conduct to his or her supervisor, an on-site Ethics Officer, the
Ethics Committee, or to the Company’s General Counsel.  Reports may be made by telephone, in
writing, through the Help Line, or through any other method acceptable to the
employee, and may be made anonymously. 
All reports of possible ethics violations will be recorded on an Ethics
Committee Report (“ECR”) form.


 


Violations of federal, state, or local law violate
this Code of Conduct and can expose you and the Company to criminal and civil
prosecution.  Violation of this Code may
result in disciplinary action, including suspension, demotion, or termination
of employment.  The Company also may
pursue civil remedies and/or refer criminal misconduct to appropriate
prosecutorial authorities.


 


GENERAL DIRECTIONS


 


All salaried and
certain other designated employees must read, understand and implement the
Accuride Corporation Code of Conduct. 
In doing so, every employee has the responsibility to recognize, and to
avoid or prevent situations that may cause possible violations of this Code.  If, after reviewing the information in the
Code, an employee has questions about its content or about matters pertaining
specifically to his or her area of responsibility, the employee should consult
with his or her supervisor, the on-site Ethics Officer or a member of the
Ethics Committee.


 


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ACCURIDE
CORPORATION


Ethics Committee Report (ECR)


Instructions to Employee


 


1.                                       Fill out only the Circumstances of
Suspected Violation section.


2.                                       If you are unsure of specifics, estimate
or leave the space blank.


3.                                       Do not identify yourself or anyone else
as the person making this report.  You
may list yourself and others in the appropriate section as a person who may
have relevant information.


4.                                       Do not fill out any other section.  The remaining sections will be completed by
the Company representatives who receive and act on your report.


5.                                       You may leave your report with any
Company manager, supervisor, Ethics Officer, or mail it to:


Bruce Henderson, Senior Ethics Officer


Accuride Corporation


P. O. Box 15600


Evansville, IN 
47716


6.                                       You may confirm that your report was
received by the appropriate Company authorities by calling the Senior Ethics
Officer anonymously at (812) 962-5471 and asking if the report has been logged
in.


 


CIRCUMSTANCES OF SUSPECTED VIOLATION


 


Briefly describe suspected violation (what happened?)                                                                                                          

                                                                                                                                                                                                

When did it happen?                                               Where?                                                                                                    

Person(s) suspected of involvement:                                                                                                                                       

Person(s) who may have relevant information:                                                                                                                       

                                                                                                                                                                                                


 


RECEIPT OF INFORMATION BY COMPANY


 


Person Receiving ECR:                                                                                                     
Phone:                                         




Date & Time Received:                                                                              
Where Received:                                                




Received:          In
Person            By
Mail            Help
Line           Other
Phone           Otherwise




          
Level I Violation: No Investigation Required. 
Receiving Officer:                                                                             




Date Received by Ethics Committee:                   
Logged Into Case Management:                                                              




DISPOSITION




Date Investigation Completed:               
By:                                                                                                                         




Findings:            
Sustained            Unfounded            Exonerated            Inconclusive




Corrective Actions Taken:                                                                                                                                                     




                                                                                                                                                                                               


 


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CERTIFICATION


 


An Employee Certification Form is included with this
summary.  Every employee is asked to
review, sign, and forward the completed form to his or her Human Resources
Department for placement in the employee’s personnel file.  Periodically, employees may be required to
reaffirm their understanding of the Code of Conduct, in the same manner.


 


The contents of this document DO NOT CONSTITUTE THE TERMS OF A CONTRACT OF
EMPLOYMENT.  This document
should not be construed as a guarantee of continued employment.  Rather, employment with the Company is on an
“at will”
basis.  This means that the employment
relationship may be terminated at any time by either the employee or the
Company for any reason not expressly prohibited by law.


 


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CODE OF CONDUCT


EMPLOYEE
CERTIFICATION FORM


 


This
will confirm that I have received, recently read, and understand the Accuride
Corporation Code of Conduct, which includes the following:


 


•                  Policy on
Antitrust Compliance


•                  Policy on
Freedom from Discrimination, Harassment, and Other Abusive Situations


•                  Policy on
Environment, Health and Safety


•                  Policy on
Freedom from Conflicting Interests


•                  Policy to
Conduct Business Legally and Ethically and to Maintain Accurate and Meaningful
Financial Records


•                  Policy on
Political Contributions and Public Service


•                  Policy on Foreign Corrupt Practices Act


 


I acknowledge that I am
responsible for understanding, complying with and implementing these policies
as they apply to my position and area of accountability.  I accept this responsibility as a condition
of my continuing employment.


 


To the best of my knowledge, I have been and currently am in compliance
with these policies, except as noted below or as has already been properly
reported to Accuride representatives.


 


(Use the space below and the back of this sheet to describe any
existing circumstances that may conflict with the Code of Conduct.  Please include as much detail as possible.)


 


 


	
   

  
	
  Name (Print)

  
	
   

  
	
   

  
	
  Signature

  
	
   

  
	
   

  
	
  Title

  
	
   

  
	
   

  
	
  Location

  
	
   

  
	
   

  
	
  Date

  



 


 


Please forward the completed form to your location’s Human
Resources Department.


 


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