TABLE OF CONTENTS PAGE  Letter from Management  1 Corporate Compliance Office  2 Management and Employees’ Roles  2 Questions  2 In the Event of a Violation  2 What to do about Suspected Violation  2 Confidentiality  3 Reporting Your Own Mistakes  3 Compliance with Laws and Policies  3 General  3 Product Safety and Quality  3 Environmental Compliance  4 Competition; Antitrust  4 International Business Issues  5 The Foreign Corrupt Practices Act  5 Anti-boycott Laws  5 U.S. Embargoes  5 Export Controls  5 Labor and Employment Laws  6 Equal Employment Opportunity  6 Sexual Harassment  6 Workplace Safety  6 Safety and Health  6 Conflicts of Interest  6 Inside Information — Securities  7 False Statements; Fraud  7 Improper Payments  8 Delegating Authority  8 Theft or Similar Conduct  8 Wiretapping and Eavesdropping  8 Political Activities  8 Advertising  8 Intellectual Property  9 Copyright Compliance  9 Trademark Protection  9 Patent Protection  9 Records Management  9 Financial Records  9 A Last Word  10 
 
 

 
Dear Fellow Employees:In the last year the headlines too often told of people and companies who have not donebusiness the right way. We want to impress upon all Armstrong employees the importance ofcomplying with our Code of Business Conduct, and the necessity of conducting ourselvesethically in all business practices.We all want Armstrong to be a great company. Greatness demands making the right decisions —quickly. Our Code of Business Conduct helps us understand the ethical considerations we must weighwhen making the right decisions. The Code also tells us where to go when we need help fullyunderstanding a situation.For almost 150 years, Armstrong employees have been living the spirit of our Code ofBusiness Conduct by following a few basic rules of ethical behavior. Making a companygreat takes the work of teams of people. Yet the unethical or non-compliant actions of oneindividual can undermine a company’s quest for greatness.We urge you to read carefully our Code of Business Conduct and acknowledge yourunderstanding of these principles. Let’s continue to do business the right way!Armstrong Management**This**Code of Business Conduct provides a summary of the Company policies for conducting business ina legal and ethical manner. Our fundamental policy is that all business conducted by Armstrong andits subsidiaries must comply with all applicable laws and regulations and meet high ethicalstandards.The purpose of the Code is to:**•** Prevent unethical or unlawful behavior; **•** Discover and stop any such behavior that may occur as soon as possible; and **•** Discipline those who violate the standards contained in the Code and related policies.In matters where the Code establishes standards that go beyond the strict requirements of the law,violations of the Code and related disciplinary actions by the Company are not intended to begrounds for claims by third parties, such as government authorities or customers.Nonetheless, the Company intends to respond to such incidents in a manner designed to reassurecustomers’ faith in our products and our integrity.
 
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**CORPORATE COMPLIANCE OFFICE**The Chief Compliance Officer is an officer designated by the Board of Directors. This officerreports to the Audit Committee of the Board of Directors and the full Board. The Audit Committeeoversees Armstrong’s general compliance with the law and this Code of Conduct. The Director ofCompliance reports to the Chief Compliance Officer. You can reach the Director of Compliance viae-mail at “Director of Compliance” on the Armstrong system or the toll free Armstrong Ethics Lineat 877-481-8913 (access the Armstrong Corkboard/Compliance for toll-free access codes for countriesoutside North America).The Director of Compliance works with business managers and employees to provide timely, pragmaticadvice on compliance questions and administer education, training and compliance auditing programs.The Director is also involved in investigation of violations of the Code.**MANAGEMENT AND EMPLOYEES’ ROLES**“Compliance” and “ethics” are not just a concern of management. They are the responsibility ofevery employee. We all must be active participants in furthering the policy of this Code. Whetherwe develop, manufacture, procure, market or sell Armstrong’s products, or deal with our customersor consumers, we all have a direct impact on our Company’s good name. Managers must understand ourOperating Principles and the Code and make them “real” for all employees. They must be active insupporting the Code and teaching employees about it. Each of us must make the Code a part of ourworkday life. All employees are obliged to cooperate in the investigation of possible violations.**QUESTIONS AND REPORTS OF POSSIBLE VIOLATIONS**If you have a question concerning the Code or related policies, or if you need help with a legal orethical question, e-mail the Director of Compliance at “Director of Compliance” on the Armstrongsystem or call 877-481-8913. Employees are encouraged to discuss their questions and reportpossible problems to their supervisors first. However, we recognize that there are occasionalsituations where this is not the best course. In that case, please contact the Legal Department.Our objective is to have meaningful opportunities for employees in all situations to come forward,ask questions and report potential problems.**IN THE EVENT OF A VIOLATION**We hope that serious violations of the Code never occur. Through communication and education, wewant to avoid problems rather than deal with their consequences.Failure to comply with the Code can have severe consequences for both the Company and the peopleinvolved. In addition to damaging our good name and hurting trade and consumer relations andbusiness opportunities, conduct that violates the Code may also violate the law. This can subjectthose involved to prosecution, imprisonment and fines.We will impose discipline for violations of the Code, up to and including termination of employmentin appropriate cases. Some violations may result in our referring individual misconduct togovernment authorities and seeking reimbursement for loss from the employee responsible.**WHAT TO DO ABOUT SUSPECTED VIOLATIONS**If you know of or suspect there is a violation of the law, regulations, this Code, or the Company’srelated policies, you are to report that information immediately. Contact your supervisor, yourhuman resources manager, your supervisor’s supervisor, the Director of Compliance, or the LegalDepartment. Supervisors to whom a possible violation is reported must, in turn, report it to theDirector of Compliance. If you believe a person to whom you have reported a potential violation hasnot taken appropriate action, contact the Director of Compliance or the Legal Department.
 
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**CONFIDENTIALITY**Reports of potential violations will be treated confidentially to the extent reasonable andpossible and allowed by our legal obligations**.**No person reporting a suspected violation will besubjected to retaliation because of a good-faith report. If there are any reprisals against such anemployee, those responsible for the reprisals will be subject to disciplinary action.It is preferred that you identify yourself when reporting suspected violations to allowinvestigators to contact you if further information is needed. In every case, we will do our bestto respect a request to keep your identity confidential. We do this to encourage employees to comeforward, but we cannot *guarantee*confidentiality because government authorities may request it oryour testimony may be needed in legal proceedings.If you have special concerns about confidentiality, however, you may report suspected violations bycalling the toll-free Ethics Line at 877-481-8913. Calls to that number have their origin blocked,and we will not attempt to track them.**REPORTING YOUR OWN MISTAKES**We strongly encourage people to voluntarily report their own errors. A voluntary reportdemonstrates the type of integrity and character that we want to foster in the Company. If you areinvolved in a violation, your reporting of it, the degree of your cooperation, and whether theviolation is deliberate or unintentional will be considered in any resulting disciplinary action.An unintentional error made in good faith that is voluntarily and promptly reported is unlikely tobe punished, and your prompt report may help avoid more serious problems.**Compliance*****with*****LAWS and POLICIES****GENERAL**The actions of the Company and its directors, officers, employees, agents, consultants and otherrepresentatives must be in compliance with applicable laws, this Code and our policies. When thereis doubt as to the lawfulness of any proposed activity, seek advice from the Legal Department.Described on the following pages are summaries of certain legal obligations and policies that areparticularly important to our business and reputation. Further information on any of these mattersmay be obtained from the Legal Department or the Director of Compliance. You may access moredetailed discussion on a variety of legal and policy issues through those sources.**PRODUCT SAFETY AND QUALITY**Armstrong built its reputation on providing products of uncompromising quality. The philosophy“Let the customer have faith” is a foundation of our culture. We will continue to serve the needsof our customers only if we maintain this dedication to product safety and quality. Our productsare subject to laws around the world relating to safety and performance. We will comply with theselaws and, in some cases, may set even higher Armstrong standards for safety, durability,maintenance or appearance.Our concern for product safety extends from product design and manufacture to products’ use inhomes and commercial buildings. It involves:**•** the raw materials we use **•** product design **•** our manufacturing processes **•** installation safety **•** flammability and toxicity once installed **•** product performance **•** use of recycled materials and recyclability
 
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All products, whether manufactured by our own operations or sourced from third parties, mustconform to applicable safety and quality standards, and must be approved through our ProductSafety Design Review process. Each business operation must be aware of standards for jurisdictionsto which products will be supplied. Appropriate raw materials, manufacturing processes, qualitycontrols and testing specifications and procedures must be utilized to verify the conformance ofproducts with applicable requirements.Product problems must be reported to the appropriate product manager and, in serious casesaffecting health and safety, to the business unit head and to the Legal Department. The businessunit must take necessary measures to protect public health and safety and safeguard our customers’interests and our reputation for quality.**ENVIRONMENTAL COMPLIANCE**Our policy on the environment recognizes the importance of exercising care in the selection, useand conservation of energy and raw materials, especially natural resources, providing forenvironmental safety in workplaces and communities; and reducing risks to the earth, its watersand atmosphere. The Company is committed to exercising environmental stewardship in our dealingswith customers, employees, community neighbors and government in meeting an obligation to futuregenerations.Violations of environmental laws can be serious for Armstrong, our employees, and the communitiesin which we operate and live. The Company and individual employees may be liable not only for thecosts of cleaning up pollution, but also for significant penalties. Violations of pollutioncontrol and waste management regulations can subject us to enormous penalties, and responsibleemployees can be fined or imprisoned. **•** Your activities must strictly adhere to all applicable environmental laws andregulations, to all Company policies and procedures, and to the requirements of allenvironmental permits. **•** Intentionally bypassing any environmental control or monitoring device in violationof any permit condition or regulation is strictly prohibited. **•** The entry of information known to be false on any governmental environmental form,on any monitoring report, or in response to any request for information from anygovernment agency is prohibited. Tampering with or diluting of samples, or otherwiseproviding false information about sampling, as well as intentional failure to followpermit conditions or applicable protocols for collecting, sampling, testing, analyzing,or recording environmental data is prohibited. **•** If you become aware that any employee is violating any environmental law,regulation, or permit, providing false information or data, or bypassing anyenvironmental control or monitoring device, immediately report that information to yoursupervisor, your supervisor’s supervisor or, as appropriate, the Director, Environment,Health and Safety, the Legal Department, or the Director of Compliance. **•** Immediately report all spills above Reportable Quantity or releases in excess ofpermitted amount in accordance with established procedures at your facility. Unlessexigent circumstances involve all hands in containing a release, a report to properauthorities should be made within mere minutes of discovering it. If you are uncertainto whom you should report, report to the facility manager, the Director, Environment,Health and Safety or the Director of Compliance.**COMPETITION/ANTITRUST**It is our policy to compete vigorously, but fairly, and to comply with applicable antitrust andcompetition laws. While these laws are not easy to summarize, in general those of the UnitedStates require that there be noagreements or understandings with our competitors that affect prices, terms or conditions of saleor unreasonably restrain competition. Antitrust laws apply to many aspects of business behavior.Any questions about permissible conduct should be raised with the Legal Department before anyaction is taken.
 
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There are to be no discussions or other contacts with competitors regarding prices to be chargedby Armstrong or our competitors, or the territories or markets in which products will be sold.Further, there should be no agreements with competitors as to persons or companies to whomproducts or services will be sold or not sold. Some laws also affect price differences betweencustomers and the terms of agreements with suppliers. Agreements with customers, suppliers,distributors, or retailers should be reviewed with the Legal Department prior to signing, asshould any arrangements resulting in price differences to competing customers.Trade association meetings and other industry gatherings typically serve legitimate purposes, butbring together competitors who are prone to discuss matters of mutual concern. Any discussion oraction that may involve prohibited conduct must be avoided, whatever the setting. Agreements canbe inferred from informal discussions or the mere exchange between competitors of information fromwhich collusion could result. Any communication with a competitor, no matter how innocuous it mayseem at the time, may later be subject to antitrust scrutiny. Employees must conduct all relationswith competitors, including social activities, as if they were completely in the public view.**INTERNATIONAL BUSINESS ISSUES**Employees must comply with the laws of the countries in which they operate. Even if certain lawsdo not seem to be enforced in practice, or if a violation is not subject to censure, violationsare still prohibited. If you have a question about certain activities, contact the LegalDepartment. You must get clearance before you risk taking questionable actions.Employees responsible for matters affected by the following U.S. laws must be aware how theyapply. Many other countries have their own laws on these matters, some of which can differ fromU.S. law. Employees responsible for our international operations must be aware of all these lawsand how they affect our business.**The Foreign Corrupt Practices Act.**Under this law and our policies, employees and Company agentscannot offer or make bribes, payments, offers or “gifts” of value to obtain or retain business.Indirect payments made through agents and the use of personal funds for such purposes is alsoprohibited. The Company discourages the presentation of gifts generally. (See “Improper Payments”below.)**Antiboycott Laws.**Armstrong conducts its business in accordance with U.S. antiboycott lawsintended to prevent cooperation with unsanctioned foreign boycotts. In general, the antiboycottlaws prohibit cooperation with a foreign boycott by (i) refusing to do business with anotherperson, (ii) taking certain discriminatory employment actions, (iii) furnishing information on therace, religion, sex or national origin of any U.S. person, (iv) furnishing information concerningany person’s affiliations or business relationships with a boycotted country or any personbelieved to be restricted from doing business in the boycotting countries, and (v) utilizingletters of credit containing certain boycott provisions. Employees should promptly report anyrequest for boycott-related cooperation or information.**U.S. Embargoes.**We conduct our business in light of U.S. international trade policies. Forexample, trade restrictions can affect countries such as North Korea, Cuba, Iran, Libya, Syria,Sudan, Yugoslavia (Serbia and Montenegro), Iraq, Afghanistan, Burma (Myanmar), UNITA (Angola) andSierra Leone. The list of embargoed countries changes periodically. Contact the Legal Departmentconcerning such changes. The restrictions imposed vary. They may affect exports, imports, travel,currency transactions and assets and accounts. Generally speaking, what may not be done directlyalso may not be done or arranged through third parties. Any contact in respect to an embargoedcountry must be reviewed in advance with the Legal Department.**Export Controls.**Under the U.S. Export Administration Regulations, the export of goods, servicesand information from the United States requires an export license from the Commerce Department.Our general license applies to most regular product shipments, but take care in exports of specialmaterials such asdangerous chemicals and certain unusual products. It is also important to observe documentationand record retention requirements for exports and imports.
 
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**LABOR AND EMPLOYMENT LAWS****Equal Employment Opportunity.**We are dedicated to providing equal employment opportunities. In theU.S., this policy is applied without regard to any impermissible classification. We respect allpeople, regardless of race, color, religion, sex, national origin, citizenship, age, disability orveteran status. All employees must avoid any act that is designed to cause, or causes, unlawfulemployment discrimination in any aspect of a person’s employment, including decisions concerninghiring, placement, transfer, demotion, promotion, recruitment, training, advertising,compensation, termination or use of employee benefits or facilities. We will not tolerateharassment of or by our employees based upon such discrimination.**Sexual Harassment.**Sexual harassment is one type of employment discrimination. We support theright of our employees to work in an environment that is free from sexual harassment. This mayinclude unwelcome sexual advances, requests for sexual favors, and any other verbal or physicalconduct or visible condition of a sexual nature that has the effect of unreasonably interferingwith an employee’s work performance or that creates an intimidating, hostile, or offensive workenvironment. If you believe you have been the victim of sexual harassment you should contact yoursupervisor; your human resources manager; your supervisor’s supervisor; or the Manager, EmploymentPractices. All allegations of harassment will be investigated in as confidential a manner aspossible, and appropriate corrective and disciplinary action will be taken.**WORKPLACE SAFETY****Safety and Health.**We are committed to eliminating hazards from the workplace, providing employeeswith a safe and healthy work environment and complying with all such applicable occupationalsafety and health laws and standards. Employees are required to comply with all such laws andrelated Company policies. Employees are also required to appropriately report any adverse healthor unsafe conditions, hazards, broken equipment or machinery, and accidents.**CONFLICTS OF INTEREST**Every Armstrong employee has a primary business responsibility to the Company, and must avoid anyactivity that may interfere, or have the appearance of interfering, with the performance of thisresponsibility. A conflict of interest is any interest, relationship or activity that isincompatible with the best interests of the Company or that potentially affects a person’sobjectivity in performing services for the Company. An individual may have this type of conflictof interest not only when he or she is in fact improperly influenced, but also when a situationlends itself to improper influence.A conflicting interest may unconsciously influence even the most conscientious person, and themere existence of that interest may cause the propriety of an employee’s acts to be questioned.Potential conflict situations may include, but are not limited to: **•** Serving as a director, officer, employee, partner, consultant or agent of a firmthat is a present or potential supplier, customer, competitor or other business partnerof the Company; **•** Owning stock or other interest in an enterprise described above or other investmentsuch as trading in commodities used by the Company (except where the stock or interest isgenerally available to the public and does not adversely affect the employee’s judgment,job performance or loyalty); **•** Receiving from a vendor or other enterprise described above a gratuity, specialallowance, discount, loan at a special rate or other benefit not generally available tothe public is a violation of policy. In addition, it is also a violation to accept a giftwhen its value is in excess of that which is allowable under our Gift Policy. **•** Any other significant direct or indirect personal interest in a transactioninvolving the Company;
 
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 **•** Disclosing or personal use of the Company’s confidential or proprietaryinformation; and **•** Appropriating for personal benefit a business opportunity that the Company mighthave an interest in pursuing, without first making the opportunity available to theCompany.Employees should review their personal and employment situations and must discuss any possibleconflicts of interest that arise by virtue of their own activities or the activities of theirfamily members with their supervisors. If you have any questions regarding a possible conflict ofinterest, contact the Director of Compliance or the Legal Department.**INSIDE INFORMATION — SECURITIES**Employees and consultants may not use or pass on nonpublic, material information about Armstrongor our business partners acquired during the course of business.Do not trade in Armstrong securities or other companies’ securities based upon such non-public,material information. Do not disclose inside information to outsiders, either intentionally orinadvertently, under any circumstances, whether during the business day, in after-hoursdiscussions or on the Internet. Protect all proprietary and confidential information and keep itwithin authorized circles in the Company. Only the Public Relations office or other personsauthorized by the Chief Financial Officer may publicly release material corporate information orrespond to inquiries from the media, the financial community, investors and others. Refer all suchinquiries about corporate or earnings-related news to the specified officials or to yoursupervisor to do so.Material information is any information that an investor might consider important in decidingwhether to buy, sell or hold securities. Examples include: financial results or forecasts; changesin dividends; possible acquisitions, divestitures or joint ventures; significant discoveries orproduct developments; and information concerning major litigation developments. Information isconsidered to be non-public unless it has been adequately disclosed and available to the public.Examples of adequate disclosure include public filings with securities regulatory authorities andissuance of press releases. Regular product and promotional information can be shared withindustry and trade press, but major product news, such as a breakthrough new product or a majorrecall, should only be disclosed by proper corporate sources.As indicated above, this policy also applies to material non-public information you learn aboutour distributors, retailers, suppliers, or acquisition targets. If you learn such informationabout one of these parties, you may not disclose it outside authorized Company circles, or tradein the securities of that company based on that information until the information has becomepublic. If you have a question as to whether information is proprietary, material or nonpublic,contact the Legal Department.**FALSE STATEMENTS; FRAUD**It is a violation of our policy and potentially a criminal offense to knowingly and willfully makeor cause to be made a false statement, orally or in writing, to a government official. It is alsoimproper to conceal a material fact called for in a governmental report, application or inquiry.You can get into trouble even if you do not personally make the false statement or conceal anyfacts. For example, you cannot provide false information to another employee knowing that, orunder circumstances making it likely that, the information will be provided to the government.These prohibitions extend to all communications with any federal, state, local or foreigngovernment agency. If you have any questions about this, contact the Legal Department.In addition, any scheme to defraud anyone, including customers, suppliers, or the Company itself,out of money, property, or honest services is prohibited. Transactions must be properlydocumented, and the creation of false or misleading documentation or the reporting of false,misleading or nonexistent transactions is prohibited.
 
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**IMPROPER PAYMENTS**No employee, agent or consultant may offer, give, solicit, receive, or encourage any form ofbribe, illegal rebate, improper gratuity, or kickback, whether directly or indirectly. Armstrongpolicy severely restricts conduct such as gift giving. Personal funds or resources may not be usedto do anything that is otherwise prohibited. All payments and receipts must be recorded accuratelyin our books and records.With respect to government officials and other customers, it is not necessary that a gift orpayment be given with the intent to influence that person to be prohibited. Further information isset forth above in the section titled “International Business Issues.”**DELEGATING AUTHORITY**Delegate authority on behalf of the Company only to employees and outside representatives who arepeople of integrity. Do not delegate substantial business or financial authority to people youknow or suspect based upon objective criteria (such as a prior history or threats) might violatethe law in the course of their work. Your decision can be based on background checks, informationin personnel files, audit results, and customer/supplier surveys. This requires careful judgmenton the part of managers. It presents some delicate issues, including employee privacy and the riskof defamation. **•** Unless approved by appropriate authority, do not hire or retain anyone you know hasbeen convicted of a criminal offense pertaining to their prospective areas ofresponsibility. **•** Make appropriate background checks and other reasonable inquiry into the status ofany potential employee, agent or consultant. **•** Periodically review delegations of substantial discretionary authority (includingapplicable controls). **•** If any employee, agent or consultant is charged with a criminal offense, contactthe Legal Department about removing the person from responsibility for related businessoperations, and terminating the person if he or she is subsequently convicted.**THEFT OR SIMILAR CONDUCT**Theft, fraud, embezzlement, misappropriation or wrongful taking of any property, including that ofthe Company, is prohibited, whether or not the act could result in a criminal proceeding. Thisincludes unauthorized use of our assets, including proprietary information, trade secrets, andcomputer and communications systems.**WIRETAPPING AND EAVESDROPPING**It is our policy to comply fully with all laws governing wiretapping, eavesdropping, and otherforms of electronic surveillance. Without express permission from the Legal Department, noemployee may use any type of device to acquire the contents of any wire, oral or electroniccommunication.**POLITICAL ACTIVITIES**We must comply with all campaign finance and election laws. You may not use Company funds, assets(including phones, copiers, or computers), services, or facilities on behalf of a political partyor candidate. Only limited exceptions on conditions approved by the Legal Department for certaintypes of fundraising and political activity involving corporate executives is allowed. We will notcompensate or reimburse any employee or other individual, in any form, for a politicalcontribution they make or intend to make. Also, U.S. law prohibits honoraria payments to U.S.public officials.**ADVERTISING**Advertising and product labeling are regulated by law. Generally, the law prohibits false,misleading or deceptive advertising and inaccurate labels. All advertising claims about ourproducts or services must be truthful and have a reasonable basis. Fair and accurate advertisingis important not only to comply with the law,but also to preserve the Company’s goodwill and reputation. All advertising claims must besubstantiated in advance of their publication. The labeling of our products must also comply withadvertising laws and labeling practices laws. It is our policy to label and advertise our productsand services in accordance with the law. No employee may create, approve or disseminate anyadvertising materials or labels for our products or services that are false, misleading, ordeceptive or that contain objective claims that cannot be substantiated. Failure to comply mayresult in both civil and criminal penalties.
 
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**INTELLECTUAL PROPERTY**Various laws govern the use of material or information that may be the subject of a trademark,patent or copyright or that may be treated as a trade secret. We have rights to many trademarks,patents, copyrights and trade secrets that are vital to our success. To protect our rights,employees’ use of all such intellectual property must be in accordance with applicable laws andour policies. Certain of these matters are described below. For further information concerning allaspects of intellectual property requirements, contact the Legal Department.**Copyright Compliance.**Written materials, such as books, articles, magazines, drawings, computersoftware, photographs and advertising are covered by copyright law. It is a violation of law andof our policy to make unauthorized copies of these materials. Violations can subject both theemployee and the Company to substantial penalties. The copyright law and our policy also prohibitillegal duplication of computer software. Copyright law does, however, permit copying ofcopyrighted material under limited circumstances.**Trademark Protection.**A trademark is a word, symbol, name, device or combination thereof used toidentify a product or line of products or services and to distinguish them from the products andservices of other companies. We use a number of trademarks that are recognized by the public andare extremely valuable. All employees must use our trademarks in accordance with our Policy onApprovals, Use and Protection of Trademarks to ensure that our trademarks are protected. Employeesmust clear new trademarks through the Legal Department and should notify the Legal Department ofany unauthorized use of our trademarks.**Patent Protection.**It is Company policy to respect the valid patents of our competitors and otherparties. No employee should intentionally infringe the patented technology of others.**RECORDS MANAGEMENT**You and your work group’s management of business records, both paper and electronic, must takeplace in accordance with our records management policy. It is our policy to control the retention,long-term storage and destruction of business records in accordance with legal, tax, auditing,operational and historical requirements. If you have questions concerning records management,consult Internal Auditing, the Tax Department or the Legal Department.**Financial Records.**Company financial and business records must be prepared accurately and storedproperly. Keep books, records, and accounts that accurately and fairly reflect all transactionsand disposition of assets. All transactions must be executed only in accordance with properauthority. Books, records, and accounts must reflect, accurately and fairly and within our normalsystem of accountability, all transactions and other events that are the subject of specificregulatory record keeping requirements.All transactions must be recorded as necessary or appropriate to permit the preparation offinancial statements in conformity with generally accepted accounting principles and otherapplicable rules and to ensure accountability for all our assets and activities. All assets andliabilities must be properly recorded. Under no circumstances may there be any unrecorded fund orasset, regardless of the purposes intended. No improper or inaccurate entry may be knowingly madeon our books and records.No payment on behalf of the Company may be approved or made with the intention, understanding orawareness that any part of the payment is to be used for any purpose other than that described bythe documents supporting the payments. All receipts and disbursements must be fully and accuratelydescribed on our books and records and must be supported by appropriate documentation properlydescribing their purposes.
 
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***A LAST*****Word**Thank you for reviewing this Code. It protects all of us as well as the Company. We all wantto work for a company we can be proud of. Armstrong is such a company. Let’s keep it that way.
 
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**Please make a copy of this Acknowledgment page only, complete it and return to Shared Services.Where differences in local law or policy varies from those outlined, local law or policy willapply. For issues pertaining to the Code of Business Conduct, e.g. where an employee function doesnot exist locally, contact your local HR department for information or assistance.****EMPLOYEE/CONSULTANT**