Code of Conduct

Klein Tools, Inc. and its affiliates are committed to observing the laws of the countries in which they operate. Accordingly, Klein Tools expects its business partners and their officers, directors, employees, agents, and other representatives (“Business Partners”) to comply with all applicable laws in connection with its marketing, sales and distribution of Klein Tools’ products. Compliance with such laws includes, without limitation:

• Anti-Corruption. Business Partners will comply with the U.S. Foreign Corrupt Practices Act, the United Kingdom Bribery Act (“UKBA”) and any other applicable laws prohibiting bribery, corruption, kickbacks, or other similar conducts. Under no circumstances will Business Partners offer, promise, or give anything of value to a government official or other third party with the goal of securing an unfair business advantage for the Business Partner or Klein Tools.
• Anti-Money Laundering. Business Partners will comply with all applicable U.S. and other laws prohibiting fraud, money laundering, or other transactions designed to conceal and transmit funds associated with criminal or terrorist activities. Under no circumstances will Business Partners structure or conceal financial transactions with Klein Tools (or involving Klein Tools products) to avoid applicable bank reporting requirements.
• Economic Sanctions. Business Partners will comply with all economic sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”), and EU, respectively. To that end, Business Partners will not directly or indirectly engage in any commercial or financial transactions implicating: (1) Cuba, Iran, North Korea, Sudan, Syria, or the occupied Ukrainian region of Crimea; or (2) any prohibited parties appearing on OFAC, OFSI, or EU sanctions lists without prior written approval from Klein Tools and any required authorization from the relevant governmental authorities.
• Export Controls. Business Partners will comply with the Export Administration Regulations (“EAR”), International Traffic Arms Regulations (“ITAR”) and other applicable export control laws. To that end, Business Partners will not directly or indirectly export, re-export, ship, or transfer any Klein Tools products, parts, components, accessories, know-how or technical data to: (1) any countries or parties prohibited under the EAR, ITAR, or other applicable export control laws; or (2) any parties appearing on the U.S. Department of State’s List of Debarred Parties or the U.S. Department of Commerce’s Entity List, Denied Persons List or Unverified List, without prior written approval from Klein Tools and any required authorization from the relevant governmental authorities.
• U.S. Anti-Boycott Regulations. Business Partners will not engage in any action that may cause Klein Tools to participate in the Arab League Boycott of Israel and other unsanctioned international boycotts. Business Partners will not make any representations to any third party, including governmental officials, concerning the ownership of Klein Tools, Business Partner or their respective business activities and relationships in any country in the world. Business Partners will notify Klein Tools of any request for information about Klein Tools or its business activities or any other documents or inquiries that would constitute a boycott request under the U.S. Anti-Boycott Regulations.
• Anti-Human Trafficking. Business Partners will not engage in trafficking in persons, including but not limited to commercial sex acts or sex acts in exchange for something of value, such as prostitution and related activities; or forced, involuntary or coerced labor; or child labor.
• Conflict Minerals. Business Partners will not source or incorporate into products supplied to Klein Tools any cassiterite, columbite-tantalite, wolframite, gold or their derivatives which originate from the Democratic Republic of Congo or specified adjoining countries, as defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Klein Tools expects its Business Partners to provide training to its officers, directors, employees, agents, and other representatives, as needed, to ensure full compliance with these laws.