CPG International (CPG) is committed to maintaining the highest standards of ethical business conduct. This Code of Business Conduct and Ethics (Code) sets forth fundamental principles and key policies and procedures that govern the conduct of all employees of our Company. All employees are bound by the requirements and standards set forth in this Code, as well as those set forth in all other applicable policies, procedures, and guidelines provided by the Company to employees. Adherence to the Code of Business Conduct and Ethics is a condition of employment and failure to comply with this core policy could result in disciplinary action, up to and including termination of employment.

Overview
The integrity, reputation and profitability of CPG ultimately depend upon the individual actions of our directors, officers, employees and representatives. Each is personally responsible and accountable for compliance with this Code. Reasons such as “everyone does it” or “it’s not illegal” are unacceptable excuses for violating these standards. We must be mindful of avoiding at all times, on and off the job, circumstances and actions that give even the appearance of impropriety or wrongdoing which can discredit our company.

At times, we face situations at work where the right decision may not be clear. If that happens, you can follow these guidelines:

CODE OF ETHICS
OUR MISSION
PEOPLE
RESPONSIBILITY
Is it legal? Is this action consistent with our Mission Statement? Am I involving the right people? Does the action protect the Company’s reputation?
Is it consistent with our code of business conduct and ethics? Does it exemplify the CPG way? How will my actions impact others? Does it prevent future issues from occurring?
Is it consistent with company policies?

IN BRIEF…
A Leader
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 At any level takes a leadership role in modeling exemplary behavior in ethical business conduct. Leaders lead the way.
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 Ensures that every new or transferred employee receives a copy of the Code of Business Conduct and Ethics and the Business Ethics toll-free phone number.
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 Provides appropriate training for employees on business ethics issues. Employees are trained on ethics.
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 Monitors and ensures compliance with this core policy by employees and others who do business on behalf of the company. Code compliance is monitored.
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 Deals effectively with business ethics concerns that arise in the business units.
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 Supports protection from retaliation for employees who report or supply information about, or assists in an investigation into a business conduct or ethics concern. We do not permit retaliation against employees.
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 Periodically certifies compliance with this Code. Any false certification, even if directed by a supervisor, will be dealt with severely.

Employment Expectations
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 We behave with integrity which encompasses everything from valuing our employees to protecting the environment to accurate financial reporting. We seek to be an employer of choice.
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 All employees participate in regular training to learn about the Company’s business conduct, ethics standards and expectations.
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 CPG employees are expected to demonstrate ethical leadership by raising questions and concerns about the right thing to do. We ask questions, raise concerns, and call attention to problems.
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 As an employee, you’re not only responsible to behave ethically yourself; you’re also obligated to report violations you become aware of.
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 Each employee is obligated to disclose his or her own conflict or any appearance of a conflict of interest.
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 Personal conduct, unrelated to CPG, is not CPG’s concern, unless such conduct impairs the employee’s work performance or affects the reputation or other legitimate business interests of CPG.

Compliance With Employment and Labor Laws
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 CPG’s most important assets are its employees. Each employee has genuine worth and deserves the respect and consideration of everyone.
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 All employment must be in compliance with all applicable laws and regulations, including those concerning hours, compensation, opportunity, human rights and working conditions. We comply.
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 CPG strictly prohibits discrimination or harassment against any employee because of the individual's race, color, religion, gender, sexual orientation, national origin, age, disability, veteran's status or any status protected by law.

Company Records
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 Because CPG is a public company, it is the special responsibility of all representatives, including in particular, the senior financial officers and the chief executive officer, to ensure that there is full, fair, accurate, timely, and understandable disclosure in reports and documents filed with the Securities and Exchange Commission and in other public communications made by CPG. We keep and report as needed accurate and complete records.

Compensation & Benefits
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 CPG will attract, motivate and retain competent, dedicated people by designing compensation and benefits programs that are competitive in our marketplaces and consistent with the Company’s mission statement. We follow our mission statement.

Employee Communications
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 CPG will provide its employees with timely information about our company, its operations and performance requirements.We communicate. We communicate.
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 One channel of communication is the employee survey, which is generally conducted every other year.

Employee Development
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 The “Employee Scholar Program” measures, enhances and encourages each employee’s pursuit of Life Long Learning and enhances the attainment of excellence in their chosen area of competence. We support lifelong learning.

Conflicts of Interests
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 Social amenities customarily associated with legitimate business relationships are permissible.
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 You are expected to avoid any investment, interest, or association that might impair or appear to impair your best exercise of judgment on CPG’s behalf.
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 A conflict of interest exists when your duty to give undivided loyalty to CPG can be prejudiced by actual or potential personal benefit from another source. We are loyal to CPG and avoid any conflict of interest.
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 Any employee who has a question about whether any situation in which he or she is involved amounts to a conflict of interest or the appearance of one should disclose the pertinent details, preferably in writing, to his or her supervisor.
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 Any activity which even appears to present such a conflict must be avoided or terminated unless, after disclosure to the appropriate level of management, it is determined that the activity is not harmful to the Company or otherwise improper.

Business Conduct and Ethics Hotline
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 CPG manages a system to respond to allegations of violations of the Company’s Code of Business Conduct and Ethics. We support business ethics and proper conduct.
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 In addition, a toll free Business Conduct and Ethics hotline, # 1-877-874-8416, is managed by a third party provider and is available 24 hours a day, seven days a week for reporting issues.
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 The third party managing the Business Conduct and Ethics hotline makes every attempt to protect the confidentiality of information provided to it.
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 The Company is dedicated to protecting employees from retaliation when they raise business conduct or ethics issues, or report an alleged violation of company policy or the law. We protect employees from retaliation.
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 Any employee having information concerning any prohibited or unlawful act shall promptly report such matter through the hotline.

Customers and Suppliers
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 We listen to our customers and suppliers and are dedicated to maintaining and enhancing key business relationships based on integrity, service and the principle of “Building Branded Value”. We listen.

Marketing and Selling
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 We will sell our products and services honestly and will not pursue any sale that requires us to act unlawfully. We sell our products honestly.
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 Any activity in marketing or selling that impinges on the conflict of interest provision of the CPG International Code of Business Conduct and Ethics is subject to the requirement of self reporting.
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 Business gifts that are customary and reasonable in frequency and value are permitted, generally. A gift is never permitted if intended in exchange for favorable treatment.

Antitrust Matters
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 It is widely understood that agreements with competitors to fix prices, to allocate markets or customers, to refuse to deal or to exclude competitors are generally forbidden by the antitrust laws. We compete fairly.
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 Trade associations are susceptible to misinterpretations. Membership in any trade association should be carefully considered to ensure that its purposes and practices are proper and lawful. Furthermore, no CPG representative is authorized to participate in any meetings with representatives of competitors, whether held by a trade association, professional society, management association, government advisory committee, or otherwise, in which discussions range into improper areas.

Compliance With Environmental Laws and Regulations
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 CPG is committed to conducting its business in an environmentally sound manner.
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 We share a common interest with our community to protect the quality of the environment for the present and for future generations. We protect the natural environment.

Political Activities and Contributions
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 No employee shall directly or indirectly use or contribute funds or assets of the Company for, or to any political party, candidate or campaign unless such a use or contribution is properly accounted for and approved by the Senior Vice President of People Services, the CFO and CEO.