Code of Conduct

Respect the law. Treat everyone, coworkers, customers, and suppliers with dignity and respect. Take care of the environment and your workplace. Take no personal gain besides salary, benefits and satisfaction from your work. Honor the privacy of personal information and customer intellectual property. And above all act ethically and honestly in all dealings remembering that no performance goal or production need is more important than individual and collective integrity.

Conflict Mineral Policy

4.2.3,F-13, Conflict Free Minerals Policy, Revision 1

The mining and trading of Coltan (the metal ore from which Tantalum is extracted), Wolframite (the metal ore from which Tungsten is extracted), Cassiterite (the metal ore from which Tin is extracted), and Gold, and their respective derivatives, originating from the Democratic Republic of Congo (“DRC”) or adjoining countries (the “DRC Region”) has financed conflict, resulting in widespread human rights violations and environmental degradation. Section 1502(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Conflict Minerals Law”) requires SEC reporting companies to undertake an inquiry as to the source and chain of custody of conflict minerals and to report their “DRC Conflict-Free” status.

Vander-Bend Manufacturing supports the objectives of this legislation, which aims to minimize violence and environmental damage in the DRC Region. We will exert reasonable effort in making good faith country of origin inquiries of Vander-Bend suppliers. Vander-Bend Manufacturing expects that all suppliers comply with Conflict Minerals Law and provide all necessary declarations using the EICC / GeSI Conflict Minerals Reporting Template. These measures will be used in conjunction with industry initiatives such as the Conflict-Free Smelter Program to reasonably assure that the Tantalum, Tungsten, Tin or Gold in the products we manufacture do not directly or indirectly finance or benefit unauthorized armed groups in the DRC Region. Vander-Bend Manufacturing will assess future business with suppliers who are noncompliant with this policy.

Vander-Bend Manufacturing is committed to ethical practices and compliance with applicable laws and regulations.

Equal Employment Opportunity

Vander-Bend provides equal employment opportunities to all employees and applicants for employment without regard to race, color, religion, sex, national origin, age or disability, in accordance with applicable federal, state and local laws. This policy applies to all terms and conditions of employment including, but not limited to hiring, placement, evaluation, promotion, termination, layoff, leaves of absence, compensation and training. Vander-Bend will continue to make equal opportunity a reality at all levels of the organization.

Quality Policy

Vander-Bend is our customers’ manufacturing arm, producing their products with intelligence and care, as an extension of their vision.

To achieve the highest level of customer satisfaction, we will:

This shall be achieved by compliance with customer and regulatory requirements in an ideal, safe, and environmentally friendly workplace by employees and suppliers chosen and rewarded for their productivity, knowledge, skill, and dedication.