Code of Conduct INTRODUCTION

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1 INTRODUCTION Kingspan Group plc is committed to acting responsibly in its business, and maintaining high standards of ethics and integrity in all its dealings with its stakeholders, be they investors, customers, suppliers, its employees and the community it operates in. This policy sets out the fundamental principles which it requires all its directors, officers and employees to adhere to in order to meet those standards. These principles are supplemented locally both by the provisions of other policies, and the Employee Handbook, but in the event of any conflict this policy must be complied with. This policy was updated and adopted by the Board of Kingspan Group plc on the 25 November 2011 and is directly applicable to all employees of the Group. Eugene Murtagh, Chairman Gene M Murtagh, Chief Executive Officer

2 PRINCIPLES 1. INTEGRITY AND HONESTY This is the fundamental principle, underlying all other principles. Employees are expected to act with integrity and honesty in all their business dealings with third parties and in internal matters. It is the responsibility of each employee to ensure that they adhere to this standard. No one can justify an unethical act by saying that it was directed by someone in a superior position, and no manager is authorised to direct anyone to act other than in compliance with this policy. Any breach of this principle which tends to bring the Group into disrepute will be treated as a serious disciplinary matter. 2. COMPLIANCE WITH THE LAW All business decisions and actions must comply with the law and all applicable statutory or other governmental regulations. Kingspan operates in a large number of countries worldwide, subject to many different laws. It is committed to fully complying with the legal and regulatory requirements of all the countries in which it operates. In many cases failure to comply with local laws may result in the individual employee being liable to criminal prosecution and sanctions as well as the Group. Competition Kingspan firmly believes in the benefits of free and fair competition. Practices which distort competition or abuse market position are prohibited in many countries, and Kingspan is committed to complying with local regulations and has adopted a strategy which includes a training programme and continuous review of its activities to ensure compliance by local entities. Adherence to the Group s Competition Policy is mandatory. Corruption It is prohibited for any person to offer or pay any person (public or private) a bribe with the intention of obtaining favourable treatment, or influence the outcome of any business negotiations in which the Group is engaged. All employees of the Group are required to adhere to the Group s Anti-Bribery and Corruption Policy. It is proper and appropriate to entertain and give and receive gifts/gratuities where they are for a legitimate business purpose, not excessive in value, and not offered in connection with a specific business gain. It is never permissible to give or accept cash gifts of any amount, or gifts/gratuities which might be considered to affect the Group s impartiality in making sound business decisions. Fraud Employees who prepare accounting records must act honestly, and every transaction must be recorded and documented. Kingspan does not tolerate fraud, and any infringement will be treated as a matter of gross misconduct.

3 Inside information Directors and relevant employees of the Group with price sensitive information must not misuse or improperly circulate such information. This includes dealing in shares based on the inside information, causing or advising others to deal in shares based on such information, disclosing the information to a third party or making any public disclosure other than by way of an announcement to the Stock Exchange authorised by the Group. All directors and relevant employees of the Group are required to sign up to the Group s Share Dealing and Inside Information Policy. 3. CONFLICTS OF INTEREST All employees should avoid circumstances which may give rise to a conflict of interest between the employee and the Group. Employees should avoid having a financial interest (either directly or indirectly through family or third party connections) with customers or suppliers of the Group. Where a conflict of interest arises, the employee should notify the person(s) to whom he/she reports and seek their approval before proceeding. 4. OUR PEOPLE AND OUR ENVIRONMENT Health and safety Kingspan is committed to doing all that is reasonably practicable to prevent personal injury, and to protect against work hazards and environmental risk to employees, contractors and the general public who could be affected by its activities. In particular, the Group takes a proactive approach to health, safety and welfare matters applicable to the Group s activities, in particular, by monitoring the workplace environment, by consulting and involving employees, and by providing training and instruction to enable employees to perform their work safely. Employees have a duty to co-operate in the implementation of the Health & Safety Policy applicable to his/her workplace, to comply with all relevant safety procedures and not do anything which might cause a danger to or harm their fellow employees. Equal opportunities Kingspan is determined to ensure that our workplaces are free from unlawful or unfair discrimination on the grounds of sex, gender, sexual orientation, marital status, ethnic or national origin, nationality, colour, age, disability or religious or other similar philosophical belief.

4 Kingspan will not tolerate unlawful discrimination, harassment or intimidation on any of the above grounds. Management and employees must adhere to the Equal Opportunities Policies adopted locally. The environment It is Kingspan s objective to conduct its business activities in an environmentally and socially responsible manner. Kingspan is committed to complying with applicable environmental legislation, optimising of energy and raw material usage, prevention of pollution and environmental damage, and continuous improvement of environmental performance. Kingspan has set its own Net Zero Energy targets which it aims to achieve by IT Kingspan encourages the use of information technology to improve the working environment, provided it is used in a safe and lawful manner. Employees are required to comply with the Group s Information Technology And Telecommunications Policy in particular insofar as it concerns acceptable use of the internet and PROTECTION OF GROUP ASSETS Internal controls The integrity of the Group s financial reporting is of paramount importance. Whist the Board of directors have overall responsibility for the Group s financial statements, this responsibility is delegated to appropriate levels of local management. All employees must cooperate fully with any persons performing internal controls or audit procedures. All records, books of accounts and financial statements must reflect the transactions carried out, and conform to applicable legal requirements and generally acceptable accounting principles, and reflect a full and accurate disclosure of the financial situation of the relevant entity. The rules and procedures applicable to accounting records are set out in the Group Financial Policies. Confidentiality Employees who have access to and are entrusted with information related to the business, finance, processes, plans, clients, customers or affairs of the Group, are under a duty of confidentiality to the Group, and must not disclose such confidential information or use it for their own purposes other than in the proper performance of their duties, either during their employment or at any time after its termination. Employees are under an express duty of confidentiality under the terms of their Employment Contracts.

5 COMPLIANCE Reporting responsibility This Policy is intended to encourage and enable employees and others to raise serious concerns within the Group rather than seeking resolution outside the Group. It is the responsibility of all directors, officers and employees to report any breaches of this policy, or any other malpractice or illegal acts, in accordance with this policy. It does not include grievances with other employees or managers these should be addressed to Human Resources. Reporting violations It is recommended that employees firstly share their questions, concerns, suggestions or complaints with someone internal who can address them properly. In most cases, an employee s supervisor is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor s response, you are encouraged to speak with someone in Human Resources or anyone in management whom you are comfortable in approaching. Local management should report concerns to the Group s Head of Internal Audit, who has specific responsibility to investigate such issues. For suspected fraud, or when you are not satisfied or uncomfortable with approaching local management, individuals should contact the Head of Internal Audit directly. The Group s Head of Internal Audit is responsible for investigating and resolving all reported complaints and allegations and, at his discretion, shall advise the Chairman, CEO, Finance Director, and/or the audit committee. He has direct access to the audit committee of the board of directors and is required to report to the committee three times annually on his compliance activity. To report any concerns or breach of this Code of Conduct, you can call our Whistleblower confidential phoneline, details of which are posted in your workplace, or contact the Group Head of Internal Audit at +353 (0) Accounting and auditing matters The audit committee of the board of directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Head of Internal Audit shall immediately notify the audit committee of any such complaint and work with the committee until the matter is resolved. Acting in good faith Anyone reporting an issue must be acting in good faith and have reasonable grounds for believing the information disclosed is of genuine concern. Any allegations that prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offence Confidentiality Concerns may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reported concerns will be kept confidential, consistent with the need to conduct an adequate investigation. No retaliation No director, officer or employee who in good faith reports an issue shall suffer harassment, retaliation or adverse employment consequence. An employee or manager who retaliates against someone who has reported a concern in good faith will be subject to discipline up to and including termination of employment. Handling of reported violations The Head of Internal Audit will notify the sender and acknowledge receipt of the reported violation or suspected violation. All reports will be investigated and appropriate corrective action will be taken if warranted by the investigation. 25 November 2011.

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