Certificate of Compliance
NOTE: You should have received and reviewed a Summary of the Alamo Group Inc. Code of Business Conduct and Ethics. If you have not received the Summary, contact your Supervisor. Please answer all questions to the best of your knowledge and belief by checking the appropriate response. Exceptions should be explained beneath the question or on a separate sheet, referencing the question number. If you have any questions regarding this Certificate of Compliance or any of the policies of the Company, please address them to your supervisor, the Compliance Committee or the Legal Department.
This certificate covers the year proceeding the date you sign it. "Company" includes Alamo Group Inc. and all its subsidiaries and affiliates worldwide. "Representative of the Company" includes officers, employees, directors, agents and any other persons performing services for the Company.
I am familiar with the Code of Business Conduct and Ethics of the Company, including the sections concerning Conflicts of Interest and Fair Dealing, Confidential and Proprietary Information, Corporate Opportunity, Insider Trading and Tipping, the Foreign Corrupt Practices Act, Antitrust, Export Control, sanctions and Antiboycott. I certify that:
1) I have no nor am I aware of any Representative of the Company having a direct or indirect financial interest in, or position with, any business enterprise that to my knowledge is a competitor of the Company or is or has sought to be a supplier of or a party to a transaction with the Company. (Securities of a bank, insurance company, stock ownership in a public company of less than 5% or mutual fund may be excluded)
______ No Exception ______ Exception(s) As Described Per Attached
2) I have not nor am I aware of any Representative of the Company having received, requested, made, or offered, directly or indirectly, any payment, loan, service, excessive entertainment or travel, or gift from or to any business or individual having transactions with or in competition with the Company. (Normal and customary financial services and items of modest value legitimately used in the business community may be excluded)
______ No Exception ______ Exception(s) As Described Per Attached
3) I have not nor am I aware of any Representative of the Company having used or revealed outside of the Company, for other than Company purposes, any confidential information concerning the Company.
______ No Exception ______ Exception(s) As Described Per Attached
4) I have not bought or sold shares of the Company’s stock, options or other securities using inside information or without first obtaining approval from the Vice President, Administration and I am not aware of any person having a close personal relationship with me or Representative of the Company having done so.
______ No Exception ______ Exception(s) As Described Per Attached
5) I have not used nor am I aware of Representative of the Company using any Company employees, materials, or equipment for personal purposes. (Exclude any minor or occasional personal use that has minimal value)
______ No Exception ______ Exception(s) As Described Per Attached
6) I have not violated and am not aware of any violation of the Foreign Corrupt Practices Act, including any bribe, kickback, or similar payment or offer of payment in money, property, or services, direct or indirect, by or on behalf of the Company or any Representative of the Company, to or for the benefit of any foreign government official or political party or candidate for office for the purpose of inducing such person to us his or her influence to assist the company in obtaining or retaining business. (Exclude "facilitating payments" of relatively minor amounts to foreign officials whose duties are essentially ministerial or clerical.)
______ No Exception ______ Exception(s) As Described Per Attached
7) I have not and am not aware of any Representative of the Company who issued any check of the Company for purposes other than those recorded in the books and records of the Company, or otherwise contrary to the Policy on Conflict of Interest or Foreign Corrupt Practices Act.
______ No Exception ______ Exception(s) As Described Per Attached
8) I have not and am not aware of any Representative of the Company who entered into anticompetitive agreements, such as bid-rigging or fixing resale prices, with or among suppliers, distributors or customers.
______ No Exception ______ Exception(s) As Described Per Attached
9) I have not and am not aware of any Representative of the Company who participated in (1) a transaction with a country on which the U.S. Government has placed trade restrictions, (2) a violation of U.S. antiboycott laws or (3) violations of U.S. export control laws.
______ No Exception ______ Exception(s) As Described Per Attached
10) I have not violated and am not aware of any Representative of the Company or person having a close personal relationship with me violating the Company’s Code of Business Conduct and Ethics.
_______ No Exception _______Exception(s) as Described per Attached
I certify that I have carefully reviewed the Company's Code of Business Conduct and Ethics before completing this Certificate. I have answered the above items to the best of my ability and of my own free will.
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Date
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Signature
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Name - Printed
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Position
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Company
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