The integrity, reputation and profitability of The AZEK^® Company ultimately depends 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.

At all times, we must be mindful of avoiding, 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: Is it legal? Is it consistent with our code of business conduct and ethics? Is it consistent with company policies?
• Our Mission: Is this action consistent with our mission statement? Does it exemplify the AZEK way?
• People: Am I involving the right people? How will my actions impact others?
• Responsibility: Does the action protect the company’s reputation? Does it prevent future issues from occurring?

A Leader

An employee at any level can take a leadership role in modeling exemplary behavior in ethical business conduct.

• Ensure every new or transferred employee receives a copy of the Code of Business Conduct and Ethics and the Business Ethics toll-free phone number.
• Provide appropriate training for employees on business ethics issues.
• Monitor and ensure compliance with this core policy by employees and others who do business on behalf of the company.
• Deal effectively with business ethics’ concerns that arise in the business units
• Support 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.
• Periodically certify compliance with this Code. Any false certification, even if directed by a supervisor, will be dealt with severely.

Employment Expectations

The AZEK Company wants to be seen as an employer of choice. We behave with integrity which encompasses everything from valuing our employees to protecting the environment to accurate financial reporting. All employees participate in regular training to learn about the company’s business conduct, ethics standards and expectations.

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. As an employee, you are not only responsible to behave ethically yourself; you’re also obligated to report violations you become aware of.

Each employee is obligated to disclose his or her own conflict or any appearance of a conflict of interest. Personal conduct, unrelated to The AZEK Company, is not the Company’s concern, unless such conduct impairs the employee’s work performance or affects the reputation or other legitimate business interests.

Compliance with Employment and Labor Laws

The AZEK Company’s most important assets are its employees. Each employee has genuine worth and deserves the respect and consideration of everyone. All employment must be in compliance with all applicable laws and regulations, including those concerning hours, compensation, opportunity, human rights and working conditions.

The AZEK Company 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.

Compensation & Benefits

The AZEK Company 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.

Employee Communications

The AZEK Company will communicate to its employees timely information about our company, its operations and performance requirements. One channel of communication is the employee survey, which is generally conducted every other year.

Conflicts of Interests

Social amenities customarily associated with legitimate business relationships are permissible. You are expected to avoid any investment, interest, or association that might impair or appear to impair your best exercise of judgment on The AZEK Company’s behalf.

A conflict of interest exists when your duty to give undivided loyalty to The AZEK Company can be prejudiced by actual or potential personal benefit from another source. We are loyal to The AZEK Company and avoid any conflict of interest.

Any employee who has a question about whether a 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. 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

The AZEK Company 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. In addition, a toll free Business Conduct and Ethics hotline, 877-874-8416, is managed by a third party provider and is available 24 hours a day, seven days a week for reporting issues. The third party managing the Business Conduct and Ethics hotline makes every attempt to protect the confidentiality of information provided to it.

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. Any employee having information concerning any prohibited or unlawful act shall promptly report such matter through the hotline.

Customers and Suppliers

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

We will sell our products and services honestly and will not pursue any sale that requires us to act unlawfully. Any activity in marketing or selling that impinges on the conflict of interest provision of the The AZEK Company Code of Business Conduct and Ethics is subject to the requirement of self-reporting.

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

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.

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 AZEK Company 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

The AZEK Company is committed to conducting its business in an environmentally sound manner. We share a common interest with our community to protect the quality of the environment for the present and for future generations.

Political Activities and Contributions

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 Human Resources the CFO and CEO.