Global Purchasing Policy

1. Mission:

To purchase goods and services in a manner that attains the best overall value to the company considering quality, price and service. We do this through a coordinated policy that is simple, compliant and flexible to support the Company's growth strategy. We follow applicable laws and our Code of Business Conduct and Ethics.

2. Scope:

This policy applies to all representatives including employees, companies, subsidiaries and identified third parties of Simpson Manufacturing Company Inc. (Simpson) purchasing goods and/or services.

3. Policy Statement

We aim to ensure that everything we make or purchase is produced consistent with local law and our Code of Business Conduct and Ethics. Every supplier doing business with Simpson should be equally committed to providing a healthy and safe working environment where workers are free from discrimination and intimidation; respecting both human rights and the environment. Simpson seeks to build and maintain long-term, mutually profitable and ethical supplier relationships while promoting the company's best interest.

The extraction and harvesting of some raw materials can have significant social and economic impact - both positive and negative. We endeavor to identify and limit the materials in our supply chain that pose negative implications. These materials however, might be incidental to the manufacturing of the raw materials we use.

Review/Oversight

Overall review and oversight of the purchasing function is the responsibility of the VP of Purchasing and the CFO. The creation and modification of any regional or local purchasing procedures requires approval from the VP of Purchasing.

Segregation of Duties

Simpson's practice is to include more than one person in the purchasing process. Authorizers of purchases and those receiving goods and services should be independent of each other.

Approval of Vendors

The approval of vendors needs to be done in compliance with Simpson's Signature Authority Policy and applicable Quality purchasing procedures.

Conflict of Interest

Decisions should be made that are in the best interest of the Company and not for personal gain. A conflict can arise when one acts with a personal interest that may make it difficult to perform objectively. Everyone is expected to be free of influences which are actually or potentially detrimental to the best interest of the company.

Due Diligence and Screening of Vendors and Agents

Due diligence and screening of vendors and all those who act on Simpson's behalf are subject to the Anti Corruption Policy.

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