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Leadership Through Integrity PPG Industries Global Code of Ethics ■ A Guide to Corporate Conduct

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FROM THE OFFICE OF THE CHAIRMAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 USING THIS CODE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 How do I use this Code? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2 What is expected of me? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2 What are the consequences of violating the law or this Code? . . . . . . . . . . . . . . . . . . . . . . . .2 How do I report violations of this Code, the law or workplace misconduct? . . . . . . . . . . . . .3 How will I be protected from retaliation for reporting a violation of law or the Code? . . . . . . . . . . .3PPG’S RELATIONSHIPS WITH CUSTOMERS, SUPPLIERS AND COMPETITORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4

Antitrust . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 Anti-Corruption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 Gifts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 Meals, Entertainment and Travel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 Inappropriate Entertainment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8RESPONSIBILITY TO PPG EMPLOYEES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 Safety, Health, Working Conditions and Human Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 Internal Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Diversity at PPG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Harassment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 PrivacyandConfidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Privacy in Communications and in the Workplace . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 ConflictsofInterest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Alcohol, Drugs and Other Intoxicants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12PROTECTING CORPORATE ASSETS AND PREPARING ACCURATE FINANCIAL STATEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Accurate Accounting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Payments and Expenditures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Security of Property and Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Intellectual Property . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Inside Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

External Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16PPG’S COMMITMENT TO SUSTAINABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Product Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Stewardship of the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17PPG AS A GLOBAL ORGANIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Trade Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Respecting Local Law and Customs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19YOUR PERSONAL COMMITMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19ETHICS HOTLINE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Contents

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Our company’s reputation for being an honest, fair and capable firm with which to do business, wherever we operate, is one of our most

valuable assets . To ensure we maintain this crucial competitive advantage, it’s important that everyone within PPG knows, understands and conforms to one standard .

As PPG continues to grow and succeed, one aspect that will not change is our company’s commitment to ethical behavior . As PPG enters new markets, makes acquisitions and expands, we must reinforce our already excellent standards of conduct . It’s crucial that new and veteran employees alike keep pace with the evolving legal and compliance standards affecting our company and their respective jobs .

In addition, the ethical conduct of each and every PPG employee is a cornerstone to our efforts toward corporate sustainability . We do what we do in order to ensure the success and lasting presence of our company for the benefitofourcustomers,suppliers,shareholders,employeesandneighbors.

Our uncompromising ethics are a critical component of our ability to accomplish this objective .

This publication, the PPG Global Code of Ethics, sets forth the principles that apply to all PPG people, everywhere and in every circumstance . We cannot diminish our company’s good name

because of a lack of knowledge of this code or failure of any of our people to put its provisions into practice .

Our reputation rests not only on our ability to be a provider of quality goods and services, but also on our integrity and high ethical standards .

Let this code guide us as we work together toward our mutual goals: to furnish goods and services that meet our customers’ and society’s needs; to provide all employees with a safe, healthy and fulfillingworkenvironment;toaffordshareholdersa superior return on their investment; and to contribute as a good corporate citizen to each nation and each community in which we operate .

Charles E . Bunch Executive Chairman

From Th e Offi ce of Th e Chairman

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USING THIS CODE

■■ How do I use this Code?

The Global Code of Ethics is designed to guide the conduct of all PPG employees, regardless of function or position, on ethical issues that are faced during the normal course of business .

TheGlobalCodeofEthicsisdividedintofivegeneralcategories:

• PPG’s Relationships With Customers, Suppliers and Competitors;

• Responsibility To PPG Employees;

• Protecting Corporate Assets and Preparing Accurate Financial Statements;

• PPG’s Commitment To Sustainability; and

• PPG as a Global Organization .

Global Ethics and Compliance Committee

PPG has established a Global Ethics and Compliance Committee under the leadership of its Chief Executive Offi cer. This committee is supported by three regional Ethics committees located in Europe, South America and the Asia Pacifi c region. Each committee is comprised of executive and senior management-level employees from a range of functions and business units.

The committees’ purposes are as follows:

• To review the ethical aspects of corporate conduct policies.

• To advise the Chairman and Board of Directors concerning ethical standards.

• To promote awareness of PPG’s ethical standards.

• To consider appropriate responses to ethical issues that are brought to the attention of the Company or its employees.

• To provide help and counsel on ethical issues that can’t be resolved at the supervisor level, or where the supervisor may require additional guidance.

Undereachcategory,youwillfindPoliciesandexplanationsrelatedtospecific subjects covered by that category. Wherever possible, clearand unambiguous language is used to describe what is expected of each PPG employee . As a practical matter, though, we recognize that you may encounter situations in which your ethical obligation may not be entirely clear . Sometimes you may not be familiar with the relevant body of law . At other times, prevailing custom or practice may not offer suitable guidance . When conducting international business involving severaldifferentcultures,wemayfindourselvesfacingconflictingethicalsystems.Tobetterassistyou,aresourceisidentifiedundereachsubjectin the Code should you have any questions or require further guidance on a particular Policy .

■ What is expected of me?

All PPG employees are required to read, understand and follow this Code .

Enforcement is the direct responsibility of every PPG supervisor, regardless of location .

No code of conduct, including this one, can cover every situation a person might encounter . Nevertheless, PPG people everywhere are expected to conduct their business in a manner that brings credit to themselvesasindividualsandreflectsfavorablyontheCompany.Shouldyou have any questions about this Code or how to respond in a particular situation, you are expected to contact your regional or business unit lawyer for guidance .

■■ What are the consequences of violating the law or this Code?

PPG regards violation of the law and this Code as a serious matter . A breach of law or established policy can put the Company, its people and its products at substantial risk . Every PPG employee is accountable for his or her own behavior . Accordingly, anyone who violates the law or this Code will be subject to appropriate disciplinary action, up to and including termination .

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PPG’s efforts to achieve higher levels of financial performance in no way diminish our ongoingcommitment to integrity . In today’s highly competitive global economy, some people may be tempted toacttoadvancetheCompany’sfinancialinterestswithoutsufficientregardtotheethicsorlegalityof their actions. However, PPG does not recognize any conflict between achieving its corporateperformance goals and observing the law and its ethical code .

We want PPG to remain an attractive company with which to do business . We are convinced that conducting our affairs according to the law and high ethical standards contributes to that status . We will continue to support the employee or agent who forgoes a business advantage that can only be gained in violation of law or PPG policy .

■■ How do I report violations of this Code, the law or workplace misconduct?

All employees are required to report promptly any illegal action or Code violations by anyone working for or on behalf of PPG . Certain violations can cause serious harm to the company and/or third persons, and prompt reporting may allow PPG to avoid or mitigate that harm . Failure to report illegal activities is not only a violation of Company policy, but may itself be a violation of the law . In addition, knowingly and intentionally making a false report of misconduct is unacceptable and might also be illegal .

Report the conduct promptly, fully and objectively to one of the following people who are in a position to respond to the matter:

• Your Supervisor – Your Supervisor is obliged to pursue the issues raised by your report and to inform you about its disposition . If the supervisor’s response is not satisfactory or if, because of the nature of the issue, you would prefer to report the problem to someone else, you may report it to the next higher level of authority .

• Security or Human Resources Personnel – Professionals trained in security-related matters and human resources representatives are available to help you .

• Chief Compliance Officer at PPG’s Global Headquarters, Pittsburgh – The Chief Compliance Officerisresponsibleforenforcingcorporatecomplianceandethics,exportcontrolpolicies,controls and procedures, global asset protection, loss prevention, investigations and security consulting . Note particularly that suspected or actual violations of law (including but not limited to any U .S . export control laws or regulations), of PPG’s export compliance policies, controls, or procedures, or of your compliance obligations under this Code, such as those stated in the policies on Antitrust, Anti-Corruption, Payments and Expenditures and Trade Compliance, shouldbereporteddirectlytotheChiefComplianceOfficer.

• The PPG Ethics Hotline – The toll-free Ethics Hotline is maintained by a third party onbehalfofPPGandwilltakeyourreportinstrictconfidenceandreferittotheappropriate PPG authority .

If requested to do so, the Company will make every effort to maintain the anonymity andconfidentialityofanyonedisclosingsuchinformation.

■■ How will I be protected from retaliation for reporting a violation of law or the Code?

It is against PPG policy to retaliate against anyone for making a good faith report of a violation of law or this Code .

Any PPG employee who receives a report of a violation of law or this Code is responsible for ensuring that the report is handled properly and that the employee making the report is treated fairly in the process . For example, all individuals charged with investigating an Ethics Hotline call are advised that it is against PPG policy to retaliate in any manner against the caller, should the caller’s identity be revealed during the investigation . If an employee makes a report to someone other than his or her direct supervisor, the person who takes the report is responsible for its proper handling and for ensuring that the employee is treated fairly .

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PPG’S RELATIONSHIPS WITH CUSTOMERS, SUPPLIERS AND COMPETITORS

The key to PPG’s business success lies in our ability to deliver goods and services of consistently

high value to our customers . To meet this standard, we manufacture products that perform according to customer expectations, promote those products truthfully, and provide effective customer support and service . Our commercial success is linked to the satisfaction of our customers . PPG depends on long-term, continuing relationships with satisfied customers, not on isolated single sales . Therefore, it is essential to develop customer relationships with the Company’s long-term interests in mind . Cultivating our customers’ trust and selling our products on the basis of merit are fundamental to this long-range approach .

■■ Antitrust

EveryonemustcomplyfullywiththeantitrustlawsoftheUnitedStateswherevertheyareapplicable,athomeandabroad.WemustalsocomplywiththecompetitionlawsineverycountryinwhichPPGanditsaffiliatesconductbusiness.AvoidcommunicationswithPPGcompetitorstotheextentpossible.Donotenterintodiscussions,formalagreementsorinformalunderstandingswithourcompetitorsconcerningthemanufacture,saleordistributionofproductsorservices,includingissuessuchasprice,wages,costs,profits,termsofsale,creditarrangements,marketshare,productionvolume,salesterritories,productsandservicestobeoffered,biddingstrategy,customerallocationandmethodsofdistribution.

The purpose of the antitrust laws is to preserve our competitive free enterprise system . PPG is committed to fair and open competition in markets throughout the world . We believe the long-range interests of our shareholders, customers and employees are best served by following business practices based on compliance with the law and respect for the operation of a free-market economy . Our policy is founded on the belief that the public interest is best served by vigorous competition – competition free from collusive agreements between competitors. Thus,while the attainment of profits by all lawful andproper means is strongly encouraged, PPG’s efforts in that regard must be conducted in accordance with the law .

In the eyes of the public, as well as in courts of law, perceptions are often more important than reality . Even innocent contact with our competitors carries the risk of being viewed as a possible conspiracy . We aremindfulthatittakesyearstoearnagoodreputationinanyfieldofendeavor,butitisanunfortunatefact that all the previously attained good can be wiped out by the acts of a single individual on a single occasion. Intheantitrustfield,themisconductofasingleemployeecaninvolvetheemployee,theemployee’s supervisor, the Company and its management in costly, arduous litigation that can lead to civiljudgmentsandcriminalfinesofseveralmillionsofdollars,injunctionsandevenimprisonmentofseveral years for the involved individuals .

Participation in agreements or understandings that violate the antitrust laws is contrary to PPG policy . Examples of activities that violate PPG policy and the United States antitrust laws include: agreements orunderstandingsbetweentwoormorecompetitors:(1)tofixprices,discountsortermsofsale;(2)to divide markets, customers or territories; or (3) to refuse to deal with, or boycott, third parties . Each of these activities can lead to criminal prosecution and conviction of the individuals involved as well as their companies . Their mention is not intended to minimize the importance of other less obvious activities that may also violate the antitrust laws .

Information concerning competitor strategies and market conditions that we obtain from our customers, suppliers or from other independent third parties is both legitimate and desirable . However, you are prohibited from asking customers to serve as conduits to enable us to communicate with our competitors .

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In practice, the distinction between competitors, customers and suppliers can become blurred . There are even some companies that relate to PPG in all three ways .

Beyond that, there are situations in which discussions with our competitors could serve a legitimate and useful business purpose . These include trade association activities, lobbying efforts, industry-wide wageandbenefitsurveys,certaindiscussionsconcerningthecreditworthinessofcustomers,collectivebargaining, safety, health and environmental programs, and various joint business and research ventures .

Consultation with PPG legal counsel concerning any communications with our competitors is important, and any employee who is in doubt as to the legality of a contemplated course of action should communicate with the Law Department before action is taken .

Contact your regional or business unit lawyer for further guidance regarding this Policy.

Handling Unethical Requests or Compromising Situations

If you are approached by anyone inside or outside PPG with a request to do something that you recognize to be illegal or unethical, you must refuse to do so. Tell the person making the request that such conduct is contrary to PPG policy. To report the incident, refer to the section in this Code entitled “How do I report violations of this Code, the law or workplace misconduct?” No supervisor may direct a subordinate to violate the law or the Company’s Global Code of Ethics.

Likewise, you should immediately disassociate yourself from taking part in any discussions, activities or other situations that you recognize to be potentially illegal. Where you have reason to believe that a violation of law or this Code has actually taken place, you must report it to PPG’s Chief Compliance Offi cer.

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■■ Anti-Corruption

PPGprohibitsbriberyandcorruptioninallofitsbusinessdealingsineverycountry.Thispolicyappliestoall transactionsbetweenPPGandanyotherparty, regardlessofwhether it isbetweenPPGandaprivateentityorPPGandagovernmentofficial.Particularlystringentprohibitionsapplytoanyefforttoimproperlyinfluencegovernmentofficials–includingthepersonnelofgovernment-ownedorcontrolledentitiesthatareengagedinordinarycommercialactivities.

In addition to being a good business practice, this policy is required for compliance with the laws and regulations in many countries where PPG does business .

These laws and regulations, which include the U .S . Foreign Corrupt Practices Act and the U .K . Bribery Act, among others, have been adopted to eliminate corruption in the global marketplace and to promote a fair and competitive commercial environment within which to conduct business . These laws and PPG policy prohibit PPG employees from making or offering bribes, payments or anything of value to obtain or retain business or any other improper business advantage . ”Anything of value” includes cash, gifts, meals, entertainment, and services .

Gifts, meals, and entertainment may only be provided when there is no intent to improperly obtain or retain business or other business advantage and if otherwise in accordance with PPG’s Gifts Policy and Meals, Entertainment and Travel Policy, as set forth later in this Section .

ThispolicyandtheselawsandregulationsapplytoPPGanditssubsidiaries,aswellastheirofficers,directors, and employees . These laws and regulations also prohibit any effort to take such actions through any party retained, directly or indirectly, by PPG, such as sales representatives, contractors, intermediaries or agents .

Careful selection of business partners, agents and sales representatives is also critical to PPG’s efforts to ensure integrity and honesty in its business dealings . We are obligated to know with whom we are doing business and to ensure that when those parties act on PPG’s behalf, they do so ethically and in compliance with applicable laws . Similar diligence should be applied in selecting joint venture partners, candidates for acquisition, and their respective agents and representatives .

Because violations of these laws and regulations can result in severe criminal and/or civil penalties for both the Company and the individuals involved, it is critical to act in a manner which avoids even the appearance of a potential violation of these restrictions . Any violation of this policy may result in disciplinary action, up to and including termination of employment .


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■ Gifts

No one working on behalf of PPG shall give or accept a gift that could reasonably be interpreted as an attempt to improperly infl uence the recipient. In no case may cash or securities be given or accepted. Giving or accepting gifts of more than nominal value should be approved in advance by your supervisor. Gifts may never be solicited. Further, you may never give or accept a gift where it would be unlawful to do so or if it would knowingly violate the policy of the other party’s employer.

The purpose of giving business gifts is to create goodwill for the Company, nothing more . Examples of permissible gifts are mementos that are proportionate to the occasion and gifts that are responsive tolocalcustom.However,attemptingtoinfluenceothersonthebasisofpersonalgiftsisimproper,unacceptable and, in some instances, unlawful . It is useful to remember that appearances, as well as reality, are important considerations . Providing tickets to an event for an unaccompanied customer is not entertainment but a gift . Likewise, accepting tickets to attend an event unaccompanied by a supplier is not entertainment but a gift . The guiding principle in this area is good judgment . When you cannot refuse to accept an impermissible gift tactfully or without risking damage to a valuable business relationship, you may accept the gift . However, you must promptly turn the gift over to the Company’s internal auditors for donation to a charitable organization . Alternatively, if you prefer to keep the gift, you may pay its fair market value to the Company . PPG, in turn, will donate the money to charity .


Additional Obligation for Officers and Directors

PPG’s Global Code of Ethics applies not only to employees worldwide, but also to all PPG directors. Any waiver of the Code for executive offi cers or directors may be made only by the Board or a Board committee and must be promptly disclosed to shareholders. Waivers or exceptions to the Code for executive offi cers or directors will be granted only under unusual circumstances. This ensures that in the rare instance that a waiver is sought by an executive offi cer or director that it undergoes an additional level of scrutiny by the highest governance authority of the company.

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■■ Meals, Entertainment and Travel

No one working on behalf of PPG shall offer or accept meals, entertainment or travel that could reasonably be interpreted as an attempt to improperly influence the recipient. Meals, entertainment or travel may never be solicited. Further, you may never give or accept them where it would be unlawful to do so or if it would knowingly violate the policy of the other party’s employer.

Decisions concerning whether to offer or accept meals, entertainment or travel should be governed by good judgment and moderation . Take particular care in accepting meals, entertainment or travel from suppliers . As a general rule, providing or accepting meals, entertainment or travel is permissible if it meets the following test:

• The occasion serves essentially a business purpose .

• The PPG employee accompanies the customer or the supplier accompanies the PPG employee .

• The meals, entertainment or travel are proportionate to the occasion .

PPG reimbursable “entertainment” is definedasanyappropriateactivityoreventfor which a PPG employee accompanies a customer . As noted above in the “Gifts” section, under certain circumstances tickets to an event may be considered a gift rather than entertainment . They therefore are subject to the approval requirements for gifts . When deciding whether to provide or accept meals, entertainment or travel, also take into account their frequency and value . Unusually high frequency or value of such offers should be approved in advance by your PPG supervisor .


■■ Inappropriate Entertainment

Do not propose or engage in any form of entertain-ment that could reasonably be expected to lead to embarrassment to PPG or its employees or to reflect negatively on the Company’s image.

Some forms of entertainment are not appropriate for the conduct of the Company’s business . An example is entertainment that exploits or degrades anyone with respect to gender, ethnic identity, culture, race or religion . Supervisors shall not authorize reimbursement of expenses incurred for inappropriate forms of entertainment .


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RESPONSIBILITY TO PPG EMPLOYEES

The relationship between PPG and its employees at every level is based on mutual respect, reciprocal trust and shared objectives . Recognizing

these ties, strengthening our common bonds and enhancing their impact on the Company’s day-to-day activities are the ongoing responsibilities of every PPG manager .

Even though local circumstances vary from one Company location to another, certain global principles and expectations concerning the relationship of PPG to its employees transcend local conditions. Those principles definethe implicit understanding that exists between PPG and every individual employed by the Company .

■ Safety, Health, Working Conditions and Human Rights

PPG will provide a safe and healthful workplace and partner with our employees to improve their health and well-being and that of their families.

• Protecting and promoting the health, safety and well-being of PPG people is a top corporate priority worldwide . Our strategy for achieving that objective involves:

• Establishing safe and healthful working conditions that meet or exceed the applicable standards for occupational health and safety .

• Providing appropriate safety and health training and instruction .

• Promoting health and safety off the job for our employees and their families .

• Ensuring that the working hours for our employees comply with applicable local laws regulating hours of work .

• Ensuring that child labor is not used and the minimum age of all employees complies with applicable local laws .

• Providingouremployeeswithcompetitivewagesandbenefitsthat,ataminimum,comply with applicable law .

• A commitment that we will never use forced labor in any form .

• Respecting the right of our employees to voice their work-related concerns to management, to associate freely, and in accordance with local laws to organize and bargain collectively or refrain from such activities .

PPG endeavors to prevent the incidence of work-related illness or injury . To achieve that goal, we have developed corporate-wide policies and procedures related to the safe operation of PPG’s equipment, proper handling of materials, safe work practices, limits on exposure to potentially hazardous substances, and other matters affecting employee health and safety on the job . PPG also has developed procedures in the event of emergencies related to our facilities or natural disasters . PPG requires that all employees adhere to these policies and procedures .

Contact your business unit or corporate HR or EH&S representative for further guidance regarding this Policy.

Your Right to Know PPG Procedures

Everyone employed by PPG has the right to examine those PPG policy statements and procedures that apply to his or her own job responsibilities. If you feel that becoming more familiar with the details of any particular corporate policy document will help you to do your job better, you should contact your supervisor or your local HR representative. Upon request, those offi ces will provide you with the information you need.

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■■ Internal Communications

PPG is committed to an environment that fosters clear, honest and timely communication.

Achievement of PPG’s performance goals depends in large part on a well-informed and motivated workplace . That, in turn, requires effective, candid two-way communication throughout the Company .

To that end, all employees are expected to communicate important information and offer suggestions that will benefit the operations of the Company. This includes the prompt reporting of problemsand violations of PPG policies to the appropriate supervisory personnel . Likewise, every supervisor is expected to convey timely information about Company plans, performance, goals and policies to the people who report to him or to her . Additionally, every PPG employee has the right to information relatedtohisorherownperformance,compensationandbenefits.

Contact your supervisor for further guidance regarding this Policy.

■■ Diversity at PPG

PPG recognizes the business and intrinsic value of promoting diversity in today’s global workforce and is committed to that endeavor.

Diversity at PPG means valuing differences among us such as experience, perspective, background, race, age, gender, sexual orientation, culture, geography and even style . But it also means creating a cultureofinclusionbasedondignityandrespect–acultureinwhichartificialbarrierstoachievementare removed and the contributions of all employees are recognized and valued . Promoting and embracing these concepts enables all of us to make unique contributions to PPG and achieve our full potential . Effective diversity management can result in increased creativity, better problem-solving, improvedproductivity,reducedinterpersonalconflictandimprovedteamwork.

Consistent with PPG’s commitment to diversity, PPG gives equal employment opportunity to, and will not discriminate against, individuals on the basis of any status protected by applicable laws .

PPGhiresonthebasisofindividualqualificationsandabilityrelativetojobrequirements.Advancementis based on merit and demonstrated performance on the job .

Contact your human resources representative or your regional or business unit lawyer for further guidance regarding this Policy.

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■■ Harassment

PPG will not tolerate unlawful harassment of any kind, including verbal or physical abuse or intimidation.

Harassment of any PPG employee – by management, co-workers, customers or suppliers – destroys teamwork and can affect productivity negatively . Accordingly, all PPG employees are expected to treat each other with courtesy, dignity and respect . Every PPG employee should be alert to signs of harassment in the workplace . If you feel you are being harassed or think that another employee is being harassed, take appropriate actions to resolve the matter, such as reporting the incident or conduct to Human Resources or any member of management .

PPG will promptly and thoroughly investigate any complaints of harassment and take appropriate disciplinary action against any employee found to have violated this policy . PPG will not tolerate retaliation in any manner against any employee for truthfully reporting harassment or participating in an investigation of alleged harassment .


■■ PrivacyandConfidentiality

PPG respects the privacy of its employees.

PPG’s relationship with its employees is built on trust and respect. Accordingly, PPG will provide confidentialemployee information to others only on a need-to-know basis for legitimate business purposes and in accordance with applicable laws . PPG employees who have access to confidential employee information are responsible fortaking reasonable steps to ensure that the records are kept confidentialinaccordancewithPPGpolicyandprocedure.


■■ Privacy in Communications and in the Workplace

PPG telephones, e-mail, internet connections, computer inputs, facsimile machines and other electronic devices are intended to be used for PPG business-related purposes. Any inappropriate use of these systems, including excessive non-work-related use, is prohibited.

All messages or other communications sent on these systems are Company records . PPG reserves the right to access and disclose the content of such messages when there is a legitimate business reason to do so and in accordance with applicable laws . PPG will not tolerate the transmission or storage of electronic communications that are abusive, obscene, offensive or profane .

Electronic communication systems are not entirely secure and may be susceptible to interception . Employees are responsible for safeguarding e-mail messages, faxes and other electronic transfers of information to those outside the Company . Employees should also exercise the same care, caution and etiquette in telephonic and electronic communications as they would in a written business letter or memo .


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■■ ConflictsofInterest

No employee shall engage in conduct, or allow a situation to exist, in which the employee’s personal interest conflicts with his or her responsibility for honesty and fair dealing in his or her relations with the Company.

Aconflictofinterestoccurswhenanemployee’spersonalinterestsinterferewithhisorherabilitytousehisorherjudgmentobjectivelyinthebestinterestsofPPG.Forexample,aconflictofinterestcanarisewhereanemployee,acloserelativeoraclosefriendcanpersonallyprofitfromatransactioninvolvingtheCompanyandtheemployeeorathirdparty.AconflictcanalsooccuriftheemployeeplacesorinfluencesCompanybusinesswithhimself/herself,aprivately-heldbusinessinwhichtheemployee,closerelativeorclosefriendofhis/herfamilyhasafinancialinterestorapubliclyheldbusinessinwhichtheemployee,acloserelativeoraclosefriendhasamajorfinancialinterest.

Anemployeemustpromptlyreportanycircumstanceinvolvingapotentialconflictofinterest,oranychangeincircumstance,tohis/hersupervisor.Byavoidingactualorapparentconflictsofinterest,PPGemployees help to build and sustain the trust of our co-workers, customers, business employees and the general public .

Contact your supervisor or your regional or business unit lawyer for further guidance regarding this Policy.

■■ Alcohol, Drugs and Other Intoxicants

It is contrary to PPG policy for any employee to impair his or her capabilities on the job through the use of alcohol, drugs or other intoxicants . Moreover, PPG is committed to achieving a workplace free from intoxicants, consistent with applicable laws, and prohibits the distribution, possession or use of illegal or unauthorized alcohol, drugs or other intoxicants on Company property or on Company time .

PPG expects all employees to contribute their best efforts on the job . This means, among other things, that we expect an employee’s judgment and decision-making to be clear and unimpaired by alcohol, drugs or other intoxicants . In addition to affecting an employee’s own work and decision-making capability,theuseofintoxicantscancreateasignificantrisktothesafetyofothersandthewelfareofthe business .


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PROTECTING CORPORATE ASSETS AND PREPARING ACCURATE FINANCIAL STATEMENTS

Everyone working for PPG has a duty to safeguard the Company’s assets against theft, loss or misuse . These assets belong to the shareholders and are valuable resources . They provide PPG

people with their means of livelihood . These assets include information as well as money, equipment, supplies, facilities and materials .

Particularlyinthoseproductmarketswhereconfidentialinformationandproprietarytechnologiesplaya major role in PPG’s business strategy, there is a substantial consequence of information passing into the possession of unauthorized persons . It is essential for everyone to exercise constant vigilance in protecting PPG’s trade secrets, business data and proprietary know-how against improper use and industrial espionage .

Similarly, the responsible management of PPG’s resources requires an accurate accounting for uses made of the Company’s assets and the results of its operations . Company resources must not be diverted for inappropriate or unauthorized uses .

PPG has established internal control standards and practices to ensure that assets are protected and properly used and that accounting records and reports are accurate and reliable . All employees are responsible for maintaining and complying with required internal controls .

Compliance with PPG’s accounting policies is not optional . Following these requirements will result in goodbusinesspracticesandwillbenefitallPPGemployeesandshareholders.

■■ Accurate Accounting

Every individual involved in creating, transmitting or entering information into PPG’s financial records is responsible for doing so accurately, completely and with appropriate supporting documentation. Compliance with established accounting procedures and controls is necessary at all times. PPG’s records, books and documents must accurately reflect the Company’s transactions and provide a full account of the organization’s assets, liabilities, revenues and expenses.

Commercialmarkets,financialmarketsandanumberof parties both inside and outside the Company have a legitimate interest in PPG’s financial results. Theyrely on the timeliness, accuracy and integrity of our record-keeping to produce information on which they rely to make decisions concerning a wide range of important matters .

Contact corporate security, internal audit or your local finance representative for further guidance regarding this Policy.

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■■ Payments and Expenditures

No undisclosed or unrecorded fund or account shall be directly or indirectly established for any purpose. No direct or indirect payment or expenditure on behalf of PPG shall be authorized or made with the intention or understanding that any part of such payment or expenditure is to be used for a purpose other than that described by the documents supporting the payment or expenditure. All entries made in the financial records of the Company shall fairly and accurately reflect the facts and circumstances of any payment or expenditure made by the Company. No employee shall make any direct or indirect payment or expenditure or give any gift to improperly influence, or which would appear to improperly influence, any person in his/her relations with the Company or others.

All PPG transactions shall be supported by documentation that clearly and accurately states the purpose for the transaction . In addition to being a good business practice, the above policies are required to comply with the laws in many countries where PPG does business . These rules require U .S . companies that (like PPG) issue debt or stock to the public to maintain internal accounting controls and tokeepbooksandrecordsthataccuratelyreflecttransactions.Aviolationoftheserulesmaysubjectanindividualtoimprisonmentandafine,andmayexposePPGtopenaltiesaswell.

Contact your local finance representative or your regional or business unit lawyer for further guidance regarding this Policy.

■■ Security of Property and Information

Every PPG employee with access to Company money, information or property has an absolute responsibility to manage these PPG assets with the highest level of integrity and to avoid any misuse of such assets. It is PPG’s policy to terminate and prosecute violators of this requirement.

Fraud, theft, embezzlement or other improper means of diverting corporate funds is, of course, illegal as well as unethical . Preventing the theft, misuse or misappropriation of Company property by others should be a concern of every PPG employee . Such losses can often be limited through normal precautions, through handling Company assets in a prudent manner and through compliance with our established internal control procedures and processes . These include the following:

• Secure equipment, supplies and materials against theft .

• Implement reasonable information security measures .

• Report suspicious persons or activities to security personnel .

It is always important to be aware of the circumstances in which you are conducting your business and avoid discussions of sen-sitiveorconfidentialCompanyinformationin the presence of unauthorized persons .

Contact corporate security, internal audit or your regional or business unit lawyer for further guidance regarding this Policy.

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■■ Intellectual Property

No one working for PPG may disclose to unauthorized individuals – whether inside or outside the Company – any information that would tend to compromise proprietary technologies or trade secrets. In addition, reasonable precautions should be taken to prevent the inadvertent disclosure of such information. This confidentiality of Company information applies even after an individual has left the employment of PPG.

PPG has made a major investment in such intellectual properties as its patents, trademarks, brand names and computer programs . Protecting these properties against infringement is a high priority for the Company . We are committed to the aggressive pursuit of violators by every legal means . Just as PPG expects its intellectual property rights to be observed, we respect the property rights of others . Accordingly, it is contrary to PPG policy to intercept, duplicate or appropriate through electronic or other means such materials as computer software, audio or video recordings, publications or other protected intellectual properties except by permission of the patent or copyright holders . It is also against PPG policy for employees to disclose proprietary information they receive under personal obligationof confidentiality fromothers, includingprior employers, or to solicit disclosureof suchinformation.Moreover,PPGwill not instructemployees to reveal suchconfidential informationnorretaliate against them for failure to do so .

Additionally, any offer of confidential information from outside sources should be refused unlessappropriatelegalsafeguardshavebeentakeninadvance.SuchsafeguardswouldincludeaConfidentialDisclosureWaiverorPPG’sstandardConfidentialInformation/SampleAgreement(bothavailableonthe PPG Law Department’s website) .


■■ Inside Information

PPG employees must respect the con-fidentiality of sensitive or privileged information and exercise a high level of trustworthiness in dealing with such infor-mation. This includes information concern-ing the Company’s business or financial data pertaining to sales, earnings, assets, liabilities, forecasts, business plans, acqui-sition strategies and other confidential information. PPG employees who possess any such confidential information that is not available to the public are prohibited from disclosing such information to any unauthorized person.

Employees also must respect the confidential nature of any similar information they may obtainconcerning organizations with which PPG has business dealings as a supplier, customer or competitor . Furthermore, they are prohibited from using material inside information as the basis for trading in the Company’s stock or in the securities of any other company .

In addition to PPG’s long-standing commitment to ethical behavior, this is the law . Nonpublic information obtained as a consequence of Company employment may not be used for the personal profitoftheemployeeorofanyoneelseasaresultofassociationwiththeemployee.Useforpersonalprofitincludestakingadvantageofsuchinformationbytradingorprovidinginformationtootherstotrade in securities of PPG or any other company . Examples of information that may be of a nonpublic nature include PPG financial results before release to the public; SBU or product line financialinformation that is not publicly disclosed; information about customers, suppliers or competitors; real estate acquisitions; research activities; and proposed acquisitions or divestitures .


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■■ External Communications

To build public trust, it is in PPG’s best interest to provide accurate, timely and consistent nonproprietary information about its products, services and activities to the news media. Earning that trust requires ongoing, two-way and mutually beneficial communications with the various stakeholders critical to PPG’s success. At PPG, these key stakeholders include: employees, shareholders, customers, suppliers, public officials, residents of communities in which PPG operates, the financial community, various trade and professional groups, the general public and the news media.

Each PPG business unit is encouraged to interact with the media for the purposes of marketing their products and services . Other media interactions that relate to PPG as a corporation should be managed by PPG’s Corporate Communications department, as per the Company’s External Communications Policy . Individuals who receive inquiries from news media should refer them to the appropriate business unit contact, the facility’s senior manager or Corporate Communications for handling in accord with this policy .

Contact your supervisor or Corporate Communications for further guidance regarding this Policy.

PPG’S COMMITMENT TO SUSTAINABILITY

As a component of PPG’s values, the company recognizes its responsibility to preserve and protect the global environment in which it operates . What’s more, PPG strives to be a responsible

corporate citizen in the communities in which we operate . This multi-faceted concept of sustainability involves:

• A commitment to responsible corporate citizenship by combining our business interests with our role as a steward of the earth .

• Improving and safeguarding the well-being of our neighbors, planet, employees and shareholders by investing in safe and sustainable technology and resources .

• Enhancing the quality of life in the communities in which we operate by supporting various charitable and philanthropic activities in arts, education, human services and encouraging our employees to donate their time, talent and treasure to these same institutions .

• Encouragingouremployeestobeengagedcitizensandtofulfillthecivic duties of the nations and communities in which they live . In this regard, employees are advised to consult with the PPG’s Government Affairs Department before engaging in any lobbying activity in the name of PPG or if they have any questions on participating in civic or electoral activities .

We expect our name - PPG - to be synonymous with responsible and ethical corporate citizenship . And we ask each of our employees to embrace the challenges and opportunities presented by our ever-changing world and make a positive and sustainable difference in their daily work .

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■■ Product Safety

PPG will ensure that our products can be developed, produced, distributed, used and disposed of in a safe and environmentally sound manner. We will train, equip and support employees, as appropriate, in the management of environmental, health and safety activities and advise customers on the safe use and handling of our products. No PPG employee shall authorize the shipment of a product known to be improperly labeled, defective, unsafe or unsuited for its intended purpose.

Ensuring the safe use of our products and minimizing the risk of product-related injury to our customers or the environment are critical to PPG’s welfare . We conduct product tests required by law and additional testing beyond what is legally required when we believe such testing is appropriate to help us understand the EHS implications of our products . In the case of products that carry potential risks of injury during shipping, handling and use, clear and relevant safety information is provided with the product . We are committed to protecting our customers, our company, the general public and the environment .

Contact your business unit or corporate Product Stewardship representative for further guidance regarding this Policy.

■■ Stewardship of the Environment

PPG will design, build and operate our facilities in ways that respect public health and the environment, conserve energy, water and raw materials, integrate pollution prevention and make a positive contribution to the surrounding community and to society as a whole.

Environmental compliance with government regulations is the responsibility of each PPG business unit and all employees within that business . Recognizing the differences in governmental regulations at the national, provincial, state and local level is critical to environmental compliance . PPG is committed to complying with these laws and regulations throughout the world .

Contact your business unit or corporate EH&S representative for further guidance regarding this Policy.

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PPG AS A GLOBAL ORGANIZATION

PPG has maintained operations outside of the United States for most of its history . The magnitude of our overseas activities has increased in recent years .

That growth has reflected the worldwide diffusion of technology and the global expansion of product markets . As a supplier to industries that are increasingly global in scope, PPG is committed to extending its own manufacturing operations to wherever the markets for its products can justify the investment . That pattern has resulted in an organization with people drawn from many different cultures and with operations in countries having substantially different social, cultural and legal systems . Accordingly, the standards of business conduct appropriate to PPG people reflect those of an increasingly global organization . As our company moves further from its roots as a predominantly North American firm toward greater global operations, our relationships to the many jurisdictions in which we operate differ in important ways . Moreover, the composition of our work force in each country also varies significantly . Nevertheless, it is useful to think of PPG as a guest in each host country, and employees must govern their conduct accordingly .

■■ Trade Compliance

PPG’s ability to export its products, services, technology and technical data around the globe is a privilege that must be carefully safeguarded. We require our employees to understand and abide by all applicable export laws and regulations and to maintain and adhere to PPG’s internal procedures and processes that govern our compliance with applicable export controls. Similarly, PPG requires compliance by its employees with all trade and customs restrictions, laws and regulations, in addition to PPG’s internal requirements, relating to the import of materials and services around the world.

Our global export management and compliance program consists of a number of toolsandresourcesthataffirmthecommitmentofPPGmanagementtothiscriticalissue, provide practical guidance and training, and require recordkeeping and monitoring to help foster and achieve export control compliance . PPG’s Global Export ControlPolicyandU.S.ExportControlManual,aswellasthespecificproceduresofyour business or function, provide essential information and extensive guidance for every employee whose work affects or supports our export business . PPG recognizes that, depending upon the transaction, export control laws and regulations in various countrieswherePPGoperatesmayseemtoconflict,butitisimperativethatwhereU.S.laws and regulations apply that they be followed . We strongly encourage employees to contact their regional or business unit export personnel or lawyer to resolve any concerns .

The import of materials and services presents potential compliance issues related to security,valuation,classificationandrecordkeeping,amongothersubjects.Numerousfunctions are involved in PPG’s importing process, from the time an order is placed until payment is made for received goods . All employees involved in import transactions must make every effort to fully understand their legal and internal obligations and properly coordinate their work to facilitate PPG’s compliance with import and customs requirements .

For export control questions regarding this Policy, contact PPG’s Chief Compliance Officer, PPG’s Manager, Export Compliance, or your regional or business unit export compliance coordinator or lawyer for further guidance. For import and customs questions regarding this Policy, contact PPG’s Team Lead for Import Services (U.S. only) or your regional or business unit lawyer for further guidance.

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■■ Respecting Local Law and Customs

PPG will obey the law wherever we operate. We regard observing local law to be the minimum acceptable level of conduct. In addition, PPG’s own standards of conduct frequently oblige us to go beyond the legal minimum of a locality and to conduct our affairs according to the higher standard.

In the conduct of our business, we endeavor to respect local customs and institutions . However, we must not use local custom as an excuse for violating applicable laws or corporate policies . We also recognizethatlawswilldiffer,andsometimesconflict,fromoneplacetoanother.Andwerecognize,too, that we may not always accept the underlying philosophy or consider the practical consequences of a particular law to be desirable . Nevertheless, we must always obey the local laws of host countries in which we are guests .


YOUR PERSONAL COMMITMENT

PPG’s reputation as an ethical and trustworthy company is in your hands every day . How you serve customers, manage employees and treat suppliers will determine how we are viewed in the

community and whether the good name PPG has earned since our founding in 1883 will live on . Your personal commitment to the principles and values outlined in this document is the single most important tool we have in ensuring PPG’s continued reputation as a valued business partner . We are confident that you will take this commitment seriously and that your words and deeds will continue to ensure and enhance PPG’s outstanding ethical tradition .

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Argentina (ALA Spanish) 0-800-288-5288 1-800-742-9687

Argentina (Telecom) 0-800-555-4288 1-800-742-9687

Argentina (Telefonica) 0-800-222-1288 1-800-742-9687

Australia 1-800-28-5922

Austria 0-800-200-288 1-800-742-9687

Belgium 0800-7-6258

Brazil (option 1) 0-800-890-0288 1-800-742-9687

Brazil (option 2) 0-800-888-8288 1-800-742-9687

Canada 1-800-742-9687

Chile (AT&T Chile) 171-00-311 1-800-742-9687

Chile (AT&T Chile Spanish) 171-00-312 1-800-742-9687

Chile (AT&T Node) 800-225-288 1-800-742-9687

Chile (Easter Island) 800-800-311 1-800-742-9687

Chile (Easter Island Spanish)

800-800-312 1-800-742-9687

Chile (ENTEL) 800-360-311 1-800-742-9687

Chile (ENTEL Spanish) 800-360-312 1-800-742-9687

Chile (Telefonica) 800-800-288 1-800-742-9687

China Telecom South 10-800-110-0852

China Netcom Group 10-800-711-0925

Colombia (English Speaking)

01-800-911-0010 1-800-742-9687

Colombia (Spanish Speaking)

01-800-911-0011 1-800-742-9687

Cote d'Ivoire (English speaking operator)

00-111-11 1-800-742-9687

Cote d'Ivoire (French speaking operator)

00-111-12 1-800-742-9687

Czech Republic 800-143-470

Denmark 80-881255

Egypt (Cairo) 2510-0200 1-800-742-9687

Egypt (Outside Cairo) 02-2510-0200 1-800-742-9687

France (General Counsel Europe)

41-21-822-3011

Germany 0800-182-8013

Greece 00-800-11-002-3725

Hong Kong 800-93-3456

Hungary 06-800-17-086

India 000-117 1-800-742-9687

Indonesia 001-803-1-002-3725

Ireland (Ireland) 1-800-550-000 1-800-742-9687

Ireland (UIFN) 00-800-222-55288 1-800-742-9687

Italy 800-789334

Japan KDD 00531-11-3903

Japan (Cable & Wireless IDC) 0066-33-830201

Japan NTT 0034-800-900290

Korea, Republic of 00798-1-1-002-3725

Malaysia 1-800-81-4617

Mexico 1-800-742-9687

Netherlands 0800-022-5885

New Zealand 0800-451458

North America 1-800-742-9687

Philippines 1-800-1-111-0350

Poland 0-0-800-111-1827

Portugal 800-8-11180

Romania 021-800-4288 1-800-742-9687

Russia (Russia) 8^10-800-110-1011* 1-800-742-9687

Russia (option 2) 8^10-800-120-1011* 1-800-742-9687

Russia (Moscow) 755-5042 1-800-742-9687

Saudia Arabia 1-800-10 1-800-742-9687

Senegal (English speaking operator)

800-103-072 1-800-742-9687

Senegal (French speaking operator)

800-103-073 1-800-742-9687

Singapore 800-110-1717

Slovakia 0-800-000-101 1-800-742-9687

South Africa 0800-982-058

Spain 900-98-1003

Suriname 156 1-800-742-9687

Sweden 020-797769

Switzerland 0800-89-0137

Taiwan 00801-10-4237

Thailand 001-800-11-002-3725

Turkey 0811-288-0001 1-800-742-9687

Ukraine 8^100-11* 1-800-742-9687

U.A.E. (U.A.E.) 0-800-121 1-800-742-9687

U.A.E. (alternate) 0-800-161 1-800-742-9687

United Kingdom 0808-234-2927

United States 1-800-742-9687

Uruguay 000-410 1-800-742-9687

Vietnam 1-201-0288 1-800-742-9687

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* ^ means wait for tone before proceeding.

ETHICS HOTLINE

PPG IndustriesOne PPG PlacePittsburgh, PA 15272 USA(412) 434-3131www.ppg.com

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Leadership Through Integrity - PPG Industriescpppgdev.ppg.com/getmedia/fec9cae1-8f75-42f0-82ca-e3cfbbf6b060/... · Leadership Through Integrity ... • To consider appropriate responses