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ABD00004477 CORPORATE HANDBOOK The Company's Vision, Mission, and Guiding Principles, Code of Conduct, and General Policies of the Corporation This Handbook is for the sole use of Georgia Gulf managers and employees Contact the H R Department with any questions about the handbook June 1998 ABD00004478 INTRODUCTION AND PURPOSE The purpose of the Corporate Handbook is to set forth the general policy of the company as a guide to employees, supervisors and managers to assure that these policies are known and uniformly maintained throughout the organization These policies replace or supersede any previously published policy statements on these topics The policies contained herein apply to all employees of the company except the union employees at the Tiptonville location The Handbook is divided into three sections as follows SECTION ONE - Statement of the company's vision, mission, guiding pnnciples, and core aims SECTION TWO - The Code of Conduct and related policies SECTION THREE - General policies Questions regarding specific policies should be referred to the contact person if one is listed in the body of the policy in question Other questions should be directed to the Corporate Human Resources Department in Atlanta EMPLOYEE DUTY TO COOPERATE A key element to each of the policies and procedures used by the company is the duty of management to carry out their responsibilities as managers and the duty of all employees to comply with the rules and cooperate in the company's business operation This cooperation extends to all areas of the company's activities including, but not limited to, internal investigations, environmental, health and safety practices, operating efficiency, etc As an example, if the company were to investigate some incident of employee misconduct, every employee contacted in that investigation has a responsibility to cooperate in the successful completion of the investigation In fact, employees have an obligation to report misconduct they observe without waiting to be asked DISCLAIMER The contents of this manual summarize current policies and may be amended by the company at any time THE CONTENTS OF THIS MANUAL DO NOT CONSTITUTE THE TERMS OF A CONTRACT OF EMPLOYMENT AND SHOULD NOT BE CONSTRUED AS A GUARANTEE OF CONTINUED EMPLOYMENT WITH THE COMPANY EMPLOYMENT WITH THE COMPANY IS ON AN AT WILL BASIS. This means that the employment relationship may be terminated at any time by the company or the employee for any reason not expressly prohibited by law Any oral or written statement to the contrary made by anyone other than the President of the company is invalid ABOUT THIS DOCUMENT The Handbook is in WordPerfect, font type is Arial Font size is 10 point for text and 16 point for headings ABD00004479 CONTENTS SECTION ONE (Blue Pages) Company Vision, Mission, Guiding Principles and Core Aims SECTION TWO (Green Pages) Code of Conduct Introduction & Letter from the President Equal Employment Opportunity Drug And Alcohol Policy Government Affairs Business Ethics Antitrust Environmental Policy Health & Safety Insider Trading Policy Responsible Care SECTION THREE (White Pages) PAGE Absences Alcohol Antitrust Automobile (Use of personal auto for business) Benefits Bulletin Boards Business Entertainment Business Ethics Car Rental Computer Systems Computer Hardware and Software Computer Viruses Confidential Business Information Copyrights Credit Card - Company Credit References Disability Leave Drugs And Alcohol Educational Assistance 1 See "Drugs and Alcohol" See "Code of Conduct" See "Expenses" See "Salary & Benefits" See "Solicitations" See "Expenses" See "Code of Conduct" See "Expenses" 4 See "Computer Systems" See "Computer Systems" See "Information & Inventions" See "Trademarks & Copyrights" See "Expenses" See "References" See "Absences" 5 See "Training & Development" ABD00004480 Electronic Mail Employment References Employment of Relatives Employment Testing Equal Employment Environmental Policy Expenses Fraternization of Employees Funeral Leave Garnishments Government Affairs Health And Safety Holidays Information and Inventions - Confidential Insider Trading Internet Usage Investor Relations Jury Duty Leave of Absence Legal Service Media Relations Military Leave Pay Increases - Approvals Plant Tours Pre-Employment Physical Exam Privacy - Employee Record Retention References Relatives - Employment Relocation Responsible Care Salary & Benefits Service Awards Sexual Harassment Shareholder Relations Sick Leave Solicitations Terminations Trademarks & Copyrights Trade Secrets Training & Development Travel Expenses PAGE 6 See ``References'' See "Relatives - Employment" 7 8 See "Code of Conduct" 9 See "Equal Employment" See "Absences" 11 See "Code of Conduct" See "Code of Conduct" 12 13 See "Code of Conduct" 14 15 See "Absences" See "Absences" 16 17 See "Absences" See "Salary & Benefits" See "Visitors & Plant Tours" See "Employment Testing" 19 20 21 22 23 See "Code of Conduct" 24 25 See "Equal Employment" See "Investor Relations" See "Absences" 26 27 30 See "Information & Inventions" 31 See "Expenses" ABD00004481 PAGE Unsolicited Suggestions - Products or Processes See "Information & Inventions" Vacations & Holidays 33 Violence in the Workplace 35 Visitors & Plant Tours 36 Voice Mail 37 aaintro5/14/98 ABD00004482 pi_As Comm y /?7 u<t *o Very low Capital Engineering Projects - 3rd and 4th quarter 2001 <s>JRH Work off Resin Alarm List f0/\ AC^ <$> Work off Compound Alarm list SRO , *'0 <> <s> Manual Task Automation NM Hazop Action list <> PSM Audit List 10/1 izm/i to 11 /o/l i \zstt > ES 3^ ,:CS <5> Organize and Relief Valve Calculation files <S> Basic Engineering Design Data Specifications Develop a Scrap Materials list and sell off scrap Clean Up DMS Evaluate options for reactor hydroblasting //1 /oi 1 III <D <S> Air System RCM i 11 Organize back hall files Uttility Usage Survey - energy balance steam, water , air, elect /d/I A 6 <L <5? Train on In Tools, Hazcp, etc - - /o/l iz/1 Bench mark engineering effort <3> VCM unloading area maintenance and pm system optimization :Bra> < ! SL CD ,et5 51 ft |tr(A VCM unloading rack S/D system Professional Training - Engineering etc Boiler Controls project - ( DASA Controls />/1 //1 /z/< /z/l /o/1 1 is1'AcvaJ 1 TCm Evaluate New Technologies <S> Document SA module Co <S) Start SPC /o/1 zz/1 g#Q (^} Overall Equipment Effectiveness parameter development (OEE) |Z/| i Visual Basic Applications f1 f Northwest Analyst i 1 r Joe t 1 (rein I L N4 %oci o(*ca. Pw . f/ fjrbiA (ft) - <?Acdr '( j?A/C f/oC&'y ABD00004483 SECTION ONE VISION, MISSION, GUIDING PRINCIPLES AND CORE AIMS VISION The vision for Georgia Gulf is to be a company that provides increasing value to shareholders MISSION Georgia Gulf will continue to be an efficient, integrated manufacturer and marketer of quality chemical and plastic products to users worldwide and will grow responsibly in present and closely related businesses We are dedicated to continuous improvement of the processes, products and services required to meet our customers' changing needs We will strive to earn a supenor long-term return for our shareholders while providing meaningful work for our employees and always operating with the highest regard for environmental protection, safety and the overall well-being of the communities in which we operate GUIDING PRINCIPLES All applicable laws and regulations will be adhered to with special emphasis on meeting or exceeding environmental and safety standards Relationships with customers, stockholders, employees, suppliers and the communities in which we operate will be conducted in a fair, open and ethical manner Never ending process improvement will be practiced in order to provide quality products and services which meet the needs of our customers Equal opportunity for advancement will be provided to all employees in an atmosphere of open ABD00004484 communication, trust, respect and support Competitive compensation and benefits, including incentive and equity programs based upon company profitability and long-term growth, recognizing both team work and individual achievement, will be offered to all employees CORE AIMS Complying with Environmental. Safety and Regulatory Responsibilities To operate our business in a safe and environmentally sound manner by improving safety and environmental performance with special emphasis on the Responsible Care initiative, and by always conducting our business in compliance with legal and regulatory requirements Optimizing Businesses Sell to and grow with customers in the most profitable long-term markets Creating a Positive Environment for Employees To create and maintain a positive environment for our employees in which they are treated with respect, provided competitive compensation and benefit programs, training, advancement opportunity and the potential to share in the company's success Optimizing Resources To maximize utilization of all resources through continuous improvement to remain a low cost provider Improving Financial Performance To pursue a strategy of responsible growth, stock repurchases and dividends that balances both long and short term return to shareholders handbookWision 1/21/98 ABD00004485 GEORGIA GULPS CODE OF CONDUCT CONTENTS General Policy Letter from the President Policies Equal Employment Opportunity Drug And Alcohol Policy Government Affairs Business Ethics Antitrust Environmental Policy Health And Safety Insider Trading Policy Responsible Care Workplace Violence Prevention Page 1 2 3 3 4 5 6 6 7 8 9 10 GENERAL POLICY Georgia Gulfs Guiding Principles, developed with our Vision, Mission and Core Aims, set out high standards for us to follow in conducting our business A written Code of Conduct has been developed to emphasize our commitment to complying with these standards and to provide guidance in certain important areas All employees should have a copy of the Code of Conduct The Code of Conduct provides policies that give direction in broad areas of daily business activity where possible problems or conflicts could occur Some policies such as the EEO standard apply to all employees Certain standards, such as antitrust compliance, involve only some employees Policies of particular importance to those with sales responsibilities are included in this Sales Manual as well as the Code of Conduct Georgia Gulf will not tolerate violations of these policies If you become aware of a possible violation, you should bnng the matter to the attention of appropriate people in the company Corporate personnel, such as members of the Law Department or the Human Resources Department could be contacted An appropriate person could also be a supervisor, someone in the controller's department, a member of the Environmental, Safety & Health Department, or a department manager We have also established a Corporate Compliance Officer, John Hager of the Human Resources Department in Atlanta, who has responsibility to monitor the operation of our Code of Conduct He can be reached at (770) 395-4511 If you are not comfortable discussing the matter internally, or receive an unsatisfactory response when you discuss the matter with the appropnate people, you should use the Georgia Gulf anonymous hotline which can be reached at 1-800-93-ALERT All reports will be investigated 1- - ABD00004486 LETTER FROM THE PRESIDENT Dear Georgia Gulf Employee Our Guiding Pnnciples, developed with our Vision, Mission and Core Aims, set out high standards for us to follow in conducting our business The enclosed Code of Conduct has been developed to emphasize our commitment to complying with these standards and to provide guidance in certain important areas Our policies give direction in areas of daily business activity where possible problems or conflicts could occur Some policies such as the EEO standard apply to all employees Certain standards, such as antitrust compliance, involve only some employees Some policies involve ethical issues directly and state what conduct is acceptable or unacceptable Other standards involve safeguards put in place to avoid either the fact or appearance of misconduct Of course, no Code of Conduct can anticipate and address every situation We have highlighted major areas of concern and have attempted to provide guidance In many cases, common sense and good judgment will be your best guides We will not tolerate violations of these policies If you become aware of a possible violation, you should bnng the matter to the attention of appropnate people in the company Corporate personnel, such as members of the Law Department or the Human Resources Department could be contacted An appropriate person could also be a supervisor, someone in the controller's department, a member of the Environmental, Safety & Health Department, or a department manager We have also established a Corporate Compliance Officer, John Hager of the Human Resources Department in Atlanta, who has responsibility to monitor the operation of our Code of Conduct He can be reached at (770) 395-4511 If you are not comfortable discussing the matter internally, or receive an unsatisfactory response when you discuss the matter with the appropnate people, you should use the Georgia Gulf anonymous hotline which can be reached at 1-800-93-ALERT All reports will be investigated With all this help available, there is no excuse for remaining silent if you believe our policies are not being followed Please read this Code of Conduct carefully and make it a part of the way you conduct business at Georgia Gulf Sincerely, EA Schmitt President and Chief Executive Officer 2- - ABD00004487 EQUAL EMPLOYMENT OPPORTUNITIES It is Georgia Gulf Corporation's policy to employ and to advance the best qualified people available based on individual merit and to ensure equal opportunity in employment to every employee regardless of race, color, religion, sex, national ongm, age, marital status, disability, veteran status or sexual onentation Georgia Gulf Corporation will continue to develop and implement all necessary policies to create and maintain an equal opportunity climate within the Company Explanation This policy applies not only to hmng practices, but to all aspects of the employment relationship including promotions, salary increases, work assignments and terminations It also prohibits sexual harassment It is the continued policy of Georgia Gulf to promote an atmosphere free of sexual harassment, in any form, at all levels of employment This includes but is not limited to unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature Such actions or conduct are viewed as creating an intimidating, harmful and offensive work environment and may subject persons who engage in such conduct or behavior to discipline up to and including discharge The Employment Policy posters which are placed in each location include the name of a company representative designated by division or local management who will hear complaints or you may contact the Corporate Personnel Manager directly We expect all employees to comply fully with this policy and will not tolerate noncompliance It is extremely important that all of us take our responsibilities seriously for ensuring equal opportunity We must have the best qualified personnel and we must provide everyone equal opportunity and treatment By carrying out these responsibilities, you will help keep Georgia Gulf an excellent company and enable us to meet our moral and legal obligations For questions, contact your local Human Resources Representative or Human Resources in Atlanta DRUG AND ALCOHOL POLICY Georgia Gulf Corporation maintains and is committed to a drug-free workplace Unlawfully using drugs, or possessing, providing, buying, selling, or using controlled substances during working time or on company premises is prohibited Being under the influence of alcoholic beverages or unlawfully using drugs or substances when working or at other times so as to adversely affect the company's reputation is prohibited Explanation Georgia Gulf Corporation is very concerned about drug abuse and its effects on safety, job performance, the work environment and the public's confidence in our company Employees who possess, buy, sell or use an unauthorized drug or controlled substance during working hours and/or while on Georgia Gulf property will be terminated Georgia Gulf property includes company vehicles regardless of where they may be Employees must report to work in a condition fit for duty "Fit for duty" means that an employee has not used an unauthonzed drug or controlled substance under such circumstances that there is a detectable amount 3- - ABD00004488 in an employee's system Georgia Gulf will conduct tests to determine whether employees have used an unauthorized drug or controlled substance These tests will be conducted at the discretion of the company and may include, but will not be limited to A Pre-employment Testing B Location-wide Testing C Random Testing D Testing in response to accidents or other unusual behavior Any employee who refuses to take a drug test will be terminated If upon testing it is revealed that an employee has a detectable level of an unauthorized drug or controlled substance in his or her system, that employee will be subject to disciplinary action including termination Drug abuse is recognized as a "disorder" and the company has provided an employee assistance program (EAP) as a means through which an employee can obtain help It is the employee's responsibility to seek that help We are committed to operating our business with the highest regard for our employee's safety and the overall well-being of the communities in which we operate For questions, contact your local Human Resources Representative or Human Resources in Atlanta GOVERNMENT AFFAIRS Communications All employees should be certain that statements, written or oral, to members of Congress, state and local officials or federal, state and local agencies on behalf of the company or on company letterhead are consistent with company policies and positions All contacts with the federal government m Washington, D C should be coordinated with the Law Department Political Contributions In connection with federal elections, the company is prohibited from making contributions directly or indirectly to political candidates or parties The use of company equipment, services and facilities is also prohibited However, occasional individual employee volunteer political activity using company facilities, equipment and employee's time is not a violation of the law In such cases, the employee must reimburse the corporation in a timely manner for costs incurred and employee time lost Strict guidelines are applied to telephone usage, copy machines and vehicles For this reason, management clearance for such activity is required Guidance on the laws and regulations is available from the Law Department For questions, contact the Law Department in Atlanta 4- - ABD00004489 BUSINESS ETHICS Georgia Gulf Corporation is proud of its high standards of honesty and integrity in the conduct of its business affairs The overriding principle is that both as a business and as individual employees, we should obey all laws and we should conduct ourselves ethically and in the best interest of the Company and its shareholders Conflict of Interest All employees of the company must avoid persona! situations which might be construed as conflicts of interest, i e , any personal interest outside of the company which could make it advantageous for the officer or employee to place such personal interest above his or her obligation to Georgia Gulf One such obligation is to first make available to the company any business opportunity which is related to any business activity of the company No employee of the company should have any position with, or substantial interest in, any business enterprise operated for a profit, the existence of which would conflict or might reasonably be supposed to conflict with the proper performance of company duties or responsibilities, or which might tend to affect independence of judgment with respect to transactions between the company and such other business enterprise Sensitive Payments It is the firm policy of Georgia Gulf to forbid the making of an illegal payment or contribution of any nature All payments shall be for legitimate services lawfully rendered or for goods, benefits, or rights lawfully acquired This policy shall be strictly adhered to without deviation or exception Authorized Transactions and Accurate Accounting Expenditures of company funds and use of company property should be made only as properly authonzed The company requires accurate and complete accounting in compliance with accepted accounting rules and controls All expenditures and payments should be properly recorded and documented Employees who suspect fraud have a responsibility to report it immediately Bribery and Kickbacks The company does not permit or condone bribes, kickbacks or any other illegal or improper payments You should not solicit, accept or give any money or anything else of value for the purpose of obtaining or bestowing business or preferential treatment Business Entertainment and Gifts You should not provide or accept business entertainment or gifts that exceed the bounds of good taste or reasonable business standards and should never solicit such entertainment or gifts No cash or cash equivalents, such as gift certificates, should be accepted These policies apply to all employees Any officer or employee having information or knowledge of any prohibited act or practice shall promptly report such matter to the General Counsel For questions, contact the Law Department in Atlanta 5- - ABD00004490 ANTITRUST It is the policy of Georgia Gulf Corporator! to comply with the antitrust laws of the United States It is also our policy to comply with the law of many other countries and areas of the world which regulate competitive behavior Explanation Antitrust laws, and other laws regulating competitive behavior are aimed at invalidating conduct and arrangements which distort competition In the United States, the prohibited anticompetitive conduct includes agreements with competitors regarding pnce fixing, boycotts and market allocation as well as actions that do not involve a competitor such as price discrimination, predatory pricing, fixing a re-seller's or downstream manufacturer's prices and tie in sales In other countries, the prohibited conduct may differ from that in the United States so it is important for employees, particularly in sales and marketing positions, to consult with the Law Department when issues of concern are raised The antitrust laws have severe criminal and civil consequences for both Georgia Gulf and individuals Due to these consequences, Georgia Gulf has established procedures for avoiding conduct which may raise the appearance of unlawful conduct Compete vigorously and independently at all times and in every ethical way, and indicate to all that you are competing vigorously Avoid not only any kind of agreement, understanding, or arrangement, whether formal or informal, but the appearance of the same with representatives of competitors Do not discuss prices (including terms) or divide customers, markets or territories with competitors Always treat customers honestly, equitably and in a manner that respects their independence Never agree upon or attempt to control a customer's resale price or resale activity, avoid any discussion of customer selection or dealings with any other customer Offer to all competing customers on a proportionally equal basis any services, assistance, discounts, or refunds offered or made to any one customer Do not require a customer to buy a product only from you and do not use one product as bait to sell another Similarly, do not make sales or purchases conditional on reciprocal purchases or sales Lastly, avoid any activity which could be characterized as unfair or deceptive, and always adhere to the principles of honesty, frankness, and forthrightness in the sale of our products These guidelines and policies are not meant to be exhaustive, only an overview of the policies are contained herein For further information or questions regarding antitrust concerns, please contact the Law Department in Atlanta ENVIRONMENTAL POLICY It is the policy of Georgia Gulf Corporation to operate and maintain our facilities in compliance with all applicable local, state and federal laws governing environmental protection All Georgia Gulf operations shall be managed in a manner that protects the environment, employees, neighbors, and equipment in the surrounding communities Explanation Environmental laws, such as the Clean Air Act, the Clean Water Act, and the Toxic Substances Control Act, as well as many local and state rules and regulations, apply to Georgia Gulfs facilities These laws govern 6- - ABD00004491 the proper management of hazardous wastes, regulate releases of materials to the environment, establish clean-up requirements to address the releases of hazardous substances, and regulate the manufacture of chemical substances Frequently, environmental laws have prompt reporting and recordkeeping requirements Georgia Gulf has established procedures for the reporting of releases and any adverse reactions caused by the manufacturing process, as well as strict recordkeeping procedures Failure to comply with environmental laws can have serious consequences to Georgia Gulf as well as to individuals The General Manager of each location is primarily responsible for the development and implementation of environmental policies and procedures However, all employees have a responsibility to comply with corporate environmental policies and to provide complete and accurate information in response to environmental regulations and permits Each facility has been assigned an individual or individuals to help assure the environmental compliance of that location This person is informed of information and concerns relating to the handling, use, and disposal of all materials, including changes in the use or management of the plant's raw materials, products, intermediates, and wastes Georgia Gulf has the following departments to further assist any employee or customer on issues regarding its environmental policy Engineering Department - each location Environmental Department - each location Safety & Health - Plaquemine, Louisiana Law Department - Atlanta, Georgia It is our goal to reduce both the amount of waste and the amount of releases to the environment at every Georgia Gulf facility Our success in achieving this goal depends upon each employee integrating environmental concerns into the overall planning and execution efforts of our business For questions, contact your local Environmental, Health & Safety Department HEALTH AND SAFETY It is the policy of Georgia Gulf Corporation to require that every job be performed in such a manner as to assure the primary importance of accident-prevention, to comply with accepted industry standards, and to meet or exceed all applicable local, state and federal safety requirements Explanation Safety and health laws, such as the Occupational Safety & Health Act, regulate the safe use and management of hazardous matenals, including raw materials, intermediates, products and wastes, the proper communication relating to those materials, and workplace and transportation safety practices These laws often impose strict recordkeeping requirements Failure to comply with safety and health laws may result in very serious consequences to Georgia Gulf, as well as to individuals Managers and supervisors will be held accountable for the results of their efforts in identifying and correcting unsafe acts and conditions and for promoting safety awareness among their employees Employee performance will be evaluated on the basis of the results of individual efforts to incorporate safety into the preparation and execution of each job We must devote our time and energies to 7- - ABD00004492 the day-to-day prevention of unsafe acts and conditions to protect against accidents Our success in preventing accidents will depend upon all employees integrating safety into the overall planning and execution effort Although a conscious effort is required from each employee to provide continuous improvement of our safety performance, each plant has been assigned an individual or individuals who will help assure the safety and health compliance of that plant This person answers questions and assists the plant in making required reports on a timely basis Georgia Gulf has the following departments to further assist any employee or customer on issues involving safety and health Health and Safety Department - Plaquemine, Louisiana Environmental Department - Plaquemine, Louisiana Law Department - Atlanta, Georgia INSIDER TRADING POLICY Georgia Gulf employees shall not use material inside information for the purpose of buying or selling Georgia Gulf common stock, options on Georgia Gulf stock, or other Georgia Gulf securities, or for the purpose of buying or selling the securities of other companies with which Georgia Gulf has a business relationship Likewise, Georgia Gulf employees shall not disclose such information to third parties who might use it to trade in these securities, and shall not recommend the purchase or sale of any of these securities based on such information In light of the detailed restrictions and reporting requirements regulating trading by Georgia Gulf directors and officers, directors and officers are required to confer with the Vice President, General Counsel and Secretary (or other legal counsel in appropriate cases) before engaging in any transactions in the company's securities or options Explanation United States securities laws, as well as the securities laws of many states and foreign jurisdictions, prohibit insiders, as well as people who obtain information from insiders, from benefiting from "material inside information" by trading in securities The purpose of this prohibition is to prevent insiders from benefiting from their superior knowledge of non-public information at the expense of people who do not possess this information "Insider information" is any information regarding a company which has not been generally disclosed to the public Inside information is "material" if a reasonable investor is likely to consider it important in deciding whether to buy or sell the company's securities Examples of significant events that might be considered "material" include significant changes in current or anticipated earnings, changes in dividends, a stock repurchase program, proposed major acquisitions or dispositions, a major contract such as a joint venture, a proposed stock offering, 8- - ABD00004493 substantial purchases, sales or write-offs of assets, and major developments in litigation An employee who possesses material inside information regarding Georgia Gulf or another company, must refrain from buying or selling its securities until the information is publicly disclosed (such as through a press release or quarterly report) and a period of time (usually at least one trading day) has passed for the markets to learn of, and assess, the information These prohibitions apply both to Georgia Gulf securities and to the securities of any other company where Georgia Gulf employees obtain material inside information through their Georgia Gulf employment If, for example, a Georgia Gulf employee were to learn that Georgia Gulf was planning to acquire a particular company, the employee would be prohibited from trading in the other company's securities until after the information becomes public The prohibitions described above do not prohibit you from exercising Georgia Gulf employee stock options, but could require you to wait until the information becomes public before you can sell the stock acquired on the exercise of the option If you have any questions regarding this policy, contact the Law Department in Atlanta RESPONSIBLE CARE It is the policy of Georgia Gulf Corporation to comply with the Responsible Care Program of the Chemical Manufacturers Association All Georgia Gulf operations shall be managed in a manner that assures adherence to the Guiding Principles of Responsible Care as listed below To recognize and respond to community concerns about chemicals and our operations To develop and produce chemicals that can be manufactured, transported, used and disposed of safely To make health, safety and environmental considerations a priority in our planning for all existing and new products and processes To report promptly to officials, employees, customers and the public, information on chemical-related healthy or environmental hazards and to recommend protective measures To counsel customers on the safe use, transportation and disposal of chemical products To operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public To extend knowledge by conducting or supporting research on the health, safety and environmental effects of our products, processes and waste materials To work with others to resolve problems created by past handling and disposal of hazardous substances 9- - ABD00004494 To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment To promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals Georgia Gulf has the following departments to further assist any employee or customer on issues involving safety and health Health and Safety Department - Plaquemine, Louisiana Environmental Department - Plaquemine, Louisiana Law Department - Atlanta, Georgia WORKPLACE VIOLENCE PREVENTION It is Georgia Gulf Corporation's intent to provide a safe, secure workplace for all individuals while on our property or during the conduct of business With this in mind, any act of a violent nature or any threat of violence occurring at any time on Company property is expressly prohibited For the purpose of this policy, workplace violence is defined as, but is not limited to, threats or actions which result in the use of power or force, gestures which may be interpreted as intimidating or belligerent, and/or intimidating or belligerent verbal comments This prohibition extends to any individual who is on company property including but not limited to employees, contractors and visitors This policy is also in effect while on Company business or at Company sponsored events All employees are required to immediately report to their supervisor any violent acts or threats of violence tn the workplace All reports of threats of violence or actual violence will be promptly and thoroughly investigated WEAPONS Weapons, including hand guns, are strictly prohibited from any and all work areas This policy is also in effect while on Company business or at Company sponsored events A weapon is considered to be any object that could be used to harass, intimidate, or injure another individual, as well as any item deemed to be a weapon by management or security department personnel Employees are required to report any potential violations of this policy to their supervisor immediately Any employee found responsible for a violent incident, the threat of violence, or found in violation of the Company's Weapons Policy, will be subject to disciplinary action, up to and including termination of employment Code 5/14/98 -10- ABD00004495 ABSENCES EFFECT OF ABSENCES ON PAY & BENEFITS Whether an absence is paid or unpaid, time absent will not be counted as time worked for purposes of overtime premium pay Periods during which the employee is on leave of absence shall not be included in the computation of employee vesting service for the Georgia Gulf Salaried Employees Retirement Plan, nor for any other employment benefits based on length of service (i e vacation, service awards or other benefits to which salaried employees are otherwise entitled) Health coverage may be continued but the employee must pay a premium Other benefits that require a contribution may be suspended or terminated The employee should check in advance with their Human Resources Department to learn the possible effect of the leave on all employee's benefits ABSENCES-PAID The following policies apply to salaried employee absences from work and will be administered by local management in an impartial and prudent manner and without discrimination because of race, color religion, national origin, sex, age, handicap, or disabling condition SHORT-TERM ILLNESSES & INJURIES A supervisor may approve an employee's disability-related absence as a Paid Absence as long as the absence does not exceed five consecutive working days for non-shiftworkers or three consecutive scheduled working days for shift workers A physician's statement may be required Each employee has an obligation to perform the duties of their job on a regular basis Repetitive periods of short- term absence by an employee adversely affect productivity and, in certain cases, may result in disciplinary action NONOCCUPATIONAL DISABILITY - LEAVE OF ABSENCE AND SALARY CONTINUATION An employee's absence of more than five consecutive days (three days for shift workers) that is due to a nonoccupational disability, including pregnancy, may be approved for Salary Continuation if the following conditions are met 1 The employee has one year's continuous service with the Company, and 2 The employee has submitted a Leave of Absence Request Form including a licensed physician's statement certifying that the absence from work is medically required and stating the beginning date and predicted ending date of the absence The company, in deciding whether or not an employee's request for leave should be granted, may require that a physician appointed by Georgia Gulf examine the employee The company's decision is final The employee is required to notify his or her supervisor as soon as the employee becomes aware that a nonoccupational disability leave will be necessary by completing the appropriate Leave of Absence Request form with the Physician's statement attached 1 ABD00004496 The leave of absence may not exceed five months unless approved by the Director-Human Resources and the responsible officer In no circumstance will salary continuation exceed five months EFFECT ON SALARY AND BENEFITS Once the leave is granted, the Company will continue the employee's base salary or a portion thereof for the period of disability up to a maximum of five months (22 weeks) as follows Full Pay for the number of weeks that equals the number of full years of service and then half pay The employee's company-provided health coverage will be continued for the Salary Continuation period The Company may require the employee to periodically submit a recertification of the medical condition during the course of the leave to determine continued eligibility The recertification may be required to be made by a physician appointed by Georgia Gulf TEMPORARY REPLACEMENT AND RETURN TO WORK When the employee is capable to return to work, the employee must furnish the company with a licensed physician's statement that the employee is medically able to return to work as of a stated date The company will, within a reasonable time period, reinstate the employee in the same job if it still exists or any available job of like status and pay for which the employee is qualified without loss of continuous service credit Individuals hired to replace disabled employees who have been granted disability leaves should be considered as temporary employees and, as such, it is preferable to utilize contract personnel or temporary employment sources for replacement personnel OTHER PERSONAL PAID ABSENCE JOB RELATED DISABILITY When an employee sustains an injury or illness which arises out of and in the scope of employment, he or she is entitled to compensation and medical benefits as prescribed by the Workers' Compensation laws of the state in which he or she works Employees are required to immediately notify their supervisor in the event they are injured or become ill at work Compensation received under these laws may be supplemented by benefits under the provisions of the company's Salary Continuation and group insurance programs PERSONAL APPOINTMENTS - FAMILY EMERGENCIES Local management may grant personal time off with pay for employee medical, dental and legal appointments that cannot be arranged outside of regular working hours, and for the employee's responsibilities to immediate family members in connection with true emergencies Payment for such time away from work is contingent upon the employee's full disclosure of the circumstances and upon the employee's completion of the local probationary period, if any, for regular full-time employment with the company FUNERAL LEAVE Local management may grant personal time off with pay for an employee to attend the funeral of a family member For this purpose, spouse, child, stepchild, other minor child living with the employee, grandchild, brother and brother-in-law, sister and sister-in-law, mother and mother-in-law, father and father-in, grandparents and grandparents-in-law are considered family Other situations will be dealt with on a case by case basis The duration of the paid leave will depend on the location of the funeral Generally, one to two days of paid 2 ABD00004497 leave will be granted for a local funeral while two to four days of leave may be granted for a distant funeral Additional unpaid leave may be requested by the employee in conjunction with the paid funeral leave if needed to attend to other personal matters related to the loss of the relative JURY DUTY The Company will grant an employee paid time off for the days on which the employee is required to act as a witness or serve on a jury The employee may keep any pay received form the court for such service ABSENCES - UNPAID PERSONAL LEAVE OF ABSENCE It may be advantageous on occasion to grant an employee a personal leave of absence Such leaves cannot be for more than twelve months and will be without pay They may be granted when all of the following conditions are met 1 The employee submits a written request to the company at least four weeks (except in bona fide emergencies) before the leave is to start, giving the purpose and the starting and ending dates 2 The purpose and the duration of the leave are reasonable and not detrimental to the company's interests 3 Arrangements can be made without undue inconvenience, expense or unfairness to others to have the employee's work performed temporarily during the leave 4 The employee has completed one full year of continuous service When a leave is granted and taken in accordance with these conditions and the employee gives at least two weeks written notice of his or her ability and desire to return to work, the company will make every effort to place the employee in the same job if it still exists or in a job of like status and pay based upon available openings and the employee's qualifications However, the company cannot guarantee a job at the end of a personal leave, nor can we guarantee an equal job level or salary if a job is offered The Company may require the employee to submit to a medical examination by a physician appointed by Georgia Gulf or to provide the Company with a licensed physicians's statement that the employee is medically able to return to work Under this policy, disabled employees may be granted personal unpaid leaves of absence immediately before and/or after the physician's stated period of disability, provided the above conditions are met and the combined periods of leave do not exceed twelve months MILITARY LEAVE Upon receipt of a copy of orders calling an employee to serve in the U S armed forces, the Company will grant a military leave of absence without pay for the required period of time The employee will be entitled to all rights to employment provided by law absence 1/21/98 3 ABD00004498 COMPUTER SYSTEMS SECURITY AND INTEGRITY OF COMPUTER SYSTEMS Georgia Gulf has a policy which requires that information resources be secure from unauthorized access and destruction The computer systems of Georgia Gulf (servers, networks, personal computers and related software) exist for the use of its employees and agents in the proper and legal conduct of the business of Georgia Gulf Any abuse or misuse of these computer systems constitutes a theft of valuable resources from Georgia Gulf Each person who needs to utilize Georgia Gulfs computer systems in accomplishing his/her job tasks is assigned personal identification code(s) and password(s) (access code) Each person receiving access to Georgia Gulfs computer systems bears responsibility for all activities performed using his/her access code The Information Services Department initiates assignment of user access codes upon written authorization from management Each user (employee or agent) is responsible for the control of his/her password If a user believes his/her password is compromised for any reason, the user should immediately modify the password Under no circumstances should a user allow another person to use his/her password Under no circumstances should a user record, or include a password in a PC file, macro or other form, which might compromise the password Users should not leave a computer unattended while logged on If sensitive data exists on a personal computer, the user should take precautions which prevent unauthorized access of the data Each employee is responsible for ensuring that the data on his/her computer is backed up on a regular basis, with the schedule of back ups based on the effort that would be required to recreate the data Critical data should be stored off-site ACQUISITION OF COMPUTER HARDWARE AND SOFTWARE The Information Services Department has a standard list of computer hardware, software or software upgrades that are approved for use at Georgia Gulf Employees and agents of Georgia Gulf shall buy and/or install only hardware or software that is on the standard list or that has been specifically approved for use by the Information Services Department Georgia Gulf requires that employees follow software licensing rules Any misuse of software should be reported immediately to the Department Manager or the Information Services Department Employees who acquire or use unauthorized copies of computer software will be subject to discipline up to and including termination COMPUTER VIRUSES Care should be taken to prevent computer viruses Files downloaded from outside sources should be checked with approved virus detection software computer 1/21/98 4 ABD00004499 ELECTRONIC MAIL The Company provides electronic mail to employees (as approved by appropnate management) at Company expense for their use on Company business Following is the policy with regard to access to and disclosure of electronic mail messages sent or received by employees and the use of the electronic mail system 1 All messages created, sent and received through the electronic mail system are the property of the Company The Company has the right to access and monitor all messages and files, and employees should have no expectation of privacy when they use the Company electronic mail system 2 Although employees have individual access codes to computer systems including the electronic mail system, these systems are accessible at all times by the Company The Company has the right to access and disclose the contents of electronic mail messages as necessary The Company may use information regarding the number, sender, recipient, and addresses of messages sent over the electronic mail system for any proper business purpose 3 Harassment of any kind is prohibited No messages with derogatory or inflammatory remarks about an individual or group's race, religion, national origin, physical attributes, or sexual preference will be transmitted 4 Misuse of the electronic mail system by any employee, including electronic snooping and sending offensive messages, is a violation of company policy and may result in disciplinary action up to and including termination Electronic messages should be treated as mail, and should be returned to the sender if improperly addressed or incorrectly delivered 5 Electronic mail messages are confidential internal Company communications and must comply with the corporate record retention guidelines and other Company communication policies and procedures 6 Access to the Company electronic mail system by third parties must be approved by appropriate management including Information Services Any questions concerning this policy and the associated procedures should be directed to the Information Services Department in Baton Rouge email 1/21/98 6 ABD00004500 EMPLOYMENT TESTING PRE-EMPLOYMENT HEALTH SURVEY After accepting an offer of employment but before reporting to work, every prospective employee must take a Pre-Employment Health Survey This survey shall include a medical examination which conforms with corporate standards The results of the examination will be evaluated with consideration for the requirements of the job and any issues of safety to determine if the prospective employee is fit for duty and can be allowed to report PRE-EMPLOYMENT APTITUDE/INTELLIGENCE TESTS Facilities may use validated aptitude/intelligence tests as a part of the selection process All such tests must be reviewed by the Corporate Personnel Manager and approved prior to use emptest 1/21/98 7 ABD00004501 EQUAL EMPLOYMENT It is Company policy to employ and advance the best qualified people available based on individual merit and to ensure equal opportunity in employment to every employee regardless of race, color, religion, sex, national origin, age, marital status, disability, veteran status or sexual orientation This policy applies not only to hiring practices, but to all aspects of the employment relationship including promotions, salary increases, work assignments and terminations SEXUAL HARASSMENT Sexual Harassment is prohibited It is the continued policy of Georgia Gulf to promote an atmosphere free of sexual harassment, in any form, at all levels of employment This includes but is not limited to unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature Such actions or conduct are viewed as creating an intimidating, harmful and offensive work environment and may subject persons who engage in such conduct or behavior to discipline up to and including termination Furthermore, employees are strongly discouraged from engaging in romantic or sexual relationships with any employee, agent or vendor of Georgia Gulf to avoid relationships that interfere with the Company's legitimate business interests and to prevent uncomfortable working relationships, morale problems among employees, and the potential for improper behavior Employees whose behavior is deemed inappropriate in this regard will be subject to discipline up to and including termination equalemp 1/21/98 8 ABD00004502 EXPENSES - TRAVEL AND BUSINESS ENTERTAINMENT The policy of Georgia Gulf is to reimburse employees for out-of-pocket costs incurred for travel and business entertainment upon receipt of a properly completed and approved Expense Report Form Travel expenses may include those expenses incurred by an employee while traveling away from home that would otherwise not have been incurred TRANSPORTATION - AIR TRAVEL First class air travel is authorized only for officers or for employees authorized by officers on an individual trip basis All employees are encouraged to plan trips in advance to secure discount air fares when available and to use alternate airports when significant savings can be realized without hardship Air travel including a Saturday night stay may be utilized when the overall cost is less than the cost of air travel without a Saurday night stay when it fits business needs and is approved by the employee's supervisor TRANSPORTATION - CAR RENTAL Employees should obtain car rentals from the primary carrier selected by Georgia Gulf Car rental contracts normally contain a collision damage insurance option and personal accident insurance option for which extra charges apply Georgia Gulf is self-insured for collision damage and adequately covered for corporate accident liabilities Employees are to waive and not pay for these insurance options when renting cars for Company business PERSONAL AUTOMOBILE ALLOWANCE Employees who use their personal automobile as transportation to conduct business are reimbursed for the wear and tear and expenses associated with that use (i e gasoline, oil, etc) at the per mile rate established by the Corporate Controller TRAVELING SPOUSES The cost of a spouse accompanying an employee on a business trip is a personal expense to be paid by the employee However, a double room rate is recognized as a Company expense when a spouse travels with an employee on business TRAVEL ADVANCE Permanent travel advances of $300 00 may be given to employees who travel frequently on Company business, with manager and officer approval The advance must be repaid upon change of travel status or termination of employment Temporary travel advances may be issued to employees in advance of a specific trip with manager approval This advance must be repaid or credited against expenses incurred immediately upon completion of the trip CREDIT CARD USE Georgia Gulf has furnished a general purpose credit card and a telephone credit card to employees who travel frequently Telephone credit card charges are billed directly to the Company and should be for business purposes only All charges made to the general purpose credit card are the employee's responsibility for payment Business travel expenses charged on the credit card will be reimbursed by the Company to the employee upon receipt of a properly completed and approved Expense Report Form 9 ABD00004503 BUSINESS ENTERTAINMENT EXPENSES Under the law, only fifty percent of the expenses incurred for business entertainment are deductible and only if the entertainment falls within the following parameters The entertainment must be directly related to the active conduct of a trade or business, the production or collection of income, or the management, conservation, or maintenance of property held for the production of income and/or consists of a business meal (food and beverage expense) in a place conducive to a business discussion The entertainment must be directly preceded or followed by a substantial and bona fide business discussion (including a business meeting at a convention or otherwise) Entertainment of other Georgia Gulf employees not directly related to the conduct of trade or business is not justified ACCOUNTING TO EMPLOYER - EXPENSE REPORT An adequate accounting of expenses must be made weekly in the form of an expense report for daily travel and entertainment expenses, with attached receipts Receipts are required for all transportation, lodging and other payments in excess of $25 00 The expense report must be approved by the appropriate manager before the employee will be reimbursed expenses 1/21/98 10 ABD00004504 GARNISHMENTS Disciplinary action may be taken against an employee due to excessive garnishments upon prior approval from the Law Department Federal law prohibits the discharge of any employee for garnishments on any one indebtedness, and a number of states have more restrictive laws garnish 1/21/98 11 ABD00004505 HOLIDAYS All holidays to be observed by a division or operating unit will be determined in advance by the responsible operating officer The list of paid holidays should be made available to employees by the individual employee's manager If management approves discretionary or "floating" holidays, employees are to be encouraged to use these days to observe religious or ethnic holidays or other days of personal importance Employees must receive the manager's approval before taking a discretionary holiday Only regular salaried employees who are scheduled to work at least 24 hours per week for at least five months in a calendar year are eligible for fully paid holidays The amount of holiday pay for employees working at least 24 hours but less than 40 hours per week will be determined by proration If a nonexempt salaried employee is required to work on a scheduled paid holiday, the employee will receive regular holiday pay plus time-and-one-half for hours actually worked on the holiday The employee's supervisor should explain this to each employee affected TERMINATION PAY FOR UNTAKEN HOLIDAYS Employees whose terminations are effective more than one working day prior to a scheduled paid holiday will not receive pay for the holiday Employees who are laid off and whose terminations are effective on the working day immediately prior to a scheduled paid holiday will receive pay for that holiday Employees who terminate due to any other reason than layoff will not receive pay for any scheduled holiday that occurs following the last day worked Terminated employees who have untaken discretionary or "floating" holidays will be paid for those days unless terminated for grounds which required immediate discharge holidays 1/21/98 12 ABD00004506 INFORMATION AND INVENTIONS - CONFIDENTIAL All salaried employees are required to execute a Confidential Information and Invention Agreement (form 7701) at the time of their employment If an employee leaves the Company's employ for any reason and accepts employment with a competitor or in a related field, the details of the subsequent employment should be communicated to the Law Department in Atlanta The determination will then be made if an appropriate letter can be written advising the new employer of the former employee's continuing obligations to the Company The law grants the Company various rights with respect to all inventions made by employees on Company time or using Company facilities, equipment or materials even though such inventions are not made subject to an invention and trade secret agreement It is the policy of the Company to retain all such rights No employee, during or after his or her employment, shall use or disclose to any third party any trade secret or confidential information relating to the Company's business or research HANDLING UNSOLICITED SUGGESTIONS FOR INVENTIONS, NEW PRODUCTS, PROPERTY, VENTURES OR PROCESSES Occasionally, individuals may contact Company representatives in an effort to sell an invention, idea or suggestion for a new product or process It is the policy of Georgia Gulf not to receive such inventions, ideas or suggestions from anyone without first having such individual sign a letter agreement that sets forth the terms of the disclosure If such information is presented, contact the Law Department before entering into a discussion or accepting any documents or related material It is the policy of Georgia Gulf not to receive such disclosures in confidence without the written approval of an officer info&mv 1/21/98 13 ABD00004507 INTERNET USAGE Access to the Internet, allowing employees to access information resources around the world, has been provided for the benefit of Georgia Gulf Each employee has a responsibility to use the Internet in a productive manner by following these guidelines 1 All messages created, sent or retrieved over the Internet are the property of the Company The Company has the right to access and monitor all messages and files, and employees should have no expectation of privacy when they use Company computers Employee usage of the Internet is recorded and those records may be reviewed when deemed appropriate 2 To prevent computer viruses from being transmitted through the system, all software downloads from the Internet must be checked for viruses with approved software 3 Each employee is responsible for the content of all text, audio or images that they place or send over the Internet Fraudulent, harassing or obscene messages are prohibited All content should be of a professional, business-related nature 4 The Internet is not to be used for personal gam or advancement of your individual views Use of the Internet must not disrupt the operation of the Company network or employee productivity 5 Copyrighted materials belonging to entities other than Georgia Gulf may not be transmitted by employees on the Internet One copy may be downloaded for personal use and research Failure to observe copyright or license agreements may result in disciplinary action by the Company or legal action by the copyright owner 6 No Company computer may be used in any way to access or download pornographic or defamatory material, or material from any site where the principal content of the material is sexually oriented, or where employees have reason to believe that the information being accessed may be defamatory or irresponsible 7 Harassment of any kind is prohibited No messages with derogatory or inflammatory remarks about an individual or group's race, religion, national origin, physical attributes, or sexual preference will be transmitted Violations of any of these guidelines may result in disciplinary action up to and including termination If necessary, the Company will advise the appropriate legal officials of any illegal actions by employees internet 1/21/98 14 ABD00004508 INVESTOR RELATIONS Communication with owners of the Company's stock or the investment community is coordinated by the Director-Investor Relations Please refer all inquiries or requests for information from shareholders or the investment community to the Investor Relations Department in Atlanta investor 1/21/98 15 ABD00004509 LEGAL SERVICE Statutes of various states designate those authorized to accept papers required in order to institute legal action against the company Proper delivery of these original papers constitutes legal service Georgia Gulf has appointed CT Corporation System to act as Registered Agent to accept such legal service That agent immediately advises the Law Department in Atlanta of service, which refers the matter to the proper department for handling On many occasions a person desiring to institute legal action will attempt to serve the papers on a Georgia Gulf employee rather than the Registered Agent In such instances, the employee should observe the following procedures 1 Advise such process server that employees are not authorized to accept service and to serve the company's Registered Agent 2 If the process server insists on leaving such papers, accept them and (except for garnishments) immediately call the Atlanta Law Department, keep a copy and on the same day forward the original as directed by the Law Department Include an explanatory note with the papers giving date, time and place of service legalsvc 1/21/98 16 ABD00004510 MEDIA RELATIONS This policy establishes responsibilities and procedures for all media contacts for the Company The media include daily and weekly newspapers, news wire service, radio and television, trade or consumer magazines, books, newsletters and all other publications FINANCIAL NEWS Release of previously unpublished financial or related information to the media requires approval by the Chief Financial Officer This includes financial information about construction or expansion of plants, laboratories or offices, the purchase or sale of properties, business conditions, changes in officer personnel or duties, shareholders' meetings, directors and director's meetings, earnings or financial reports, stock plans, taxes and payroll OTHER COMMUNICATIONS In addition to immediate reports to division managers, officers, the Corporate Law Department and/or public agencies as required for significant events, the following should be reported quickly to the officer responsible for the area affected 1 Information concerning litigation 2 Strikes or labor disputes 3 Significant changes in construction schedules 4 Product or process breakthroughs, changes, or product eliminations 5 Plant closures, reopenings or shift layoffs 6 Events having potential environmental impact 7 Other significant events In these instances, the officer responsible will designate the individual to handle the flow of information to the media and others RELEASE OF INFORMATION AT THE DISCRETION OF LOCATION MANAGEMENT The manager of a site may use his/her own judgment in releasing the following information A copy of each press release must be forwarded to the Public Affairs Department in Plaquemine 1 Personnel Changes 2 Large, Local Purchases 3 Plant Beautification Programs 4 Safety Records and Awards 5 Retirements and Employee Recognition 6 Civic Activities (Blood Bank, United Way, Chamber of Commerce, Scholarships, Jr Achievement, etc) LETTERS TO THE EDITOR Letters to the editor, whether for publication or to correct errors or applaud good reporting, are part of the company's media relations program All letters of a critical nature and those involving corporate policy must be cleared through the Public Affairs Department in Plaquemine This policy applies to all letters to the media written on behalf of the company, on the corporate letterhead, or by an individual using a corporate title or address 17 ABD00004511 ASSISTANCE AND ADVICE For assistance in prepanng press releases, fact sheets and other media relations materials, contact the Public Affairs Department located in Plaquemine For assistance regarding financial news or shareholder communications, contact the Investor Relations Department in Atlanta media 1/21/98 18 ABD00004512 PRIVACY - EMPLOYEE It is company policy that no personnel or medical file will be released to outsiders or unauthorized company personnel without the written consent of the employee, except during the course of judicial or administrative proceedings If such information is subpoenaed or required by law to be divulged, the file should be forwarded to the Law Department which will then be responsible for submitting the information CREDIT REFERENCES Occasionally, a credit organization or financial institution will contact the Company seeking information including employment and salary verifications about a current or former employee It is the Company's policy that the only information that will be verified without a written authorization from the employee is the current (or final) job title and dates of employment Requests for information are to be handled by the Corporate Human Resources Department in Atlanta COMPANY'S RIGHT TO ACCESS INFORMATION Although the Company respects the individual privacy of its employees, an employee cannot expect privacy rights to extend to work-related conduct or the use of company-owned equipment, supplies or property Therefore, the Company may at its discretion search or access any area on Company premises including, but not limited to, desks, computer files and systems, briefcases, lunch boxes, file cabinets, lockers, offices, and vehicles that are located on company premises The Company may also inform outsiders of any information discovered through a search of company property that documents any illegal activity NOTE: Also See "Computer Systems", " Internet Usage", "Electronic Mail" and "Voice Mail" policies privacy 1/21/98 19 ABD00004513 RECORD RETENTION Laws and regulations relating to taxes and other matters, court orders relating to litigation, and prudent business practice require the retention of certain business records for specified periods of time It is the policy of Georgia Gulf to ensure that all documents produced in the conduct of its business are retained only for as long as required by law or as determined for prudent business reasons The company has established a protected and controlled environment for the preservation of these documents, as well as procedures for organizing them for quick retrieval The Director of Human Resources coordinates the overall program and establishes the mechanics of the storage and retrieval system The Human Resources Department is responsible for coordinating the preparation of the general policy statements in consultation with the Law and Tax Departments The Law and Tax Departments are, in turn, responsible for determining and communicating to the Director of Human Resources and other appropriate personnel in a timely manner any changes to the normal retention periods due to litigation or tax audits by government agencies The Controllers in the field then assume the responsibility for having these records retained for the additional specified period A detailed statement of this policy and the procedures for carrying it out are contained in the Records Manual which is maintained in the Controller's office at each operating division records 6/17/98 20 ABD00004514 REFERENCES It is the policy of Georgia Gulf that the only information the Company will verify for a prospective employer about a former employee is final job title and inclusive dates of employment With the former employee's written authorization the Company will also verify the employee's final salary CREDIT REFERENCES It is the Company's policy that the only information that will be verified without the written authorization of the employee is dates of employment and current or (final) job title Requests for information are to be handled by the Corporate Human Resources Department in Atlanta refrncesl/21/98 21 ABD00004515 EMPLOYMENT OF RELATIVES The full-time employment of relatives is discouraged, especially in the same department at the same location However, the Company recognizes, that under certain circumstances, the employment of relatives may be appropriate In such instances the situation will be examined to determine if there is a potential conflict of interest or if the relationship presents other problems which might compromise the efficiency of the Company or the employees affected In any case, the following conditions must be met before a relative of an employee is hired 1 The Company must follow normal employment practices for the position in question including recruiting and screening of candidates for a bona fide existing job vacancy while observing the company's Equal Employment Opportunity Policy 2 Relatives must not report to one another under any circumstance 3 Employment of relatives within the same department at the same location must be approved by the responsible officer If an employee marries another employee and they work in the same department or report to one another, or if their relationship represents a security risk or violates generally recognized internal control principles, the Company has the option to decide which employee can stay and which employee will be transferred or terminated In this regard, this policy also applies to employees who are engaged in a spousal relationship although not legally married relative 1/21/98 22 ABD00004516 RELOCATION ASSISTANCE Georgia Gulf will reimburse or pay for specific and reasonable relocation expenses incurred by or on behalf of full-time salaried employees who must change their place of residence as a result of companyrequested transfers This policy excludes employees transferred at their own request or for their own convenience except in situations where such a move is in the best interest of the company and written approval is obtained from the officer responsible for the locations affected Portions of this policy may apply to newly hired exempt employees with officer approval The purpose of this policy is to provide uniform and fair relocation benefits which will enable transferring employees to secure housing at their new work location and dispose of their principle residence at the old location as quickly as possible with a minimum of financial hardship and inconvenience Benefits are provided through the Relocation Assistance Program administered by the Corporate Human Resources Department and may include Pre-Move House Hunting Trips Temporary Living Expenses at New Location Household Moving Expenses Automobile Travel or Transport Expenses Family Transportation Expenses In addition, with the appropriate approvals, this policy may provide assistance for DISPOSAL OF PRIOR PRIMARY RESIDENCE EXPENSES 1 Third Party Purchase 2 Home Sale Closing Services 3 Renter Consideration ACQUISITION OF NEW PRIMARY RESIDENCE EXPENSES 1 Home Purchase Closing Cost 2 Home Equity Loans 3 Renter Consideration There are also provisions for assisting the employee with miscellaneous expenses related to furnishings, utility fees, vehicle licensing and other extraordinary expenses in the form of a relocation allowance Tax considerations are also dealt with to relieve the employee's tax burden for any taxable reimbursements received under this program The Corporate Human Resources Department has provided a copy of the Employee Relocation Assistance Policy & Procedures booklet to Division Controllers, Human Resources Managers, and local management which includes all of the details of the policy and program Discuss the circumstances of any proposed relocation with the local controller, Human Resources Manager or local manager, or with the Corporate Personnel Manager in Atlanta, for details regarding the specific assistance available Questions or requests for information regarding this policy should be directed to the Corporate Personnel Manager in Atlanta. relocate 6/17/98 23 ABD00004517 SALARY AND BENEFITS It is the policy of the Company to competitively compensate employees at a level appropriate for their job and location of work As such, the Company sets the competitive pay rates for our jobs by comparing its total compensation plan - salary, overtime pay, profit sharing plans, and benefits - to other organizations which employ people in comparable jobs It is the responsibility of local operating management to manage the compensation of their employees with the assistance of the Compensation and Benefits Manager and the Human Resources Department SALARY ADMINISTRATION - SCHEDULED PERIODIC PAY INCREASES Most overtime-eligible (non-exempt) operations jobs have scheduled progression increases that are defined by local management For other overtime-eligible jobs, the schedule for salary increases is For New Hires For Existing Employees 6 Months/12 Months then annually Annually Exempt positions are scheduled for annual salary increases All regular salary increases are to be scheduled for the first day of a calendar month In the case of promotions, demotions or equity pay adjustments, the salary increase should be made as of the first day of a calendar month and the next regular salary increase should be scheduleded to occur twelve months after the change AUTHORIZATION OF SALARY INCREASES Salary increases have different signature approval requirements depending on the employee's salary level and/or the percentage amount of the salary increase Generally, increases for salaries over $65,000 or for greater than 4 1 % require officer approval in addition to local management approval Supervisors should contact the local Payroll or Human Resources Department for information on local approval requirements BENEFITS The Company provides its salaried employees with a comprehensive program of benefits as a part of its total compensation plan to be competitive with other companies and to meet the needs of its employees in the areas of health coverage, insurances, and retirement plans The program includes (1) the Group Program that includes medical, dental and vision coverage, employee and dependent life insurance, and supplemental life and disability insurances, (2) the Salaried Employees Retirement Plan, a defined benefit pension plan, (3) the Savings & Capital Growth Plan, a 401(k) type retirement savings plan, and (4) an assortment of miscellaneous benefit plans like the Educational Assistance Program for tuition reimbursement, the Dependent Care spending account and the Employee Stock Purchase Plan Refer to the summary descriptions of these plans or contact your local Human Resources Department for information salary&b 1/21/98 24 ABD00004518 SERVICE AWARDS Georgia Gulf has established a service awards program for recognition of loyal service of company employees This program is meant to be flexible to allow for special local conditions, and may not be required where conflict with labor contracts exists or where it is otherwise impractical ELIGIBILITY Service award eligibility will begin when an employee has completed five years of service and a presentation will be made for each five-year interval of employment thereafter The service period for qualifying individuals for service awards will begin with the hire date of employment and will include credit for past employment with Georgia Gulf or at an operating or administrative facility acquired by Georgia Gulf When an employee has a break in service, the hire date for service award purposes will be adjusted so that the period of prior employment is included in the period of credit employment An employee will be eligible for a service award if his or her five-year increment of service falls within the year, up to and including December 31 For example, if an employee's hire date is December 26,1990, that employee would be entitled to a service award at the function held during 1995 Service awards will be supplied from the headquarters office in Atlanta through the Human Resources Department Service award order information will be distributed by the Human Resources Department to recipients in the middle of each year Shipment of service awards to locations will be scheduled for September delivery servawrd6/17/98 25 ABD00004519 SOLICITATIONS The company prohibits solicitations, collections, posting or distribution of printed or written materials anywhere or at anytime on company premises by nonemployees No employee may solicit or collect from another employee during a time when either of them is supposed to be actively engaged in his or her work tasks This rule is not intended to prohibit such activities during a rest or lunch break or other such time when both employees are free from work responsibilities No literature may be posted or distributed by any employee in any work area This rule is not intended to prevent employees from distributing written or printed materials to one another in non-work areas such as the lunch rooms so long as the result does not create litter or a safety hazard and so long as the employees involved are free from work responsibilities Bulletin boards are intended for the dissemination of information approved by local management Therefore, no material should be posted without the prior approval of the responsible manager or a designee solicit 1/21/98 26 ABD00004520 TERMINATION OF EMPLOYMENT - SALARIED EMPLOYEES Georgia Gulf is an At-Will employer As such, it is the policy of Georgia Gulf that the employment and compensation of any employee can be terminated, with or without cause, at any time, at the option of the employee or at the option of the company This means that the employment relationship may be terminated at any time by the Company or the employee for any reason not expressly prohibited by law Any oral or written statement to the contrary made by anyone other than the President of the Company is invalid Specific procedures to be followed depend upon the circumstances of the termination Any questions about this policy should be referred to the Director-Human Resources INVOLUNTARY TERMINATIONS 1 Grounds for Immediate Discharge Actions which are normally grounds for immediate discharge include, but are not limited to, unacceptable conduct such as theft, disclosure of trade secrets, dishonesty, insubordination, gross misconduct, willful or deliberate destruction of company property, willful violation of company policy (e g alcoholic beverage and drug policies and policies designed to protect or properly document the transfer of company property), or any other similarly serious offenses Employees discharged for such offenses will not normally be given advance notice of termination They will be paid only through the last day worked They will only be paid for earned but untaken vacation days unless required by state law Their group medical coverages will terminate at the end of the calendar month in which discharged and all other coverages will terminate as of the last day worked Settlement of their distributable interests, if any, in the Georgia Gulf Retirement and Savings and Capital Growth Plans will be made in the amounts described and at the time specified in the applicable provisions of the plans Supervisors should consult with the local Human Resources Department, the Law Department in Atlanta or the Corporate Human Resources Department before executing this type of termination 2 Actions Which Normally Result in Warning Prior to Discharge Other discharges may include, but are not limited to, continued violations which normally warrant progressive disciplinary steps - violations such as poor performance, neglect of duty, excessive absenteeism and tardiness, etc Employees who are terminated by the company as a result of this type of violation will be paid through the last day worked and will normally be given two weeks notice or pay in lieu of notice They will only receive pay for earned but untaken vacation days Their group medical coverages will terminate at the end of the month in which their pay-through date occurs and all other coverages will end as of the last day worked The local Human Resources Department should be contacted prior to the discharge of any employee 27 ABD00004521 3 Plant or Office Closure or Job Elimination In the event an employee's job is eliminated for any reason (including plant or office closure) and there is not a chance of recall, the employee will be terminated as of the last day worked and receive Termination Pay as outlined below In such a case, the employee's group insurance coverages will end at the end of the calendar month in which the employee's pay-through date occurs TERMINATION PAY A salaried employee terminated due to job elimination will receive a lump sum termination payment equal to a minimum of one week's current base pay for each year of completed continuous service with the company, with a minimum of two weeks and a maximum of 52 weeks If the Company sells a facility, terminated salaried employees will receive termination pay as outlined above, provided the following conditions are met A Salaried employee is not offered employment by the buyer, or B Prior to 120 days from the date of the sale of the facility by Georgia Gulfl (i) salaried employee is terminated by the buyer as a result of the buyer's plant closure or job elimination or (n) salaried employee is terminated as the result of a resale of the facility by buyer where the salaried employee is not offered employment by the subsequent buyer LAYOFFS If there is a reasonable likelihood that the company will recall or offer certain employees other suitable jobs within twelve months of being laid off, such employees will be offered unpaid leaves of absence not to exceed twelve months During such leaves the employees may A Continue their group life and health insurance coverages by paying the monthly premiums to Georgia Gulf (Note Travel Accident insurance and optional benefits such as long-term disability, personal accident, supplemental life and accidental death and dismemberment cannot be continued) B Collect unemployment insurance, if otherwise legally eligible C Work for a different employer D Cancel the leave and be terminated At the beginning of such leaves, employees will be paid for their earned but untaken vacation days as of the last day worked If an employee refuses recall or an offer of another job with the company which, in the sole discretion of the company, is suitable, the employee will be considered to have resigned with two weeks' notice and will be terminated, without termination pay, as of the date of recall or job offer In such a case, if the employee has elected to continue his or her group insurance coverages during the leave, such group insurance coverages will end at the end of the month in which termination occurs although the employee will retain their COBRA rights to continue health coverages if otherwise eligible If the company doesn't recall or offer an employee another suitable job within such leave, the 28 ABD00004522 employee will be terminated as of the end of the leave and receive termination pay as outlined above In such a case, the employee's continued group insurances will end at the end of the month in which the termination occurs Periods during which the employee is on unpaid leave of absence shall not be included in the computation of employee vesting service for the Georgia Gulf Salaried Employees Retirement Plan, nor for any other employment benefits based on length of service (e g , vacation, service awards) 4 Other Involuntary Discharges There may be grounds for discharge other than those discussed above This discussion is not meant to be inclusive or to limit in any way management's freedom to discharge an employee at any time for any reason not prohibited by law OTHER TERMINATIONS 1 Resignations ; Employees who are employed temporarily or part-time on an average of less than 20 hours per week and who resign will be paid only through the last day worked Employees who resign with less than two week's notice will be paid through the last day worked and for their untaken, earned vacation Their group coverages will end as of their last day worked All other employees who resign with at least two weeks' notice will be paid through the last day worked They will also be paid their untaken, earned vacation and pay in lieu of notice if asked to leave work prior to the end of their two week notice period Their group health coverages will end at the end of the calendar month in which their pay-through date occurs and all other group coverages will end as of their last day worked 2 Deceased Employees Salaries of deceased employees will be paid through the date of death plus any earned, untaken vacation days In addition a separate check in an amount equal to one calendar month's regular salary will be made payable to the employee's beneficiary or estate as a death benefit Group insurance coverages of deceased employee's dependents, if any, will end at the end of the calendar month in which the employee's actual last day worked occurs The local Human Resources Department will assist the deceased employee's beneficiaries in applying for and receiving all benefit payments due from Company plans 3 Retirement (Normal or Early) Employees who retire will be paid through the last day worked and for any untaken, earned vacation days Their group health coverages will end at the end of the calendar month in which the paythrough date occurs and all other coverages end as of the last day worked Benefits from all retirement programs can be coordinated with the Manager-Compensation and Benefits in Atlanta term 5/14/98 29 ABD00004523 TRADEMARKS AND COPYRIGHTS Georgia Gulf trademarks are valuable assets that help the public recognize and choose Georgia Gulf products, distinguishing them from competitive products and guaranteeing Georgia Gulf's standards of quality Consequently, it is important to follow a uniform corporate policy regarding adoption, registration, use and protection of the Company's trademarks All questions concerning our trademarks should be directed to the Law Department in Atlanta PROPER USE AND PROTECTION OF THE MARK Proper use of Company trademarks is very important and is critical to their continued viability The prime objective of Georgia Gulfs trademark policy is to prevent the trademark from becoming, in the mind of the public, the generic or common name identifying the product itself instead of a particular source for that product If the Company does not use its trademarks properly, and does not prevent others from infringing or otherwise misusing its trademarks, then their value will be lost Therefore, it is extremely important that every employee be mindful of the use of Company trademarks, seek guidance concerning their proper use, and report examples of misuse to the Law Department in Atlanta USE OF THE MARK ON SPECIALITY ITEMS Georgia Gulf authorizes the production and sale of specialty items such as pens, pencils, key chains, jackets, hats, etc In order to insure the proper use of the Georgia Gulf trademark, suppliers of such specialty items must receive advance written approval from the Corporate Administration Department The Corporate Administration Department in Atlanta should be contacted before ordering, as it maintains relationships with approved vendors and can assist with special orders COPYRIGHTS Federal law grants the Company copyrights in "original works of authorship" (i e advertising copy, photographs, catalogs, videotapes, computer programs, etc) created by an employee within the scope of his/her employment It is the policy of the Company to retain and enforce all of its copyrights When the Company has an original work prepared for it by a nonemployee, or an employee outside the scope of employment, it is imperative that the Company receive appropriate rights from the creator of the work so as to enable the Company to use the work for its intended purpose The Company respects the copyrights of others and does not sanction the infringement of those rights in the conduct of the Company's business All questions concerning copyright matters should be referred to the Law Department in Atlanta trademrk 1/21/98 30 ABD00004524 TRAINING AND DEVELOPMENT Employee training and development is an integral part of the interdependent relationship between employees and the Company Our training and development system is designed to provide opportunities that will help all employees develop, maintain, and enhance job performance in the primary job, special assignments and future challenges Employees share the responsibility for keeping up to date on their required health, safety and environmental training (i e , OSHA, EPA, DOT, etc), the technology, processes and procedures (PSM, CIP, etc), and the interpersonal/working relationships associated with your job This may require employees to participate in seminars, workshops, courses, study groups, on-the-job-training, self-study, self-paced computer-based training, conferences, reading assignments, tests, demonstrations and other methods intended to increase competencies required for optimal performance Upon completion of such learning opportunities, employees are expected to apply the knowledge, skills and attitudes learned in the training and development experience to add value to the Company OPERATIONAL DEFINITIONS TRAINING refers to learning focused on the employee's present job The purpose of training is to improve knowledge, skills and attitudes needed of the employee Training usually has specific, shortterm objectives for specific knowledge and skills needed for a specific task After an analysis has been conducted to determine training requirements and/or performance gaps, training should be accomplished during paid time at Company expense DEVELOPMENT refers to the long term growth of the individual Development opportunities may come in a variety of structured or unstructured learning situations and are designed to maintain and expand knowledge, skills and attitudes in present and future assignments Development opportunities can be supported at different levels (full/partial/no reimbursement) as determined by individual management depending on the circumstances An analysis of the individual need should be conducted to determine gaps between current and desired performance Development courses that are not tied to the present job but would be beneficial (like professional certifications or college course work) will likely fall under the guidelines of the Educational Assistance program below COMPANY PROVIDED/SPONSORED TRAINING CLASSES To assist employees in acquiring and improving their job skills, the Training Department develops training to be delivered through internal Company resources or approved external partners The courses are listed in the "Employee Training and Development Catalog" and includes instructions for enrollment ATTENDANCE Employees are expected to participate in company sponsored training and development programs in their entirety Full attendance is required from start to finish TRAINING AND DEVELOPMENT PROGRAM FEES Registration fees and educational materials/supplies required for training and development programs authonzed or required by the Company shall be paid for by the Company Payment for these programs is separate and distinct from compensation paid to employees in the form of salary or wages 31 ABD00004525 SALARIES AND WAGES Exempt employees authorized to participate in training and development programs shall receive normal compensation regardless of the duration and/or day of the week the program is conducted Non-exempt employees authorized to participate in training and development programs shall receive compensation based on the Fair Labor Standards Act for actual time required (and spent) to complete the program TRAVEL, LODGING, MEALS AND ENTERTAINMENT EXPENSES Employees will be reimbursed for out-of-pocket expenses incurred in order to participate in approved training and development programs based on the Company's policy for "Travel and Business Entertainment Expenses" Employees are expected to use sound judgement for efficient use of resources (effective planning, combined car travel, etc) EDUCATIONAL ASSISTANCE - TUITION REIMBURSEMENT As a means for employees to increase their individual value and their contribution, the Company encourages individual self-improvement through job-related courses provided by accredited educational institutions To provide encouragement toward achieving this, Georgia Gulf has established an Educational Assistance Program For satisfactorily completed courses, the company will reimburse 80 percent of the reasonable expenses of tuition, registration, books, required course supplies and laboratory fees To take advantage of the program, the employee must have been employed for at least one year and must obtain written approval (use the "Application for Educational Assistance" form) from their manager prior to beginning the coursework The manager may approve the course(s) if it is found to relate to the employee's present job or to a job the company foresees the employee assigned to in the future PROFESSIONAL CERTIFICATION/CONTINUING PROFESSIONAL EDUCATION (CPE) As a part of the Educational Assistance program, the Company will support employees m the pursuit of approved professional certifications and continuing professional education to maintain approved licenses and certifications To take advantage of this policy the employee must have been employed for at least one year prior to the examination date and/or course registration and have received prior management approval Upon successfully passing the certification exam, eighty percent of the reasonable costs of professional review courses and related materials (one time) or self-study materials will be reimbursed to the employee With prior approval by management, an employee will be reimbursed the full cost of obtaining required Continuing Professional Education (CPE) credits including registration fees, supplies, and travel expenses The Company will allow employees a reasonable amount of paid time away from work each year to take an examination or attend CPE courses to the extent that department needs are not affected Any questions regarding the application of this policy should be referred to the Training Manager training 5/15/98 32 ABD00004526 VACATIONS & HOLIDAYS Georgia Gulf provides employees with paid time away from work to meet family, personal, and recreational needs It is the Company's belief that employees need this time away from work and require employees to utilize vacation and other scheduled time off for that purpose unless exceptional business conditions exist which prohibit it The Company provides for a certain number of days of vacation for each employee to use each year based on the schedule below The Company also provides for a number of paid holidays per calendar year VACATION Following is the vacation policy for all Georgia Gulf salaned employees 1 Employees are granted time-off for vacation as a gratuitous benefit of employment Georgia Gulf will permit vacation leave in the following manner If, as of December 31 an employee has During the following year the employee will be granted Less than 3 Months of service* 5 days More than 3 Months but less than 5 years of service 10 days 5 but less than 10 years of service 15 days 10 but less than 18 years of service 20 days 18 or more years of service 25 days * Service is calculated from most recent hire date 2 A new employee with a hire date not later than September 1 may, at the discretion of the Company, be granted up to five (5) days of vacation upon completion of sixty (60) days of service in the year of hire provided that the award of vacation time does not cause any hardship to the Company New employees hired after September 1 are not eligible for vacation during that calendar year 3 Vacation days are not accrued but are "awarded" each December 31st except as otherwise provided Consequently, each employee is responsible for ensunng that vacation is taken Any unused portion will be automatically forfeited unless prior approval in writing is obtained from the responsible officer 4 Where requested by local management for the convenience of the Company's operations, employees may, at the discretion of the Company, receive pay in lieu of time off for any portion of awarded vacation days that exceeds two weeks per calendar year Such payments must be approved in advance by the responsible officer 33 ABD00004527 5 Employees terminating for any reason will be paid for any untaken vacation days 6 Paid absence time will count as time worked for the above purposes 7 Only regular full-time employees are eligible to receive paid vacation 8 If there is a death in the employee's immediate family while the employee is on vacation and funeral leave is applicable, the employee's vacation may be extended by the amount of time normally allotted for funeral leave or the appropriate time may be credited to the employee's vacation time remaining HOLIDAYS All holidays to be observed by a division or operating unit will be determined in advance by the responsible operating officer The list of paid holidays should be made available to employees by the individual employee's manager If management approves discretionary or "floating" holidays, employees are to be encouraged to use these days to observe religious or ethnic holidays or other days of personal importance Employees must receive the manager's approval before taking a discretionary holiday Only regular salaried employees who are scheduled to work at least 24 hours per week for at least five months in a calendar year are eligible for fully paid holidays The amount of holiday pay for employees working at least 24 hours but less than 40 hours per week will be determined by proration If a nonexempt salaned employee is required to work on a scheduled paid holiday, the employee will receive regular holiday pay plus time-and-one-half for hours actually worked on the holiday The employee's supervisor should explain this to each employee affected TERMINATION PAY FOR UNTAKEN HOLIDAYS Employees whose terminations are effective more than one working day prior to a scheduled paid holiday will not receive pay for the holiday Employees who are laid off and whose terminations are effective on the working day immediately prior to a scheduled paid holiday will receive pay for that holiday Employees who terminate due to any other reason than layoff will not receive pay for any scheduled holiday that occurs following the last day worked Terminated employees who have untaken discretionary or "floating" holidays will be paid for those days unless terminated for grounds which required immediate discharge vacation 5/14/98 34 ABD00004528 WORKPLACE VIOLENCE PREVENTION It is Georgia Gulf Corporation's intent to provide a safe, secure workplace for all individuals while on our property or during the conduct of business With this in mind, any act of a violent nature or any threat of violence occurring at any time on Company property is expressly prohibited For the purpose of this policy, workplace violence is defined as, but is not limited to, threats or actions which result in the use of power or force, gestures which may be interpreted as intimidating or belligerent, and/or intimidating or belligerent verbal comments This prohibition extends to any individual who is on company property including but not limited to employees, contractors and visitors This policy is also in effect while on Company business or at Company sponsored events All employees are required to immediately report to their supervisor any violent acts or threats of violence in the workplace All reports of threats of violence or actual violence will be promptly and thoroughly investigated WEAPONS Weapons, including hand guns, are strictly prohibited from any and all work areas This policy is also in effect while on Company business or at Company sponsored events A weapon is considered to be any object that could be used to harass, intimidate, or injure another individual, as well as any item deemed to be a weapon by management or security department personnel Employees are required to report any potential violations of this policy to their supervisor immediately Any employee found responsible for a violent incident, the threat of violence, or found in violation of the Company's Weapons Policy, will be subject to disciplinary action, up to and including termination of employment violence 3/4/98 35 ABD00004529 VISITORS AND PLANT TOURS Every year Georgia Gulf receives many requests for tours of company facilities Effective handling of tours and visitors requires planning, and it is Georgia Gulfs policy to handle visitors and tours in a way which maximizes public goodwill and minimizes plant disruption Any questions regarding plant visitations should be directed to division managers who will coordinate application of this policy As a general rule, visitors will be allowed in the plants at the discretion of plant and divisional managers or company officers This policy is subject to the following guidelines 1 No competitor will be allowed in any operation without the approval of the divisional manager or the responsible officer 2 Visitors under 18 years of age will be allowed in operations at the discretion of the plant manager but must be accompanied by appropriate adult supervision 3 During political campaigns, plant tours by candidates or their representatives should not be permitted The candidates or their representatives may be allowed to meet employees as they enter or leave the plant premises Care should be exercised to assure fairness among candidates Permission to visit company offices is discretionary with each management However, if federal candidates are permitted such visits, all other candidates for the same office must be allowed to do so on request Other legal restrictions also apply to visits by federal candidates, therefore, the Law Department should be consulted prior to arranging such visits 4 News media tours, other than local media involving only local interests, should be coordinated with the Public Affairs Department in Plaquemine 5 Shareholders or members of the investment community who request tours should be referred to the Investor Relations Department in Atlanta SAFETY AND CONFIDENTIALITY Tours should be conducted to best assure visitor safety Routes and caution areas should be indicated Walkways and railings should be kept clean and clear of dust or obstructions, and railings should be periodically checked for defects Visitors must comply with all rules and regulations regarding safety, such as a prohibition against beards if applicable Appropriate protective equipment such as hard hats respirators or eye protections must be provided and used by visitors in plants where employees are required to wear such devices The possibility of access to certain plant areas by visitors should be limited or denied as appropriate, taking into consideration safety factors, the purpose of the tours, weather conditions, the need for confidentiality and the composition of the group Those plants with proprietary products, processes or equipment should either take such steps as are reasonably necessary to prevent access to such proprietary information, or require all visitors to sign an appropriate nondisclosure agreement before beginning a tour Forms for this purpose are available through the Law Department visitors 1/21/98 36 ABD00004530 VOICE MAIL The Company provides voice mail to employees (as approved by appropnate management) at Company expense for their use on Company business Following is the policy with regard to access to and disclosure of voice mail messages sent or received by employees and the use of the voice mail system 1 The Company has the right to access and monitor all messages, and employees should have no expectation of privacy when they use the Company voice mail system 2 Although employees have individual access codes to Company systems including the voice mail system These systems are accessible at all times by the Company The Company has the nght to access and disclose the contents of voice mail messages as necessary The Company may use information regarding the number, sender, recipient, and addresses of messages sent over the voice mail system for any proper business purpose 3 Harassment of any kind is prohibited No messages with derogatory or inflammatory remarks about an individual or group's race, religion, national origin, physical attnbutes, or sexual preference will be transmitted 4 Misuse of the voice mail system by any employee, including snooping and sending offensive messages, is a violation of Company policy and may result in disciplinary action up to and including termination Voice messages should be treated as mail, and should be returned to the sender if improperly addressed or incorrectly delivered 5 Voice mail messages are confidential internal Company communications and must comply with the corporate record retention guidelines and other Company communication policies and procedures 6 Access to the Company voice mail system by third parties must be approved by appropriate management and the Associate Director of Information Services Any questions concerning this policy and the associated procedures should be directed to the Associate Director of Information Services in Baton Rouge Voicemai 6/17/98 37