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Superior Essex Inc. Compliance Reporting

Superior Essex Inc. has earned the reputation of a company with the highest integrity - producing and delivering quality products with outstanding customer service. We are proud not only of what we are accomplishing, but of how we are achieving success. This reputation is one we want to protect. To protect this reputation, we must continually strive to serve the best interests of our customers, employees and shareholders, while behaving as a responsible corporate citizen. This commitment requires, among other things, that we act with the highest ethical and legal standards.

Our commitment to the highest standards of integrity begins with ensuring that everyone across the Superior Essex organization understands our core values - values that define how we conduct ourselves. These values are the foundation of our Code of Ethics.

Most issues regarding the Code of Ethics and how it applies to a particular situation can be resolved locally before they become problems for the Company, employees or the public. The Company encourages employees to present ideas, raise concerns or ask questions about the Code-especially those of a legal or ethical nature. All managers are responsible for supporting and enforcing this policy by maintaining an "open door" for their direct reports and those who may reach out to them. While we hope that employees feel comfortable discussing any matter with their supervisors, there may be times when a supervisor cannot help.

There are a variety of resources available to help. You can contact any one of the following:

The next higher level of supervisor
The head of your business unit
Any member of the Legal Department
Local or corporate Human Resources
The Compliance Officer

While your questions and concerns can often be resolved at the local level, the Compliance Officer provides another way to address issues that cannot be resolved there and, in general, provides a way to report a concern or get information or advice regarding the Code of Ethics. You may contact the Compliance Officer in any of the following ways:

**Compliance Officer**
E-mail	compliance@spsx.com
Mail	Compliance Officer Superior Essex Inc. 5770 Powers Ferry Road Suite 400 Atlanta, GA 30327
Phone	Call the Compliance Officer or a member of the Legal Department by dialing 001-770-657-6000
In Person	Call the Compliance Officer or a member of the Legal Department for an appointment

Anonymous Reporting System
While you should be able to resolve your compliance issues through these resources, there may be an occasion where you want to raise an issue or concern anonymously. For this reason, the Company has established the Superior Essex Compliance Reporting System. All messages submitted through this system are anonymous (unless you reveal your name) and are reviewed by the Company's Compliance Officer or someone on his or her staff acting under the Compliance Officer's supervision. The Company will investigate and handle all messages in such manner as it considers appropriate based upon the specific circumstances of the matters raised. In responding to your concern or comment, you may be asked to provide additional information regarding your message, which you may provide with anonymity. The system will generate a 14 to 16-digit code for each complaint or comment, and you can use that code to track the status of your message and interact confidentially with the Compliance Officer or others using the system. You may submit your message in one of two ways: Secure Web Form or Secure Hotline.

Anonymous Reporting System

While you should be able to resolve your compliance issues through these resources, there may be an occasion where you want to raise an issue or concern anonymously. For this reason, the Company has established the Superior Essex Compliance Reporting System. All messages submitted through this system are anonymous (unless you reveal your name) and are reviewed by the Company's Compliance Officer or someone on his or her staff acting under the Compliance Officer's supervision. The Company will investigate and handle all messages in such manner as it considers appropriate based upon the specific circumstances of the matters raised. In responding to your concern or comment, you may be asked to provide additional information regarding your message, which you may provide with anonymity. The system will generate a 14 to 16-digit code for each complaint or comment, and you can use that code to track the status of your message and interact confidentially with the Compliance Officer or others using the system.

You may submit your message in one of two ways: Secure Web Form or Secure Hotline.

Investigation and feedback
Where concerns are raised, they will be passed to an appropriate and authorised person within the Company, which will usually be your local HR Manager (the "Responsible Person"). The Responsible Person will usually acknowledge your concern within seven days after receipt by the Superior Essex Compliance Reporting System and will arrange for an initial confidential interview with you to discuss the areas of concern. You will be asked to provide as much information and supporting detail as you can in relation to the disclosure being made. Failure to do this may hinder any subsequent investigation and raise doubts about the genuineness of your belief in that disclosure. In a limited number of cases, the Responsible Person may decide that your concern(s) are best dealt with under another internal procedure. Should this be the case then the Responsible Person will discuss with you at the appropriate time. This policy is applicable to the extent that you raise your concern in good faith and without direct financial motive. In the event you do not meet one of the criteria specified in this policy and your concern(s) are not otherwise deemed 'whistleblowing' or a 'protected disclosure' under local law, your alert may be considered inadmissible for the purposes of this policy. In such case, you will receive a notification indicating the reasons therefor. Depending on the nature of the concerns raised, the Responsible Person may involve internal and/ or external subject matter experts (for example the Head of HR Europe) in investigating your concerns. The Responsible Person may also reach out to Corporate & Legal department in our headquarters to discuss the appropriate outcome, although where any such discussions would be privileged they will not be able to share them with you. We will aim to keep you informed of the progress of any investigation and we will usually provide you with feedback on the final outcome within three months of you raising your concern. The level of feedback you receive will take into account the legal obligations of confidentiality the Company has. For the avoidance of doubt, any information that you may be provided about the investigation and/ or its outcome should be considered confidential unless you are advised otherwise. If you raise a genuine concern in accordance with this policy, you (and anyone connected with your raising of the concern) will be protected against detrimental treatment imposed as a result of raising it, in accordance with the protections granted by local law. However, doing so does not give you any right to be involved in any investigation that takes place as a result, nor does it give you the right to dictate any particular remedy or response, whether or not your concern is found to be genuine. If you believe you have suffered detrimental treatment for having raised genuine concerns about wrongdoing at work or for having participated in an investigation into potential wrongdoing under this policy, you should raise a complaint under the grievance/complaints procedure that applies in your country of work. If you raise or repeat a concern which you know is false, you may be subject to disciplinary action or dismissal. The Company encourages you to first raise any concerns about wrongdoing at work internally, whether under this policy or otherwise, but we recognize that it may occasionally be appropriate for you to contact an external body such as a regulator, for example where the complaint has been raised internally but ignored or where there has been a recurrence of the same wrongdoing.

Investigation and feedback

Where concerns are raised, they will be passed to an appropriate and authorised person within the Company, which will usually be your local HR Manager (the "Responsible Person"). The Responsible Person will usually acknowledge your concern within seven days after receipt by the Superior Essex Compliance Reporting System and will arrange for an initial confidential interview with you to discuss the areas of concern. You will be asked to provide as much information and supporting detail as you can in relation to the disclosure being made. Failure to do this may hinder any subsequent investigation and raise doubts about the genuineness of your belief in that disclosure. In a limited number of cases, the Responsible Person may decide that your concern(s) are best dealt with under another internal procedure. Should this be the case then the Responsible Person will discuss with you at the appropriate time.

This policy is applicable to the extent that you raise your concern in good faith and without direct financial motive. In the event you do not meet one of the criteria specified in this policy and your concern(s) are not otherwise deemed 'whistleblowing' or a 'protected disclosure' under local law, your alert may be considered inadmissible for the purposes of this policy. In such case, you will receive a notification indicating the reasons therefor.

Depending on the nature of the concerns raised, the Responsible Person may involve internal and/ or external subject matter experts (for example the Head of HR Europe) in investigating your concerns. The Responsible Person may also reach out to Corporate & Legal department in our headquarters to discuss the appropriate outcome, although where any such discussions would be privileged they will not be able to share them with you.

We will aim to keep you informed of the progress of any investigation and we will usually provide you with feedback on the final outcome within three months of you raising your concern. The level of feedback you receive will take into account the legal obligations of confidentiality the Company has. For the avoidance of doubt, any information that you may be provided about the investigation and/ or its outcome should be considered confidential unless you are advised otherwise.

If you raise a genuine concern in accordance with this policy, you (and anyone connected with your raising of the concern) will be protected against detrimental treatment imposed as a result of raising it, in accordance with the protections granted by local law. However, doing so does not give you any right to be involved in any investigation that takes place as a result, nor does it give you the right to dictate any particular remedy or response, whether or not your concern is found to be genuine. If you believe you have suffered detrimental treatment for having raised genuine concerns about wrongdoing at work or for having participated in an investigation into potential wrongdoing under this policy, you should raise a complaint under the grievance/complaints procedure that applies in your country of work.

If you raise or repeat a concern which you know is false, you may be subject to disciplinary action or dismissal.

The Company encourages you to first raise any concerns about wrongdoing at work internally, whether under this policy or otherwise, but we recognize that it may occasionally be appropriate for you to contact an external body such as a regulator, for example where the complaint has been raised internally but ignored or where there has been a recurrence of the same wrongdoing.

To anonymously follow up on your message, please click here.