As a member of the Winnebago Industries family, you may have access to information about Winnebago Industries that has not yet been publicly disclosed. If this information is considered to be material “nonpublic” information, many countries, including the United States, prohibit trading on the basis of such information. Information could be material “nonpublic” information if an investor would consider this information important in deciding whether to buy or sell our stock, or if it could affect the price of our stock. If you have such information, you may not trade Winnebago Industries stock (NYSE: WGO) until the end of the day following the date on which the information has been disclosed through a Securities and Exchange Commission filing, the issuance of a broadly disseminated press release or other acceptable means of public dissemination. In addition, you cannot pass this information to other persons or make recommendations about trading Winnebago Industries stock.

In addition to restrictions on trading in our stock, if you acquire nonpublic information that is material to another publicly traded company, like a competitor, supplier or dealer, the same restrictions apply. Additionally, certain management employees and members of the board of directors must comply with additional requirements when trading in our stock.

Failure to abide by insider trading laws and regulations is not only a serious violation of our Code, but may also subject you to imprisonment, fines and other penalties. You are expected to read and understand the Winnebago Industries insider trading policy. If you are uncertain as to whether you are able to freely trade, please contact the legal department.