Employee Code of Conduct

fostering greatness

Conducting Business with Integrity

Our Code

Conducting business with integrity is essential to who we are as a premium outdoor recreation company. We must always have an unwavering commitment to act in accordance with the law and the highest ethical standards, every moment of every day. Our Code of Conduct describes this commitment, outlining our shared values and expectations for ethical conduct. Our Code is here to help you understand our ethics-related policies and principles, so that we can together uphold our commitment to conducting business with integrity.

Who is Covered

The standards of ethical conduct in our Code apply to every person in the Winnebago Industries family of companies, regardless of position. This includes all employees, officers and members of the board of directors. Third parties representing us or performing work on behalf of us, including consultants, agents and contractors, are also expected to follow our Code.

 

What is Expected

Conducting business with integrity means that each one of us must take personal responsibility for understanding and upholding the policies and standards contained in our Code. It also means acting in an honest, fair and ethical manner at all times. While conducting business with integrity sounds simple, there may be times when the appropriate action is unclear. If you have questions about whether an action is lawful or complies with our Code, ask your supervisor or manager or our legal department. It is each of our obligation to report all violations of our Code and applicable law.

Waivers and Exceptions

In certain exceptional circumstances, a waiver from a provision of our Code may be appropriate. Such waivers must be approved by the legal department or, in the case of waivers applicable to any executive officer or member of the board of directors, by the board or the audit committee. Contact the legal department if you believe that an exception to our Code should be considered.

Code Interpretation

Our Code may be amended or modified only by our board of directors. Questions regarding interpretation of our Code and related policies should be first directed to the legal department.

Navigating Rough Water

If a situation arises that is not specifically addressed in our Code:

Is this situation consistent with the spirit of our Code and our values as a company?

Is this situation consistent with our status as a trusted leader in outdoor recreation and with our commitment to conducting ourselves with the highest degree of integrity, trust and respect?

Would you be comfortable if the situation or your actions were on the front page of The Wall Street Journal or local newspaper?

The Winnebago Industries Ethics Hotline is available at all times and is managed by an independent third party. The online service is an external, secure, third-party site managed by EthicsPoint.

All employees of the Winnebago Industries family of companies have an obligation to promptly report any suspected violations of this Employee Code of Conduct.

Reports can be made in person with our legal department, anonymously by calling the Winnebago Industries Ethics Hotline at 844-418-7596 or by submitting an online report here.

Purpose, Vision, Principles and Values

Working Respectfully