Hercules Business Practices Policy

Dear Colleague:

This booklet summarizes some of the principles that are to guide our business actions. There are additional principles (such as honesty, integrity, and common sense) which are not summarized in this booklet but nevertheless also guide our business actions. Your own best judgment will usually be an accurate guide regarding ethical behavior. Accordingly, if something does not sound or feel right to you, please raise a question with the appropriate person(s).

Please use this Business Practices Policy and the other resources identified herein whenever it is necessary to seek information, clarification, or confirmation.

Sincerely,

Craig A. Rogerson
President and Chief Executive Officer