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Although the terms of such agreements may vary based upon the relationship between the parties, the transaction at hand, and the local jurisdiction, each written agreement shall attach and incorporate the Terms and Conditions of Ethical Business Practices contained at Exhibit B hereto and each third-party contractor must agree in writing to abide by same.

Attached hereto as Exhibit C is a list of Red Flags to be aware of when retaining and doing business with third-party contractors. The presence of any of the Red Flags listed in Exhibit C should be brought to the attention of the Legal Department. You should not retain or do business with any third-party contractor where any of the listed Red Flags are present without first consulting with and obtaining the written approval of the Company’s Legal Department.

V. Enforcement of FCPA Policy

Every Company employee, agent or representative whose duties are likely to lead to involvement in or exposure to any of the areas covered by the FCPA is expected to become familiar with and comply with this FCPA Policy. Periodic certifications of compliance with the Company's FCPA Policy will be required, as will participation in training sessions as instructed by management.

It is the individual responsibility of each officer, employee, and agent of the Company, whose duties are likely to lead to involvement in or exposure to any of the areas covered by the FCPA, by action and supervision as well as continuous review, to ensure strict compliance with this FCPA Policy. The Company may take severe disciplinary action, up to and including dismissal, against any officer, employee or consultant who violates this FCPA Policy.

Any officer or employee who suspects or becomes aware of any violation of the FCPA Policy shall report the violation to his or her supervisor, who will immediately advise the Legal Department, who shall cause an investigation of the reported matter to be conducted. In the alternative, any officer, employee or agent who suspects or becomes aware of any violation of this FCPA Policy, may report the suspected violation to the Company's Confidential Hotline.

If you have questions or problems concerning this FCPA Policy, foreign officials or payment practices you should contact the Company's Legal Department at:

TriMas Corporation
Attn: Joshua Sherbin
General Counsel
39400 Woodward Avenue, Ste 130
Bloomfield Hills, MI 48304
Telephone: (248) 631-5497
Facsimile: (248) 631-5413

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