As part of our commitment to act in the best interests of our company, we should always avoid conflicts of interest. A conflict of interest occurs when our private interests or actions interfere – or even appear to interfere – in any way with the interests of our company.

Conflicts commonly arise in situations such as:

• Exchanging gifts and entertainment
• Conducting business with or supervising family members or friends
• Participating in outside business interests or employment outside of our company
• Taking personal advantage of corporate opportunities that our company might be interested in pursuing

We have a duty to carry out our responsibilities with the utmost respect for and loyalty to our company. In fulfilling this duty, we must avoid situations that create actual or potential conflicts in which our actions or loyalties are divided.

If your job responsibilities include buying or leasing materials and services on behalf of Timken, you must do so objectively. Never accept or seek any benefit from a supplier or potential supplier that would appear to compromise your judgment.

To preserve the best interests of our company, we must never:

• Hold a significant financial interest in one of our company’s customers, competitors or suppliers
• Enter into personal transactions with our customers or suppliers on terms other than those generally available to the public or our company’s associates
• Invest in customers, suppliers or competitors that are not publicly traded
• Make or receive a loan or credit from any of the company’s customers, competitors or suppliers or from a director, officer or associate of a customer, competitor or supplier, other than in the ordinary course of our company’s business
• Engage in any other non-company-related activities during our work hours, or use company supplies or equipment in other employment or activities