Snap-on Incorporated Code of Business Conduct and Ethics

Integrity - Principles - Snap-on

Snap-on's commitment to doing the right thing is encapsulated in two simple words: Integrity. Principles. These words define who we are and how we operate as a global business family. Maintaining these principles requires dedication to our values as individuals and as a corporation, upholding the highest ethical standards in all our endeavors. This begins with our people.

Every day, we make choices. Most are straightforward: right or wrong. However, in today's complex world, making the right choice isn't always clear. We need guiding principles and a framework for how we conduct our business in this demanding environment.

For over two decades, Snap-on has had this guidance in the form of an official code of conduct. As a valued Snap-on employee, please take the time to read and understand this document thoroughly.

This document contains the full text of the Code of Business Conduct and Ethics. It also provides information on how to get answers to your questions and whom to contact if you suspect a violation.

Having such a code is a legal requirement in the United States for public companies. This law applies to all employees at Snap-on, regardless of title, responsibilities, or geographic location. Many different laws regulate global companies simultaneously. There may be instances where the laws of two or more countries conflict. If you encounter such a conflict, please consult our legal department for guidance on how to resolve the situation correctly.

Thank you for your attention to this important topic and for your commitment to demonstrating the principles and spirit of this code. Through our actions, we will maintain the excellent reputation our corporation has worked so hard to build.

Thank you.
Nicholas T. Pinchuk
Chairman, President and Chief Executive Officer

Snap-on Workplace

Accuracy in Public Communications

All company personnel are obligated to assist the Company's Chief Executive Officer and senior financial officers in fulfilling their responsibilities to establish and maintain adequate and effective disclosure controls and procedures, by providing reliable and accurate information and otherwise supporting sound disclosure practices. These controls are designed to safeguard the Company and its shareholders by ensuring that material information related to the Company and its consolidated subsidiaries is disclosed in periodic reports filed with the Securities and Exchange Commission and other public communications in a full, fair, accurate, timely, and understandable manner.

What this means for me

Changes in securities laws affect how U.S. public companies disclose and certify important information. These changes help ensure that this information is communicated to all audiences in a fair, understandable, timely, and complete manner. We make every effort to communicate important news as fully, fairly, widely, clearly, and promptly as possible. What we communicate to shareholders, regulators, employees, and the general public has been and will be true. And, by law, it must be.

• Selective disclosure of information—that is, providing material information to some external parties over others—is strictly prohibited.
• Communication with the media, the investment community, and the public is the responsibility of designated company representatives.

Accuracy and Integrity of Books and Records

All company books, records, and accounts must accurately represent the transactions recorded. All company assets and liabilities must be entered on the regular books of account. No undisclosed or unrecorded funds or assets may be established. No false or artificial entries may be made. No payment may be made, or purchase price agreed upon, with the intent or understanding that any part of the payment is to be used for any purpose other than as described in the document evidencing the payment.

This policy is not limited to accounting and auditing personnel. It applies to all employees, including those who negotiate or authorize purchase agreements, prepare expense reports, or approve invoices.

Fair Dealings

The Company will engage only reputable, qualified individuals or firms as consultants, agents, representatives, or distributors under compensation arrangements that are reasonable for the services rendered. Any such agreement must be in writing.

The Company expects its employees and agents to conduct business honestly. Ignorance of this standard is never an acceptable excuse for improper conduct, nor is it acceptable for rationalizing improper conduct as being in the Company's best interest. No violations benefit the Company. You must treat customers, suppliers, competitors, and Company employees fairly. You must not unfairly take advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.

What this means for me

The Company strives to work with suppliers and other partners who share our desire to act ethically and responsibly. Regardless of whether we are dealing with external parties or with colleagues, our obligation is to be fair and to conduct business honestly. This obligation extends to how we treat our competitors. Healthy competition is one thing. Showing favoritism to friends, engaging in questionable business practices, and making "sweetheart" deals is quite another. They can spoil the Company's work environment.

Working honestly and ethically is not always easy. Especially when it means losing a customer or a potential sale. Put yourself in another person's shoes. Behave as you and your company would want to be treated.

Money Laundering

Money laundering is the conversion of money or property derived from illegal activity into money that appears to have been obtained legally. It is the Company's policy to fully comply with all applicable anti-money laundering laws in the United States and in all other countries where the Company does business. It is the Company's policy to do business only with customers who engage in lawful and legitimate business activities, and to engage in transactions with funds derived solely from legitimate business and legal sources. Snap-on will not engage in any activity that facilitates money laundering or the financing of terrorism or any other criminal activity.

What this means for me

Our business takes us to many parts of the world, as well as to most areas of the U.S. As a result, we do business with a wide range of customers, suppliers, partners, and other parties. Recent geopolitical events and terrorist activity, as well as widely publicized instances of fraud, racketeering, and other illegal activities, have placed additional emphasis on the dangerous consequences of money laundering. In light of this, you are urged to:

• Trust your instincts. If you are faced with questionable requests or transactions, alert your supervisor.
• Be alert for one-time requests or services, such as a one-time wire transfer of funds to an unauthorized party or a request to bypass company payment policies or procedures.

Equal Employment Opportunity, Employment and Labor Laws, and a Harassment-Free Work Environment

The Company is committed to providing equal opportunities for all our stakeholders and does not discriminate on the basis of race, religion, color, sex, national origin, age, ancestry, sexual orientation, veteran status, marital status, disability, or any other reason prohibited by federal, state, or local laws in the United States. The Company is committed to fostering an appreciation of the diverse cultural values of its employees. No single culture, background, or group has a monopoly on good ideas. Indeed, the rich and diverse perspectives, experiences, and backgrounds of our employees make us a stronger company, enhancing productivity and providing a real competitive advantage.

The Company requires you to comply with all employment and labor laws applicable to the operating division or office where you work. The Company believes that every employee has the right to work in an environment free from discrimination, and it is the Company's policy to maintain a work environment free from discrimination and harassment of any kind. All employees must understand both the moral and legal responsibilities associated with a respectful and harassment-free work environment.

What this means for me

Respect, dignity, opportunity. These are things every person deserves and every employee expects. Our goal is to create and maintain an environment that fosters cooperation, teamwork, tolerance, and respect. We strive for a work environment free from harassment and intimidation.

• It is our obligation to comply with all applicable laws in hiring, employment relations, and all other human resources matters. This is also good business.
• At Snap-on, promotions, advancements, promotions, bonuses, assignments, and training opportunities are based on performance and contributions—on merit.
• It is your responsibility to report any form of harassment to your supervisor. If the issue is not resolved or you are uncomfortable raising the issue with your supervisor, you should contact Human Resources or you can contact the company's ethics hotline at 866-GO-TOOLS (866-468-6657) or submit a question via the website https://workplacealertprogram.alertline.com.

Policy Against Human Trafficking and Slavery

The Company will not tolerate or condone the use of slave labor, forced labor, compulsory labor, child labor, human trafficking, or sexual trafficking by any employee, agent, subcontractor, or supplier in the performance of work or the support of our business or the manufacture and distribution of our products. For more information, please refer to the Company's Policy Against Human Trafficking and Slavery, which can be found at https://www.snapon.com/EN/Anti-Human-Trafficking.

What this means for me

Each of us is responsible for how we treat our colleagues and for monitoring how others in our supply chain treat their employees. As individuals and as a company, we are committed to strengthening and ensuring the freedom of our work environments from human trafficking and slavery.

Health, Safety, and the Environment

It is the Company's policy that all company personnel will be provided with a safe and healthy work environment. All employees are required to comply with all applicable occupational safety and health laws, as well as company rules and programs pertaining to health and safety.

The Company recognizes and believes in the importance of preserving natural resources and the world's environmental heritage. The Company believes that environmental goals can and must be compatible with economic health.

The Company is committed to protecting the quality of the environment and the well-being of people in our communities; and to implementing environmentally sound policies that focus on preventing, mitigating, and, where necessary, remediating environmental impacts on the community.

The Company can best meet its commitments to the environment, our employees, and our neighbors by adhering to the following principles of conduct:

• Conserve energy and natural resources through prudent use and reuse where appropriate.
• Work diligently toward the continuous elimination of waste and pollution at their source; otherwise, reduce, reuse, and recycle.
• Properly dispose of or effectively manage any waste that is not economically reusable.
• Design, operate, and maintain our facilities, ensuring the safety and health protection of our employees and our neighbors, including contractors and others who visit our facilities.
• Make health, safety, and the environment a priority in the development of new products and processes.
• Recognize, anticipate, respond to, and promptly communicate significant environmental aspects/impacts to employees and the community concerning our products and operations.
• Participate in public discussions of regulatory issues to advance reasonable and economical regulatory theory.
• Conduct all operations lawfully and comply with all other applicable environmental, safety, and health requirements.
• Periodically review and assess our performance against our stated goals and principles of our management system.

What this means for me

Each of us can make a difference in big and small ways. By paying attention to health and safety issues, avoiding wasteful practices, and working in such a way as to protect the environment, these and related issues are of concern to everyone. And everyone benefits from improved health, comfort, efficiency, and productivity when we diligently adhere to prudent practices.

Remember, common sense goes a long way in maintaining a safe and healthy work environment, and so does being alert. A second of inattention or carelessness—at work or away from it—can change a life forever. There is no room for a passive, careless, or inconsistent approach to something as important as our health, our safety, and our environment.

In fact, we believe it is good practice to handle air, water, and other natural resources with care.

• To ensure everyone's safety, report things like a burnt-out light bulb on a staircase. Notify your supervisor about a hazard on the factory floor or in the office.
• Conserve, recycle, and reuse whether it is paper, glass, plastic, office supplies, water, or energy. Be a good steward of the Company, community, and natural resources.
• Take care of one another, as well as the people and generations who will come after us.

Prohibition Against Retaliation

The Company prohibits retaliation for good-faith reporting of actual or potential violations of this Code, as well as for participating in investigations or proceedings related to this Code. Retaliation in any form against any Company personnel who reports a potential violation of this Code or who assists in an investigation of a potential violation of this Code is itself a violation of this Code and will be grounds for appropriate disciplinary action. In certain circumstances, criminal penalties may apply for retaliation, including fines and imprisonment.

What this means for me

Freedom of expression is an important part of the Company's culture. However, it is not always easy to file a complaint or "blow the whistle" on behavior that violates Company policy. But remember:

• The Company strongly encourages the reporting of all suspected violations of the Code of Business Conduct and Ethics.
• It is wrong to punish or otherwise mistreat a person who has filed a complaint or reported unethical behavior. There are serious penalties for doing so.
• Where possible, information about investigations into illegal, improper, or other unethical conduct is kept confidential.

Protection of Snap-on Assets

Protection and Proper Use of Company Assets

You must protect company assets and ensure their effective use in accordance with the Company's Rapid Continuous Improvement [RCI] initiatives. Theft and waste have a direct impact on the Company's profitability. All company assets must be used only for legitimate commercial purposes. For example:

• Do not use company assets that create additional expenses for the company, interfere with job duties, or violate company policy.
• Do not allow company property to be used for illegal purposes.

What this means for me

It is against this Code and against the law to steal, falsify, or destroy company assets. It is also against the Code and the law to use company property for illegal purposes. Remember, the misuse and theft of company assets are not victimless acts. Everyone pays—not just the company, but fellow employees, customers, and others.

• Treat company assets as if they were your own. Protect them, care for them, and use them to their fullest potential.
• Trust your instincts. If you are tempted to do something or are asked to do something, ask the appropriate person.

Prevention of Conflicts of Interest

You must avoid conflicts between your personal interests and the Company's interests. You must disclose any actions, financial interests, or relationships that could present an actual or potential conflict of interest, including, but not limited to, those involving (i) members of management and their families; (ii) members of the Snap-on Board of Directors, their families, and/or subsidiaries; and (iii) any company affiliates that may or may not occur in the ordinary course of business. Therefore, you must avoid any investments, interests, or associations that could interfere with or appear to interfere with the objective or independent exercise of your best judgment or the performance of your duties in the Company's best interest.

Specifically, you must:

• Deal with all suppliers, customers, competitors, other employees, and all other parties who do business with the Company fairly and objectively without personal financial gain or advantage;
• Do not accept or provide any gifts, entertainment, or other benefits to any supplier, customer, or competitor, including payments or credits, except as expressly permitted by this Code;
• Do not hold a financial interest, hold a job, or hold a management position in any firm or corporation that is a competitor or that does or seeks to do business with the Company, if that interest or position could influence any decision in the performance of your duties; and
• You must not seek or accept, offer, or give any payments, fees, credits, services, or gifts to any person or firm as a condition of, or in return for, doing business with the Company. The Company's policy does not prohibit gifts of nominal value (up to $50 USD). Normal business meals and entertainment (such as attending sporting or cultural events), as well as similar customary and reasonable expenses to foster goodwill, are also acceptable, even if their cost exceeds $50, as long as they are accompanied by a company host.

Expenses for gifts and entertainment exceeding nominal value must be approved in writing by your supervisor. The policy regarding gifts and entertainment does not apply to sales contests and incentive trips for the Company's benefit. Company employees must approve such programs in writing. All such contests and incentive trips must be conducted fairly and in accordance with applicable laws and are subject to Company policies related to the approval of business expenses. In relation to gifts and entertainment of public officials or employees, this policy is subject to the provisions of "Ethics and Compliance in the International Community" described in this document.

The Company's goal is to compete in the marketplace by providing excellent products and services at competitive prices. No payment or anything of value in any form may be provided, directly or indirectly, to anyone anywhere in the world for the purpose of obtaining or retaining business or for obtaining any other favorable action.

What this means for me

The guiding principle is judgment. The Code requires each of us to conduct ourselves in a manner that will withstand scrutiny. We must be above board, equitable, fair, and consistent in our dealings with colleagues, suppliers, customers, and others with whom we do business. For example, it goes without saying that accepting or giving gifts of more than nominal value can alter business relationships, leading to indebtedness and favoritism. For many reasons, it is best to avoid such situations.

If you have questions about business or outside activities, do not hesitate to speak with your supervisor or the Company's legal counsel. Keep in mind that many outside activities and affiliations are permissible as long as you have informed the Company and received your supervisor's approval.

• Avoid any business activities or relationships that violate the standards of fairness.
• Our loyalty must be to the Company.
• Disclose any interests or activities that may conflict—or appear to conflict—with your job or the Company's business.
• If a vendor offers gifts or entertainment, consult your supervisor to determine if it is appropriate to accept.
• Avoid even the appearance of a conflict of interest.
• If you have any questions, do not hesitate to ask.

Corporate Opportunities

You must not take for yourself opportunities discovered through the use of Company property, information, or your position for personal gain or to compete with the Company. It is your obligation to advance the Company's legitimate interests when the opportunity arises to do so, and not to engage in activities that harm the Company's interests.

What this means for me

The message here is similar to what is found throughout this guide. We, as employees, must maintain high standards of conduct. This includes not taking advantage of personal opportunities that we may encounter in the course of doing business. These opportunities may take many forms, including the use of company property and the exploitation of your job or authority.

• Remember that our loyalty must be to the Company.
• It is wrong to compete with the Company in any way.
• Do not take advantage of personal information to which you are exposed as a result of your position with Snap-on.

Trading in Securities

Except as specifically permitted by applicable law, you may not buy, sell, transfer, or otherwise acquire or dispose of any Company securities while in possession of material, non-public information about Snap-on. You may not buy, sell, transfer, or otherwise acquire or dispose of any securities of any other company while in possession of material, non-public information relating to that company.

You may not "tip" or disclose (intentionally or unintentionally) material, non-public information in any manner, orally, or in writing, including via social media, (i) about Snap-on to any person outside the Company, unless it is required in the course of your regular duties for Snap-on, or specifically authorized by the General Counsel, or (ii) about any other public company to anyone that you have obtained in the course of your relationship or duties with Snap-on.

"Material information" is information that a reasonable investor would consider important in making an investment decision to buy, hold, or sell securities or the securities of another company. Simply put, material information is any type of information, positive or negative, that, if publicly disclosed, could reasonably be expected to affect the market price of securities or influence investors' decisions regarding a security. "Material information" includes, but is not limited to, the Company's annual and quarterly earnings or profits; changes in dividend rates or policies; potential mergers, acquisitions, or sales; changes in senior management; information about significant new products, contracts, or orders; significant changes in product volume, market share, or pricing; and actual, threatened, or potential litigation, or the resolution of significant lawsuits.

"Non-public information" is information that has not been disclosed to the market. Information is considered "non-public" until it has been widely disseminated to the public through a filing with the Securities and Exchange Commission ("SEC") filing, a press release, or other means of disclosure reasonably designed to provide broad public access, and sufficient time has passed for the market to digest that information.

In the United States, employees can find the Company's insider trading policy in the policies section on the legal page of the intranet. What this means for me The SEC regulates all U.S. public companies, including Snap-on Incorporated. In addition, various stock exchanges and other regulatory bodies have their own rules that member companies must follow. The SEC asks companies to identify official "insiders"—typically senior business officials. These individuals may buy and sell company stock only during specific periods.

Confidential and Proprietary Information

What does this have to do with the rest of us? It follows: The designation of an insider may apply to any employee who has access to material information that has not been publicly disclosed.

Here's how to determine if company information is material: if knowledge of it would encourage someone to buy or sell securities.

• You cannot trade on material company information that has not been publicly disclosed. Ignorance of the law is no excuse.
• Securities laws are strictly enforced by the SEC.
• Penalties for securities violations are severe and can include imprisonment.
• If you have questions about any planned purchase or sale of securities, please contact the legal department.

If you are entrusted with confidential knowledge and information about the Company, you must keep that information secret. Disclosure of such information could harm the Company or give unfair or illegal advantage to competitors, investors in our stock, or others. You must guard against the improper or premature disclosure of confidential information to outside parties or to employees who do not need the information to perform their jobs.

Confidential information may include information about employees, products, technologies, financial matters, customers, suppliers, and competitors; long-term plans; trade secrets; business plans, including potential acquisitions and sales; manufacturing systems and procedures; research and development work; and computer data that is not publicly available or in the public domain. The use of confidential information for personal gain by an employee or anyone else is contrary to these principles and, in many cases, may be against the law.

Communication with the media, the investment community, and the public is the responsibility of designated representatives within the Company. Snap-on provides electronic communication tools to enhance productivity and allow employees to perform their jobs effectively and with quality. Electronic communications include all aspects of voice, video, and data transmission, such as voice mail, e-mail, text messaging, instant messaging, social media messaging, EDI (electronic data interchange), fax, Internet, and intranet services. Because these technologies allow for the rapid dissemination of information to a broad audience, you must guard against disseminating confidential information through any electronic communication. The practice of electronic communications is outlined in the Policy, Practice, and Procedures Guide.

Trade Names and Logos

You must safeguard against the accidental disclosure of confidential information by avoiding public discussion of company matters or working on confidential documents in public places, such as airplanes.

Snap-on trade names and logos must be used only in accordance with Company policy and only in accordance with lawful business. For employees in the United States, please refer to Policy E-6, Policy, Practice, and Procedures.

What this means for me

Virtually everyone in the Company has access to confidential information. Virtually every employee can be considered an insider of the Company. That is why it is so important that every employee knows about the potential misuse and abuse of confidential materials. It is easy to lose perspective on what is and what is not confidential and proprietary information. What might seem like an innocent statement—for example, a comment to a neighbor about your company's strong quarterly results before those results have been released—could expose individuals and the business to significant penalties. Similarly, what might seem like "safe" use of company information—for example, sharing the company's strategic plan with a consultant before that person has signed a confidentiality agreement—could harm a number of parties, including colleagues, shareholders, and customers.

And, as noted in the previous section, employees who possess inside information cannot buy or sell company stock before that information is publicly disclosed.

• The stakes are high. Know the laws and how they apply to you.
• Pay special attention to sensitive company material, ensuring it is properly protected. Consider the consequences of leaving private records in plain view or forgetting to "password protect" certain electronic files.
• Be careful when engaging in business discussions in a public place, such as a restaurant, train, or lounge. You never know who might be listening.
• Be careful when discussing confidential information on a mobile phone. If possible, use a landline.
• Route media inquiries to designated company representatives.
• Understanding Company policies, exercising good judgment, and acting with integrity are the best protection.
• If you have questions about confidential company information, consult your supervisor or the legal department.

Global and Ethical Competition

Ethics and Compliance in the International Community

The Company strives to maintain high standards of business conduct in the United States and abroad. The Company and its employees must comply with all national and local laws of the countries in which the Company does business, applicable international and intergovernmental rules, and all U.S. laws that apply to international activities. If the material provisions of a local law are more restrictive than the Code, you must comply with the local law. Your business may have policies and practices that are more demanding than this Code, and the same may be true for local law; in these cases, you must adhere to the stricter code, policy, practice, or law.

In the event the Code is translated into local languages and there is a conflict between the English version and the local language version, the English version of the Code controls. If you do business outside the United States, it is your responsibility to understand the laws and regulations of each country in which you operate and to be aware of subsequent U.S. laws and regulations. Violating these laws can result in significant penalties, imprisonment, and severe restrictions on the Company's ability to do business.

The Foreign Corrupt Practices Act (FCPA); the UK Bribery Act; the Organization for Economic Co-operation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Convention); {{ FCPA, the EC Convention, and the OECD Convention (and the ratification of legislation adopted by signatories to the OECD Convention and the EC Convention, which include many countries in which the Company currently does business) make it a crime to promise or give anything of value to a public official or political party for the purpose of obtaining or retaining business or obtaining any improper advantage. It is also illegal to make payments to agents, sales representatives, or other third parties when you have reason to believe that your payment will be used illegally. The UK Bribery Act not only prohibits bribery of both domestic and foreign public officials but also prohibits bribery in the private sector. Every employee, officer, and agent of the Company must keep records that reflect all transactions and the acquisition and disposition of Company assets for both domestic and foreign business activities.

Supplier Code of Conduct and Labor Practices

Child, prison, and forced labor are not permitted with any business partner or supplier. It is the responsibility of all of us to ensure that our business partners and suppliers, when providing services for, from, or on behalf of Snap-on, comply with Snap-on's Supplier Code of Conduct, which includes, but is not limited to:

• Suppliers will not engage in or condone the use of child labor, complying with all applicable local child labor laws and hiring only workers who meet the minimum age requirements for their location.
• Suppliers will not engage in or condone the use of forced or compulsory labor. Suppliers will not engage in any form of human trafficking, whether by force, fraud, or coercion; or any form of forced servitude or slavery; or any form of sexual trafficking or the acquisition of any commercial sexual act.
• Suppliers will treat their employees with dignity and respect, and will not permit or condone any form of harassment, complying with all applicable local laws. Suppliers will not charge recruitment fees for employees and must not use recruiters who do not comply with the local labor laws of the country in which the recruitment takes place.
• Suppliers who provide housing for their employees must ensure safe and healthy conditions that meet the housing and safety standards of the host country.
• Suppliers who use subcontractors to provide goods and services to Snap-on will also be responsible for the subcontractor's compliance with this Code of Conduct.

To read the full Snap-on Supplier Code of Conduct, please visit the following link: https://www.snapon.com/EN/Suppliers/Supplier-Code-of-Conduct.

Trade Restrictions

The U.S. maintains strict embargoes that prohibit and restrict lesser sanctions, commercial operations with certain countries, government entities, organizations, and individuals. For current lists of these countries, government entities, organizations, and individuals, please contact the legal department.

Boycott Laws

All operations, including foreign subsidiaries, must comply with U.S. laws regarding foreign boycotts. Cooperating in any boycotts between foreign countries is illegal unless those boycotts are sanctioned by U.S. law. The Company must:

• Refuse to do business with any blacklisted country, company, or individual.
• Respond to requests from boycotting countries for information about our business dealings with boycotted countries or companies or individuals.

Report all requests for boycott support or information related to boycotts to the legal department.

Treasury Sanctions / Specially Designated Nationals Lists

The Office of Foreign Assets Control of the Department of the Treasury prohibits U.S. companies and their foreign subsidiaries from doing business with certain countries, agencies, and certain individuals, including specially designated terrorists, narcotics traffickers, and government entities that are owned or controlled by embargoed countries. The rules and their application to foreign subsidiaries vary by country and type of transaction, and they are often changed as U.S. foreign policy changes.

If you become aware of any sensitive political issues with a country in which the Company operates or is considering doing business, please consult the legal department.

Export Control Restrictions

To prevent the transfer of controlled goods, technology, and software into the wrong hands, the export of these products and technical information to certain countries or individuals is restricted. These restrictions may also apply to translations between the Company and its foreign subsidiaries; the nature of the product, the country of destination, and the foreign purchaser or consignee are controlling factors in whether a U.S. export license will be required before shipment.

"Export" is defined as any means of transferring products or data to foreign individuals or companies in oral, electronic, or written form, including sales, training, and consulting, as well as product promotion, even if these activities take place in the U.S.

Because these control restrictions are intended to promote U.S. foreign policy and national security objectives, they may be subject to change. Obtain technical and legal guidance to determine applicable regulations before exporting such goods or technology.

What this means for me

We believe there is an opportunity to do business in non-U.S. countries. Countries carry a dual responsibility: to comply with the laws of each country in which we operate and to conduct ourselves in accordance with the highest ethical standards. U.S. citizens and foreign subsidiaries of Snap-on must comply with all U.S. trade laws wherever they operate. Also, please be aware that the U.S. government prohibits U.S. companies and their foreign subsidiaries from doing business with parties that threaten our national security. The wave of terrorist activity worldwide has intensified this concern.

Antitrust Laws

It is important that we understand and comply with the laws of the localities in which we operate. Violations can lead to severe penalties. It is against the law and our Code to offer gifts to foreign officials or other parties—whether to win, retain business, or gain an unfair advantage over others. To protect yourself and Snap-on, do not participate in a boycott that the U.S. has not approved. Familiarize yourself with the current list of countries subject to boycott. Be aware of the countries, businesses, and individuals with whom the U.S. government prohibits us from doing business. Lists of restricted countries and prohibited parties must be consulted before doing business with foreign countries and their citizens. It is also important not to forget export control restrictions. These restrictions and the situations to which they apply may change.

The Company supports a policy of compliance with applicable laws governing relationships with competitors, which in some countries are known as antitrust laws. U.S. antitrust laws govern the conduct and transactions of the Company in relation to competitors, customers, and suppliers. Other countries in which the Company does business may also have antitrust laws that apply to the Company. The Company and its employees may be subject to severe criminal and civil penalties if an employee sanctions or participates in a violation of antitrust laws. Therefore, it is important to understand and strictly adhere to Company policy so that the Company and its employees can avoid even the appearance of violating antitrust laws.

To avoid activities that could be interpreted as violations or lead to accusations of violating antitrust laws, you must not engage in practices prohibited by Company policy, including the following activities:

• Reaching an understanding or making an agreement with competitors to limit competition by establishing price levels or terms of sale, restricting production, or establishing joint procedures regarding distribution, territory, or customers. Such activities are contrary to law.
• Entering into unauthorized agreements or contracts that provide for exclusive dealing, sales, or other restrictive arrangements with customers or suppliers. Some arrangements, such as dealer call lists and sales territories for representatives that are approved by the Company, may, of course, be put into place, but arrangements or programs that are not currently used by the Company must be approved in advance, upon recommendation of the Company's legal counsel. Furthermore, price differences or other terms of sale between customers, as well as quantity discounts, may not comply with the law and should not be implemented without consultation with the Company's legal counsel.

Political Activity and Contributions

We encourage all employees to participate fully in the political process, as individuals, and to make voluntary contributions to candidates of your choice.

Direct Company contributions to political parties or for the benefit of candidates for federal, state, or local office are illegal and strictly prohibited. The Company's policy also does not contribute to organizations whose primary purpose is to support and promote specific political parties or candidates.

Employees who engage in political activity must make it clear that they are not acting for or on behalf of Snap-on Incorporated. The Company cannot and will not endorse any political candidates or parties.

What this means for me

When it comes to government participation, Snap-on encourages employees to be active in the political process. The Company asks that such participation be conducted on your own time; that Company resources not be used; that the Snap-on name not be used; and that Snap-on's endorsement not be implied.

Compliance and Accountability

You must comply with this Code and all other Company policies and procedures in all respects. To the extent permitted by law under applicable local law: (1) the Company may require you to sign a certification that confirms compliance with the policies set forth in this Code; and (2) any employee who provides a certification that contains a false statement or material omission, or who knowingly violates this Code or knowingly permits subordinates to do so, shall be subject to disciplinary action, including demotion or termination.

Certain employees are required to complete web-based training modules that cover this Code and ethics in general. For questions not related to the Code, including any customer service questions or concerns, please submit them by calling the numbers listed in the following link, https://www.snapon.com/EN/Contact-us, or at www.snapon.com by selecting the "Contact Us" link at the bottom of the web page.

For questions or disputes of a franchisee, the Ombudsman Program provides an opportunity to confidentially discuss with an ombudsman who is independent and neutral. The purpose of the Human Rights Committee is to help resolve disputes with franchisees. More detailed information is provided at https://www.snapon.com/mall/US/FranchiseRelations.htm or by calling 800-786-6600, extension 5506.

Questions

Questions about situations not covered in this document should be addressed to your supervisor, the legal department, or the corporate human resources department.

The Code of Business Conduct and Ethics is not intended to provide contractual rights of any kind to any employee or other person identified therein, or to create any contractual obligations of any kind for the Company. As the Company's purposes related to the Code of Business Conduct and Ethics may change, the Company reserves the right to amend the Code of Business Conduct and Ethics at any time, with or without prior notice.

Snap-on Incorporated
2801 80th Street
Kenosha, Wisconsin 53143

Snap-on is a trademark of Snap-on Incorporated; All rights reserved. ©2025 Snap-on Incorporated