Graco Inc.

CEO Letter to Employees on Ethics

Dear Graco Employee: 

Graco is committed to conducting business with the highest degree of ethics, integrity, and compliance with laws worldwide. Graco’s Code of Ethics and Business Conduct (“Code of Conduct”) reflects this commitment and is available on Graco’s website for your reference. The Code of Conduct is also available in booklet form. 

Graco’s Code of Conduct provides our directors, executive officers, and employees with the policies that govern our global business and the tools necessary to make sound business decisions. The Code of Conduct is an extension of our values and is a foundation for our long-term success. The Code of Conduct goes beyond complying with laws, expecting Graco employees to be honest and conduct themselves with integrity. When faced with a difficult situation, you should ask yourself, “What is the right thing to do?” 

The Code of Conduct is designed to help you act according to the Company’s high ethical standards. It is important that you understand and follow the Code of Conduct, comply with all applicable laws, and refrain from business situations that would jeopardize Graco’s integrity. 

An important component of corporate ethics and compliance with laws is accuracy and completeness of financial reports. The Audit Committee of the Board of Directors oversees the preparation and audit of our financial reports. As part of this duty, it is vital that the Audit Committee have access to information indicating any irregularities or problems that could result in those reports being inaccurate. Therefore, the law requires the company to have a complaint procedure allowing anyone to bring any accounting, internal control or auditing issues to the attention of the Audit Committee. 

Every Graco employee is encouraged to report any known or suspected accounting, internal control, or audit irregularity. This can be done by directly writing or calling the Vice President, General Counsel, and Secretary, Karen Gallivan (612-623-6604) who will receive the complaint confidentially on behalf of the Audit Committee. You may email gracoauditcommittee@graco.com. You may also contact the Graco Ethics Hotline at 1-877-846-8913 to report any accounting, internal control, or auditing irregularity. A third-party vendor runs the multi-lingual, confidential Graco Ethics Hotline. The hotline is available 24 hours per day, 7 days per week. 

The hotline may also be used to report any violation of the Code of Conduct. If you know of, or suspect, a violation of the Code of Conduct or any law, we encourage you to promptly and fully report the matter. You may also report the matter by contacting your supervisor, contacting the Legal Department at 612-623-6604 or legal@graco.com, or emailing ethics@graco.com. All reports of suspected violations will be thoroughly investigated, confidentially to the extent possible. Reports go to Graco’s Vice President, General Counsel, and Secretary. An investigation will be conducted as discreetly as possible and will be reported to the Audit Committee as appropriate. 

There will be no reprisals against any employee reporting a violation or suspected violation in good faith. You may remain anonymous if you wish. Remember that the Graco Legal Department, Human Resources, and your supervisor provide help with ethics and compliance questions. 

Ethics and compliance with laws are vital to Graco’s future success. Please do your part by reporting any issues or problems that come to your attention. 


Patrick J. McHale
President and Chief Executive Officer
Graco Inc.