Corporate Compliance Policy Manual

All employees of Tenneco Inc., and each of its subsidiaries (the "Company"), are expected to be guided by the basic principles of honesty and fairness in the conduct of the Company's affairs. Enforcement of sound ethical standards is the responsibility of every director, officer and employee of the Company. The purpose of this Corporate Compliance Policy Manual ("Manual") is to state the principles of business conduct that the Board of Directors requires of each of its members as well as all officers and employees of the Company. The Manual outlines specific guidelines for conduct in situations that affect all employees. Such principles and guidelines are to be adhered to at all times and under all circumstances and are applicable to all directors, officers and employees of the Company.

• ANTITRUST (TA 1-100)
• PROTECTION OF COMPANY INFORMATION (TA 2-100)
• CONFLICT OF INTEREST POLICY (TA 3-100)
• DISSEMINATION OF CORPORATE INFORMATION (TA 4-100)
• DISCLOSURE CONTROLS AND PROCEDURES (32-100)
• ELECTRONIC MEDIA (TA 5-100)
• ENVIRONMENT, HEALTH AND SAFETY
• EXPORT CONTROLS AND EMBARGOES (14-100)
• INTERNAL ACCOUNTING CONTROLS (15-100)
• FOREIGN CORRUPT PRACTICES ACT (16-100)
• FOREIGN ECONOMIC BOYCOTTS (17-100)
• GIFTS AND ENTERTAINMENT (18-100)
• GOVERNMENT INVESTIGATIONS AND LEGAL CONDUCT (19-100)
• TRADING IN TENNECO SECURITIES (20-100)
• COMPANY SPONSORED CLUB MEMBERSHIP (21-100)
• COMMUNITY AFFAIRS (22-100)
• POLITICAL CONTRIBUTIONS AND GOVERNMENT AFFAIRS (23-100)
• CORPORATE PURCHASING POLICY (24-100)
• PURCHASING (25-100)
• NATIONAL PURCHASE AGREEMENTS AND PROGRAMS (26-100)
• FOREIGN TRANSACTIONS (27-100)
• PURCHASING FROM MINORITY BUSINESS ENTERPRISES (28-100)
• SEPARATION OF FUNCTIONS - REQUISITIONING, PURCHASING, RECEIVING AND DISBURSING (29-100)
• PURCHASING ETHICS (30-100)
• PAYMENTS TO GOVERNMENT OFFICIALS OR EMPLOYEES (31-100)

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