Business Conduct Policy

Securities Trading and Disclosure Policy

November 2006

Business Conduct Policy – Questions or Concerns

Dear Republic Employees,

Critical to Republic Engineered Products success is the way in which we conduct ourselves as we do business. Each of us must strive to handle the business affairs of the Company in an ethical as well as legal manner. Not only does the Company have a stake in your and my proper conduct, but also to the extent any of us engages in illegal activities we expose ourselves and the Company to criminal prosecution.

Thus, in an effort to remind us of what is expected of us by Republic and also to clearly state what conduct will not be permitted or tolerated, the attached Business Conduct Policy has been adopted. Republic's Business Conduct Policy illustrates the shared accountability each of us has in respect to conducting business with honesty and integrity.

In today's global market, it is often difficult to keep up with the new challenges our organization faces or to adequately deal with all complex situations. Nobody has all the answers. But we do know that the best answers will evolve in an organization whose guiding values are known, and where an environment is cultivated that supports ethically sound behaviors.

You should never hesitate to ask a question or report a concern. If you become aware of a situation in which you believe Republic's ethical and legal guidelines have been violated or if you feel you are being pressured or being asked to compromise your values, it is your responsibility to communicate this concern to the Company. It is important for you to know that you will not be disciplined, lose your job or be retaliated against in any way for asking questions or voicing concerns about our ethical or legal obligations, as long as you are acting in good faith. Good faith does not mean that you have to be right – but it does mean that you believe you are providing truthful information.

Jaime Vigil President and CEO

John A. Willoughby Vice President, Human Resources and Corporate Relations