Code of Ethics

Our first code of ethics, "Weyerhaeuser's Reputation, A Shared Responsibility," was issued to managers in 1976. The code applies to all employees, officers of the company, and the board of directors. It is currently in its seventh edition and is issued to all employees. It is also available to customers, contractors, suppliers and the public.

The code of ethics explains the standards of conduct that employees are expected to follow. Topics covered include:

• Antitrust and competition laws
• Company assets
• Conflict of interest
• Corporate opportunities
• Employment expectations
• Employment issue resolution process
• Entertainment
• Environmental responsibility
• Full and fair disclosure
• Gifts
• Government affairs and reports
• Inside information and insider trading
• Intellectual property
• International business conduct
• Protection of employee information
• Protection of third-party information
• Safety and health
• Suppliers, contractors and customers

Regular improvements are made to our Ethics and Business Conduct program, including seven revisions of our code of ethics to address new issues or clarify company policies. In addition to receiving the code, all employees participate in ethics training on a regular basis and are expected to role-model and promote ethical behavior.

A certificate of compliance is sent to all salaried employees, including top management, to audit compliance with the code of ethics, company policy and the law. New employees are introduced to our code of ethics as part of our orientation process.

Key ethics and business conduct accomplishments in 2008 include:

• Weyerhaeuser’s CEO and President reinforced the company’s commitment to ethical business conduct and the issue resolution process in a letter to all employees in January 2008.
• We published a Supplier Code of Ethics and distributed it to key suppliers.
• We introduced anti-bribery (Foreign Corrupt Practices Act) training for salaried employees who work internationally or are in positions to have interactions with foreign government officials.
• We published a non-retaliation policy.
• We published a new company policy internal website with reformatted and easy-to-find policies.