CORPORATE RECORDS RETENTION POLICY TRAINING By: Diana C. Toman, Corporate Counsel & Assistant Secretary

Corporate Records Retention Policy Training PRESENTATION OUTLINE  Purpose of the Corporate Records Retention Policy and Revisions  Scope and Structure of the Policy  Definition of “Record”  The Retention Schedule  Retention  Procedures: Records Hold Orders; Records Destruction Authorization; and Request for Guidance/Exception  Responsibility and Enforcement  2008 Records Retention Initiative  Question/Answer Period

Corporate Records Retention Policy Training  Purpose of the Policy  Purpose of Policy:  to establish a current and legally-compliant process for identifying, retaining, storing, protecting, retrieving, and disposing of records which are necessary for the operations, legal, fiscal and historical purposes of Gardner Denver, Inc.

 Scope and Structure of the Policy  Scope:  The Policy applies to all divisions, subsidiaries, locations, and corporate departments of the Company worldwide  Thus, ALL employees worldwide must follow the Policy  Structure:  The Policy consists mainly of three parts:  (1) the body of the policy, which sets for basic rules and procedures on records retention; and  (2) two separate retention schedules, one designated for US Company locations and the other designated for international Company locations (Exhibits A & B, respectively)  (3) Exhibits C-E implementing the various procedures outlined in the Policy Corporate Records Retention Policy Training

 Definition of “Record”  “A ‘record’ is any form of recorded information, which may be in the form of paper, pictures, drawings, schematics, designs, microfilm, audiotapes, photographs, slides, or any purely electronic or computer- readable medium, including but not limited to, electronic messages and attachments, computer tapes or disks (including any backup tapes or disks), compact disks or optical disks, which relates to the business of the Company and falls within a category reflected on the Corporate Records Retention Schedules.” (Policy, p. 1, Sect. III.)  Definition is intended to be broad to encompass all data generated or received by the Company  Includes material not normally thought of as “records storage” such as material on QuickPlace sites  Does not include transitory documents  If in doubt, err on side of identifying as a record subject to Policy

Corporate Records Retention Policy Training  The Retention Schedules  Two separate schedules – one for US; one for all international locations (Exhibits A & B, respectively)  If in conflict with local law, use Request for Guidance/Exception  Generally the schedules are divided into 17 substantive categories with retention periods ranging from one year to permanent retention  The categories are NOT intended to be completely exhaustive  A general “catch-all” category is also included in the schedules, as are similar sub-categories in each of the 17 primary categories  Company managers should use their sound business judgment in determining which category and subcategory a Record falls into  Any questions, inconsistencies, or clarification can be obtained through the Request for Guidance/Exception process

Corporate Records Retention Policy Training

 Retention  “ System” is any material accessed through the user’s program (Lotus Notes, MS Outlook, etc.) – this includes archives  Individual users must remove all from the System within 18 months of creation or receipt of the same  that standing alone qualifies as a Record for purposes of the Policy must be retained outside of the system in accordance with the periods set forth in the Retention Schedule  Automated destruction solutions are being evaluated for use in the later half of 2008  Legal, IT, and/or Internal Audit Departments may implement routine audits to review user compliance at any time

 Retention Improvements  Barracuda - Stores all s sent or received through Quincy Server  Employees can access all sent or received through Lotus Notes for 18 months  On-Base storage of s constituting records  Categories are set out to mirror the Policy Corporate Records Retention Policy Training

 Procedures: Records Hold Orders  Records Hold Orders:  Exhibit C to the Policy  Used to effect a suspension of the destruction of any particular type or set of records required to be retained as a result of litigation, an audit, or otherwise  Can only be issued by the Corporate Legal Department  The Corporate Legal Department will directly forward such Records Hold Orders to the heads of the Company office(s)/facility(ies) where the records are located.  Division, subsidiary, Company location, and corporate department heads must adhere to all Records Hold Orders issued by the Corporate Legal Department  Valid until removed by the Corporate Legal Department

Corporate Records Retention Policy Training  Procedures: Records Destruction Authorization  Records Destruction Authorization:  Exhibit D to the Policy – available in Word format through Lotus Notes  All Records that have been retained for their required period of retention must be destroyed by incineration, shredding, or permanent electronic destruction  Must be completed and routed to the Corporate Legal Department for approval before any Record required to be retained under the Retention Schedule for longer than 2 years is destroyed  To be completed by the lead director/manager of the division, subsidiary, location or corporate department requesting destruction of the Records  Records designated by the Retention Schedule to be retained for a period of 2 years or less may be destroyed upon approval of the appropriate division, subsidiary, location, or corporate department head

Corporate Records Retention Policy Training

 Procedures: Request for Guidance/Exception  Request for Guidance/Exception:  Exhibit E to the Policy – available in Word format through Lotus Notes  Any question concerning a specific record, a retention period, the destruction procedure, or any other issue relating to the Policy should be addressed using this procedure  Can be used to obtain an exception from the Policy’s requirements upon good cause shown  Submitted to the Corporate Legal Department for its consideration and response  May be submitted by any employee at any time

Corporate Records Retention Policy Training  Responsibility and Enforcement  Operations:  Monitor their division’s, subsidiary’s, location’s, or corporate department’s compliance  Advise the Corporate Legal Department of suggested revisions to the Policy  Follow appropriate destruction procedures as outlined in the Policy  Adhere to any Records Hold Orders issued  Corporate Legal Department:  General oversight of the Policy and its procedures  Periodic review and revision of Policy and Retention Schedules  Review and approve all Records Destruction Authorizations  Review and counsel on all Requests for Guidance/Exception  Implement, monitor, and withdraw Records Hold Orders as needed  Issue quarterly reminders on compliance

Corporate Records Retention Policy Training  Responsibility and Enforcement (Cont.)  Corporate IT Department:  Ensure proper retention and accessibility to all “live” and “archived” electronic data  Support electronic signatures and procedures of the Policy  Provide assistance and support with Records Hold Orders and audit procedures  General:  Failure to comply with the terms of the Policy may result in severe civil, criminal and other penalties, including potential charges of obstruction of justice and spoliation of evidence, significant monetary penalties, and other sanctions against the Company and/or the employee  Material breaches of the Policy by an employee may result in additional or alternative sanctions by the Company, including up to termination of employment

Corporate Records Retention Policy Training  2008 Record Retention Initiative  Gardner Denver and Iron Mountain have developed a new business partnership for records management at all Gardner Denver locations. The new partnership provides consistent national pricing to all of our locations for the off-site storage of business records and document destruction.

Corporate Records Retention Policy Training  Questions?