Code of Business Conduct and Ethics continued

Financial Statements and Other Records.

All of the Company’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect the Company’s transactions and must conform both to applicable legal requirements and to the Company’s system of internal controls.

Records should always be retained or destroyed according to the Company’s record retention policies. In accordance with those policies, in the event of pending or anticipated litigation or governmental investigation, please consult the General Counsel.

III. REPORTING VIOLATIONS OF THIS CODE


Illegal or Unethical Behavior.

Employees who suspect or know of a situation that may violate or lead to a violation of this Code have an obligation to report such information to the Company. Employees may report such information on a confidential, anonymous basis using the Company’s compliance reporting line by calling 800.461.9330 (toll free) in the US or Canada, calling 00.800.1777.9999 (toll free) or 720.514.4400 (collect) outside of the US or Canada or going to www.mysafeworkplace.com. In the alternative, employees may report such information to their supervisor or manager or the officer in charge of their department. If the individual to whom such information is reported is not responsive, or if there is a reasonable basis to believe that reporting to such individual is inappropriate in a particular case, then the employee should contact the Company’s General Counsel. All such communications will be kept confidential to the extent feasible, subject to applicable law.

Accounting Concerns or Complaints.

The Company’s policy is to comply with all applicable financial reporting and accounting regulations. Employees of the Company who have unresolved concerns or complaints regarding questionable accounting or auditing matters of the Company, are encouraged to report those concerns or complaints to the Company. Employees may report such concerns or complaints on a confidential, anonymous basis using the Company’s compliance reporting line by calling 800.461.9330 (toll free) in the US or Canada, calling 00.800.1777.9999 (toll free) or 720.514.4400 (collect) outside of the US or Canada or going to www.mysafeworkplace.com. In the alternative, employees may report such information to their supervisor or manager or the officer in charge of their department. If the individual to whom such information is reported is not responsive, or if there is a reasonable basis to believe that reporting to such individual is inappropriate in a particular case, then the employee should report his or her concerns to the Company’s Chief Financial Officer with a copy to the General Counsel. All such communications will be kept confidential to the extent feasible, subject to applicable law.

Non-Retaliation.

The Company prohibits retaliation of any kind against individuals who have made good faith reports or complaints of violations or suspected violations of this Code. No action will be taken or threatened against employees who submit such report or complaint unless (1) the reports or complaints were made with the knowledge that they were false or with willful disregard for their truth or accuracy, or (2) the employee was involved in the improper activity.

IV. AMENDMENT, MODIFICATION AND WAIVER

This Code may be amended or modified only by the Board of Directors of CompX. Any waiver of this Code may be granted only by the Audit Committee of the Board of Directors of CompX or other committee of the Board of Directors with specific delegated authority. Waivers will be disclosed as required by the Securities Exchange Act of 1934, and the rules thereunder, and the applicable rules of the New York Stock Exchange Amex.

ADOPTED BY THE BOARD OF DIRECTORS
OF COMPX INTERNATIONAL INC. ON
FEBRUARY 24, 2004. (Corrected November 15, 2008).

/s/ A. Andrew R. Louis
A. Andrew R. Louis, Secretary