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IMC BERKSHIRE HATHAWAY INC.
CODE OF BUSINESS CONDUCT AND ETHICS
INT’L METALWORKING CO.
A. Scope.

This Code of Business Conduct and Ethics applies to all Berkshire Hathaway directors, officers
and employees, as well as to directors, officers and employees of each subsidiary of Berkshire
Hathaway. Such directors, officers and employees are referred to herein collectively as the
“Covered Parties.” Berkshire Hathaway and its subsidiaries are referred to herein collectively as
the “Company.”

B. Purpose.

The Company is proud of the values with which it conducts business. It has and will continue to
uphold the highest levels of business ethics and personal integrity in all types of transactions and
interactions. To this end, this Code of Business Conduct and Ethics serves to (1) emphasize the
Company’s commitment to ethics and compliance with the law; (2) set forth basic standards of
ethical and legal behavior; (3) provide reporting mechanisms for known or suspected ethical or
legal violations; and (4) help prevent and detect wrongdoing.

Given the variety and complexity of ethical questions that may arise in the Company’s course of
business, this Code of Business Conduct and Ethics serves only as a rough guide.
Confronted with ethically ambiguous situations, the Covered Parties should remember the
Company’s commitment to the highest ethical standards and seek advice from supervisors,
managers or other appropriate personnel to ensure that all actions they take on behalf of the
Company honor this commitment. When in doubt, remember Warren Buffett’s rule of thumb:

“…I want employees to ask themselves whether they are willing to
have any contemplated act appear the next day on the front page of
their local paper – to be read by their spouses, children and friends
– with the reporting done by an informed and critical reporter.”

C. Ethical Standards.

1. Conflicts of Interest.

A conflict of interest exists when a person’s private interest interferes in any way with the
interests of the Company. A conflict can arise when a Covered Party takes actions or has
interests that may make it difficult to perform his or her work for the Company objectively and
effectively. Conflicts of interest may also arise when a Covered Party, or members of his or her
family, receive improper personal benefits as a result of his or her position at the Company.
Loans to, or guarantees of obligations of, Covered Parties and their family members may

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