Page 17 - EthicsCode

IMC Although not all Covered Parties are expected to know the details of these laws, it is important to
know enough about the applicable local, state and national laws to determine when to seek
INT’L METALWORKING CO. advice from supervisors, managers or other appropriate personnel.

The document “Prohibited Business Practices Policy” sets forth the Company’s policy on
compliance with laws, specifically addressing such topics as prohibited offers or payments,
gifts and entertainment, transactions with certain countries and persons, accounting controls,
and accurate record-keeping. This Policy is furnished to senior managers and available to
all employees.

8. Timely and Truthful Public Disclosure.

In reports and documents filed with or submitted to the Securities and Exchange
Commission and other regulators by the Company, and in other public communications made
by the Company, the Covered Parties involved in the preparation of such reports and documents
(including those who are involved in the preparation of financial or other reports and the
information included in such reports and documents) shall make disclosures that are full,
fair, accurate, timely and understandable. Where applicable, these Covered Parties shall provide
thorough and accurate financial and accounting data for inclusion in such disclosures. They
shall not knowingly conceal or falsify information, misrepresent material facts or omit material
facts necessary to avoid misleading the Company’s independent public auditors or investors.

9. Significant Accounting Deficiencies.

The CEO and each senior financial officer shall promptly bring to the attention of the

Audit Committee any information he or she may have concerning (a) significant deficiencies in
the design or operation of internal control over financial reporting which could adversely affect the
Company’s ability to record, process, summarize and report financial data or (b) any fraud,
whether or not material, that involves management or other employees who have a significant
role in the Company’s financial reporting, disclosures or internal control over financial reporting.

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