Page 8 - EthicsCode

IMC 4 No Conflicts of Interest, No Insider Trading, No Corrupt Practices
Non-public information may not be shared with any third parties, under any circumstance,
INT’L METALWORKING CO. other than as authorized by IMC management. Among other important reasons, this is done
to prevent any inadvertent risk of “insider dealings” in securities, and other “bad choices”
on anyone’s part.

Each IMC Member is expected to avoid and prevent situations where a person’s private
interests may conflict with the interests of IMC. Any personal relationships or associations
should be reported to management in advance.

We expect all those who are engaged by IMC Members, whether employees, officers or outside
consultants, to provide their services objectively, truthfully, and to the best of their ability and
professional competence. By the same token, we also expect our Business Associates to take
positive measures to obligate any other third parties which may be linked to the IMC Group
in some way, or which may obtain IMC Group information over the course of business, to
observe and prevent any such insider dealings or improper activities as a result of
conflicting interests.

All IMC Members are committed to local, global and United States
“anti-trust” and “anti-corruption” legal and ethical standards.

IMC Campaign Launch for Leading Customers and Distributors

8