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IMC D. Waivers.

INT’L METALWORKING CO. Any waiver of this Code for executive officers or directors may be made only by the
Company’s Board of Directors or its Audit Committee and will be promptly disclosed as
required by law or stock exchange regulation.

E. Violations of Ethical Standards.

1. Reporting Known or Suspected Violations.

The Company’s directors, CEO, senior financial officers and chief legal officer shall promptly
report any known or suspected violations of this Code to the Chairman of the
Company’s Audit Committee. All other Covered Parties should talk to supervisors, managers or
other appropriate personnel about known or suspected illegal or unethical behavior. These
Covered Parties may also report questionable behavior in the same manner as they may report
complaints regarding accounting, internal accounting controls or auditing matters by contacting
(anonymously, if desired) a third party organization called NAVEX Global (toll-free number 800-
261-8651 or web site at http://brk-hotline.com). Separate anonymous reporting procedures are
available for Company employees working outside the United States. No retaliatory action of
any kind will be permitted against anyone making such a report in good faith, and the
Company’s Audit Committee will strictly enforce this prohibition.

2. Accountability for Violations.

If the Company’s Audit Committee or its designee determines that this Code has been violated,
either directly, by failure to report a violation, or by withholding information related to a violation,
the offending Covered Party may be disciplined for non-compliance with penalties up to and
including removal from office or dismissal. Such penalties may include written notices to the
individual involved that a violation has been determined, censure by the Audit Committee,
demotion or re-assignment of the individual involved and suspension with or without pay or
benefits. Violations of this Code may also constitute violations of law and may result in criminal
penalties and civil liabilities for the offending Covered Party and the Company. All Covered
Parties are expected to cooperate in internal investigations of misconduct.

F. Compliance Procedures.

We must all work together to ensure prompt and consistent action against violations of this
Code. In some situations, however, it is difficult to know if a violation has occurred.
Because we cannot anticipate every situation that will arise, it is important that we have a way to
approach a new question or problem. These are the steps to keep in mind:

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