Page 6 - IMC_Ethics_code_2022_en
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IMC


    INT’L METALWORKING CO.
                            We recognize that not all risks can be foreseen in advance. To minimize the
                            effect of such risks, the following guidelines should be followed:


                            (i)   Ask questions: In most situations, it is virtually impossible to plan for all risks or to devise
                              real solutions without knowing all the facts and intended context. Good preventative
                              action begins with clear interpretation, attention to detail and forward planning.


                            (ii)   Trust your instincts: If you sense that something is improper in any transaction or activity,
                              stop and question. Personal interests, private gains or improper use of company assets or
                              information for individual benefits of the performer or others, must be completely excluded
                              and never sought. There is never a justification for doing something which your instincts tell
                              you is improper and, in any such case, please seek advice before taking further action.

                            (iii)  Be informed about risks: Conducting up-to-date regular risk assessments, forward
                              business planning and “background checks” will minimize the chance that you
                              find yourself surprised. Always make sure that you know enough about who you
                              are dealing with, including the relevant background, other past and present
                              activities, as well as the person’s and the organization’s reputation.


                            (iv)  Evaluate associations: Do not create long term business ties before
                              investigating the facts about third-party identity and past conduct.
                              Before engaging with a third party, decide if you can trust this
                                                                        IMC Production Facilities
                              third party to operate in the IMC name, to comply with
                              all the Codes, policy decisions and legal rules.

                            (v)  Keep records: IMC Members are expected to keep tidy
                              and complete corporate files, as well as accurate
                              documentation of finances, regarding any
                              transaction and dealings with any third party.

                            (vi)  Disclose information: Your reports are very important,
                              whether to your direct manager or to the IMC higher
                              management. Only with accurate reports are we able to
                              plan ahead for risks or deal with “grey area” situations.


                            (vii) Seek help: Our management team implements an “open door”
                              policy. We are available for any approach regardless of company,
                              regional or country affiliations. If you believe that any matter would be
                              better or faster solved by our Tefen executives or legal department, we
                              expect you to immediately forward any relevant data to our attention.

                            (viii) Training: All IMC Member teams should be properly educated and trained
                              in ethics and compliance matters. IMC Management and Compliance
                              provides regular updates and training course materials.












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