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IMC

INT’L METALWORKING CO. B Fair Dealings
1 Protecting Corporate Assets
We are committed to protecting data privacy, corporate assets and confidential information.
Any misuse of corporate assets or information may prejudice business operations and cause
irreparable harm, costs, legal proceedings, loss of profit, and damage to our reputation and
goodwill.

Such risks exist regardless of whether the subject asset belongs to IMC Members or to any
of our Business Associates. Accordingly, IMC Members should exercise a reasonable degree
of care to limit disclosure of proprietary confidential information, and to prevent misuse and/or
disclosure of information by other third parties.

Every IMC employee is expected to strictly follow IMC policies and instructions regarding
computer and online media use.

2 Fair Competition and Interaction with Third Parties
We expect all IMC Members and staff to act with complete integrity and fair play. We recognize
the inherent mutual benefits of conducting good-faith interactions with third parties.

IMC maintains internal controls to monitor and ensure that IMC publications or materials will not
unfairly infringe the rights of third parties, and will not include any information or reference which
may be misleading.

Any manipulation, concealment, misrepresentation, inducement of others to breach
confidentiality obligations or any other unfair competition practices is inconsistent with the IMC
Compass and will be expressly prohibited and strictly avoided by all IMC Members.

3 Accurate Documentation
Corporate documents produced by IMC Members should be made in a full, fair, accurate,
timely, and understandable way. IMC managers are expected to ensure that the company is
operating and complying with applicable regulations. For any required advice on such matters,
each manager may contact the IMC legal and/or finance teams in Tefen.

No documents, records, recordings or anything which reflects occurrence of any event shall
ever be falsified, “back-dated,” “re-constructed” or changed retrospectively, for any reason.
All transactions must be recorded in a timely, consistent and accurate manner in terms of
amount, accounting period, purpose and accounting classification and must have proper
authorization. No secret or unrecorded fund or asset shall be created or maintained, and no
accounting balances shall be created or maintained that do not have supporting documentation,
are fictitious in whole or in part, or have no reasonable basis in fact. No checks may be
written to “cash”, to “bearer”, or to third-party designees of a party entitled to payment. Other
than documented petty cash transactions, no cash transactions may be made, unless such
transaction is evidenced by a receipt bearing the signature of the recipient and the recipient is a
party with whom the relevant subsidiary has a written contract.

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