Page 9 - IMC_Ethics_code_2022_en

IMC

INT’L METALWORKING CO.
Our internal networked systems facilitate real-time individual monitoring. This enables
management to execute broad-based long-term business planning, resource allocation, and to
prevent and minimize unauthorized or improper dealings.

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,
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. No IMC member shall use non-public information obtained from IMC or obtained
as a result of the member’s IMC employment for his or her personal gain or for the personal gain
of others through the trading of securities or otherwise.

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.
IMC Campaign Launch for Leading Customers and Distributors

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 including the Foreign
Corrupt Practices Act (“FCPA”). For further details
on the FCPA, please see the BRK PBPP.

IMC Members are prohibited from engaging in any activities
which may lead to:

(i) Prohibited business arrangements such as monopolies,
cartels or trusts.
(ii) Influencing a government or a public official, a political candidate, any political
party, any officer or employee of a public international organization such as the
United Nations or World Bank, any Royal family member or any officer or employee of
a company owned or controlled by a government (such as state-owned oil companies,
automobile companies and hospitals).
(iii) Securing improper advantages from a government or a public official.
(iv) Unduly or corruptly affecting government or public official decision-making process.
(v) Unduly or corruptly securing business as a result of influence on government or
public officials.

9