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IMCCOMPASS N

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INT’L METALWORKING CO. W E
IMC COMPASS THE IMC COMPASS

GOOD BUSINESS CONDUCT SW S SE

AND ETHICS CODE A Compliance at IMC: Leading by Example

IMC Members and employees can be rightly proud of our rich corporate history and culture.
These have been the driving force behind much of our success. We work relentlessly to preserve
and maintain the values that have made IMC a global leader and a very special place to work.

The IMC Compass is our way to promote and maintain the highest ethical
and legal norms of conduct, and to ensure that our Group companies
and individual employees are always doing the right things.

Being a part of Berkshire Hathaway (“BRK”), also means that we are all subject to the Berkshire
Hathaway Code of Business Conduct and Ethics (“BRK Code”), the Berkshire Hathaway
Prohibited Business Practices Policy (“BRK PBPP”) and other policies, as amended
from time to time and published online. Current versions of the BRK Code and BRK
PBPP are available online at https://www.imc-companies.com/wp-content/
uploads/2021/11/Prohibited_Business_Practices_Policy.pdf. The BRK Code
and Policies together with the IMC Compass and compliance policies
constitute the minimum standards of conduct that we expect from
every employee, manager and representative (“the Codes”).

Every IMC Group company, all personnel and anyone IMC Headquarters
authorized to operate on behalf of an IMC Group
company (“IMC Member”) is expected to take real
active measures to apply the Codes, and to act
with personal integrity, loyalty, credibility, reliability,
accountability, responsibility and genuine respect for
others. Every IMC Member will also need to ensure that
the same values and standards are applied when engaging
with third parties and customers (“Business Associates”).

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