Page 15 - EthicsCode

IMC create conflicts of interest. It is almost always a conflict of interest for a Covered Party to work
simultaneously for a competitor, customer or supplier.
INT’L METALWORKING CO.
Conflicts of interest may not always be clear-cut, so if you have a question, you should consult
with your supervisor or manager or, if circumstances warrant, the chief financial officer or chief
legal officer of the Company. Any Covered Party who becomes aware of a conflict or potential
conflict should bring it to the attention of a supervisor, manager or other appropriate personnel
or consult the procedures described in Section E of this Code.

All directors and executive officers of the Company ,[and the chief executive officers and chief
financial officers of Berkshire Hathaway’s subsidiaries,] shall disclose any material transaction
or relationship that reasonably could be expected to give rise to such a conflict to the Chairman
of the Company’s Audit Committee. No action may be taken with respect to such transaction or
party unless and until such action has been approved by the Audit Committee.

2. Corporate Opportunities.

Covered Parties are prohibited from taking for themselves opportunities that are discovered
through the use of corporate property, information or position without the consent of the Board
of Directors of the Company. No Covered Party may use corporate property, information or
position for improper personal gain, and no employee may compete with the Company directly
or indirectly. Covered Parties owe a duty to the Company to advance its legitimate interests
whenever possible.

3. Fair Dealing.

Covered Parties shall behave honestly and ethically at all times and with all people. They shall
act in good faith, with due care, and shall engage only in fair and open competition, by treating
ethically competitors, suppliers, customers, and colleagues. Stealing proprietary information,
possessing trade secret information that was obtained without the owner’s consent, or inducing
such disclosures by past or present employees of other companies is prohibited. No Covered
Party should take unfair advantage of anyone through manipulation, concealment, abuse of
privileged information, misrepresentation of material facts, or any other unfair practice.

The purpose of business entertainment and gifts in a commercial setting is to create good
will and sound working relationships, not to gain unfair advantage with customers. No gift or
entertainment should ever be offered or accepted by a Covered Party or any family member of
a Covered Party unless it (1) is consistent with customary business practices, (2) is not
excessive in value, (3) cannot be construed as a bribe or payoff and (4) does not violate any laws
or regulations. The offer or acceptance of cash gifts by any Covered Party is prohibited. Covered
Parties should discuss with their supervisors, managers or other appropriate personnel any gifts
or proposed gifts which they think may be inappropriate.

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