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INT’L METALWORKING CO.                                                                            320 340                                 NW  N
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                        THE IMC COMPASS                                                                                                  260SW
                        A	Compliance at IMC: Leading by Example                                                                                 S

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                        IMC HeadquartersIMC 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 thing.

                        Being a part of Berkshire Hathaway group (BRK), also means that we are all subject to the
                        Berkshire Hathaway Code of Ethics and other policies, as amended from time to time and
                        published online. A current version of the Berkshire Code of Ethics is available online at
               and attached to this Code.
                        The BRK Code of Ethics 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 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”).

                        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 transactions or activity,
                        stop and question. Personal interests, private gains or improper use of company’s 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.

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