Page 6 - EthicsCode
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IMC                     (iii)	 Be informed about risks: Conducting up-to-date regular risk assessments,
                        forward business planning and “background checks” will minimize the chance that
INT’L METALWORKING CO.  you find yourself surprised. Always make sure that you know enough about who
                        you are dealing with, including the relevant background, other past and present
                        IMC Production Facilitiesactivities, as well as the person’s and the organization’s reputation.

                        (iv)	 Evaluate associations: Do not create long term business ties before
                        investigating the facts about third party identity and past conduct. Before engaging
                        with a third party, decide if you can trust this third party to operate in the IMC
                        name, to comply with all the Codes, policy decisions and legal rules.

                        (v)	 Keep records: IMC Members are expected to keep tidy and complete corporate files, as well
                        as documentation of finances, regarding any transaction and dealings with any third party.

                        (vi)	 Disclose information: Your reports are very important, whether to your direct
                        manager or to the IMC higher management. Only with accurate reports are
                        we able to plan ahead for risks or deal with “grey area” situations.

                        (vii)	Seek help: Our management team implements an “open door” policy. We
                        are available for any approach regardless of company, regional or country
                        affiliations. If you believe that any matter would be better or faster
                        solved by our Tefen executives or legal department, we expect you
                        to immediately forward any relevant data to our attention.

                        (viii)	Training: All IMC Member teams should be properly
                        educated and trained in ethics and compliance matters.
                        IMC Management and Compliance provides
                        regular updates and training course materials.

                        A.	Reporting:

                        It is the duty of each person to report actual or suspected
                        wrong-doing. A reporter who makes a report in good faith will be
                        protected from any prejudice or retaliation as a result of the report.
                        HR and other operational business-related matters should be
                        reported directly to management. Illegal and unethical conduct
                        should be reported to management and/or to BRK’s Compliance
                        Hotline, available at: WWW.BRK-HOTLINE.COM. In cases of difficult or
                        sensitive reports, it is possible to make the report on an anonymous basis.

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