Page 16 - EthicsCode

IMC

INT’L METALWORKING CO.

4. Insider Trading.

Covered Parties who have access to confidential information are not permitted to use or share
that information for securities trading purposes (“insider trading”) or for any other purpose except
the conduct of the Company’s business. All non-public information about the Company should
be considered confidential information. It is always illegal to trade in Berkshire Hathaway
securities while in possession of material, non-public information, and it is also illegal to
communicate or “tip” such information to others. While all Covered Parties are prohibited from
insider trading, Berkshire has adopted specific “Insider Trading Policies and Procedures”
applicable to the Company’s directors, executive officers and key employees (“Directors and
Covered Employees”). This document is posted on Berkshire’s website and is sent periodically
to Directors and Covered Employees in connection with certification of compliance.

5. Confidentiality.

Covered Parties must maintain the confidentiality of confidential information entrusted to them,
except when disclosure is authorized by an appropriate legal officer of the Company or required
by laws or regulations. Confidential information includes all non-public information that might
be of use to competitors or harmful to the Company or its customers if disclosed. It also
includes information that suppliers and customers have entrusted to the Company. The
obligation to preserve confidential information continues even after employment ends.

6. Protection and Proper Use of Company Assets.

All Covered Parties should endeavor to protect the Company’s assets and ensure their
efficient use. Theft, carelessness, and waste have a direct impact on the Company’s profitability.
Any suspected incident of fraud or theft should be immediately reported for investigation. The
Company’s equipment should not be used for non-Company business, though incidental
personal use is permitted.

The obligation of Covered Parties to protect the Company’s assets includes its proprietary
information. Proprietary information includes intellectual property such as trade secrets, patents,
trademarks, and copyrights, as well as business, marketing and service plans, engineering and
manufacturing ideas, designs, databases, records, salary information and any unpublished
financial data and reports. Unauthorized use or distribution of this information would violate
Company policy. It could also be illegal and result in civil or criminal penalties.

7. Compliance with Laws, Rules and Regulations.

Obeying the law, both in letter and in spirit, is the foundation on which the Company’s ethical
standards are built. In conducting the business of the Company, the Covered Parties shall
comply with applicable governmental laws, rules and regulations at all levels of government in
the United States and in any non-U.S. jurisdiction in which the Company does business.

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