Page 6 - EthicsCode

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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