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IMC

INT’L METALWORKING CO.
IMC operates a complete ban on corrupt practices. This includes any cases of “willful blindness”
or other actions to circumvent or avoid working according to the law. Third parties cannot be
used to perform actions that IMC prohibits its employees from undertaking either directly or
indirectly.

We expressly prohibit, whether directly or indirectly through our Business Associates or other
third parties, any offers, payments, cash transfers and monetary gifting, as well as the provision
of other advantages, or anything else of value (or the authorization thereof), with the corrupt
intent of gaining “something in return”, (“quid pro quo”) or to secure any business advantage to
any person, whether or not the recipient is a government official.

Facilitation payments are expressly prohibited, even if they are permitted by local laws. No IMC
Member or Business Associates or third-party agents shall participate in any such payment.

Payments to Business Associates, third-party agents or intermediaries should be made only in
the country where the party provides the services or in the country, if different, in which the party
has its headquarters. The practice of transferring funds to accounts in countries other than
the location of the services or the Business Associate’s, third-party agent’s or intermediary’s
headquarters is not permissible unless the applicable party provides a valid business purpose
and proper supporting documentation and the transactions are authorized by IMC Compliance
Officer.

IMC Research and Development Center

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