Business ethics and conduct

In an effort the re-emphasise our commitment to adhere to the highest ethical standards, we have recently adopted, as a supplement to our Policies, a more general Code of Business Ethics and Conduct which sets forth in broad terms the ethical standards which are the cornerstones of our business. This programme is designed to insure that we have necessary policies and systems in place to prevent and detect violations of law and of our Code. The Compliance Programme has procedures for reporting violations of law and of our Policies as well as for asking questions about them.

Elements of the Code of Business Conduct:

• Conflict of interest
• Entertainment, gifts and payments
• Protection of proprietary information
• Protection of physical and intellectual assets
• Integrity of records and accounting procedures
• Illegal insider trading
• Antitrust
• Foreign corrupt practices act
• Boycotts
• Trade restrictions and export controls
• Political contributions
• Procurement activity
• Equal employment opportunity
• Alcohol and substance abuse
• Harassment and discrimination
• Health, safety and the environment
• Integrity in business relationships