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IMC IMCCOMP ASS 0 20

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THE IMC COMPASS 260SW
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A Compliance at IMC: Leading by Example S

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IMC HeadquartersIMC Members and employees can be rightly proud of our rich corporate history and culture.
These have been the driving force behind much of our success. We work relentlessly to preserve
and maintain the values that have made IMC a global leader and a very special place to work.

The IMC Compass is our way to promote and maintain the highest ethical
and legal norms of conduct, and to ensure that our Group companies
and individual employees are always doing the right thing.

Being a part of Berkshire Hathaway group (BRK), also means that we are all subject to the
Berkshire Hathaway Code of Ethics and other policies, as amended from time to time and
published online. A current version of the Berkshire Code of Ethics is available online at
http://www.berkshirehathaway.com/govern/ethics.pdf and attached to this Code.
The BRK Code of Ethics and Policies together with the IMC Compass and
compliance policies constitute the minimum standards of conduct that we
expect from every employee, manager and representative (“the Codes”).

Every IMC Group company, all personnel and anyone authorized to
operate on behalf of an IMC Group company (“IMC Member”)
is expected to take real active measures to apply the
Codes, and to act with personal integrity, loyalty,
credibility, reliability, accountability, responsibility
and genuine respect for others. Every IMC
Member will also need to ensure that the same
values and standards are applied when engaging with
third parties and customers (“Business Associates”).

We recognize that not all risks can be foreseen in advance. To minimize
the effect of such risks, the following guidelines should be followed:

(i) Ask questions: In most situations, it is virtually impossible to
plan for all risks or to devise real solutions without knowing all
the facts and intended context. Good preventative action begins
with clear interpretation, attention to detail and forward planning.

(ii) Trust your instincts: If you sense that something is improper in any transactions or activity,
stop and question. Personal interests, private gains or improper use of company’s assets or
information for individual benefits of the performer or others, must be completely excluded
and never sought. There is never a justification for doing something which your instincts tell
you is improper and, in any such case, please seek advice before taking further action.

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