Page 9 - Ethics code ISCAR
P. 9

Our internal networked systems facilitate real-time individual monitoring. This enables
                               management to execute broad-based long-term business planning, resource allocation, and to
                               prevent and minimize unauthorized or improper dealings.


                            4  No Conflicts of Interest, No Insider Trading, No Corrupt Practices
                               Non-public information may not be shared with any third parties, under any circumstance,
                               other than as authorized by ISCAR management. Among other important reasons, this is done
                               to prevent any inadvertent risk of “insider dealings” in securities, and other “bad choices” on
                               anyone’s part.  No ISCAR member shall use non-public information obtained from ISCAR or
                               obtained as a result of the member’s ISCAR employment for his or her personal gain or for the
                               personal gain of others through the trading of securities or otherwise.

                                                                             ISCAR Campaign Launch for Leading Customers and Distributors
                               Each ISCAR Member is expected to avoid and prevent situations where a person’s private
                               interests may conflict with the interests of ISCAR. Any personal relationships or associations
                               should be reported to management in advance.


                               We expect all those who are engaged by ISCAR Members, whether employees, officers
                               or outside consultants, to provide their services objectively, truthfully, and to the
                               best of their ability and professional competence. By the same token, we also
                               expect our Business Associates to take positive measures to obligate any
                               other third parties which may be linked to the ISCAR in some way,
                               or which may obtain ISCAR Group information over the course of
                               business, to observe and prevent any such insider dealings or
                               improper activities as a result of conflicting interests.

                               All ISCAR Members are committed to local, global
                               and United States “anti-trust” and “anti-corruption”
                               legal and ethical standards including the Foreign
                               Corrupt Practices Act (“FCPA”). For further details
                               on the FCPA, please see the BRK PBPP.


                               ISCAR Members are prohibited from engaging in any activities
                               which may lead to:

                            (i)   Prohibited business arrangements such as monopolies,
                               cartels or trusts.
                            (ii)  Influencing a government or a public official, a political candidate, any political
                               party, any officer or employee of a public international organization such as the
                               United Nations or World Bank, any Royal family member or any officer or employee of
                               a company owned or controlled by a government (such as state-owned oil companies,
                               automobile companies and hospitals).
                            (iii)  Securing improper advantages from a government or a public official.
                            (iv)  Unduly or corruptly affecting government or public official decision-making process.
                            (v)  Unduly or corruptly securing business as a result of influence on government or
                               public officials.










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