Code of Conduct

Background

This Code of Conduct (“Code”) is based on the business principles of IMC Limited Ltd. (IMC). The Code helps to ensure observation and application of these principles in all the dealings on behalf of the Company and by the designated persons.

Business Principles

1.We expect the highest levels of personal conduct from everyone within IMC, regardless of position. Honesty, integrity and fairness form the cornerstones of relationships inside and outside IMC. Bribery of any form is unacceptable. No undeclared offers or payments will be accepted, solicited, or made by, anyone in IMC.

2.In addition, everyone within IMC is required to avoid any conflicts of interest between their personal activities and the business of IMC.

3.Everyone is required to make proper use of company assets. Fraud and theft of any form are unacceptable, and the Company will treat any incidences seriously. Prevention of fraud and theft is the responsibility of all employees, who should demonstrate a commitment to an anti-fraud culture through their actions.

4.While it is recognized that limited corporate hospitality is given and received as part of building normal business relationships, employees should avoid accepting hospitality or gifts, which might appear to place them under an obligation.

5.Proper and full records are made of all transactions made on behalf of IMC.