IXM Code of Conduct

This code should be complied with by all employees and, when relevant, by third parties, without prejudice to applicable mandatory legal requirements which by definition must govern all actions.

The Company strives to build the most appropriate work environment so that employees may realize their full professional potential in the interest of their future career within the Company as well as in the best interest of the Company.

Discrimination including based on sex, race, origin, religion, age, disability, sexual orientation or beliefs, is in contradiction with our values, history, culture and economical interest, and will not be accepted.

We aim at creating a safe and healthy work environment for our employees and for third parties invited to access our premises.

Our individual actions affect the Company’s reputation and standing in the markets and communities where it is active. Accordingly, we must:

- act with a high sense of responsibility, loyalty, dignity and respect for our colleagues and business partners, in accordance with our values and

- discharge our duties and legal or contractual obligations in compliance with professional standards, the terms and conditions governing them and the Company’s long term interests.

- not engage in unfair trade practices; no agreement or understanding having generally prohibited anti-competitive purposes or effects shall be discussed, reached or performed with competitors.

Employees are prohibited from offering, promising, authorizing, making or receiving from customers, suppliers, public officials or any other business relations or partners, either directly or through a third party, any inappropriate pecuniary or other benefit and in this respect must always comply with applicable laws and regulations.

Gifts and entertainment may be offered and received to strengthen business relationships only if they are of modest value and aligned with local business practice and laws and the policies applicable in the company concerned. In case of any doubt, employees should obtain the management’s approval.

It is critical that we always form a reasoned, independent and informed view on the many issues we need to consider and decide upon in the interest of the Company.

Accordingly:

We must avoid engaging directly or through associated parties or with third parties in actions which may not be compatible with the interests or image of the Company. These include deriving personal benefits from a business decision or action, nepotism, using confidential information for purposes other than the interest of the Company or disclosing such information to associates, family or friends.

Conflicts of interest must be disclosed in due course by the employees to their management. Employees must declare any and all of the transactions in which they are involved directly or through associates, family or legal entities in which they have an interest in or are in the process of entering into with the Company whether as partners, clients, suppliers or otherwise. Such transaction must be disclosed and may require the approval of the CEO.

Employees must refrain from speculating personally in relation with commodities traded by the Company (equity shares in privately held companies, derivatives, cash contracts), and in any case must not engage into transactions or dealings on the basis of information obtained in connection with their work for the Company.

Employees commit to contribute all of their working hours, professional skills and business relations exclusively to the Company in the areas where it is active, save where expressly agreed otherwise. Employees must not compete with the Company or hold any position as member of the Board of directors or of any committee in any company or organization which is a competitor of the Company.

The Company’ tangible and intangible assets (physical and financial assets, technology, information, research, strategies, name, image, etc.) must not be used for personal or associated third-party’s benefit or outside the scope of the employee’s needs for the purposes of carrying out her or his duties for the Company.

Exceptions to these rules can only be granted by CEO.

Sustainable growth is a central issue for each of us and our families, it is also critical to our long term economic interests:

We are committed to environmental responsibility and comply pro-actively with relevant legal and regulatory requirements.

We promote the economic development and improvement of the quality of life of the communities where we operate and support actions to this effect.

We strongly condemn child or forced labor and pro-actively apply the UN recommendations in this respect. We promote relations with providers, business partners and sub-contractors operating under the same values.

Employees should always see that their actions comply with all mandatory laws and regulations of the countries in which it operates.

All financial records must be maintained in accordance with applicable Law and no employee shall participate in the creation of illegal, improper, inaccurate or unreliable records.

Whenever an employee receives a notice or threatened litigation or proceeding from a third party or any communication from legal or regulatory authorities, he must inform the CEO.

This Code is applicable, subject to its lawfulness and enforceability under local laws.

Reporting concerns over possible instances of non-compliant conduct should be done directly:

All emails, including anonymous emails, will be taken into consideration. They will be handled confidentially by the IXM Compliance and Internal Audit Department.