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An employee, while in the employ of INHAIL TRADING, is expressly prohibited

               from engaging in any activity which is conflict with the interest of INHAIL TRADING
               or which will interfere with the performance of his/her job, including consulting,
               whether within or outside of the working hours without the prior written consent
               of the Senior Officer.

               9.14 Confidentiality

               From time to time, employees may come or access to contact with confidential
               information, including but not limited to information about INHAIL TRADING’s
               customers, subsidiaries or affiliates, suppliers, finances and business plans.


               Employees are required to keep any such matters that may be disclosed to them
               or learned by them strictly confidential. All employees are likewise expected to
               keep  all  information  that  may  come  into  his/her  possession  in  the  course  of
               his/her  employment  in  INHAIL  TRADING  strictly  confidential,  whether  such
               information is labelled as “confidential” or not.

               Unauthorized reproduction, dissemination, or disclosure of any such information
               shall  be  considered  a  breach  of  trust  of  the  INHAIL  TRADING  and  shall  be

               actionable pursuant to this Code. The confidentiality provisions in this Code shall
               remain  in  full  force  and  effect  even  after  the  termination  of  the  employee’s
               employment.

               IT Information Storage and Security Employees acknowledge that any storage
               devices (USB’s, Memory Sticks, CD’s, Floppy Discs) used by employees  at the
               company premises are the property of INHAIL TRADING. Furthermore, it should

               be  understood  by  employees,  that  company  equipment  should  be  used  for
               company business only during normal working hours.  Downloading of personal
               materials on company equipment can be harmful to said equipment and should
               not be done.

               12. Health  and Safety The Roxas  Group, along with  its employees, must take
               reasonable  precautions  to  ensure  that  the  workplace  is  safe.  Alcohol
               consumption  or  illegal  drug  use  is  not  permitted  during  work  hours  on  the

               premises. From time to time, with the permission of the Chief Executive Officer,
               alcohol may be used to celebrate an occasion/event. 13. Harassment and Bullying
               The  Roxas  Group  wants  to  provide  a  harassment-free  environment  for  its
               employees. Mutual respect, along with cooperation and understanding, must be
               the basis of interaction within the organization. The Roxas Group will neither
               tolerate nor condone behaviour that is likely to undermine the dignity or self-
               esteem of an individual, or create an intimidating, hostile or offensive
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