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1.     PURPOSE OF MANUAL






               The  information  contained  in  this  Employees’  Handbook  is  presented  for  the
               benefit of all employees of INHAIL TRADING.

               The  intention  is  to  furnish  as  much  information  as  possible  concerning  what
               benefits and compensation, the employees can expect from INHAIL TRADING,
               and what the INHAIL TRADING expects from its employees.

               It is the employees’ responsibility to familiarize themselves with all the benefits,
               compensation, and rules and regulations contained in this Handbook and Code of
               Conduct as well as all amendments, revisions or supplements thereto, as may be
               published or circulated from time to time.


               2.     INTRODUCTION


               The success of INHAIL TRADING, respectively, are measured not only by financial
               or operational success but is also measured by its values and its commitment to

               each  employee,  its  business  partners  and  to  the  communities  where  its
               employees and officers work and live.
               Each employee must be fully aware that he or she needs to positively embody
               the INHAIL TRADING’s culture and act as brand ambassadors for the organization.

               INHAIL TRADING takes pride in performing its business in compliance with all legal

               requirements  and  the  highest  standards  of  integrity.    Part  of  the  INHAIL
               TRADING’s personal integrity means that others can trust and respect it and know
               that its personnel will be honest, fair, and forth right.  As a company, Integrity
               means  that  INHAIL  TRADING,  and  all  its  constituents,  will  always  honor  their
               commitments  and  will  always  be  reliable  business  partners  and  trusted
               neighbors.


               Integrity protects the company's reputation, and enables  it to  thrive, even in
               today’s complex and competitive business environment.

               This Code is designed to help when employees have questions about what to do
               in  specific  situations.  It  is  a  summary  of  how  the  company  will  perform  its
               business  in  accordance  with  its  policies,  laws,  and  regulations.    By  faithful
               adherence to this Code, all employees ensure that the company’s business

               activities and decisions are consistent, not only with law and regulations, but also
               with ethical business standards.
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