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4 SCOPE

This Employee Handbook and Code of Conduct (the “Code”) provides the ethical
guidelines and expectations for conducting business on behalf of INHAIL

TRADING. The Code applies to all directors, officers, employees, consultants,
temporary workers, project-based, fixed term -employees and other personnel
of INHAIL TRADING.

Suppliers and certain business partners serve as an extension of the company and
their conduct and behavior while carrying out business dealings with INHAIL

TRADING or on behalf of INHAIL TRADING can have an impact on INHAIL TRADING
and its reputation.

For this reason, they are expected to conduct their businesses in a legal and
ethical manner and to adhere to the spirit of the Code, as well as any applicable
contractual obligations. In some cases, provisions of the Code are not applicable
to suppliers, vendors, and consultants.

It is understood however, that employees who are assigned in other locations
should also be compliant with the policies of the sites they are assigned to, which
are deemed incorporated herein by way of reference.

No written policy can definitively prescribe an appropriate action for each
situation. However, this Code seeks to define the minimum standards that must
be followed in all professional dealings and relationships.

The Code does not cover every possible subject or potential situation. It does
indicate, however, the policies that should guide an individual in daily work and
describes the minimum standard of conduct expected from everyone.

5 IMPLEMENTING GUIDELINES

All reported offenses shall be dealt with in accordance with the established
Disciplinary Management procedure. The company will take appropriate
disciplinary action against any director, officer, employee, consultant, temporary
worker, project-based, probationary, fixed- term and other personnel of the
company whose actions are found to violate these policies or any other policies
of INHAIL TRADING.

Disciplinary actions may include immediate termination of employment or
business relationship in accordance with this Code.

This Code applies to all employees/personnel in the absence of any
Department/Business Unit specific policy/process. INHAIL TRADING reserves the
right to periodically review and correspondingly update and/or amend this Code.

Any amendments/revisions/supplements to this Code shall be deemed
incorporated herein by way of reference.