Conflict of Interest Policy

BUSINESS
CONDUCT & ETHICS
DIRECTORS SENIOR MANAGEMENT EMPLOYEES

Conflict of Interest

A director should avoid situations that may compromise his impartiality. If an actual or potential conflict of interest may arise on his part, a director should fully and immediately disclose it and should not participate in the decision-making process, or should seriously consider resigning if there exists a continuing material conflict of interest.

Officers and other employees should disclose any relationship or association to the proposed supplier or contractor or its authorized representative to avoid possible conflict of interest.

Officers and other employees of the Company are liable for violation of the Employee Handbook if they are found guilty of engaging in competitive operations or business similar to those of the Company.

Before an employee enters into an official transaction with a supplier or contractor, he should disclose in writing to his immediate supervisor any relationship or association that binds him to the supplier or contractor or its authorized representative to avoid possible conflict of interest.

Officers and other employees of the Company are liable for violation of the Employee Handbook if they are found guilty of engaging in competitive operations or business similar to those of the Company.