1. Principles relating to Code of Conduct

(a) The code comprises the following main principles:-

i. to avoid conflict of interest;

ii. to avoid misuse and/or abuse of position;

iii. to ensure confidentiality of information and to prevent misuse of information gained through the Company’s operations, either for personal gain or for any purpose other than that intended the Company.

(b) In addition to these principles, an Employee must accept individual responsibility for his own actions and that his conduct must measure up to the high standards of integrity and honesty expected of each Employee in the Company and FFM Group of companies.

2. Conflict of interest

An Employee must not engage directly or indirectly in any business activity that competes or conflicts with the interest of the Company or FFM Group of companies. These activities include , but are not limited to, the following:-

(a) Other Business Interests

An Employee shall not conduct any business other than the Company’s business during office hours.

(b) Other Employment

An Employee is discouraged from carrying out additional gainful employment outside the Company. In the event an Employee is required to engage in part-time employment after and outside normal office hours, he shall give full details of such employment and shall obtain the written approval of the Managing Director before undertaking such employment. Approval shall only be granted where the interest of the Company will not be prejudiced.

(c) Corporate Directorships

An Employee shall not serve as a director of corporations which are not related to the Company or FFM Group of Companies without the approval of Managing Director. However, an Employee may assume directorships of non-profit or public service corporations, such as religious, educational, cultural, social, welfare, philantrophic, or charitable institutions provided that the discharge of these responsibilities does not interfere with his duty and responsibilities in the Company.

3. Entertainment and Gifts

(a) An Employee shall not accept entertainment, commission, emoluments, service, gratuity, money, property or any pecuniary benefit or gift for his own personal benefit or advantage from any person/agent or representative having a direct or indirect business dealing with the Company or FFM Group of companies, particularly if this is given with intent to influence the Employee’s conduct in relations to the Company’s affairs.

(b) An Employee may accept a gift of very nominal value provided that:-

(i) the gift, if not accepted, would in the judgement of the Employee have an adverse effect upon the business relationship of the companies concerned;

(ii) refusal or return of the gift item is truly impractical.

(c) If an Employee is offered a pecuniary benefit or gift, he shall immediately inform the appropriate Head of Department or Superior, who will provide guidance.

4. Misuse of Positions

An Employee must not use his position or the Company’s name for personal advantage in political, investment, or retail purchasing transactions, or in similar types of activities. The use of position to obtain preferential treatment not normally accorded to the Company’s Employees at large is discouraged.

5. Insider Information

(a) An Employee shall not deal in the securities of any company listed or pending listing on a stock exchanged at any time when he is possession of information, obtained as a result of his employment by the Company which is not generally available to shareholders of that Company and the public, and which, if it were so available, would likely bring about a material change in the market price of the shares or other securities of the company concerned.

(b) If an Employee possesses insider information he is also prohibited from influencing any other person to deal in the securities concerned or communicating such information to any other person, including other members of the staff who do not require such information in discharging their duty.

6. Confidentially

An Employee must take every precaution to protect the confidentially of Company information. An Employee shall not during, or after termination of his employment with the Company (except in the proper course of his duties or with the Company’s written consent) divulge or make use of any secrets, copyright material, or any correspondence, accounts or dealings of the Company. An Employee shall not in any way use information so obtained for financial gain.

7. Media Relations

(a) All enquiries from the media e.g. T.V, Radio, Press etc, must be referred to the Corporate Affairs Department.

(b) An Employee is not permitted to give interview or written articles for any purpose connected with the Company without the prior consent of the appropriate authority.

8. Trade Union, Political and Social Activities

(a) If an employee is involved in trade union, political and social activities, he shall conduct these activities outside the Company’s premises and after his working hours. An Employee shall ensure that his involvement or participation in these activities will not infringe on or interfere with his duties and responsibilities to the Company.

(b) The Company, however reserves the right to request an Employee to stop his involvement/participation in these activities if these deprive an Employee from giving his commitment to his duties and responsibilities to the Company.

9. Employee’s Personal Particulars

Information on the Employee in the personnel file must be accurate and up-to-date, and it is the Employee’s responsibility inform the Company within 14 days of any changes in personal particulars such as address, telephone numbers, marital status, qualifications and details of immediate dependents.