Trade Compliance

Export and Import Laws

The ANSA McAL Group complies with export and import control legislations and regulations of all countries in which it does business. We also expect all of our vendors to know and understand the custom laws that apply to their products. If you work in our supply chain, you need to make sure you and our vendors provide accurate product descriptions, correct tariff classifications, valuation information and country of origin statements for all items we import or export, whenever required. If you have a question or concern, report it immediately.

Insider Trading

We maintain trust with our investors and the public by respecting the spirit of financial laws, which means we do not trade based on material nonpublic information. Information is “material” if a reasonable investor would consider it important in deciding whether to buy or sell that Company’s securities. Information is “nonpublic” if it has not been broadly communicated to the public in a press release or in a Securities and Exchange Commission (“SEC”) filing.

In our work, we may become aware of material nonpublic information about the ANSA McAL Group, companies we do business with, customers, suppliers, competitors or potential acquisitions. Employees or officers who have material nonpublic information as a result of their relationship with the Company are prohibited by law and Company policy from trading in securities of the Company or such other companies. In addition, employees and officers are prohibited from recommending, “tipping” or suggesting that anyone else buy or sell securities in ANSA McAL shares or the shares of any other Company based on material nonpublic information, as it not only breaks trust with our investors and the public, but is also illegal, violates Company policy, and is unfair to other investors.

Gain or loss of a significant customer or supplier.

Major lawsuit or regulatory investigation.

Any other information that may positively or negatively affect the share price of ANSA McAL or any other Company.

When to Trade

Once you are not in possession of material inside information, you may purchase, sell or transfer ANSA McAL shares or exercise options granted. Consult with the Group Corporate Secretary if you are unsure whether you have material inside information at any point in time.

You should not trade in ANSA McAL securities during quarterly and other blackout periods when they apply to you. Even if you are not covered by formal blackout restrictions, before trading, you are encouraged to wait until at least 24 hours after material inside information has been publicly disclosed or following the public dissemination of financial results, to ensure the market has had an opportunity to absorb and evaluate the information. Directors, Executives and Senior Officers are required to notify the Group Corporate Secretary prior to engaging in transactions in ANSA McAL Group shares.

Violation of insider trading laws can result in severe fines and criminal penalties, as well as disciplinary action by the Company, including potential termination of employment.

Examples of Confidential Information

Directors, Executives, Senior Officers and select employees of our Company are the most likely to possess inside information, which may be considered significant or material, about the Company before it is made publicly available to ordinary investors. Examples of information that could be material are:

Information about possible business deals, such as a merger, purchase, sale, or joint venture.

Financial results or changes in dividends.

Important management changes.

Major raw material shortages or discoveries.

Significant product or manufacturing process developments.

Government Requests & Subpoenas

Employees should immediately contact the Group Legal Department if they are contacted by law enforcement or other government officials with respect to their duties in most circumstances.

Any information you provide to law enforcement or government officials must be completely honest and truthful. If you receive a subpoena related to the ANSA McAL Group or your work, immediately contact the Group Legal Department. If you become aware of pending, imminent or contemplated litigation or a government examination or investigation, you must immediately contact the Group Legal Department. All records and documents relevant to a subpoena, litigation or investigation must be saved, including any records that may otherwise be automatically destroyed or erased (such as e-mail and voice mail messages).