Business Ethics Policy

1. Purpose

Our commitment is to conduct our business consistent with the highest standards of conduct and ethics, and to buy and sell on the basis of value, which is a combination of quality, service and price. Our reputation as businesspersons committed to these principles is an invaluable asset. Therefore, ITE and its affiliated businesses will be conducted in accordance with the letter and spirit of the law wherever we do business, so that full disclosure of our manner of doing business will at all times be a matter of pride.

2. Applicability

This policy statement applies to ITE, and its subsidiaries and affiliates, all of their officers, directors and employees.

3. Responsibility

The Risk Mitigation Team of ITE is responsible for disseminating this policy statement to all Company personnel on an annual basis. Management and supervisors are also responsible for disseminating this policy statement to all their direct reports.

4. Policies

The following must be observed:

• The Company's best interest is paramount in all business decisions.
• The Company's purchase of goods and services shall be based on prices, quality and service.
• All financial and other books and records of the Company must be completed and correct and accurately reflect all assets, liabilities, and disbursements, not only as to amount, but also as to their nature and purpose.
• Company payments shall be made only in accordance with established Company procedures and only for the purposes reflected in the Company's records' accounts and supporting documentation.
• Gifts and entertainment shall only be in amounts reasonable and customary.

The following are improper and prohibited:

• Bribes, payoffs, kickbacks or other considerations made to obtain a commercial advantage
• Theft of Company property or the property of others, in any form
• Charging purchases of personal items to Company's account (even though later paid with personal funds) without approval from an immediate supervisor
• Falsification or misrepresentation of expense accounts or other business records
• Borrowing money from or incurring personal financial obligations to those with whom the Company does business (excluding lending institutions)
• Disclosure of confidential or proprietary information about the Company to others, or use of such information for personal gain
• Acquiring or maintaining any ownership interest in private concern that does business with the Company without prior express disclosure and approval from ITE's CEO and General Counsel

5. Reporting Responsibility

Persons covered by this policy that become aware of any payments or business practices in violation of this policy must report such violations.

Reporting can be done through one of the following channels:

• To the employee's direct supervisor
• To a Human Resources Manager
• To the Chief Compliance Officer or any member of the Compliance Group
• To the anonymous Ethics & Compliance telephone line at 051 2806184 or via email to info@itepk.com

6. Administration of This Policy

ITE's Compliance Group shall develop and maintain a program approved by the CEO to insure compliance with this Policy.

The Company's Risk Mitigation Team, in cooperation with employees from Human Resources, Accounting and Internal Audit will be requested to conduct regular audits with respect to compliance with this Policy and report results to the CEO.

Any investigation deemed necessary or requested by the CEO or Management with respect to possible violations of this Policy will be conducted by the Company's Risk Mitigation Team, in cooperation with Human Resources, Accounting and Internal Audit, under the direction of the General Counsel.

All employees shall fully cooperate with any investigation conducted pursuant to this Policy in the interest of full and complete disclosure as to the matters being investigated.

This Policy shall be distributed to all employees of the ITE on an annual basis and to all new employees so they may be continually aware of its provisions.

7. Annual Compliance Certification

Annually, ITE will require all persons covered by this policy to submit a statement of compliance.

8. Penalties

Violations of this policy will be cause for disciplinary actions, including dismissal, and possible civil and criminal legal proceedings in appropriate cases. Such penalties will also apply to those employees who obstruct or interfere with the code of any investigation, which may be undertaken pursuant to this policy.