The integrity and good reputation of a company represent crucial competitive advantages. As a corporate group operating on a global scale, the Adval Tech Group (hereinafter referred to as'Adval Tech') not only complies with the relevant national legislation and regulations but alsocultivates commercial relationships established on the basis of trust and honesty with all its partners.

The Board of Directors of Adval Tech Holding AG has issued these regulations on the basis ofArt. 716b of the [Swiss] Code of Obligations (OR), Art. 17, sub-paragraph 2 of the Articles ofAssociation and no. 2.1.1.2 of the Organizational Rules.

These regulations governing behaviour in business relationships, hereinafter referred to as 'the regulations', apply to all managers and employees of companies under the managerial control of Adval Tech. Consultants, representatives or sub-suppliers are required to comply with the regulations appropriately in their business relationship with Adval Tech.

Adval Tech adheres to the principle of good corporate citizenship. All managers and employees of Adval Tech must comply with national legislation in the various countries in which Adval Tech operates.

Adval Tech observes the human rights of its employees and ensures that they have good, safe working conditions. Adval Tech will not tolerate any discrimination on the basis of race, sex, religion or membership in trade unions or political parties.

Adval Tech is committed to sustainable development and takes all necessary actions to protect the environment within its sphere of influence. In accordance with this obligation, the Adval Tech Group companies pursue a comprehensive approach in terms of health, safety and environmental management in order to achieve continuous performance improvement in this field.

All managers and employees of Adval Tech must refrain from action which could damage the trust of our business partners and the public in Adval Tech. In particular, corrupt, immoral action is expressly prohibited. Executive bodies and employees are prohibited from promising officials of a government or third parties inadmissible advantages for the purpose of obtaining or receiving transactions or partial transactions or from paying or approving bribes.

Furthermore, Adval Tech complies with applicable monopoly legislation and the corresponding legislation on pricing, competition law and consumer protection.

Managers and employees of Adval Tech may not accept any gifts or favours from suppliers, customers or other business partners. This prohibition does not extend to less valuable items or to invitations to ordinary business events. Visits upon invitation by the customer to events lasting longer than one day or requiring extended travel must be approved by the relevant line manager. Cases of doubt must be discussed with the line manager.

Managers and employees of Adval Tech must avoid situations which may lead to conflict between their personal interests and those of Adval Tech. Managers and employees of Adval Tech with interests in companies with which Adval Tech Group companies maintain a commercial relationship must disclose their financial or other interests. All financial interests must be disclosed to the line manager and the responsible member of Group Management. Other interests to be disclosed include all positions such as membership of boards of directors or advisory boards, etc. and all consultancies. This disclosure requirement also applies to family members, e.g. spouses, parents, children, siblings and their spouses.

All managers and employees of Adval Tech must comply with the regulations. They represent a substantial component of the contract of employment and must be issued to new managers and employees on commencement of their employment. Managers and employees who infringe the regulations will be subject to disciplinary measures in accordance with local company rules, including the possible termination of their employment. Enquiries or the discovery of infringements of these principles must be sent to Mr Roland Waibel, Member of the Board of Directors of Adval Tech Holding AG and Chairman of the Audit Committee, Hasenrain 26, 4106 Therwil. Line managers must not discriminate against employees who ask questions or report infringements of the regulations.

The regulations were approved at the meeting of the Board of Directors on 10 July 2007 and came into effect immediately. They may be amended or expanded by the Board of Directors at any time.