Code of Conduct

SMS Equipment Inc. is committed to being a corporate leader in ethical practices and will maintain high ethical standards in its activities, and fairness and honesty in its business relationships. As part of our Corporate Governance, the Company has a Code of Conduct which applies to all employees and representatives of the SMS Equipment Inc.

Anti-Bribery, Fraud and Corruption Policy

SMS recognizes that bribery, fraud, corruption and other unlawful acts introduce uncertainty into commercial transactions, foster an environment for other business crimes, and have the potential to put our Company’s value and reputation at risk. The Company has adopted this policy to ensure the ongoing success of our organization and to protect the best interests of the Company, it’s employees, vendors and customers from any illegal or damaging actions, committed by individuals either knowingly or unknowingly. Similar to the Code of Conduct, this policy applies to all stakeholders. It outlines the responsibilities and expectations of the Company and its employees for preventing, detecting and investigating acts or instances of bribery, fraud and corruption.