Business Integrity and Code of Conduct

The Hatch Code of Conduct applies to every Hatch employee, and every Officer and Manager within Hatch's energy unit annually recommits and reconfirms their adherence to its high standards.

The ethical principles embodied in the Code of Conduct form the basis of the Hatch Business Integrity Management System. It is designed to guide Hatch's business practices and enhance the quality of all aspects of our business. The core of the system comprises five formal Procedure documents:

• Code of Conduct Administration
• Business Integrity Management System – Project Audit Procedures
• Selection and Engagement of Third Party Representatives in Foreign Countries
• Selection and Engagement of Subconsultants and Subcontractors in Foreign Countries
• Appropriate Funding of Overseas Client Visitors

Code of Conduct

The Hatch Code of Conduct applies to all employees of the company, and to all Hatch Energy representatives and to some of its subcontractors. It requires adherence to principles organized under the following headings

• social responsibility
• respect for the law
• professional integrity, including corporate ethics and competition standards, application of integrity principles during assignments, corporate and personal conflict of interest and confidentiality
• quality of service, including quality management and continuous improvement
• personal responsibility and accountability, including giving and receiving gifts and accounting practices.

Business Integrity Management System

The Business Integrity Management System (BIMS) provides a framework for verifying that all operations within Hatch Energy are being carried out in accordance with the fundamental principles laid down in the Code of Conduct and in the BIMS Procedure Memoranda. BIMS is an audit-based system modeled on the BIMS advocated by the International Federation of Consulting Engineers (FIDIC) in publications dated 2001 and 2002.

Selection of Representatives and Subconsultants in Foreign Countries

The procedures for selection and engagement of third party representatives and subconsultants define the due diligence process required for the selection and engagement of representatives and subconsultants in certain countries. This includes due diligence processes and agreement procedures, as well as monitoring requirements to be followed during contract execution. The procedures require that all new representative agreements comply with a specific set of agreement principles.