This Policy enjoins Covered Individuals to always act in the best interest of the MNC Group, consistent with sound business principles and judgment, and without bias or partiality. This Policy requires Covered Individuals who find themselves in a potential or actual conflict of interest situation to promptly disclose the matter and, as applicable, seek approval from the proper authorities. Unless otherwise authorized by the MNC Group, the Covered Individual concerned is required to inhibit himself from any action, transaction, discussion, evaluation, or decision involving any matter where such conflict of interest exists. This Policy also prohibits any MNC Group entity from granting personal loans to directors or officers unless the same is a regular employment benefit given by the Company to employees in the same benefit group and unless allowed by applicable laws and regulations.

There is conflict of interest when a Covered Individual has a personal or pecuniary interest which influences or could influence his/her ability to exercise objectivity and perform his/her responsibilities in the best interest of the MNC Group.

Common examples of actual, perceived or potential conflicts of interest include:

• pursuing, awarding or maintaining MNC Group business opportunities for personal gain or the benefit of close relatives or friends;
• holding outside jobs or affiliations, including directorships, that would impair his ability to perform his duties and commitments to MNC or the MNC Group;
• holding investments directly or indirectly in businesses or assets that are contracted to do business for or on behalf of any MNC Group entity;
• receiving money, property, services or other forms of benefits, financial or otherwise, from suppliers or other third parties doing, or proposing to do, business with the MNC Group;
• influencing the results of a bid or tender;
• offering jobs or affiliations to close relatives or friends; and
• offering or accepting more than a modest amount of gifts, hospitality and entertainment.