Ethical Code:

Introduction

The Code of Ethics obligates all managers and employees of the EIM Group and its subsidiaries and officers in all positions, including senior officers. The Code of Ethics expresses the standards and rules important to the EIM Group and in any case of ambiguity, the employee is required to contact his superiors to receive instructions and clarifications.

Background

The Code of Ethics of all employees and managers of the EIM Group is a document containing the principles which guide the path towards the realization of the spirit, values and ethics of the Company. This document sets out the rules of behavior resulting from this path. The values included in this Code are fundamentally human and universal and can fit any person at any place and time. The values of the Group as they appear in this document and in the vision and policy documents are the internal and personal compass which guides us to create an ethical and quality work environment that allows us to develop outstanding ingenuity, planning and implementation abilities.

The Purpose of the Code of Ethics:

The purpose of the Code of Ethics is to set standards and tools to maintain the quality of service provided to the customers of the Company while simultaneously maintaining the welfare of the employees and all stakeholders.

Details of the Code of Ethics

1. Fair and healthy work environment

We maintain human dignity, respect the feelings, values, customs and beliefs of others, and make sure not to harm them. We treat fairly and act impartially in all our activities. EIM Group ensures a physically, managerially and socially safe and adequate work environment for its employees, which allows optimal and effective operations. We make sure to maintain security and safety while complying with the laws and with health and safety standards and human engineering rules relevant to our operations. We believe in the existence of a partnership between employees themselves and between the various business divisions. We make sure to protect, to the best of our ability, human rights from the concept as it appears in the UN Declaration documents on Human Rights (December 10, 1948). Moreover, we believe in the existence of a partnership between employees themselves and between the various business divisions. Our sense of partnership is expressed by the understanding and empathy with their needs and the constant care for their well-being. The employees and managers of the Company consider the ethics issues, human and individual rights, health and safety, health and welfare as a superior value. We are committed to ensuring that each employee of the Company will always have the possibility to express himself without fear of sanctions, dismissal or harassment.

2. Marketing, Sales and Customer Relations

We operate with honesty, loyalty to the organization and maintain incorruptibility and integrity within the rules prevailing in the organization and ensure the quality of our personal, organizational and business actions. We are committed to the benefit of our customers. We provide quality, efficient and reliable service while identifying needs in real time and providing a substantive and comprehensive response to these needs. We are committed to ensuring truth in advertising and not presenting false promises or offensive advertising, presenting all the facts to the customer and delivering the right and most accurate message before he decides to perform a business transaction with us in order to lead to a long term position of mutual profit (WIN-WIN). The marketing and sales people understand and are committed to operating in accordance with the following rules:

• Honesty and reliability to the customer and to the salespeople within the Company
• Conducting negotiations while maintaining the respect of the competitors, business fairness and telling the truth
• Commitment to delivering reliable and timely information
• True reporting requirement for managers and decision-makers
• Transparency towards the customer, truth in the details, decency while striving for the performance of the sale
• Must be expressed from the point of making contact with the customer until the supply of the product in order to contribute to the success of the team
• Prohibition of performing a bad sale which will complicate the customer and the Company in the future.
• Maintaining presentability and professionalism in all areas of activity

3. Relations with Stakeholders

EIM Group recognizes its responsibility towards its stakeholders and the importance of creating a broad, transparent, honest and sharing dialogue with them and the opportunities and mutual benefits derived therefrom, and is an essential basis for our operations. We at EIM Group believe that the enlightened and responsible corporation should strive to create value for all of its stakeholders. We are committed to conducting our business activities in a fair and honest manner while maintaining the rights of all parties. In reference to the relations of the Group with its suppliers – the decision-making processes regarding purchase and sale issues will be held in accordance with the law, the procedures and in accordance with the rules of fairness and decency. In reference to strengthening the ties of the Group with the community, we encourage our employees to take part in our activities with the community according to their wishes and areas of interest. We consider the existence of a dialogue with the stakeholders as an essential basis for the activities of the Group and therefore it will be fulfilled.

4. Benefits and Conflicts of Interest

EIM Group conducts its business in a responsible and fair manner, so that all operations are carried out according to the law and beyond its requirements, proper business etiquette and implementation of the Group's Code of Ethics. Consequently, all EIM Group employees are required to operate with integrity, reliability and fairness with all stakeholders Integrity.

We insist on the existence of moral behavior according to moral standards, dignified representation and universal norms while employees, representatives and suppliers fulfil their duties to the Company. We attach most importance to integrity in its activities, including prevention of corruption, public corruption, bribery, favoritism, arbitrary preference, conflict of interest and external considerations. Consequently, EIM Group encourages and enables its employees to report any concerns pertaining to compromising integrity and protects the informer from harm that may be caused to him as a result thereof. Should a suspicion arise that an employee or a Group representative has harmed integrity while carrying out his duties, that person may be obligated to an investigation by the security authorities and the relevant parties, and be reported to the appropriate parties in accordance with the case and circumstances.

Prohibition to accept benefits and gifts

We make sure that all employees, managers and their representatives act with integrity, credibility and decency and in accordance with the rules of the Code of Ethics. As such, we prohibit the acceptance or provision of gifts or benefits (gift, benefit, bonus, payment) involved directly or indirectly, or even apparently, as an attempt to accept any consideration in order not to subject the employee to a situation in which his judgment may be affected while carrying out his duties in providing preferential treatment or an intent to cause a change of decisions.

• An employee is entitled to accept a personal gift of small value from a factor of the EIM Group for a personal occasion or according to practice in accordance with the circumstances of the matter.
• We prohibit our employees from contracting with external factors whom he has direct working ties and purchase from them products / services for private purposes, unless approval is obtained from the factors responsible for the employee.
• We require each employee who received a benefit or gift from an external factor to report it to the supervisor and not accept it, except for acceptable commercial gifts (with a small value, bearing the symbol or name of the company providing them) under the circumstances of the matter.
• We prohibit a supervisor from accepting benefits from an employee he supervises, directly or indirectly, and an employee will not accept a benefit from a supervisor. The EIM Group will prohibit situations of commercial contracting between a supervisor and an employee outside of working hours in order to prevent harm to the proper system of the working relations.
• We permit accepting a gift for a festive occasion of the employee or his family member from acquaintances, guests and invitees he has contact with as a result of carrying out his duties in the EIM Group or with the unit in which he is employed, including a check, a gift check of reasonable value for an occasion of this type.

Conflict of Interest:

• We require our employees to fulfill their duties honestly and fairly and avoid situations or actions that could create conflicts of interest between the benefit of the EIM Group and the personal benefit of the employees or their families / friends or competitors and other foreign parties related thereto and which are in conflict with the EIM Group. The employee is responsible to prevent such situations.
• We require our employees to refrain from investing funds or any other business activity which may create a situation of conflict of interest.
• We require that our employees not be connected, influenced or try to influence a transaction in which they may have a personal interest or benefit from the factor conducting the transaction and which may harm the interest of the EIM Group.
• We prohibit those employed by us to conduct any business or private employment activity with a business organization competing with the Company or with a customer or supplier of the Company, if that activity may create a situation of conflict of interest for the employee in carrying out his duties in the EIM Group, all as specified in the EIM Group procedures.
• An employee of the EIM Group will not receive payment of any type for services rendered for the EIM Group from any source, except for the EIM Group.

In case of doubt, the employee is required to raise the matter with the division or Group manager, and they will be required to provide coherent and detailed reference to his request within a time period of 7 business days.

5. Business Activity Research & Development and Production

We aspire to excel in all areas of our activity and strive to achieve excellence by adoption and bestowment of learning norms, updating, innovation, technological progress and initiative. Employees of the EIM Group perform their work in the most professional manner. The employees must maintain secrecy and confidentiality - facts, data and other information that they obtained in the framework of their work. The professional activities of the employees of the Company will be done with honesty and integrity and will be free and distant of any fraud, deceit, bribery or industrial espionage. The employees of the Company will perform work and services in the areas in which they were trained and certified. Their work will be done professionally and under acceptable standards.

Sincerely;

Itzik Samuel – CEO of EIM Group Avi Dulberg – Board of Directors of EIM Group