The IDW Code Of Ethics (amended and restated)




Applicability :

The IDW Code of Ethics ("CODE") applies to all personnel of IDW and its subsidiaries from Executive Committee member to Operator. It covers in broad terms what IDW expects from all of its employees and will be interpreted in the light of each person's responsibility and job function.


Dissemination :

The Code shall be available on the intranet and on notice boards throughout all general offices and factories that IDW operates. It should be read to and by all new recruits as part of the job acceptance process. It shall be published in English and Chinese.


IDW as a company and each employee in it shall not discriminate on the basis of race, sex or age. It shall be sensitive to cultural differences in the regions in which it operates and shall adopt the best practices available internationally.


All employees shall:

Deal honestly with their colleagues, customers and suppliers.

Provide full details of all relationships that may, in the course of a transaction be construed as creating a conflict of interest or appearance of a conflict of interest. A "conflict of interest" exists when an individual's private interests interfere or conflict in any way (or even appear to interfere or conflict) with the interests of IDW.

Shall proactively provide all information to their superiors that may have a material influence on matters under consideration

Shall support and maintain systems of internal control and internal check and not seek to over ride them by acts of omission or commission

Shall report (see below) all irregularities that come to their attention, irrespective of by whom committed and regardless of whether they fall within their span of responsibility

Shall protect the interests of shareholders

Shall abide by the laws and regulations of the country in which they operate and the laws and regulations that govern IDW

Shall provide full, fair, accurate, timely and understandable information in all internal reports and documents filed with the Securities and Exchange Commission or releases to the public.

Shall act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing their independent judgment to be subordinated.

Shall protect and respect the confidentiality of information acquired in the course of their work except when authorized or otherwise legally obligated to disclose and shall not use confidential information acquired in the course of their work for personal advantage.

Shall achieve responsible use of and control over all assets and resources employed by or entrusted to them.

The above general principals provide the framework within which the operations of each department are to be managed and the management of each manager. They provide both specific goals and behavior patterns for IDW, which managers should give effect to, and standards of behavior for each department.


IDW shall:

Deal fairly with all current, prospective and departing employees.


Promote and remunerate on the basis of ability and performance.


Participate and support the communities in which it does business.


Protect the environment to the best of its ability.


Encourage and promote best practice seeking to raise standards both internally and externally rather than accepting the status quo.


Communicate effectively with employees and provide communication lines such that all issues may be raised.



Shall establish and maintain systems in accordance with our established certifications and generally accepted best practice.


Shall faithfully record and report all findings irrespective of cause, responsibility or consequence.



Shall take all steps necessary to record and preserve IDW's assets.


Shall maintain systems to accurately record and present the operations of IDW, openly disclosing value judgments and estimates incorporated in presentations and using generally accepted accounting principles and policies. The principal executive officer and the principal financial officer shall review the annual and quarterly reports, certifying the accuracy of the information, prior to filing with the Securities and Exchange Commission.


Reporting of Breaches or Suspected Breaches

It is the responsibility of every member of staff to promptly report breaches or suspected breaches of the code.


Unless the suspected breach is by an employee's immediate supervisor the normal channel of reporting is through the employee's supervisor with a copy to the HR manager. In the case of suspected breaches by managers the reporting channel is to the CFO, with a copy to the CEO. In the case of suspected breaches by a member of the Executive Committee the procedure is to report to another member of the Executive Committee with a copy to the Chairman of the Audit Committee. ( All contact information is provided on the contact section of the intranet.


Employees are expected to cooperate in internal investigations of misconduct and violations of this Code.


Employees should be aware that IDW has a statutory duty to protect any employee who reports his or her concerns in good faith and to insure that there is no retaliation. Reports will be treated in a confidential manner.


Waivers of the Code

Any waiver of this Code may be made only by the Audit Committee of the Board of Directors and will be promptly disclosed as required by law or the private regulatory body. Requests for waivers must be made in writing to IDW's Chairman of the Board and Audit Committee Chairman prior to the occurrence of the violation of the Code.


The Code is the minimum standard of behavior IDW expects of its employees. Breaches will be taken into account when assessing performance pay, discretionary bonuses, merit raises, renewal of fixed term contracts etc. In extreme material cases, IDW may deem a breach of the Code a breach of your employment contract or the terms of your employment and consider such breach termination for cause. Such violator may also be subject to civil action and/or referral to law enforcement agencies for criminal prosecution.