Preamble:


All H&H Metals Corporation management and employees are responsible for adhering to ethical business practice, mining safety and prevailing law.  Failure to adhere to acceptable business practice and civil ethical behavior will result in the appropriate consequences, both by the company and by the laws of the prevailing country.

All employees are responsible to report any behavior that is deemed to be contrary to good business ethics to the company. In addition, it is the company's responsibility to report any unlawful conduct to the necessary authorities.

All H&H Metals adhere to the principles of the Foreign Corrupt Practices Act  (http://www.justice.gov/criminal/fraud/fcpa/guide.pdf). 


Article 1: Declaration of Principles

Members shall perform work only in their areas of competence.
Mining is a privilege granted by local and prevailing law.  All Members recognize the privilege requires expertise of mining and strict attention to safety of self and others. All members shall at all times be responsible for the welfare and health of the community

Article 2: Professionalism                                                                                   

H&H Metals Corporation in New York has been built on professional and personal respect in all its dealings. As a company, it guides its conduct by principles, such as honesty, integrity, loyalty and human kindness.

It is also H&H Metal’s responsibility to adhere closely to the laws of the respective countries where it is practicing business.

The company also endeavors to maintain a good working environment by honest, open and effective communication between employees and management.

Article 3: Conflicts of Interest

H&H Metals will not allow bribes in the form of evading customs, obtaining false documents,  lowering tax assessments and/or any form of a bribe.  H&H Metals Corp employees and management will not solicit any gifts or gifts of cash that would compromise or influence them to make unsound business decisions.

All employees and management will strive to act only in the best interests of the company. Any conflict of interests, which will make it difficult for an employee or management to act in the best interests of the company, should be avoided. Any work that would only benefit the personal gain of the individual at the expense of the company, which would constitute improper gain, would be a conflict of interest to the company.

H&H Metals Corporation recognizes the right of employees and management to take part in financial and business activities outside of their company work, but these should not be at the expense of the company or in conflict with its business interests. Any such activity would compromise their personal judgment within the company.

Any employee or management of H&H Metals Corp may not work as employees or consultants to outside companies that would constitute competitors, or potential business partners with H&H Metals Corp, without the prior consent of the company management.

If conflicts of interest are persistent and there is not sound judgment on the part of an employee or director, H&H Metal’s general policy will be to correct the situation in the best interests of the company, allowing reasonable time to prevent unnecessary hardship for the person involved.

Article 4: Proper Use of Assets

H&H Metals abides by the terms of each respective contract.  Any asset being mined, processed, transported, delivered and/or in any stage of process is accurately analyzed, accounted and executed in accordance and  not limited to local law.

All employees and management are expected to be prudent with Company assets. This includes protecting company assets from loss, theft, misuse, damage and waste. Proper use of assets also includes proper use of work time and company property.

Article 5: Public Disclosure

H&H Metals Corp commitment is to provide timely, accurate and factual information to its respective business units and accountants.

Article 6: Accounting Practices

H&H Metals Corp accounting will reflect an accurate and complete record, with reasonable detail of business transactions undertaken by the company. These records stored in hard copy for 5 years.  Each employee and person in management must work to facilitate accurate records for accounting and proper expenditure by the company.

Article 7: Confidentiality

Employees and management must maintain confidentiality on matters of business or financial importance. This obligation extends beyond the term of employment with the company. Where applicable, the company will request an employee to complete a Non Compete and Confidentiality Agreement.

Article 8: Discrimination and Harassment

H&H Metals Corp does not tolerate any discrimination due to, race, cultural or spiritual background of any employees or management.

It is believed that all employees and management will act with professionalism free from bias or harassment.

Article 9: Compliance

H&H Metals Corp is committed to comply with all laws, and regulations in any jurisdiction in which it chooses to operate as a company.

All employees and management are expected to inform themselves to the best of their ability of all laws and regulations governing their business in the district they are operating in, and to adhere to such.

It is also H&H Metals Corp policy that neither the company, nor its employees or management shall accept, pay for or promise to give anything to any government official, Government Department, political party or Government committee for any purpose other than according to the law of the country in which a bonafide receipt is required, or for the purpose of unjust gain, either that would benefit the company or indirectly benefit them on behalf of the company.

Article 10: Health & Safety

H&H Metals Corp will practice business with a sound mind in compliance with the safety regulations governing the mining industry and with the standards of the local office.

All employees and management will be helped to maintain a healthy and happy outlook while working for the company.

Corporate code of Ethics

H & H Metals Corporation