Social and Ethics Policy



Background



Revel’s code of ethics requires compliance with the law of every country in which we do business. Our standards go beyond the legal minimum and require a high level of conduct. Our employees are expected to comply with all laws affecting our business, and to act in every respect with honesty, fairness, and integrity. The ethical code is a statement of beliefs that should guide employees’ conduct.

Positive Responsibilities



Each employee has an individual responsibility to deal ethically with our customers and suppliers, fellow employees, and the general public. All employees are expected not only to avoid unethical conduct, but also to take the initiative and assume positive responsibilities for quality, honesty, and fairness. Employees are expected to raise ethical concerns and report any actual or suspected ethical misconduct to their Manager as appropriate. Honesty also requires that employees refuse to participate in any cover-up of such misconduct, and to cooperate fully in any investigation of ethical matters.

Conflicts of Interest



Employees, their spouses and other close family members are expected to avoid outside interests or activities that could be advanced at the expense of our company’s interests. Such involvement creates a potential conflict of interest and includes: non-company business involvement with a competitor, supplier, or customer; working for a competitor, supplier, or customer; and running a side business that will compete with, sell to, or buy from Revel.

Receipt of Gifts



Gifts from suppliers, customers, or competitors to our employees raise the appearance, if not the reality, of dishonest or unfair dealings. It is our policy that all business decisions must be made impartially and fairly, and not on the basis of gratuities offered to employees. No employee, or any of his or her family, may solicit or receive favours, gifts, loans, or other benefits (including service and discounts as well as material goods) from any supplier, customer, or competitor. The only exception to this policy is for casual entertainment or gifts (other than money) of nominal value. Our employees should exercise good judgement in deciding whether to accept a gift of nominal value or casual entertainment and should resolve all doubts and questions in favour of declining to accept the offer.

Use of Company Resources



Each of us has a responsibility to use company resources, including time, materials, equipment and proprietary information, for company business purposes only, and not for personal benefit. Any such personal use, without proper permission, amounts to theft.

All employee requests for reimbursement from the company, whether for medical claims, travel expenses or other business-related items, must be legitimate, properly documented and in accordance with policy. All employees receive, and are expected to maintain, company information in confidence and not disclose or use it other than for company business and for company benefit. This information includes, for example, names of customers, suppliers or employees, manufacturing processes and equipment, product development plans, information systems, business plans, financial and marketing information and all documents and data which relate to such items. All company business and technical information and know-how is a part of the value of the company and employees are expected actively to protect these assets. Persons who use any of this information for their own personal gain or give or sell this information to outsiders will be dismissed and may be subject to prosecution.

Entertainment and Gratuities



We believe that business decisions by our customers should be made solely on the basis of our quality, service, price, and other competitive factors. Gifts and entertainment of nominal value are used only to create goodwill with our customers. If they go beyond this and make the customer feel obligated to offer any special consideration to us, they are unacceptable. Our policy is to avoid even the appearance of favoritism based on business entertainment or gratuities.

Employees should exercise good judgement and moderation and should offer gratuities to customers only to the extent they are in accordance with reasonable customs in the market place. Where there is any doubt, no gifts should be made.

Payments to Third Parties



Payments should be made by the company to third parties only for services or products properly provided to us. No company employee shall make any direct or indirect payment in the nature of a bribe or payoff to secure or maintain business, or for any other purpose, to any customer, supplier, or competitor. In order to avoid even the appearance of improper payments, no payments are to be made by the company in cash, other than documented petty cash disbursements. No group cheques are to be written to “cash,” “bearer,” or third party designees of the person entitled to the payment.

Marketing Practices



The company policy is to comply with all trade regulation laws and to use only ethical and proper methods to market our services and products. All of our customers will be treated fairly and even-handedly, and no preferential trade terms or other treatment will be extended to any customer in violation of any law. To avoid the appearance of improper action, we absolutely prohibit consultations with competitors regarding prices, customers, or territories. Commissions and other payments must be adequately documented and reported to government authorities as required. Advertising must always be in good taste. All claims made in advertisements must be fully supportable.

Environmental Protection



The company fully supports the belief that each of us has a responsibility to protect the environment and human health. It is imperative that each employee accepts responsibility for the observance of laws and regulations governing the protection of the environment and human health. No individual will knowingly buy for use at Revel, or dispose of, other than in accordance with the law, any illegal chemical or other substance. Managers are expected to keep up to date with all relevant laws and regulations concerning the protection of the environment, to seek professional guidance when necessary, and to assure observance of the laws and regulations. We will continue to seek alternatives to hazardous methods, substances, or products to assure protection of the environment and personal safety. Individuals who knowingly violate any environmental law or regulation will be subject to dismissal. Accidental incidents which affect the environment are to be reported immediately to senior management.

Responsibilities to Employees



The company believes that all of its employees should have a safe workplaces and equal opportunities for promotion and advancement. Revel is committed to maintaining safe working conditions in all of its facilities. Employees are expected to assume individual responsibility for safety procedures, following all necessary precautions, avoiding any activity that might endanger themselves or fellow employees, and notifying supervisors and management of any potentially dangerous conditions in the workplace. Management and supervisors are expected promptly to correct and serious safety hazards and to stop any production process involved until the hazard has been corrected.

The company policy is that all of its employees will enjoy a work environment free from sexual harassment. Sexual harassment includes unwelcome sexual advances or requests for sexual favours and the creation of an intimidating, hostile, or offensive work environment through unwelcome sexual conversations, advances, jokes or suggestive objects or pictures. Any complaint of sexual harassment will be immediately investigated and appropriate action, which may include dismissal, taken.

Use of Alcohol and Drugs



The company is strongly committed to the prevention of illegal activities, and to the protection of its employees, company property, and the public from any danger which might result from the use of drugs or alcohol. It is group policy to provide a safe drug-free and alcohol-free work environment. Use or possession of illegal drugs or alcohol during working hours or on company premises is strictly forbidden, and is cause for discipline up to and including dismissal. Employees reporting to work under the influence of drugs or alcohol are subject to discipline up to and including dismissal.

Reporting Practices and Financial Information



Whilst honest differences of opinion are expected, we must base our action on facts, logic and fair play. All reporting at all levels throughout the company must be factual and open. Employees are responsible for ensuring the accuracy and reliability of the company accounts. Fictitious, improper, deceptive, undisclosed or unrecorded accounts of funds or assets are a serious ethical abuse and are illegal. It is the policy of the company that the accounts and records conform to accepted accounting principles and to all applicable laws and regulations. All transactions must be accurately documented and accounted for in the accounts and records of the group. No employees shall enter into any transaction with the understanding that it is other than as described in the supporting documentation. No employee shall participate in obtaining or creating false invoices, payroll records or other misleading documentation, or inventing or using fictitious entities, sales, purchases, services, loans, or other financial arrangements for any purpose. The company will not maintain or use any anonymous (“numbered”) bank account or other account that does not identify company ownership.

Product Integrity



Strict product integrity is necessary for the company to achieve its quality objectives and to maintain its reputation for quality products. It is company policy to never willfully conceal defective work or material, falsify records or make false certification or claims regarding its products. All employees are responsible for ensuring the integrity of the products under their control and for the accuracy of the documentation supporting the product integrity. Incidents of suspected or known concealment of defective work or material, or falsifications of records are to be immediately reported to management.

Community Responsibility



No community’s standard should ever be damaged or debased due to Revel’s presence, but rather should be improved. All employees have an obligation to ensure that their personal behavior reflects this policy. Those managers with lead responsibility of a company establishment in any community must ensure the company makes an appropriate contribution to that community’s overall well-being.

Industry Regulation



It is in all employees’ interests to make a positive contribution to the reputation of our industry by supporting the industry’s education and community relations programmes as appropriate. Employees should also avoid all forms of publicity that will reflect negatively on the industry, for example, by refraining from disparaging or slandering our competitors and their products or services.

Human Rights and Ethical Trading



Revel is committed to human rights and ethical trading in its business activities and employment practices. The company will:

- Conduct its business with integrity, recognizing the economic, social, cultural, political, and civil rights of those involved in the company’s operations and respecting the different cultures and the dignity and rights of individuals in the countries where it operates;
- Comply with national laws and be guided by the general principles of international law, especially for the purposes of this policy with respect to human rights;
- Accept that we have an obligation to promote respect for and observance of human rights and fundamental freedoms for all, without distinction as to race, creed, colour, nationality, ethnic origin, age, religion or similar belief, political affiliation, gender, gender reassignment, sexual orientation, marital status, family connections, membership or non-membership of a trade union disability or any other group;
- Not employ underage staff;
- Encourage suppliers and subcontractors to abide by the same principles;
- Ensure that for staff, subcontractors, and suppliers, the terms of engagement will be clear, fair, and reasonable in comparison with those offered by similar companies;
- Strive, at all times, to provide customers with the standards of products and services that have been agreed.

Application of the Code



All employees are expected to be familiar with and to observe the ethical standards outlined in this code. Abuse of the company ethical code may be grounds for dismissal and the abuser could be subject to legal action. Managers are responsible for ensuring the application of this ethical code by monitoring and enforcing the code within their areas. All of the company managers are expected to lead by example and communicate a real concern for the observance of these ethical guidelines.

Personal Responsibility



Each of us should take pride in the high standard of conduct that has always defined us as Revel employees. Let us resolve together to continue to be a Group which will tolerate nothing less than complete honesty, fairness, and integrity in our dealings with all individuals, social groups, and businesses that depend on us.

Corporate Social Responsibility



Environmental, social and ethical issues



Revel takes account of the significance of environmental, social and ethical matters to its business.

Environmental



Revel and its employees take collective responsibility for environmental matters, including promoting and monitoring compliance with the environmental policy.

Revel will find ways of reducing its environmental impact and serving the needs of customers who are becoming increasingly environmentally aware. Revel will also record and monitor waste levels, with the objective of achieving annual reductions.

Revel is committed to continue with its work to seek to reduce the environmental impact of our operations.

Social and ethical



Revel has a comprehensive ethics policy. Each employee has an individual responsibility to deal ethically with customers, suppliers, fellow employees and the general public. The policy has been effective in defining the ethical standards to be followed throughout the company.

The policy requires the company to make appropriate contributions to the local community’s well-being. This is achieved by charitable donations, close involvement with local schools and colleges and provision of training and work experience opportunities.