Reibus Code of Conduct

Our Core Values

Reibus (“Reibus” or the “Company”) was founded with two principal goals: 1. Modernize the industrial materials industry. 2. Always be a great place to work. What’s a great place to work? We think it’s a place where you can do and be your best, where you are safe, supported, and encouraged to expand your horizons, and where your workdays fly by because you’re having fun and focused on the exciting challenges before us. We want employees who are always trying to improve, always trying to have a greater positive impact, and always trying to be better than the day before.

We can’t achieve our goals without great people. We’ve assembled a stellar team by focusing on exceptional candidates who share our values:

Courage: Have the courage to fail, to voice your opinions, to challenge the consensus, and to face your own weaknesses.

Curiosity: Be open to new ideas. Learn more every day. Ask questions. Seek out and find answers. Bring new solutions.

Grit: Stick with it. Don’t give up. Push through the challenges. Never stop trying. Find a way to get it done.

Ownership: Always behave like an owner. Take initiative. Own the outcome and always do the right thing.

Honesty: Tell the truth. Be yourself. Say what you mean. Show respect and understand your impact on others.

The Reibus Why: Make a positive impact by constantly challenging the status quo.

About this Code

The Reibus Code of Conduct (“Code”) guides our ethical and legal responsibilities to each other, our customers, and our business partners. The Code applies to all of us, at every level and at every location. It’s intended to assist you in identifying ethical and legal issues that may arise. Importantly, the Code explains how to voice a concern or ask questions if something is unclear.

While Reibus’s guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct.

Honesty and Ownership are key aspects of our culture. You are responsible for understanding this Code, as well as other Reibus policies and guiding resources. Anyone who violates (or fails to report a violation of) our Code, our policies, or applicable laws/regulations is subject to disciplinary action, up to and including termination of your role with Reibus.

Trust to Do the Right Thing

We give everyone who joins our team a lot of trust and responsibility. We operate under the assumption that all our people will do the right thing, including you.

At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. At Reibus, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that Reibus is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.

When in doubt, ask yourself:

• Does what I am doing comply with the Reibus guiding principles, Code of Conduct and Company policies?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if it made the headlines?
• Am I being loyal to my family, my Company and myself?
• What would I tell my child to do?
• Is this the right thing to do?

Senior leadership and Management have the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is a product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example.

To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication.

How to Report Concerns

If you become aware of any actual, suspected, or potential violation of any aspect of this Policy, you must promptly inform your manager or contact the Company’s Legal Department.

In addition to other means, suspected incidences of non-compliance with this Policy can be reported directly to John Blount by emailing him at jblount@reibus.com, or to the Legal Department by e-mailing legal@reibus.com, or anonymously via AllVoices, Reibus’ internal reporting platform, by visiting https://reibus.allvoices.co/.

Commitment to our Colleagues

We all deserve to work in an environment where we are treated with dignity and respect. Reibus is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.

Reibus is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types and from abusive, offensive, or harassing behavior. Any employee who feels harassed or discriminated against should report the incident to his or her manager or to the People & Culture team.

We Do Not Tolerate Discriminatory Behavior or Harassment

All Reibus employees are also expected to support an inclusive workplace by adhering to the following conduct standards:

• Treat others with dignity and respect at all times.
• Address and report inappropriate behavior and comments that are discriminatory, harassing, abusive, offensive, or unwelcome.
• Foster teamwork and employee participation, encouraging the representation of different employee perspectives.
• Seek out insights from employees with different experiences, perspectives, and backgrounds.
• Be open-minded and listen when given constructive feedback regarding others’ perception of your conduct.

Reibus will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive, or unwelcome. Further guidance can be found in Reibus’ Anti-Harassment and Anti-Discrimination Policy.

We Create a Culture of Open and Honest Communication

Anyone at Reibus can and should communicate with anyone else according to what they think is the fastest way to solve a problem for the benefit of the Company. You can reach out to your manager, your manager’s manager, the CEO, or anyone else in the Company, and you don’t need anyone’s permission. In fact, you should consider yourself obligated to do so until the right thing happens.

Disagreements happen all the time, however they are not an excuse for poor behavior or personal attacks. We should accept that different people have different perspective and try to understand why. This diversity only makes our business stronger. Show respect and empathy to everyone at Reibus and our business partners.

At Reibus everyone should feel comfortable to speak his or her mind, particularly with respect to ethics concerns. Reibus will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the Company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.

We Create a Safe Workplace

Safety is critically important to us. You can’t be your best if you get hurt and your co-workers can’t be their best if you hurt them. Use good judgment and common sense. Be safety-conscious at all times, comply with any safety procedures, and never do a task that you feel is unsafe. When driving, remain alert, obey all traffic laws, and be courteous to other drivers. Keep work areas clean and free of unnecessary hazards. Immediately report any safety issues you see or safety improvement you identify.

Commitment to our Customers and Business Partners

We Conduct Business Lawfully

Reibus’s commitment to integrity begins with complying with laws, rules, and regulations where we do business. Further, each of us must understand the Company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Reibus policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations.

Proprietary Information

It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

Anti-Corruption

Reibus will not directly or indirectly offer, promise to pay, or authorize the payment of money or anything of value to foreign government officials, parties or candidates for the purpose of influencing the acts or decisions of foreign officials.

Selective Disclosure

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to Reibus, its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.

Global Trade

Reibus is committed to complying with all applicable laws that govern global trade for Reibus’ business, including customs, export controls, and anti-boycott regulations. It is the responsibility of any personnel who is involved in the procurement, sale, distribution, or shipment of any Reibus material to understand the relevant laws. We also expect our agents and vendors to understand the laws that apply.

Forced Labor, Child Forced Labor and Human Trafficking

Reibus will not tolerate, engage, or support Forced Labor, Child Forced Labor, or Human Trafficking through any activities, including through the Company’s supply chain.

We Protect Confidential and Proprietary Information

Integral to Reibus’s business success is our protection of confidential Company information, as well as nonpublic information entrusted to us by employees, customers, and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

We Do Not Engage in Any Form of Bribery

Reibus is committed to competing solely on the merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities by Reibus was sought, received, or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom Reibus does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation, or policies of Reibus or customers, or would cause embarrassment or reflect negatively on Reibus’s reputation. Provision of any gift, hospitality (including any meals or entertainment), or anything else of value to a government official is prohibited.

We Avoid Conflicts of Interest

At times, we may be faced with situations where the business actions we take on behalf of Reibus may conflict with our own personal or family interests. We owe a duty to Reibus to advance its legitimate interests when the opportunity to do so arises. We must never use Reibus property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Reibus.

Here are some other ways in which conflicts of interest could arise:

• Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier, or contractor, regardless of the nature of the employment, while you are employed with Reibus.
• Hiring or supervising family members or closely related persons.
• Serving as a board member for a competitor or potential competing company or organization.
• Owning or having a substantial interest in a competitor, supplier, or contractor.
• Having a personal interest, financial interest, or potential gain in any Reibus transaction.
• Placing Company business with a firm owned or controlled by a Reibus employee or his or her family.

Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict-of-interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or the People & Culture team.

We Report Results Accurately

We create, retain, and dispose of our Company records as part of our normal course of business in compliance with all Reibus policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and Company data must be promptly and accurately entered in our books in accordance with Reibus’s and other applicable accounting principles. We must not improperly influence, manipulate, or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of Reibus books, records, processes or internal controls.

Summary

At Reibus, we respect all our employees and want to provide everyone with an enjoyable environment where they can have fun and do their best. We expect everyone to treat others the way you would want to be treated, while abiding by our culture, our values, our guiding principles, and the law. If we do this, we have everything we need to succeed and do great things.