Our Code of Ethical Conduct

Rehlko is committed to compliance with all laws and regulations in the countries where we operate. This Code is the foundation of our commitment to ethical business practices. It sets out the standards for how we interact with each other and engage in business activities globally. Additionally, the Code summarizes the guidance and expectations set out in each of our Global Core Policies.

The Code applies to Rehlko (the Company), subsidiaries, associates, those who work for or represent Rehlko, and members of the Board of Directors when acting in their capacity for Rehlko.

Violation of this Code and Company policies may result in disciplinary action, up to and including termination of employment.

Whatever our role at Rehlko, ethics should be central to every business decision we make. All associates must take personal responsibility for knowing and following the law, being honest and objective, competing fairly, respecting others, building trust, exhibiting loyalty, avoiding conflicts of interest, and protecting Rehlko's positive reputation.

Even if there is no specific policy or law to follow, we will make the best decisions for Rehlko when we are committed to acting with integrity and asking for help in situations where doing the right thing is not entirely clear. We must not allow business goals to cause us to lose sight of our commitment to ethical business practices.

Remember:

To help determine the right path, we should ask these questions when making decisions or taking action in our role:

• Is this legal?

• Is this consistent with our Code and policies?

• Does this reinforce Rehlko’s reputation as an ethical company?

• How would this look to others within Rehlko and externally?

Associates:

Associates can do the right thing, every day, by:

Understanding the Code and Global Core Policies

Gaining a deeper understanding of other policies directly applicable to our position, business, or function;

Being truthful and behaving in a transparent and authentic way;

Being accountable for an ethical work environment;

Completing relevant compliance and ethics training; and

Being committed, promptly speaking up when something is not right, and cooperating fully and honestly if concerns are raised.

People Leaders:

Managers and leaders have increased responsibility for laying the foundation for a culture of compliance and ethics by:

Serving as a positive role model of integrity with words and actions;

Emphasizing Rehlko ethics in decision making;

Knowing and sharing key risks that impact our business activities;

Creating an environment where associates are empowered to respectfully challenge the status quo, ask questions, and raise concerns;

Preventing retaliation against those who speak up; and

Recognizing those who exemplify integrity and compliance.

At Rehlko, we strive to create a diverse and inclusive culture where we bring our full selves to work and know we are valued team members working together with a shared purpose. The variety of our backgrounds and experiences contributes to the success of Rehlko.

Rehlko is committed to fairness in all employment-related processes and programs. Rehlko provides equal employment opportunity to all individuals regardless of race, creed, color, religion, gender, gender identity or expression, age, national origin, disability, veteran status, marital status, sexual orientation, military status, or any other characteristic protected by law.

Rehlko is also committed to fairly paying associates in compliance with all applicable wage and hour laws, rules, and regulations. Employment at Rehlko is freely chosen, and associates are free to leave at any time.

Our Role

As associates, we support these commitments by:

Ensuring employment decisions are based on ability and not on beliefs or any other personal characteristic;

Providing fair and equitable wages, benefits, and other employment conditions in accordance with local laws;

Prohibiting the use of forced, involuntary, and child labor and the unreasonable restriction of associates’ freedom of movement; and

Ensuring our suppliers and business partners uphold the same principles.

The Scenario

When first hired and as a transgender woman, Pat was confident in the Company’s commitment to providing an equal opportunity work environment. But during the first few months on the job, Pat quickly felt discriminated against because of their identity as a transgender woman. It was not anything blatant, but Pat was not given the same challenging assignments, responsibilities, and opportunities as team members who identify differently. Although there was no one specific situation that represented Pat’s concerns, the situation had to be addressed.

Our Stance

At Rehlko, our fair employment practices policy must be represented and upheld beyond the recruiting and hiring process. Concerns should be brought to a manager or supervisor, Human Resources, Legal, Compliance and Ethics, or the Ethics Helpline.

Rehlko’s Commitment

Rehlko believes that experiences in the workplace have the power to influence our lives and change the direction of our future. In addition, Rehlko believes that a respectful workplace is the foundation of a great place to work and one that sparks creativity and enhances a sense of mutual trust.

With that in mind, Rehlko is committed to providing such a work environment—one that is free of all forms of harassment, including sexual harassment and bullying.

Our Role

As associates, we support this commitment by treating one another with respect and dignity, embracing diversity, and supporting an inclusive workplace. In addition, we do not engage in prohibited behaviors, which include, but are not limited to:

Unwelcomed conduct or statements of any kind that causes others to feel uncomfortable or intimidated;

Belittling or humiliating comments or nicknames;

Threatening or intimidating conduct;

Sexually explicit or suggestive remarks, texts, or emails;

Sexual advances or unwanted physical contact; and

Racial, ethnic, gender, or religious slurs or offensive comments about gender identity or sexual orientation.

Remember:

Harassment is determined by actions and words and how they impact others, regardless of intent. As associates, we speak up if we witness these behaviors so they can be immediately addressed.

The Scenario

Chris has been hired full time at the Company. One of the senior managers from a different department always makes an extra effort to stop by Chris’s desk, which is something the manager does not do with other new. The manager recently texted Chris with an invite to a weekend night dinner. Chris was uncomfortable with this invite and declined. The manager hinted that if Chris attended dinner, the manager would consider recommending Chris for a higher role within the Company. Chris is uncomfortable with the manager’s behavior and comments.

What action should Chris take?

Our Stance

Rehlko is firmly committed to providing a respectful work environment for all associates free of all forms of harassment. Chris should immediately discuss this situation with a direct manager, Human Resources, or the Ethics Helpline. Likewise, coworkers who witness this situation are expected to report it to management, Human Resources, or the Ethics Helpline.

Rehlko’s Commitment

Rehlko has had a long-standing commitment to provide a safe workplace for all associates and to establish programs promoting high standards of associate health and safety. The use of alcohol and controlled substances may affect the workplace and the performance of job duties and create an unsafe environment for associates and our suppliers, customers, and business partners. For these reasons, Rehlko is committed to providing an environment free from alcohol and other drug use.

Our Role

As associates, we support this commitment by:

Never possessing, distributing, or using alcohol during working hours or on Company property at any time unless previously approved by leadership for a Company-sponsored corporate event;

Never possessing, distributing, or using illegal drugs during working hours on Company property at any time; and

Notifying management about any use of legally prescribed or over-the-counter drugs for medical purposes that may impair our ability to work safely or affect the safety of others.

All associates must report to work in suitable mental and physical condition and consistently and safely perform work for and on behalf of Rehlko.