91AV

1. Introduction

The 91AV (“RSC”) is committed to acting ethically and with integrity at all times. To achieve this, the RSC has implemented and enforces effective systems and controls in all its business dealings and relationships throughout the world.

2. Purpose of this Code of Conduct

The RSC has established this Code of Conduct to communicate the standards it requires from its associates, which may include contractors, distributors, suppliers, agents, funding partners, third party representatives and all others who have, or seek to have, a business relationship with the RSC (“Associates”).

To work with the RSC, Associates are required to:

• respect the principles of this Code of Conduct,
• adopt practices within their own operations and supply chains that are consistent with it, and
• act at all times in compliance with the same.

3. Legal Requirements

There shall be full compliance with local and international law, as well as relevant regulations and standards.

This Code of Conduct may require additional compliance in countries where legal requirements fall below the principles outlined in our Code of Conduct.

4. Modern Slavery

Modern slavery is a criminal offence under the Modern Slavery Act 2015 and a violation of fundamental human rights. Modern slavery can occur in various forms, including the offences of:-

• holding another person in slavery or servitude;
• forced and compulsory labour; and
• human trafficking for exploitation

all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

The RSC has a zero-tolerance approach to modern slavery and is committed to identifying and minimising so far as possible the risk of slavery and human trafficking occurring in its supply chains and in all areas of its business.

The RSC is committed to ensuring there is transparency within its organisation, and in its approach to tackling modern slavery throughout its business supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015. The RSC expects the same high standards from its Associates.

As part of the RSC’s contracting processes, specific obligations against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, are included in our terms and conditions. Again, the RSC expects its Associates to hold their own suppliers to the same high standards.

The prevention, detection and reporting of modern slavery in any area of the RSC’s business or supply chains is the responsibility of all those working for the RSC or under the RSC’s control. Associates are required to avoid any activity that might lead to, or suggest, a breach of this Code of Conduct. Policies and procedures must be implemented and monitored to ensure modern slavery is not taking place anywhere in an Associate’s own business or supply chains and employees, suppliers and all those reporting to an Associate should receive training on the issue of modern slavery to a level relevant to their role.

5. Human Rights (not covered by the Modern Slavery Act 2015)

Policies that are consistent with the spirit and intent of the Human Rights Act 1998 should also be adopted. Such policies may include:

• elimination of discrimination in employment;
• prohibition of child labour;
• eradication of harassment, physical or mental punishment or abuse;
• reasonable wages (including, at least, the minimum wage) and hours of work; and
• freedom of association.

6. Health and Safety

The RSC expects its Associates to provide its employees with a safe and healthy work environment.

Policies and procedures regarding the prevention of ill health and injury should be implemented through the training of our Associates’ employees to a level relevant to their role.

Performance should be continually measured and systems must be in place to mitigate and manage risk.

7. Environment

Our Associates should have in place initiatives to minimise their negative impact upon the environment, and to maximise resource efficiency wherever possible.

8. Bribery and Corruption

The RSC is committed to the elimination of bribery and corruption wherever it may occur, and therefore, the following are expressly prohibited:-

• offers to pay, solicit or accept bribes in any form whether directly or indirectly. This includes facilitation payments, which are small payments or gifts made to obtain approvals or permits more speedily, for example;
• engagement in commercial espionage, covert surveillance of competitors or other activities that would lead to an unfair competitive advantage or anti-trust.

The RSC will not make political donations anywhere in the world.

9. Compliance & Verification

The RSC will seek assurance that its Associates adhere to the principles of this Code of Conduct and are taking responsibility to ensure compliance in their own supply chains. In order to monitor compliance, the RSC may audit its Associates at any time, upon request and with reasonable notice.

If an Associate believes or suspects a breach of this Code of Conduct has occurred or may occur in the future, it must notify its RSC representative contact via email and the RSC Legal Team as soon as possible.

10. Updates/Revisions

This Code of Conduct is subject to amendment from time to time by the RSC in accordance with the Bribery Act 2010, the Modern Slavery Act 2015 and any other relevant human rights legislation.