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Ethics and Business Integrity

Our Code of Conduct

At Revaz Corp, we are committed to upholding the highest ethical standards in our investment operations and fiduciary responsibilities. As a USA-based energy investment company, we believe that conducting business ethically is not only the right thing to do, but is essential to maintain investor trust, regulatory compliance, and ensure long-term sustainable value creation.

Our Code of Conduct is aimed at embedding Revaz Corp's core values and investment principles in all our activities, and is designed to ensure personal and business integrity at every level of our organization. It provides guidance to help navigate ethical dilemmas we may encounter in our investment analysis, portfolio management, and stakeholder engagements, ensuring we responsibly fulfill our fiduciary obligations. The Code sets out requirements for ethical investment conduct and provides the foundation for our policies, procedures, and compliance guidelines.

Living by the Code is everyone's duty. All investment professionals, employees, officers, and executive staff at Revaz Corp are required to adhere to it. We are also committed to fostering an environment where team members and stakeholders feel comfortable to speak up and report instances of misconduct without fear of retaliation. We have established multiple whistleblowing reporting channels for this purpose, including tools for anonymous reporting and independent evaluation.

The key areas of our Code

Our Code addresses the rules and principles around the following areas:

Integrity
Personal Integrity
Ensuring our personal interests and activities do not conflict with our fiduciary responsibilities at Revaz Corp. Never engaging in fraudulent or unlawful activities, insider trading, market manipulation, or conflicts of interest. All investment professionals must declare all actual, potential, and perceived conflicts of interest and adhere to strict personal trading policies.
Gifts and Entertainment
Gifts and entertainment from and to third parties, including energy companies, service providers, and business partners, are only permitted where they support Revaz Corp's legitimate business interests, are reasonable and appropriate, and do not create conflicts of interest. We must always comply with Revaz Corp's gift policy including mandatory gift declaration requirements.
Bribery and Corruption
It is strictly forbidden to offer, promise, give, pay, demand, or receive anything of value to influence decisions or secure an improper advantage, including facilitation payments. Stricter rules apply to our transactions with public officials.
Business relations
Business Integrity
Always dealing fairly and lawfully with those we interact with and never engaging in unfair, deceptive or misleading practices.
Company Information
Safeguarding all Revaz Corp's non-public information, including material non-public information (MNPI) about investments, portfolio companies, and investment strategies. Maintaining strict confidentiality of investor information and proprietary research. Being cautious in making statements (including on social media) that may impact Revaz Corp's reputation or constitute selective disclosure.
Company Assets
Protecting Revaz Corp assets, including capital, investment data, proprietary systems, and intellectual property, and only using them for legitimate business purposes. Safeguarding investor capital through prudent investment decisions and rigorous risk management.
Working practices
Health, Safety and Environment
Revaz Corp is committed to protecting the health and wellbeing of our team members, fostering a safe workplace, and supporting environmental sustainability through our investment decisions. We prioritize ESG considerations in our energy portfolio to preserve and protect our environment for future generations.
Workplace Practices and Human Rights
Respecting the rights and dignity of employees throughout our own operations and those of our business partners, while being mindful and abiding by applicable data protection rules and regulations.
Whistleblowing
We all have an obligation to uphold Revaz Corp's ethical standards and regulatory compliance. We promote a culture where individuals feel comfortable to speak up without fear of retaliation and expect our team members and stakeholders to promptly report violations they become aware of through our confidential reporting channels.

Ethics initiatives

As part of our commitment to promote a culture of integrity, transparency, and regulatory compliance across Revaz Corp, and to ensure our investment operations are conducted responsibly and ethically, our Compliance & Ethics team carries out regular training, awareness, and communication on the Code of Conduct, fiduciary responsibilities, SEC compliance, anti-bribery and corruption, and whistleblowing for all team members throughout the year.

Key measures that are currently in place include:

Revaz Corp Code of Conduct
All team members are required to read and acknowledge adherence to the Code upon joining the company. New joiners attend comprehensive induction training covering the Code, fiduciary responsibilities, investment ethics, and regulatory compliance, with regular reminders on key ethics topics published through our internal communication platforms throughout the year.
Third Party Code of Conduct
A Third-Party Code of Conduct is in place, setting out the standards of behavior Revaz Corp expects from its business partners, including energy companies, service providers, consultants, and advisors. A copy of the Third-Party Code is available on the Revaz Corp website and provided to all third parties during the onboarding process.
Anti-bribery and Corruption Prevention Policy (ABC policy)
The ABC policy outlines rules to prevent and detect corrupt practices, including obligations to declare conflicts of interest, guidelines and limits on exchange of gifts, hospitality and entertainment and prohibition on bribes and facilitation payments.
Ethics e-learning
Mandatory online training is delivered on the Code of Conduct, investment ethics, fiduciary responsibility, SEC compliance, anti-bribery and corruption, insider trading prevention, whistleblowing, and related topics for all team members and investment professionals.
Ethics Ambassadors
We have a team of Ethics Ambassadors across our investment teams and business units, who serve as the first point of contact to address team member queries on the Code, investment ethics, compliance matters, and related topics.
Whistleblowing Reporting Channels
Supported by Revaz Corp's anti-retaliation policy, multiple whistleblowing reporting channels (email, web, phone, in-person) have been established to facilitate a speak-up culture with tools for confidential and anonymous reporting.
Conflicts of Interest and Gift Declaration System
Revaz Corp has an online system in place to facilitate team members in disclosing conflicts of interest, reporting personal trading activities, and documenting exchanges of gifts, hospitality, and entertainment with third parties in line with the ABC policy and investment industry best practices. All disclosures are reviewed with appropriate risk mitigation applied.
We regularly review and update our policies and procedures to ensure we align with leading ethical practices, while complying with legal and regulatory requirements. Last update December 2023.

Whistleblowing

Speak up - Don't hesitate to escalate

At Revaz Corp we are committed to ethical conduct in our investment operations and business activities. Breaches of our business principles, violations of applicable laws, or concerns about investment practices can be reported confidentially or anonymously. Reports received will be independently evaluated and treated with utmost confidentiality.

Report a concern