Statement of Corporate Ethics

It is the policy of RMX BSL LLC dba Rymax (“Rymax”) to conduct its business in an honest and forthright manner. To this end, Rymax employees strive for excellence in their work and for a consistent standard of integrity in their business dealings.

Consistent with this objective is Rymax’s requirement that all employees comply with company policies, and all relevant laws and regulations in conducting the company’s business. No violation of the spirit or intent of these policies, laws and regulations will be tolerated.

To maintain consistent standards of integrity:

1. Rymax employees shall not become involved in any activity which might influence, be reasonably expected to influence, or give the appearance of influencing their objective business judgment in dealing with others. Employees shall not become involved in conflict of interest situations.
2. No Rymax employee shall engage in illegal or unethical actions involving any person or organization doing business or attempting to do business with the Rymax.
3. Rymax employees shall maintain complete and accurate books, records and documentation in accordance with the accounting rules and controls established by the Rymax.
4. Employees who are officers, directors, division directors or managers, shall have responsibility: (a) to insure that these policies are annually communicated to the employees reporting to them; (b) to clarify and explain said policies when necessary; (c) to monitor compliance therewith, and (d) to report all known (or suspected) violations of said policies to the Executive Vice President of the Rymax, or to other persons whom they designate, as appropriate.

Where a question arises whether a particular anticipated course of business conduct is ethical or legal, the individual contemplating the action or directed to perform the action shall seek advice from the Office of the General Counsel of the Rymax.

Failure to comply with this policy and any specific implementing policies may result in dismissal from employment or other disciplinary action. Violations of law will be reported to appropriate law enforcement officials.

Consistent with historic company practice, this Corporate Ethics Policy shall be distributed to all directors, officers, contractors and employees.

II. Ethical Business Relationships

To ensure that the Rymax maintains a reputation for ethical conduct in its business relationships, it is the individual responsibility of each employee to avoid any activity or interest that might tend to discredit him or herself, or the Rymax. Specific prohibitions are as follows:

Each employee will be free of any investment, company or connection, which interferes, or may appear to interfere, with the independent exercise of his or her judgment on behalf of the Rymax. The fulfillment of this obligation shall include, but not be limited to, the following:

1. No employee may own directly or indirectly, or act as agent or trustee for any financial interest in any supplier of goods or services to the company, unless such financial interest is in stocks, bonds or other publicly traded securities of a corporation, and the interest comprises less than five percent (5%) of the assets of the corporation.
2. No employee may hold a position of director, officer, employee, trustee, statutory employee, independent contractor or agent with any such supplier.
3. No employee may accept personal favors, gifts, entertainment or gratuities from any supplier or potential supplier with either a retail price or fair-market value in excess of $50 unless, prior to accepting or receiving such personal favor or gratuity, the employee submits a written statement of justification that is approved by Executive Vice President. A copy of the approved justification will be filed with the Human Resources Division.
4. No employee may use, for personal gain, any information that he or she acquires in the course of his or her employment.
5. Any employee involved in any situation that may represent a possible conflict of interest, shall report same immediately to the Executive Vice President.

Employees who in good faith believe that a fellow employee, supervisor, manager, or director is in violation of this policy are encouraged to report their concerns as discussed in Section III below.

III. Whistleblower and Reporting Policy

Rymax is committed to complying with applicable laws and conducting business with honesty and integrity. Every director, officer, trustee, employee, contractor, and volunteer is expected to do the same. Rymax leadership encourages anyone who suspects or is aware of unethical or illegal activities or any conduct that is inconsistent with our Statement of Corporate Ethics, policies, or internal controls involving Rymax and its affiliates to report the matter through appropriate reporting channels.

RYMAX INTEGRITY REPORTING

The Rymax Whistleblower and Integrity Hotline Reporting Site is available on web form below to receive reports confidentially or anonymously. Further, if you have questions regarding Rymax compliance or ethical matters, you can submit your question and the matter will be forwarded to the Office of the General Counsel. This reporting channel enables you to communicate with the General Counsel confidentially or anonymously.

RYMAX ANTI-RETALIATION COMMITMENT

Rymax strives to promote a culture where employees and individuals are encouraged to come forward and make reports without fear of retaliation. As retaliatory actions against reporters may compromise the integrity of the reporting process and may dissuade others from reporting in the future, Rymax does not tolerate retaliation against a reporter that has made a good faith report.

Good faith reporting means when the reporter reasonably believes the information alleged is true and may violate the Ethics Policy, applicable laws, or policy requirements. A good faith belief that the information may be true, and that the information provided is not knowingly false or malicious is sufficient to meet the good faith standard. A reporter is not expected to have all the information or substantiate the allegations prior to reporting.

IV. Use of and Accounting for Rymax Funds and Assets

1. The use of company funds or assets for any unlawful or improper purpose is strictly prohibited.
2. No undisclosed or unrecorded fund or asset of Rymax shall be established for any purpose.
3. The appropriate employees of Rymax will make and keep books, records, and accounts, in reasonable detail, sufficient to reflect accurately and fairly all financial transactions and the disposition of funds and assets.
4. The appropriate employees of Rymax will devise and maintain a system of internal controls sufficient to provide reasonable assurance that:
   a. Transactions are executed in accordance with management’s general or specific authorization;
   b. Transactions are recorded: 1) to permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements, and 2) to maintain accountability for funds and assets;
   c. Access to assets is permitted only in accordance with management’s general or specific authorization; and
   d. The recorded accountability for funds and assets is compared with the existing funds and assets at reasonable intervals and appropriate action is taken with respect to any differences.

If you have questions regarding Rymax compliance or ethical matters, you can submit your question and the matter will be forwarded to the Office of the General Counsel.  This reporting channel enables you to communicate with the General Counsel confidentially or anonymously. Your personal contact information is optional.