Ethics Policy - The Cornerstone of Customer Satisfaction

Our Creed - We believe in the free enterprise system. We shall consistently treat our customers, employees, shareholders, suppliers, and the community with honesty, dignity, fairness, and respect. We will conduct our business to the highest ethical standards.

We require these same standards of our sub-contractors, partners, and associated companies.

1. Reporting of Risks

RANDEX is committed to providing quality products and services that meet or exceed the expectations of our customers. Deficiencies that threaten the physical well being of any person or put the financial security of our company at risk should be reported immediately to senior management or the Managing Director. Deficiencies may involve product quality, safety, design, installation, or maintenance.

2. Promoting Health and Safety

The health and safety of RANDEX employees – wherever they operate – is of utmost importance. Our work processes and policies are designed to minimize risk. We all must routinely review and improve workplace conditions to ensure a safe and healthful workplace and must report unsafe working conditions to supervisors and management. Additionally, health and safety requires abstinence from alcohol and drug abuse.

3. Equal Opportunity, Development, Diversity, and Maternity Discrimination

We value and respect the diversity of our employees, office holders (officers), directors, suppliers, customers, and communities. We work to eliminate discrimination and harassment in all of its forms, including that related to colour, race, gender, sexual preference, age, pregnancy, caste, disability, union membership, ethnicity or religious beliefs. Our company is committed to providing equal opportunity in all of our employment and purchasing practices. This applies to hiring, salary, benefits, advancement, discipline, termination, and retirement. Only in valuing diversity and committing to equal opportunity practices will we be able to fully utilize the human and business resources available to us in our pursuit of customer satisfaction. At the same time, we believe that by valuing diversity we enable all to fully realize their potential.

For RANDEX to succeed as a company, our employees must also succeed, as contributors to our company’s mission and objectives and as individuals and citizens. Therefore, in addition to protecting their health and safety, we are committed to the development of their unique skills and capabilities and the establishment of supportive communities.

We believe that new experiences on the job and involvement in work teams or special projects are valuable development opportunities. As part of our commitment to employee development, we offer training in technical and interpersonal skills and educational programs, and we will work with government and community organizations on programs for any workers from disadvantaged backgrounds. The tools, training and support, together with the compensation and benefits provided by RANDEX Limited, raise the social and economic opportunities for many employees.

We are committed to providing a workplace that is free of harassment or any other behaviour that diminishes a person’s integrity and self esteem. Neither physical nor mental harassment nor abuse will be tolerated.
Employing children less than the age of completion of compulsory schooling and in any case less than 16 years, or using forced labour, is strictly prohibited. Any youth (from ages 16 to 18 years) employed will enjoy all of the benefits of our nurturing environment such as training and development programs.

Any workers’ representatives would not be subject to discrimination and would have access to workplaces necessary to carry out their respective functions.

RANDEX respects the special needs of individual employees, including those who are pregnant or are returning to work after childbirth. Paid breaks will be provided for nursing mothers.

4. Freedom of Association, Work Hours, and Fair Compensation

We respect voluntary freedom of association, including the right to organize and bargain collectively in a manner that is legally compliant. Any workers’ representatives would not be subject to discrimination and have access to workplaces necessary to carry out their respective functions. Except in extraordinary circumstances, our employees work no more than the limits established by law. Employees receive at least the minimum wage required by law or the prevailing industry wage, whichever is higher. Employees are provided benefits and overtime compensation compliant with applicable laws. When no such laws exist, then our employees are paid at a rate at least equal to their regular hourly compensation rate. Employees receive full details regarding deductions for taxes, benefits, etc. Wages are not deducted for disciplinary purposes and are paid in cash, check form or by direct deposit. Overall, the compensation and benefits provided by RANDEX are designed to enable our employees to meet their basic needs, and provide the opportunity to improve their skills and capabilities for raising their social and economic opportunities.

5. Protecting the Environment

We respect the needs and concerns of the communities in which we live and work. Our products, services, and engineering activities reflect this concern and our belief that what is good for the environment is good for RANDEX Limited. Sound waste management and source reduction practices, recycling and energy conservation are legal, ethical, and business requirements. In meeting that commitment, we implement where appropriate, environmental management systems to ensure continuous improvement with specific measures to prevent pollution, minimize toxic and greenhouse gas emissions, seek ways to use and supply products that are environmentally friendly, and ensure that operations address both concerns and biodiversity preservation.

6. Protecting Employee Privacy

RANDEX is committed to providing privacy protection of employee data maintained by the company. Employee data will be used for the sole purpose of supporting company operations and providing employee benefits. RANDEX will comply with all local data protection regulations, please refer to our updated privacy policy.

The company has put safeguards in place to ensure that personal data is protected from unauthorized access and disclosure, including limiting access to such data only to those employees with a legitimate business purpose. All employees are responsible for ensuring compliance with this employee privacy policy.

7. Protecting the Company's Information

Protecting information about RANDEX products, activities, performance, or plans is critical to our company's competitive position and reputation. Good judgment is needed to determine what information can or cannot be disclosed to others. Should there be any question as to whether certain information is confidential, employees should consult their supervisor. To limit the potential for important information being used improperly, employees should use "need to know" guidelines even with other RANDEX employees.

The use of confidential company information for the personal gain of an employee, officer, director, or anyone else is contrary to RANDEX policies and, in many cases, unlawful. Confidential information includes all non-public information that might be of use to competitors, or harmful to the company or its customers, if disclosed.

Buying or selling RANDEX or partner company’s stock on the basis of material non-public information is also prohibited. It is unlawful to communicate this information to other persons who may trade in our stock. Material information is defined as anything a prudent investor should know before investing in a company. This type of information includes, but is not limited to, financial results, new products, and acquisition plans that have not already been disclosed to the public.

8. Avoiding Conflicts of Interest

The best interests of RANDEX are expected to be foremost in the minds of our employees, officers, and directors as they perform their duties. When we become employees of the company, and receive pay and benefits, we make this commitment.

It is wrong to seek any other economic gain by virtue of being a RANDEX employee, officer, or director. Giving or receiving anything of enough value to influence sound business judgment is prohibited. This also applies to family, friends and business associates. In addition, discussions of future employment with government officials with whom RANDEX seeks to do business must be approved in advance.

RANDEX trusts its employees with information about company activities and with company funds and property. Use of any of these in a way that conflicts with company interests is strictly prohibited. Situations that may conflict with company interests must be approved in advance by the Managing Director.

We must also take care that our actions cannot be perceived as serving other interests. While mutually beneficial relationships with customers and suppliers are encouraged, we should avoid situations that offer the potential for problems. Examples include having a significant stake in, or serving as a director of, a firm that sells to or purchases from RANDEX Limited. Employees should also not work for a customer or a supplier. All these examples apply to involvement with our competitors as well.

9. Gifts Policy

We are committed to the highest standards of ethical business conduct where entertainment, gifts, and other business courtesies are concerned. Our employees are not permitted to accept cash of any amount. Further, RANDEX employees who are involved in the purchase of goods and services are prohibited from accepting any gifts, with the exception of promotional items of nominal value.

Business courtesies, such as an occasional lunch, dinner, or refreshments during a business meeting, are permissible, provided they are not lavish, extravagant, or frequent, are intended to foster goodwill and successful business relations, and could not be reasonably construed as an attempt to secure favourable treatment.

10. Proper Use of Company Funds

Employees are personally accountable for any form of company funds such as credit cards, tickets, cash, and checks. Those who authorize the use of funds must ensure that the company has received proper value in return. RANDEX may be obligated to notify appropriate civil authorities should funds be used for any improper or illegal purpose and will take appropriate disciplinary action in any event.

11. Proper Use of Company Information and Company Property

RANDEX trusts its employees with information about company activities and with company property. Use of these in a way that conflicts with company interests, or in any manner that may reasonably be considered offensive or disruptive to another employee, is strictly prohibited.

12. Appropriate Use of Email, Internet, and Other Computing Resources

Electronic commerce, electronic mail, and other Internet-related systems are intended to be used for company business. Additionally, all information on company computer systems, including electronic mail, is the property of RANDEX Limited. Therefore, to ensure that computing resources are used in accordance with expectations, management may inspect and disclose the contents of electronic messages if such inspection and disclosure is made for legitimate business purposes or as necessary to protect the rights and property of RANDEX Limited.

Use of computing resources to offend or harass others is prohibited. Employees who use the Internet to access sites that contain offensive materials related to sex, race, or other protected categories, or who otherwise violate these prohibitions, will be subject to discharge.

13. Integrity of Recordkeeping/Accounting

RANDEX documents a wide range of its activities. The integrity of these records is relied upon to make important business decisions and take actions. Therefore, it is essential that all records are accurate and complete. This responsibility prohibits false or misleading entries regarding either the amount or purpose of transactions. Some examples include vouchers, bills, financial data, expense reports, and performance records. Strict care must be taken to comply with the law on protection and disclosure of any classified information

Employees, officers, and directors should report any concerns regarding questionable accounting or auditing matters to the Managing Director anonymously.

14. Political/Governmental and Non-Governmental Contributions

Within the United Kingdom, no contribution of funds or services are to be made to, or on behalf of, any political organization or candidate by RANDEX or any associated companies without advance approval of the Managing Director. Within the United Kingdom, offering any favour, service, entertainment, meal, gift, or other thing of value, directly or indirectly, to government officials or employees in connection with their government duties is prohibited and includes things of value offered to their family members. Throughout the world, direct or indirect contributions to any government officials (including their representatives or family members) that are intended to gain preferential treatment for our company are always prohibited.

RANDEX recognizes that in some countries outside the United Kingdom it is legal and customary for companies to make certain contributions to political parties and government officials. Nevertheless, no such contributions or payments can be made by RANDEX or its subsidiaries, employees, officers, directors or agents with the intent to obtain or retain business. In addition, contributions or payments must be approved by the Managing Director and must be completely and accurately documented in our company's books and records.

15. Rule of Law

Any employee, officer or director involved in court or other similar proceedings arising out of his or her employment with, or service to, RANDEX shall abide by the rules of that forum, cooperate with the orders of that forum, and not in any way commit perjury or obstruction of justice. All RANDEX employees must, at a minimum, comply with all applicable laws that relate to the conduct of our business in the relevant jurisdiction.

17. Antitrust

Planning or acting together with any competitor to fix prices or to agree about the nature, extent or means of competition in any market is against company policy and in violation of antitrust laws. Antitrust laws may also in some circumstances prohibit agreements to boycott, to allocate products, territories, or markets, and to limit the production or sale of products. Using illegal or unethical means to obtain competitive information or gain a competitive advantage over a competitor is prohibited.

18. International Business

There are several laws that restrict where we can do business, what information or products we can supply to certain countries and what information we can provide to a foreign government (e.g., boycott-related requests or national security concerns). For these reasons, business entry into any new foreign country must be in compliance with these restrictions.

19. Senior Financial Officers

RANDEX principal officers or controllers (executive, financial, accounting), or any person performing similar functions, must engage in honest and ethical conduct, including the ethical handling of apparent conflicts of interest between personal and professional relationships. These officers must avoid conflicts of interest. In addition, these officers must make immediate disclosure to the Managing Director of any material transaction or relationship that reasonably could be expected to give rise to such a conflict.

RANDEX requires full, fair, accurate, timely, and understandable disclosure in reports, documents, and any other public communications made by the company. In addition, all RANDEX employees must maintain compliance with applicable governmental laws, rules, and regulations. All violations of the Ethics Policy by a principal executive officer, principal financial officer, principal accounting officer, or controller, or any person performing similar functions should be reported to the Managing Director, anonymously if preferred. Adherence to these standards is a condition of employment with RANDEX Limited. Violations are serious matters and will result in disciplinary action.

20. Responsibilities

Each employee, manager and director of RANDEX is expected to carry out his or her work in accordance with the business standards of conduct of RANDEX Limited. Managers are expected to implement policies, programs, and procedures and ensure adequate communications as well as ensure internal controls are in place for their business unit or site to ensure compliance with the spirit and intent of applicable laws and policies. An effective mechanism to realise much of this communication is through adequate training and briefings. The next high level of management must be notified of any inconsistencies and, as part of quality management system continuous improvement, establish goals, targets and plans against which progress can be measured. Further, all employees are urged to direct any questions or concerns about the company's activities or these standards to their supervisors or the Managing Director without delay. This includes customer and supplier activities that may directly affect our operations or employees. Any employee who suspects that a violation of the Ethics Policy has occurred is obligated to report it, and such employees shall be protected from retaliation.

Employees should also be aware that these standards are greater than those that may be required by local law. Adherence to these standards is a condition of employment with RANDEX Limited. Violations are serious matters and will result in disciplinary action. Managers and supervisors are responsible for distributing copies of the Ethics Policy to employees, officer and directors, as well as making them aware of the importance and specific requirements of the policy.

The Ethics Policy is not all encompassing: any concerns, clarifications, or questions about situations not discussed in the Ethics Policy should be addressed to the Managing Director.

Employees may anonymously report a possible violation of policies by contacting the Managing Director.

The company’s Ethics Policy is applicable to the members of the board of directors and to all company employees.

Effective 1st December, 2007