Revion Solutions – Anti-Corruption, Gifts & Entertainment, and Business Ethics Policy

Effective date: September 1st, 2025
Applies to: All Revion employees, officers, contractors, and anyone acting on Revion’s behalf, worldwide.

1. Zero tolerance for bribery & improper payments
   Revion prohibits bribery and corrupt payments of any kind, whether offered directly or through third parties. This includes cash, gifts, favors, travel, entertainment, charitable or political contributions, internships, or anything of value intended to influence a business decision. We comply with applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act.

2. Government Officials
   Extra care applies to interactions with Government Officials (including employees of state-owned/controlled entities, candidates for office, political parties, and public international organizations).
   • Do not offer anything of value to a Government Official to gain an improper business advantage.
   • Any proposed gift, meal, hospitality, travel, fee, or sponsorship involving a Government Official must receive prior written approval from Revion’s Compliance Lead.

3. Gifts, meals, and entertainment (G&E)
   G&E must be modest, infrequent, and lawful; never cash or cash equivalents; and never intended to influence.
   • Thresholds: Nominal value only (e.g., under $100 per recipient per year) unless pre-approved by the Compliance Lead.
   • No “quid pro quo.”
   • Record all approved expenses accurately with business purpose, attendees, date, and amount.

4. Third parties, commissions, and partners
   We only engage agents, resellers, consultants, or lobbyists for legitimate services and reasonable compensation.
   • No success-based commissions that could incentivize improper payments without compliance review.
   • Perform risk-based due diligence; include anti-corruption clauses, audit rights, and termination for breach in contracts.
   • Never use a third party to do what Revion is prohibited from doing.

5. Charitable & political contributions
   • Corporate charitable donations or sponsorships must be transparent, made to bona fide organizations, and never to influence an official act.
   • Revion does not make political contributions on behalf of the company without written approval from the CEO and Compliance Lead.

6. Books, records, and internal controls
   All transactions must be accurately recorded with sufficient detail to reflect their true nature. Falsifying records, using slush funds, or mischaracterizing payments is strictly prohibited.

7. Conflicts of interest
   Disclose any personal, family, or financial interest that could appear to influence your Revion decisions. Avoid situations that create—or appear to create—improper influence.

8. Reporting & non-retaliation
   If you see or suspect a violation, report it immediately to: compliance@revion.com (or your manager). Revion prohibits retaliation against anyone who raises concerns in good faith.

9. Training & enforcement
   Revion provides periodic anti-corruption training for relevant personnel. Violations may result in discipline, up to and including termination, and may be reported to authorities where required by law.

10. Questions
    Contact legal@revion.com with any questions or to request pre-approval for Government-Official interactions, higher-value G&E, or third-party commission structures.

—
This policy is part of Revion’s commitment to ethical business conduct and compliance with applicable laws and regulations. It should be read together with our other company policies and procedures.

Last updated: September 10th, 2025