CODE OF ETHICS, CORPORATE AND SOCIAL RESPONSIBILITY POLICY STATEMENT

Arfon Rewinds Ltd (hereby referenced as Arfon Rewinds) will conduct its business honestly and ethically wherever we operate in the world. We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. No illegal or unethical conduct on the part of directors, employees or affiliates is in the company’s best interest. Arfon Rewinds will not compromise its principles for short-term advantage. We are committed to ensuring that our business is conducted in all respects according to the highest ethical and professional standards, taking into account legislation and customs in the countries and regions we operate in. The ethical performance of this company is the sum of the ethics of the men and women who work here. Thus, we are all expected to adhere to high standards of personal integrity. This Policy is supported by the Employee Handbook which must be referred to by Directors and Employees for further responsibilities and information.

In addition, Arfon Rewinds recognises their corporate and social responsibilities to shareholders, customers, suppliers, employees and other stakeholders. Arfon Rewinds is committed to conducting business in a manner which achieves sustainable growth whilst fulfilling legal compliance and moral obligations. We aim to achieve our business objectives in a caring, compliant and responsible manner recognising the economic, social, environmental and legal impacts of our activities. All our customers and suppliers will be treated fairly and with respect. All applicable legislation will be upheld and any confidential information will be dealt with accordingly.

We seek to minimise the environmental impact of our activities through the prevention of pollution, minimizing waste, and good environmental management practices by using environmental management systems which are externally audited. We are committed to conducting our activities and operations in line with current legislation and best environmental practice seeking continual improvement and innovation throughout the whole business and activities. For further information, see Arfon Rewinds Environmental Policy.

Health and Safety

We are committed to high standards of health and safety, recognising our duty and the benefits of providing safe working conditions. We aim to achieve continuous improvement in health & safety performance through the use of a robust externally audited health and safety management systems. For further information, see Arfon Rewinds Health & Safety Policy.

Suppliers

We regard suppliers as our partners and work with them to achieve our aspirations in the delivery of products and services. Arfon Rewinds are committed to working with its suppliers to understand where products are sourced and ensure that the principals of environmental sustainability are upheld. This is further communicated in our Sustainability Policy. Arfon Rewinds work to ensure that the welfare of workers and labour conditions within our supply chain meet or exceed standards that we are required to comply too. Arfon Rewinds recognise their responsibilities under the Finance Act and the Criminal Finances Act 2017 and as such have a procurement and accounting system in place which ensures that all services and products are invoiced accordingly and tracked through auditable processes. Communication with Arfon Rewinds Ltd and its suppliers will remain open and honest at all times. Any conflicts of interest must be communicated.

Customers

We recognise that our business and livelihood depends upon our customers. Every employee is responsible for ensuring that customer contact is professional and appropriate. We aim to ensure that our customers receive the level of service and quality of product they have come to expect from Arfon Rewinds. Any conflicts of interests between Arfon Rewinds Ltd and its customers will be formally communicated. Communication between Arfon Rewinds Ltd and its customers will remain open and honest at all times.

Community

We are committed to making a sustainable positive impact on the communities in which we operate. We aim to make a distinctive contribution to inequality and social development through the establishment of effective partnerships and programmes that make best use of the energies and skills of our employees. We support our employees should they wish to participate in fundraising for charities and voluntary work, acknowledging both the benefit to the community and to the employees themselves. We also sponsor young people within our community to develop their skills and experience both within the industry and in other aspects of their lives.

Communication

We communicate our activities externally through our website and internally through our Management meetings, notice boards and team briefings. As a company, we place great emphasis on delivering our works to the highest standards of Health, Safety, Environmental and Quality performance and communicate this commitment throughout our workshop by billboards. This raises a sense of awareness in the company as well as acting as a prompt for staff to get involved. Every employee receives an Employee handbook on induction and revision which supports this Policy.

Equal Opportnities

We provide equal opportunities to all existing and prospective employees recognising that our reputation is dependent on the quality, effectiveness, and skill base of our employees. We are committed to the fair and equitable treatment of all our employees and specifically to prohibit discrimination on the grounds of race, religion, sexual orientation, nationality, or ethnic origin. Opportunities are available to disabled persons in accordance with their abilities and aptitudes on equal terms with other employees. Directors and employees will obey all Equal Employment Opportunity laws and act with respect and responsibility towards others in all of their dealings.

Personal Interests and Responsibility

Directors, and employees of the company must never permit their personal interests to conflict, or appear to conflict, with the interests of the company, its clients or affiliates. Directors and employees must be particularly careful to avoid representing Arfon Rewinds in any transaction with others with whom there is any outside business affiliation or relationship. Directors, and employees shall avoid using their company contacts to advance their private business or personal interests at the expense of the company, its clients or affiliates.

Directors and employees are responsible for ensuring that they remain personally balanced so that their personal life will not interfere with their ability to deliver quality products or services to the company and its clients. Directors and employees are responsible for disclosing unethical, dishonest, fraudulent and illegal behaviour, or the violation of company policies and procedures, directly to management.

Fraud, Malpractice and Anti-Bribery

Arfon Rewinds understand the prevalence of fraud and malpractice in the commercial environment and the negative impact it could have on its employees and clients. The organisation requires all staff at all times to act honesty and with integrity and to safeguard the resources for which they are responsible. Fraud is an ever-present threat to these resources and hence must be a concern to all members of staff. The purpose of this statement is to set out responsibilities with regard to the prevention of fraud and tax evasion. Arfon Rewinds recognise their responsibilities under the Finance Act and the Criminal Finances Act 2017 and, as such, ensure that all operatives are employees under PAYE and therefore would be personally taxed accordingly by HMRC. All employees disclose their National Insurance numbers on employment which are used to ensure that National Insurance contributions are made as required. The company operate a pension scheme in accordance with the pensions scheme act and ensure that their corporate responsibilities are met. All accounting is processed through a programme known as Pegasus which ensures that all invoices sent and received are correct and the relevant tax contributions have been processed. This programme is audited by a chartered accountant and company secretary.

The Bribery Act 2010 describes those actions as: theft, deception, bribery, forgery, corruption, false accounting and conspiracy to commit these offences. For practical purposes fraud may be defined as the use of deception with the intention of obtaining an advantage, avoiding an obligation or causing loss to another party. Employers should report details immediately to the Directors if they suspect that a fraud has been committed or see any suspicious acts or events. No bribes, kickbacks or other similar remuneration or consideration shall be given to any person or organization in order to attract or influence business activity. Directors and employees shall avoid gifts, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business activity. Any instances of suspected fraud or malpractice reported to the directors may be made with full anonymity and in the strictest of confidence. They will be recorded, investigated and if necessary acted upon in line with the company’s Disciplinary Procedures and UK Law. The Employee Handbook supports this Policy.

Information, Processing Security and Use

Directors and employees of Arfon Rewinds will often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and must take appropriate steps to assure that such information is strictly safeguarded. This information – whether it is on behalf of our company or any of our clients or affiliates – could include strategic business plans, operating results, marketing strategies, customer lists, personnel records, new investments, and manufacturing costs, processes and methods. Proprietary, confidential and sensitive business information about this company, other companies, individuals and entities should be treated with sensitivity and discretion and only be disseminated on a need-to-know basis.

Misuse of material inside information in connection with trading in the company’s securities can expose an individual to civil liability and penalties under the [ACT]. Under this Act, directors and employees in possession of material information not available to the public are “insiders.” Spouses, friends, suppliers, brokers, and others outside the company who may have acquired the information directly or indirectly from a director or employee are also “insiders.” The Act prohibits insiders from trading in, or recommending the sale or purchase of, the company’s securities, while such inside information is regarded as “material”, or if it is important enough to influence you or any other person in the purchase or sale of securities of any company with which we do business, which could be affected by the inside information. The following guidelines should be followed in dealing with inside information:

• Until the material information has been publicly released by the company, an employee must not disclose it to anyone except those within the company whose positions require use of the information.

• Employees must not buy or sell the company’s securities when they have knowledge of material information concerning the company until it has been disclosed to the public and the public has had sufficient time to absorb the information.

• Employees shall not buy or sell securities of another corporation, the value of which is likely to be affected by an action by the company of which the employee is aware and which has not been publicly disclosed.

Directors and employees will seek to report all information accurately and honestly, and as otherwise required by applicable reporting requirements.

Directors and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The directors and employees of Arfon Rewinds will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.

Violation of this Policy can result in discipline, including possible termination and criminal proceedings. The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether or not the violator cooperated in any subsequent investigation.

Employees can disclose any breach of this Policy, as well as all other company policies in the strictest of confidence to their line manager or directly to the HSQE Director. All complaints will be dealt with in the strictest of confidence and will be formally investigated to ensure that all are treated fairly.

Remember that good ethics and commitment to responsibility is good business.