Scope:

This policy establishes a Code of Conduct and Ethics Policy for all Rockymountain Employees, Suppliers, and Business Partners. This document will hereby be referenced as Rockymountain Circuits Ethics Policy.

Intent:

Rockymountain Circuits Express, Inc. is committed to conducting its business in an ethical, legal and socially responsible manner. Rockymountain Circuits expects its Employees, Agents, Suppliers and Business Partners to share this commitment, and therefore have established the Code of Conduct.

Suppliers:

Although there may be different legal and cultural environments applicable to its Suppliers, Rockymountain encourages their suppliers to make every effort to meet the Code of Ethics policy as set forth in this document and adhere to all applicable National and International Trade Laws and State and US Federal Labor laws.

Employees:

The Ethics Policy applies to everyone at Rockymountain – including the Board of Directors, company officers, employees, members of management, agents, Suppliers and Business Partners.

Each employee must agree and adhere to the following guidelines and principles;

• Any violation of the Ethics Policy must be reported to Rockymountain Circuits Express, Inc.
• Rockymountain Circuits will not tolerate threats or retaliation against anyone who makes a good-faith report of a possible Ethics Policy violation.

Ensuring Compliance and Accountability

• Employees are expected to follow the Ethics Policy and assist their fellow employees in understanding and complying with the Ethics Policy.
• Supervisors will help make their employees aware of the Ethics Policy’s importance and requirements, and help implement programs and procedures to promote “personal integrity every day.”
• Supervisors and management are responsible for helping their associates comply with the Ethics Policy’s requirements.

It is imperative that our employees work in healthy and safe environments.

Each individual employee must help ensure this by;

• Understand and follow the safety policies and procedures.
• Regularly look for ways to improve workplace safety.
• Do your best to avoid accidents and to help others avoid them.
• Report all accidents, near misses and safety issues.
• Help create a physically and emotionally safe work place.
• Do not commit or permit violence in the workplace.
• We do not tolerate violent behavior, threats to people or property, or physical intimidation or coercion.

• Never be under the influence of drugs or alcohol at work. You must remain free from the influence of illegal drugs, alcohol or any substances that may impair your ability to work safely and effectively.
• You must cooperate with any legal company searches of you or your workplace for alcohol or illicit drugs.
• Report team members who work under the influence of alcohol or other substances that may impair their ability to work safely and effectively and put you or others in danger.
• Rockymountain Circuits expects their employees to display personal integrity and reliability and avoid doing anything that may harm Rockymountain Circuits Express, Inc. or their reputation.

Rockymountain Circuits provides equal opportunity in hiring, salary, benefits, advancement, discipline, and termination.

You can help by;

• Respecting equal opportunity throughout the workplace.
• We do not tolerate discrimination on the basis of race, color, gender, sexual orientation, age, pregnancy, caste, disability, union membership, ethnicity, religious beliefs, political persuasion, appearance or physical constitution, or any other factors protected by law.
• Oppose harassment.
• Do not tolerate physical, sexual or mental harassment or any other harmful behavior.
• Harassment includes language or conduct that others may find derogatory, intimidating or offensive.
• Immediately report all incidents of harassment to your Supervisor, Manager or Human Resource Representative.

Rockymountain Circuits expects employees witnessing violations of these rules and policies set forth in this document to report them to Human Resource Management, Operations Management, and EH&S Management as applicable.

Rockymountain Circuits shall use all means at our legal disposal to stop any kind of coercion or force or threat of force.

Rockymountain Circuits obeys all applicable Federal and State laws on working hours and compensation.

When circumstances require you to work beyond normal hours, we provide benefits or overtime compensation as required by law.

• You will receive at least the legally required minimum wage or the prevailing industry wage, whichever is higher.
• Rockymountain Circuits will give you full details on pay roll deductions for taxes and benefits.
• Rockymountain Circuits compensation and benefits are designed to enable our employees to meet their basic needs and provide them the opportunity to improve their skills and capabilities.

Human Rights:

Rockymountain Circuits complies with internationally promulgated human rights. Rockymountain Circuits forbids any kind of child labor or forced labor and expect our business associates and partners to also abide by these same principles.

Conflict of Interests:

Rockymountain Circuits employees must avoid situations which might result in personal conflict of interest internally or conflict of interest with our business partners.

Every employee must immediately notify Human Resource Management and Rockymountain Operations Management of any business relationship of a private nature with Governing Personnel directly associated with Rockymountain Circuits or Rockymountain Circuits business partners.

Confidentiality:

Our employees are bound by duty to maintain confidentiality regarding all internal confidential matters of Rockymountain Circuits and regarding all confidential information and data belonging to or concerning our business partners. Confidential information must be safeguarded from unauthorized viewing of third parties.

Conflict Minerals/Metals:

Rockymountain Circuits supports authorities, industrial associations and non-government organizations in their efforts to stop the trade of so-called Conflict Minerals/Metals (Section 1502 Dodd-Frank Wall Street Reform and Consumer Protection Act). This applies to the trade of Tin from the Democratic Republic of Congo and the adjacent countries that mined under inhumane conditions. Rockymountain Circuits requests their supply chain to follow the same guidelines and principles to ensure no so-called Conflict Minerals/Metals are procured, processed or supplied to us to be processed in production.

Competition:

Rockymountain Circuits is committed to legal and ethical means in pursuing corporate goals.  We participate in using fair and legal methods in competition.  Suppliers, as well as each individual, are obligated to comply with all antirust and competition laws. Practices which breach the competition law such as agreements with competitors prices and terms are not permitted.

Corruption:

It is our goal to influence people and customers with our quality, reputation, and value of our products. We oppose any form of bribery or unfair competition. It is against Rockymountain Circuits policy for employees to use his or her job, business connections to the Company for his or her own benefit or for the benefit of a third party or to the detriment of Rockymountain Circuits.

No employees shall offer or accept private benefits such as money, items of services, which will or are intended to or might influence decisions or unfair advantage.

Environment:

Rockymountain Circuits announces its responsibility for environmental protection and sustainability. We have in place rules and guidelines for environmental protection and require all employees to comply.

Corporate Assets:

Rockymountain Circuits assets, both tangible and intangible, including intellectual property and software products, and information, are to be protected by all employees. Corporate assets may only be used for permitted business purposes and under no circumstances for illegal purposes.

International Trade Laws:

Rockymountain Circuits follow all trade laws of all countries that Rockymountain Circuits may conduct business with. This includes laws concerning; exporting specific goods, services or technology, prohibiting transactions with specific countries, entities or people, participating in international boycotts, and Government approval, licenses or other requirements necessary to complete a transaction or sale, and product labeling.

The Management of Rockymountain Circuits Colorado, Inc. is bound by this Code of Ethics and will use all means to enforce these guidelines or to have them enforced.

Rockymountain Circuits Supplier Diversity Initiative:

Rockymountain Circuits believes that our corporation and our communities benefit from providing equal opportunities for diversity business enterprises to compete for Rockymountain Circuits business. Our suppliers are our business partners, and it is important that these partnerships reflect the communities where we live, work and serve.

Rockymountain encourages small, veteran, minority and women-owned businesses that provide quality products and services at competitive prices to contact Rockymountain Circuits purchasing department for a list of commodities that Rockymountain Circuits is currently seeking bids. Companies wishing to apply as minority and/or woman-owned must be 51% owned, controlled or operated by a person of female gender or one of the following ethnic groups:

• African American
• Asian-Indian American
• Asian-Pacific American
• Hispanic American
• Native American

Proof of certification is required and acceptable from the National Minority Supplier Development Council (NMSDC), Women Business Enterprise National Council (WBENC), or the Small Business Administration.