RAD is committed to the highest level of integrity in the conduct of business. The company believes that compliance with the highest standards of ethical conduct is critical to maintaining trust and credibility with customers, partners, suppliers, and employees, and is key to the company’s long-term survival and success.

 

This document outlines the principles of ethical conduct, and details the company policy in various related areas.

 

Every RAD employee is expected to conduct himself and his business in line with this Code without exception. Managers in particular should lead by setting an example for other employees. Beyond legal compliance, all RAD employees are expected to observe high standards of business and personal ethics in the performance of their assigned duties and responsibilities. This requires the practice of honesty and integrity in every aspect of dealing with other company employees, customers, suppliers, the public, the business community, shareholders, and governmental and regulatory authorities.

Compliance with the Law

RAD policy is to observe and comply with all national and international laws applicable to the Company, or applicable to the conduct of business in all countries where it provides products or services. The Company’s goal is not only to comply with the minimum legal requirements, but also to be a leader and set an example in corporate ethical behavior, driven by the Company’s responsibility and good citizenship.

 

Treating Employees with Respect

All employees enjoy basic human rights and should be treated with dignity and respect in the workplace. They should not be unreasonably interfered with in the conduct of their duties and responsibilities for prejudicial reasons. All employees are entitled to freedom of thought, conscience, religion, and expression as long as these do not interfere with the rights of others.

 

RAD is committed to equality of opportunity in all its employment practices, policies and procedures. No employee should be discriminated against because of age, race, gender, religion, disability, sexual orientation, marital or maternity status, political opinion or ethnic background.

 

RAD respects the privacy of its employees, customers and suppliers and is extremely careful when processing personal information. All personal data collected and held by RAD is handled in confidence, sensitivity and care to ensure that the privacy of individuals is protected.

 

RAD employees should never engage in abusive, intimidating behavior toward others in the workplace, such as sexual harassment, physical confrontation or verbal hostilities that could create a hostile or offensive work environment.

The success of RAD depends on our ability to outperform our competitors; however, the Company is committed to achieving success using fair, honest and ethical means.

 

In order to continue to maintain RAD’s reputation for fair dealing among our customers, partners, competitors, and the public, all employees should adhere to the following principles:

• Fairness to customers – All customers and partners should be treated equally and fairly. Market conflict between channel partners or customers should be resolved on the basis of equality, fairness and long-term interest of the Company.

• Honesty and truthfulness – Information or material facts on the company, its technology, products, quality, timetables, and other business-related issues should never be misrepresented with intent to deceive.

• Unfair competition – Employees should never make defamatory or false statements regarding the business solvency, lack of competency, lack of quality, or lack of integrity of other companies. Employees should never misappropriate trade secrets or knowingly misuse a competitor's confidential information.

RAD and its employees should not demand or accept, offer or give any kind of bribery, kickback, payoffs, or any other illegal or unethical benefits, and should never be involved in any corrupt business practices.

 

The use of company funds for political contributions to any organization or to any candidate for public office is strictly prohibited.

Employees should make or participate in business decisions and actions based on the best interests of the Company as a whole, and not based on personal relationships or benefits, and they should avoid any activity that might lead to a conflict of interest.

 

Some examples of conflicts of interest:

• Business Opportunities - Making profit, or assisting others to profit, from opportunities that are discovered through the use of corporate information or position.

• Business Relationship with Other Companies – Involvement in a business relationship with RAD customers, partners, suppliers, or competitors. Any outside business interests that divert time and attention away from RAD responsibilities.

• Personal Relationship with Other Parties - Making business decisions involving RAD and another party, while having personal relationships (family, friends) with the other party.

 

In the event that a conflict arises between the interest of an employee and the Company, the employee must immediately notify his or her superior in full and in writing, and disengage himself/herself from any involvement in the matter.

As part of RAD’s Marketing and promotion efforts, employees are permitted to offer to customers, potential customers or business partners only modest tips, gratuities, hospitality (such as dining in a restaurant), gifts, or invitations to entertainment events, and only if such offering is legal under applicable local or national laws. “Modest” value is defined as less than $100 per year per business associate (not including business meals).

 

Gifts, invitations or hospitality offered to RAD employees in connection with their business activity might be accepted only if such gifts and invitations have no influence on the employees decision-making. Any such gifts or invitations should be less than $50 per year per business associate (not including business meals).

RAD has a wide variety of assets, including physical assets, proprietary information and intellectual property. RAD assets should be used only for lawful and proper Company purposes.

• Physical assets - Equipment, materials and other physical assets should be handled and cared for properly, and should be used only for RAD’s business purpose. They should not be used for personal benefit, sold, loaned, given away or otherwise disposed of, regardless of their condition or value, without proper authorization.

• Confidential or Proprietary Information – RAD recognizes the importance of Intellectual Property rights and other proprietary or confidential information to any company. RAD and its employees shall take every appropriate action to preserve and enhance its Intellectual Property, while respecting the Intellectual Property rights of others.

RAD employees should never access or use confidential or proprietary information for any purpose other than as required for the performance of their duties, and should never disclose such information, either during or after employment, without Company authorization to do so. This policy covers also confidential or proprietary information of any company with which RAD has signed a contract or an NDA.

• RAD’s Communication Systems – RAD’s communication systems, including personal computers, laptops and connections to the Internet, shall be used for conducting RAD’s business. Employees should not use RAD’s communication systems for sending, retrieving, accessing, displaying, storing, printing or otherwise disseminating material and information that is fraudulent, harassing, threatening, illegal, racial, sexually oriented, obscene, intimidating, defamatory, or otherwise inconsistent with a professional and ethical conduct.

Coverage

The commitment to comply with this Code extends to all RAD employees on all matters, including decisions relating to trade, investment, subcontracting, supplying, business development, and in all other business and employment relationships.

 

RAD is aware that questions of interpretation may arise in specific instances, particularly regarding the need to balance local customs and requirements of some countries with global standards and guidelines. RAD will do its utmost to resolve any identified ethical, legal, environmental, employment, and human rights issues, which seem to be in conflict with this Code.

All current employees shall be provided with a copy of this Code at the earliest possible date. All new employees shall be given a copy of this Code when joining the Company. The Code and any amendments thereof shall be posted on RAD’s web site.

It is the responsibility of each RAD employee to promote and follow this Code. Questions about the application or meaning of any provisions of this Code should be addressed to the employee’s direct superior, to the VP of Human Resources or to the General Counsel.

 

All managers of the Company are responsible for the enforcement of, and compliance with, this Code, including necessary distribution and training to ensure employees knowledge, understanding and compliance. Non-compliance with this Code might result in disciplinary measures up to and including termination of the relationship with the Company or legal action against the violating employee.

Any report by an employee who knows or believes that another employee of the Company has violated this Code should be made to the employee’s supervisor or to the Human Resources Department or to one of the Company’s VPs.

 

Any report of possible violation shall be investigated thoroughly and treated with the utmost care in confidentiality.

 

RAD shall not discharge, demote, suspend, threaten, harass or in any other manner discipline, discriminate or retaliate against any employee because he or she reported any violations. However, the Company may take disciplinary action against an employee who provides an incorrect report on violations of the Code if the report was not made in good faith.

Any questions, suggestions for changes or additions to this Code should be addressed to the General Counsel.

The Company may amend this Code from time to time with or without notice.