Message from Revo’s Managing Director, Cenk Bayrakdar:

At Revo Capital we have embraced the motto “Empowering local entrepreneurs to unlock global potential”. We have to live up to this mission on an ongoing basis through showing our commitments and by making available our professional skills and competences to all our clients, both investors and portfolio companies, as well as other stakeholders. Whereas we have to do so every day, we have the vision that our mission requires establishing sustainable long-lasting relationships. That is what we aim for. This can only successfully be reached on the basis of trust, which we have to earn every day by means of acting fair and honest, always in the best interests of our clients. To do so, requires having a strong team that shares identical ethical standards and feels comfort and pride to work on realizing Revo’s mission. At Revo we have such team, with all staff members intrinsically carrying the ethical principles as set in this Code.

I am pleased to refer to this Code of Ethics as a point of reference for what we stand for and what we consider acting fair and honest. I invite you all to read the Code and become familiar with our principles. I stand for these principles and feel accountable for the due adherence to the Code. I am therefore open to any feedback that may help us in the realization of our mission.

Our Principles

Revo stands for good citizenship

We aim to be compliant with all legislation and regulations as applicable to Revo. Obviously! We abide by all applicable rules & regulations and in case of interpretive questions we observe the objectives and spirit of legislation.

Good citizenship is also about decent behaviour, respecting commonly accepted standards in society, without losing sight on cultural differences and the importance of critical mindsets. What counts in the end are sincere intentions and respect for each other.

We respect fundamental rights and freedoms

As Revo, we respect the fundamental rights and freedoms of our employees, investors, portfolio companies and all business partners within the framework of international law.

When recruiting and retaining employees, we treat all candidates equal and we rule out discrimination based on religion, race, gender and ethnic origin. We expect our staff to work hard and at the same time we take care to provide a safe and sound working environment.

As for our clients and other business relations, we include this principle into the equation upon assessing their eligibility for entering into a relationship.

We respect privacy and protect personal data and confidentiality commitments

We respect the privacy of all individuals and companies that we work with. Therefore, we have a Confidentiality & Data Protection Policy, in which we commit to take adequate measures to secure the confidentiality of all information received from our clients and other business relations, as well as personal data of our employees, as if it was our own confidential information. More in particular we stand for protecting personal data in compliance with applicable national and international legislation.

We stand for respectful human interaction under all circumstances

We treat each other respectfully in all due respect, same as we want to be treated ourselves. This implies that we do not tolerate or excuse any employee demonstrating disrespectful or indecent behaviour towards others, such as (sexual) harassment, bullying, mobbing and exclusion of other people. Vice versa, we do not accept our employees being treated disrespectfully by others.

We are diligent on conflicts of interest

Revo provides several services to its clients, whereby conflicts of interest may (potentially) arise and cannot always be avoided. Revo strives to avoid conflict-of-interest situations, but is otherwise committed to diligently manage conflicts of interest, in order to protect the interests of clients, as well as other stakeholders as the case may be. Diligent managing of conflicts of interest implies that (potential) conflicts are handled transparently and that decisions are based on the principle of fairness, meaning that no one should get entitlement to benefits or be confronted with disadvantages, that would otherwise not be the result of ordinary market conditions as would apply between independent parties or persons.

We have therefore adopted a Conflicts of Interest Policy, in which we commit to the following principles for handling conflict of interest situations: Transparency, Fairness, Sound Governance, Confidentiality, Proper Documentation and Ongoing Monitoring. We have finally defined an Unacceptability Line as follows: Revo shall not accept or tolerate a situation of conflicting interests whereby a fair solution cannot be reached and a client or group of clients or other stakeholders would suffer disadvantages as a consequence, unless explicitly permitted by those clients or other stakeholders.

We are pro fair trade and thus against corruption & bribery

We are aware of the huge damage for society caused by corruptive practices. As Revo, we commit to abstain from such practices and we expect the same from our clients and other business relations. That we abstain from illegal corruptive practices goes without saying. Moreover, we are also sensitive to any other practices that could compromise our independent judgements and those of our clients, which could lead to disadvantageous outcomes for Revo and / or its stakeholders.

We have not formulated a ‘gift & entertainment’ policy, setting rule-based limits, while we trust our staff to be conscious and transparent when being exposed to benefit offers. Vice versa we will never offer abundant gifts to our (potential) clients and other business relations with the expectation to receive benefits in return.

We care for environmental and social consequences of our activities

While Revo does not specifically strive for reaching certain defined sustainability objectives and its investment focus does not carry inherently high environmental or social (E&S) risks, we remain vigilant to avoid investments that could carry material adverse E&S risks. And as risk profiles can change over time, we continue to monitor the E&S risk profile of our investments. In case that we become aware of (potential) negative E&S impacts by our portfolio companies, we will stimulate and give support to our portfolio companies to develop and implement action plans aimed at mitigating such adverse E&S impacts.

We want to learn continuously

We strive to continuously improve ourselves by staying on top of relevant developments, sharing knowledge and experiences with our business partners, our colleagues and by following relevant trainings. We have an open mind for the views and opinions of others, also when they challenge our own stances

This also goes for living up to our ethical principles. Ethics is not always black or white, we are and will be confronted withdilemmas, just like everyone. We will deal with such dilemmas diligently, always with good intentions.

As mentioned, we want to learn continuously. Therefore, we are open to criticism, internally from our staff, as well as from our clients, other business relations and stakeholders and in fact anyone being genuinely interested in Revo. To us a complaint is an advice, a recommendation. We invite everyone to share any criticism, concerns or questions they may have in relation to Revo’s conduct and appreciate suggestions for improvement. For this purpose, we have opened a portal, which can be reached bysending an email to [email protected]. We do by the way also appreciate positive feedback!