Ethics and compliance

Commitment to others

At RiverStone, we strive for an inclusive culture that promotes engagement through our people, community investment, charitable giving, and a desire to get involved. We will always strive to do what is right, not just the bare minimum, for the sake of legal compliance.

Code of ethics

RiverStone Holdings Limited and Advent Capital (Holdings) Limited and each of their respective subsidiaries (“RiverStone”) remain committed to maintaining high standards of ethics and business conduct. Anyone who is employed by, or who acts for or on behalf of, RiverStone must maintain the highest ethical standards.

No gift, entertainment or personal benefit or opportunity should ever be offered, accepted or permitted in a commercial context or by virtue of the employee’s, representative’s or agent’s position or office, unless it:

1. is consistent with customary business practices;
2. is not excessive in value;
3. cannot be construed as a bribe or payoff; and
4. does not violate any laws or regulations or internal, employee requirements.

It is RiverStone’s policy to comply with all domestic and applicable foreign anti-corruption laws and regulations.

Members of RiverStone and their employees, agents and representatives are prohibited from:

• offering or accepting a bribe;
• authorizing, giving or receiving a facilitation payment, improper payment or other benefit to any person or entity (including a public official) in order to obtain an advantage for any RiverStone company or to induce them to do something corrupt; or
• acting in any way that may induce or facilitate someone else to be in breach of this policy.