Code or appear to interfere with the best

Code of ConductIntroductionWhile employed by Revolut Ltd., personnel should act lawfully, honestly, ethically, and in the best interests of Revolut. This code of conduct lays out the basic guidelines for business conduct required of all employees while performing their job duties at Revolut.

It is important to read this entire document in order to get a general idea of Revolut’s values and to refer to it in any case of uncertainty on whether your conduct or the conduct of your coworkers are in line with this code. After referring to this guide, if the uncertainty persists, you should contact your manager or the HR and Legal department. Personal ConductConflicts of interestEmployees are expected to use their judgment to act in the best interests of Revolut while performing their job duties, which involves avoiding actual or apparent conflicts of interest. A conflict of interest exists when your personal interests or personal activities or relationship interfere or appear to interfere with the best interests of Revolut. For example, a conflict of interest may occur when you or a family member receive a personal benefit as a result of your position with Revolut or when an employee’s business or personal relationship with a customer, supplier, competitor, impairs an employee’s objective business judgement.

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Other specific areas of potential conflict of interest such as external business relationships, gifts, entertainment etc are discussed in more detail in Compliance training on Moodle.Money laundering You have a personal responsibility to report knowledge or suspicion of money laundering to the Revolut’s Money Laundering Reporting Officer. Please refer to the Anti Money Laundering material on Moodle for more information on who to contact. This is knowledge or suspicion about a firm or person, formed or obtained in the course of your work, which links the financial dealings of that firm or person (or its customers, connected persons, etc.

) to any criminal conduct or terrorist activities. The Money Laundering Regulations 2007 create this responsibility and providing you follow our reporting procedure , you will comply with the law.Confidentiality of information You must observe absolute confidentiality concerning the affairs of Revolut, other than as required to perform your normal duties. Information must be kept confidential, even if it is favourable and not adverse to the firm or individual concerned. This includes confidential information of third parties that we have received under non-disclosure agreements.

Confidential information includes, without limitation, proprietary data, trade secrets and know-how such as software and product designs, product plans, processes, designs, engineering, customer lists, employee data (other than your own), financial information, budgets, pricing, business plans, or other business information.You should seek further guidance if you are at all uncertain as to whether confidential information can be disclosed.Exclusive Employment While employed by Revolut you are not permitted to undertake any additional employment, whether directly or indirectly, except with written approval of Revolut. Agreement will not be given where a potential conflict of interest exists.

The undertaking of an external employment can include part-time work in your spare time (whether paid or not) and employment includes directorships, board membership, local authority councillorships, or provision of services as consultant. When you join Revolut, you will be asked to disclose any external professional commitment or business interest and you will need to obtain written approval in advance from your Director/Head of Department before continuing with this activityIntellectual property Any intellectual property such as design, logos, computer programs, patents, created or produced during your employment with Revolut may not be used by you except in the performance of your duties. Such work will remain the property of Revolut and you may be required to assign the property rights to Revolut.

Media enquiries In order to help Revolut to maintain a consistent line when dealing with press or other media enquiries, all press enquiries must be referred to the Marketing and Communications Team. If you receive a media enquiry you should not comment on what is being put to you, but politely and firmly refer the Marketing and Communications Team. You should also contact them yourself to inform them of the enquiry.

Other Communications Because all business communications may be shared or become public during investigations, litigations or even media publication, it is important to make sure that all recorded communications, including emails and texts are respectful, clear and accurate. Potential risks from inaccurate or misleading statements include claims of false advertising, misrepresentation, breach of contract, securities fraud, unfair disclosure, and antitrust violations. In addition, you may not discuss Revolut’s business, performance, goals, products and ventures to the media, current or potential investors prior to requesting the approval of the CFO. Protection of User DataRevolut users have chosen our platform in order receive, send payments and conduct their personal or professional financial business. Because of this privilege, during your time of employment at Revolut, you may have access to information systems or tools that enable you to view certain personal information relating to users (including your coworkers, friends and family), which is not available to the public.

These tools are important and necessary to in order to help Revolut employees perform their work effectively. However, it is extremely important to treat this data with the utmost importance, sensitivity and caution. Revolut’s brand depends on the trust of our users and  on your good judgment and discretion when using tools that allow you to view user information that would otherwise not be visible to you on the sites. Please make sure to complete the GDPR trainings available on Moodle, which offers details on your use of and access to user data as an employee of Revolut.

Harassment  At Revolut we strictly prohibit unlawful discrimination or harassment by or of workers, contributors, managers, guests, clients, or agency partners in the workplace or in a work-related situation on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity, or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. If you suspect harassment, discrimination, or retaliation has occurred, you are encouraged, and managers are required, to promptly provide a written or oral complaint to a HR. There is also an incidents escalation process that can be used.Protection of Company Property  Revolut provides its employees with different assets such as laptops, phones, software, and facilities that help you perform your job under the best circumstances. Employees are expected to treat these assets with care and use them with the interests of the business in mind. This means that assets should be well maintained and not subject to unreasonable use. If something you are using is damaged, please see that it gets fixed or replaced. In addition, you should use your judgment in using company assets for personal matters.

Revolut’s assets are property of the company and provided for business use. While we recognize that personal use occurs, it should not be excessive and should not interfere with performance of your business duties.Whistleblowing Policy and Reporting ViolationsIf you learn about or suspect a violation of this code, another Revolut policy, or any law, you shall promptly report it to your manager, another manager, Human Resources, Internal Audit, or the Legal Department. If you are uncomfortable making such a report, you may do so anonymously if permitted by applicable law. For more information on reporting violations, please see Revolut’s Whistleblower Policy below. In cases in which an individual reports a suspected violation of policy or law in good faith and is not engaged in the questionable conduct, Revolut will attempt to keep its discussions and actions confidential to the greatest extent possible and in compliance with applicable laws and regulations governing privacy.

Whistleblowing Policy This policy aims to encourage individuals to report concerns in the knowledge that concerns will be taken seriously and investigated, provide guidance on raising concerns and provide assurances about how we protect whistleblowers. Our policy applies to all employees, officers, secondees, consultants, contractors, volunteers, interns, casual workers and agency workers. All these individuals should familiarise themselves with this policy. It also applies to former employees and others whose work with or for Revolut has come to an end.For the purposes of this policy, a whistleblower is any person that has disclosed, or intends to disclose, a concern relating to any of the below (a “Reportable Concern”).Reportable Concerns can relate to suspected danger, risk, malpractice or wrongdoing at work which affects others.

This may include, but is not limited to: a criminal offence, including bribery and corruption; a failure to comply with any legal obligation;  a miscarriage of justice; endangering the health and safety of any person;  damage to the environment;  unauthorised disclosure of confidential information;  breach of our Code of Conduct above;  breach of our internal policies and procedures;  behaviour that harms or is likely to harm the reputation or financial well-being of Revolut.  the deliberate concealment of any of the above. If you have a Reportable Concern, you should raise it in person or in writing by contacting one of the following:  Your line manager;Another manager;The Legal departmentHuman Resources;If you are unable to contact the people above, you can reach out to C-level employees or the board.Your identity will not be revealed without your consent. It is helpful to all parties if you can confirm whether you are a whistleblower under this policy.We hope that individuals will feel able to voice their concerns openly under this policy.

However, if you prefer to raise your concerns confidentially, we will do all we can to keep your identity secret except if this right is overridden by law. If it is necessary for anyone other than the original recipient of your disclosure to be aware of your identity we will discuss this with you before your identity is disclosed to anybody else. We do not encourage individuals to make disclosures anonymously. It makes a proper investigation more difficult if it isn’t possible to obtain further information from the whistleblower.

It can also be in a whistleblower’s own interests for a proper audit trail to exist (records are held securely and access is strictly.)We understand that whistleblowers are sometimes worried about possible repercussions. We wish to encourage openness and will support individuals who raise genuine Reportable Concerns under this policy even if they turn out to be mistaken.

Managers should make sure that their staff are aware of the policy and encourage a positive open working culture in which individuals feel comfortable expressing concerns. Reportable Concerns should be taken seriously and be dealt with in accordance with this policy.Whistleblowers must not suffer detriment because they have raised a genuine concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.

Revolut will not retaliate against anyone making a good-faith report of a potential violation. Revolut will investigate any report of a violation. You must cooperate fully with any investigation, but should not investigate independently, as alleged violations may involve complex legal issues, and you may risk compromising the integrity of a formal investigation. Conduct that violates the law or company policies is grounds for prompt disciplinary or remedial action. In addition, your failure to report a known violation of law or company policy by someone else may result in disciplinary action for employees and/or termination of employment/your relationship with Revolut.Disciplinary ActionsDiscipline for a violation of Revolut’s policies or applicable law may range from a warning up to and including summary termination of employment/your relationship with Revolut (in accordance with applicable law).

Where laws have been violated, we will cooperate fully with the appropriate authorities.


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