Code of Ethics and Business Conduct

Last Updated: 2/1/2022

Our Core Values

Convenience, Quality, Family, and Growth & Results.

Mission

The Refuel Way – Refueling the tanks, bodies, and lives of people on the go!

Build Trust and Credibility

The success of our business is dependent on the trust and confidence we earn from our employees, customers, and shareholders. We gain credibility by adhering to our commitments, displaying honesty, integrity and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.

When considering any action, it is wise to ask: will this build trust and credibility for Refuel? Will it help create a working environment in which Refuel can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering “yes” to those questions and by working every day to build our trust and credibility.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. Refuel is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.

Refuel is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive, or harassing behavior. Any team member who feels harassed or discriminated against should report the incident to his or her manager or to human resources directly.

All Refuel team members are also expected to support an inclusive workplace by adhering to the following conduct standards:

  • Treat others with dignity and respect at all times.
  • Address and report inappropriate behavior and comments that are discriminatory, harassing, abusive, offensive, or unwelcome.
  • Foster teamwork and team member participation, encouraging the representation of different team member perspectives.
  • Seek out insights from employees with different experiences, perspectives, and backgrounds.
  • Avoid slang or idioms that might not translate across cultures.
  • Support flexible work arrangements for co-workers with different needs, abilities and/or obligations.
  • Confront the decisions or behaviors of others that are based on conscious or unconscious biases.
  • Be open-minded and listen when given constructive feedback regarding others’ perception of your conduct.

Refuel will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive, or unwelcome.

Create a Culture of Open and Honest Communication

At Refuel everyone should feel comfortable to speak his or her mind, particularly with respect to ethics concerns. Managers have a responsibility to create an open and supportive environment where team members feel comfortable raising such questions. We all benefit tremendously when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times.

Refuel will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.

For your information, Refuel Listens Ethics Program policy is as follows:

Refuel has developed a confidential hotline (the “Hotline”) whereby Employees can report any wrongdoing or misconduct that they suspect or believe may be occurring at Refuel (a “Report”). Any wrongdoing or misconduct includes, but is not limited to, any violation of the standards set forth in the employee handbook, any discrimination, harassment, finance, and accounting violations, privacy violations, or other misconduct. A Report may be filled anonymously or in person. Unless compelled by legal process, an Employee who makes a Report confidentially shall remain confidential, and no effort to ascertain the identity of such Employee will be tolerated. Employees can access the Hotline via the internet from a computer, tablet, or mobile phone, as well as via phone call, at the following links/numbers: 

  • Web Intake Site: http://refuelmarket.ethicspoint.com/
  • Mobile Intake Site: http://refuelmarketmobile.ethicspoint.com
  • Hotline: 844-942-3295

Team members are encouraged, in the first instance, to address such issues with their managers or the HR department, as most problems can be resolved swiftly. If for any reason that is not possible or if a team member is not comfortable raising the issue with his or her manager, the Refuel Listens Ethics Line is a great option and Refuel does operate with an open-door policy.

Set Tone at the Top

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At Refuel, we want the ethics dialogue to become a natural part of daily work.

Uphold the Law

Refuel’s commitment to integrity begins with complying with laws, rules, and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Refuel’s policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations.

Competition

We are dedicated to ethical, fair and vigorous competition. We will sell Refuel products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for Refuel or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.

Proprietary Information

It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

Selective Disclosure

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to Refuel Operating Company, LLC, its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.

Health and Safety

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to Refuel Operating Company, LLC, its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.

Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of Refuel may conflict with our own personal or family interests. We owe a duty to Refuel to advance its legitimate interests when the opportunity to do so arises. We must never use Refuel property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Refuel.

Here are some other ways Conflicts of Interest could arise:

  1. Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier, or contractor, regardless of the nature of the employment, while you are employed with Refuel.
  2. Hiring or supervising family members or closely related persons.
  3. Serving as a board member for an outside commercial company or organization.
  4. Owning or having a substantial interest in a competitor, supplier or contractor.
  5. Having a personal interest, financial interest or potential gain in any Refuel transaction.
  6. Placing company business with a firm owned or controlled by a Refuel employee or his or her family.
  7. Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier, unless equally available to all Refuel’s team members. Per the guidelines established in Refuel’s Anti-Bribery/Anti-Corruption policy on gift value – Refuel team members must obtain written preapproval from a Refuel executive for any gifts valued over $100.00, whether given or accepted. Gifts of cash are never allowed.  Please see the full Anti-Bribery/Anti-Corruption policy for reference.

Determining whether a conflict of interest exists is not always easy to do.  Team members with a conflict-of-interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or the HR department.

Corporate Recordkeeping

We create, retain, and dispose of our company records as part of our normal course of business in compliance with all Refuel’s policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with Refuel’s and other applicable accounting principles.

We must not improperly influence, manipulate, or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of Refuel books, records, processes, or internal controls.

Promote Substance Over Form

At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.

At Refuel, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that Refuel is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.

Although Refuel’s guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct. 

Accountability

Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the HR department.

Refuel takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of employment. 

Confidential and Proprietary Information

Integral to Refuel’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers, and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

Use of Company Resources

Company resources, including time, material, equipment, and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace.

Team members and those who represent Refuel are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

Generally, we will not use company equipment such as computers, copiers, and fax machines in the conduct of an outside business or in support of any religious, political or other outside daily activity, except for company-requested support to nonprofit organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.

In order to protect the interests of the Refuel network and our fellow team members, Refuel reserves the right to monitor or review all data and information contained on an team member’s company-issued computer or electronic device, the use of the Internet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate.

Questions about the proper use of company resources should be directed to your immediate manager. 

Media Inquiries

Refuel is a high-profile company in our community, and from time to time, our team members may be approached by reporters and other members of the media.  To ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the following email address: legal@refuelmarket.com.  No one may issue address the media or authorize a press release without first consulting with the legal department at legal@refuelmarket.com.

Do the Right Thing

Several key questions can help identify situations that may be unethical, inappropriate, or illegal. Ask yourself: 

  • Does what I am doing comply with the Refuel guiding principles, Code of Conduct and company policies?
  • Have I been asked to misrepresent information or deviate from normal procedure?
  • Would I feel comfortable describing my decision at a staff meeting?
  • How would it look if it made the headlines?
  • Am I being loyal to my family, my company and myself?
  • What would I tell my child to do?
  • Is this the right thing to do?