Code of Ethics

Remington Industries, Inc. (“Remington” or “Company”) will conduct its business honestly and ethically wherever we operate in the world and we therefore adopt this Code of Ethics & Business Conduct (“Code”) to document this commitment.

We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. No illegal or unethical conduct on the part of officers, directors, employees or affiliates is in the Company’s best interest and none will be tolerated. Remington will not compromise its principles for short-term advantage. The ethical performance of this Company is the sum of the ethics of the men and women who work here. Thus, we are all expected to adhere to high standards of personal integrity.

This Code is neither a contract nor a comprehensive manual that covers every situation that might be encountered. It is a guide that highlights key issues and identifies policies, procedures and resources to help our officers, directors and employees make decisions that will reflect well on themselves, their teams and Remington.

Officers, directors, and employees of the Company must never permit their personal interests to conflict, or appear to conflict, with the interests of the Company, its licensors, customers or suppliers. Officers, directors and employees must be particularly careful to avoid representing Remington in any transaction with others with whom there is any outside business affiliation or relationship. Officers, directors, and employees shall avoid using their Company contacts to advance their private business or personal interests at the expense of the Company, its licensors, customers or suppliers.

No bribes, kickbacks or other similar remuneration or consideration shall be given to any person or organization in order to attract or influence business activity. Officers, directors and employees shall avoid gifts, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business activity.

Officers, directors and employees of Remington will often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and must take appropriate steps to assure that such information is strictly safeguarded. This information—whether it is on behalf of our Company or any of our licensors, customers or suppliers—could include strategic business plans, operating results, marketing strategies, customer lists, personnel records, upcoming acquisitions and divestitures, new investments, and manufacturing costs, processes and methods. Proprietary, confidential and sensitive business information about this Company, other companies, individuals and entities should be treated with sensitivity and discretion and only be disseminated on a need-to-know basis.

Officers, directors and employees will:

• Seek to report all information accurately and honestly, and as otherwise required by applicable reporting requirements.
• Refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge that has been gathered in such a manner.
• Seek to avoid exaggerating or disparaging comparisons of the services and competence of the Company’s competitors.
• Obey all Equal Employment Opportunity laws, and other applicable laws and regulations, and act with respect and responsibility towards others in all of their dealings.
• Remain personally balanced so that their personal lives will not interfere with their ability to deliver quality products or services to the Company and its customers.
• Will disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of Company policies and procedures, directly to management.

REPORTING CODE OF ETHICS VIOLATIONS

Systems have been implemented and communicated to all officers, directors, employees and other interested parties to assure their ability to ask questions about the Code or to report a violation.  These systems include:

• Chain of command reporting options;
• Human Resources Department reporting options; and
• The Remington Hotline that will be effective by the Spring of 2011.

Questions and complaints will be handled in a confidential manner. Remington will not retaliate against any party for reporting in good faith any suspected violation of the Code, or any other Company policy/procedure or federal, state or local law or regulations. Similar protection extends to anyone giving information in relation to an investigation conducted by Remington or a governmental agency.

VIOLATIONS OF THE CODE OF ETHICS & BUSINESS CONDUCT

Remington will promptly and thoroughly investigate all complaints of Code violations. Violations of the Code by officers, directors or employees will result in discipline, up to and including termination of employment or removal from office. The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether or not the violator cooperated in any subsequent investigation.

Violation of the Code by vendors or other outside parties may result in termination of their relationships with Remington as permitted by governing agreements. If applicable, civil or criminal prosecution may also be pursued.