Code of Conduct

The following content is excerpted from the RBA Employee Handbook and is presented here to ensure transparency and accessibility for employees, partners, and clients who require visibility into our policies and practices. This information highlights key guidelines that govern employment standards within RBA and is intended to provide clarity on expectations and compliance obligations. For the complete and most current version of the Employee Handbook, employees should refer to the official document available through internal HR resources.

Ethics and Conduct

It is important for every team member to understand the Company policies, laws, and rules which apply to their role. If an employee is unsure, they should ask their manager for guidance.  Several key questions can help identify situations that may be unethical, inappropriate, or illegal.

  • Does what I am doing comply with Company policies?
  • Have I been asked to misrepresent information or not follow a normal procedure?
  • Would I feel comfortable describing my decision to my manager?
  • Is this the right thing to do?

Employees are responsible for preventing violations of the law and for speaking up and reporting possible violations. The Company will investigate reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the Company will take appropriate action. Redhill Business Analytics will not tolerate retaliation against team members who raise genuine ethics concerns in good faith.

Harassment, Discrimination, and Retaliation Prevention Policy

Redhill Business Analytics is committed to providing a work environment free of harassment, discrimination, retaliation, and disrespectful or other unprofessional conduct based on:

  • Race
  • Religion (including religious dress and grooming practices)
  • Color
  • Sex/gender (including pregnancy, childbirth, breastfeeding, or related medical conditions), sex stereotype, gender identity/gender expression/transgender (including whether or not you are transitioning or have transitioned) and sexual orientation.
  • National origin
  • Ancestry
  • Physical or mental disability
  • Medical condition
  • Genetic information/characteristics
  • Marital status/registered domestic partner status
  • Age (40 and over)
  • Sexual orientation
  • Reproductive decision-making
  • Military or veteran status
  • Any other basis protected by federal, state or local law or ordinance or regulation.

Redhill Business Analytics also prohibits discrimination, harassment, disrespectful or unprofessional conduct based on the perception that anyone has any of those characteristics or is associated with a person who has or is perceived as having any of those characteristics. In addition, the Company prohibits retaliation against individuals who raise complaints of discrimination or harassment or who participate in workplace investigations.

Harassment Prevention

The Company’s policy prohibiting harassment applies to all persons involved in the operation of the Company. The Company prohibits harassment, disrespectful or unprofessional conduct by any employee of the Company, including supervisors, managers, and co-workers. The Company’s anti-harassment policy also applies to vendors, customers, independent contractors, unpaid interns, volunteers, persons providing services pursuant to a contract and other persons with whom you come into contact while working.

Prohibited harassment, disrespectful or unprofessional conduct includes, but is not limited to, the following behavior:

  • Verbal conduct such as epithets, derogatory jokes or comments, slurs or unwanted sexual advances, invitations, comments, posts or messages;
  • Visual displays such as derogatory and/or sexually oriented posters, photography, cartoons, drawings or gestures;
  • Physical conduct including assault, unwanted touching, intentionally blocking normal movement or interfering with work because of sex, race or any other protected basis;
  • Threats and demands to submit to sexual requests or sexual advances as a condition of continued employment, or to avoid some other loss and offers of employment benefits in return for sexual favors;
  • Retaliation for reporting or threatening to report harassment; and
  • Communication via electronic media of any type that includes any conduct that is prohibited by state and/or federal law or by company policy.

Sexual harassment does not need to be motivated by sexual desire to be unlawful or to violate this policy. For example, hostile acts toward an employee because of their gender can amount to sexual harassment, regardless of whether the treatment is motivated by sexual desire. Prohibited harassment is not just sexual harassment, but harassment based on any protected category.

Non-Discrimination

The Company is committed to compliance with all applicable laws providing equal employment opportunities. This commitment applies to all persons involved in Company operations. The Company prohibits unlawful discrimination against any job applicant, employee, or intern by any employee of the Company, including managers and coworkers.

Pay discrimination between employees of different sexes or between employees of another race or ethnicity performing substantially similar work, as defined by the California Fair Pay Act and federal law, is prohibited. Pay differentials may be valid in certain situations defined by law. Employees will not be retaliated against for inquiring about or discussing wages, however, the Company is not obligated to disclose the wages of other employees.

Anti-Retaliation

The Company will not retaliate against you for filing a complaint or participating in any workplace investigation or complaint process, and will not tolerate or permit retaliation by management, employees, or co-workers.

Reasonable Accommodation

To comply with applicable laws ensuring equal employment opportunities to qualified individuals with a disability, the Company will make reasonable accommodations for the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or an employee unless undue hardship would result.

Any job applicant or employee who requires an accommodation in order to perform the essential functions of the job should contact your performance manager and/or an HR representative and discuss the need for an accommodation. The Company will engage in an interactive process with the employee to identify accommodations, if any, that will help the applicant or employee perform the job. An applicant, employee or unpaid intern who requires an accommodation of a religious belief or practice (including religious dress and grooming practices, such as religious clothing or hairstyles) should also contact the designated HR representative and discuss the need for an accommodation. If the accommodation is reasonable and will not impose an undue hardship, the Company will make the accommodation. The Company will not retaliate against you for requesting a reasonable accommodation and will not knowingly tolerate or permit retaliation by management, employees, or co-workers.

Complaint Process

If you believe that you have been the subject of harassment, discrimination, retaliation, or other prohibited conduct, bring your complaint to any manager as soon as possible after the incident. If you need assistance with your complaint, or if you prefer to make a complaint in person, contact the designated HR representative. Please provide all known details of the incident or incidents, names of individuals involved and names of any witnesses. It would be best to communicate your complaint in writing, but it is not mandatory.

The Company encourages all individuals to report any incidents of harassment, discrimination, retaliation, or other prohibited conduct forbidden by this policy immediately so that complaints can be quickly and fairly resolved. You also should be aware that the Federal Equal Employment Opportunity Commission and the California Civil Rights Department investigate and prosecute complaints of prohibited harassment, discrimination, and retaliation in employment. If you think you have been harassed or discriminated against or that you have been retaliated against for resisting, complaining, or participating in an investigation, you may file a complaint with the appropriate agency. The nearest office can be found by visiting the agency websites at www.calcivilrights.ca.gov and www.eeoc.gov

Managers must refer all complaints involving harassment, discrimination, retaliation, or other prohibited conduct to the designated HR representative so the Company can try to resolve the complaint.

When the Company receives allegations of misconduct, it will immediately undertake a fair, timely, thorough, and objective investigation of the allegations in accordance with all legal requirements. The Company will reach reasonable conclusions based on the evidence collected. The Company will maintain confidentiality to the extent possible. However, the Company cannot promise complete confidentiality. The employer’s duty to investigate and take corrective action may require the disclosure of information to individuals with a need to know.

If the Company determines that harassment, discrimination, retaliation, or other prohibited conduct has occurred; appropriate and effective corrective and remedial action will be taken in accordance with the circumstances involved. The Company will also take appropriate action to deter future misconduct. Any employee determined by the Company to have engaged in harassment, discrimination, retaliation, or other prohibited conduct will be subject to appropriate disciplinary action, up to, and including termination.

Employees should know that if they engage in unlawful harassment, they can be held personally liable for the misconduct.

Anti-Corruption Compliance

Redhill Business Analytics is committed to conducting business in compliance with all applicable anti-corruption and anti-bribery laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.


Bribery and Improper Payments:
Employees, contractors, and representatives must never offer, promise, give, or authorize payment of money or anything of value to any customer, government official, or third party to improperly influence a decision or gain an unfair advantage.


Gifts and Entertainment:
Modest gifts and entertainment may be permitted only if they are lawful, infrequent, and not intended to influence business decisions. Cash or cash equivalents are strictly prohibited. Any gift or entertainment involving government officials requires prior written approval from management.


Payment of Commissions:
Commissions, rebates, discounts, or similar payments must be transparent, properly documented, and comply with all applicable laws. Payments to agents or intermediaries must never be used as a conduit for bribery.


Reporting and Compliance:
Employees must promptly report any suspected violation of this policy to their manager or the designated compliance officer. Violations may result in disciplinary action, up to and including termination, and could lead to legal consequences.