Code of Business Ethics

We all want Vista Outdoor to be successful. The way in which we conduct ourselves is equally important to the results we achieve. We must never compromise our integrity or ethics to achieve results. This is why we have an ethics and compliance program that helps define Vista Outdoor’s commitment to legal and ethical conduct.

Our Code summarizes the standards that govern how we conduct our business. This Code is a common-sense guide to help you make ethical business decisions, raise your awareness of legal and ethical issues, and understand the process in place for dealing with those issues.

Bring it to the attention of your local supervisor, or any member of local management, as appropriate. The most immediate resource for reporting good faith concerns of suspected violations is your immediate Supervisor or any member of local management. If you prefer not to go to your Supervisor, or your concern was not adequately addressed by your local supervisor or local management, other options are available.

Reports, concerns, and questions relating to banking, accounting, finance, internal accounting controls, bribery or anti-corruption, or antitrust/competition, and other topics covered in this Code may also be made directly, to any of the following:

A Business Ethics Committee Representative

Your Human Resources Department

Your Vista Outdoor Legal Counsel

Vista Outdoor’s Ethics Office

When you have a question, need guidance, or suspect a violation of the Code, our policies, or applicable legal requirements has occurred (or may occur), then speaking up is the right thing to do.

In addition, reports may be made through the following Ethics Hotlines, which are managed by an outside service provider, and are available all day every day.

The Kinetic Group – an ethics or compliance concern related to The Kinetic Group can be reported at:

tkghelpline.ethicspoint.com

844-286-0005

Revelyst – an ethics or compliance concern related to Revelyst can be reported at:

revelyst.ethicspoint.com

Dedicated phone numbers are listed below.