SECTION 6 FOREIGN CORRUPT PRACTICES ACT (“FCPA”)
In the event that you believe that a SEKO Representative’s business conduct or practices is in violation of this policy, you have an obligation to do the following: STEP 1: You may request a joint meeting (Skype, conference call or face/face) with the Senior Director of Compliance of SEKO Worldwide, LLC. You may be asked to put your complaint or question in writing. The current Senior Director of Compliance is Sandra Scott, sandra.scott@sekologistics.com . STEP 2: If the Senior Director of Compliance is involved with the complaint or you are not satisfied with the resolution provided, you may request a joint meeting with the SEKO Worldwide, LLC Chief Compliance Officer or the General Counsel. The current Chief Compliance Officer is James Gagne, 1100 Arlington Heights Road, Itasca, Illinois USA 60143, james.gagne@sekologistics.com . The General Counsel is Char Dalton, 1100 Arlington Heights Road, Itasca, Illinois USA 60143, char.dalton@sekologistics.com . You may also report a complaint through SEKO’s Anonymous Hotline. Please see the SEKO Logistics Anonymous Hotline Policy for methods of reporting a confidential complaint. SEKO will protect the confidentiality of the allegations to the extent possible and appropriate under the circumstances. If you feel uncomfortable making a complaint under your name, you may make the complaint anonymously. SEKO will actively investigate all complaints under this policy, and if it is determined that a violation has occurred, SEKO will take appropriate disciplinary action against the offending party - up to and including discharge of the employee or termination of the agreement with such SEKO Representative. SEKO will not take or permit retaliation against any person who has complained about corruption or Anti-Corruption Laws violations, or who otherwise participated in an investigation of such complaints. Any SEKO Representative who receives a complaint from a member of the public should advise the person to report his or her complaint directly to the Senior Director of Compliance. SEKO will not pay any fines, penalties or legal expenses assessed against a SEKO Representative who is found guilty of violating any Anti-Corruption Laws.
SEKO Logistics (“SEKO”) conducts its business ethically and in compliance with all laws in the countries where SEKO does business, including all anti-corruption laws such as the U.S. Foreign Corrupt Practices Act of 1977, as amended and the UK Bribery Act, as amended (collectively, the “Anti-Corruption Laws”). SEKO Representatives MAY NOT directly or indirectly give, offer, promise, make or facilitate the making of payments of anything of value (monetary or otherwise) to (i) a U.S. or foreign official to induce that official to affect any government act or decision in a manner that will assist SEKO Representatives to obtain or retain business or any business advantage or violate the Anti-Corruption Laws, including, but not limited to, Facilitating Payments or (ii) any employee, shareholder, officer, director, manager or agent of any other person for any improper purpose. In addition, SEKO Representatives MAY NOT accept any offer, promise or payment (monetary or otherwise) from any customer or SEKO Representative other than payments in the ordinary course of business for a proper purpose. SEKO Representatives are obligated to keep books, records, and accounts that accurately and fairly reflect all transactions and disposition of SEKO assets. Some examples of conduct that may be construed as unethical or corrupt behavior include, but are not limited to: (i) illegal conduct of SEKO Representatives; (ii) use of funds or property of SEKO for any illegal, improper or unethical purpose; (iii) fraud or theft of corporate property or embezzling funds, misappropriating funds, assets or corporate information; (iv) tampering with any accounting or audit-related records or documents of SEKO (in any format, including electronic records such as e-mails) or improperly destroying any accounting or audit-related records or documents; (v) fraud or deliberate error in the recording and maintaining of SEKO’s financial records describing an expenditure for one purpose when, in fact, it is being made for something else); or (vi) any effort to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statement or records of SEKO. (for example, overstating expense reports, falsifying time sheets, preparing erroneous invoices, misstating inventory records or
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