SEKO - Global Policies & Employee Handbook 2019

SECTION 10 CODE OF CONDUCT AND ETHICS STATEMENT I. PURPOSE.

SEKO has a strong and unwavering commitment to promoting honest and ethical business conduct by all employees, and other parties associated with SEKO. To effectuate SEKO’s commitment to these principles, this Code of Conduct and Ethics Statement (hereafter referred to as the “Code of Conduct”) serves to: (1) emphasize SEKO’s commitment to ethics and compliance with the law; (2) set forth expectations for the adherence to basic standards of ethical and legal behavior; (3) provide reporting procedures for known or suspected ethical or legal violations; and (4) help prevent and detect wrongdoing. The Code of Conduct is an addition to, and supplements the other policies and procedures which comply with the law. However, if a local custombusiness practice, standard of dealing, or other non-legally binding authority conflicts with this Code of Conduct, this Code of Conduct supersedes that local practice or standard of dealing and youmust comply with this Code of Conduct. SEKO’s standard business practice is to distribute and/or make available copies of the Code of Conduct to its employees, independent contractors, suppliers and all other parties associated with SEKO. The aforementioned parties are required to read the Code of Conduct and to understand it. Partners, Agents, and all other separate entities who have an affiliation with SEKO are urged to have similar policies and WE ARE COMMITTED TO ALWAYS DOING THE RIGHT THING

procedures in force to secure compliance with the principles of business integrity and ethics as set forth in this Code of Conduct. All parties are expected to apply this Code of Conduct and to apply common sense with the objective of reaching full compliance. All employees and affiliated parties are responsible for their own actions. All claims of violations of this Code of Conduct will be investigated by appropriate company personnel. Those who violate the standards of this Code of Conduct will be subject to disciplinary action, and in the case of Partners and Agents, suspension or termination of their contract or agreement with SEKO. In all instances, appropriate legal action may be taken if a violation is discovered. The absence of a specific guideline, practice, or instruction covering a particular situation does not relieve one from exercising the highest ethical standards applicable to the circumstances. In all cases, parties associated with SEKO are expected to make decisions prudently and seek guidance within the Human Resources and/or Compliance Department or direct management in cases of uncertainty.

You are encouraged to report any possible violation by sending an e-mail to: ethics.sekologistics.com

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