SEKO - Global Policies & Employee Handbook 2019

d. Anti-Boycott Policy In the United States, Congress has promulgated laws and regulations that makes it illegal for any U.S. Citizen or American based business (incorporated and unincorporated) to participate in any foreign boycott not sanctioned by the U.S. Government. In addition to prohibiting all unsanctioned foreign boycotts, it is also illegal to engage in the following: • Agreeing to refuse or actual refusal to do business with or in Israel, or with blacklisted companies. • Agreeing to or actually discriminating against other persons based on their race, religion, sex, national origin or nationality. • Agreeing to furnish or actually furnishing information about business relationships with or in Israel, or with blacklisted companies. • Agreements to furnish or actual furnishing of information about the race, religion, sex, or national origin of another person. The U.S. has a strong interest in ensuring that U.S. Citizens and U.S. businesses are not helping to effectuate foreign policies that are contrary to U.S. policies. Therefore, all SEKO employees, and representatives must refrain from participating in any unsanctioned foreign boycott. Violations of U.S. anti-boycott will not only result in the termination of relations with SEKO, but may also be subjected to criminal penalties.

e. Reporting Violations All employees and parties associated with SEKO are responsible for compliance with this Code of Conduct. In the area of ethics, legality and propriety, all parties have an obligation to SEKO to be alert to possible violations of the Code of Conduct in any business transaction and are encouraged to report such violations promptly to SEKO Corporate Ethics, in writing, to the following email: ethics@sekologistics.com Employees and all other parties representing SEKO will also be expected to cooperate in any type of investigation. In addition, any Employee, Partner, and/or Agent who is convicted of a felony, should make this known to SEKO Corporate Ethics (unless otherwise prohibited or protected by law from doing so). In all cases when there is questionable activity involving the Code of Conduct, or other misconduct, an investigation will be conducted to determine appropriate action. Whenever possible, SEKO will keep confidential the identity of all employees and other parties. SEKO’s Confidentiality Policy will keep confidential all information about or against whom allegations of violations are brought, until it has been determined that a violation has occurred. Similarly, whenever possible, SEKO will keep confidential the identity of anyone reporting a possible violation. Retaliation against any employee for reporting a suspected violation is strictly prohibited.

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