SEKO - Global Policies & Employee Handbook 2019

V. DISCIPLINARY ACTION The Management of SEKO, and/or of SEKO’s Partners and/or Agents (if affected) will determine the appropriate action in an investigation regarding potential violation of the Code of Conduct or any alleged misconduct that falls within the purview of the principles set forth herein. Violations of SEKO’s Code of Conduct, or of its other policies and procedures that are aligned with this Code of Conduct, will be grounds for disciplinary action up to and including termination, or in the case of a Partner and/or Agent, the contract or agreement with SEKO may be terminated or suspended. All Employees, Partners, and Agents will be held to the same standards of conduct described herein. VI. ACKNOWLEDGEMENT & PUBLISHING OF THE CODE OF CONDUCT Each Employee, Partner, and Agent will be required to review the Code of Conduct via SEKO intranet or on SEKO’s public website at www.sekologistics.com . Any questions regarding the terms of this Code of Conduct should be sent to the email address set forth herein. SECTION 11

ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT I. PURPOSE

suppliers, subcontractors or business partners worldwide (collectively “Suppliers”). SEKO strongly opposes any use of slavery or human trafficking in the distribution of its own products, or its client’s products, and fully supports the promotion of ethical and lawful business practice within our workplace. II. SCOPE This policy covers all employees of SEKO and all of its subsidiaries or entities controlled by SEKO. In the event that anything in this policy may conflict with local law, local law will control the interpretation and application of this policy statement.

SEKO has a strong and unwavering commitment to prohibiting human trafficking and slavery by any of its business entities, employees, and other parties associated with SEKO. In compliance with the law, and to effectuate SEKO’s commitment to prohibiting these practices, this Anti-Slavery and Human Trafficking Statement (hereafter referred to as the “Anti-Slavery Statement”) serves to ensure a work environment that is free from human trafficking, forced labor and unlawful child labor (Slavery and Human Trafficking). SEKO strongly believes that it is responsible for promoting ethical and lawful employment practices amongst the SEKO group of companies. These practices are also required to be followed by our

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