SEKO - Global Policies Handbook 2018

SEKO - Global Policies Handbook 2018

SEKO LOGISTICS GLOBAL POLICIES

Release Date: January 1, 2018

WELCOME

Dear SEKO Team Member,

Welcome to SEKO Logistics group companies! For more than 40 years, SEKO Logistics has been a leading provider of logistics services. SEKO has made a name for itself as a supply chain differentiator for our customers, and has earned this reputation due to our unique services, our lean and adaptable model, and our overarching commitment to customer-centricity above all else. We’ve been recognized consistently as an industry leader in superior customer service and on-time performance. With your help, we are looking forward to continuing growth and prosperity, as we find new and better ways to serve our customers’ needs. As a global organization, you may be a member of our team in the UK, in China or Hong Kong, in the United States, or elsewhere. Wherever you are geographically based, we welcome you and want to make you aware of the global policies that impact you. We invite you to read and be familiar with the following contents, and to let your manager know if you have any questions or concerns. Your specific Employee Handbook, listing local policies and procedures, may be provided as separate from this global policy document. SEKO wishes you much success in your career with our company and thanks you for your service, dedication, and adherence to the global policies that ensure our future success.

With my best regards,

William J. Wascher, Chairman

TABLE OF CONTENTS

SECTION 8 WORKPLACE VIOLENCE SECTION 9 ANONYMOUS HOTLINE SECTION 10 CODE OF CONDUCT AND ETHICS STATEMENT SECTION 11 ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT

SECTION 1 SEKO’S CORE VALUES SECTION 2 EQUAL EMPLOYMENT OPPORTUNITY

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SECTION 3 HARASSMENT

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SECTION 4 NO RETALIATION

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SECTION 5 C-TPAT

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SECTION 12 ANTITRUST

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SECTION 6 FOREIGN CORRUPT PRACTICES ACT

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SECTION 7 GIFTS AND ENTERTAINMENT

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SEKO TIMELINE

Technology Award winner in the Irish Logistics & Transport Awards 2017

SEKO expands operations in Syracuse and Pittsburgh

SEKO named a Multichannel Merchant Top 3PL for 2017

SEKO named Top 10 Leading Vendor in Internet Retailer Magazine's Top 1,000 report

SEKO launches new SaaS division - Gelnius

James Gagne becomes new President

40th Anniversary!

SEKO named a Multichannel Merchant Top 3PL for 2016

SEKO launches new Aerospace and Aviation industry vertical

SEKO recognized as highest ranking Freight Forwarder for customer service in the Logistics Management Quest for Quality Awards

First UK 'Center of Excellence' for Aerospace and Aviation opens in Farnborough

SEKO recognized by Inbound Logistics magazine as a Top 10 3PL

SEKO Profiled as a Top Supply Chain & Logistics Provider in Transport Intelligence Report

SEKO approved as a SmartWay Transportation Partner by the US Environmental Protection Agency

Sponsors Drapers Awards 2016

Omni-channel division wins PwC ‘Start Up Disruptor’ Award

SEKO named Top 10 Logistics Service Provider in Inbound Logistics' Top 100 3PL Providers list SEKO recognized as highest ranking Freight Forwarder for customer service in the Logistics Management Quest for Quality Awards

SEKO named a Multichannel Merchant Top 3PL for 2015

SEKO Cape Town opens

Chino, CA Omni-Channel Logistics hub opens

SEKO selects Greenbriar Equity Group as equity partner

SEKO partners with Caliber to create SEKO Store Development Services

SEKO expands into new 100,000 square ft. facility in San Francisco

SEKO named Top 10 Leading Vendor in Internet Retailer Magazine's Top 1,000 report

SEKO European and US MedTec operations awarded ISO13485 certification

SEKO Milton Keynes distribution center opens > Dallas, Laredo and new Houston location opens

SEKO MedTec opens European Control Center in Ireland

SEKO achieves full Authorized Economic Operator (AEO) certification in Ireland

SEKO invests in eCommerce agency Red Hot Penny

SEKO recognized by Inbound Logistics magazine as a Top 10 3PL > SEKO named a Multichannel Merchant Top 3PL for 2014

SEKO Store Development Services is launched

SEKO joins Advisory Board of the International Omni Retailing Members Association (IORMA)

SEKO sponsors first Home Delivery World conference

SEKO Boise, Gothenberg, Southampton, Manchester, Kansas City and San Antonio open

MySEKO Harmony is launched

SEKO listed in the Sunday Times HSBC Fast Track International 200

SEKO named as an Inc. Magazine Top 5000 Privately Held Company

SEKO Ride25 charity cycle ride initiative is launched

SEKO Denmark obtains Authorized Economic Operator (AEO) status

Recognized as Top 100 3PL by Inbound Logistics magazine

SEKO Synergy rebrands as SEKO Logistics to align with company name

SEKO Norway opens

Global Logistics Carrier Excellence Award received from Owens Corning

SEKO Las Vegas opens

2010 MedTec launched > Salt Lake City, Minneapolis, Rochester, Nashville, Cincinnati and New York open

2003 First SEKO office outside the US opens in the UK with London, making SEKO truly Global > SEKO UK wins BIFA Gold Award > Seattle, Chicago, Miami, Baltimore and Detroit open 2002 William J. Wascher, Tom Cagney and Steven Goldberg purchase SEKO on October 31st > SEKO brand reintroduced > Pittsburgh opens 2004 SEKO UK wins BIFA Gold Award > Portland, Los Angeles and Jacksonville open > MySEKO V1 is launched

2009 SEKO Norfolk opens > MySEKO V3 is launched

2007 SEKO deploys first SaaS TMS solution > Spokane opens

2006 30th Anniversary! > Two offices open in South Africa > MySEKO V2 is launched 2005 SEKO UK wins BIFA Gold Award > San Francisco and Milwaukee open > SEKO RED is launched

2001 SEKO Cleveland opens

1990 Albany, Philadelphia and Providence open

1999 Offices in Indianapolis and Syracuse open

1998 USF SEKO Worldwide becomes USF Worldwide and the SEKO brand as we know it ceases to exist

1988 William J. Wascher, Bob Imhoff, Peter Baker and Joe Blais acquire SEKO Air Freight, Inc. from Norman S. Koppel

1997 SEKO Worldwide becomes USF SEKO Worldwide as part of USF acquisition

1986 10th Anniversary!

1985 SEKO’s first Order Management solution > Buffalo and Louisville open

1996 20th Anniversary! > SEKO Air Freight becomes SEKO Worldwide > Ocean Freight Forwarding launched 1995 Raleigh/Durham opens > Dedicated ground transport division launched 1994 SEKO enters the B2C delivery market with first home delivery customer in the United States

1983 William J. Wascher joins the business

1981 SEKO Atlanta opens

1980 SEKO Charlotte and Phoenix open

1992 Hartford, Memphis, Newark, Orlando and Tampa open

1976 SEKO Air Freight, Inc. is founded in Chicago by Norman S. Koppel from a department of SEKO Messenger, Inc. and the SEKO we know today begins to take shape.

1991 San Diego opens

THE SEKO ORIGIN: The name SEKO is a derivative of Siegel and Koppel. In the 1950s, business partners Norman S. Koppel and Bernard (Bernie) Siegel started SEKO Rocket Enterprises, Inc., which shuttled cars between dealers in new car trading that is common in the auto sales space. They then formed SEKO Messenger, Inc. and bought numerous messenger companies in the Chicagoland area.

SECTION 1 SEKO’S CORE VALUES

SEKO is committed to creating a positive and fulfilling work environment and recognizes our employees’ need for a healthy work-life balance. To this end, all employees are expected to abide by SEKO’s Core Values of: Respect, Customer Focus, Integrity, Teamwork, and Work Hard/Play Hard. SECTION 2 EQUAL EMPLOYMENT OPPORTUNITY SEKO is an equal opportunity employer and its policy is to promote equal employment opportunity. This means SEKO will not discriminate against any employee or applicant for employment because of race, color, creed, religion, national origin, sex, age, marital status, sexual orientation, sexual preference, mental or physical disability, or any other status protected by law. Equal employment opportunity will be extended to all persons, in all aspects of the employer-employee relationship, including recruitment, hiring, upgrading, training, promotion, transfer, discipline, reductions in force and termination. SECTION 3 HARASSMENT

SEKO believes that our employees should be able to work in an atmosphere free from all forms of discrimination and harassment. Therefore, it is our policy to prohibit all types of discrimination and harassment, including, but not limited to, discrimination or harassment based on: race, color, creed, religion, national origin, sex, age, marital status, sexual orientation, sexual preference, disability, handicap or any other category protected by law. This policy extends to each and every level of our operations. Accordingly, discrimination or harassment - whether by a fellow employee, a contractor, a visitor, a guest or a member of management - will not be tolerated. Activities of this nature are unlawful and serve no legitimate purpose - they have a disruptive effect on your ability to perform your job and they undermine the integrity of the employment relationship. Harassment is verbal or physical conduct relating to an individual’s race, color, creed, religion, national origin, sex, age, marital status, sexual orientation, sexual preference or disability when this conduct: (i) has the purpose or effect of creating an intimidating, hostile or offensive working environment; (ii) has the purpose or effect of unreasonably interfering with an individual’s work performance; or (iii) otherwise adversely

affects an individual’s employment opportunities. Some examples of conduct that may constitute prohibited harassment include: slurs, jokes, cartoons, stereotypes, statements, etc. based upon categories protected by law. Specifically, acts considered to constitute sexual harassment include, but are not limited to, unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when: (i) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment; (ii) an individual’s submission to or rejection of such conduct is used as a basis for an employment decision affecting that individual; or (iii) the purpose or the effect of such conduct is to substantially interfere with the affected individual’s work performance or to create an intimidating, hostile or offensive work environment. Some examples of unwelcome behavior that can be construed as sexual harassment include, but are not limited to: sexual advances, propositions, sexually suggestive gestures, sexual jokes, touching, physical assault, sexually explicit or suggestive objects or pictures, references to a person’s body parts and/or sexually explicit conversation. We take allegations of discrimination and harassment very seriously.

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If you believe that you are the target of discrimination or harassment, you should do the following:

(i) If possible, document or otherwise record each incident of alleged discrimination or harassment, including the date, time, place, what was said or done, and the surrounding circumstances.

(ii) Clearly and directly communicate to the offending individual that his/her conduct is unwelcome, and request that the offensive behavior stop.

(iii) At the same time, you should immediately bring the matter to the attention of your manager. If your manager is somehow involved in the discrimination/harassment, or if you are uncomfortable talking to him or her, you should report this matter to your manager’s manager, the Human Resources Department, any Vice President, any Chief Executive, or the President. If you believe that you have been deprived of any job benefit or that you have been threatened, you should immediately report it to one of the individuals listed above. We will protect the confidentiality of discrimination/harassment allegations to the extent possible and appropriate under the circumstances. We will actively investigate all discrimination/harassment complaints, and if it is determined that discrimination or harassment has occurred, management will take appropriate disciplinary action against the offending party, up to and including termination.

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SECTION 4 NO RETALIATION Individuals will not be retaliated against for

SECTION 5 C-TPAT

SEKO is committed to fulfilling its responsibilities as a participant in the Customs-Trade Partnership Against Terrorism (“C-TPAT”) program operated by the U.S. Bureau of Customs and Border Protection (“CBP”). C-TPAT is a voluntary program open to certain members of the international trade community, through which SEKO agrees to undertake specific responsibilities related to supply chain security. In exchange for voluntarily taking on these responsibilities, SEKO and SEKO’s customers receive certain benefits relating to their roles in the import process. Each employee has a general responsibility to support SEKO’s participation in this status. For additional information regarding the C-TPAT program, please contact SEKO’s Compliance Department.

reporting harassment in good faith, or those who have otherwise participated in an investigation of discrimination or harassment. No one will be subject to - and SEKO expressly prohibits - any form of discipline, reprisal, intimidation or retaliation for good faith reporting of incidents of harassment of any kind, pursuing any harassment claim or cooperating in related investigations.

WORKING TOGETHER AS A TEAM IN EVERYTHING WE DO EACH DAY

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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, [email protected] . 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, [email protected] . The General Counsel is Char Dalton, 1100 Arlington Heights Road, Itasca, Illinois USA 60143, [email protected] . 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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EVERYTHING WE DO IS FOCUSED ON MAKING OUR CUSTOMERS’ LIVES EASIER

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SECTION 7 GIFTS AND ENTERTAINMENT

any gift must be minimal in value and bear the company logo (i.e. article of SEKO clothing, pin, marketing materials, etc.). In addition, special care must be taken in entertaining Government Officials since, like receiving gifts, entertaining has the potential to be seen as a bribe. (vi) Research local laws prior to giving or receiving any gift to ensure you are in full compliance and will not violate any local law. If you violate such law(s) you may be held liable in contempt of the law as well as fines associated with such. There is also the possibility you may lose the business/ service of such client/customer. (vii) Use common sense and good judgment in determining the value of any gifts/entertainment you are giving or receiving while conducting company business. (viii) Any entertainment should not be extravagant Entertainment should not be at a venue that would be embarrassing to SEKO if disclosed publically. SEKO Representatives are obligated to keep books, records, and accounts that accurately and fairly reflect all transactions and disposition of SEKO assets, gifts, and entertainment expenses. In the event that you have questions regarding this policy and/or whether a Gift or Entertainment offer might be appropriate, you should escalate your concern to your direct manager or supervisor. In addition, you may always contact any of the following individuals for direct guidance and/or to report violations of this policy: Senior Director of Compliance is Sandra Scott, [email protected] ; Chief Compliance Officer is James Gagne, [email protected] ; General Counsel, Vice President is Char Dalton, [email protected] . SEKOwill protect the confidentiality of your questions and subject matter to the extent possible and appropriate under the circumstances. If you feel uncomfortable reporting a violation under your name, youmay make the report anonymously via SEKO’s Confidential Reporting Hotline (see SEKO Anonymous Hotline Policy at www. sekologistics.com ). SEKOwill actively investigate all inquiries under this policy, and if it is determined that a violation has occurred, SEKOwill 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. SEKOwill not take or permit retaliation against any person who has complained in good faith about a potential violation of this policy, or who otherwise participated in an investigation of such inquiries. or lavish and should be done in good taste and occur at an appropriate business venue.

SEKO recognizes that business gifts and entertainment on a modest scale are commonly used to build goodwill and strengthen working relationships among business associates. Providing or accepting occasional company mementos, meals, tickets to sporting and other events may be appropriate in certain circumstances. However, if offers of gifts, entertainment, etc. are frequent or of substantial value, they may create the appearance of, or an actual, conflict of interest or illicit payment. SEKO has developed this policy to help employees make the right decisions when providing or accepting gifts or entertainment, while conducting business on behalf of SEKO. This policy applies to all divisions of SEKO and SEKO Representatives worldwide. The following are important rules and guidelines to follow regarding gifts, meals, and entertainment: (i) Never give or receive anything of value to influence a decision or to obtain special or preferential treatment. Gifts that are bribes, payoffs or kickbacks (i.e. gifts given in order (ii) Cash or cash equivalents (such as gift cards, gift certificates, checks) are never acceptable business gifts. If at any given time a gift card/ or cash is accepted, it could be considered as a bribe and could at the very least lend itself to the appearance that the employee’s business judgment may be affected. (iii) Frequent gifts (such as meals, promotional items) to the same individual may be inappropriate. (iv) Be cognizant and aware of the customer’s Code of Conduct and potential policies on gifts to obtain or retain business, or to secure an improper advantage) are never appropriate. as some organizations prohibit the receipt of gifts altogether. Many Codes of Conduct and corporate policies that deal with gift and hospitality acceptance contain a general prohibition against accepting any benefit that could lead to an actual or perceived conflict of interest. Violating our customer’s Codes of Conduct could jeopardize and harm business relationships. (v) Be aware that special rules apply in the federal contractor and public sector work. Government or Public Sector servants are not to accept any gifts, hospitality or other benefits that may have a real, apparent or potential influence on their objectivity in carrying out their official duties, or that may place them under obligation to the donor. A general rule of thumb in dealing with Government or Public Sector servants are that

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SECTION 8 WORKPLACE VIOLENCE It is the policy of SEKO to promote a safe environment for its employees. SEKO is committed to working with its employees to maintain a work environment free from violence, threats of violence, harassment, intimidation, and other disruptive behavior. While this kind of conduct is not generally associated with companies like ours, no company is immune. Violence, threats, harassment, intimidation and other disruptive behavior in our workplace will not be tolerated; that is, all reports of incidents will be taken seriously and dealt with appropriately. Such behavior can include oral or written statements, gestures, or expressions that communicate a direct or indirect threat of physical harm. Individuals who commit such acts may be removed from the premises and may be subject to disciplinary action, criminal penalties, or both. SECTION 9 ANONYMOUS HOTLINE SEKO conducts its business ethically and in compliance with all laws in the countries where SEKO does business - including all state, federal and international laws. In short, we are committed to always doing the right thing. For that reason, we have adopted a Code of Conduct and Ethics Policy as well as introduced an Anonymous Hotline specifically designed to be part of an effective program to prevent and detect - as well as report possible violations of law and conduct. SEKO encourages its employees, agents, and worldwide partners to raise concerns that will help us with our commitment to ethical, moral and legal business conduct. This policy aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith. However, if an employee feels that their anonymity is not required then they should follow our existing grievance procedure.

We need your cooperation to implement this policy effectively and maintain a safe working environment. Do not ignore violent, threatening, harassing, intimidating, or other disruptive behavior. If you observe or experience such behavior by anyone on company premises - whether he or she is a company employee or not - report it immediately to your Human Resources Department, management, or the local authorities. The incident will be investigated and appropriate action taken. If you or someone else in the office is feeling unsafe or threatened by another employee, remove yourself from the situation if possible, call law enforcement immediately, and report the incident.

The Anonymous Reporting Hotline is intended to cover serious concerns and/or sensitive issues that could have a large impact on SEKO, such as actions that: • May lead to incorrect financial reporting; • Are unlawful; • Are not in line with company policy, including the Code of Conduct and Ethics Policy; or • Otherwise amount to serious improper conduct.

Reporting a Complaint Toll-Free Telephone:

• English speaking USA and Canada: (844) 510-0059 • Spanish speaking North America: (800) 216-1288 • French speaking Canada: (855) 725-0002 • Spanish speaking Mexico: 01-800-681-5340

• All other countries: 800-603-2869 (must dial country access code first)

Website Reporting: www.lighthouse-services.com/sekologistics

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Reports can be filed in a number of languages which can be selected from the website, or the direct url can be found below:

Language Abbreviation Language Name

Direct URL

ara ben csm ctr cze dan dut eng geo ger gre heb hin hun jpn kor lav nor pol por may rum ind ita fil fin fre

Arabic Bengali

www.lighthousegoto.com/sekologistics/ara www.lighthousegoto.com/sekologistics/ben www.lighthousegoto.com/sekologistics/csm www.lighthousegoto.com/sekologistics/ctr www.lighthousegoto.com/sekologistics/cze www.lighthousegoto.com/sekologistics/dan www.lighthousegoto.com/sekologistics/dut www.lighthousegoto.com/sekologistics/eng www.lighthousegoto.com/sekologistics/fil www.lighthousegoto.com/sekologistics/fin www.lighthousegoto.com/sekologistics/fre www.lighthousegoto.com/sekologistics/geo www.lighthousegoto.com/sekologistics/ger www.lighthousegoto.com/sekologistics/gre www.lighthousegoto.com/sekologistics/heb www.lighthousegoto.com/sekologistics/hin www.lighthousegoto.com/sekologistics/hun www.lighthousegoto.com/sekologistics/ind www.lighthousegoto.com/sekologistics/ita www.lighthousegoto.com/sekologistics/jpn www.lighthousegoto.com/sekologistics/kor www.lighthousegoto.com/sekologistics/lav www.lighthousegoto.com/sekologistics/may www.lighthousegoto.com/sekologistics/nor www.lighthousegoto.com/sekologistics/pol www.lighthousegoto.com/sekologistics/por www.lighthousegoto.com/sekologistics/rum www.lighthousegoto.com/sekologistics/rus www.lighthousegoto.com/sekologistics/slo www.lighthousegoto.com/sekologistics/som www.lighthousegoto.com/sekologistics/spa www.lighthousegoto.com/sekologistics/swe www.lighthousegoto.com/sekologistics/tha www.lighthousegoto.com/sekologistics/tur www.lighthousegoto.com/sekologistics/ukr www.lighthousegoto.com/sekologistics/vie

Chinese (Simplified) Chinese (Traditional)

Czech Danish Dutch English Filipino Finnish French

Georgian German

Greek

Hebrew

Hindi

Hungarian Indonesian

Italian

Japanese

Korean Latvian

Malay

Norwegian

Polish

Portuguese Romanian

rus slo

Russian Slovak Somali Spanish Swedish

som spa swe

tha tur ukr

Thai

Turkish

Ukrainian

vie

Vietnamese

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E-Mail: [email protected] (must include company name with report) Fax: Fax alternative for written documents: 215-689-3885 (must include company name with report) Safeguards Confidentiality Reporters to the hotline will have the ability to remain anonymous if they choose. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting and your anonymity will be protected to the extent possible by law. However, your identity may become known during the course of the investigation because of the information you have provided. Reports are submitted by Lighthouse, the Anonymous Hotline reporting service, to SEKO or its designee, and all reports will be investigated at the sole discretion of our company. Timing Keep in mind that the earlier a concern is expressed, the easier it is for us to take action. Evidence Although you are not expected to prove the truth of an allegation, the employee submitting a report needs to demonstrate in their hotline report that there are sufficient grounds for concern. How Reports will be Handled The action taken will depend on the nature of the concern. A number of SEKO nominated individuals or designees will each receive a copy of the report and follow-up reports on actions taken by the company. Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved by agreed upon action without the need for an investigation. Harassment or victimization of individuals submitting hotline reports will not be tolerated. Malicious allegations may result in disciplinary action.

Feedback to Reporter Whether reported directly to SEKO personnel or through the hotline, the individual submitting a report will be given the opportunity to receive follow- up on their concern: • Acknowledging that the concern was received; • Indicating how the matter will be dealt with; • Giving an estimate of the time that it will take for a final response; • Telling them whether initial inquiries have been made; • Telling them whether further investigations will follow, and if not, why not. Further Information The amount of contact between the individual submitting a report and the body investigating the concern will depend on the nature of the issue, the clarity of information provided, and whether the employee remains accessible for follow-up. Further information may be sought from the reporter. Outcome of an Investigation At the discretion of the company and subject to legal and other constraints the reporter may be entitled to receive information about the outcome of an investigation.

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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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II. STATEMENT OF CORE VALUES SEKO is committed to creating a positive and fulfilling work environment. To this end, all employees are expected to uphold SEKO’s Core Values of Respect, Customer Focus, Integrity, Teamwork, and Work Hard - Play Hard. Acting with integrity, professionalism, and honesty are the driving forces behind SEKO’s success. SEKO has always conducted business in an ethical manner and has treated employees, customers, vendors, communities and all other stakeholders fairly. From the very beginning, SEKO has been committed to conducting its business ethically and by “doing right” by our employees, customers, vendors, suppliers, stockholders, committees and all other stakeholders. SEKO shares the responsibility for protecting and advancing SEKO’s reputation. Simply put, our ethics and values are the driving force behind our business strategies and activities. As a global organization with headquarters in the United States, SEKO must comply with the applicable laws and regulations of every jurisdiction - both in the United States, as well as in all other countries where SEKO operates. All employees and all other parties affiliated with SEKO, are charged with the responsibility of acquiring sufficient knowledge of laws and regulations relating to his/her duties in order to recognize potential non-compliance issues or violations of the Code of Conduct, and to know when to seek advice from SEKO Corporate Ethics or Legal Counsel. All managers of SEKO employees are responsible for ensuring that their employees are in compliance with the local laws and regulations that apply to their area of responsibility. IV. PRINCIPLES OF CONDUCT: a. Confidentiality and Privacy Confidentiality is one of the cornerstones of our organization and is how we measure our ethics. SEKO has confidential information that must not be revealed to outside parties. Our client lists, knowledge, techniques, written materials and other information relative to business plans and strategies, financial information, suppliers, and employee or personnel information are examples of confidential information that cannot be disclosed to an unauthorized person. This obligation not to disclose confidential information extends beyond your term of employment with SEKO. Upon termination of employment or upon the request of SEKO, employees shall return to SEKO all confidential information and other property of III. COMPLIANCE WITH LAWS, RULES, AND REGULATIONS

SEKO or its clients (and any copies thereof) in the employee’s possession. Should you leave SEKO for any reason, your obligation not to disclose such confidential information continues. b. Conflicts of Interest A conflict of interest exists when a person’s private interest interferes in any way with the interest of the Company. Employees and all other parties who are working on SEKO’s behalf are prohibited frommaking decisions in the course of employment or in their representation of SEKO that would allow them to give preference or favor to a customer in exchange for anything of personal benefit to themselves or their friends and families. Making these types of decisions could interfere with an employee’s ability to make judgments solely in SEKO’s best interest. Furthermore, employees, officers, and directors are prohibited from taking corporate opportunities and misappropriating those opportunities for themselves or for another third party without SEKO’s consent. Moreover, no employee or party affiliated with SEKO may use corporate property or information for personal gain and no employee may compete with SEKO directly or indirectly during their employment with the Company. Employees and all affiliates owe a duty to SEKO to advance SEKO’s interest when the opportunity to do so arises. c. Bribes, Gifts, Entertainment, etc. Employees and all other parties affiliated with SEKO are expressly prohibited from offering or soliciting, directly or indirectly, any special treatment or favor in return for anything of economic value or the promise or expectation of future value or gain. This prohibition also prevents employees and all other parties from giving economic and non-economic benefits to the employees, or customers of suppliers and all other parties from whom SEKO solicits business.

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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: [email protected] 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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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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III. DEFINITIONS Human Trafficking: The recruitment, transportation, transfer, harboring or receipt of persons by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation. Forced Labor: All work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty. Harmful Child Labor: Consists of the employment of children that is economically exploitative, or is likely to be hazardous to or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development. IV. RATIONALE SEKO will not tolerate or condone the use of unlawful child labor or forced labor in the supply of goods and services it sells, and will not accept goods or services from suppliers that utilize child labor in any manner in any part of our organization. Human trafficking and slavery are intolerable crimes. These crimes exist in countries throughout the world. This statement shall define SEKO’s efforts and commitment to eradicate human trafficking and slavery from not only our organization but also from our own supply chains.

V. REQUIREMENTS SEKO’s suppliers are an important part of our success and our culture. We expect each of these business partners to conduct their business with the same commitment to ethical business practices as SEKO. SEKO and its suppliers: • Will not use forced or compulsory labor, i.e. any work or service that a worker performs involuntarily, under threat of penalty. • Will ensure that the overall terms of employment are voluntary. • Will not hold passports of migrant workers. • Will not pay fees to agents other than reputable temporary worker agencies where there is an opportunity for workers to engage in temporary to permanent employment. • Will comply with the minimum age requirements prescribed by applicable laws unless a specific contract contains stricter age requirements. • Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay agreements. • Will abide by applicable law concerning the maximum hours of labor – such as the provisions of Working time Directive(s) or other applicable laws. • Will keep records of, and be entirely transparent in complying with the above. VI. CONSEQUENCES Suppliers of SEKO who engage in human trafficking and slavery will have their supply agreements terminated. Suppliers must be able to demonstrate compliance with this policy at the request and satisfactions of SEKO. If a supplier to SEKO is found to be in violation of this policy statement, SEKO will take prompt, remedial measures to address the violation including but not limited to termination of the business relationship and involvement of legal authority(s).

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SECTION 12 ANTITRUST

SEKO absolutely prohibits any consultation with competitors relating to prices or terms and conditions of sale. For purposes of clarity, some examples of conduct that may be construed as unlawful and contrary to Antitrust laws include, but are not limited to:

SEKO conducts its business ethically and in compliance with all laws in the countries where SEKO does business - including all state, federal and international antitrust laws such as the U.S. Sherman Act, U.S. Clayton Act, U.S. Federal Trade Commission, as amended, and EU Antitrust Laws. SEKO Representatives MAY NOT directly or indirectly communicate with the “competition” and display any form of unlawful restraints, price-fixing, price discrimination, exclusive dealing arrangements, conspiracy, monopolies, prices, profit margins, and/or discounts in any engagements. Compliance with the law requires obedience both to the letter and spirit of the law. A basic tenet of SEKO policy is that no employee shall enter into any understanding, agreement, plan or scheme, whether express or implied, formal or informal, oral or written, with any competitor with respect to prices, terms or conditions of sale, output, production, distribution, territories or customers.

(a) price-fixing with the competition;

(b) rigging bids with the competition;

(c) conspiring with the competition;

(d) destruction of documents in an effort to achieve or hide any of the foregoing motives; and

(e) price discrimination.

ANY INFRACTION OF SEKO’S ANTITRUST POLICY OR THE ANTITRUST LAWS WILL SUBJECT ANY EMPLOYEE TO LEGAL PENALTIES AS WELL AS CORPORATE DISCIPLINE, UP TO AND INCLUDING DISMISSAL FROM EMPLOYMENT.

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Complaints/Reporting 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: Send email to [email protected] . Subject line: Antitrust Alert, body of email include the senders signature. You will be contacted immediately by our Legal/Compliance department. No Retaliation for Reporting SEKO will protect the confidentiality of the allegations to the extent possible and appropriate under the circumstances. If you feel uncomfortable making a complaint/reporting 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 Antitrust Laws violations, or who otherwise participated in an investigation of such complaints. Any SEKO Representative who receives a complaint/reporting from a member of the public should advise the person to report his or her complaint directly to email [email protected] SEKO will not pay any fines, penalties or legal expenses assessed against a SEKO Representative who is found guilty of violating any Antitrust Laws and who acted contrary to this policy. It should be noted that this brief statement is not intended to be a complete statement of all aspects of the Antitrust Laws or SEKO policy. If you should have any questions respecting Antitrust Policy, please contact the office of the General Counsel.

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