I. What is expected of everyone ?

All employees of Good Logistics are subjected to this Code of Conduct and all of us are required to understand and follow this Code and the laws in our daily activities. We have to use our good judgment and take into consideration our actions. At times we might face difficult situations in which the right choice is not clear. In these situations ask yourself :

• Is it consistent with the Code ?
• Is it ethical ?
• Is it lawful ?
• what image will it give to me and Good Logistics ?
• what if I have to read about it on the newspaper ?
• would my family and friends approve of it ?

The answers should be yes to all questions. If the answer is “no” to any of these questions, don’t do it. If you are still uncertain, ask for guidance. You can seek advice to from your manager or Human Resources. If you do not feel comfortable speaking to either, you can speak to the Corporate Ethics and Compliance Department.

As an alternative you can address your communications to Good Logistics. All contact information can be found on the internet.

II. What is expected of managers ?

The Managers of Good Logistics are expected to serve as role models and promote the image of Good Logistics within their area of responsibility. This includes making sure that the employees that are supervised understand their responsibilities under the Code of Conduct, in spirit and in letter. Managers must create a positive work environment in which employees are encouraged and feel comfortable to speak up and ask for help. When managers receive reports of a situation that is unethical or potentially damaging Good Logistics reputation they must immediately notify the Corporate Ethics and Compliance Department.

III. Reporting of breaches

In case of any reason you believe that any employee or anyone working on behalf of Good Logistics has engaged in ethical or legal misconduct, you are required to report the incident promptly. You can talk to your manager, Human Resources or the Corporate Ethics and Compliance Department. Alternatively feel free to report your concern to the Ethics and Compliance Hotline. The Ethics and Compliance Hotline is a secure way to submit confidential reports, anywhere in the world, 24 hours a day, 7 days a week, either online or by phone. You can access the respective phone number and the web reporting tool via our internet.

IV. Non retaliation and confidentiality

Good Logistics highly values the help of employees who identify potential problems that need to be address. Good Logistics will undertake all possible steps to ensure that reports are kept confidential, including the identity of the reporter. Good Logistics does not tolerate retaliation of any kind against employees who, in good faith, report breaches or violations of Good Logistics Code of Conduct or any other illegal conduct. Good Logistics takes claims of retaliation seriously. Allegations of retaliation are investigated and appropriate action is taken.

I. Valuing diversity

The employees of Good Logistics range is a tremendous asset and every single employee is a key contributor to our success. We are firmly committed to providing equal opportunity in all aspects of employment and welcome differences regarding race, gender, language, education etc. Diversity is the basis for creativity and innovation.

II. Harassment and discrimination

Good Logistics promotes a harassment free environment. We do not tolerate any conduct which inappropriately or unreasonably interferes with work performance, diminishes the dignity of any person or creates an intimidating, hostile or otherwise offensive work environment. This includes discrimination or harassment based on race, colour, religion, gender, age, national origin, sexual orientation, marital status or disability.

III. Fair employment practises

Good Logistics strongly follows all applicable laws and regulations governing fair employment practices, for example those related to compensation and benefits, child labor, forced labor and freedom of association, in all the countries we operate in. As a principle, we must not tolerate any form of unacceptable treatment of workers in any of Good Logistics operations.

IV. Health and safety

Good Logistics values all its employees as its most important asset and is committed to provide all employees with a safe and healthy working environment. Every employee has the responsibility to meet this commitment by following all health and safety procedures and by maintaining a safe and healthy workplace. All of us are expected to conduct business free from the influence of any substance that could impair our work. All workplace accidents, unsafe equipment, unsafe practices and conditions in the workplace must be reported to your HSE or HR manager. This includes alcohol, illegal drugs, controlled substances, and in some cases prescribed medication.

V. Punctuality

Punctuality is the characteristics of being able to complete a require task or fulfill an obligation before the designated time. At Good Logistics we are committed to punctuality to both the customer and the employer.

I. Outside employment

It is acceptable for Good Logistics that its employees take on outside positions as long as those positions do not interfere with the employee’s responsibilities at Good Logistics. Outside work must not involve a Good Logistics competitor nor should it involve the use of Good Logistics equipment or proprietary information such as computers, software, customer information and others. All outside employment must be disclosed to your manager.

II. Family and personal relationships

Except for limited circumstances; we should not hire, supervise or have influence over a family member or a close personal relation within Good Logistics unless prior approval is provided by the management. Good Logistics’ success depends on its partners and subcontractors. For this reason it is crucial that the selection of its partners is based on objective criteria including integrity, quality and performance and not personal interests. Consequently if a family member or a close personal relation works for a third party that does business with Good Logistics (a subcontractor for example) we must disclose this information to the management.

I. Anti corruption & Anti-bribery

Bribery destroy not only our company but also the communities where operate. Governments are taking steps to eradicate bribery and many countries in which we operate have specific laws against it. This is why Good Logistics has adopted a zero tolerance policy for bribery regardless of where we are located. This means that any Good logistics employee must not give or promise any undue advantage to a person in a position of trust whether in government or in private business. There are no exceptions for small amounts or the so-called “facilitation-” or “grease-” payments. Moreover Good Logistics employees must not accept or solicit any undue advantages.

II. Indirect-bribery

Good Logistics employees do not use third parties for paying bribes or the execution of so-called “facilitation-“or “grease-“ payments. For this reason we must make sure our partners are aware and are committed to Good Logistics anti-corruption policies and relevant due-diligence procedures for selecting third parties are strictly followed.

III. Gift and entertainment

Gifts and entertainment are common business courtesies and are socially acceptable in many cultures; in fact in many instances it is an important way of creating goodwill and establishing trust in business relationships. We have to ensure that our business gifts and entertainment practices are reasonable and consistent with both Good Logistics policies and relevant local laws and regulations. We must always make sure that business courtesies are never given or received to obtain or give an undue advantage.

IV. Charitable donations and sponsorships

Good Logistics supports certain charitable donations as a way of giving back to the community and contributing to worthy causes. Additionally, Good Logistics also supports certain corporate sponsorships in order to promote Good Logistics presence in the business world. Unfortunately, even legitimate donations and sponsorships sometimes have the risk of creating the appearance of bribery and corruption. Therefore, you must obtain prior approval in accordance with established procedures before making donations or sponsorships on behalf of Good Logistics.

V. Political contributions

Good Logistics does not make any kind of political contributions anywhere in the world, whether in cash or in kind (e.g. donations of property or services, or the purchase of tickets to fundraising events). However, Good Logistics recognizes employees’ right to participate as individuals in the political process, if they thoroughly make clear that they do not represent Good Logistics in the process.

VI. Competition and anti-trust

Good Logistics strictly cling to what we called ‘competition’ laws in some countries and ‘anti-trust’ laws in others. These laws promote or protect free and fair competition around the world and prohibit all anti-competitive behavior, such as price-fixing conspiracies. No Good Logistics employee is permitted to engage in price-fixing, bid rigging, allocation of market or customers, or similar illegal anti-competitive activities. Some competition laws – such as the US and EU anti-trust laws – can apply even when the conduct occurs outside the relevant country’s or countries’ borders.

Good Logistics only uses available expert-, industry- and other publicly available sources to understand business, customer and supplier strategies, technology trends, regulatory proposals and developments, and existing and expected actions of suppliers and competitors. Good Logistics gathers this information fairly and legally and never by doubt.

VII. Trade restrictions

A number of countries, and the United Nations, from time to time impose restrictions on exports and other dealings with certain countries, entities and individuals. Such restrictions prohibit Good Logistics from engaging in certain business activated in specified countries and with particular individuals. Good Logistics will not enter into business relation with companies excluded by governments. Severe penalties, such as fines, revocation of permits to export, and imprisonment, can apply when these restrictions are not followed. Good Logistics respects all national and international export embargo laws and regulations.

VIII. Contract compliance

We comply with all terms and conditions of our contracts and expect our business partners to do the same. We deliver as we promise, and bill in strict compliance with contract terms.

I. Record keeping, financial reporting, financial controls and disclosures

As a company, it is crucial that Good Logistics books, records, accounts and financial statements are complete, accurate, and understandable. They should be maintained in reasonable detail and in compliance with Good Logistics system of internal controls. All financial transactions have to be properly recorded in the appropriate books in a timely manner, as prompt reporting allows early management intervention. Unrecorded or ‘off the books’ funds, assets or transactions are highly prohibited.

II. Additional responsability

Senior financial officers and others responsible for the accuracy of financial reporting have an additional responsibility to ensure that proper controls are in place to achieve truthful, accurate, complete, objective, consistent, timely and understandable financial and management reports.

III. Business expenses

All business expense accounts must be documented and accurately recorded in a timely manner. If you are not sure whether a certain expense is legitimate, ask your line manager beforehand.

IV. Buying and selling stock

While working at Good Logistics, we may become aware of non-public information about the Company or other companies with whom we do business. Nonpublic information (also known as “inside information”) is information about a company that is not known to the general public and that a reasonable investor would consider important when deciding whether to buy, sell or hold that company’s securities. Buying or selling the securities of a company on the basis of inside information (known as “insider trading”) is a criminal offense in many countries and Good Logistics employees are prohibited from trading on the basis of ‘inside’ information in shares or other securities of Good Logistics or any Good Logistics entity. Revealing “inside information” to others, even to members of your family (known as “tipping”) is also prohibited and may result in the criminal prosecution of anyone involved.

V. Anti-money laundering

Money laundering is the process by which individuals or entities try to hide illegal funds or otherwise make these funds look legitimate by moving them through the financial system in order to hide all traces of the criminal origin. It is important that we know and comply with all laws and regulations aimed to halt money laundering. We must be diligent and exercise good judgment when dealing with unusual customer or vendor transactions. Good Logistics will not condone, facilitate or support money laundering.

I. Physical assets and communication system

All employees are required to protect Good Logistics assets and ensure their efficient use. They are to be used for legitimate purposes and Good Logistics business only. All employees must use Good Logistics communication system, such as e-mail and internet, for business related purposes only and must use these resources appropriately and legally. We should not access, download or distribute any material that is illegal, offensive or could reflect negatively on Good Logistics reputation. We should also exercise discretion and diligence when drafting e-mails to ensure that our communications are professional and appropriate.

II. Proprietary information and intellectual property

Proprietary information and intellectual property, such as patents, trademarks, copyrights, trade secrets, non-published and confidential business information (customer databases, software, and marketing strategies) represents Good Logistics assets. Proprietary information includes all non-public information that might be of use to competitors, or harmful to the Company, or its customers or suppliers, if disclosed. Unauthorized use, disclosure or distribution of this information is prohibited and might lead to civil or criminal penalties. Employees must maintain the confidentiality of proprietary information entrusted to them by Good Logistics or its customers and suppliers, except when disclosure is authorized in writing by the Managing Director, or required by law and regulations as confirmed by the Legal Department.

III. Record retention

All Good Logistics employees are required to ensure that business records are retained in accordance with internal policies and local regulations. This includes physical documents such as contracts or files and also electrical data such as email.

IV. Data privacy

Good Logistics respects the privacy of all its employees, business partners and customers. We must handle personal data responsibly and in compliance with Good Logistics internal policies and all applicable privacy laws. Employees who handle the personal data of others must act in accordance with Good Logistics internal policies and with applicable law; collect, use and process such information only for legitimate business purposes, limit access to the information to those who have a legitimate business purpose for seeing the information; and take precautions to prevent unauthorized disclosure.

Preserving the environment is everyone’s responsibility. At Good Logistics, we are committed to ensuring that there are minimal environmental impacts from our daily activities, and will continue to monitor our activities in order to ensure continuous improvement.

Good Logistics is committed to minimizing the environmental impacts in all its activities, and will comply with the laws and regulations for environmental protection in all countries we operate in. This commitment, and compliance with it, is required from all our employees. As Good Logistics is fully committed to upholding the highest possible environmental standards, we will continuously evaluate the environmental aspects of our activities to deliver services with no undue environmental impact.