Code of Conduct

We are aware of our role and responsibility as corporate citizen in society and act accordingly. Cargodian acts fair, legal, considerate, and courteous and contributes to the promotion of fair and sustainable standards, social conditions, and environmental awareness. We aim to continuously improve performance and awareness with all our employees and business partners globally. We at Cargodian lead by example, and we shall always strive to act honourably, professionally and with great professional care.

Scope

This code of conduct applies to all facilities and business units of Cargodian globally. We encourage our business partners to also comply with the principles enshrined in this Code.

Laws and Regulations

Cargodian complies with applicable laws and regulations of the countries in which it operates and requires that its suppliers do likewise.

Forced Labour

No forced labour of any kind, including forced labour in prisons and bonded labour may be used.

Integrity and Anti-Corruption

Cargodian actions are guided by generally accepted ethical values and principles, by integrity, honesty, respect for human dignity, openness, and non-discrimination on the grounds of religion, ideology, gender, or ethnicity. Cargodian rejects any form of corruption or bribery as defined by the relevant UN Convention (adopted in 2005). It promotes transparency, acting with integrity and responsible corporate management and control.

Communication

In all their activities, our employees and associates must proceed in accordance with legislation, Cargodian internal regulations and, first and foremost, this Code of Conduct. We are not tolerating unlawful conduct even where it might be described as an “everyday business practice”. We will not help anyone to engage in unlawful conduct. We at Cargodian reject all unlawful or unethical conduct on the part of our employees, associates, suppliers, customers, and other persons. We shall strive to detect and combat all unlawful activity that might take place in connection with our business operations. We are aware of the consequences of breaking the law and we shall inform our employees of such consequences. Those consequences may be:

Child Labour

No child labour is used. Unless local legislation stipulates a higher age limit, no person who is still of school age or younger than 15 will be employed (subject to the exceptions stipulated in ILO Convention 138). Employees under the age of 18 may not perform any hazardous work and may be exempted from night work in consideration of their educational needs.

Harassment

Employees will not be subjected to any corporal punishment or any other form of physical, sexual, physiological, or verbal harassment or abuse.

Compensation and Benefits

Compensation, including wages, overtime and benefits must be equal to or exceed the levels stipulated by applicable laws and regulations. Compensation for full-time employment must be sufficient to meet the employee’s fundamental needs.

Working Hours

Unless national regulations stipulate a lower maximum number of working hours, and except in exceptional business circumstances, employees will not be required on a regular basis to work a standard working week more than 48 hours per week or total weekly working hours more than 60 hours (including overtime). Employees are to be given the equivalent of at least one day off in every 7-day period.

Non-Discrimination

With respect to all employment decisions, including but not limited to hiring and promotion, compensation, benefits, training, redundancies and terminations, all employees will be treated strictly in accordance with their abilities and qualifications.

Health and Safety at Work

To prevent accidents and injuries, employers will provide a safe and healthy working environment and, if necessary, safe, and healthy residential facilities, which at a minimum comply with applicable statutory requirements.

Freedom of Association and Collective Bargaining

Employers recognize and respect the statutory right of employees to freedom of association and collective bargaining.

Environment

The company implements and continuously improves environmentally friendly practices in all facilities in which it operates. It meets the environmental protection requirements and standards applicable to its respective facilities and uses natural resources responsibly.

Whistleblowing and Protecting the Whistle-blowers

To combat illegal or unethical conduct Cargodian encourages current and former employees third parties to provide timely and active notification of unlawful and unethical conduct, orders to engage in such conduct, and any suspicions thereof. We support open and fast communication at all levels so that any problems can be identified and appropriately addressed in a timely manner. Cargodian provides the following contact channels for the notification of unlawful conduct (or any suspicions thereof) and for the collection of enquiries and improvement proposals related to compliance or this code of conduct: E-mail address: compliance@cargodian.com

 

If the Compliance Officer or members of the governing, management or supervisory bodies are suspected of unlawful conduct, notification may be sent directly to any of the members of the supervisory board of the company affected by the infringement.

We shall ensure the confidentiality of the notifier and the information received. Any notification shall be properly investigated, and an anonymized report shall be drawn up thereon that does not contain details that could identify the notifier. Employees or associates who make a notification in good faith shall not suffer any punishment or discrimination for such notification.

Gifts

We shall not provide, offer, or promise gifts or other favours to public officials, their families and other persons associated with them where this could give the impression that such gifts or other favours are intended to influence decision-making by public officials. Where a gift or other favour is solicited in this context, the employee or associate shall refuse to provide that gift (or favour) and shall report the matter to his or her superior and the compliance officer without undue delay.

Furthermore, we shall not allow ourselves to be promised or offered, and we shall not accept, any gifts or favours if the objective or consequence thereof is support for illegal or unethical conduct.

An exception to the rule on gifts and favours shall be the provision or acceptance of token gifts provided during everyday-business to the extent of EURO 44 per person (this does not mean daily).

Money Laundering

Money laundering denotes conduct intended to conceal the illegal origin of money in a bid to give the impression that it has been obtained legally. More broadly, it also includes the financing of illegal activities with legal resources. Cargodian shall strive to comply with rules combating money laundering in the broadest sense. Under no circumstances shall we participate in activities associated with money laundering. We shall always stand ready to comply with all obligations deriving from national and international money laundering legislation.

Sanctions and Embargos

As global business we shall respect the rules of cross-border business and taxation, including international sanctions. We shall analyse thoroughly every single trade transaction, whenever possible by automated processes in line with defined rule criteria.

Engagement with Public Officials and Nation States

We shall engage with all public officials courteously. Only employees authorized by their position shall negotiate with public authorities. We shall disclose only truthful information about our company in accordance with legislation. We shall cooperate with all oversight and inspection bodies and with other public authorities. We shall keep due and truthful accounts on all transactions. We shall pay tax and make social security and health insurance contributions dutifully and on time, and we shall make all other obligatory payments. As global business we shall also respect the rules of cross-border business and taxation, including international sanctions. We shall analyse thoroughly every single trade transaction.

Non-Corruption

We are categorically opposed to corruption. Cargodian shall not provide, offer, or promise, directly or otherwise, any gifts or favours to any person if the objective or consequence thereof is support for illegal or unethical conduct. This prohibition shall not only apply to our business partners (present or future), but it shall also especially apply in relation to public officials. “Public officials” means officers, politicians, judges, and other employees working for central or local government or for international institutions.

Internal Policies and Procedures related to this Code of Conduct