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SECTION 7 any gift must be minimal in value and bear the
company logo (i.e. article of SEKO clothing, pin,
GIFTS AND marketing materials, etc.). In addition, special
care must be taken in entertaining Government
ENTERTAINMENT Officials since, like receiving gifts, entertaining

has the potential to be seen as a bribe.
SEKO recognizes that business gifts and entertainment (vi) Research local laws prior to giving or receiving
on a modest scale are commonly used to build goodwill any gift to ensure you are in full compliance and
and strengthen working relationships among business will not violate any local law. If you violate such
associates. Providing or accepting occasional company law(s) you may be held liable in contempt of the
mementos, meals, tickets to sporting and other events law as well as fines associated with such. There
may be appropriate in certain circumstances. However, is also the possibility you may lose the business/
if offers of gifts, entertainment, etc. are frequent or service of such client/customer.
of substantial value, they may create the appearance (vii) Use common sense and good judgment in
of, or an actual, conflict of interest or illicit payment. determining the value of any gifts/entertainment
SEKO has developed this policy to help employees make you are giving or receiving while conducting
the right decisions when providing or accepting gifts or company business.
entertainment, while conducting business on behalf of
SEKO. This policy applies to all divisions of SEKO and (viii) Any entertainment should not be extravagant
SEKO Representatives worldwide. or lavish and should be done in good taste
and occur at an appropriate business venue.
The following are important rules and guidelines to Entertainment should not be at a venue that would
follow regarding gifts, meals, and entertainment: be embarrassing to SEKO if disclosed publically.
(i) Never give or receive anything of value to SEKO Representatives are obligated to keep books,
influence a decision or to obtain special or records, and accounts that accurately and fairly
preferential treatment. Gifts that are bribes, reflect all transactions and disposition of SEKO
payoffs or kickbacks (i.e. gifts given in order assets, gifts, and entertainment expenses.
to obtain or retain business, or to secure an
improper advantage) are never appropriate. In the event that you have questions regarding this
policy and/or whether a Gift or Entertainment offer
(ii) Cash or cash equivalents (such as gift cards,
gift certificates, checks) are never acceptable might be appropriate, you should escalate your
business gifts. If at any given time a gift card/ concern to your direct manager or supervisor. In
or cash is accepted, it could be considered as addition, you may always contact any of the following
a bribe and could at the very least lend itself to individuals for direct guidance and/or to report
the appearance that the employee’s business violations of this policy:
judgment may be affected. Senior Director of Compliance is Sandra Scott,

(iii) Frequent gifts (such as meals, promotional items) sandra.scott@sekologistics.com;
to the same individual may be inappropriate. Chief Compliance Officer is James Gagne,
james.gagne@sekologistics.com;
(iv) Be cognizant and aware of the customer’s General Counsel, Vice President is Char Dalton,
Code of Conduct and potential policies on gifts char.dalton@sekologistics.com.
as some organizations prohibit the receipt of
gifts altogether. Many Codes of Conduct and SEKO will protect the confidentiality of your questions
corporate policies that deal with gift and hospitality and subject matter to the extent possible and appropriate
acceptance contain a general prohibition against under the circumstances. If you feel uncomfortable
accepting any benefit that could lead to an actual reporting a violation under your name, you may make the
or perceived conflict of interest. Violating our report anonymously via SEKO’s Confidential Reporting
customer’s Codes of Conduct could jeopardize Hotline (see SEKO Anonymous Hotline Policy at
and harm business relationships. www. sekologistics.com). SEKO will actively investigate
all inquiries under this policy, and if it is determined that
(v) Be aware that special rules apply in the federal
contractor and public sector work. Government a violation has occurred, SEKO will take appropriate
or Public Sector servants are not to accept any disciplinary action against the offending party - up to and
gifts, hospitality or other benefits that may have including discharge of the employee or termination of the
a real, apparent or potential influence on their agreement with such SEKO Representative. SEKO will
objectivity in carrying out their official duties, not take or permit retaliation against any person who has
or that may place them under obligation to the complained in good faith about a potential violation of this
donor. A general rule of thumb in dealing with policy, or who otherwise participated in an investigation of
Government or Public Sector servants are that such inquiries.

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