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SECTION 8

             WORKPLACE VIOLENCE




             It is the policy of SEKO to promote a safe environment   We need your cooperation to implement this
             for its employees. SEKO is committed to working   policy effectively and maintain a safe working
             with its employees to maintain a work environment   environment. Do not ignore violent, threatening,
             free from violence, threats of violence, harassment,   harassing, intimidating, or other disruptive
             intimidation, and other disruptive behavior. While   behavior. If you observe or experience such
             this kind of conduct is not generally associated with   behavior by anyone on company premises - whether
             companies like ours, no company is immune.       he or she is a company employee or not - report it
                                                              immediately to your Human Resources Department,
             Violence, threats, harassment, intimidation and   management, or the local authorities. The incident
             other disruptive behavior in our workplace will not   will be investigated and appropriate action taken.
             be tolerated; that is, all reports of incidents will be
             taken seriously and dealt with appropriately. Such   If you or someone else in the office is feeling
             behavior can include oral or written statements,   unsafe or threatened by another employee, remove
             gestures, or expressions that communicate a direct   yourself from the situation if possible, call law
             or indirect threat of physical harm. Individuals   enforcement immediately, and report the incident.
             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      The Anonymous Reporting Hotline is intended to cover
             compliance with all laws in the countries where   serious concerns and/or sensitive issues that could
             SEKO does business - including all state, federal   have a large impact on SEKO, such as actions that:
             and international laws. In short, we are committed
             to always doing the right thing. For that reason, we   •  May lead to incorrect financial reporting;
             have adopted a Code of Conduct and Ethics Policy as   •  Are unlawful;
             well as introduced an Anonymous Hotline specifically   •   Are not in line with company policy, including the
             designed to be part of an effective program to prevent   Code of Conduct and Ethics Policy; or
             and detect - as well as report possible violations of
             law and conduct. SEKO encourages its employees,   •  Otherwise amount to serious improper conduct.
             agents, and worldwide partners to raise concerns
             that will help us with our commitment to ethical,   Reporting a Complaint
             moral and legal business conduct. This policy aims
             to provide an avenue for employees to raise concerns   Toll-Free Telephone:
             and reassurance that they will be protected from   •   English speaking USA and Canada: (844) 510-0059
             reprisals or victimization for whistleblowing in   •   Spanish speaking North America: (800) 216-1288
             good faith. However, if an employee feels that their
             anonymity is not required then they should follow our   •   French speaking Canada: (855) 725-0002
             existing grievance procedure.                    •   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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