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SECTION 10

CODE OF CONDUCT AND ETHICS STATEMENT

I. PURPOSE.

SEKO has a strong and unwavering commitment to procedures in force to secure compliance with the
promoting honest and ethical business conduct by all principles of business integrity and ethics as set forth
employees, and other parties associated with SEKO. in this Code of Conduct. All parties are expected to
To effectuate SEKO’s commitment to these principles, apply this Code of Conduct and to apply common
this Code of Conduct and Ethics Statement (hereafter sense with the objective of reaching full compliance.
referred to as the “Code of Conduct”) serves to:
(1) emphasize SEKO’s commitment to ethics and All employees and affiliated parties are responsible
compliance with the law; (2) set forth expectations for for their own actions. All claims of violations of this
the adherence to basic standards of ethical and legal Code of Conduct will be investigated by appropriate
behavior; (3) provide reporting procedures for known company personnel. Those who violate the standards
or suspected ethical or legal violations; and (4) help of this Code of Conduct will be subject to disciplinary
prevent and detect wrongdoing. action, and in the case of Partners and Agents,
suspension or termination of their contract or
The Code of Conduct is an addition to, and supplements agreement with SEKO. In all instances, appropriate
the other policies and procedures which comply with legal action may be taken if a violation is discovered.
the law. However, if a local custom business practice, The absence of a specific guideline, practice, or
standard of dealing, or other non-legally binding instruction covering a particular situation does
authority conflicts with this Code of Conduct, this Code not relieve one from exercising the highest ethical
of Conduct supersedes that local practice or standard of standards applicable to the circumstances. In all
dealing and you must comply with this Code of Conduct. cases, parties associated with SEKO are expected to
make decisions prudently and seek guidance within
SEKO’s standard business practice is to distribute the Human Resources and/or Compliance Department
and/or make available copies of the Code of Conduct or direct management in cases of uncertainty.
to its employees, independent contractors, suppliers
and all other parties associated with SEKO. The You are encouraged to report any possible violation
aforementioned parties are required to read the Code by sending an e-mail to: ethics.sekologistics.com
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

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