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d. Anti-Boycott Policy                           e. Reporting Violations
             In the United States, Congress has promulgated    All employees and parties associated with SEKO are
             laws and regulations that makes it illegal for any U.S.   responsible for compliance with this Code of Conduct. In
             Citizen or American based business (incorporated   the area of ethics, legality and propriety, all parties have
             and unincorporated) to participate in any foreign   an obligation to SEKO to be alert to possible violations
             boycott not sanctioned by the U.S. Government.   of the Code of Conduct in any business transaction and
             In addition to prohibiting all unsanctioned foreign   are encouraged to report such violations promptly to
             boycotts, it is also illegal to engage in the following:  SEKO Corporate Ethics, in writing, to the following email:
                                                              ethics@sekologistics.com
             •   Agreeing to refuse or actual refusal to do business   Employees and all other parties representing SEKO
               with or in Israel, or with blacklisted companies.
                                                              will also be expected to cooperate in any type of
             •   Agreeing to or actually discriminating against   investigation. In addition, any Employee, Partner,
               other persons based on their race, religion, sex,   and/or Agent who is convicted of a felony, should make
               national origin or nationality.                this known to SEKO Corporate Ethics (unless otherwise
             •   Agreeing to furnish or actually furnishing   prohibited or protected by law from doing so).
               information about business relationships with    In all cases when there is questionable activity
               or in Israel, or with blacklisted companies.   involving the Code of Conduct, or other misconduct,
                                                              an investigation will be conducted to determine
             •   Agreements to furnish or actual furnishing
               of information about the race, religion, sex,    appropriate action. Whenever possible, SEKO will
               or national origin of another person.          keep confidential the identity of all employees and
                                                              other parties. SEKO’s Confidentiality Policy will keep
                                                              confidential all information about or against whom
             The U.S. has a strong interest in ensuring that
             U.S. Citizens and U.S. businesses are not helping   allegations of violations are brought, until it has been
             to effectuate foreign policies that are contrary to   determined that a violation has occurred. Similarly,
             U.S. policies. Therefore, all SEKO employees, and   whenever possible, SEKO will keep confidential the
             representatives must refrain from participating in   identity of anyone reporting a possible violation.
             any unsanctioned foreign boycott. Violations of U.S.   Retaliation against any employee for reporting a
             anti-boycott will not only result in the termination of   suspected violation is strictly prohibited.
             relations with SEKO, but may also be subjected to
             criminal penalties.











































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