We have produced a Code of Conduct (“Code”) which demonstrates to our stakeholders, our commitment to a strong and unique company culture with solid ethical values. It requires all of us to act with integrity and apply the highest ethical standards in our daily work.
Our core values are based on three key principles:
1.1 This Code applies across the entire Cargo Services Group, its subsidiaries, affiliates and associates (collectively known as “CS”). The policy applies to all individuals working at all levels and grades, including senior managers, officers, director, employees (whether permanent, fixed term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with the CS Group of Companies, wherever located (collectively referred to as employees in this policy).
1.2 In the case of joint ventures or companies in which the Company does not hold a controlling interest, the Company’s representatives concerned are expected to act in accordance with the Code themselves and to make a concerted effort to influence those with whom they are working to act to similar standards of integrity and ethical behaviour.
1.3 Contractors working for the Company are urged to follow our Code of Conduct for the duration of their contract with the Company. The Company will fully support those who pass up unethical opportunities or in good faith report potential or actual breaches of the Code.
2.1 We are committed to conducting business with integrity, in accordance with strong business ethics.
2.2 All our business must be conducted honestly and fairly, with no conflict of interest or undue influence.
2.3 We must be accurate and truthful in our dealings with third parties, and not misrepresent ourselves or the quality, features, price or availability of our products and services.
2.4 We must also be honest and forthcoming with our colleagues, prepare and offer honest business assessments, evaluations and proposals, and record accurately all transactions. If we make a business commitment, we will dedicate ourselves to ensure that we meet it.
2.1 We are committed to conducting business with integrity, in accordance with strong business ethics.
2.2 All our business must be conducted honestly and fairly, with no conflict of interest or undue influence.
2.3 We must be accurate and truthful in our dealings with third parties, and not misrepresent ourselves or the quality, features, price or availability of our products and services.
2.4 We must also be honest and forthcoming with our colleagues, prepare and offer honest business assessments, evaluations and proposals, and record accurately all transactions. If we make a business commitment, we will dedicate ourselves to ensure that we meet it.
3.1 We value the help of employees who identify potential problems that we need to address. CS will ensure that reports are kept confidential, including the identity of the reporter.
3.2 We do not tolerate retaliation of any kind against employees who, in good faith, report breaches or violations of our Code of Conduct or any other illegal conduct. We take claims of retaliation seriously. Allegations of retaliation are investigated and appropriate action is taken.
4.1 The Company’s activities are subject to the laws of different jurisdictions, statutory requirements and statutory codes.
4.2 Each of us is required to adhere strictly to both the letter and spirit of all applicable laws, regulations and statutory codes.
4.3 The laws that apply to particular international transactions and activities include those of the countries where the transaction occurs. The applicable laws also include certain laws of the jurisdiction, where we operate, governing international operations of the Company.
4.4 Each of us is expected to co-operate fully in the investigation of any alleged violation of the law or Company policy. Concealing a violation or altering or destroying evidence may be illegal and will be treated as a serious breach of the Code.
5.1 The Company is committed to abiding by all laws and regulations, and to prevent bribery wherever we do business.
5.2 The Code forbids paying, offering, asking for, proposing terms for, or accepting, bribes directly or with the assistance of any organization or individual. We are strictly prohibited from discussing terms with people who ask for or offer bribes.
5.3 For details of the policy, please refer to “Anti-corruption policy”.
6.1 We must decline entertainment, gifts or other benefits (e.g., personal favours, or preferential treatment) that could in any way influence, or appear to influence, business decisions in favour of any person or organization with whom the Company may have business dealings.
6.2 We are also under an obligation to ensure agents or others providing gifts or entertainment on the Company’s behalf follow our guidelines “Anti-corruption policy”.
7.1 CS makes charitable donations from time to time, normally in the form of sponsorship to support someone’s endeavours (and is donated via “just giving”) in activities or where a location gets involved in things such as Red Nose day or Jeans for Genes where we often match sums raised by staff.
7.2 We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices.
8.1 We strictly adhere to what are called “competition” laws in some countries and “anti-trust” laws in others. These laws promote or protect free and fair competition around the world and prohibit all anti-competitive behavior, such as price-fixing conspiracies.
8.2 No CS employee is permitted to engage in price-fixing, bid rigging, allocation of market or customers, or similar illegal anti-competitive activities.
8.3 The Company only uses available expert-, industry- and other publicly available sources to understand business, customer and supplier strategies, technology trends, regulatory proposals and developments, and existing and expected actions of suppliers and competitors.
8.4 CS gathers this information fairly and legally and never by dubious means such as theft, illegal entry, bribery, misrepresentation of who you are or electronic eavesdropping.
9.1 We comply with all terms and conditions of our contracts and expect our business partners to do the same. We deliver as we promise, and bill in strict compliance with contract terms.
10.1 The employee shall not at any time, either during or after the termination of his employment agreement, divulge or communicate to any person or persons (except to those officials of the Company whose province it is to know the same) any of the secrets or any other information which he may receive or obtain in relation to the private affairs of the Company or to the working of any process, system or invention which is carried on or used by the Company or which he may make or discover during his/ her appointment and shall not use for his/ her own purposes nor for any purposes other than those of the Company any information or knowledge of a confidential nature which he may from time to time acquire in relation to the Company.
10.2 All lists, accounts, schedules, correspondence, files and other documents, papers and property, which may have been prepared by the employee or have come into his/ her possession during the course of the employment, belong to the Company. The information shall be handed over by the employee to the Company from time to time, on demand, and in any event immediately upon the termination of this agreement with the Company and the employee shall not retain any copies thereof.
10.3 The Company prohibits any staff from transferring sensitive materials and information, and intellectual property of the Company to those of third parties, without the express approval of the Senior Management.
11.1 In our daily activities we work with suppliers, customers and others who do business with CS. It is important that every decision is made with objectivity and is based on the needs of the company and not on personal interests or relationships.
11.2 The Company respects the right of employees to engage in outside activities, including business interests but they must declare the interests and obtain pre-approval from senior management.
11.3 It is imperative that all employees shall protect the Company’sbest interests at all times and avoid work which endangers the proprietary position of the Company.
11.4 Employees must declare to the Company any financial interest, direct or indirect, which they or members of their immediate family may have, in any business or other organization which competes with the Company or with which the Company has business dealings.
12.1 The Company commits to creating a safe, fair and socially responsible working environment and complying with the Ethical Trading Initiative (“ETI”).
12.2 Having adopted the ETI base code, a programme of independent audits has been introduced to measure Ethical and Social compliance within our global network. Our customers, colleagues and the experience we can draw from within the ETI will determine how our program evolves.
12.3 Our Commitment:
12.3.1 Employment is freely chosen
12.3.2 Freedom of association and the right to collective bargaining are respected
12.3.3 Working conditions are safe and hygienic
12.3.4 Child labour shall not be used
12.3.5 Living wages are paid
12.3.6 Working hours are not excessive
12.3.7 No discrimination is practised
12.3.8 Regular employment is provided
12.3.9 No harsh or inhumane treatment is allowed
13.1 As an internationally operating logistics company, we are continually confronted with changes. Our management regularly assesses the impact of future scenarios and evaluates the opportunities and risks in their departments. Risks can also be reported at any time on an ad hoc basis.
13.2 Our early identification process leads to uniform reporting standards for risk management in the Company. The risk management process is also used to ascertain potential risks in the areas of environmental management, litigation or personnel. We make continuous improvements to the IT application used for this purpose.
14.1 CS is committed to responding promptly to business and work-related situations that could be damaging to the Company or cause harm to others such as emergencies, accidents, irregularities or other unexpected events.
14.2 The Code requires each of us to promptly notify our supervisor or higher management of these situations and take reasonable action to prevent damage or harm. Situations covered are those that may result in: injury, illness or loss of life; damage to property or the environment; violation of the law or other applicable regulations; interruptions of service; and failure to meet the Company’s obligations.
15.1 Interpretation of the Code and OtherQueries
15.1.1 Advice regarding interpretation of the Code may be obtained from Head of Internal Audit.
15.1.2 The Company values the input of every employee on matters relating to the Code. We also value input from our business partners, suppliers and other external parties. If you have any queries concerning any aspect of the Code, please do not hesitate to contact Head of Internal Audit directly or through local Human Resources representatives.
15.2 If you have reason to believe that any CS employee or anyone working on behalf of CS has engaged in ethical or legal misconduct, you are required to report the incident promptly. You can talk to your manager, or Head of Internal Audit.
15.3 Each of us has an obligation to fully comply with its provisions and promptly report ethical concerns and potential or actual violations of the Code, whether or not it is known who may be responsible for the violation or how it may have occurred. We could be in breach of the Code if we assist or authorise others in activities that breach the Code, or conceal or fail to report any known or suspected breaches by others.
15.4 Any types of potential actual violations of the Code must be reported to the Head of Internal Audit. Alternatively, one may prefer to initially report to his/her manager or local Human Resources representatives who must in turn report to Head of Internal Audit. Business partners, suppliers and other third parties are encouraged to report any violations directly to Head of Internal Audit.
15.5 As the Company takes this reporting seriously and wants to fully investigate both potential and actual violations, it is preferred that these reports not be made anonymously. All reports and inquiries will be handled confidentially to the extent possible under the circumstances to preserve anonymity.
15.6 Anyone found violating the Code will be subject to disciplinary action which may include dismissal.
15.7 Anyone initiating or threatening to initiate retaliation against a complainant or informant, will be subject to disciplinary action which may include dismissal.