Sierra Nevada Global Logistics Code of conduct

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1.1 Overview 

The Code of Conduct provides essential guidance on ethical behavior and legal compliance, underscoring SNVGL’s dedication to integrity and excellence in all business activities. Any breach of the Code may lead to disciplinary action, which could include termination of employment. Additionally, violations that breach applicable laws may result in civil or criminal prosecution. Employees are obligated to report any known violations of the Code, unless prohibited by law. 

1.2 How to Use the Code

All employees and representatives should familiarize themselves with the Code and apply its principles to daily work activities—the Code guides on various issues, including legal compliance, ethical behavior, and company policies.

1.3 Compliance with Local and International Laws

Ensure your actions comply with all relevant local, national, and international laws. The Code is a minimum standard; local laws may impose additional requirements. Integrity is non-negotiable. If you have any questions about how the Code applies to specific situations, please seek clarification from your manager or consult the resources provided in this document. 

2.1 Speaking Up Is the Right Way

Reporting unethical or illegal behavior is essential to upholding SNVGL’s integrity. If you observe or suspect misconduct or violations of the Code, speak up. Integrity involves addressing situations, behaviors, or conduct inconsistent with the Code, Company policies, or applicable laws. Everyone is encouraged to raise concerns, ask questions, and report issues using SNVGL’s reporting resources. 

2.2 SNVGL’s AlertLine

To seek advice or raise concerns about ethics, safety, compliance with laws, or other Company policies, please contact the AlertLine. You can remain anonymous, although providing your name might facilitate a more thorough follow-up. Use the communication method you are most comfortable with. The key is obtaining the necessary guidance, reporting what you know, and answering your questions. The AlertLine provides a confidential and anonymous way to report concerns. You can access it via (alert@snvgl.com) ( 866-768-4548 option 1)  

2.3 Open Door Policy

We encourage open communication. Employees should feel free to discuss concerns with their supervisors or management without fear of retaliation.

2.4 Retaliation

SNVGL prohibits retaliation against individuals who report concerns in good faith. Any form of retaliation will not be tolerated or subject to disciplinary action. Retaliation against anyone for reporting a potential violation or participating in an investigation is strictly against Company policy and may also be illegal in certain jurisdictions.

3.1 Diversity and Inclusion

Sierra Nevada Global Logistics is committed to fostering a diverse, equitable, and inclusive workplace. We recognize that our employees are our greatest asset and deeply value their contributions to our success. As a global company, we strive to align with local cultures and business practices, provided they adhere to our Code of Conduct and applicable legal standards. We value diversity and strive to create an inclusive work environment. All employees should be treated respectfully regardless of race, gender, age, disability, or other characteristics.

3.2 Discrimination and Harassment

At Sierra Nevada Global Logistics, all employees have the right to work and participate in work-related events in a professional environment that is free from violence and all forms of harassment, including sexual harassment. 

Discrimination and harassment are unacceptable. Harassment involves unwelcome behavior towards an individual based on any protected characteristic that creates an intimidating, offensive, or hostile work environment. This can include physical actions, spoken or written remarks, distribution of sexually explicit or abusive materials, derogatory jokes, and verbal abuse. Regardless of its form, harassment is strictly prohibited and undermines individual performance and the overall workplace atmosphere.  Report any incidents of discrimination or harassment to management or through the AlertLine.

3.3 Safe Work Environment

SNVGL is committed to providing a safe and healthy work environment. Adhere to safety policies and report any hazards or unsafe conditions immediately.  Acts or threats of violence disrupt our commitment to maintaining a safe workplace. All threatening behavior must be taken seriously and reported without delay, regardless of whether it is made in jest. Contact local law enforcement authorities immediately if you or anyone else is in danger. 

4.1 Environmental Responsibility

At Sierra Nevada Global Logistics, we are committed to improving the quality of life in the communities where we operate. We encourage our employees to contribute through volunteerism and charitable giving. Our dedication to environmental responsibility guides our business practices, promoting sustainable decision-making across all operations and value chain aspects. 

4.2 Human Rights

At Sierra Nevada Global Logistics, we conduct our business with a firm respect for the rights of all individuals, including employees, contractors, workers in our supply chain, and others affected by our operations. Our commitment to human rights is guided by internationally recognized standards, including the International Labor Organization conventions, the United Nations Universal Declaration of Human Rights, the United Nations Global Compact, and the Responsible Business Alliance.  Respect and support human rights in all business practices. We are committed to ethical labor practices and protecting workers' rights.

4.3 General Labor Principles

 We uphold employees' rights to participate in protected activities, such as lawful free association, organization, and collective bargaining, while respecting their right to abstain from such activities. We ensure wages and working hours fully comply with applicable laws and expect the same commitment from all our business partners. We are dedicated to fair labor practices, which include equitable wages, safe working conditions, and respect for workers' rights. 

4.4 Forced and Child Labor

SNVGL has a zero-tolerance policy for forced and child labor. We ensure that all employment practices adhere to relevant labor laws and standards. We strictly prohibit forced, bonded, indentured, involuntary, or exploitative labor in our operations and throughout our supply chain. Additionally, we prohibit the use of child labor and comply with the minimum age requirements in all jurisdictions where we operate. 

5.1 Anti-Bribery and Anti-Corruption Laws

Adhere to all applicable anti-bribery and anti-corruption laws. Do not offer or accept bribes or corrupt payments.

5.2 Use of Third Parties

Conduct due diligence on third parties to ensure they comply with SNVGL’s ethical standards and legal requirements.

5.3 Global Trade Laws

Follow all relevant global trade laws and regulations. Ensure compliance with import/export restrictions and trade sanctions.

5.4 Antitrust and Fair Competition

Engage in fair competition and avoid practices that may constitute anti-competitive behavior or violate antitrust laws.

5.5 Insider Trading

Do not engage in insider trading or misuse confidential information for personal gain.

5.6 Conflicts of Interest

Avoid situations where personal interests conflict with SNVGL’s interests. Disclose any potential conflicts of interest to management.

5.7 Gifts and Entertainment

Gifts and entertainment must be modest and in compliance with company policies and applicable laws. Avoid any gifts or entertainment perceived as a bribe or improper influence.

5.8 Engaging in Political Activities

Participate in political activities personally and not as a representative of SNVGL. Ensure that such activities do not conflict with SNVGL’s interests or values.

5.9 Political Contributions and Campaigning

Political contributions and campaigning must comply with applicable laws and company policies.

5.10 Lobbying

Any lobbying activities must be conducted transparently and in compliance with all relevant regulations and company policies.

6.1 Integrity of SNVGL Records

Maintain accurate and complete records. Ensure that all financial and operational records are truthful and comply with legal and regulatory requirements.

6.2 Physical Assets and Intellectual Property

Protect SNVGL’s physical assets and intellectual property from loss, theft, or misuse. Respect and safeguard proprietary information and inventions.

6.3 Confidential Information

Handle confidential information with care and only disclose it to authorized individuals. Ensure that confidential data is protected against unauthorized access.

6.4 Safeguarding Personal Data

Comply with data protection laws and company policies regarding collecting, using, and storing personal data.

6.5 Cybersecurity

Follow cybersecurity protocols to protect SNVGL’s digital assets and information systems from cyber threats and breaches.

6.6 Artificial Intelligence

Use artificial intelligence responsibly and ethically, ensuring compliance with relevant laws and standards.

7.1 Social Media

Exercise caution when using social media. Ensure your posts and interactions reflect positively on SNVGL and do not disclose confidential or proprietary information.

7.2 Communications with the Public, Investors, and Government Officials

All communications with the public, investors, and government officials must be accurate, transparent, and compliant with SNVGL’s communication policies.

If you have questions about the Code or encounter problems that may violate our ethical standards, contact your supervisor or the compliance officer or use the AlertLine. Report violations promptly to ensure they are addressed and resolved appropriately.

This guide aims to provide clear and comprehensive information to help employees and stakeholders adhere to ethical standards and comply with relevant laws. If you have any questions or need further clarification, please refer to the detailed sections or contact the appropriate contacts within SNVGL. Orders are processed and shipped quickly.