ANTI-CORRUPTION AND ANTI-BRIBERY POLICY

1. PURPOSE

1.1 Integrity, honesty and fair play are among our core values. Globalink (hereinafter referred to as the Company) promotes the highest standards of business ethics and complies with all applicable laws, including anti-bribery laws in the country in which we operate and conduct business.

1.2 Bribery and corruption are detrimental to business and lead to unfair competition and uncertain business results.

1.3 We expect high levels of business ethics from all directors, officers and employees of the HO and branches, as well as from those with whom we do business, including our agents, intermediaries, consultants, contractors, subcontractors, suppliers. We have a zero-tolerance approach to bribery in any form in any country/territory in which we operate and do business.

1.4 This Policy sets out the Company’s global standards and identifies the various situations in which bribery issues are most likely to arise, but it does not cover every possible situation. If you are in any doubt as to whether a particular course of action may breach this Policy, please contact the QHSE department QHSE@globalinklogistics.com, Head of Human Resources a.gaisina@globalinklogistics.com and your Branch/Department Manager before acting.

2. APPLICABILITY

2.1 This Policy is effective immediately and applies to all Company personnel and all business partners acting on behalf of the Company in all countries. Company employees must communicate the terms of this Policy to the business partners with whom they deal.

2.2 Any practice that is contrary to or in breach of this Policy is strictly prohibited by the Company.

2.3 You must read and understand this Policy and comply with its terms. If you have any questions about this Policy, please seek advice from your HR manager or the QHSE department.

3. CONSEQUENCES OF NON-COMPLIANCE

3.1 Any failure to comply with this Policy will be taken seriously. Any Company employee who breaches the standards set out in this Policy may face disciplinary action, including the possibility of summary dismissal without compensation from the Company in accordance with applicable law. Violations of this Policy may also be a violation of law and may subject you, your colleagues and/or the Company to civil and criminal penalties.

3.2 In the event that the Company suffers any losses because of any violation of this Policy, the Company may hold those responsible liable for such losses.

4. POLICY STATEMENTS

4.1 A bribe may be an advantage that may take many forms, such as cash, cash equivalents (such as vouchers or coupons for purchases), gifts, travel, entertainment, sponsorship, donations, securities, property or property interests, loans of money or property of value, commissions, services, fees, remuneration, position, employment, contracts, full or partial release from liability or any other benefit or service (an “Advantage”), directly or indirectly offered, given, requested or accepted with the intent to improperly influence the recipient in the performance of his or her duties in order to obtain or retain business or otherwise gain an unfair advantage.

4.2 You must never engage in any act of bribery. You may not give, offer, or receive any Benefits, especially if this could be construed or reasonably suspected to be for the purpose of obtaining an unfair business advantage for the Company or influencing any person or company to provide or direct business to the Company.

4.3 Similarly, you must not accept, receive, demand, request or solicit any Benefits in connection with any matter relating to the Company, especially if accepting such Benefits could influence your objectivity, induce you to act against the interests of the Company or give rise to questions, reasonable suspicions or complaints regarding your bias and/or impropriety. Gifts and entertainment may be permitted in certain limited circumstances set out in the Policy as described below.

5. RELATIONS WITH THE PUBLIC SECTOR/GOVERNMENT OFFICIALS

5.1 No advantage may be offered, directly or indirectly, to any public official holding a legislative, administrative or judicial position in any country and/or government, a political party, candidates for public office or any employee of any government, government department, government agency, public enterprise, public authority, public organization or international organization who performs public functions, or to any person acting on behalf of or for the benefit of such public officials.

5.2 For the avoidance of doubt, the prohibition on giving advantages to public officials includes any advantage given to a public official anywhere with the intent to influence:

• the performance or non-performance of an act by the public official done within the scope of his or her official authority.
• expediting, delaying, obstructing or preventing a public official from performing an act performed in his official capacity.
• a public official assisting, favoring, obstructing or delaying any person in an actual or potential business transaction with a government organization or government agency.
• a public official assisting or using influence in actual or potential contracts and subcontracts with a government organization or government agency.

5.3 You must never offer, solicit or accept any Advantage for the withdrawal of a tender or bid at an auction, whether made by a government agency.

6.1 GIFTS/OTHER BENEFITS

Acceptance of Gifts/Other Benefits

6.1.1 You must not directly or indirectly accept, and must politely refuse, any gift, entertainment or other Benefits in any form from the Company’s clients, prospects, business partners and potential business partners, unless prior approval has been obtained in accordance with the approval procedure set out in Section 7 of this Policy.
A Benefits is:

• a gift of nominal value that is of an advertising, promotional or charitable nature.
• entertainment permitted in accordance with Section 6.2 below,

AND ALWAYS ON CONDITION THAT

• acceptance will not influence your performance or decision making;
• you will not feel obligated to do anything in return for the offeror;
• and you can openly discuss the acceptance of a gift or entertainment with the Company or anyone else without any reservations.

6.1.2 If you receive a gift other than as permitted in Section 6.1.1 above, which you did not have a reasonable opportunity to refuse, you must disclose it at the earliest opportunity by completing the Gift Declaration Form. You must comply with any instructions the Company may give in relation to the gift, which are at the sole discretion of the Company, including but not limited to returning the gift to the offeror or otherwise disposing of or gifting the gift.

Offering or Giving Gifts / Other Benefits

6.1.3 In all dealings with the Company’s customers, prospective customers, business partners and potential business partners, you are strictly prohibited from offering, promising or giving, directly or indirectly, any benefit in any form other than:
6.1.3.1 entertainment permitted in accordance with paragraph 2 below.
6.1.3.2 symbolic Company mementos of nominal value bearing the Company’s name and/or logo.
6.1.3.3 if prior approval has been obtained following the approval process set out in Section 7 of this Policy.
6.1.3.4 If you wish to offer sponsorship or a gift or entertainment to any potential and/or existing business partners on behalf of the Company, you must strictly comply with the Company’s corporate sponsorship/gift donation rules applicable to the individual region/country/territory to which you belong.

6.2 Acceptance of Entertainment

6.2.2 No entertainment offered by the Company’s customers, potential customers, Business Partners and potential Business Partners may be accepted or received except where:
6.2.2.1 prior approval has been obtained following the approval procedure set out in Section 7 of this Policy; or
6.2.2.2 the entertainment concerned is an ordinary business meal or attendance at an entertainment, social or sports event that is not lavish, excessive or frequent (“Ordinary Entertainment”).

6.2.3 For the avoidance of doubt, the acceptance of invitation to all entertainment events, including an Ordinary Entertainment where no prior approval is required, must be declared to the Company at first practicable opportunity after acceptance according to the reporting procedures set out in Section 7 of this Policy.

Offering or Giving of entertainment

6.2.4 No entertainment may be offered to Business Partners, potential Business Partners, customers or potential customers except where the entertainment concerned is an Ordinary Entertainment. In the event you intend to offer any entertainment to any customers, potential customer, Business Partners or Potential Business Partners which you are in doubt if it is an Ordinary Entertainment, you should seek prior approval in accordance with the approval procedure set out in Section 7 of this Policy. Please also refer to more detailed entertainment expenses approval guidelines and procedures as may be set up and announced by senior management of individual region / country / territory applicable to you.

6.3 DEALINGS WITH RELATED PARTIES

6.3.1 Unless prior approval has been obtained pursuant to Section 6.3.3 below, you shall not enter into on behalf of the Company, its subsidiaries and/or affiliates and/or cause the Company, its subsidiaries and/or affiliates to enter into any agreements, contracts, transactions and/or any other business relationship with yourself, your Family (as defined below) and/or your Controlled Vehicles (as defined below).

6.3.2 For the purpose of this Policy, “Family” of a person means such person’s spouse, parent, child or step child and sibling, whether natural or adopted, collectively and “Controlled Vehicles” of a person means:- (i) any trustee of any trust of which that person and/or his/her Family is/are beneficiary; (ii) a company in which such person and his/her Family together are entitled to exercise or control the exercise of 50% or more of the voting power at general meetings; or (iii) a company that such person and his/her Family are in a position to control a majority of the board of directors or similar organ.

6.3.3 For the avoidance of doubt, the Company prohibits any dealings, transactions, contracts and/or agreements with parties where Company Personnel and/or his/her Family directly or indirectly have a personal or financial interest unless such interest has been sufficiently declared to the Company in accordance with the procedure set out in Section 7 of this Policy, prior to the Company’s commitment to the dealings, transactions or execution of contracts and/or agreements.

7. APPROVAL AND REPORTING PROCEDURE

7.1 In accordance with this Policy, prior declaration or approval, which shall be announced and revised by the Company from time to time via email, internal mail system and/or post, must be completed “(where Section 6.1 applies) or “GLK/KZ/CM/F06 Gifts Declaration Form” in the prescribed form of the Company must be sent/submitted to the designated and approving person in the Company/business unit/department applicable to you. If there is any reason why it is not possible to submit a written request for approval, you should call the designated and approving person to obtain prior verbal approval and submit a written request for approval as soon as possible.

7.2 For any subsequent reporting required under this Policy, the following procedure shall be followed: “Personal Declaration Form – Acceptance/Offer of Benefit/Related Party Relationship” as prescribed by the Company shall be submitted to the designated and approving person who shall maintain all declaration forms submitted to him/her for verification by the Head of Human Resources from time to time.

8. REPORTING VIOLATIONS OR SUSPICIOUS ACTIVITY

8.1 You must report any actual or suspected violations of this Policy to the Company at the earliest possible opportunity by contacting the General Director at HO, email or post giving the facts and evidence (if any) you have or are aware of and your contact details (if possible). Anonymous reports with insufficient information on the suspected violation will not be processed. We encourage you to provide your contact information when reporting, to help us investigate the matter fully. Your confidentiality will be respected.

8.2 The Company does not tolerate retaliation against anyone who in good faith reports a concern, even when allegations are found to be unsubstantiated. Anyone who retaliates against any other person who in good faith reports a concern is in violation of this Policy and may be subject to disciplinary action, including possible dismissal. If you suspect retaliation, you should report it immediately to the Head of HR.

8.3 If you have followed the reporting procedure set out above but are not satisfied with the response or if you feel uncomfortable raising your concerns or making a report to the persons designated above, you should contact the Chief Financial Officer of the Company.

9. COOPERATION WITH INVESTIGATIONS

9.1 You have an obligation to cooperate with investigations into any misconduct that may be carried out by the Company. Company Personnel who fail to cooperate and provide honest, truthful information may be subject to disciplinary action, including possible dismissal.