Code of Ethics & Business Conduct

1. Purpose & Scope

This Code of Ethics and Business Conduct establishes the ethical standards and behavioral expectations for all employees, officers, directors, contractors, and business partners of SafeTransit EXPRESS. Our commitment to ethical conduct is foundational to maintaining trust with our customers, communities, and stakeholders across the global logistics industry.

This Code applies to all individuals acting on behalf of SafeTransit EXPRESS, regardless of geographic location, role, or seniority. Compliance is mandatory and forms part of all employment and contractor agreements.

2. Core Ethical Principles

SafeTransit EXPRESS operates according to the following guiding principles:

• Integrity: We conduct all business honestly, transparently, and in good faith
• Accountability: We take responsibility for our actions and their impact
• Respect: We treat all individuals with dignity, fairness, and respect
• Excellence: We pursue the highest standards in service delivery and governance
• Compliance: We adhere to all applicable laws, regulations, and industry standards
• Sustainability: We consider environmental and social impact in all decisions

3. Anti-Corruption & Anti-Bribery

SafeTransit EXPRESS maintains a zero-tolerance policy toward bribery and corruption in any form. We comply with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and all applicable anti-corruption legislation in jurisdictions where we operate.

3.1 Prohibited Conduct

• Offering, promising, giving, or accepting bribes, kickbacks, or improper payments
• Making facilitation payments to government officials or customs authorities
• Providing gifts or hospitality intended to improperly influence business decisions
• Using third parties or intermediaries to circumvent anti-corruption obligations
• Concealing or misrepresenting financial transactions

3.2 Gifts & Hospitality

Business gifts and hospitality must be reasonable, proportionate, and transparent. All gifts exceeding $100 USD (or local equivalent) must be pre-approved by the Compliance Department and recorded in the gifts register. Government officials and customs authorities may not receive any gifts or hospitality without prior written authorization from the Chief Compliance Officer.

4. Conflicts of Interest

All personnel must avoid situations where personal interests conflict, or may appear to conflict, with the interests of SafeTransit EXPRESS. Potential conflicts must be disclosed immediately to the Compliance Department.

4.1 Examples of Conflicts

• Financial interests in competitors, suppliers, or customers
• Outside employment or consulting that competes with company activities
• Personal relationships with vendors that could influence procurement decisions
• Using company resources, information, or position for personal gain
• Serving on boards of competing organizations without prior approval

4.2 Disclosure Requirements

All potential or actual conflicts must be disclosed via the Conflict of Interest Declaration Form. The Ethics Committee reviews all disclosures and determines appropriate mitigation measures. Annual conflict of interest certifications are required for all management-level personnel.

5. Whistleblower Protection

SafeTransit EXPRESS is committed to providing a safe environment for reporting concerns about unethical, illegal, or non-compliant behavior. We operate a confidential reporting mechanism available to all employees, contractors, and external stakeholders.

5.1 Reporting Channels

• Ethics Hotline: 24/7 confidential telephone reporting service
• Online Portal: Secure web-based reporting at ethics.safetransitexpress.com
• Direct Reporting: Reports may be made to any manager, HR, or the Compliance Department
• External Counsel: Anonymous reports may be submitted through independent legal counsel

5.2 Non-Retaliation Policy

SafeTransit EXPRESS strictly prohibits retaliation against any individual who reports concerns in good faith. Retaliation includes termination, demotion, harassment, discrimination, or any adverse employment action. Individuals found to have engaged in retaliation will face disciplinary action up to and including termination.

6. Fair Competition & Antitrust

We compete fairly and lawfully in all markets. SafeTransit EXPRESS complies with all applicable competition and antitrust laws, including EU competition law, the US Sherman Act, and equivalent legislation globally.

• Price fixing, bid rigging, or market allocation with competitors is strictly prohibited
• Sharing competitively sensitive information with competitors is forbidden
• Abuse of dominant market position in any segment is not permitted
• All trade association participation must be pre-approved and monitored

7. Data Protection & Confidentiality

All personnel must protect confidential business information, trade secrets, and personal data in accordance with applicable data protection laws (GDPR, CCPA, and local equivalents). Customer shipment data, pricing information, and strategic plans must be handled with the highest level of confidentiality.

8. Workplace Standards

8.1 Diversity & Inclusion

SafeTransit EXPRESS is committed to maintaining a diverse, equitable, and inclusive workplace. Discrimination based on race, gender, age, religion, disability, sexual orientation, national origin, or any other protected characteristic is strictly prohibited.

8.2 Health & Safety

We maintain the highest standards of workplace health and safety across all facilities, warehouses, and transport operations. All personnel must comply with safety protocols and immediately report unsafe conditions.

8.3 Anti-Harassment

Harassment of any kind, including verbal, physical, visual, or online harassment, is not tolerated. All reports of harassment are investigated promptly and thoroughly.

9. Environmental Responsibility

We are committed to minimizing our environmental footprint and conducting business in an environmentally responsible manner. All personnel must comply with environmental regulations and support our sustainability initiatives, including emissions reduction, waste minimization, and responsible resource consumption.

10. Enforcement & Disciplinary Action

Violations of this Code may result in disciplinary action, including verbal or written warnings, suspension, termination, and where appropriate, civil or criminal proceedings. The severity of disciplinary action will be proportionate to the nature of the violation.

All personnel are required to complete annual ethics training and certify their understanding of and commitment to this Code. Managers have additional responsibility to promote ethical culture and address concerns within their teams.

11. Contact & Resources

For questions about this Code, ethical concerns, or compliance guidance, please contact:

• Chief Compliance Officer: compliance@safetransitexpress.com
• Ethics Hotline: Available 24/7 in multiple languages
• General Inquiries: Visit our Contact Page