Anti-Bribery and Corruption Policy

1. Introduction
Spediteurs (“Company,” “we,” “our,” or “us”) is fully committed to maintaining the highest ethical standards in all aspects of its business operations. We adhere to a strict zero-tolerance policy regarding bribery and corruption in all forms. This policy is designed to ensure compliance with relevant anti-bribery laws and regulations, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other applicable international and local laws.

2. Scope
This policy applies to all employees, directors, officers, agents, consultants, contractors, suppliers, business partners, and any other individuals or entities acting on behalf of Spediteurs. It encompasses all business activities conducted domestically and internationally, ensuring that our ethical standards remain uncompromised across all regions and jurisdictions in which we operate.

3. Definition of Bribery and Corruption
Bribery refers to the offering, giving, receiving, or soliciting of any item of value—whether monetary or non-monetary—to improperly influence a business decision, secure an unfair advantage, or induce improper conduct. Corruption is a broader term that includes any dishonest or fraudulent conduct undertaken to gain an advantage, including bribery, fraud, embezzlement, and abuse of power.

4. Prohibited Conduct
The following activities are strictly prohibited under this policy:

• Offering, promising, giving, or accepting bribes, kickbacks, or inducements of any kind.
• Providing or receiving facilitation payments to expedite routine government or business transactions.
• Offering or accepting gifts, hospitality, or entertainment that may be perceived as an attempt to influence a business decision.
• Engaging in or tolerating conflicts of interest that compromise ethical business practices.
• Concealing or misrepresenting transactions to disguise improper payments or benefits.
• Making political or charitable contributions intended to secure business advantages.

5. Gifts, Hospitality, and Entertainment

• Gifts, hospitality, and entertainment must be reasonable, proportionate, and transparent, and must not create a perception of impropriety.
• Any gifts or entertainment offered or received must be recorded in accordance with the company’s financial policies and must not exceed legally permissible thresholds.
• Under no circumstances should gifts or entertainment be provided during a procurement or contracting process to influence the outcome.

6. Reporting and Whistleblowing

• All employees and third parties conducting business on behalf of Spediteurs must report any suspected or known instances of bribery or corruption immediately.
• Reports can be made confidentially through the designated reporting channels, including the Compliance Officer or an anonymous whistleblower hotline.
• The company ensures that all reports are thoroughly investigated and appropriate corrective actions are taken.
• Retaliation against individuals who report concerns in good faith will not be tolerated.

7. Compliance and Enforcement

• Violation of this policy will result in serious consequences, including disciplinary actions up to and including termination of employment or contractual agreements.
• Individuals found guilty of bribery and corruption may also be subject to criminal prosecution, significant fines, and imprisonment under applicable laws.
• The company will cooperate fully with regulatory authorities in any investigations concerning bribery and corruption.

8. Training and Continuous Improvement

• Spediteurs is committed to regularly training employees and stakeholders on anti-bribery laws, ethical business practices, and compliance requirements.
• This policy will be periodically reviewed and updated to align with evolving legal and industry standards.
• Employees and business partners are encouraged to provide feedback and suggest improvements to enhance our anti-bribery framework.

9. Contact Information
For questions regarding this policy or to report any concerns, please contact:

Spediteurs Global Services
Email – info@spediteurs.com

By engaging in business with Spediteurs, all employees, partners, and stakeholders affirm their commitment to upholding this Anti-Bribery and Corruption Policy.