1. INTRODUCTION

Oxen Cargo Logistics is a company specialized in air, sea and road transport services, headquartered in the city of Rio de Janeiro/RJ, Brazil, with geographic coverage throughout all the brazilian national territory. 

The present Code of Conduct aims to define the rules of conduct that should guide internal and external interactions at all levels of the company’s organization. Internal rules of conduct are regulated in this document, as well as rules of conduct with suppliers, customers, partners and any other third parties involved in the operation. The compliance of the rules of this manual by the company’s employees, partners and clients allows for a safe and sustainable growth of the business.

2. MISSION, VISION, VALUES AND QUALITY POLICY

Oxen Cargo intends to be a market leader in the international trade segment, respecting the following guidelines: 

Mission: 

Provide the most seamless, highest quality and most personalized logistics experience to our clients and partners, driven by efficient communication, dedication and long-lasting relationships. We relentlessly strive to foster a positive work environment that inspires those within the company to transcend their potential. 

Vision:  

Tighten the gap between countries and stengthen world-wide thus promoting globalization and mutual collaboration. 

Values: 

Our values are divided into three categories: 

  1. People:Foster a positive work environment that inspires everyone in the company to transcend their potential.
  2. Partners:Cultivate a leading network of talented partners; always collaborate with mutual respect.
  3. Service: Deliver services that exceed expectations while constantly pushing the standard to a higher level. 

For all the occasions, the company is committed to always acting in good faith, in an ethical and transparent manner, respecting the individual with whom it collaborates or works, always aiming to continuously improve the service offered and contributing to socio-sustainability environmental and innovation. 

Quality Policy: 

Oxen Cargo is committed to acting in accordance with the internal Quality Policy, outlined below. 

Oxen is not just family owned, it is a family in itself that is constantly striving to provide a more personalized logistics experience. 

We relentlessly insist on deteriorating contact barriers between client and provider by establishing a more open line of communication, ultimately giving a familiar face to the “middle-man”. No matter the size of the cargo, we will be with you every step along the way, even after your shipment has been delivered. We perform to exceed our customer expectations, by following the legal requirements needed, identifying and solving external factors that may affect the final outcome of the service provided. We seek the right partners and suppliers that share the same values as Oxen, in order to provide the best service possible to our customers by understanding their needs, structure and objectives. We design our company strategy, motivation and actions to match the dynamic logistics market. We offer our customers the latest technology, sales and financial structure, continuously striving to improve the quality standard to always higher levels.

3. WORKING ENVIRONMENT

It is clear to us that a harmonious, pleasant and safe work environment is what everyone is looking for, regardless of being employer or employees. In order for Oxen Cargo to continue providing a high-level environment in which to work, some relevant points must be remembered. Those are: 

3.1. Conflict of interests 

There is a conflict of interest when someone is willing to obtain a particular advantage for himself/herself, and when it interferes with decision-making and the development of the company. 

Our employees must refrain from performing any act that results in a conflict of private interests with those of Oxen Cargo, such as using the prerogatives of the function for their own benefit or selling any products or services of a private nature on the company’s premises. This can also be manifested in the form of a commercial relationship, in corporate participation or acting through a third party at a competitor or customer of Oxen Cargo or in association in parallel activities that prevent the employee from fulfilling his responsibilities to the company. 

It is also forbidden to breach the duty of secrecy, which is manifested by the use for private purposes or in the form of passing on to third parties, any and all information, whether patented or not, of a technical, operational, commercial, legal, know-how, inventions, internal or external processes (administrative or judicial), formulas and designs, patentable or not, business plans, accounting methods, accumulated techniques and experiences, documents, contracts, papers, studies, opinions and research to which the member has access to: 

a) By any physical means (for example, printed documents, manuscripts, photographs etc.);

b) By any means registered in electronic media (e-mail, pen drive, etc.);

c) Verbally.

Therefore, the confidentiality of Oxen Cargo’s internal or proprietary confidential information that has not been disclosed to the general public must be kept confidential. Non-public information from suppliers, customers, employees, agents, consultants and other third parties must also be protected in accordance with legal and contractual requirements. 

It is also forbidden to speak on behalf of the company, including on social networks, blogs or any other type of media or vehicle, without prior authorization. 

If a situation is observed or becomes known that is or appears to be a conflict of interest, the interested party must immediately inform the Management to adopt the appropriate measures, ensuring anonymity. 

3.2. Use of company assets, materials and spaces 

It is prohibited to use the company’s financial and technological systems and resources to exercise personal activities or those that do not fit the professional activities performed for Oxen Cargo. Any act that may cause damage to the company’s intellectual or physical assets is considered an unacceptable conduct. 

Employees must use the company’s assets with due care and observance of the technical specifications indicated for their proper functioning. 

In order to provide more comfort and convenience to its employees, Oxen Cargo has a kitchen and pantry at their disposal. In this scenario, it is advisable to remember some rules of peaceful use, namely: 

  • When using utensils, employees must wash them immediately after the end of use, dry them and keep them in the appropriate storage place; 
  • Do not leave dishes, glasses, cutlery or other dirty objects in the sink; 
  • Do not leave food scraps in the sink or on the table; 
  • Do not leave any kind of food for more than 2 (two) days in the fridge. 

Employees who use the kitchen and pantry must assist in maintaining order and cleaning the places or utensils they have used. Failure to observe and disregard these rules will allow the company to disregard improperly stored food and objects, and to warn of conduct that is considered inappropriate. 

Smoking is strictly prohibited on the company’s premises. In urgent cases, employees can use the company phone for private purposes, as long as authorized by the supervisor or area manager. Lists, raffles, products for sweepstakes and / or sales and related items will not be allowed to circulate on Oxen Cargo’s premises. 

Salespeople and representatives of personal items are not allowed in the company, as well as private commerce and the loan of money in the loan sharking system among employees. 

It is also not allowed to carry any type of weapon, make use of toxic substances, alcoholic beverages and / or cigarettes on the premises of Oxen Cargo. The company does not admit that its employees are under the influence of alcoholic beverages or illegal drugs during the working day, whether on their dependence or that of their clients, including on trips, events, training and / or business meals. 

The employee must comply naturally with the determinations established by the superiors, fulfilling their daily obligations. It must also maintain the principles of respect for the dignity of the human person without any distinction, in relation to subordinates, co-workers, superiors, suppliers and customers. 

The employee must observe the rules of hygiene, safety and the environment of his work sector, aiming at the individual protection, of the collective of people and equipment. 

Any type of violence by an employee in relation to another or to third parties is considered a serious occurrence and subject to penalties. Only with prior authorization from the Administrative Management can photographs and/or filming take place inside the company, as well as receive private orders and hold parties (happy hour) at the place and during working hours. 

Only previously authorized employees can receive goods from suppliers and correspondence in general. The improper receipt of these articles can cause financial and operational problems for the company. 

If any irregularity / misuse of Oxen Cargo’s goods, materials and spaces is observed or becomes known, and / or non-compliance with any of the above provisions, the fact must be communicated to the Management, guaranteeing anonymity. 

3.3. Interpersonal relations, subordination and leadership 

All members of society must be treated equally, with respect, education and, above all, civility. Oxen Cargo does not tolerate aggressive, embarrassing or inappropriate treatment and behavior. 

Also, employees, administrators and directors must not use their position or hierarchy to disparage or treat any person badly, since any disagreements with the objective or the way in which the tasks are performed do not confer the right to gross or inappropriate treatment to anyone. Respect is fundamental in any human relationship, and Oxen Cargo makes a point of always acting with it. 

Oxen Cargo also repudiates any type of embarrassment and coercion, such as prank calls or bad games in the workplace, subjecting violators to the sanctions and penalties provided for in this code. Such practices must be communicated to the Management as long as it becomes known, anonymity is ensured.

4. WORKPLACE SAFETY

The guarantee of the physical integrity of all those who work with Oxen Cargo, and the maintenance of a safe work environment, are values that must always prevail. 

Oxen Cargo is committed to respect all labor safety laws and regulations, with the aim of protecting the physical integrity of its administrators, employees, third parties, representatives, distributors, business partners or any other persons entering the company’s facilities.  

If it is noted that some unsafe act is imminent to be practiced, or even the lack of procedures/equipment that aim to protect the physical integrity of people, we request that the Management be immediately communicated for the adoption of the appropriate measures.

5. INTERNAL RELATIONSHIP RULES

The rules of conduct for internal relationships must be based on the company’s values. It will be praised all the positive conducts, and it will have administrative penalties for standards deemed unacceptable.  

Company employees must work together in a cordial and non-competitive manner. The progression system is governed by meritocracy. 

The following cases are defined as unacceptable behavior: 

  • Moral harassment; 
  • Sexual harassment; 
  • Disrespectful, discourteous, threatening and discriminatory treatment; 
  • Discrimination based on social origin, race, color, gender, age, religion, physical characteristics or sexual orientation; 
  • Propagation of rumors, pornography, games or political party advertisements; 
  • Labor under the influence of alcohol or illegal drugs; 
  • Carrying weapons of any kind on the company’s premises, with the exception of security personnel legally authorized and qualified to do so, with no weapon other than those of Oxen’s security officers being admitted. 

These cases apply to any hierarchical level, position or function. 

Loving relationships between employees must be communicated in writing to management, to avoid internal conflicts. 

If any conduct is observed that confirms or appears to configure any of the above hypotheses, the interest must report the incident to the Management, guaranteed anonymity.

6. EXTERNAL RELATIONSHIP RULES

Oxen Cargo requires that its administrators, partners, employees, third parties, commercial representatives, distributors, and business partners act in compliance with all current legislation, the guidelines in this document and the guidelines of its Anti-Corruption Policy. Please contact Hernan Wilkins for more information about the Anti-Corruption Policy at hw@oxencargo.com. 

6.1. Customer relations 

Oxen Cargo’s service to customers must be based on the company’s values and focused on respect, courtesy, and efficiency, providing clear and accurate information when contracting services, to achieve the expected results. 

6.2. Relations with competitors 

Oxen Cargo respects the rules of the free market and does not agree with any measure of its employees that results in unfair competition. 

So, the company bases its activities in defense of the rules provided for in national and international competition laws and, therefore, the primacy over competitive freedom must always prevail in the spirit of our employees. 

6.3. Relations with suppliers, business partners, representatives, and distributors 

Oxen Cargo’s suppliers, business partners, representatives and distributors are extremely important parts of the company’s business and operations. However, any improper conduct on their part can have a serious impact on Oxen Cargo’s image and reputation. 

For this reason, Oxen has as a principle to work with suitable suppliers and business partners, treating them without privileges, favoring or discrimination of any kind. Thus, it will be up to the person responsible for the relationship, to carry out the analysis prior to contracting, in which it will be verified whether the suppliers share the principles outlined below: 

  1. Compliance with absolutely all laws applicable to the execution of business, such as, but not restricted to, labor, environmental, civil, customs, criminal legislation, among others;
  2. Prohibition of acts of corruption;
  3. Respect for human rights; 
  4. Take responsibility for the health and safety of your employees; and
  5. Act in accordance with applicable local and international standards regarding environmental protection.

All the suppliers and business partners must guide their behavior according to the principles expressed in this document. 

Oxen Cargo will not hire commercial representatives, distributors and commercial partners who have on their staff any public agents or politically exposed persons, or who have a family and kinship relationship with them, in order to safeguard their reputation. 

6.4. Relations with public agencies, public agents, and politically exposed people 

Oxen Cargo’s administrators, employees, third parties, commercial representatives, distributors, and business partners, when acting on behalf of the company, must strictly comply with all laws and regulations that apply to it as well as the provisions of this Code of Conduct and the Anti-Corruption Policy, always acting with courtesy and politeness. All the operations with national or foreign public administration agents must be done with fairness, transparency, ethics and morality. 

When there is a demand for inspection by public agencies, such as, but not limited to, the Federal Revenue Service of Brazil, Brazilian Sanitary Inspection and the Public Ministry of Labor of Brazil, the Management must be immediately communicated to adopt the appropriate measures with the Legal Department. This communication should preferably be in writing and in a sufficient way to clarify the issue. 

When dealing with public officials and politically exposed people, it is strictly forbidden to use the name of Oxen Cargo when dealing with personal matters of any nature, as well as offering or receiving any improper advantage. 

Under no circumstances can employees promise, offer or give, directly or indirectly, an undue advantage to public agents and/or politically exposed persons, or even to a third party in the relationship. An undue advantage is understood as the offer of something valuable, such as money, entertainment, travel, gifts, donations, among others. 

6.5. Relations with third parties 

Oxen Cargo does not allow any commercial relationship or operation that, directly or indirectly, could put its image or reputation at risk. 

Suppliers, service providers, business partners, distributors and customers will be hired/accepted using objective criteria, when applicable, such as: product/service quality, price, commercial and social reputation. 

The hiring of third parties or the acceptance of clients who have on their staff/be any public agents or politically exposed persons or who have a family and kinship relationship with them should be avoided. In such cases, it is important that proper communication is made as provided for in the Anti-Corruption Policy. Please contact Hernan Wilkins for more information about the Anti-Corruption Policy at hw@oxencargo.com. 

In the event that it is observed or becomes aware of the hiring of third parties in breach of this code or the Anti-Corruption Policy, the Management must be immediately communicated.  

6.6. Respecting the principles of an Authorized Economic Operator (OEA Program)  

According to article 2 of the Brazilian Normative Instruction RFB no. 1.598/15, the Authorized Economic Operator (OEA Program) is governed by the following principles, which Oxen Cargo strictly follows:  

  1. Facilitation;
  2. Agility;
  3. Simplification; 
  4. Transparency; 
  5. Trust; 
  6. Voluntariness; 
  7. Public-private partnership; 
  8. Risk management; 
  9. International safety standards; 
  10. Compliance with procedures and legislation; and 
  11. Emphasis on digital communication. 

6.7. Gifts and entertainment in business relationships 

Gifts and entertainment that do not cost or appear to cost more than a quarter of a brazilian minimum wage may be accepted or offered, as an act of courtesy or for institutional purposes, such as: 

  • Candy baskets, chocolates, wines; 
  • Diaries, notebooks, pens, pencils or calendars; 
  • Lunches and dinners; 
  • Oxen brand merchandising. 

For any gift or entertainment in excess of the established amount, approval from the Board of Directors will be required. Gifts and entertainment should never be offered in the form of bribes or malicious behavior. 

Also, no gifts or entertainment can be offered/accepted to public agents, politically exposed people and their family members, from representations of other competition companies or in a bidding process, as compensation for business in the past or who have the in order to make current or future contracts viable, nor as a form of bribery. 

6.8. Prohibition of political and electoral contributions 

Oxen Cargo is a non-partisan company and prohibits any support activity and/or donations to political and/or candidates from any position. Likewise, it does not allow political or electoral contributions on your behalf, regardless of the nature of the asset or resource.

7. HUMAN RESOURCES

7.1. Clothing 

The image of the employee reflects the image of the company and vice versa. It is essential that the employee preserves it, wearing appropriate and consistent clothes with the work environment, taking care of appearance and personal hygiene. Therefore, on the premises of the company or its external customers, the use of a cap is not allowed, as well as transparent or inappropriate pieces of clothing for the development of its activities.  

The employee who is not properly dressed will, in the first occurrence, be verbally warned and, in the next, prohibited from remaining inside the company, configuring absence on the day and consequent loss of the Remunerated Weekly Rest. 

7.2 Personnel Selection and Management Policy 

The Human Resources Policy of Oxen Cargo is consulted at any time, which aims to establish criteria and rules for the selection of Oxen Cargo personnel, in compliance with the Brazilian OAS Program. This procedure applies to Boi Cargo when selecting and managing personnel. For more information on the present policy, please contact Oxen Cargo’s management at hw@oxencargo.com.

9. PRIVACY POLICY

Oxen Cargo values you and respects your privacy in relation to any information about you that we may collect on our website or any other application that we own and operate. For this reason, we give our employees, customers, suppliers, representatives, distributors and partners transparency to the personal data processing activities carried out by us and to our practices to protect the security and privacy of our users, in accordance with our Privacy Policy, which can be checked at .https://www.oxencargo.com/privacy-policy.

10. CONDUCT OF BUSINESS FAIRLY AND RESPECTING THE CURRENT LEGISLATION

Operating in the market with maximum integrity is, for Oxen Cargo, one of the most important business pillars. Acting in accordance with the law, practicing correct acts and only negotiating fairly are guidelines of our company.  

9.1. Legitimate negotiations 

Oxen Cargo must always negotiate fairly, as well as provide honest and correct information regarding the provision of its services. It is strictly forbidden to make misleading statements to business partners in order to gain undue competitive advantage. 

9.2. Public contracts and tenders  

The participation of administrators, employees, commercial representatives, distributors and partners of Oxen Cargo in public contracts and bidding processes must be guided by respect for legal rules, ethics and transparency. Informal contacts with public agents involved in contracting or bidding are prohibited.  

Offering entertainment, hospitality, invitations or gifts of any kind to public officials responsible for contracting or bidding is prohibited. Any informal contact made by these same public agents must be immediately communicated to the Management, for later referral to the legal department and adoption of the appropriate measures. 

The content of the proposal presented by Oxen Cargo in the bidding process is confidential, therefore, it is forbidden to maintain contact with any competing companies in order to reduce competition or defraud the event. 

If you observe or become aware of irregular conduct in the course of public procurement or bidding, contact the Management. 

9.3. Free and fair competition 

Oxen Cargo acts with transparency and loyalty in its commercial transactions, observing all laws and regulations on free competition in Brazil and in any country that acts or will act. 

The company repudiates any cartel, monopoly, trust or dumping practices. 

Any type of adjustment with competitors, manipulation or combination of market prices, production costs, sales conditions, market divisions, as well as any conduct of an anti-competitive nature is prohibited. 

If there is a need to make contact with a competitor, this must be done in compliance with the restrictions provided for in this code and in the Anti-Corruption Policy. Please contact Hernan Wilkins for more information about the Anti-Corruption Policy at hw@oxencargo.com. 

9.4. Combating slavery, human trafficking, child labor, drug trafficking, money laundering and any type of fraud 

Oxen Cargo is committed to observe the current laws of relevant labor agreements and conventions, as well as the international human rights standards of workers. 

It is absolutely forbidden by the company to use forced labor, human trafficking, child labor and the submission of an employee to a condition analogous to that of a slave. 

The hiring of minors will be permitted provided as apprentices, always respecting the respective laws and never making the school timetable unfeasible. Likewise, the hiring of higher-level trainees/interns will also be permitted, in accordance with the law.  

Oxen Cargo strictly complies with the applicable legislation for the prevention of drug trafficking, terrorism, fraud in general and money laundering, acting to ensure the legitimate origin of the commercial activities and the resources involved. 

The payments made and the receipts of amounts must correspond to goods and services actually provided, with due registration in the company’s accounting. Oxen Cargo does not accept payments to bank accounts of strangers or receipts originating from people or companies that are not related to the commercial transactions carried out. 

If any violation of current labor rules and the above provisions is observed or acknowledged, the interested party must inform the Management. 

9.5. Compliance in import and export operations 

Oxen Cargo fully complies with all laws, Brazilian or not, regarding the import and export of goods and merchandise, and repudiates any undue action by its administrators, employees, third parties, representatives, distributors and business partners, especially with regard to interaction with public agents of any nature.

10. VIOLATIONS TO THE CODE, SANCTIONS AND ACTION MEASURES

All the subjects mentioned in this Code, namely, those who perform activities for or on behalf of Oxen Cargo, are subject to administrative and/or legal disciplinary measures in case of violation of this document, including, but not limited to, suspension, dismissal, termination of employment contract or contractual relationship, depending on the specific case.

11. COMUNICATIONS

Any question related to the application of this Policy should be directed to the Management, in the care of: 

Hernan Wilkins 

hw@oxencargo.com 

+55 (21) 98172-2272 

All Oxen Cargo employees, administrators, representatives, distributors, partners and customers are expected to be aware of possible violations of this Policy, the Code of Ethics and applicable laws. If the occurrence, or even the suspicion, of any type of infraction is found, we should be informed as soon as possible. Communication can be done anonymously, through the contact above. 

 

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