CODE OF CONDUCT & QUALITY POLICY

FOR YOU, COLLABORATOR 

The present Code of Ethics and Conduct is directed to all employees of OXEN CARGO and aims to serve as a reference to guide their actions and decision making. It also aims to define the ethical principles and norms of conduct that must guide the interactions of all levels of the organization, as well as the norms of external conduct with suppliers, clients, partners and any other third parties involved in our operation.  

It is our fundamental principle to follow all laws and regulations applicable to our business and to conduct our activities in an honest and ethical manner. All employees must read this document, know it and make it known, observe and uphold it, and commit to complying with it in full. 

OUR PRESIDENT 

“Since the beginning of OXEN CARGO’s activities, I have always sought to create an environment of trust and transparency among our employees and with our customers. For this, we are always trying to choose people who share our culture and have the ambition to grow and evolve together with us.   

We hand-pick our customers, suppliers, and partners, so that all our work fits in with our principles and values, in every part of the supply chain. Thank you for being part of our team, together we will build a great company.”  

– Hernan Wilkins  

WHO WE ARE  

We are an air, ocean and road transportation service company, headquartered in the city of Rio de Janeiro, with geographic coverage throughout the national territory. We are specialists in delivering fast, simple and humanized solutions in the global logistics industry. We relentlessly break down the barriers between customer and supplier, establishing open lines of communication, providing a friendly and familiar relationship for all our customers’ needs.  

We are an ISO 9001:2015 certified company and guarantee in our service an accredited quality management system respecting international standards. We are also an IATA certified agent and as members, we currently cooperate with over 290 logistics partners worldwide who have passed strict admission criteria, proving to be safe, reliable and helpful. We are DUN & BRADSTREET registered, we want to be transparent and demonstrate the reliability and financial stability of our company by being present in the largest business credit file in the world.  

OUR PURPOSE

To create an environment of trust and transparency, so that everyone can transcend their maximum potential. 

OUR MISSION 

To humanize the logistics experience, delivering smart solutions with friendliness. 

OUR VISION  

We want to be an international company recognized by the trust and professionalism of our services and admired by our collaborators. 

OUR VALUES  

  • Integrity: We have a strong commitment to the truth; 
  • Cooperation: We believe that together we are stronger and go further; 
  • Bravery: We encourage our employees to reach their full potential; 
  • Responsibility: We commit to our challenges and own our deliverables; 
  • Loyalty: we value cultivating partners through a long-lasting relationship of trust and mutual respect; 
  • Progress: We seek constant change for the sake of improvement and renewal of our processes.   

OUR WORK ENVIRONMENT  

We know that a harmonious, pleasant, and safe work environment is what everyone seeks, whether employers or employees. So that we can continue to provide a healthy, high-level environment in which to work, we have highlighted some of our internal conduct guidelines.  

  • Working Hours and Absence

We believe that respecting the working hours demonstrates respect and commitment to the team, customers, and suppliers who know our working hours and expect us to be ready, prepared, and available within these hours to serve them well. Commitment, clear and transparent communication about absences and absences must be practiced. Planned absences should be communicated in advance.  

We know that unforeseen things happen, but we expect our employees to plan as well as possible, weighing personal and professional needs. Emergencies and unplanned situations should also be communicated as soon as possible. Reporting must follow the company’s hierarchical structure, that is, the employee must always communicate to his/her direct leader and to the Human Resources sector. 

  • Occupational Health and Safety  

We are concerned with meeting all the legal and pertinent requirements applicable to the business regarding Occupational Health and Safety, seeking continuous improvement of our processes. We are concerned with maintaining a safe work environment and the physical integrity of all those who relate to us, identifying risks in advance and eliminating and/or controlling any and all potential risks to the physical integrity and health of our employees. 

Therefore, everyone is expected to:  

  1. Act in accordance with Occupational Safety regulations and procedures; Ensure and preserve cleanliness, organization and safety in all our facilities;  
  2. Perform periodic medical examinations, which attest to their fitness to perform their activities;  
  3. Participate in campaigns aimed at health and safety at work;  
  4. Communicate to the immediate manager when you are undergoing medical treatment or taking medication that might interfere with your reflexes and reasoning, and consequently, with your safety while performing your job;  
  5. Deliver the medical certificates or attendance statements to the Human Resources area, when necessary; 
  6. Are outside the safety and occupational health processes:  
  7. Smoking on the institution’s premises;  
  8. Consuming, selling or being under the effect of alcoholic beverages or illicit substances during the performance of their professional activities or inside the organization; 
  9. Using a firearm or white weapon inside the company’s premises, even if the employee holds a weapon for personal defense or sports, except in security positions.  
  •  Personal Presentation  

We believe that the care taken with personal cleanliness and presentation are part of the set of attitudes that define a good professional performance. The use of clothes in accordance with the dress code of our industry, event, or commitment is essential for a good presentation.  

In addition to the type of clothing, be careful with everything that makes up your look, such as beard, hair, accessories, cleanliness of clothing, personal hygiene, use of perfume, etc. Hats are not allowed, nor are transparent or inappropriate clothes for the professional environment.  

  • Use and Preservation of Assets  

Our assets are made up in part of the equipment, facilities, and structures made available to offer a safe and comfortable work environment. We believe that making good use of these assets is a way of showing respect and gratitude for all the effort made to offer this infrastructure.  

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 our employees, we have a kitchen and pantry available. In this scenario, it is worth pointing out some peaceful usage rules, as follows: 

  1. When using utensils, employees must wash them immediately after finishing use, dry them, and put them away in the appropriate storage place; 
  2. Do not leave dirty dishes, glasses, cutlery or other objects in the sink; 
  3. Do not leave food scraps in the sink clogging the drain or on the table; 
  4. Do not leave food for more than two (2) days in the refrigerator;  
  5. When using the microwave oven remember to protect the food so that the contents do not spill or overflow, and if it happens, please clean it up for the next use;  
  6. Handling or taking possession of other people’s food is not allowed;  
  7. It is not allowed to have meals on the work table.  

Employees who use the kitchen and the pantry must help maintain order and cleanliness in the places or utensils they use. Failure to observe and disrespect these rules will allow the company to throw away the food and objects improperly stored and to warn of conduct considered inappropriate. 

Therefore, it is the employees’ duty to use the spaces properly, contributing to their conservation. We value care, keeping the environments, especially the common areas, clean and organized according to internal recommendations and instructions.  

In cases of urgency, you can use the company phone for private purposes, as long as authorized by the area manager. Lists, raffles, products for raffles and/or sale, and related items may not circulate on company premises.  

The entry of salespeople and representatives of personal items is not allowed in the company, as well as private commerce and the loan of money in the loan sharking system among employees.   

It is forbidden to use the company’s financial and technological systems and resources to carry out personal activities or activities that do not fall within the professional activities carried out for the company. Any act that may cause damage to the intellectual or physical assets of the organization is considered unacceptable behavior. 

Only with prior authorization from management may there be photography and/or filming inside the company, as well as receiving private orders and holding parties (happy hour) in the workplace and during working hours. 

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

  • Information Confidentiality and Security Policy  

The company’s information system is considered a valuable asset. The transmission of any unauthorized information to third parties could affect the company.  

We believe it is our duty to protect the operational security and privacy of the processes we manage and our business strategy. We fully comply with the commitments stipulated in the Internal Information Security and Document Quality Policy.  

It is forbidden to breach the duty of confidentiality, which is manifested by the use for private purposes or in the form of passing on to third parties, of any and all information, patented or not, of 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 experience, documents, contracts, papers, studies, opinions, and research to which the integrant has access: 

  1. By any physical medium (e.g., express documents, manuscripts, photographs, etc.);
  2. By any form recorded on electronic media (e-mail, USB flash drive, etc.);
  3. Orally.

Thus, confidential internal or proprietary company information that has not been disclosed to the general public must be kept confidential. Non-public information of 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 manifest oneself on behalf of the company, including on social networks, blogs, or any other type of vehicle or media, without prior authorization.  

In case of breach of professional secrecy, duly proven, by the collaborator, it will enable the immediate termination of any contract signed between the parties. All losses and damages suffered by the company will be ascertained, including those of a moral or competitive nature.  

The maintenance of information confidentiality persists, even after the employee’s dismissal. For more information, the Information Security and Document Quality Policy can be consulted and is available internally. 

  • Interpersonal and Subordination Relations 

The employee must respect the hierarchy and the determinations established by his superiors, fulfilling his daily obligations. He/she must also maintain the principles of respect for the dignity of the human being without any distinction in relation to subordinates, coworkers, superiors, suppliers, and customers, and his/her position or hierarchy must not be used to belittle or treat badly any person. 

Possible disagreements with the objective or the way in which the tasks are carried out do not entitle anyone to be treated rudely or inappropriately. Respect is fundamental in any human relationship, and we make it a point to always act with it. 

We also repudiate any kind of embarrassment and coercion, such as pranks or bad jokes in the work environment, subjecting violators to the sanctions and penalties provided for in this code. Such practices must be communicated to the Human Resources area, ensuring anonymity. 

  • Internal Relationship Rules  

The rules of conduct for internal relations must be based on the company’s values. Positive and constructive behavior will be praised, and there will be administrative sanctions for behavior that is considered unacceptable.  

The company’s employees must work together in a cordial and non-competitive way, and the progression system is governed by meritocracy. 

We define as unacceptable behaviors for any hierarchical level, position or function the following cases: 

  1. Moral harassment; 
  2. Sexual harassment 
  3. Physical and verbal aggression; 
  4. Disrespectful, discourteous, threatening, and discriminatory treatment; 
  5. Discrimination and/or any kind of prejudice due to social origin, race, color, gender, age, religion, political ideology, physical feature or sexual orientation; 
  6. Propagation of rumors, pornography, games, or political party propaganda; 
  • Affectionate Relationship among Coworkers 

All employees must relate within the company with professionalism, not letting possible affective relationships influence their actions and performance. Affective relationships between coworkers will only be allowed if they occur after the admission of one of the members, without interfering in the professional ambit and preserving respect within the work environment.  

The existence of this type of relationship must be communicated in writing to the Human Resources area, and there can be no direct subordinate relationship between the employees involved, in order to avoid internal conflicts and/or conflicts of interest.  

  • Indication/hiring of family members of employees and former employees 

Indication and/or hiring of family members of employees and/or former employees with a first-degree relationship will be avoided or strictly evaluated by the Human Resources area in order to avoid favoritism and conflicts of interest.  

In case any conduct is observed that configures or seems to configure any of the situations mentioned above, the interested party must communicate the case to the area responsible for the Recruitment and Selection process, making the report and guaranteeing anonymity.  

OUR EXTERNAL RELATIONS NORMS

  • Relationship with Clients 

Our customer service is based on the company’s values and focused on respect, courtesy, and efficiency. Our team is trained and able to provide services based on the highest quality standards, seeking to establish a relationship of mutual trust, conducting our business fairly, adopting communication based on truthful information about our products and services.  

  • Relationship with Competitors 

We respect the rules of the free market and do not condone any action by employees that results in unfair competition or in obtaining undue competitive advantage. In this way, the company bases its actions in defense of the rules foreseen in the national and international legislation for the defense of competition and, thus, the primacy that free competition must always prevail in the minds of our collaborators. 

  • Relationship with Suppliers, Commercial Partners, Representatives, and Distributors 

Our suppliers, business partners, representatives, and distributors are extremely important parts of the company’s business and operation, and their behavior must be guided by the principles expressed in this document.  

However, any inappropriate conduct on their part can have a serious impact on our image and reputation. For this reason, our principle is to work with reliable suppliers and business partners, making impartial choices and treating them without privileges, favoritism, or discrimination of any kind.  

Thus, it is up to the person responsible for the relationship to make the analysis prior to contracting, in which it will be verified if 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, and criminal legislation, among others; 
  2. Prohibition of acts of corruption
  3. Respect for human rights; 
  4. Take responsibility for the health and safety of its employees;
  5. Act in accordance with applicable local and international standards relating to environmental protection.
  • Relationship with Public Bodies, Public Agents and Politically Exposed Persons  
The administrators, employees, third parties, commercial representatives, distributors and business partners, when acting on behalf of the company, must strictly comply with all applicable laws and regulations as well as the determinations of this Code of Conduct and the Anti-Corruption Policy. 

All transactions with national or foreign public administration agents must be carried out fairly, transparently, ethically, and morally. When a demand for inspection is presented by public agencies, such as, but not limited to, the Internal Revenue Service, Health Inspection, and the Labor Prosecution Service, the management must be immediately communicated so that it can adopt the appropriate measures with the Legal Department. This communication should preferably be made in writing and in a manner sufficient to clarify the issue. 

When relating to public agents and politically exposed people, it is strictly forbidden to use the name Oxen Cargo to deal with personal matters of any nature, as well as the offering or receiving of any undue advantage. 

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

  • Relationship with Third Parties  
We do not allow any commercial relationship or operation that, directly or indirectly, may put our image or reputation at risk.  Suppliers, service providers, commercial partners, distributors and clients will be contracted/accepted using objective criteria, when applicable, such as: product/service quality, price, commercial and social reputation.  

Hiring third parties or accepting clients that have in their staff any public agents, or politically exposed people, or that have family or kinship with them, must be avoided. In case it is observed or becomes aware of the hiring of third parties in non-compliance with this code, or with the Anti-Corruption Policy, the management must be immediately communicated.  

For more information, the Anticorruption Policy in effect can be consulted and is available internally. 

Relationship with the Logistics Chain  

According to art.2 of RFB Normative Instruction No. 1598/2015, the AEO (Authorized Economic Operator) Program is governed by the following principles, which we strictly follow: 

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

  • Business Relationship  
Gifts, presents and entertainment that do not cost or appear to cost more than a quarter of a minimum wage, such as Baskets, chocolates, wines; 

  1. Diaries, notebooks, pens, pencils or calendars; 
  2. Lunch and/or dinner;  
  3. OXEN CARGO brand merchandising.
For any gift, present or entertainment received, Board approval is required for acceptance. They must never be offered in corrupt or malicious behavior.  

In the same sense, no gifts may be offered/accepted to public officials, politically exposed people and their families, from representatives of other companies involved in a competition or in a bidding process, as compensation for past business deals or with the intention of enabling current or future contracts, nor as a form of bribery. 

  • Prohibition of Political and Election Contributions  
We are a non-partisan company and, therefore, we forbid any activity of support and/or donations to political parties and/or candidates of any position. Likewise, we do not allow political or electoral contributions in our name, regardless of the nature of the asset or resource.  

  • Public Contracts and Biddings  
All participation by our managers, employees, commercial representatives, distributors, and partners in public contracts and bidding processes must be guided by respect for legal rules, ethics, and transparency. Informal contacts with public agents involved in the contracting or bidding process are prohibited. 

It is forbidden to offer gifts, hospitality, invitations or presents of any nature to public agents responsible for the hiring or bidding. 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, the maintenance of contact with eventual competing companies with the objective of reducing the competition or fraud the contest is forbidden. 

Should irregular conduct be observed or become aware of in the course of a public contracting or bidding process, please contact the management. 

  • Compliance in Import and Export Operations
We fully comply with all laws, Brazilian or otherwise, regarding the import and export of goods and repudiates any improper action of its administrators, employees, third parties, representatives, distributors and business partners, especially when it comes to interaction with public agents of any nature. 

QUALITY POLICY  

We are committed to act in accordance with our internal Quality Policy. We are not just a family company, we are a family that constantly strives to offer a more personalized logistics experience. 

We relentlessly insist on reducing the contact barriers between the customer and the provider, establishing a more open line of communication and ultimately giving a familiar face to the “middleman”.  

No matter the size of the cargo, we will accompany the customer every step of the way, even after their shipment has been delivered. We work to exceed our customers’ expectations by following the necessary legal requirements, identifying and solving external factors that may affect the final outcome of the service provided. 

We seek the right partners and suppliers who share our values to offer the best possible service to our customers, understanding their needs, structure, and objectives. 

The Quality policy can be consulted at any time and is available internally. 

HUMAN RESOURCES POLICY  

Our human resources policy aims to clarify the way the company operates with regard to people management. It aims to expose and establish clear rules related to the processes of: recruitment and selection, training and development, benefits, positions and salaries, performance evaluation, experience period evaluation, among others.  

These rules are important directing tools that ensure standardization and equity in the way people are treated and relate within the company. Moreover, we can say that the human resources policy makes everyone aware of how to act in each situation. In other words, the HR policy helps a lot in people management. 

The Human Resources Policy can be consulted at any time and is available internally. 

PRIVACY POLICY  

We value you and respect your privacy, regarding any information we may collect from you on our site or any other application we own and operate. For this reason, we provide our employees, customers, suppliers, representatives, distributors and partners with transparency about our personal data processing activities and our practices to protect the security and privacy of our users,  

The Privacy Policy may be consulted at any time and is available internally and through our website.  

INFORMATION SECURITY POLICY

We aim to preserve the confidentiality, integrity and availability of the information used by our employees in the performance of their activities, describing the appropriate conduct for its handling, control, protection and disposal, as well as establishing rules for physical access to its facilities. 

It is based on the recommendations proposed by the AEO Certification guidelines on information security management and by the good practices of ISO 9001 Quality Certification (Norm ABNT NBR ISO 9001:2015), as well as in accordance with the laws in force in our country. 

The Information Security Policy may be consulted at any time and is available internally and through our website. 

ANTI-CORRUPTION POLICY  

We do not condone and strongly repudiate any form of corruption, regardless of whether the person involved is a public official, politically exposed person, private-sector individual or corporation. For this reason, we prohibit any payment or promise of payment that violates the laws in general.  

All our employees, customers, suppliers, representatives, distributors and partners must always act respecting the determinations of the Anti-corruption Laws of the Brazilian Penal Code and of the other countries in which we operate. The Anticorruption policy may be consulted at any time and is available internally and through our website. 

 VIOLATIONS OF THE CODE 

All subjects mentioned in this Code, namely those who perform activities for or on behalf of the company, 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 the employment contract or of the contractual relationship, depending on the specific case and occurred.  

In applying the sanctions, the nature and seriousness of the violation will be considered, always taking into account the human resources standards and the applicable legislation. Any questions related to the application of this Code of Ethics should be directed to the Human Resources sector through the contact: rh@oxencargo.com 

POLICY CHANGES 

This Policy may be modified from time to time, according to the requirements of the applicable legislation. Date of last revision: May 25, 2022