Code of Business Ethics

The policy of LXGlobal is to comply with all governmental laws, rules, and regulations applicable to its business.

The Company’s Ethics policy does not stop there. Even where the law is permissive, the Company chooses the course of highest integrity. Local customs and traditions differ from place to place, and this must be recognized. But honesty is not subject to criticism in any culture. Shades of dishonesty simply invite demoralizing and reprehensible judgments. A well-founded reputation for scrupulous dealing is itself a priceless corporate asset.

The Company cares how results are obtained, not just that they are obtained. Directors and employees should deal fairly with each other and with the Company’s suppliers, customers, competitors, and other third parties.

The Company expects compliance with its standard of integrity throughout the organization and will not tolerate employees who achieve results at the cost of violation of law or who deal unscrupulously. The Company’s directors and officers support, and expect the Company’s employees to support, any employee who passes up an opportunity or advantage that would sacrifice ethical standards.

It is the Company’s policy that all transactions will be accurately reflected in its books and records. This, of course, means that falsification of books and records and the creation or maintenance of any off-the-record bank accounts are strictly prohibited. Employees are expected to record all transactions accurately in the Company’s books and records, and to be honest and forthcoming with the Company’s internal and independent auditors.

The Company expects candor from employees at all levels and adherence to its policies and internal controls. One harm, which results, when employees conceal information from higher management or the auditors, is that other employees think they are being given a signal that the Company’s policies and internal controls can be ignored when they are inconvenient. That can result in corruption and demoralization of an organization. The Company’s system of management will not work without honesty, including honest bookkeeping, honest budget proposals, and honest economic evaluation of projects.

It is the Company’s policy to make full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company keeps and for public communications. All employees are responsible for reporting material information known to them to higher management so that the information will be available to senior executives responsible for making disclosure decisions.

Gifts and Entertainment Policy

It is the policy of LXGlobal Company to base commercial decisions on commercial criteria. That policy serves the Company’s business interests and fosters constructive relationships with organizations and individuals doing business, or seeking to do business, with the Company. In many cultures, those constructive relationships may include incidental business gifts and entertainment. Directors, officers, and employees providing or receiving third-party gifts and entertainment in their corporate capacities are expected to exercise good judgment in each case, taking into account pertinent circumstances, including the character of the gift or entertainment; its purpose; its appearance; the positions of the persons providing and receiving the gift or entertainment; the business context; reciprocity; and applicable laws and social norms. All expenditures for gifts and entertainment provided by the Company must be accurately recorded in the books and records of the Company.

Conflicts of interest can arise where employees, their friends or members of their families are offered gifts, hospitality or favours (including but not limited to receipt of any preferential treatment, discount coupons, gift vouchers, travel expenses of any nature, appliances, cases of liquor, personal expenses paid on the employee’s behalf) which may or could be perceived to, influence their judgement in relation to business transaction.

As a general rule employees may not accept gifts, hospitality or favours. The acceptance of the following however, would not be contrary to this policy.

  • promotional material;

  • reasonable business entertainment such as business breakfasts, lunches, cocktail parties or dinners;

  • personal hospitality to local events such as sporting events or theatres;

  • gifts of a value lower than the threshold set by LogistiQ Xpeditors from time to time, the details of which are available from the Human Resources Department;

  • other reasonable business entertainment which includes accommodation provided that it does not include payment of airfares;

Employees are obliged to disclose all gifts, hospitality or favours received by them, their friends, their family or partners, other than those listed above, from customers, suppliers or other related or potential business partners, to their managers who must report same to the Divisional Managing Director for inclusion in a gifts register held by the Chief Financial Officer. The register will be scrutinised by internal Audit on a regular basis.

The giving of gifts, hospitality or favours is similarly limited to the nature described above.

The giving or receiving of gifts or cash equivalents is always prohibited.

Employees should also respect any similar codes of their customers, suppliers and/or other parties with whom LogistiQ Xpeditors has dealings from time to time.

Any deviation from this section of this Code must be specifically authorised by an executive manager in writing in advance of any gift, hospitality or favour. Deviations may only be authorised in exceptional circumstances.

Political Activities Policy

It is the policy of LXGlobal Company to refrain from making contributions to political candidates and political parties, except as permitted by applicable laws and authorized by the Board of Directors.

It is the Company’s policy to communicate information and views on issues of public concern that have an important impact on the Company.

The Company considers that registering and voting, contributing financially to the party or candidate of one’s choice, keeping informed on political matters, serving in civic bodies, and campaigning and office holding at local, state, and national levels are important rights and responsibilities of the citizens of a democracy.

Directors, officers, and employees engaging in political activities are expected to do so as private citizens and not as representatives of the Company. Personal, lawful, political contributions and decisions not to make contributions will not influence compensation, job security, or opportunities for advancement.


Employees may not divulge confidential information to any external party, unauthorised persons or bodies relating to any aspect of his/her work or any of the operations or processes of LogistiQ Xpeditors. Such information shall include but not limited to methods/processes, computer software, documents, any information on customers including customer lists or leads, programmes, trade secrets, technical information which could be damaging to LogistiQ Xpeditors operations or which could benefit other parties to the detriment of LogistiQ Xpeditors. Such restrictions shall apply during and after the employee’s employment with LogistiQ Xpeditors.

Employees who have access to LogistiQ Xpeditors records containing personal employment identification, medical and psychological information about LogistiQ Xpeditors employees and co-workers must ensure that these personal records and the information contained therein are not misused or improperly disclosed.

Compliance with Laws and Regulations

LogistiQ Xpeditors will not tolerate any violation of applicable laws and regulations by any employee. All employees must ensure that their conduct cannot be interpreted as being a contravention of applicable laws and regulations governing the operations of LogistiQ Xpeditors.


Conflict of Interest

A conflict of interest occurs when an individual’s personal interest may possibly interfere in any way with the performance of his or her duties or the best interest of LogistiQ Xpeditors. Employees must not use their positions or knowledge gained through their employment with LogistiQ Xpeditors for private or personal advantage in a manner that a conflict or a perception of a conflict arises between LogistiQ Xpeditors’ interest and their personal interest.

Relationship with Customers and Suppliers

The relationship with customers and suppliers may give rise to many situations where conflict of interest, real or perceived may arise. Employees must ensure that they maintain their independence and are seen to be independent from any person or business that has or may have a contractual relationship with LogistiQ Xpeditors. If an employee deals directly with a customer or supplier, he or she must not engage in any private financial relationship with that customer or supplier or any of its owners, shareholders, directors, partner or members.

Employees shall not invest or acquire any financial interest for their own account in any business organisation or with any of the owners, shareholders, directors, partners or members of any value with LogistiQ Xpeditors other than normal share dealings through a recognised stock exchange.

Employees may not purchase goods and/or services for personal use with LogistiQ Xpeditors funds.


LogistiQ Xpeditors remunerates employees based upon formal remuneration scales and rates for salaries, wages, fringe benefits and other regular remuneration. No employee may receive commissions or other remuneration related to the sale of products or assets of LogistiQ Xpeditors, except as specifically provided under an individual’s term of employment.

Employees may not receive any money or item of value other than regular remuneration and incentives either directly or indirectly for negotiating, procuring, recommending or aiding in any transaction made on behalf of LogistiQ Xpeditors, or have any direct or indirect financial interest in such transaction.

LogistiQ Xpeditors specifically prohibits the acceptance of kickbacks or commissions from any supplier or other party. Any breach of this rule will result in immediate termination and possibly, in litigation.


Outside Employment, Directorships and Activities

Employees may not take up extraneous employment in any other business or undertaking, without first making full disclosure of all facts and obtaining prior written permission from the Human Resources Manager who shall forward a copy of such written permission to the Executive Directors.

Approval will generally only be granted for external directorships where there is a Company business requirement. A copy of the approval by the Managing Director of the business must be placed on the employee’s personnel file. Fees received for any outside directorship must be paid to LogistiQ Xpeditors.

Employees may not participate as presenters in any external business seminars or conferences without the written permission of the Executive Directors. Clarity in this area can be obtained from the Human Resources Department.

Company Funds and Property

All employees who have access to Company funds and property in any form must at all times follow prescribed procedures for recording, handling and protecting such.

Employees must at all times ensure that LogistiQ Xpeditors’ funds and property are used only for legitimate Company business purpose.

Where an employee’s position requires Company funds to be spent, it is the individual’s responsibility to use good judgement on LogistiQ Xpeditors' behalf and to ensure that appropriate value is received by LogistiQ Xpeditors for such expenditure.

Any inventions, copyrights, patents or other intellectual property which may arise out of the employment with LogistiQ Xpeditors and/or use of LogistiQ Xpeditors facilities, will automatically become the property of LogistiQ Xpeditors without exception.

If employees become aware of any evidence that LogistiQ Xpeditor’s funds or property may have been used fraudulently or improperly, they should immediately and confidentially advise LogistiQ Xpeditors as set out in this code.


Company Records

Accurate and reliable records across many areas are required to meet the corporate governance requirements and to manage the business. The integrity of LogistiQ Xpeditors’ records depends on the validity, accuracy and completeness of information supporting the entries to LogistiQ Xpeditors’ books of account and other records. Records must therefore be developed and maintained with accuracy, truthfulness and diligence and in accordance with group, divisional and operational policies and guidelines.

Employees may not make nor complete any false or misleading business records or issue misrepresentative communications of any nature.

Employees are prohibited from taking any original copies of Company records and communications and/or any other form of Company information on termination of their services with the group.

Company Communications

Company information will be disclosed to the public, investors, analysts and the media only by executive management to avoid inappropriate publicity and to ensure that every person with an interest in LogistiQ Xpeditors or its affairs will have equal access to information.

Electronic media and services provided by LogistiQ Xpeditors (such as computers, e-mail telephone, voice mail, fax machines and the internet) are LogistiQ Xpeditors property, and their purpose is to facilitate LogistiQ Xpeditors business. This area is governed by the LogistiQ Xpeditors IT Acceptable Use Policy as amended from time to time.  Specifically, electronic media and service are not to be used for knowingly transmitting, retrieving or storage of any communications which are:

  • Of a racially or sexually discriminatory or harassing nature;

  • Derogatory to any individual or group;

  • Obscene or pornographic;

  • Defamatory or threatening in nature

  • “chain letters”;

  • For any purpose which is illegal;

  • Religious or political in nature ;

  • Used to solicit funds, collect signatures, conduct membership drives, distribute literature or gifts, sell merchandise or services or carry on any other form of business without approval of the Executive Director

  • against LogistiQ Xpeditors’ policy; or

  • contrary to LogistiQ Xpeditors’ interest


Limited occasional or incidental use of electronic media for personal, non-business purpose is acceptable; however, employees must demonstrate that such use:

  • does not affect performance or disrupt others;

  • is truly occasional in nature;

  • is not in the furtherance of the business activities of any entity or enterprise other than LogistiQ Xpeditors;

  • does not put LogistiQ Xpeditors IT facilities, software or information at risk;

  • does not result in any excessive cost to LogistiQ Xpeditors

LogistiQ Xpeditors reserve the right to access, monitor, review and disclose any information transmitted, received or stored, using LogistiQ Xpeditors’ electronic equipment, to the extent necessary to ensure that electronic media and services are not excessively used for personal purposes and that their use is in compliance with the law and this code. Any actions taken by LogistiQ Xpeditors in this regard shall comply with relevant legislation.