Code of Conduct

ACE Logistics Group companies adhere to the norms defined by ethical principles and acts at all levels and locations honestly and ethically.

ACE has a zero tolerance policy when it comes to unethical business behavior, such as bribery and corruption. We expect that all of our employees, suppliers and partners adhere to similar standards and act ethically. This ACE Code of Conduct defines the main principles underlying our business activities.

Every employee of ACE who notices or has suspicions relating to violations of the Code of Conduct must immediately notify their direct superior, company managing director or the Group’s quality- and personnel manager.

1. Safe working environment

ACE takes responsibility for its employees and strives to create a safe and healthy working environment for them.

Each individual employee has the responsibility to meet this commitment by following all health and safety procedures and by maintaining a safe and healthy workplace. All workplace accidents, unsafe equipment, unsafe practices and conditions must be reported to direct superior or person responsible for workplace safety. This includes use of alcohol and illegal drugs on the work place.

ACE expects all of its employees, especially managerial staff, to be committed to uphold on-the-job safety at all times.

Each manager is responsible for providing employees of ACE with appropriate health and safety information and training on how to evacuate from buildings safely, how to correctly handle equipment, tools and chemical substances in workplace.

2. Fair working conditions

ACE ensures fair payment and reasonable working hours for its employees in every country, and condemns every form of forced or child labour.

ACE honours the privacy of it’s employees and protects relevant information.

ACE does not allow discrimination against employees, all employees have the right for fair and equal treatment. Employees who have same qualification, experience and work results must receive equal payment for equal amount of work.

Number of working hours must correspond to applicable laws. Regular working week does not exceed the norms derived from the laws of relevant country.

3. Avoiding conflict of interest

ACE expects from its employees and members of its organisational units to behave in such a way, that does not harm the interests and reputation of the company.

Outside work must not involve an ACE competitor nor should it involve the use of ACE equipment or proprietary information such as computers, software, customer information etc.

Except for limited circumstances, ACE should not hire, supervise or have influence over a family member or a close personal relation within ACE unless prior approval is provided by the company Managing Director of relevant area. It is crucial that the selection of partners is based on objective criteria including integrity, quality and performance, and not personal interests.

4. Protecting company assets and information

All employees are required to protect ACE‟s assets and ensure their efficient use. They are to be used for legitimate purposes and for ACE business only. All employees must use ACE‟s communication system for business related purposes only and do so appropriately and according to the laws.

It is forbitten to download or distribute any material that is illegal, offensive or could reflect negatively on ACE‟s reputation. We should also exercise discretion and diligence when drafting e-mails to ensure that our communication is professional and appropriate.

The success of ACE as a business is based on the knowledge of its employees. Employees must ensure that the operational and business secrets of ACE as well as its business partners do not become known outside of the company. It is forbidden to publish operational or business secrets without permission, to pass them to third parties, or to utilise them for one’s own purposes without permission.

5. Protecting the environment

ACE considers itself committed to the sustainable use of natural resources. It is therefore natural that ACE upholds the legal regulations that apply to the protection of the environment.

At ACE, we are committed to ensuring that the impact of our daily activities is minimal and we will continue to monitor our activities in order to ensure continuous improvement.

ACE is committed to minimizing the environmental impact in all its activities, and will comply with the laws and regulations for environmental protection in all countries we operate in. Such commitment and compliance with it is required from all employees of ACE. ACE will continuously evaluate the environmental aspects of its activities to deliver services with no undue environmental impact.

6. Handling the media

Providing the public, including the media, with clear, dialogue-oriented and consistent information strengthens the global image of ACE. Official statements, especially to the media, may therefore only be made after consultation with the Managing Director of relevant area.

7. Anti-corruption principles

7.1 Anti-bribery policy

Bribery means: paying money, promising to pay money, authorizing to pay money, or offering or promising anything of value to a person in a position of trust in order to unduly influence the judgment or conduct of that person.

ACE considers any form of bribery, extortion and corruption unacceptable.

ACE does not engage in the bribery of any public official, political candidate, party, party official, private sector employee or individual. Even where ACE is faced with extortion, in the form of a threat of financial harm or loss of business, bribery of any kind is not allowed. There are no exceptions for small amounts or the so called “facilitation-“ or “grease-“ payments. Furthermore, ACE also prohibits its employees from accepting or soliciting bribes or any other undue advantages.

7.2 Charitable contribution policy

Charitable contributions are donations given to a reputable non-profit institution or organization, for example in the field of disaster relief, without the intent to achieve a business advantage other than goodwill and reputational benefits. Charitable contributions can be financial or in kind (e.g. services) and are often provided in the framework of a company’s corporate social responsibility activities.

ACE allows for charitable contributions only under restricted circumstances:

  • They are not made in order to secure a business deal;
  • They are made for a legitimate purpose;
  • They are given to a recognized and reputable charitable organization, not to an individual. In exceptional cases, with approval from ACE Group managing director, charitable contributions may be made to public or government institutions (e.g. hospitals). Charitable contributions to public or government institutions must not be made to gain an improper business advantage;
  • The recipient of the charitable contribution has no business or private ties whatsoever with ACE and its employees;
  • The amount of the contribution is reasonable;
  • Pre-approval by the company managing director.

7.3 Sponsorship policy

Sponsorships are payments to an organization or an individual, made in cash or in kind. The purpose is to link ACE to a popular event (e.g. sports activity, concert, festival etc), or to a well-known person (e.g. a singer, sportsman, etc). The benefit to ACE is association of its name with the well-known and famous, an association which usually results in more publicity and a stronger brand. The business relationship between the sponsor and the receiving party as well as the commercial advantage for the sponsor distinguishes sponsorship from charitable contributions.

ACE allows for sponsorships only under restricted circumstances:

  • The sponsored party can only be a recognized and reputable organization or individual;
  • The sponsorship payments are made for the benefit of ACE and for a legitimate purpose;
  • The sponsored party has no private ties with ACE employees, such as family relationship;
  • The sponsorship payment is transparently documented in an agreement with the organization;
  • The contribution can be financial or in-kind;
  • The amount is reasonable and inline with local practices;
  • Pre-approval by the company managing director.

7.4 Political contribution policy

A political contribution (also referred to as political donation) is any contribution made to a politician or a political campaign or a political party. This includes payments made directly or indirectly (i.e. through an acquaintance or any other intermediary), and contributions in cash or in kind.

ACE employees are prohibited from making political contributions in any form for or on behalf of ACE. Personal contributions by ACE employees may be made in their own capacity, if they are not made with the intention or result of directly or indirectly benefiting ACE and if no ACE funds, resources, time or assets are involved.

Furthermore, ACE employees must not use third parties (i.e. agents, subcontractors, consultants or other intermediaries) to make political contributions on ACE’s behalf.

7.5 Gift and entertainment policy

ACE allows the offering and receiving of gifts, hospitality, entertainment and expenses if they are:

  • in compliance with relevant laws and acceptable according to local culture;
  • offered/promised/given or received openly and unconditionally;
  • given without the intention of obtaining or retaining any direct business advantage;
  • of reasonable/modest value, i.e. insignificant compared with local average salaries;
  • given or received infrequently;
  • in good taste, i.e. not offending the feelings of others in relation to disability, gender, culture, nationality, etc.;
  • properly recorded and documented according to local legislation;
  • pre-approval by the company managing director.

 “Gifts” are benefits given to an institution or an individual, either in the public or the private sector without the intent of achieving a business advantage in return other than goodwill and reputational benefits. Example: office trinkets.

“Hospitality and Entertainment” include occasional invitations to ordinary sports, theatre or other cultural events as well as invitations to modest meals / refreshments or customer events.

7.5.1 Additional requirements for gifts

Private sector gifts have to be given in good faith, as a gesture of goodwill or to further a good cause. Furthermore, gifts must always be given in kind and never in cash.

Differences between the public sector and private sector need to be considered:

Public sector

Most countries have tight restrictions in regards to the value of gifts which can be given to public officials. Therefore all gifts to public officials (exceptions are promotional materials such as pens, paperweights, T-shirts or other items bearing the Company logo) must be pre-approved by the corporate manager. All gifts given to officials must stay within the cost limits specified in local law and must be recorded to a central list.

Private sector

Giving gifts: all gifts that are given to third parties must be approved by the company managing director. Exceptions are promotional materials such as pens, paperweights, T-shirts or other items bearing the Company logo. Gifts must be of modest value and reflect good local customs.

Receiving gifts: all gifts that are accepted by ACE employees from business partners must be of modest value and reflect good local customs.

7.5.2 Additional requirements for hospitality and entertainment

Hospitality and entertainment must be secondary and related to the main business purpose. Furthermore, hospitality and entertainment must always be in kind and never in cash.

Differences between the public sector and private sector need to be considered:

Public sector

Most countries have tight restrictions in regards to the value of hospitality and entertainment that can be provided to public officials. Therefore all hospitality and entertainment provided for public officials must be pre-approved by ACE Group managing director. All entertainment provided to officials must stay within the values specified in local law and must be documented according to local law.

 Private sector

Entertaining: expenses for entertaining third parties (dinners, lunches etc.) must be of modest value and reflect good local customs.

Should this value be exceeded (i.e. sponsoring events etc.), then the company managing director needs to approve this in writing prior to occurring the expense.

Receiving entertainment: expenses for receiving entertainment by business partners (dinners, lunches etc.) must be of modest value and reflect good local customs. Should this value be exceeded (i.e. sponsoring events, conferences etc.), then the company managing director needs to approve this in writing prior to the event.

7.5.3 Additional requirements for expenses

Only the expenses of reputable institutions or organizations should be reimbursed.

Reimbursement should never be transferred to an individual’s personal bank account.

8. Violations

Non-adherence to the Code of Conduct is followed by investigation of alleged violation, which can result in disciplinary measures as specified by law.

Every employee must must immediately notify their direct superior, company managing director or the Group’s quality- and personnel manager of the violation of the Code of Conduct.

If you have information of a violation, please report to the Quaity- and Personnel Manager of ACE Logistics Group, Inge Parring, at Inge.parring@ace.ee or by phone +372 509 2755.

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