Delivering
excellence®
Delivering
excellence®
Groendyke Transport, Inc. is committed to adhering to the highest possible business ethics and practices and, therefore, has adopted the following Code of Conduct for itself, and endeavors only to engage with vendors and suppliers who abide by these same standards.
Groendyke Transport, Inc. and its vendors and suppliers shall observe all laws and regulations applicable to their individual business concerns and operations, including treaties and international standards regarding the human rights of workers, environmental standards, and fair competition. Groendyke Transport, Inc. shall use all commercially reasonable methods to ensure that its practices align with these laws and regulations and shall endeavor to engage with vendors and suppliers who commit to the same goal.
Groendyke Transport, Inc. shall avoid any actual conflict of interest, as well as the appearance of any conflict of interest in all its business dealings and shall take measures to ensure that its suppliers and vendors do the same. Such avoidance shall include, in situations of uncertainty, the disclosure of any situation which appears to be a conflict of interest. Without limitation, these situations are understood to include demonstrated economic or personal relationships held between employees and the employees of contracted parties, or of employees and the elected officials in jurisdictions in which the Groendyke Transport operates. Personal relationships may manifest as close friendships, or romantic or familial bonds.
Groendyke Transport, Inc. shall act in accordance with national and international competition laws and shall endeavor to engage with vendors and suppliers who do the same. This includes non-participation in any price fixing, market sharing or bid collaboration or rigging with market competitors, or impermissible customer allocation.
Groendyke Transport, Inc. is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including, but not limited to, the U.S. Foreign Corrupt
Practices Act (FCPA) (15 U.S.C. §§ 78dd-1, et seq.), the Bribery of Public Officials and Witnesses law (18 U.S.C. § 201) and related U.S. federal and state laws, as well as other applicable laws related to bribery and corruption among and between business enterprises.
Groendyke Transport, Inc. employees are prohibited from directly or indirectly offering or promising (or authorizing the offer or promise of) anything of value to a U.S. public official or a non-U.S. government official (whether high-ranking or low-ranking personnel) on behalf of Groendyke Transport, Inc. to secure an improper advantage, direct, obtain or retain business, or to improperly influence the actions of said parties. This includes a prohibition of supplying payment to parties where the Groendyke Transport employee knows, or has reason to know, that any portion of the payment will be used for bribes. Bribery involving non-governmental parties in order to obtain an improper business advantage is also prohibited.
“Anything of Value” is understood to mean any cash (including cash equivalents, such as gift cards); material gifts; paying for travel; paying for meals; paying for lodging; paying for entertainment costs; charitable or political donations or contributions; impermissible loans; offers of employment; offers of business or investment opportunities; or any other material benefit not herein mentioned.
“Non-U.S. Government Official” is understood to mean officers or employees of a non-U.S. government, or any department, agency, or instrumentality of such government; non-U.S. political parties or officials or candidates thereof regardless of whether the party is in power; officers or employees of a company or business controlled or owned in whole or in part by a non-U.S. government; officers or employees of a public international organization, such as the European Union; or anyone acting on behalf of those groups listed herein.
“U.S. Public Official” is understood to mean a current or prospective Member of Congress, Delegate, or Resident Commissioner; an officer or employee or person acting for or on behalf of the United States, or any department, agency or branch of government thereof; or a jury.
Groendyke Transport, Inc. shall request that its vendors and suppliers to maintain accurate and timely financial and accounting records of all transactions related to their business with Groendyke Transport, Inc., to retain such records as required by applicable law, and to produce such records when required by law.
Groendyke Transport, Inc. shall control workplace hazards and take the most reasonable precautionary measures against workplace accidents and occupational diseases associated with their business enterprises, and shall endeavor to engage with vendors and suppliers to do the same. This involves supplying appropriate training and ensuring that employees are educated in applicable health and safety issues.
Groendyke Transport, Inc. shall require that, whenever applicable, its vendors and suppliers avoid the use of raw materials which directly or indirectly finance armed groups that are known violators of human rights.
Groendyke Transport, Inc. shall, and shall require that the vendors and suppliers it engages, observe and comply with all applicable laws regarding the use of child labor, forced labor, wages, working hours and conditions, and non-discrimination. Groendyke Transport, Inc. shall ensure that all of its employees are properly and legally documented and qualified to work in the location where they are working. Groendyke Transport, Inc. shall ensure that all its employees’ dealings within the context of their employment shall provide them with a right to life, personal liberty, and personal security. This includes, without limitation: promoting equal opportunities for, and treatment of, employees irrespective of skin color, race, nationality, social background, disabilities, sexual orientation, political or religious conviction, sex or age; refusing to employ any person against their will; refusing to tolerate any unacceptable or illegal treatment of employees; providing fair compensation including, without limitation, a guarantee of the applicable required minimum wage; employing no one under the age of 15 or, in those countries subject to the developing country exception of the International Labour Organization Convention 138, employing no workers under the age of 14.
Groendyke Transport, Inc. shall comply with all applicable environmental laws, regulations, and standards and shall endeavor to engage with vendors and suppliers who share this commitment. Groendyke Transport, Inc. shall minimize environmental pollution to every extent possible.
Groendyke Transport, Inc. shall comply with, and shall require that its suppliers and vendors comply with, all applicable trade, export, and import laws and regulations. This includes, without limitation, ensuring that shipments are reviewed to be in compliance with existing export and trade requirements; avoiding violations of U.S. policies designed to control nuclear proliferation, missile technology, and chemical and biological weapons; not routing goods controlled by the International Traffic in Arms Regulations (ITAR) via arms embargoed countries (unless authorized by the U.S. government); avoiding participation in any trade boycotts not sanctioned by the U.S. government; or not participating in business with any embargoed or sanctioned country.