COM-POL-001-V11ENG · Corporate Governance
1. Purpose and Commitment
L.O. Trading Corp. (LOT), Servicios Logísticos Internacionales S.A.S. (SLI), S.V. L.O. Trading S.A. de C.V. (SVL), CN L.O. Trading Ltd (CNL) and EUR L.O. Trading GmbH (EUR) are committed to conducting business with integrity, transparency, accountability, and respect for applicable laws, regulations, and ethical business standards.
The Company recognizes that sustainable business success depends on maintaining the trust of employees, customers, suppliers, business partners, regulatory authorities, and other stakeholders. Accordingly, the Company promotes a culture of compliance and ethical conduct throughout its operations and business relationships.
This Compliance and Ethics Policy establishes the fundamental principles that guide the Company's approach to legal compliance, responsible business conduct, human rights, environmental responsibility, information protection, fair competition, and ethical decision-making.
The Company expects all employees, contractors, suppliers, business partners, and third parties acting on its behalf to comply with applicable laws, act responsibly, and support the principles outlined in this Policy.
This Policy serves as the foundation of the Company's Compliance and Ethics Framework and is supported by additional policies, codes, procedures, and related governance documents that provide more detailed requirements and guidance.
2. Scope
This Policy applies to:
- L.O. Trading Corp. (LOT).
- Servicios Logísticos Internacionales S.A.S. (SLI).
- EUR L.O. Trading GmbH (EUR).
- S.V. L.O. Trading S.A. de C.V. (SVL)
- CN L.O. Trading Ltd (CNL)
It also applies to:
- All employees, regardless of position or employment status.
- Directors, managers, and company representatives.
- Contractors, consultants, and temporary personnel.
- Suppliers, service providers, and business partners.
- Agents, intermediaries, and third parties acting on behalf of the Company.
All individuals and organizations subject to this Policy are expected to conduct their activities in a manner consistent with applicable laws, ethical business standards, and the principles established herein.
Compliance with this Policy is a condition of employment, engagement, or business relationship with the Company.
3. Compliance and Ethics Principles.
The Company's Compliance and Ethics Framework is founded on the following principles, which guide business decisions, professional conduct, and relationships with stakeholders.
3.1. Integrity: The Company conducts its activities honestly, ethically, and consistently with its values. Integrity is fundamental to building trust and maintaining long-term business relationships.
3.2. Transparency: Business decisions, communications, and transactions should be accurate, truthful, appropriately documented, and capable of being reviewed when necessary.
3.3. Accountability: Individuals are responsible for their actions, decisions, and conduct. The Company promotes accountability at all levels of the organization and expects individuals to act in the best interests of the Company and its stakeholders.
3.4. Respect: The Company is committed to fostering a professional environment based on dignity, fairness, inclusion, mutual respect, and consideration for the rights and interests of others.
3.5. Compliance: The Company is committed to complying with applicable laws, regulations, contractual obligations, internal policies, and recognized standards relevant to its operations.
3.6. Sustainability: The Company recognizes that ethical conduct, responsible business practices, environmental stewardship, social responsibility, and effective governance contribute to long-term business success and sustainable value creation.
4. Ethical Business Conduct
The Company expects all individuals and organizations subject to this Policy to conduct their activities in a lawful, ethical, professional, and responsible manner.
Business decisions should be based on objective criteria, sound judgment, and the legitimate interests of the Company, while respecting applicable laws, contractual obligations, and ethical standards.
The Company promotes a culture where honesty, fairness, professionalism, and responsible decision-making are valued and encouraged at all levels of the organization.
Individuals are expected to avoid conduct that could compromise the Company's integrity, reputation, stakeholder trust, or compliance obligations.
The Company does not tolerate fraudulent, deceptive, dishonest, or unethical practices and expects concerns regarding potential misconduct to be addressed appropriately and in accordance with applicable policies and procedures.
More detailed requirements related to anti-bribery, anti-corruption, conflicts of interest, business partner expectations, human rights, data protection, and other compliance topics are addressed in the Company's related policies and governance documents.
5. Anti-Bribery and Anti-Corruption
The Company is committed to conducting business with integrity and maintaining a zero-tolerance approach toward bribery, corruption, fraud, improper influence, and other forms of unethical conduct.
The Company prohibits any activity intended to improperly influence business decisions, obtain unfair advantages, circumvent legal requirements, or compromise the integrity of business relationships.
Employees, contractors, business partners, suppliers, and third parties acting on behalf of the Company are expected to conduct their activities in a manner consistent with applicable anti-bribery and anti-corruption laws and regulations.
Additional requirements regarding bribery, corruption, conflicts of interest, gifts, hospitality, reporting mechanisms, investigations, and corrective actions are established in the Company's Anti-Bribery, Anti-Corruption and Conflict of Interest Policy.
6. Human Rights and Fair Labor Practices
The Company is committed to respecting internationally recognized human rights and promoting fair, respectful, and inclusive working environments.
The Company supports the principles of dignity, equality, non-discrimination, and respect for individuals in all aspects of its operations and business relationships.
The Company does not tolerate child labor, forced labor, human trafficking, harassment, discrimination, abuse, or any practice that violates fundamental human rights or applicable labor laws.
Employees, contractors, suppliers, business partners, and third parties acting on behalf of the Company are expected to uphold these principles and conduct their activities in a manner that respects the rights, well-being, and dignity of all individuals.
Additional requirements related to human rights, labor practices, workplace conduct, diversity, inclusion, and fair employment standards may be established through related policies, codes of conduct, and governance documents.
7. Due Diligence and Risk-Based Review
The Company may conduct reasonable due diligence, screening, and risk-based reviews of employees, contractors, suppliers, business partners, agents, representatives, and other third parties, as appropriate to the nature and level of risk associated with the relationship.
Such reviews may include verification of identity, ownership structures, business credentials, legal compliance, integrity-related concerns, sanctions screening, and other relevant information permitted by applicable laws.
The Company supports risk-based decision-making and encourages appropriate measures to identify, assess, and manage compliance-related risks throughout its operations and business relationships.
8. Health, Safety and Environmental Responsibility
The Company recognizes that protecting people, promoting safe working conditions, and minimizing environmental impacts are essential components of responsible and sustainable business operations.
The Company is committed to conducting its activities in a manner that supports the health, safety, and well-being of employees, contractors, visitors, business partners, and other stakeholders who may be affected by its operations.
The Company expects employees, contractors, suppliers, business partners, and third parties acting on its behalf to comply with applicable health, safety, and environmental laws and regulations and to support responsible practices within their areas of responsibility.
The Company encourages the prevention of workplace injuries, occupational illnesses, unsafe conditions, environmental incidents, and unnecessary impacts on natural resources and surrounding communities.
Additional requirements related to occupational health and safety, environmental management, emergency preparedness, sustainability, and related responsibilities may be established through the Company's management systems, policies, programs, procedures, and other governance documents.
9. Confidentiality, Data Protection and Information Security
The Company is committed to protecting confidential information, personal data, intellectual property, and information assets entrusted to it through its business operations and relationships.
Employees, contractors, suppliers, business partners, and third parties acting on behalf of the Company are expected to handle information responsibly and in accordance with applicable laws, contractual obligations, and internal requirements.
The Company supports the appropriate collection, use, storage, protection, sharing, and disposal of information and personal data and promotes responsible information management practices throughout its operations.
The Company also recognizes the importance of information security and encourages reasonable measures to protect information and systems against unauthorized access, misuse, disclosure, loss, theft, alteration, or other security threats.
Additional requirements related to confidentiality, privacy, data protection, intellectual property, cybersecurity, and information management may be established through related policies, procedures, and governance documents.
10. Fair Competition and Trade Compliance
The Company is committed to conducting business fairly, responsibly, and in compliance with applicable competition, trade, import, export, customs, and commercial regulations.
The Company supports fair competition and expects employees, contractors, suppliers, business partners, and third parties acting on its behalf to conduct their activities in a lawful and ethical manner.
The Company does not support anti-competitive practices, market manipulation, improper agreements, abuse of market position, or any conduct that may restrict fair and open competition.
The Company is also committed to complying with applicable international trade requirements, including import and export controls, sanctions, embargoes, customs regulations, and other legal obligations relevant to its operations.
Employees and business partners are expected to identify and manage compliance risks related to international trade activities and to provide accurate, complete, and truthful information when required by customers, authorities, or regulatory agencies.
Additional requirements related to competition law, trade compliance, import and export controls, sanctions, customs requirements, and related obligations may be established through related policies, procedures, and governance documents.
11. Reporting Concerns
The Company encourages employees, contractors, suppliers, business partners, and other stakeholders to raise concerns regarding potential violations of applicable laws, regulations, Company policies, ethical standards, or other matters that may affect the integrity of the organization.
The Company supports a culture of openness, accountability, and transparency in which concerns can be raised responsibly and in good faith.
Individuals are encouraged to report suspected misconduct, unethical behavior, compliance concerns, legal violations, fraud, corruption, conflicts of interest, health and safety concerns, human rights issues, environmental matters, or other situations that may adversely affect the Company or its stakeholders.
The Company is committed to addressing concerns in a fair, objective, and appropriate manner and supports the protection of individuals who report concerns in good faith.
Retaliation against individuals who raise concerns, participate in reviews, or cooperate with investigations in good faith is not tolerated.
Additional requirements regarding reporting channels, confidentiality, investigations, non-retaliation measures, and case management may be established through related policies, procedures, and governance documents.
12. Responsibilities
Compliance and ethical conduct are shared responsibilities that apply to all individuals and organizations subject to this Policy.
12.1. Employees and Contractors: Employees and contractors are expected to:
- Comply with applicable laws, regulations, Company policies, and ethical standards.
- Conduct their activities honestly, responsibly, and professionally.
- Protect the Company's assets, information, reputation, and interests.
- Raise concerns regarding suspected misconduct or potential violations when appropriate.
- Cooperate with reviews, assessments, investigations, and compliance-related activities when required.
12.2. Leadership and Management: Managers and leaders are expected to:
- Promote a culture of integrity, compliance, accountability, and ethical conduct.
- Lead by example and support responsible decision-making.
- Encourage open communication and the reporting of concerns.
- Support the implementation and continuous improvement of the Company's Compliance and Ethics Framework.
- Address concerns and compliance matters appropriately and in a timely manner.
12.3. Business Partners: Suppliers, contractors, consultants, agents, representatives, and other business partners are expected to:
- Conduct their activities in a manner consistent with the principles established in this Policy.
- Comply with applicable legal, regulatory, contractual, and ethical requirements.
- Cooperate with reasonable requests related to compliance matters.
- Support responsible business practices throughout their operations and business relationships.
13. Continuous Improvement
The Company is committed to continuously strengthening its Compliance and Ethics Framework and promoting responsible business practices throughout its operations and business relationships.
The Company may periodically review its policies, controls, governance practices, training activities, and compliance initiatives to identify opportunities for improvement and respond to evolving legal, regulatory, operational, and stakeholder expectations.
Employees, contractors, business partners, and other stakeholders are encouraged to contribute to the continuous improvement of the Company's compliance culture through responsible conduct, open communication, collaboration, and constructive feedback.
The Company recognizes that compliance and ethical conduct are ongoing commitments that require continuous evaluation, adaptation, and improvement.
14. Approval and Validity
This Policy becomes effective upon approval by Company Management and remains valid until revised, replaced, or withdrawn.
The Company may review and update this Policy periodically to reflect changes in legal requirements, regulatory expectations, business operations, governance practices, or organizational needs.
This Policy applies to all entities operating under the L.O. Trading group and shall be communicated to employees, contractors, business partners, and other relevant stakeholders as appropriate.
Compliance with the principles established in this Policy is expected from all individuals and organizations subject to its scope.
The most current approved version of this Policy shall be maintained and made available through the Company's designated communication and document management channels.