Policy

Why do we need a Code of Conduct for employees?

Ethical behavior is an essential part of your position with 3V Logistic LLC and is a personal responsibility that should be taken very seriously. We need and expect each Employee to be accountable for their work and behavior and to support the values, principles and standards upon which 3V Logistic LLC’s business reputation rests. This Code of Conduct (the “Code”) is a guide to help you live up to 3V Logistic LLC’s values, abide by it’s policies and respect the best interests of our customers and shareholders.

The purpose of the Code is to describe principles of business conduct and to provide guidance in ethical decision making. Many sections of the Code reference matters for which specific policies exist; this is because the Code encompasses standards of behavior set forth in other 3V Logistic LLC policies. You are expected to become familiar with 3V Logistic LLC policies that directly impact your daily work.

The Code is especially important for 3V Logistic LLC as a publicly-traded company because laws, rules and regulations are in place, which govern the disclosure of information about the business of publicly- traded companies. The Code outlines the basic legal obligations of all 3V Logistic LLC employees. As a publicly-

traded company 3V Logistic LLC’s affairs will be under close scrutiny by shareholders, regulators and the investment community. We must be aware of our obligations and conduct ourselves in accordance with the highest ethical and moral standards.

Although questionable activities may not be mentioned in this Code, ask yourself the following questions to decide if an activity should be reported or discussed with your manager:

   Does it seem right?    Is it legal?

   Does it match up with 3V Logistic LLC’s vision and values?

   Would I feel uncomfortable if I read about it in a newspaper?

   Would other people at 3V Logistic LLC feel uncomfortable if they read about it in a newspaper?

Although the Code lays out fundamental principles of ethical and legal conduct, it cannot anticipate every ethical dilemma or situation you may encounter in performing your daily work. If at any time you are unsure about the proper course of action discuss your concerns with your manager.

Application of the Code

The Code applies to all employees, contractors and the members of the Board of Directors, which for purposes of the Code are referred to as “Employees”. Contractors include any consultants, suppliers and vendors who are required to have access to 3V Logistic LLC’s confidential, business and proprietary information in order to perform their duties.

Compliance

Compliance with the Code is mandatory. You are expected to be familiar and comply with the Code in the performance of your duties. As well, you are expected to understand your obligations under 3V Logistic LLC policies. On an annual basis all employees and members of the Board are required to sign an Annual Acknowledgement of Corporate Policies form. Those of us who fail to abide by the Code and 3V Logistic LLC’s policies will be subject to disciplinary action, up to and including dismissal or prosecution.

Responsibilities to report

It is the responsibility of everybody at 3V Logistic LLC to report any known or suspected unethical conduct, which includes any violation of the Code, by other Employees or anyone in any way associated with the corporation. 3V Logistic LLC is committed to protecting all Employees who report unethical conduct from reprisal as well as offering any necessary support to individuals who make reports. When an Employee makes a report of unethical conduct they should do so in good faith. Detailed in the Whistleblower section of the Code are the reporting procedures for Employees who suspect or become aware of any unethical conduct.

Our Business Conduct

 Public Disclosure

The objective of 3V Logistic LLC’s Disclosure Policy (“Disclosure Policy”) is to ensure communications with the  investing public about 3V Logistic LLC are:

• Timely, factual, accurate, balanced; and  broadly disseminated in accordance with all applicable legal and regulatory requirements. The Disclosure Policy confirms in writing the Disclosure Policies and practices that 3V Logistic LLC follows. The Disclosure Policy extends to all Employees of 3V Logistic LLC,  its board of directors, those authorized to speak on its behalf and other people with access to undisclosed material information. 
• Disclosure and documents filed with securities regulators;
• Financial and non-financial disclosure, including Management’s Discussion and Analysis (MD&A);    written statements made in 3V Logistic LLC’s annual and quarterly reports, news releases, letters to shareholders and presentations by senior management and other Employees;
• Electronic communications through e-mail, social networking sites and 3V Logistic LLC’s website, including audio and video content; and
• Oral statements made in meetings and telephone conversations with analysts and investors, interviews with media, as well as speeches, press conferences and conference calls.

Insider trading and tipping

3V Logistic LLC’s Securities Trading and Insider Reporting Policy applies to all Employees. Applicable securities laws prohibit all Employees with access to or knowledge of material non-public information from or about 3V Logistic LLC from buying, selling or otherwise trading in 3V Logistic LLC securities or from informing or tipping others about material non-public information. 

Disclosure to the media

The purpose of 3V Logistic LLC’s Media Policy is to ensure Employees understand and comply with 3V Logistic LLC’s disclosure requirements in terms of media interaction and public presentations. The Media Policy is a supplement to 3V Logistic LLC’s Disclosure Policy and should be read in conjunction with that document. 

• If you are delegated to speak on behalf of the company, you will be briefed prior to being interviewed to review what is, and what is not, public information.
• Those of us who are asked for and give our opinions to the media regarding any of our outside interests should know that our comments are strictly personal. Be cautious not to compromise 3V Logistic LLC.

Conduct when representing 3V Logistic LLC

Conduct yourself professionally and with personal integrity, both in and out of the workplace, reflective of 3V Logistic LLC values. Communicate and negotiate with honesty with all Employees, customers, partners, stakeholders, suppliers, associates and other members of the public. Our obligation to act with integrity and within the spirit of this Code continues while traveling, whether domestically or abroad.

Legal and social responsibility

Ensure that your actions comply with and are within the meaning and intent of all applicable laws and regulations. Ensure that your actions are free from suspicion and criticism and have no unfavourable effects on society.

Conduct with customers

• Serving customers is the focal point of our business. Our customers deserve the highest quality service and standards in all transactions.
• Provide our customers with value and deal with them fairly. Act with integrity and do everything possible to provide great service to our customers, either directly or by supporting the work of other individuals or business units.
• Do not make promises that you or 3V Logistic LLC cannot keep.

Use of Corporate Information and Property

Do not disclose information about 3V Logistic LLC activities or our customers’ activities to non-authorized Employees within the workplace, or anyone outside the workplace unless in accordance with 3V Logistic LLC’s Disclosure Policy.

All information held by 3V Logistic LLC is confidential and the property of 3V Logistic LLC. This includes information relating to 3V Logistic LLC business, property, Employees, customers, partners, consultants, or others that is not generally available to the public.

In our business, we become aware of confidential information about our customers’ business and personal ventures. We have a responsibility to uphold the trust of our customers. Do not discuss or disclose confidential customer information outside the workplace and ensure that uses of confidential customer information within 3V Logistic LLC are consistent with the purposes for which it was collected.

Use of Registry Information

Ensure that information contained in the public registries administrated by 3V Logistic LLC is used according to the appropriate policies and laws. Do not use registry information for purposes other than conducting 3V Logistic LLC business. 

Use of computer systems and software

Our computer systems and software form the backbone of our registry services and our operations infrastructure. Every effort should be made to protect 3V Logistic LLC’s computer systems and associated software from various threats to their security such as accidental or deliberate destruction of data or equipment, interruption of service, disclosure of confidential information, theft or corruption of data. Any security concerns with respect to our systems or software, or any viruses or data network attacks, weaknesses or unexplained system changes should immediately be reported to the Manager of Facilities, Risk and Security.

Use of corporate property

Protect 3V Logistic LLC’s physical property and revenues. Corporate property includes, but is not limited to: premises, equipment, supplies, furnishings, Employee search accounts, funds, reports, records, vehicles, trade secrets, computer software, hardware and networks, internet accounts and intangible items such as the details of business application systems.

Ensure that corporate property under our control is used in accordance with 3V Logistic LLC’s Acceptable use of  Information Technology Policy and 3V Logistic LLC’s Security Policy and is protected from use by unauthorized individuals.

Employees are responsible for ensuring that:

• 3V Logistic LLC’s assets are protected and not used for personal use unless otherwise authorized;
• 3V Logistic LLC’s intellectual property is subject to copyright and is not reproduced, distributed or altered without authorization;
• As far as practicable, contracts are put in writing; and
• Unless otherwise authorized 3V Logistic LLC’s name or purchasing power is not used to obtain personal  benefits, discounts or rebates.

Proper Reporting of Financial Transactions

You are accountable for any corporate funds over which you have control. Follow the set procedures for handling, recording and protecting funds. When spending 3V Logistic LLC funds, ensure that 3V Logistic LLC receives good value for the expenditure. Do not use 3V Logistic LLC funds for personal benefit. Compliance with the International Financial Reporting Standards and internal controls is expected at all times, and 3V Logistic LLC’s books of account, reports, records and other documents must accurately account for and report all assets, liabilities and transactions affecting 3V Logistic LLC.  We must:

• Maintain accurate and reliable records relating to business, customers and Employees to meet our legal and financial obligations and in accordance with our accounting and business practices;
• Not intentionally cause 3V Logistic LLC’s books or records to be incorrect or misleading in any way and relevant information should never be omitted, deleted or concealed;
• Not create or participate in the creation of any record intended to conceal anything that is improper;
• Properly and promptly record all disbursements of funds;
• Cooperate and ensure full disclosure in communications with both internal and external auditors and with the Chief Financial Officer and his group;
• Promptly disclose knowledge of any untruthful or inaccurate statements or records whether intentionally or unintentionally made;
• Promptly bring to the attention of your manager any transactions that did not seem to have a legitimate commercial purpose; and
• Information must only be destroyed in accordance with approved retention schedules and procedures.