Code of Conduct and Ethics in Business

Universal Shipping Agency S.A., rendering Shipping Agency Services, adopts the following Code of Conduct and Ethics in Business as a strategic decision to undertake its activity.

We seek to reach and to keep the highest standards on all aspects of our activity and thus commit to:

• Conduct ourselves legally and ethically in business.

• All employees of Universal Shipping will support and practice the Ethical Principles on which we base our daily Management, since we understand that the sum of behaviours determine our way of proceeding whenever and wherever we carry out our activity.

• Universal Shipping Agency S.A.has established the Code of Conduct and Ethics in Business as part of its Quality Management System, Environment, Safety and Health at Work (QHSE), in order to maintain this document as a controlled record and communicates it to all the personnel.

• This Code of Business Conduct and Ethics establishes the general policies and procedures that the employees of Universal Shipping Agency S.A. must follow in order to ensure that their behaviors are managed within the highest standards and in accordance with the applicable legal and other requirements that the organization subscribes, related to its Environmental aspects, Hazards to Safety and Health at Work and Continuous Management Improvement.

• Any questions regarding a particular situation, whether or not described in the Code of Conduct and Ethics in Business, should be addressed immediately to the Supervisor or the Manager of Universal Shipping Agency S.A.

• Each employee of Universal Shipping needs to understand and strictly comply with the requirements established in the Code of Conduct and Ethics in Business and stick to our Values and our Vision 2025.

• Universal Shipping provides training on the Code of Conduct and Business Ethics (Ethical Business Practices) through the programmed in GRH01R1, Annual Training Plan.

• Any breach of this Code will be sanctioned in accordance with the provisions of GRH02R5, Internal Regulation.

• One of the values that Universal Shipping shares is integrity, understood as honesty and obedience to law.  It means treating our work mates fairly and respectfully, being accountable and taking responsibility for our actions and consequences.

• We are proud of  our track record and of our legacy to ourselves and to our community.

• The success of our venture is the consequence of Teamwork, understanding that only through everyone’s effort the goals set by ourselves will be achieved.

• Our work environment must be priviledged with honesty, respect and fair treatment.

• Universal Shipping Agency S.A. is committed to comply with the laws and to uphold the fundamental human rights of all people.

• All the staff is valued for their demonstrated knowledge, skills, attitudes, accomplishments and commitment.

• We promote the integral development of our staff through examples and permanent training.

• The company is self commited to ensure a safe and healthy work environment.

• Employees are also responsable for taking the necessary precautions to protect themselves and their co-workers, including the immediate reporting of accidents, injuries and unsafe practices or conditions.

• Appropriate and timely measures will be taken to correct unsafe working conditions.

• The health and safety of all the staff and the quality of service demanded by our customers requires each employee to work free from the effects of any substance that could prevent them from carrying our their work safely and effectively.

• The consumption, possession, purchase or sale of alcohol within the company premises is prohibited unless events approved in advance by the Management at conferences and established meetings.

• The company also prohibits the use of alcohol by employees during working hours.  If caught violating this rule, the employee will be subject to disciplinary sanctions, including dismissal for cause.

• One of the most valuable assets of the company is the information.

• Confidential information comprises, among others:  economic, financial, sales and earning figures, our services and marketing plans, research ideas and information about potential acquisitions or investments, data of the personnel as well as the salaries, bonuses and benefits that they receive.

• Avoid talking about confidential information in public areas, for example on airplanes, elevators or mobile phones.

• All our actions must be based on commercial sound judgement and must never be motivated by personal interests or financial gain.

• Any situation that creates a conflict between personal interests and the interests of the company, should be avoided.

• The staff cannot work or be paid for services from any commercial entity doing or trying to do business or competing with the company, if such work or payment may influence any decision that may be made in the fulfillment of their normal obligations.

• Confidential information cannot be used for personal gain.

• We depend on strong relationships with our customers, suppliers and other business associates who help us provide services with the quality and value damanded by clients.

• At the company we want to do business with those suppliers, contractors, partners, agents, representatives and consultants who adopt and demonstrate high standards of ethical business conduct.

TRAINING

• Annual training in the Code of Conduct and Ethics in Business, together with the dissemination of the Anti-Bribery and Anti-Corruption Policies will be included in the GRH01R1 Annual Training Plan of Universal Shipping, as part of the QHSE ISO 9001, ISO 14001 and ISO 45001 Quality, Environment and Occupational Health and Safety Management System.

• In the same way, the validity and updating of their contents will be reviewed annually through the Review by the Management in accordance with RDQ03.