Business Conduct and Ethics

1. The success of our business depends on the trust and confidence we earn from our employees and customers. We gain credibility by adhering to our policies and principles, and by displaying honesty, integrity, and reaching company goals through honorable conduct and hard work. So that our employees and independent sales contractors understand our core values, it is important that we outline our expectations, especially in situations where improper activities could damage the Company’s reputation and result in serious consequences to the Company.

2. All employees and independent sales contractors must maintain professional conduct at all times and never engage in any theft or misuse of company or customer property, including items designated for destruction. Any violative conduct could result in disciplinary action, up to and including termination.

3. No employee or independent sales contractor may accept a gift or gratuity from any customer, vendor, supplier, or other person doing business with Watchpoint Logistics, Inc., other than gifts of nominal value. For that purpose, “nominal value” means up to $25 in any 12-month period. We have this policy in place because acceptance of any gift or gratuity may give the appearance of influencing business decisions, transactions, or service.

4. Watchpoint Logistics, Inc. prohibits employees and independent sales contractors from paying, soliciting, or receiving any rebate, directly or indirectly, which is unlawful under the Shipping Act of 1984, as amended, and governing regulations of the Federal Maritime Commission. Illegal rebate activities by common carriers include:

  • Charging, collecting, or receiving any greater, lesser, or different compensation for transportation or services than the rates and charges shown in the carrier’s tariffs or provided for in an executed Negotiated Rate Agreement or non-vessel-operating common carrier service arrangement.
  • Rebating or refunding any portion of its rates except in accordance with tariffs.
  • Allowing any person to obtain transportation at less than tariff rates by means of false billing, false classification of cargo, false weighing, false measurement, or any other unfair measure.
  • Offering any deferred rebate.

 

5. Watchpoint Logistics, Inc. prohibits employees and independent sales contractors from making payments to foreign government officials to assist in obtaining or retaining business which is unlawful under the Foreign Corrupt Practices Act. Such payments include: The willful use of the mails or any means of instrumentality of interstate commerce corruptly in furtherance of any offer, payment, promise to pay, or authorization of the payment of money or anything of value to any person, while knowing that all or a portion of such money or thing of value will be offered, given or promised, directly or indirectly, to a foreign official to influence the foreign official in his or her official capacity, induce the foreign official to do or omit to do an act in violation of his or her lawful duty, or to secure any improper advantage in order to assist in obtaining or retaining business for or with, or directing business to, any person.

6. Watchpoint Logistics, Inc. also prohibits employees and independent sales contractors from engaging in bribery, i.e., giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so. That also includes seeking to influence a decision-maker by giving some kind of extra benefit to that decision-maker, rather than by what can legitimately be offered as part of a tender process.

7. Any employee or independent sales contractor who becomes aware of or witnesses a payment/bribe, or attempted payment/bribe, regardless of who is making or attempting to make such payment/bribe, must report it to the President of Watchpoint Logistics, Inc.

8. Watchpoint Logistics, Inc. requires employees and independent sales contractors to report to the President of the Company any offer to pay expenses by any customer, vendor, supplier, or other person doing business with Watchpoint Logistics, Inc. for business meals or trips. Neither an employee nor an independent sales contractor may accept such an offer without the written approval of the President of the Company.