TMT Code of Business Conduct reflects TMT’s commitment to undertake business in a fair, ethical and responsible manner.
Because TMT’s reputation for trust and integrity relies also upon every action by every Employee.
TMT Code of Business Conduct should be followed by all Employees.
INTRODUCTION OBJECTIVE OF THE CODE
As a global shipping company TMT earns its reputation and trust every day by providing unparalleled services to its customers and by conducting business fairly and ethically. Our reputation for trust and integrity relies upon every action by every Employee every day.
The Code is complementary to, and must be read in conjunction with, other policies and procedures TMT may adopt for the purpose of implementing the Code’s principles as well as other policies. TMT also reserves the right to amend the Code from time to time. Employees should keep themselves informed and aware of any updates. Unless stated otherwise in a specific section of the Code, if an Employee has a question regarding compliance with this Code, the HR Officer should be contacted.
SCOPE OF THE CODE The CODE
is a guideline to help Employees to run ethical business. In this sense the implementation of this Code is of the highest priority for TMT and TMT expects Employees to adhere to the Code. TMT encourages its employees to adopt and implement additional principles and policies to complement this Code, provided these do not conflict with it. These additional principles and policies shall be sent to TMT Legal Compliance Team.
The additional principles and policies, or the local requirement, whichever sets the highest ethical standard, must be applied. Each Employee is responsible and accountable for understanding and meeting the standards described in this Code.
Nevertheless, additional responsibilities lie with any Employee who is responsible for supervising others to:
• Act as a role model in strict compliance with the letter and spirit of the Code.
• Ensure that all Employees under their supervision have been made aware of and have been trained on how to apply the Code.
• Supervise and monitor the observance by their staff of the principles laid down in the Code.
• Stop any conduct breaching the Code and report the conduct to the HR Officer, who should report it to TMT management to take actions against this act.
INTERPRETING THE CODE
The purpose of the Code is not to cover all circumstances or anticipate every situation that may arise. Instead, it sets forth the principles and policies for the conduct of TMT’s business in an ethical manner. When encountering situations not addressed specifically by this Code Employees should maintain the highest ethical standards observed in the industry. Situations that are not covered must be referred to the local agency Compliance Officer who should report it to TMT HR Team.
If an Employee is unsure whether his conduct would be contrary to the Code, he should ask himself some simple questions:
• Is this action lawful and in compliance with the Code?
• Would it be harmless to TMT or to me if this conduct was known?
• Would I want my actions to be published on the front page of a newspaper?
• Would I want someone to act in the same way towards me?
If the answer to any of these questions is “no”, the action is deemed not compliant with the Code and should not be taken. If you are unsure of the answer then you should contact your manager.
Where appropriate words in the singular shall include the plural and vice versa. Unless the context otherwise requires, a reference to masculine shall include a reference to feminine.
REPORTING OF MISCONDUCT
Misconduct includes, but is not limited to, corruption, malfeasance, bribery, theft or misuse of TMT’s property, fraud, coercion, intentional omission to perform a duty, or a violation of the Code or any TMT’s policy and procedure.
Any Misconduct must be reported to the local agency Compliance Officer as soon as possible.
If reporting the Misconduct creates a conflict of interest for the addressed officer, the matter should be directed to the TMT management Team. When reporting Misconduct, Employees may choose to identify themselves, or to remain anonymous.
There will be no retaliation against any Employee making a report in good faith. TMT takes alleged violations very seriously and will fairly investigate each allegation. Any failure to comply with the Code may lead to disciplinary action up to and including termination of employment or any other contract, as well as possible civil or criminal penalties.
STANDARD OF CONDUCT
MSC is a company offering global logistics services. In this international environment, all Employees must comply with all applicable laws, regulations and rules, official guidelines, codes of best practice, partnerships with governments and ISO standards, whenever relevant. In addition, the Code sets forth the common standard of approved behavior, regardless of the location of the Employee. These standards supplement and may go well beyond compliance with laws and regulations in many countries where TMT cooperates with.
TMT seeks to be a leader in environmentally sustainable logistics. To this end, TMT is committed to implementing management and operational systems, including through digitalization to maximize efficiency and avoid human error.
HUMAN RIGHTS AND LABOUR STANDARDS
The diversity of Employees is one of TMT’s greatest assets. We think that their different profiles and backgrounds offer great opportunities and added value to TMT.
To make sure that each person’s individuality is respected TMT does not tolerate any discrimination based on sex, religion, gender, age, disability, political or ideological beliefs, marital status, or family responsibilities.
TMT must strictly comply with applicable laws in all aspects of employment, in particular those laws related to elimination of discrimination in respect of employment. Therefore, TMT is firmly committed to support equal employment opportunity and diversity by ensuring that all decisions to recruit and promote are based on merit.
TMT supports and respects internationally recognized human rights in conducting its business relationship and activities worldwide.
TMT believes that each person deserves to be treated equally and properly and this responsibility lies also with every Employee.
TMT also strive to provide Employees with a good working environment.
HEALTH AND SAFETY
TMT seeks to provide Employees with a safe and healthy environment. To meet this goal, TMT:
• Complies with all applicable health and safety laws;
• Has a strict procedure for transporting dangerous cargo.
However day-to-day responsibility generally lies with the master. Employees also have responsibilities: they must comply with the prescribed health and safety measures. Health and safety measures are established within TMT; all Employees must follow them. But it is important to reinforce that each Employee is responsible for his own health and safety.
Therefore, each Employee has the right to remove himself from dangerous situations or operations when there is an imminent and serious danger to his safety and health. In its effort to continuously improve health and safety performance in its operations, TMT conducts accident and near-accident investigation, whenever required.
BUSINESS AND FINANCIAL RECORDS
The accuracy and maintenance of TMT’s business and financial records is crucial and must be ensured. In this regard, all Employees must:
• Always record and classify transactions in the proper accounting period and in the appropriate account and department.
• Not distort the true nature of any transaction.
• Not falsify any document.
• Not enable another person’s efforts to evade taxes, launder money, or violate other laws.
• Always support estimates and accruals with appropriate documentation.
Each Employee must obtain all appropriate approvals before executing, modifying, or amending any contract. Unauthorized contracts or modification of contracts including oral agreements are prohibited and will not be recognized by TMT.
CONFIDENTIAL INFORMATION, DATA PROTECTION AND PRIVACY CONFIDENTIAL INFORMATION
All Employees must safeguard all of TMT’s Confidential Information as well as any Confidential Information received from TMT’s customers, suppliers and any other third parties.
Failure to do so could result in a breach of obligations arising under contracts or laws protecting business secrets, data protection, and privacy. Confidential Information must not in any case be disclosed to anyone outside of TMT and Agencies, including to family and friends, except if legally required. Confidential Information must not be shared with others inside TMT except on a “need to know” basis. All Employees are obliged to protect Confidential Information, even after employment or business ends.
DATA PROTECTION AND PRIVACY
TMT respects and protects the privacy of its Employees, customers, and business partners, processing the personal information in accordance with the requirements established by applicable data protection laws. Personal information is processed fairly and lawfully and for specified and legitimate purposes. TMT stores the personal information securely and takes precautions to prevent unauthorized disclosure.
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