Evolve Operational Logistics – Code of Conduct

Message from the MD – Steven Frixou

Evolvepack holds its leaders accountable for creating a culture of compliance in which employees understand their responsibilities and feel comfortable raising concerns without fear of retaliation. Leaders’ responsibilities span prevention, detection and response to compliance issues.

Evolvepack want to Personally set the example for integrity, not just through words, but more importantly, through actions.

Ensure employees understand that business results are never more important than ethical conduct and compliance with Evolvepack policies.

Create an open environment in which every employee feels comfortable raising concerns.

Communicate the importance of compliance with sincerity and conviction at every appropriate opportunity.

Commit adequate resources to our business’s compliance program.

To be the voice of Integrity at Evolvepack isn’t always easy, but when integrity concerns are raised, we make our Company stronger and protect our colleagues from harm.

You have an obligation to promptly raise a concern when you see a situation in which our integrity principles or policies are not being followed.

Confidentiality is respected, and you may even choose to remain anonymous. However, if you identify yourself, we are able to follow up with you and provide feedback. Your identity and information will not be shared

Any retaliation whether direct or indirect against employees who raise a concern is grounds for discipline up to and including dismissal.

You can choose to speak to someone about a potential integrity issue or put it in writing. Generally, your supervisor or manager will be in the best position to resolve an integrity concern

As a leader within the business accountability for all these policies begins with myself and continues to each and every person in the organisation

Steve Frixou

Managing Director

Who must follow our Code

The code applies equally to all employees of Evolvepack.  We also require anyone acting for Evolve to behave in a way that is consistent with this code; this includes business partners, contractors, vendors, suppliers and any third-party representatives.  We will share our code widely to ensure it is accessible and can be applied to all.

Complying with this Code, Laws and Regulations

We are committed to following all applicable laws, rules and regulations.  This is a fundamental requirement on all of us.

Be especially aware of different laws and customs that apply to some clients, we respect all clients, business partners and co-workers, all employees must as a minimum, comply with the standards and principles in this code.

Failure to comply with this code could lead to disciplinary action and possible sanctions.

Help each other and speak up whenever you have questions or concerns.

Our Responsibilities

We all have a role to play in protecting our Company’s reputation

  • Works as a team
  • Treat others with respect as you would wish to be treated yourself
  • Be professional, honest, and ethical in all your actions on behalf of Evolvepack
  • Review and understand this Code, especially those sections that apply directly to your work
  • Report any concerns about possible violations of laws, regulations of this Code
  • Cooperate with any investigations or audits

Making Good Decisions

If you’re faced with an ethical issue and you’re not sure what to do, ask these questions:

  • Is it aligned with our company values, “Who are We” and “Ambassador”?
  • Does it affect our Code?
  • Would I be comfortable with my decision if it was made public?

If the answer to any of these questions are “No” or “I Don’t Know”, then don’t do it, contact your supervisor or use any of the other resources listed in this Code.

Waivers and Exceptions

Given the importance of this Code, any future change to any provision of this code must be approved in writing by the M.D. and promptly disclosed in accordance with the requirements of applicable laws and regulations.

Caring for Our People

Alignment is working together towards a common goal while respecting diversity; it is fair decision making not consensus or compliance.

  • It is collaboration, transparency, valuing diverse inputs, sharing and learning from each other with clear accountability for decisions.
  • It is moving like an arrow to win and execute excellently once a decision is made.
  • It is employing a fair process in our decision making.
  • When we do this well, we engage and bring people with us, we tap into each other’s talents, we are agile and entrepreneurial to execute successfully to win in our markets.

Diversity, Inclusion and Dignity at work

Our shared commitment to an open and inclusive culture helps us to create a great place to work, on that attracts the best people and achieves the best results.

We are committed to equal employment opportunity and do not tolerate discrimination and harassment based on ethnicity, race, religion, gender, gender identity, sexual orientation, marital status, age, nation origin, disability, veteran status or any other characteristic protected by law.

Our workplace is free from bulling, harassment and intimidation

Bulling and harassment means any unwanted behavior that makes someone feel intimidated, degraded, humiliated or offended. It is not necessarily always obvious or apparent to others and may happen in the workplace without an employer’s awareness. We take a zero-tolerance approach to any kind of bullying and harassment.

Always Keep in Mind

  • Treat others with respect
  • Promote dignity at work and strive to create a workplace that is free from all forms of harassment and intimidation.
  • Keep an open mind to new ideas and listen to and acknowledge different points of view.
  • Help our suppliers and business partners understand our expectations and our belief in fair treatment and equal opportunity.

Dignity at Work – Our workplace is free from harassment and intimidation

  • Offensive messages, derogatory remarks and inappropriate jokes are inconsistent
  • Understand that inappropriate comments of a sexual nature, or any other sexually offensive behavior, will not be tolerated.
  • Remember that harassment does not have to occur in the workplace or involve an employee to violate our values or the law.
  • Increase your cultural awareness and be mindful that seemingly benign comments may be considered offensive by different individuals.
  • Making false allegations or accusations of bullying and harassment is not acceptable

Always Keep in Mind:

Competition or anti – trust laws are complex and compliance requirements can vary depending on the jurisdiction and the circumstances. The following activities are some of the examples which violate the anti-trust laws:

  • Entering into any arrangement with competitors on sales prices, pricing strategies, product plans, marketing plans, and sales territories
  • Agreeing on the price at which our resellers sell our products
  • Agreeing not to complete
  • Discussing competitive bids with other companies ((bid rigging)
  • Participating in market allocation (agreeing to allocate certain customers or customer group, or certain territories)
  • Selling goods or services at less than market values in order to hurt the competition (dumping)
  • Making negative statements about our competitors

We shall refrain from entering into any arrangement that may have the effect or the result of the foregoing.

We must first consult our law experts before engaging in any sales or marketing activity that may have an impact upon our competitors.

Only collect competitive information through proper public or other lawful channels. Do not use information that was obtained illegally or improperly by others, including misrepresentation, invasion of property, privacy or coercion.

Supplier Relations

Our suppliers make significant contributions to our success. We think of them as part of our family and we always treat them in an ethical manner. We base our supplier relations on the fundamental concepts of honesty, fairness, mutual respect and non-discrimination.

Its important that we work together with our suppliers to make sure that they are compliant with all relevant and regulations, we will not work with any supplier or subcontractor using child labour, violating human or operating under unsafe working conditions.

Always Keep in Mind:

  • Speak up if you observe any working conditions that could have an impact on product safety or quality and listen to others who speak up.
  • Help contractors and others we work with to understand and follow our product safety and quality procedures.

Anti-Corruption and Anti-Bribery

Bribery and corruption in all forms are completely contrary to the spirit of our founders and our values. Therefore, we do not:

  • Give or lend money, goods or services to a government official.
  • Pay a gratuity to government officials or employees to expedite an administrative action.
  • Make any payment or a commission that is disproportionate to the services provided.

Key Definitions

Bribery – a bribe is any form of payment, benefit or gift offered, given or sought with the purpose of influencing a decision or outcome of someone in government or business.

Corruption – the abuse of an entrusted power for private gain.

Facilitation payments – payment or gratuities to a government official that is intended to encourage the official to perform his responsibilities.

Always Keep in Mind:

  • Keep accurate books and records so that payments are honestly described, and we can determine if company funds are used for unlawful purposes.
  • Take great care in dealing with government officials:  in many countries’ gifts or payments to government officials are specifically prohibited by law. Some countries also extend such laws to foreign government officials overseas.
  • It is especially important that we carefully monitor third parties acting on our behalf. We must know who they are and what they are doing. Do your part to make sure they understand they are required to operate in strict compliance with our standards and to maintain accurate records of all transactions.

Keeping Accurate Records

Business partners, government officials and the public rely on our accurate, honest and complete disclosures and business records. Such information is also essential within Evolve so that we can make good decisions.

To ensure that our books and records can meet various purposes, they must be compliant with all local and national laws, accepted accounting principles, and our internal controls. Employee with a role in financial or operational recording or reporting, have a special responsibility in this area, but all of us contribute to the process of recording business results and maintaining records.

Always Keep in Mind:

  • Follow applicable laws and policies when creating, retaining, or destroying documents, including those in electronic formats.
  • Understand that you are accountable for the accuracy and truthfulness of the records you produce.
  • Report immediately any improprieties in accounting, internal controls, or auditing.
  • Keep your records organised so they can be located and retrieved when needed.

Legal Holds

Documents should only be destroyed in accordance with our records retention schedules, and never in response to, or in anticipation of, an investigation, audit, claim, lawsuit or arbitration proceeding.

Gifts and Entertainment

This section on gifts, entertainment, hospitality and gratuities is designed to preserve and maintain Evolves reputation as a global enterprise, which acts with integrity and bases decisions only on legitimate business considerations.

Employees must apply this code in good faith to ensure gifts and entertainment are never considered to be excessive, do not appear to confer any improper advantage, nor create an actual or perceived conflict of interest. These activities should never influence or appear to influence any business decision.

Always Keep in Mind:

Our employees and their immediate families shall not accept or provide gifts or entertainment if the intent is to bias a decision or is given in return for any business, services or confidential information.

Gifts, entertainment and other expenses for customers and suppliers must support the legitimate business interests of our company and should always be documented by an Invoice.

And in all cases, the following conditions must meet:

Gifts or entertainment are only to be given or accepted when:

  • The gift is not payment or consideration for influence or reward for a decision or action.
  • It does not violate applicable law.
  • Its disclosure to the public wouldn’t embarrass your or the company.

The gifts that take the form of Evolvepack branded merchandising materials are considered legitimate if they are proportionate and reasonable.

The following practices are never allowed:

  • Accepting discounted work or services from supplier or contractor for your personal benefit
  • Accepting money on your own account whether by cash, cheque or other means.
  • Giving or accepting any gift or entertainment that could reflect negatively on our reputation.
  • Providing any gift or entertainment that violates the policies of the recipient’s organization.
  • Accepting invitations or accommodations to a trade event, a premium event such as Olympics, world Cup, or an event involving overnight stays or foreign travel with no internal prior authorisation.
  • If employees are offered a gift that exceeds the local monetary limits set by the company:
  • They must politely decline and explain the company rules.
  • In exceptional situations where such gifts must be accepted to avoid causing serious offence, or circumstances genuinely preclude their return, consult your Line manager, HR Senior Officer or Legal Department.

Protecting our Company

Company Assets

We all have a responsibility to use company assets and resources wisely, with    care, and to guard against misuse, damage, loss, theft and waste.

Company assets include facilities, property and equipment, common working areas, tools, vehicles, supplies, computers and IT systems, working time, confidential and proprietary information, marketing material, intellectual property, corporate opportunities and founds.

Always Keep in Mind:

Do:

  • Your part to make sure our assets are not lost, damaged or misused. Protect our IT assets from misuse, theft and damage.
  • Act in accordance with generally accepted rules of behavior in common working areas.
  • Use your working time efficiently and effectively.
  • Limit personal use of our phones and computer systems to a level that does not interfere with your work or that involves an outside business interest.
  • While it is generally not our practice to monitor employee’s use of our information system, Evolvepack, reserves the rights top monitor the nature and content of an employee’s activity using our company’s email, phone, voicemail, internet and other systems, as and to the extent permitted by local law.

Do not:

  • Leave information assets including IT assets in public or unsecured places.
  • Use noticeboards without necessary approval.
  • Put any advertising materials in common areas without necessary approval.
  • Misuse company resources for personal activities or install any non-approved software or connect any unauthorised device.
  • Share user names or passwords.
  • Download, store, or pass on the others any inappropriate material.

Conflict of Interest

A conflict of interest may occur when our personal interests make it difficult to perform our work objectively and effectively in support of the company’s interests.

Each of us expected to be proactive and, wherever possible, avoid situations that can lead to a potential conflict. If you find yourself in a potential conflict of interest, talk with your supervisor. Depending on the circumstances, some conflict may be resolved if they are handled properly.

Always Keep in Mind:

There is a wide variety of circumstances that could be considered conflicts of interest. While it difficult to list them all, we have listed below common actions that can lead to conflicts and which should be avoided, we should not:

  • Be involved in activities that complete with, or appear to compare with, Evolvepack.
  • Let our business decisions be influenced by personal or family interest or friendships.
  • Use company property, information, or resources for personal benefit or the benefit of friends or relatives.
  • Conduct activities directly or indirectly defined as “tradesman”. Likewise, we should not be employed by competitors or companies that have relations with Evolvepack.

Relationships in the Workplace

Relatives working together don’t always make for one, big happy family. As many companies have discovered, family conflicts can sometimes spill over into the workplace, or favoritism may occur. As such, Evolvepack, does not support employees directly hiring family members. Should family members be employed by Evolvepack, they must always work in different departments, and never in a direct reporting relationship.

You must also disclose to your Line Manager, HR Senior Officer or Legal Department all business affiliations, activities or investments (including those involving immediate family members), to the extent they may adversely affect your independent and objective judgement, your ability to fulfil your performance duties for Evolvepack or otherwise conflict with Evolvepack interests.

Outside Business Activities

Your outside activities must not reflect adversely on Evolvepack or give rise to real or apparent conflict of interest with your duties to the company. You must be alert to potential conflicts of interest and be aware that you may be asked to discontinue any outside activity if potential conflict arises.

Outside activities must not interfere with your job performance or require such long hours as to affect your physical or mental effectiveness. Your job at Evolvepack should always be your first work priority. You must seek management approval for duties and significant responsibilities outside of work. (e.g. directorships, university post, and board memberships).

Confidential Information

One of our most valuable assets is information. The loss or misuse of confidential information can harm our reputation, cause us to lose a critical competitive advantage and damage our relationships with our customers or business partners.

Always Keep in Mind:

  • Use and disclose confidential information only for legitimate business purposes.
  • Never disclose any publicly undisclosed information to third parties for either personal gain or for the benefit of anyone outside the Company.
  • Never share details of confidential projects.
  • Properly label confidential information to help others know it should be handled.
  • Protect the confidential and proprietary information of business partners.
  • Never discuss confidential information when others might be able to overhear what is being said (for example on planes, elevators, and when using mobile phone in public spaces).
  • Even when your employment at Evolve ends, you are still prohibited from using confidential information or documents of the Company for personal gain or for the benefit of third parties without express written permission.

Confidential information includes but is not limited to:

  • Employee information (names, address, home phone numbers, salary or wages, medical data and personal documents)
  • Future. Pending sales, acquisitions and mergers
  • Pricing and marketing information
  • The company’s strategic business plans and financial figures
  • Data developed or purchased by the company or entrusted to us by our business partners.

Human Rights

One of the guiding principles of Evolvepack is to respect others and succeed                     together. Our success can be achieved only when we treat everyone, both within and outside our company, with respect. We recognise the importance of maintaining and promoting fundamental human rights in all our business operations. We will not tolerate abuse of human rights in our operations or in our supply chain.

We support the principles contained in the United Nation’s Universal Declaration of Human Rights and the International Labour Organisation Fundamental Principles and Labour Standards. We operate under programs and politics that:

  • Provide fair and equitable wages, benefits and other conditions of employment in accordance with local laws.
  • Recognize employee’s rights to freedom of association.
  • Provide humane and safe working conditions.
  • Prohibit forced or child labour.

Always Keep in Mind:

Each of us can help support efforts to eliminate human rights abuses;

  • Report any suspicion or evidence of human rights abuses in our operations or in the operations of our business partners.
  • Remember that respect for human dignity begins with our daily interactions with one another and with our customers and includes promoting diversity and inclusion and doing our part to protect the rights and dignity of everyone with whom we do business.

Sustainability

We are an environment – friendly company that not only operates in full accordance with environmental legislation, but we also work towards decreasing air, water and soil pollution, and to increasing recycling whenever possible. Every member of the Evolvepack family – our employees, suppliers, customers, board of directors, and all our business partners – is encouraged to take responsibility for improving or environmental impact and meeting our goals.

Being Open and Transparent with the Public


We follow an open and transparent communication model and we work to ensure that our corporate messages, information and commentaries do not mislead the public. We treat media organisations equally and nurture equal relationships.

All Evolvepack business units have a designated external relations or communications team, responsible for communicating product information and company positions on a range of issues. You should coordinate any request from media regarding financial or sector information with the Corporate Communications team responsible and refer to the relevant company policies. No individual, except specifically appointed spokespersons, can provide information to the media.

In case you become a spokesperson, make sure to keep these following pointers in mind when you speak on behalf the company:

  • Your content should be responsible, transparent, and authentic.
  • Always exercise common sense. Avoid discriminations, personal insults, obscenity or misconduct of any kind
  • As a company, we don’t associate ourselves with any kind of religious, political, social tendency, group or organisation. Stakeholders speaking on behalf of Evolve should do the same.
  • The communication channels shouldn’t in any way be used as a means of advocacy or propaganda of any kind.
  • Its advisable not to speak ill about the Group, its stakeholders, business partners, affiliates of any kind or competitors.
  • Respect copyrights, trademarks, rights or publicity and other third – party rights. If something is not yours, simply don’t use it.
  • Make sure to disclose your affiliation to the company clearly alongside your message.
  • Remember all corporate policies at the office apply equally to digital channels as well.

Using Social Media

Be careful when writing communications that might be published online. If you participate in social media, never give the impression that you are speaking on behalf of Evolvepack.

When using social media:

  • Never comment on confidential and non-public company information such as the company’s current or future business performance or business plans.
  • Be fair and courteous, and never post content that may be viewed as malicious, obscene, harassing, defamatory or discriminatory.
  • Always provide source or reference when you post someone else’s content/asset.
  • Operate from the basis of “don’t write/say anything that would make you feel uncomfortable”. If it makes you feel uncomfortable, there is a good chance other will feel the same way.
  • Think about the consequences. There’s a big difference between speaking “on behalf of” the company and speaking” about” the company
  • When you talk about the company, make sure to disclose your affiliation to it.
  • The form of disclosure might differ from one platform to another, however, make sure it is clear and part of the message itself. Whenever you publish content to any form of digital media, make it clear that what say represents your personal views and opinions and not necessarily those of Evolvepack.
  • Using a disclaimer like “the comments and views on this site/channel are my own and don’t represent the opinions or positioning of Evolve, its companies or brands” is highly advised. This way you get to preserve your authenticity and that of the company.
  • Any employee should not share any political ideology while using his/her corporate title.
  • Some managers are clearly identified as having a close association with our companies. In this case, managers must be particularly diligent in sharing their views including on personal social media accounts.
  • If you read an online comment about Evolvepack that you believe is erroneous, do not respond; instead, contact the Corporate Communications team responsible so that appropriate steps can be taken.

Helpful Resources and Raising Concerns

Asking Questions and Reporting Concerns

Every Evolvepack employee is responsible for acting ethically and following our Code. If you see or hear something you believe is illegal or a violation of our Code…. Speak up!

When you speak up to ask a question or report questionable conduct, you are protecting your colleagues and reputation of Evolvepack. Remember, an issue cannot be addressed unless it is brought to someone’s attention.

Where to go for help

You can ask questions and report possible violations of Our Code by using any of the following methods:

  • In most instances the best first step is for you to talk to your supervisor. They will be familiar with the laws, regulations and rules that relate to your work
  • If you are not comfortable talking with your supervisor, talk to your Human Resources Manager or Legal department.
  • If none of the above steps resolves your concern, you can, at any time, call the confidential Hotline that we are making available within Evolvepack in line with local laws. All calls are confidential, and you may remain anonymous where allowed by local law.

Our Non – retaliation Policy

We will not tolerate retaliation against anyone who makes a good faith report of an alleged violation of the law, or this code. We take claims of retaliation seriously. If you believe you have been retaliated against, you should contact your senior HR Officer, Company Legal Counsel or any of the resources listed in this Code.