GBA work to create long-term relationships. We ensure we comply with employment regulations and that wages paid are market reflective and the hours worked are not excessive, regardless of local practices. GBA will actively promote the physical and mental well-being of its employees.

GBA is committed to ensuring that all data including personal data of Employees, clients and suppliers is held securely. Data will not be processed/used for any other purpose other than for GBA to provide logistics solutions and purchase services and goods for the operation of the organisation.

Any persons employed or engaged by us, are obliged to take responsibility for preventing, detecting, and reporting anything they believe amounts, or could amount to human trafficking or modern slavery.

This includes vulnerable groups, including, but not limited to migrant workers, women, children and young adults, and persons with disabilities.

In the interest of trust and transparency for our stakeholders our financial statements and reports are published punctually. This documentation is validated in accordance with national and international accounting regulations.

Tax evasion is a crime in the countries GBA operates in. GBA will not tolerate deliberate and dishonest conduct which results in the intention of evading the payment of taxes.

Sanctions are restrictions on activity with targeted countries, governments, entities, individuals and industries (‘targets’) that are imposed by bodies such as the United Nations (UN), the European Union (EU), individual countries or groups of countries.

GBA will not conduct business with organisations or individuals that are known to have sanctions against them.

Our Sanctions Policy includes screening procedures before we:

• Undertake any work for or on behalf of the individual or entity, or
• Receive or transfer any funds to, from or on behalf of the individual or entity
• Directors and beneficial owners of corporate clients
• Intended recipients of funds in transactional and litigation matters, where we have reason to believe that they may be subject to sanctions

Competitive success is built on providing good value and service excellence. When in contact with competitors, employees will avoid discussing confidential information and no attempt will be made to improperly acquire competitors’ trade secrets or any other confidential information.

All members of our organisation have a responsibility to avoid business, financial or other direct or indirect interests or relationships which conflict with the interests of the company.

This also includes activities that may be detrimental to:

• Members of the organisation
• GBA’s reputation or brand
• External stakeholder members
• External Stakeholders reputation

Bribery includes rewards or inducement for acting improperly to gain an advantage, whether personal, commercial, or regulatory.

We define corruption as the abuse of power, authority, or position in return for some personal advantage.

Written records of any gifts or hospitality given or received, must be declared to prevent facilitation payments as unofficial payments.

GBA will never victimise anyone who makes a legitimate complaint if they, or somebody else is being harassed or discriminated against. Additionally, if it is believed that the following events have happened, are happening or are likely to, they also must be reported.

• A criminal offence
• A failure to comply with any legal obligation
• A miscarriage of justice
• Danger to the health and safety of any individual
• Danger to the environment
• Deliberate concealment of any of the above

GBA provides a Whistleblower reporting service hotline and online portal to enable all stakeholders to report any incidents as described above, or concerns regarding breaches of this code of conduct.

The service is managed by an external non-biased specialist that provides a safe, secure, and supportive environment to encourage whistleblowers to speak up and be heard.

Employees shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, intimidation, or retaliation.

This includes right to:

• Lawfully form, join or not join labour unions
• Bargain collectively
• Seek representation and join worker’s councils in accordance with local law and international conventions

Our grievance policy relates to complaints, concerns, and problems related to employment at GBA. It has been developed to ensure that reporting methods are fully accessible and that they are dealt with fairly and consistently.

GBA recognises and accepts its responsibility to ensure, so far as is reasonably practicable, the health and safety of all its employees, contractors, visitors and those members of the public who may be affected by our business’ activities.

GBA is an ISO 45001 (Occupational Health & Safety Management System) certified company.

The company will endeavour to eliminate any hazards which may result in personal injury, illness, fire, security losses, property damage or harm to the environment.

It is GBA’s aim to promote, set and maintain the highest standards for health, safety and welfare matters. This will be achieved by:

• Providing adequate control of the health and safety risks arising from the work activities
• Promoting individual wellbeing in terms of general health, overall safety, comfort, security and protection from adverse risk
• Consulting with employees on matters affecting health and safety
• Fulfilling our legal and other requirements
• Regularly communicating Health and Safety current practice and policy changes
• Providing and maintaining safe equipment
• Ensuring safe handling and use of substances
• Providing information, instruction and supervision for employees
• Ensuring all employees are competent to do their tasks
• Preventing accidents and cases of work-related ill health
• Maintaining safe and healthy working conditions
• Reviewing and revising this policy as necessary at regular intervals