Date: November 27, 2018

H.E. António Guterres
Secretary-General
United Nations
New York, NY 10017
USA
Communication on Progress 2017-2018

Dear Mr. Secretary-General

I am pleased to confirm that TIP Trailer Services supports the ten principles of the Global Compact with respect to human rights, labor, environment and anti-corruption.

With this communication, we express our progress in advancing those principles within our sphere of influence. We have made the Global Compact and its principles an integral part of our business strategy, day-to-day operations and organizational culture of our company. We have incorporated the UN Global Compact and its principles in decision-making processes at the highest levels.

In this report, we will describe the practical actions that we have taken to implement the Global Compact principles in each of the four issue areas (human rights, labor, environment, and anti-corruption).

We will do this by disclosing any relevant policies, procedures and activities that we have undertaken. We will then disclose the outcomes of these policies, procedures and activities which helped us meet our targets and which indicate our performance.

We support public accountability and transparency, and therefore we provide this report on our progress.

Sincerely yours,

Mr. Robert Alain Fast

President and Chief Executive Officer

Our policies and actions are in keeping with the UN Global Compact’s Ten Principles in relation to human rights which are (1) supporting and respecting the protection of internationally proclaimed human rights and (2) making sure that we are not complicit in human rights abuses.This can be seen in our TIP Integrity Guide for Suppliers, Contractors and Consultants which includes our Code of Conduct and Anti-Slavery and Human Trafficking Policy below.

TIP Trailer Services (“TIP”) is committed to being a responsible corporate citizen, which requires TIP employees, suppliers, contractors and consultants to conduct themselves with integrity and to be accountable to the highest standards of business conduct and ethics.

As a TIP supplier, contractor or consultant (collectively “suppliers”) your actions reflect on TIP’s reputation and good name. That reputation depends on each business transaction we make being grounded in a foundation of ethical behavior.

TIP bases its supplier relationships on lawful, efficient and fair practices, and expects its suppliers to adhere to applicable legal and regulatory requirements in their business relationships, including those with their employees, their local environments, and TIP. The quality of our supplier relationships often has a direct bearing on the quality of our customer relationships. Likewise, the quality of our suppliers’ products and services affects the quality of our own products and services.

To help TIP suppliers understand the TIP commitment to unyielding integrity and the standards of business conduct that all TIP suppliers must meet, TIP has prepared this TIP Integrity Guide for Suppliers, Contractors and Consultants (“Supplier Guide”).

Suppliers should carefully review this Supplier Guide, including but not limited to the section, Responsibilities of TIP Suppliers. Suppliers are responsible for ensuring that they and their employees, representatives and sub-suppliers comply with the standards of conduct required of TIP suppliers. Please contact the TIP manager you work with or any TIP Compliance Resource if you have any questions about this Supplier Guide or the standards of business conduct that all TIP suppliers must meet.

TIP Code of Conduct

TIP’s commitment to total, unyielding Integrity is set forth in the TIP Integrity Guide and this Supplier Guide. The policies set forth in the TIP Integrity Guide govern the conduct of all TIP employees and are supplemented by compliance procedures and guidelines adopted by TIP components. The policies set forth in the TIP Supplier Guide govern the conduct of all TIP suppliers. All TIP employees and suppliers must not only comply with the specific policies that govern their relationship with but also with the “spirit” of these policies.

The “spirit” of TIP’s Integrity commitment is set forth in the TIP Code of Conduct, which each TIP employee has made a personal commitment to follow:

 Be honest, fair and trustworthy in all of your activities and relationships.
 Ensure the health and safety and fair and equal treatment of all employees.
 Comply with all applicable laws governing our business, the TIP Integrity Policies and this Code of Conduct.
 Promptly report any concerns you have about compliance with law, the TIP Integrity Policies or this Code of Conduct.
 Work to run the company as competitively and profitably as possible through accountability and compliance.

TIP will do business only by lawful and ethical means. When working with customers and suppliers in every aspect of our business, we will not compromise our commitment to integrity.

TIP Compliance Obligations

All TIP employees are obligated to comply with the requirements of the Company’s compliance policies set forth in the TIP Integrity Policy. These policies implement the TIP Code of Conduct and are supplemented by compliance procedures and guidelines adopted by TIP components and/or businesses. A summary of some of the key compliance obligations of TIP employees follows:

a) Improper Payments
 Always adhere to the highest standards of honesty and integrity in all contacts on behalf of TIP. Never offer bribes, kickbacks, illegal political contributions or other improper payments to any customer, government official or third party. Follow the laws of the European Union and other countries relating to these matters.
 Do not give significant gifts or provide any extravagant entertainment to a customer or supplier without TIP management approval. Make sure all business entertainment and gifts are lawful and disclosed to the other party’s employer.
 Employ only reputable people and firms as TIP representatives and understand and obey any requirements governing the use of third party representatives.

b) International Trade Controls
 Understand and follow applicable international trade control and customs laws and regulations, including those relating to licensing, shipping and import documentation and reporting and record retention requirements.
 Never participate in boycotts or other restrictive trade practices prohibited or penalized under European Union or applicable local laws.
 Make sure all transactions are screened in accordance with applicable export/import requirements; and that any apparent conflict between EU and applicable local law requirements is disclosed to TIP counsel.

c) Money Laundering Prevention
 Follow all applicable laws that prohibit money laundering and that require the reporting of cash or other suspicious transactions.
 Learn to identify warning signs that may indicate money laundering or other illegal activities or violations of TIP policies. Raise any concerns to TIP counsel and TIP management.

d) Privacy
 Never acquire, use or disclose individual consumer information in ways that are inconsistent with TIP privacy policies or with applicable privacy and data protection laws, regulations and treaties.
 Maintain secure business records of individual consumer information, including computer-based information.

e) Supplier Relationships
 Only do business with suppliers who comply with local and other applicable legal requirements and any additional TIP standards relating to labor, environment, health and safety, intellectual property rights and improper payments.
 Follow applicable laws and government regulations covering supplier relationships.
 Provide a competitive opportunity for suppliers to earn a share of TIP’s purchasing volume, including small businesses and businesses owned by the disadvantaged, minorities and women.

f) Working with Governments
 Follow applicable laws and regulations associated with government contracts and transactions.
 Require any supplier providing goods or services for TIP on a government project or contract to agree to comply with the intent of TIP’s policies and guidance.
 Be truthful and accurate when dealing with government officials and agencies.

g) Complying with Competition Laws
 Never propose or enter into any agreement with a TIP competitor to fix prices, terms and conditions of sale, costs, profit margins, or other aspects of the competition for sales to third parties.
 Do not propose or enter into any agreements or understandings with TIP customers restricting resale prices.
 Never propose or enter into any agreements or understandings with suppliers that restrict the price or other terms at which TIP may resell or lease any product or service to a third party.

h) Environment, Health & Safety
 Learn how to conduct your activities in compliance with all relevant environmental and worker health and safety laws and regulations and conduct your activities accordingly.
 Ensure that all new product designs or changes or services offerings are reviewed for compliance with TIP guidelines.
 Use care in handling hazardous materials or operating processes or equipment that use hazardous materials to prevent unplanned releases into the workplace or the environment.
 Report to TIP management all spills of hazardous materials; any concern that TIP products are unsafe; and any potential violation of environmental, health or safety laws, regulations or company practices or requests to violate established EHS procedures.

i) Fair Employment Practices
 Extend equal opportunity, fair treatment and a harassment- free work environment to all employees, co-workers, consultants and other business associates without regard to their race, color, religion, national origin, sex (including pregnancy), sexual orientation, age, disability, veteran status or other characteristic protected by law.

j) Security and Crisis Management
 Implement rigorous plans to address security of employees, facilities, information, IT assets and business continuity.
 Protect access to TIP facilities from unauthorized personnel.
 Protect IT assets from theft or misappropriation.
 Create and maintain a safe working environment.
 Ensure proper business continuity plans are prepared for emergencies.
 Screen all customers, suppliers, agents and dealers against terrorist watch lists.
 Report any apparent security lapse.

k) Conflicts of Interest
 Financial, business or other non-work related activities must be lawful and free of conflicts with one’s responsibilities to TIP.
 Report all personal or family relationships, including those of significant others, with current or prospective suppliers you select, manage or evaluate.
 Do not use TIP equipment, information or other property (including office equipment, e-mail and computer applications) to conduct personal or Non-TIP business without prior permission from the appropriate TIP manager.

l) Controllership
 Keep and report all TIP records, including any time records, in an accurate, timely, complete and confidential manner. Only release TIP records to third parties when authorized by TIP.
 Follow TIP’s General Accounting Procedures (GAP), as well as all generally accepted accounting principles, standards, laws and regulations for accounting and financial reporting of transactions, estimates and forecasts.
 Financial statements and reports prepared for or on behalf of TIP (including any component or business) must fairly present the financial position, results of operations, and/or other financial data for the periods and/or the dates specified.

m) Insider Trading or Dealing & Stock Tipping
 Never buy, sell or suggest to someone else that they should buy or sell stock or other securities of any company (including TIP) while you are aware of significant or material non-public information (inside information) about that company. Information is significant or material when it is likely that an ordinary investor would consider the information important in making an investment decision.
 Do not pass on or disclose inside information unless necessary for the conduct of TIP business — and never pass on or disclose such information if you suspect that the information will be used for an improper trading purpose.

n) Intellectual Property
 Identify and protect commercially significant TIP intellectual property in ways consistent with the law.
 Consult with TIP counsel in advance of soliciting, accepting or using proprietary information of outsiders, disclosing TIP proprietary information to outsiders or permitting third parties to use TIP intellectual property.
 Respect valid patents, copyrighted materials and other protected intellectual property of others; and consult with TIP counsel for licenses or approvals to use such intellectual property.

o) Invention Assignment
 The Supplier agrees that all inventions, including, but not limited to, improvements, and all know-how, processes, techniques, formulas, ideas, circuits, designs, trademarks, trade secrets and copyrightable works (collectively, “Inventions”) which result from work performed by the Supplier on behalf of the Company or from access to Proprietary Information shall be the property solely of the Company. The Supplier agrees, both during and after engagement with the Company, to disclose promptly and in writing, to the Company, all Inventions that the Supplier, either solely or jointly with others, make, author, discover, develop, conceive and/or reduce to practice derived from Proprietary Information. The Supplier hereby assigns and agrees to assign to the Company or its designee, without further consideration, his entire right and interest in and to all Inventions, including all rights to obtain, register and enforce patents, copyrights, mask work rights and other intellectual property protection for Inventions.
 The Supplier agrees to execute all documents reasonably necessary to perfect such intellectual property rights and the assignment of those rights to the Company or its designee. The Supplier further agrees to assist the Company (at the Company’s expense), both during and after engagement with the Company, in obtaining, protecting and/or enforcing patents, copyrights or other forms of Inventions.

p) Confidential Information
 Proper management of confidential information is critical to the success of both TIP and suppliers.
 Suppliers must protect all TIP information, electronic data, and intellectual property or TIP technologies with appropriate safeguards.
 Any transfer of confidential information must be executed in a way that secures and protects the intellectual property rights of TIP and its suppliers.
 Suppliers may receive our confidential information only as authorized by a confidentiality or non-disclosure agreement and must comply with their obligations to not disclose the confidential information, to not use the information except as permitted by the agreement, and to protect the information from misuse or unauthorized disclosure.
 Our suppliers can expect TIP to similarly safeguard their confidential information when authorization is provided to TIP.
 Suppliers may not use the TIP trademark, images, or other materials to which TIP owns the copyright, unless explicitly authorized.

q) Supply Chain Transparency and Modern Slavery
 Supply chain transparency is required to confirm compliance to this code conduct.
 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking.
 Suppliers must ensure they and their supply chain comply with the modern slavery policy attached at Appendix A.
 To monitor this, TIP reserves the right to request documentation, conduct onsite audits, review and approve corrective action plans, and verify implementation of corrective action.
 Suppliers are expected to assist TIP in enforcing this Supplier Code of Conduct by communicating its principles to their supervisors, employees, and suppliers.

TIP will only do business with suppliers that comply with all applicable legal and regulatory requirements. Today’s regulatory environment is becoming more and more challenging, subjecting TIP and its suppliers to a growing number of regulations and enforcement activities around the world. This environment requires that TIP and its suppliers continue to be knowledgeable about and compliant with all applicable and committed to regulatory excellence. Suppliers that transact business with TIP are also expected to comply with their contractual obligations under any purchase order or agreement with TIP and to adhere to the standards of business conduct consistent with TIP’s obligations set forth in the “TIP Compliance Obligations” section of the Guide and to the standards described in this section of the Guide. A supplier’s commitment to full compliance with these standards and all applicable laws and regulations is the foundation of a mutually beneficial business relationship with TIP.

As stated above, TIP requires and expects each TIP supplier to comply with all applicable laws and regulations.

Unacceptable practices by a TIP supplier include:

 Minimum Age. Employing workers younger than the required minimum age.

 Forced Labor. Using forced, prison or indentured labor, or workers subject to any form of compulsion or coercion.

 Environmental Compliance. Lack of commitment to observing applicable environmental laws and regulations. Actions that TIP will consider evidence of a lack of commitment to observing applicable environmental laws and regulations include: o Failing to maintain and enforce written and comprehensive environmental management programs, which are subject to periodic audit.

 Failing to maintain and comply with all required environmental permits.

 Permitting any discharge to the environment in violation of law, issued/required permits, or that would otherwise have an adverse impact on the environment.

 Health & Safety. Failure to provide workers, a workplace that meets applicable health and safety standards.

 Human Rights& Modern Slavery. Failure to respect human rights of supplier’s employees. The supplier certifies that they are in compliance with the applicable modern slavery and anti-human trafficking legislation in their respective countries.

 Code of Conduct. Failure to maintain and enforce company policies requiring adherence to lawful business practices, including a prohibition against bribery of government officials.

 Business Practices and Dealings with TIP. Offering or providing, directly or indirectly, anything of value, including cash, bribes or kickbacks, to any TIP employee, representative or customer or government official in connection with any TIP procurement, transaction or business dealing. Such prohibition includes the offering or providing of any consulting, employment or similar position by a supplier to any TIP employee (or their family member or significant other) involved with a TIP procurement. TIP also requires that a TIP supplier not offer or provide TIP employees and representatives with any gifts, other than gifts of nominal value to commemorate or recognize a particular TIP-supplier business transaction or activity. In particular, a TIP supplier shall not offer, invite or permit TIP employees and representatives to participate in any supplier or supplier-sponsored contest, game or promotion.

 Code of Conduct. Failure to maintain and enforce company policies requiring adherence to lawful business practices, including a prohibition against bribery of government officials.

 Business Practices and Dealings with TIP. Offering or providing, directly or indirectly, anything of value, including cash, bribes or kickbacks, to any TIP employee, representative or customer or government official in connection with any TIP procurement, transaction or business dealing. Such prohibition includes the offering or providing of any consulting, employment or similar position by a supplier to any TIP employee (or their family member or significant other) involved with a TIP procurement. TIP also requires that a TIP supplier not offer or provide TIP employees and representatives with any gifts, other than gifts of nominal value to commemorate or recognize a particular TIP-supplier business transaction or activity. In particular, a TIP supplier shall not offer, invite or permit TIP employees and representatives to participate in any supplier or supplier-sponsored contest, game or promotion.

 Business Entertainment of TIP Employees and Representatives. Failing to respect and comply with the business entertainment (including travel and living) policies established by TIP and governing TIP employees and representatives. A TIP supplier is expected to understand the business entertainment policies of the applicable TIP component or business before offering or providing any TIP employee or representative any business entertainment. Business entertainment should never be offered to a TIP employee and representative by a supplier under circumstances that create the appearance of an impropriety.

 Collusive Conduct and TIP Procurements. Sharing or exchanging any price, cost or other competitive information or the undertaking of any other collusive conduct with any other third party supplier or bidder to TIP with respect to any proposed, pending or current TIP procurement.

 Intellectual & Other Property Rights. Failing to respect the intellectual and other property rights of others, especially TIP. In that regard, a TIP supplier shall:
1. Only use TIP information and property (including tools, drawings and specifications) for the purpose for which they are provided to the supplier and for no other purposes.
2. Take appropriate steps to safeguard and maintain the confidentiality of TIP proprietary information, including maintaining it in confidence and in secure work areas and not disclosing it to third parties (including other customers, subcontractors, etc.) without the prior written permission of TIP.
3. If requested by TIP, only transmit TIP information over the Internet on an encrypted basis.
4. Observe and respect all TIP patents, trademarks and copyrights and comply with such restrictions or prohibitions on their use as TIP may from time to time establish.

 Export Controls & Customs Matters. The transfer of TIP technical information to any third party without the express, written permission of TIP. Failing to comply with all applicable export controls laws and regulations in the export or re-export of TIP technical information, including any restrictions on access and use applicable to non-U.S. nationals, and failing to ensure that all invoices and any customs or similar documentation submitted to TIP or governmental authorities in connection with transactions involving TIP accurately describe the goods and services provided or delivered and the price thereof.

 Use Sub-Suppliers or Third Parties to Evade Requirements. The use of sub-suppliers or other third parties to evade legal requirements applicable to the supplier and any of the standards set forth in this Section of the Guide.

The foregoing standards are subject to modification in the discretion of TIP. Please contact the TIP manager you work with or the TIP Compliance Leader if you have any questions about these standards and/or their application to particular circumstances. Each TIP supplier is responsible for ensuring that the supplier and its employees and representatives understand and comply with these standards. TIP will only do business with those suppliers that comply with applicable legal requirements and reserves the right, based on its assessment of information then available to TIP, to terminate, without liability to TIP, any pending purchase order or contract with any supplier that does not comply with the standards set forth in this section of the Guide.

TIP Trailer Services supports Principle 1 and 2 of UN Global Compact and, therefore, it respects the protection of internationally proclaimed human rights and it makes sure that a company is not complicit in human rights abuses. Respect for human rights is embedded in our Business Principles and in our Code of Conduct. Our approach is informed by the Universal Declaration of Human Rights, the core conventions of the International Labour Organization and the United Nations’ Guiding Principles on Business and Human Rights. We require all our companies and our contractors to respect and protect the human rights of our workforce and our neighbouring communities.

Each TIP supplier is expected to promptly inform TIP of any Integrity concern involving or affecting TIP, whether or not the concern involves the supplier, as soon as the supplier has knowledge of such Integrity concern. A TIP supplier shall also take such steps as TIP may reasonably request to assist TIP in the investigation of any Integrity concern involving TIP and the supplier. An Integrity concern may be raised by a TIP supplier to a cognizant TIP management, or any Compliance Resource (i.e., Company legal counsel or compliance leader).

1. Define your concern: Who or what is the concern? When did it arise? What are the relevant facts?

2. Raise the concern – prompt reporting is crucial:
 Discuss with a TIP Manager;
 Discuss with a TIP legal counsel or compliance leader;
 web: www.tipeurope.com
 email: compliance@tipeurope.com
 A TIP Compliance Resource will promptly review and investigate the concern.

3. TIP Policy forbids retaliation against any person reporting an Integrity concern. Contact the TIP Compliance Leader or the TIP Ombudsperson.

Our policies and actions are in keeping with the UN Global Compact’s Ten Principles in relation to labor which are (3) that businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining, (4) the elimination of all forms of forced and compulsory labor, (5) the effective abolition of child labour, and (6) the elimination of discrimination in respect of employment and occupation.
This can be seen in our Fair Employment Policy below.

SUMMARY:
TIP provides you with fair treatment and equal access to opportunities. We prohibit all forms of illegal discrimination. Hence, we are committed to following the applicable employment laws wherever we operate. That includes observing applicable laws in the relevant jurisdictions in which TIP operates that relate to: freedom of association; privacy; labor relations; the prohibition of forced, compulsory and child labor; immigration; working time and other wage-hour laws; and employment discrimination. Beyond legal compliance, we strive to create an environment considerate of all employees where TIP business is being conducted.

WHAT YOU SHOULD DO TO COMPLY WITH THIS POLICY

1. BASE EMPLOYMENT DECISIONS on job qualifications (e.g., education, prior experience) and on an individual’s skills, performance, TIP values, leadership and other job-related criteria.
2. MAKE ALL EMPLOYMENT RELATED DECISIONS AND ACTIONS without regard to a person’s race, colour, religion, national origin, sex (including pregnancy), sexual orientation, age, disability, veteran status or other characteristic protected by law.
3. PROVIDE A WORK ENVIRONMENT free of improper harassment and bullying including behaviour that is directed at a person because if his and her race, religion, sex etc.
4. MANAGERS must create an environment in which employees feel comfortable raising concerns relating to violations of this policy. A manager or HR manager who receives any concern is responsible for making sure that the concern is investigated, responded to or referred to an ombudsperson if the concern relates to a possible violation of law or TIP Integrity policy.
5. RESPECT THE PRIVACY RIGHTS of employees by using, maintaining and transferring personal data in accordance with applicable laws and regulations.
6. TAKE LAWFUL POSITIVE ACTIONS, if required by law, to increase opportunities in employment for women, minorities, people with disabilities and certain veterans.
7. PROMPTLY RAISE ANY CONCERNS about a violation or possible violation of this policy. Escalate your concern to another person (e.g. TIP legal counsel or ombudsperson) if you do not receive an appropriate response to your complaint. Any concerns that are raised will be thoroughly investigated and, where appropriate, corrective actions will be taken. Confidentiality will be protected to the extent possible, consistent with the need to complete a thorough investigation.
8. IF A CONFLICT ARISES between the requirements of this policy and the laws, customs or practices of a particular area, consult with your TIP legal counsel to determine the most appropriate course of action.

WHAT TO WATCH OUT FOR:
• A HOSTILE WORK ENVIRONMENT (for example, telling jokes or displaying materials that ridicule or offend a member of a particular race or ethnic group).
• DISPLAYING any sexually suggestive visual material in the workplace.
• MAKING UNWELCOME SEXUAL ADVANCES to employees or persons with whom you work.
• VIOLATING EMPLOYMENT LAW in your country (for example, hiring a child under the legal minimum age).
• REFUSING TO WORK, or otherwise cooperate with, certain individuals because of their race, religion, sex, or other characteristic protected by law.
• DISCLOSING EMPLOYMENT DATA to a person who does not have the business need, authority or the subject’s consent.
• TAKING AN ADVERSE ACTION against an employee (e.g., firing, denying a salary increase)

QUESTIONS AND ANSWERS

Q: One of my co-workers has put up posters in his cubicle that make fun of Asian employees. Although she is too shy to say anything, I know that the posters offend my Asian friend, Mei. My co-worker claims that he has a fundamental right to decorate his cubicle any way he wants and that if someone doesn’t like it, they can just stop coming into his work area. Is he right or should a manager make him take those posters down?
A: Distributing or posting materials in the workplace that make fun of or defame a member of a particular religion, race, national or ethnic origin, sex, etc., or taking other actions which have the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment are examples of actions that may constitute workplace harassment and are prohibited by this policy. Your co-worker should be told to take his posters down.

Q: One of the senior managers in my business keeps putting his arm around me and asking me to go out to dinner with him. After several invitations, I am beginning to lose patience with him and am a little afraid of him. I want to report his behavior but am worried that I will lose my job if I do. My own manager is a man and will probably just say it is harmless behavior and I should ignore it. Do I have to report this to someone? If so, who should I tell if I don’t trust my own manager to take action?
A: You should report such behavior as it is creating an uncomfortable environment for you. Any employee who feels he or she might be a victim of harassment is required to raise a concern. You can do this to your manager, HR manager, legal counsel or ombudsperson.

Q: One of my employees asked me to define what constitutes sexual harassment. Is there a good definition I can use?
A: Sexual harassment includes unwelcome sexual advances or requests for sexual favors where submission or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual. Sexual harassment also includes unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature or based on a person’s sex where such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment harassment is required to raise that concern.

Q: My manager ignores my emails and calls and I have difficulty getting time with her to discuss my work and getting direction for my projects. Should I raise a case with an ombudsman?
A: This is a situation where it is more appropriate to contact your HR manager to deal with this situation as the behavior described is not sufficient to constitute a violation of this policy.

TIP Trailer Services supports Principles 3,4,5,6 of UN Global Compact and, therefore, it upholds the freedom of association and the effective recognition of the right to collective bargaining. Moreover, it confirms the elimination of all forms of forced and compulsory labour and the elimination of discrimination in respect of employment and occupation. The company makes its best efforts to make the effective abolition of child labour. We recruit, train and recompense people according to a strategy that aims to organise our businesses effectively; accelerate development of our people; grow and strengthen our leadership capabilities; and enhance employee performance through strong engagement.

PENALTIES FOR VIOLATION:
Employees who violate TIP’s policies are subject to disciplinary action up to and including termination of employment. In addition, if laws are violated, employees or TIP may be subject to criminal penalties (fines or jail time) or civil sanctions (damage awards or fines).

Our policies and actions are in keeping with the UN Global Compact’s Ten Principles in relation to environment which are (7) that businesses should support a precautionary approach to environmental challenges, (8) to undertake initiatives to promote greater environmental responsibility, and (9) to encourage the development and diffusion of environmentally friendly technologies.

This can be seen in our Environment, Health and Safety Policy below.

SUMMARY:
TIP is committed to protecting the health and safety of our employees in all countries in which we operate. This means complying with all applicable environmental, health and safety laws and working to conduct its operations in a safe manner that minimizes environmental impact. Compliance with this policy is a responsibility of management and employees in all functions. All employees must follow this policy and applicable laws and regulations to protect their own health and safety as well as that of other workers, the public and the environment.

WHAT TO DO:

• COMPLY with all applicable environmental health and safety (“EHS”) laws and regulations;
• CREATE AND MAINTAIN a safe working environment and prevent workplace injuries;
• ASSESS EHS LEGAL AND REPUTATIONAL RISKS before starting a new activity, venture or project, selling a new product, acquiring a new business;
• ELIMINATE UNREASONABLE EHS RISKS from TIP’s facilities, products, services and activities;
• TO THE EXTENT REASONABLY PRACTICABLE REDUCE TOXIC AND HAZARDOUS MATERIALS, prevent pollution and conserve, recover and recycle materials, water and energy;
• PROMPTLY ALERT YOUR MANAGER ORTIP EHS manager of unlawful or unsafe conditions, and any work-related injuries;
• PROMPTLY RAISE concerns about possible violations of this Policy to your manager, or via the TIP Ombuds process;
• CONTINUE TO IMPROVE EHS SYSTEMS and performance as an integral part of TIP’s operational strategy.

WHAT TO WATCH OUT FOR

UNSAFE ACTIVITIES AND CONDITIONS, such as:

 FAILURE to use personal protective equipment (shoes, safety glasses, hearing protection, gloves, monitors, etc.);
 UNLABELED or unapproved chemicals;
 EXPOSES or unsafe wiring;
 BLOCKED fire or emergency exits;
 UNSAFE driving or failure to wear seat belts;
 WORKING in high places without fall protection;
 WORKING beneath heavy, suspended loads, or improperly using cranes;
 WORKING on electrical or powered equipment without following safety; (e.g. “lock-out, tag-out”) procedures;
 WORKING unsafely at a customer site;
 POTENTIAL exposure to serious infectious diseases;
 DISABLING safety controls or guarding on equipment and machinery;
 FAILURE to comply with health, safety or environmental regulations and procedures;
 EHS COMPLAINTS from employees, customers or neighbors;
 UNREPORTED environmental, health or safety hazards or accidents;
 FAILING to respond promptly to concerns about possible product safety issues;
 MISSED opportunities for reducing waste and toxic materials;
 FAILING to follow applicable laws and regulations or TIP policies for the management, shipping, transportation, import/export and disposal of hazardous materials and chemicals;
 RISKS AND LIABILITY associated with new acquisitions as well as both new and existing products, processes, services and ventures that present increased legal liability and reputational risk;
 INADEQUATE SECURITY procedures or practices that may present safety threats to a facility and/or employees;
 NEW PRODUCTS, processes, ventures or acquisitions that present increased legal liability and reputational risk 3;

QUESTIONS AND ANSWERS:

Q: Does TIP’s EHS policy apply only to the TIP branches?
A: No. The EHS policy applies to all TIPs facilities, including TIP’s offices, and all TIP’s activities including work at customer locations. Health and safety risks, such as ergonomics, emergency preparedness and electrical safety, can be found in any office environment. Wherever TIP employees are working, we expect them to work safely and in compliance with all EHS laws.

Q: Does the EHS policy cover concerns about the ventilation, lighting or temperature in my workplace?
A: A: Yes. Concerns about ventilation, inadequate or excessive heat, or adequate lighting can be brought to the attention of your supervisor or EHS. In these cases, TIP will look to applicable laws and regulations, and industry guidelines to determine the appropriate conditions.

Q: What about countries where there are no environmental, health or safety laws? What should we do?
A: Most countries have environmental, health and safety laws. In some cases, the laws impose general duties without many specifics. For example, many countries impose a general duty on managers to provide a safe and healthy work environment. In these cases, we have to use our professional judgment to determine what level and type of protection is appropriate in order to comply.

Q: What if the government doesn’t enforce the environmental, health or safety laws? Do I still have to comply?
A: Yes. TIP is committed to being in full compliance with the law, even in countries where enforcement of the law is weak. We do this for four reasons:
1. It is the right thing to do.
2. The enforcement climate can change rapidly if there is a serious incident in the country.
3. Multinational companies are often targeted for enforcement actions even if local companies are not.
4. To protect TIP’s reputation.

TIP Trailer Services supports Principles 7, 8, 9 of UN Global Compact and, therefore, it endorses a precautionary approach to environmental challenges and undertakes initiatives to promote greater environmental responsibility. Furthermore, it encourages the development and diffusion of environmentally friendly technologies. Our success in business depends on our ability to meet a range of environmental and social challenges. We believe that we must operate safely and manage the effect our activities can have on neighbouring communities and society as a whole.

Penalties for violations:
Employees who violate TIP’s Integrity policies are subject to disciplinary action up to and including termination of employment. Violation of this policy can also mean breaking the law, subjecting you or the company to criminal penalties (fines or jail sentences) or civil sanctions (damage awards or fines).

Our policies and actions are in keeping with the UN Global Compact’s Ten Principles in relation to anti-corruption which are (10) that businesses should work against corruption in all its forms, including extortion and bribery.

This can be seen in our Anti-Money Laundering and Counter-Terrorism Financing Policy below.

SUMMARY:
Money laundering is the process by which a person conceals the nature or source of the proceeds of crime and disguises them to appear legitimate. Anti-Money Laundering (AML) laws around the world make it a crime to engage knowingly in a transaction that involves the proceeds of criminal activity. Terrorist-financing is the means by which a person provides or collects funds to support terrorist acts. Counter-Terrorism Financing (CTF) laws make it a crime to use legally or illegally obtained funds to further terrorism. TIP is committed to complying fully with all applicable AML/CTF laws in all countries in which it does business by taking steps to prevent the use of its products and services to facilitate money laundering and terrorist financing. TIP will conduct business only with reputable customers who are involved in legitimate business activities and whose funds are derived from legitimate sources.

WHAT YOU SHOULD DO TO COMPLY WITH THIS POLICY
1. Each TIP employee must comply with all applicable AML/CTF laws and regulations and this Policy and any procedures which implement this Policy.
2. TIP employees have an obligation to understand the “red flags” to watch for in their business activities and to escalate potential compliance concerns related to AML or CTF to the compliance leader without notifying anyone involved in the transaction.
3. “Tipping,” a disclosure of any kind to the subject of the red flag that suspicious activity is being investigated, is prohibited and considered a crime in most countries where TIP does business.

WHAT TO WATCH OUT FOR:
Some generally applicable red flags are described below. Deviation from customer and accepted business practice should alert you to further investigate the activity.
• A customer provides insufficient, false or suspicious information or is reluctant to provide complete information;
• Methods or volumes of payment that are not customarily used in the course of business, e.g., payments with money orders, travelers checks, and/or multiple instruments, and payments from unrelated third parties;
• Receipts of multiple negotiable instruments to pay a single invoice;
• Requests by a customer or partner to pay in cash;
• Orders or purchases that are inconsistent with the customer’s trade or business;
• Payments to or from third parties that have no apparent or logical connection with the customer or transaction;
• Payment to or from countries considered high risk for money laundering or terrorist financing;
• Payments to or from countries considered to be tax havens or offshore jurisdictions;
• Payments from countries unrelated to the transaction or not logical for the customer;
• A customer’s business formation documents are from a tax haven, or a country that poses a high risk for money laundering, terrorism or terrorist financing, or a country that is not logical for the customer;
• Overpayments followed by directions to refund a payment, especially if requested to send the payment to a third party;
• Any customer for whom you cannot determine the true beneficial owner;
• Structuring transactions to avoid government reporting or recordkeeping requirements;
• Unusually complex business structures, payment patterns that reflect no real business purpose;
• Wire transfer activity that is not consistent with the business activities of the customer, or which originates or terminates with parties unrelated to the transaction;
• Unexpected spikes in a customer’s activities;

QUESTIONS AND ANSWERS:

Q: TIP does not accept cash or cash equivalents such as money orders and cashier’s checks. Are we still at risk of becoming involved in money laundering activity?
A: Yes. The elimination of cash as an acceptable form of payment does not eliminate money laundering risk. Money launderers and their criminal clients are constantly developing more sophisticated means of laundering money to evade detection, including through the use of cash equivalents, third-party wire transfers, structured transactions, foreign currency and even real estate transactions.

Q: Do suspicious situations require special escalation procedures?
A: Yes. If a TIP employee knows or suspects that a customer is a terrorist, a member of an organized crime organization, or a Politically Exposed Person (PEP) who is being investigated for a crime or has been charged with a crime, then the TIP employee must immediately notify TIP risk leader, TIP compliance leader or TIP general counsel.

(TIP encourages employees to provide service to worthy not-for-profit organizations. Financial commitments should be made from personal, not TIP resources. Requests for TIP funding should be reviewed for potential conflicts of interest on a case-by-case basis with the manager)

TIP Trailer Services supports Principle 10 of UN Global Compact and, therefore, the company work against corruption in all its forms, including extortion and bribery.

We seek to obtain the best possible information to enable us to assess threats and risks. We conduct detailed assessments for all sites and activities, and implement appropriate risk mitigation measures to detect, deter and respond to corruption, extortion and bribery threats.

PENALTIES FOR VIOLATION:
Employees who violate this Policy and the business’ related procedures may be subject to disciplinary action up to and including termination of employment. In addition, violation of any AML/CTF laws or regulations could lead to employees and the company being convicted of the crime of money laundering or terrorist financing, resulting in fines, forfeiture of assets, and other serious punishment including imprisonment. Such violations could jeopardize or damage TIP’s reputation and management and employees must realize that they will be held accountable. The legal concepts of “willful blindness” and “conscious avoidance of knowledge” expand the reach of AML criminal laws to include an employee who has or should have suspicions of money laundering, but who deliberately fails to make reasonable inquiries about the suspicious activity or report the suspicion. TIP holds its employees to even higher standards. Any manipulation, modification, alteration or omission to avoid a customer or payment from being captured or properly reviewed by an AML/CTF screening or transaction monitoring process will be viewed as a serious breach of TIP’s principles and may be subject to disciplinary measures.