21 Nov 2012

To our stakeholders:

I am pleased to confirm that RG Cargo reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Perminder Sandhu
Director

Extract from our Business Code of Conduct is reproduced below and is relevent.

At RG Cargo we prohibit:
· all form of harassment done by an employee or representative of Hellmann - including
demeaning, insulting, embarrassing or intimidating behaviours and/or comments
towards any employee related to gender, race, ethnicity, sexual orientation, physical or
mental disability, age, pregnancy, religion, national origin or any other legally protected
status.

As stated above we have stipulated clear guidlines for ensuring protection of Human Rights.

Any case of Human Rights violation gets reported to company HR manager who carries out a detailed investigation and suitable action is intiated to ensure it does not recur.

RG Cargo has clearly laid down policies to comply with labor laws, employee rights and to uphold freedom of association and collective bargaining. We do not employee labor forcibly and never employ child labor.

RG Cargo Policy on employee Safety and Health is reproduced below :

ENVIRONMENT, HEALTH, SAFETY AND SECURITY GUIDELINES

OBJECTIVE: To provide a safe and healthy working environment including safe system of work for all the employees and for non-company personnel whilst on company premises. Prove a healthy and safety organization at all the operating levels to effectively manage and monitor safety policy at Company. Increase employee awareness of their responsibility for the health and safety of themselves and other personnel.

OPERATING SYSTEM: HWL Cargo Services recognizes the need for safety, security for its employees, offices, clients and their goods handled by the Company. To ensure prevention of personal injury, damage to property and the environment, as well as to ensure that responsibilities for Health & Safety, Welfare and Environment are properly assigned and fulfilled at all levels.

PERSONAL SAFETY AND EMPLOYEE RESPONSIBILITY: Safety is matter of individual responsibility. Every member of HWL India must take the responsibility on himself or herself to be alert for possible unsafe situations or actions and ensure directly or through others that they are eliminated.

All the employees at all levels will take responsible actions based on understanding their technologies, product and facilities keeping safety health and environment into force.

Every employee at work will take necessary steps to protect the health, safety, welfare and environment of themselves and all other persons who may be affected by their acts and omissions.

Ensure the Health and Safety of himself/herself and of other persons who may be affected by his/her acts of omission at work comply with Health & Safety instructions, verbal or written and use all items provided for their Health Safety & Welfare.
Report all accidents, whether persons are injured or not and provide all assistance and information to the Management, in investigating and recording of details of all accidents and/or incidents in their area of responsibility – whether these are injury causing or not – and convey this information to all concerned to prevent such accidents for the future.

Report all hazards, potential hazards or persons creating hazards.

Do not misuse anything provided in the interest of Health & Safety.

Undergo periodic medical check- ups as a preventive measure and the necessary inoculation.
Do not to use drugs or any other intoxicants while at work.

VEHICLES

The employees must ensure that their vehicles (company owned or self owned) are properly maintained and adopt safe driving practices. (Please see annexure GEN7).

The schedule of preventive maintenance as specified by the manufacturer must be adhered to.

SAFETY AT WORK

Managers will ensure that :
a) working environment of all employees is safe and without risks to health and that adequate provisions are made for First Aid, Welfare and Occupational Health.

b) A proper view should be taken of the workplace and work environment. The tools, chairs, desks, workstations and equipments should be arranged so that the person can work effectively and comfortably.

c) Control on machinery must be standardized and should operate uniformly and correctly positioned.

d) Provide each user with training in the use and assessment of their work station. E.g. the files should not be kept lying on the floor as it may pose a hazard.

e) Keep records of all assessments and corrective actions taken.

f) Review any significant changes in the work place.

g) Any person who is likely to be regularly exposed to noise levels in excess of 82 dB (A) should be given a periodic audio check.

h) All employees have regular eye checks.

OCCUPATIONAL HYGIENE FACILITIES

Manager will ensure :
a) Ensure facilities provided for staff such as toilets, lockers, pantry etc., are adequate for the number of staff and are kept in a clean and hygienic state.
b) Toilets, washbasins, etc., should be cleaned and provided with adequate sanitary facilities i.e. toilet paper, soap etc.

c) Provision for safe and clean drinking water.

d) Goods kept in fridges and storerooms must be stored correctly and at correct temperatures.

e) Pantry should be clean with no flies or vermin and garbage controlled.

POLLUTION

All pollutants must be identified, including factors of noise pollution and controlled to eliminate any discharge, which may adversely affect the health of individuals.

GOOD HOUSE KEEPING PRACTICES

Storage areas should be clearly marked. Loose rubbish should be enclosed.

Buildings, floors, roof should be kept clean and in good repair.

Rubbish should be removed regularly and not dropped on the floor / walkways or left behind or inside drawers or cabinets.

Adequate storage space should be provided.

LIGHTING: Natural or Artificial

Lighting should be appropriate especially for night work and emergencies.

Emergency lighting/generators should be supplied from an independent source.

Windows are translucent sheeting must be clean, unobtrusive and free from glare.

Lights must be correctly positioned, secure and clean. Extra precautions must be taken to prevent fluorescent tubes from dislodging and falling on employees or product.

Toughened or laminated glass must be used in hazardous areas.

Glass doors or walls or large areas of glass must be marked or etched to prevent possibility of personnel colliding with them.

VENTILLATION

Proper ventilation should be provided at the offices/warehouse etc. Ventilation openings should be located at high and low levels, should be obstructed and positioned correctly.

Air-conditioning should be proper and checked regularly. Where individual Air conditioners are provided, should follow the schedule of preventive maintenance.

ELECTRICAL SAFETY

The highest standards of electrical safety must be observed at all times. It should never be forgotten that electricity has capacity to be lethal.

To ensure the safe use of hand tools the following procedures should be followed.

All portable electrical tools and equipment must only be used on single-phase supply.

Where electric powered tools are used from a trailing lead:

i. The length of the lead should be kept to a minimum.

ii. The cable should be heavy duty and capable of serving the equipment that it is to supply.

iii. It should be paid out fully from any winding drum and if at all possible be protected from damage.

iv. It should be laid with care to ensure that it does not present a trip hazard to others or to the user of the equipment.

When using power tools that are designed to be fitted with guards, the guards will be fitted correctly prior to the use of the tool.

Power tools must be isolated from the power source before any routing adjustments are carried out (e.g. when replacing bits or blades).

The correct fuse rating must be used for all electric tools.

Managers and Supervisors should ensure that equipment and tools are properly maintained and repaired, that correct working methods are followed and that no unsafe practices are tolerated.

Employees should use tools in the correct manner and for the correct job, using the safety devices and equipment provided and report conditions they believe to be dangerous.

FIRE SAFETY

Fire safety is an important issue for everyone in the workplace from Managers and employees to visitors, contractors and maintenance sub-contractors, It is the single, biggest threat of serious injury and death in the workplace as well as having the potential for major disruption to the business.

There are all manner of potential fire risks in the workplace, from smoking to hazardous materials, but the biggest single cause of fire in the workplace is faulty electrical equipment.

Managers are therefore required to:

a. Carry out a risk assessment of fire hazards, either as a part of a general assessment of health and safety risks or as a separate exercise.

b. Check that any fire can be detected in reasonable time and that all people on the premises can be warned.

c. Check that everyone in the building can leave safely.

d. Ensure availability of fire- fighting equipment.

e. Ensure that those in the building know what to do in the event of a fire incident by providing appropriate information and training.

f. Check and maintain fire-fighting equipment.

FIRE ESCAPE ROUTES

Fire escape routes must be clearly indicated – including emergency exits and all exits not in normal use – so that people are made aware of alternative ways of leaving the building in an emergency. Fire exit signs must be placed immediately above the exit or if this is not practical in a position where the sign can be clearly seen and where it is least likely to be obstructed or obscured. In warehouses where goods may in transit, which may prevent a clear view of the exit doors, employers must ensure that directional arrows are placed at suitable points along the escape route so that people can find the fire exits.

EMERGENCY PLAN

If five or more people are employed in the work place employers must have a written escape plan. This plan must be displayed in the workplace and must inform employees of what to do in the event of a fire. Managers should use the results of the risk assessments to draw up their plan.

FIRE FIGHTING EQUIPMENT

All workplaces must have adequate fire-fighting equipment in place and employees must be provided with appropriate training so that they may attempt to extinguish a fire in its early stages without exposing themselves to any danger.

A number of portable extinguishers should be strategically placed throughout the premises so that they are readily available for use. The type of extinguisher should be dependent on the risks present. It is essential that the correct extinguisher is used on certain fires – for example a water extinguisher should not be used to extinguish fires involving flammable liquids (a violent reaction may result).

There are four main types of extinguishers:

Dry Powder: Suitable against fires involving flammable liquids or live electrical apparatus.

Water: Most fires except those involving flammable liquids or live electrical apparatus.

Carbon Dioxide: Suitable against fires involving flammable liquids or live electrical apparatus.

Foam: Suitable against fires involving flammable liquids.

FIRST AID AND MEDICAL FACILITIES

Steps must be taken to ensure that equipment and facilities are adequate for the provision of first aid for employees, if they are injured or become ill at work.

Ensure that suitable people are trained to give first aid. Each office must have atleast 1% of the workforce.

All employees must have reasonable rapid access to first-aid equipment and boxes.

First Aid Boxes

First Aid Boxes are provided within the workplace to ensure that there are adequate supplied for the nature of the hazards involved. All boxes will contain at least the minimum supplies which are required under law. Only specified First Aid supplies will be kept. No creams, lotions or drugs. However, seemingly mild, will be kept in these boxes.

The location of First Aid Boxes/Accident Book and the named person responsible for their upkeep will be clearly indicated in the work place.

First Aid Boxes are maintained and restocked by the Appointed First Aider. For the purposes of maintaining first aid supplies, First Aiders keep a record of those supplies held and replenishments ordered when necessary.

Portable First Aid Kits are available for those members of staff who are regularly required to work away from the normal workplace, where access to facilities may be restricted.

1. The provision and maintenance of equipment and systems of work are safe and without risks to health and the environment.

2. Arrangements for use, handling, storage and transport of articles and substances are safe.

3. Adequate information and training is available detailing the conditions and precautions necessary to secure the health, safety and welfare of all employees, visitors and sub-contractors.

4. All necessary safety devices and protective equipment is available and used according to manufacturers/suppliers instructions.

5. All the employees are responsible for ensuring that the policy is effectively implemented by carrying out risk assessments and making periodical checks as required by company procedures and deal with problems as they arise. All employees will be required to undergo training and orient themselves so as to ensure that they are equipped to implement this policy.

APPROVED CONTRACTORS

HWL Cargo Services will only use contractors who have proved able to discharge their primary responsibility to safeguard their employees and other persons who may be affected by their undertakings. This will be administered in the form of an approved list of contractors, which will describe the contractor capabilities and limitations. The list will be constantly reviewed and sanctions will be applied as a result of poor Health and Safety performance including written warnings, suspension, financial penalties and removal from the approved list.

Site safety rules will be issued to all contractors and will be clearly stated in contractual arrangements together with any special Health and Safety requirements likely to affect cost or time-scales.

ACCESS TO COMPANY PREMISES

The entry and exit of the employees, visitors, contractors, material and vehicles should be properly controlled. Identity cards should be issued to employees and Visitor’s book maintained. All Visitors must be met only in the designated areas.

The entry and exit should be through the are specified for the same.

All visitors must be accompanied at all times when on Company premises.

Upon arrival, the visitor(s) must complete required details in the register/visitors book and a visitor’s pass issued. Visitors sign out before leaving the premises and any Company property must be returned. They must also be informed of any specific risks whilst on Company premises.

Any problems encountered by visitors, or by employees with regard to visitors, should be reported to the Health and Safety Committee.

Security Arrangements must be adhered to when visitors enter Company property. Particular care must be taken of visitors entering areas of high risk. Where a visitor is required to enter an area where limitation of access arrangements apply, access must be correctly authorized.

RISK ASSESSMENTS

Management will carry out regular Assessments in conjunction with staff concerned. A new assessment will be carried out following any changes to working practices, environmental or building changes.

DEFINING STANDARDS

The HWL Cargo Services process of setting standards will involve the following:

a) Identification of hazards i.e. the potential cause of harm/damage.

b) The assessment of risk i.e. the likelihood that harm will be realized.

c) The elimination or control of risk by determining suitable protective and preventative measures.

d) The implementation of the control measures, through provision of resources, information, training and supervision.

e) Monitoring and review of any implementation program to a satisfactory conclusion.

HEALTH & SAFETY COMMITTEE

Each office will have a health and safety committee, chaired by the location head at locations and Director HR & Admin or any other person designated, at corporate office. The main aim of the Health & Safety Committee is to monitor and review current procedures and practices, identify any action required to control potential risk. Managing Director is regularly informed of Healthy and Safety issues.

WARE HOUSE SAFETY

The warehouse must adhere to the systems and procedures as laid down in the procedure manual, while ensuring all the above aspects.

The scales and other equipments must be maintained and serviced as per the manufacturer’s instructions. They should be calibrated as per schedule. The schedule of preventive maintenance must be adhered to.

The storage and stacking will be as per the procedure laid down in the quality manual. Adequate training should be given to staff for lifting of goods in a safe and proper manner.

SAFETY REQUIREMENTS FOR LABOURERS AT WAREHOUSE

o The worker should always carry his or her ID card.
o Safety Helmets.
o Safety Jackets with HWL Hologram.
o Safety Shoes.

STORAGE OF HAZARDOUS MATERIAL

In case of storage of hazardous material obtain from the manufacturer/client material data safety sheets, which give the chemical breakdown of the substance in question and other relevant information.

Hold these details on file and, if required, to pass copies to any relevant persons.

Ensure all staff are aware of any possible risk and train them in the safe use or handling of such products/substances.

Ensure that such products/substances are stored safely in accordance with the safety data sheets and that any signs relating to such storage are in place.

Ensure that staff has sufficient information, training and facilities to enable them to deal with any accidental spillage or other such emergency.

BOMB THREATS/DISCOVERY OF SUSPECT CARGO

In the case of bomb threats and/or hoax callers, it should be informed to the immediate supervisor who in turn should take suitable action or report to local police authorities.

Cargo being handled through a HWL Cargo warehouse facility may be found to be suspicious i.e. contain material that cannot be satisfactorily accounted for. It should immediately be reported to the immediate supervisor or Location Head as the case may be. In the absence of any of them, information to the local police authorities may be given.

TRUCK DRIVERS

All drivers must have passed a test for the type of truck being used and carry their license with them.

The Company will keep records of qualified drivers and copies of their licenses/certificates of training.

Drivers will undertake a re-test at five yearly intervals to reaffirm sage working practices and remove any bad habits, which may have developed over time.

They shall follow traffic rules and regulations as specified by the Government.

ACCIDENT RECORDING INVESTIGATION AND INCIDENT CONTROL
All accidents or near misses must be reported to the safety committee and the same must be thoroughly investigated. The prime objective of investigation is to eliminate such risks for the future.

The concerned staff, manager and others must be involved in the investigation.

Identify the person responsible for carrying out corrective action. The time frame for corrective action should be specified.

Record of all accidents must be kept and communicated to all the other offices to avoid such accidents at other locations.

EHS AUDITS

Yearly audits will be carried out by the team responsible for Quality. Any non-conformity will be recorded for agreed corrective action. Managers must be vigilant at all times in identifying potential risks in the workplace and ensuring appropriate action is taken promptly.

WRITTEN RECORDS

Written records of all the assessments, audits and meeting are to be maintained at all locations.

TRAINING & INSTRUCTION

All employees will be given adequate training on various aspects of security and safety, including fire-safety, personal safety etc.

Induction training must be organized for new/transferred employees on Health, Safety and Welfare Awareness within their area of responsibility.

Senior manager regularily undertake safety walks

Our Corporate DNA
F-A-M-I-L-Y
The core of who we are resides in the fact that we are a family owned company and we are
proud of that.
We promote the essence of what it means to be a family throughout the company. We
encourage our members worldwide to build strong relationships based on integrity,
understanding and mutual cooperation. The owners have always, and continue to be, directly
involved in the management; each decision is taken weighted against criteria that reach far
beyond short term outcomes.
We ensure the long term viability of Hellmann so it continues to provide opportunities for
generations to come.
FIRST, PEOPLE FIRST
ALL ABOUT THE CUSTOMERS, ALWAYS
MAKING IT WORK BETTER, EVERYDAY
INNOVATION AND ENTREPRENEURSHIP
LIVE SUSTAINABILITY
At Hellmann, we are serious about providing services based on the principles of economical, ecological, and social sustainability to create new opportunity for future generations. We are sensitive and responsible to the people, communities, and environments within the regions in which we are active. Through these principles of sustainable development, we ensure the future of our family-owned business.
YOU AND ME

We constantly measure the use of paper, electicity and fuel in our company and encourage programmes to reduce the usage.

Senior management regularily audit the usage and reduction targets with respect to use of paper, electricity and fuel.

Relevent extracts from our corporate code of conduct is appended below :

We are committed to doing business with integrity and in accordance with applicable
laws.
RG Cargo understands the importance that compliance plays within our own internal
organization, with the people we employ, with the vendors with whom we partner and the
government agencies with which we interact. RG Cargo conducts our business in the strictest
compliance not only with the appropriate laws and regulations of the countries where we
operate, but also with our own internal standards of excellence and ethics. Our business
partners and employees are expected to fully comply with this Code of Business
Conduct. Further, RG Cargo practices a zero tolerance policy for those employees and
business partners that violate this Code of Business Conduct.RG Cargo's enforcement of this
policy combined with our zero tolerance philosophy ensures that we conduct business ethically
perpetuating our reputation that is synonymous with quality and integrity. RG Cargo also
encourages and empowers each employee around the world to promptly report any and all
reasonable suspicions of Code of Business Conduct being violated. Our
empowerment is accomplished through ensuring that our employees are free from retaliation or
negative consequences for bringing issues that they believe in good faith constitute a violation
of Code of Business Conduct.
Preface
Compliance to Code of Business Conduct is mandatory for all RG Cargo offices.
This Code of Business Conduct sets forth standards of conduct for all our employees, network
partners, agents, subsidiaries and affiliates throughout the world. While a code cannot
anticipate nor encompass every possible scenario or situation, we strive to ensure that
Hellmann’s standards, ethics and integrity are thoroughly explained and embodied in our Code
of Business Conduct. We have therefore created our policies to serve as “guides” on
navigating through any such issue when confronting our employees and offices. Each
person/branch has the ultimate responsibility of ensuring and knowing which compliance policy
pertain to its operations in the country in which it transacts business. Pursuant to our zero
tolerance policy, any individual employed with RG Cargo who violates any legal, moral or ethical
Code of Business Conduct
6
responsibility, regardless of his/her position in the company or tenure with the company will be
disciplined accordingly, including but not limited to termination and in certain cases criminal
prosecution.

Anti-Corruption

RG Cargo being a fully owned subsidiary of Hellmann Worldwide Logistics, we are committed to the Hellmann Anti Corruption policy as under :

As any company operating in the United States, Hellmann is subject to U.S. anti-bribery laws
that are globally enforceable for all Hellmann business units, affiliates, operations, employees
and agents. Of particular importance is the United States Foreign Corrupt Practices Act
(FCPA) and/or similar laws and regulations for the countries in which Hellmann transacts
business. In general, the U.S. Congress enacted the FCPA in order to prohibit (through
criminal enforcement) bribery of foreign officials in an attempt to restore public confidence in
the American businesses. While the United States was the first country to implement such
measures, the last decade has seen a flurry of international activity geared at combating
corruption throughout their own government agencies. Specifically the FCPA prohibits a U.S.-
based company or any of its worldwide businesses or affiliates from, directly or indirectly,
bribing, inducing, enticing, coercing, offering, promising, or authorizing anything of value to a
foreign government official in exchange for new or continued business-or for favorable
treatment by that government entity. If violated, Hellmann could be held liable for such
payments-and knowledge of such intent or motivation is not an element. I.e., if Hellmann
should have known that the monies would end up in prohibited hands, Hellmann can be found
liable. Therefore, we conduct our business in strict accordance with the FCPA and all other
similarly situated international prohibitions. Any violations will be immediately dealt with the
appropriate disciplinary measures. Any suspicions will be promptly and thoroughly investigated
to a final conclusion, again, with the understanding that Hellmann will be willing to enact the
appropriate disciplinary measures that can include termination and in some cases, criminal
prosecution.
Antitrust/Un-Fair Competition
Hellmann’s belief is that healthy competition can only improve the services offered by Hellmann
while benefiting the consumer when it comes to pricing. It is Hellmann’s policy to compete
honestly, effusively and aggressively in strict adherence with all applicable antitrust and
competition laws as they are formulated to maintain a competitive economy and to foster fair
and healthy competition. All Hellmann employees, agents, partners, offices and affiliates are
required to comply with these laws and regulations. These laws and regulations encompass
such areas as customer interactions, competitors, suppliers, vendors, attendance at trade
associations, meetings and pricing discussions. As fair competition standards are a legal
requirement in nearly every country in which we operate, Hellmann is required to comply with
these laws and regulations. All Hellmann employees who are specifically and intimately involved
in sales, pricing, marketing, or involved discussions with competitors, have a heightened
responsibility to ensure that they understand our policy and their applicable competition laws.
Our policy specifically prohibits any employees from engaging in discussions or attending
meetings regarding any pricing discussions with our competitors for any purpose. Pursuant to
our zero tolerance policy, any individual employed with Hellmann who violates any legal, moral
or ethical responsibility, regardless of his/her position in the company or tenure with the
company, will be disciplined accordingly, including but not limited to termination and in certain
cases criminal prosecution.

All employees have to sign the corporate code of conduct on joining and are regularily informed that any violation will attract disciplinary action.

Internal audits are conducted to ensure consistency with anti-corruption commitment, including periodic review by senior management