Code of conduct.

This Code of Conduct sets out the principles that govern how KVNG 2HANDEL does business. It applies to every director, employee, contractor and agent who acts on behalf of the company, in every country where we operate.

International trade depends on trust. Customs authorities, banks, insurers and counterparties rely on the accuracy of our documents and the integrity of our conduct. This Code describes the standard we hold ourselves to so that trust is earned on every trade.

Four values guide our decisions. Integrity: we act lawfully and honestly, and we are open to scrutiny. Reliability: we plan carefully and deliver what we have agreed. Partnership: we build long-term relationships rather than one-off deals. Responsibility: we take ownership of the goods we move and the way we move them.

Where this Code does not address a situation, these values do. If a course of action would not withstand examination by a regulator, a partner or the public, we do not take it.

We deal fairly with suppliers, buyers, service providers and competitors. We do not misrepresent goods, prices, origin or terms, and we do not take unfair advantage of anyone through manipulation, concealment or abuse of privileged information.

We compete on the quality of our service and the reliability of our supply. We do not enter into agreements with competitors that fix prices, allocate markets or restrict supply, and we comply with the competition laws of every jurisdiction in which we trade.

We do not offer, promise, give, request or accept bribes, kickbacks or any improper advantage, whether directly or through a third party. This includes facilitation payments to speed up routine official actions such as customs clearance, permits or inspections.

Gifts and hospitality may be given or accepted only where they are modest, infrequent, transparent and appropriate to the business relationship, and never to influence a decision. Payments to or through agents, brokers and intermediaries are made only against a written agreement, for legitimate services, at a reasonable rate and to a documented account.

Before every transaction we screen counterparties, goods, vessels, routes and destinations against the sanctions, embargoes and export-control regimes that apply to us. We do not trade with sanctioned persons or entities, and we do not structure transactions to circumvent sanctions or licensing requirements.

Where goods, software or technology are subject to control, we obtain the required licences before shipment and we respect end-use and end-user restrictions. Any doubt about the status of a counterparty, product or destination is raised before the trade proceeds, not after.

Business decisions are made in the interest of the company and its partners, not for personal gain. A conflict of interest arises when a personal, family or financial interest could influence, or appear to influence, a decision taken on behalf of KVNG 2HANDEL.

Anyone who acts for the company must disclose actual or potential conflicts in writing before taking part in the related decision. Disclosed conflicts are recorded, and the person concerned steps back from the decision where the company requires it.

Our books, records and documents reflect each transaction completely and truthfully. Contracts, invoices, packing lists, certificates of origin, customs declarations and financial entries describe what actually took place, in the amounts and on the dates that it took place.

We do not create false or misleading documents, keep undisclosed accounts or alter records after the fact. Records are retained for the periods required by law and by our commercial agreements, and are made available to auditors and authorities when lawfully requested.

Commercial information entrusted to us by partners, including prices, volumes, specifications and counterparties, is used only for the purpose for which it was shared and is protected from unauthorised disclosure. The same applies to the company’s own information.

We collect personal data only where we have a lawful basis and a business need, we keep it accurate and secure, and we process it in line with the data-protection laws that apply to us. Access to confidential information and personal data is limited to those who need it to do their work.

We take reasonable care for the health and safety of our people and of those affected by our activities, including at ports, warehouses and sites we visit. Goods are packed, labelled, stored and transported in accordance with the safety and dangerous-goods rules that apply to them.

We comply with environmental laws in the jurisdictions where we operate and we expect the same of our suppliers and logistics partners. Where we have a choice, we favour practices that reduce waste, emissions and environmental harm along the supply chain.

We treat colleagues, partners and members of the public with dignity and respect. We do not tolerate harassment, discrimination or bullying on any ground, including sex, age, origin, religion, disability, sexual orientation or political opinion.

We do not use, and we do not accept in our supply chain, forced labour, child labour or human trafficking. We respect the right of workers to fair terms of employment, and we expect our suppliers to meet the labour laws and international standards that apply to them.

Anyone who becomes aware of conduct that may breach this Code, the law or our policies is expected to raise it. Concerns can be raised with a manager or confidentially with the compliance function at compliance@kvngtwohandel.com. Reports may be made anonymously.

Every report is reviewed and, where appropriate, investigated. We do not tolerate retaliation against anyone who raises a concern in good faith or who assists an investigation, even where the concern is not upheld.

Managers are responsible for making sure that the people they lead understand this Code and act on it. Each person is responsible for their own conduct and for asking when they are unsure. Breaches of the Code may lead to disciplinary action, termination of employment or contract, and referral to the relevant authorities.

This Code is reviewed periodically and updated as our business and the law develop. Business partners are expected to uphold the principles set out here in their dealings with and on behalf of KVNG 2HANDEL. Questions about the Code may be addressed to compliance@kvngtwohandel.com.