Our Policies Cargoquin

Gender Equality

At Cargoquin, Inc. and 3PL Services, S.A. de C.V. we are committed to promoting and supporting human rights inside our facilities, as well as to providing equal opportunities to men and women. We provide employment and training opportunities without discrimination of any kind (being prohibited all kinds of discrimination based on race, gender, disability, ideology, religion, economic level, or sexual orientation.) We strive to prevent, eradicate, and punish sexual harassment, and all forms of violence and to provide a healthy work environment, while promoting a balance between work and family for our employees, following the Gender Equality Model (MEG: 2012), the provisions of the National Institute for Women, and according to our Social Responsibility Management Model.

Business Policy

At Cargoquin, Inc. we are committed to our employees and their families, our shareholders, clients, suppliers, community, government, as well as to taking care of our environment, while we strive daily to provide agility and quality in our services. Our company promotes a work environment free of violence, harassment, bullying, and discrimination of any kind, in order to guarantee equal opportunities and gender equality to our employees. We work as a team, doing our best to provide constant training and a decent source of employment.

We speak out against any form of forced and child labor and against any situation that endanger the safety of our employees, clients, suppliers, and neighbors. Through policies, strategies, and actions promoted by our Ethical Corporate Governance, we foster teamwork and a sense of belonging, in addition to promoting respect for our environment through our Environmental Management Plan. We promote the celebration of Inter-Sectoral Alliances with local suppliers acquiring products that generate high social value, strengthening our commitment towards the community.

We select local suppliers, preferring the products and services of those who share our commitment to the community (internal and external) and to the environment. We make sure that each of our activities adheres to the legal provisions of the matter, respecting the regulatory government institutions of our branch of services. In accordance with our Code of Ethics and Conduct, we declare ourselves against any type of unfair competition.

We guarantee the confidentiality and effective protection of the documentation and information of our clients, suppliers and employees, promoting responsibility, discretion and loyalty among our staff and managers, complying with the laws on transparency, and protection of personal data and accountability to the government and its customers.

Training Policy

We aim to provide our employees with the necessary tools for their personal and professional development through constant training, thereby improving significantly their quality of life, since the acquisition of new knowledge and skills will bring them the possibility to grow within our company, improving their current conditions and future employability. Our company will provide training without distinction or discrimination of any kind, regardless of gender, age, sexual orientation, economic level, disability, religion or ideology. Therefore being prohibited any action or omission that results in the degradation of human dignity.

Workplace Health and Safety Policy

At Cargoquin, Inc. we commit to carry out all operations in terms of safety, workplace health, and control of material damages in all activities, including compliance with legislations, establishing for this purpose responsibilities and assignments for monitoring the compliance to this policy.

At Cargoquin, Inc. we commit to carry out all operations in terms of safety, workplace health, and control of material damages in all activities, including compliance with legislations, establishing for this purpose responsibilities and assignments for monitoring the compliance to this policy.

• -At Cargoquin, Inc. we commit to carry out all operations in terms of safety, workplace health, and control of material damages in all activities, including compliance with legislations, establishing for this purpose responsibilities and assignments for monitoring the compliance to this policy.
• -As part of our strategies, we commit to:
• -Establish an Administration System for Safety and Health.
• -Provide our employees with training and resources for the implementation of this policy.
• -Prevent accidents in our company through united efforts and commitments.
• -Ensure the execution of the different activities in terms of safety and health, considering the associated risks, in order to guarantee the physical integrity of our employees, protect our facilities and avoid risks to third-party properties and to the environment.

Psychosocial risk prevention policy

At Cargoquin, Inc. the following commitments are assumed in relation to the prevention of psychosocial risk factors, the prevention of workplace violence and the promotion of a favorable organizational environment:

• 1. It is the obligation of supervisors, managers, and directors to apply this policy and lead by example.
• 2. Acts of violence are not tolerated, as are any incidents that promote emotional risk factors or actions against the healthy work environment.
• 3. In this organization, actions are taken to promote a healthy work environment, avoiding workplace violence.
• 4. There is a fair procedure, which does not allow reprisals and avoids abusive or unfounded claims, and which guarantees the confidentiality of the cases.
• 5. Along with Awareness actions, information programs (dissemination campaigns) and trainings.
• 6. We have effective dissemination campaigns for a healthy work environment.
• 7. Employees are encouraged to participate and put this policy into practice in the workplace.
• 8. The exercise of the rights of employees to observe their beliefs or practices or to satisfy their needs related to race, sex, religion, ethnicity or age or any other condition that may give rise to discrimination is respected.
• 9. Spaces for participation and consultation are created, taking into account the ideas of employees.

Environmental Policy

• - Implement and maintain an environmental management plan that allows us to mitigate environmental contamination.
• - Promote the continuous improvement of a management system, having as a reference the identification of risks and the prevention of contamination.
• - Disseminate and promote among our employees the saving of resources, being more efficient and promoting the improvement of processes in such a way that it is economically viable.
• - Comply with the regulations applicable to our operation and encourage our commitment to employees, contractors and suppliers.
• - Prevent contamination of air, water and soil resources through emission control and final disposal of waste.
• - Properly disseminate this policy among employees, making them aware of its importance and among external agents that maintain a relationship with us and with society.
• - Prevent, reduce and control the pollution that our processes may cause to the environment.
• - Provide our employees with the necessary resources to comply with this policy, as well as the objectives and indicators established in the environmental management plan.

Política Anticorrupción Grupo Cargoquin

Objective

I At Cargoquin, Inc. we are committed to conducting our business with honesty, integrity, trustworthiness and responsibility. Since 1969, our founder, the customs broker Orfelio Quintanilla, managed to transmit to employees, partners and friends the values that today form us as a company.. We responsibly comply with the anti-corruption laws applicable to the countries where we do business, in addition to having a code of ethics and business conduct.

Group Policy

II This policy applies all employees of Cargoquin, Inc. regardless of where they are located. All employees have the responsibility to comply with this policy in the exercise of their duties on behalf of the company. The management of Cargoquin, Inc. has the responsibility of ensuring that the employees comply with this policy. Management has conferred compliance responsibilities on some employees. The compliance department will help employees understand and comply with this policy and will take the necessary steps to maintain and carry out an anti-corruption program. However, the responsibility for compliance will continue to be of the employees. Cargoquin, Inc.'s operations in certain countries may need additional specific anti-corruption guidelines to comply with laws and respond to local circumstances. Any additional country-specific guidance must be aligned with this policy. Violation of any federal, state or foreign law will not be permitted or tolerated.

Supervision and Administration

III The directors, managers, Social Responsibility Committees and internal audit teams of Cargoquin, Inc. are responsible for supervising this policy and the company's anti-corruption program. Pamela Valenzuela as Director of Human Resources and Corporate Social Responsibility, as well as Jorge de Haro Bueno as Director of Administration and Legal Representative, supervise the compliance with this policy and the company's anti-corruption program. Under their direction, their direct work teams are responsible for ethics compliance in the group, managing daily requests and routine approvals as described in this policy. Questions related to this policy and/or requests for approval should be addressed to Pamela Valenzuela or Monica Garcia by phone (867) 715 16 30 or email anticorrupcion@cargoquin.com

All forms of bribery and corruption are prohibited

IV Bribery occurs when items of value are directly or indirectly provided to individuals, including government officials, business partners, clients or potential clients, for their personal benefit, in order to influence their actions or decisions relating to their official positions or of the company. Sometimes bribery is obvious, but there are cases where it is very subtle. Employees of Cargoquin, Inc. have the responsibility to recognize the alerts indicating a possible case of bribery or corruption and to respond appropriately following the provisions of this policy. The laws in force prohibit bribery and corruption of both public officials and private persons. When dealing with public officials, Cargoquin Inc. employees must pay special attention, since the consequences in cases of corruption related to the public sector and the people involved can be especially harsh for the company. What do we mean by “items of value”? “Items of value” is a broad concept, and can include cash or its equivalents (e.g. gift cards), meals, entertainment, travel, gifts, employment, contracts, in-kind services, such as the performance of repair work at someone's home, or any other type of goods or services with tangible economic value.

No to bribery “Facilitation payments”

V “Facilitation payments” is a term that is used in different ways around the world. In some countries, a facilitation payment is a euphemism for bribery. In others, such as the FCPA (Foreign Corrupt Practices Act in the US), it is a perfectly defined term that refers to certain expedited, or “greased” payments. Although they are not illegal, they must be adequately controlled and recorded in the company's books. Facilitation payments are illegal under the laws of most countries in the world. Consistent with its policy of compliance with all applicable laws, Cargoquin, Inc. does not allow facilitation payments. If you are asked to make a facilitation payment, you must decline to do so. It is not allowed to make such payments in the performance of professional duties for the company, even if they are made from personal finances and reimbursement is not sought. All requests for facilitation payments must be reported to the compliance officer of this anti-corruption policy.

Company resources are not to be used for political purposes

VI The use of company funds, property or other resources to make contributions or offer things of value to political candidates, political parties or party members is not permitted. The company will not reimburse any employee for any personal contribution made for political purposes. Everyone is free to participate in political activities outside of working hours and at their own expense, as long as this does not interfere with the performance of their duties at Cargoquin, Inc. and is not done on behalf of the company. In addition to being prohibited by company policy, such payments may raise issues with the anti-corruption program.

Contributions to charities and sponsorships

VII Cargoquin, Inc. is committed to serving the communities in which it carries out its activity. To that end, Cargoquin, Inc. employees may sponsor events or make contributions to charities for educational, social, or other legitimate business purposes. Anti-corruption laws do not prohibit legitimate donations and sponsorships. But we have an obligation to ensure that funds earmarked for such purposes are used for their intended purpose and are not diverted and also that they reach the proper recipients and purposes. This policy covers contributions and event sponsorships to known charities for legitimate business purposes that are modest in amount and do not pose special concerns. They can be carried out without prior approval. Some examples of appropriate contributions are: A donation to health foundations, to educational programs to help with vocational training, or to Red Cross to help with rescue operations, etc. Contributions and sponsorships of events that may fall into doubts of legitimacy require the prior approval of Pamela Valenzuela or Jorge de Haro Bueno.

It is mandatory to report cases of blackmailing and extortion

VIII Even if a government official or other person (e.g. a potential client) asks you for an improper payment, that is not an excuse for violating this policy. Employees of Cargoquin, Inc. must deny such a request and immediately report any attempt of blackmailing or extortion to those responsible for compliance with this policy at company level. Bribery attempts should be politely but forcefully rejected, making sure that all comments or responses do not give the impression of agreeing to the bribery. Let the person know that Cargoquin, Inc. has strict policies and that we may lose our job if we engage in conduct that violates these policies.

We expect the same from our business partners.

IX Cargoquin, Inc.'s policy prohibits bribery and corruption, either directly or indirectly. In some countries, hiring well-connected agents or “finders” to help identify and pitch new business, to introduce people or to lobby public officials is a common practice. This can become a bribery channel. We expect our agents, consultants, joint venture partners, or any other third parties acting on our behalf (“Business Partners”) to perform legitimate services, and to adhere to standards of ethical and professional conduct, as described in this Policy and in the Code. What are the red flags as far as business partners are concerned? The red flags are facts or circumstances- a pattern, practice or specific event- that indicates the possibility of corruption. There are many examples for these red flags, and the following list does not include all of them.

• - A new business partner is referred by a public official.
• - A public official or someone close shows business interest in a business partner.
• - The business partner has no experience in carrying out the job he/she was hired to do, or has been hired solely due to the influence of a public official.
• - The business partner makes suspicious statements (e.g. ‘do not make any questions, I’ll handle this’), is not transparent in their acts or insists on keeping their dealing with you secret.
• - The business partner’s commission is too high compared to industry standard or to the job to be done. The Business partner requests their payment to be made out of the record to an account in a tax haven.
• - The business partner refuses to sign a contract with anticorruption guarantees.
• - The business partner submits fake invoices or refuses to provide documentation that support the expenses.

If you identify any of these, please contact the personnel responsible for the compliance of this anticorruption policy.

Our responsibilities when working with business partners. Due to the possible responsibilities associated with collaboration with business partners, there are a series of measures to protect Cargoquin, Inc.:

• - Due diligence should be documented and retained and regularly updated.
• - Business partners should not be asked to provide services without a contract. Contracts help demonstrate the legitimate reasons why a partner (or the contracted entity) was hired and the services to be provided. In addition, contracts typically contain provisions to help protect Cargoquin, Inc. Therefore, they are important.
• - Employees must also ensure that any compensation paid to a business partner represents an appropriate value based on legitimate assets or services rendered.

Our responsibilities do not end once a business partner has a contract. We must constantly monitor the activities of our partners. Red flags or other concerns about the correctness of a partner's conduct that arise in the course of the relationship with that partner should be reported to the compliance officer so that risks can be weighed and appropriate safeguards developed. The following are examples of issues that could arise in the conduct of a business partner:

• - The business partner requests additional compensation when there is no legitimate need.
• - There is news that a public official, or a close relative or an associate of a public official, has an interest in a partner of the company.
• - There are rumors that a partner is under investigation for money laundering or other criminal activity.

Cargoquin, Inc. can carry out the training of business partners, audits or seek compliance certifications when appropriate. Cargoquin, Inc. encourages its employees to share this Anti-Corruption Policy with their business partners so that they are aware of their commitment to legal and ethical business practices.

Annual review of anti-corruption policy compliance

X Those responsible for compliance with this policy in the group have the power and responsibility to make periodic reviews of compliance with it using different methods previously established and variables depending on the moment and situation, always clearly and objectively in relation to anti-corruption principles. Example: Through interviews or surveys in which certain questions are answered and the interested party rectifies, among other things, that:

• - They have read and understood this policy.
• - They will respect its terms.
• - They are not aware of any violations to this policy .

Information and no retaliation

XI The company will not tolerate retaliation against people who report in good faith, as indicated in the Cargoquin, Inc. Policy. Any person who has knowledge of what they believe to be a form of retaliation must inform the directors and those responsible for compliance with the Group's Anti-Corruption Policy. All Cargoquin, Inc. employees who have knowledge or suspicion that this policy may have been violated must:

• - Notify the director or person responsible for compliance with the anti-corruption policy directly in person, by call or by e-mail according to the information contained in this policy.

The identity of informants regarding a violation or suspected violation of company policy will be kept confidential, except to the extent necessary to protect the interests of Cargoquin, Inc. or as required by law in force.

Disciplinary actions

XII. Employees who violate this policy will be subject to disciplinary action, which may include termination, and may also be subject to individual criminal prosecution and/or civil prosecution in relevant jurisdictions. Business partners who violate this policy are subject to termination of all business relationships with Cargoquin, Inc.

‘WE ALL ARE CARGOQUIN, INC.’

We all have the responsibility that the company is an ethical place where we perform with high standards of good conduct and honesty. Let's contribute to Cargoquin,Inc. stay as a world-class company with transparent operations. I count on each one of you to promote and protect the integrity of our company supported by our policies and code of ethics.

Responsible Purchasing Policy

When managing the acquisition of products or contracting a service, local suppliers should be preferred over foreign ones, since they offer:

• -Reduction of times in the delivery of the products or in the provision of the service.
• -Being located in the same city, the distances traveled are shorter, thus minimizing fuel consumption in transportation and, consequently, pollution levels.
• -Greater knowledge and identification of our needs, being located in the same community.
• -Greater contribution to local economy.

Among local suppliers, preference should be given to those that offer products that cause less negative impact on our environment. Likewise, through this Policy, the celebration of intersectoral Alliances with suppliers that carry out some action in favor of our environment within their production processes is promoted.

With this policy, we commit to integrate into our supplier directory those civil society organizations in our community that offer services or market products for the subsistence and operation of their corporate objects, contributing with our purchase to the cause that they represent.

Human Rights Policy

1. Objective of this policy

The objective of this policy is to publicize the position of CARGOQUIN, INC. and|| 3PL SERVICES regarding respect for human rights, directing the message to its different interest groups. Human rights are rights inherent to all human beings, regardless of nationality, place of residence, sex, national or ethnic origin, color, religion, language, or any other condition. We all have the same human rights without discrimination. These rights are interrelated, interdependent and indivisible.

Inc.

At CARGOQUIN, INC. and 3PL SERVICES we seek to align our strategy and operations with universal principles on human rights. It is a global standard of conduct applicable to all operations, we are committed to respecting and promoting human rights and complying with recognized international standards on the matter.

At CARGOQUIN, INC. and 3PL SERVICES we are determined to:

• I. Comply with all applicable laws and respect internationally recognized human rights, in all those places where we operate.
• II. Promote the awareness of employees and business partners on issues related to human rights.
• III. Assess current and potential human rights risks and their impact on our operations.
• IV. Adopt adequate measures for the prevention, mitigation and, when appropriate, the remediation of adverse impacts in terms of human rights.
• V. Provide access to grievance mechanisms.
• VI. Continue participating in international initiatives to promote progress in terms of human rights.
• VII. Interact with our stakeholders in the area of human rights, including governments, non-governmental organizations, business and industrial partners, investors, employees and clients.
• VIII. Report transparently about our efforts in this area.

3. Scope of application:

This policy covers each branch of CARGOQUIN, INC. and 3PL SERVICES and applies to all its collaborators, regardless of their position within the group, regardless of where they reside or carry out their work, as well as to all third parties that have a business relationship with CARGOQUIN, INC. and 3PL SERVICES.

We know and we encourage our business partners, suppliers and other parties whose activity and its impact may be directly linked to the operations or services of CARGOQUIN, INC. and 3PL SERVICES to assume the principles of this policy, respecting and not infringing human rights.

Integral Policy

We are committed to satisfy our customers’ needs through our integral services in foreign trade. Our team is highly qualified and driven by quality, safety and continuous improvement seeking excellence and constant innovation, and supported by the use and development of new technologies.