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Part I Our Introduction of the Code of Conduct

What is the purpose of our Code of Conduct?
Our Code is intended to reinforce the values TCI remains tied to service, commitment, reliability and honesty. It links these values to exceptional standards of professional conduct that are expected of all leaders and employees on a daily basis.
In addition our code reflects TCIs genuine intent to conduct business in a lawful and ethical manner which contributes to a work environment that is based on fairness, trust, respect and cooperation. It communicates a commitment to preventing, detecting and remedying wrongful conduct if it should occur. It provides a valuable resource to the workforce which assists everyone in identifying and resolving ethical dilemmas they may encounter.
The guiding principles in this code cannot address every issue or provide answers to every dilemma, however, they can define the spirit in which we intend to do business and provide us with the necessary security and tools to utilize in our day-to-day operations.

Who does our Code of Conduct apply to?
Our Code of Conduct applies to all TCI employees throughout the world, regardless of their position. Each of us must behave in accordance with these standards when dealing with fellow employees, customers, suppliers, contractors, competitors and public officials.

What is Management's commitment to our Code of Conduct?
Management has established the legal and ethical expectations for every employee. By setting the tone at the top, Management is committed to leading by example and demonstrating through their daily actions, the importance of our Code. Promptly addressing ethical questions or concerns raised by employees and taking the appropriate steps to address such issues is a key responsibility required of Management. Expressing these concerns is encouraged and is viewed as a form of open and honest business communication rather than a threat or challenge to authority.

How do I determine proper ethical conduct?
Although no code can anticipate every situation that may arise, our Code is intended to provide guidance to officers, managers and employees on areas posing ethical risk. It has been developed to provide guidance to help recognize and deal with ethical issues and provide resources to report unethical conduct. When encountered with an ethical dilemma there are several key questions that can help to identify unethical, inappropriate or illegal situations:

Ask yourself:
-Is my action or decision legal or ethical?
- Does what I am doing comply with TCI Transport's guiding principles, Code of Conduct and company policies?
- Am I being loyal myself, to my family, and my company?
- Will my action or decision protect the reputation of TCI and its high ethical standards?
- Have I been asked to misrepresent information or deviate from normal procedure?
- Would I feel comfortable describing my decision at a staff meeting?
- Is this the right thing to do?

What should I do if I know or suspect a violation of our Code of Conduct?
Our Code of Conduct contains procedures for reporting suspected violations of our Code. These reporting procedures are described in the section of the Code entitled Our Reporting and Investigation Procedures.

Could reporting a known or suspected violation of the Code of Conduct affect my job?
We are committed to ethical business practices and encourage all employees to seek advice or raise their concerns in their best business judgment. TCI will not tolerate adverse action or retaliation against any employee for raising or reporting any good faith concern regarding any business practice. Adverse action includes by way of example, and not by way of limitation: discharge from employment, demotion, suspension, intimidation, retaliation or harassment; anyone engaged in such adverse action will face disciplinary action. Similarly, anyone who engages in disparagement of another persons reputation by falsely reporting a violation or complaint will be subject to disciplinary action.

What happens if someone violates our Code of Conduct?
Violations of our Code, including violations of law, may result in disciplinary action, up to and including termination of employment (in accordance with the employee procedures set forth in local office/region). Involvement in criminal conduct that potentially subjects TCI and/or its employees to liability for violation of that law is considered a violation of the Code of Conduct. The authorities involved make their own judgment regarding criminal prosecutions; therefore, you should consider that TCI has no control over the determination and judgments of those prosecuting authorities.

Part II Our Workplace Responsibilities

Professional Ethics 1. Loyal and Trustworthy
1). Maintain a high degree of loyalty to the company, safeguard the company's interests and reputation, and refrain from engaging in any behavior that damages the company's image and interests.
2). Keep your promises and be consistent with your words and deeds. Whether it is to customers, colleagues or superiors, you must behave what you preach.
2. Integrity and Self-Discipline
1). Strictly abide by the company's integrity system and do not accept bribes, kickbacks or other improper benefits.
2). Do not use your position to seek personal gain for yourself or others, and ensure the fairness and transparency of the company's business.

3. Keep Confidentiality
1). Keep the company's business secrets, customer information and internal documents strictly confidential and not disclose them to unauthorized personnel.
2). Keep the company's confidential information properly to prevent information leakage and misuse.
Promoting Open and Honest Communications
We encourage employees to raise work-related issues, questions or concerns. All employees are encouraged to speak frankly about any ethical concern. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such issues.

Encouraging Trust and Credibility
We are committed to and dependent on the trust and confidence we earn from each other and our customers. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching corporate goals through honorable conduct.

Valuing Diversity, Inclusion and Equal Opportunity in Employment
We value the talents, abilities and diversity of all employees. We define diversity as all of the unique characteristics that make up our workforce: personalities, lifestyles, work experiences, political opinion, ethnicity, race, religion, gender, age, disability, veteran status, sexual orientation or any other differences. We strive to recruit, retain and develop a workforce that embraces and respects the strength of these differences.

Preventing-Harassment
We support a work environment that is free of harassment or any other offensive or disrespectful conduct of any kind. We comply with all country and local laws prohibiting harassment in the workplace because the legal definition of harassment may vary from jurisdiction to jurisdiction. We consider the following as some examples of unacceptable behavior: degrading comments, intimidating or threatening behavior, offensive language or jokes, racial, ethnic, gender or religious slurs; physical harassment of any type is inexcusable.

Preventing Discrimination
We require all employment decisions (e.g. recruiting, hiring, training, promoting, and compensation) related to employees and applicants to be based on merit, qualifications, and job performance. These decisions are not based on non-job related characteristics or activities such as political opinion, ethnicity, race, religion, gender, age, disability, veteran status, sexual orientation and any other legally protected status.

Protecting Human Rights
We recognize the importance of maintaining and promoting basic human rights throughout our global operations. We do not tolerate human trafficking or any type of forced labor and affirmatively prohibit such practices. We do not tolerate the use of underage labor; which is typically defined by local law or in default of local law, by the standards set by the International Labor organization (ILO).

Encouraging a Safe and Healthy Workplace
We are committed to maintaining a safe and healthy work environment by complying with applicable health and safety rules and practices. Employees are responsible for their own safety when performing their work and are expected to exercise their best judgment and proper care to contribute to prevention of work related accidents.

Preventing Workplace Violence
We encourage a safe and secure work environment that is free from violence. We will not tolerate any intimidation, acts or threats of violence against any employees or business partner of TCI. Co-worker on co-worker violence will not be tolerated.

Requiring a Drug-Free Workplace
We expect all employees to perform their job duties free from the influence of any substance that could impair job performance. Working under the influence of abused prescription medications (above the prescribed dose), and/or illegal drugs, and/or alcohol can create an unnecessary risk and unacceptable safety issues. No employee is permitted to possess, use or be under the influence of illegal drugs, alcoholic beverages or other intoxicants while at work. An employee is permitted to possess and take prescription medications in the prescribed doses.

Promoting Environmental Awareness
We are committed to supporting environmental awareness and to preventing any negative impact on the environment. Employees are expected to comply with all applicable environmental legal requirements, and to protect and report any incidents or condition that might result in a violation of law or policy. We are conscious of the world and will continue to make efforts towards sustainability. To reduce environmental impact we will ensure the criteria for selecting business partners is consistent with our corporate goals.

Engaging in Proper Use of Social Media
Employees are free to use various forms of social media communications in their personal lives. However at all times employees should use their best judgment when posting material that is or could be construed as inappropriate or harmful to TCI, its employees and/or customers. Employees are not permitted to publish, post or release any information that is considered confidential or not public. Employees should be sensitive to each individuals right to privacy. In this regard, employees should refrain from publishing or posting images of co-workers or business partners if in so doing, it is reasonably believed that such publication would be offensive to the sensibilities of that other person. Hostility and harassing communications directed through social media at co-workers is not tolerated.

Avoiding Conflicts of Interest
We expect employees to avoid engaging in activities (both commercial and non-commercial) that conflict with, or have the appearance of conflicting with the best interests of TCI. A conflict of interest can arise when an employee takes actions or has interests that may make it difficult for the individual to perform work objectively and effectively.
Employees are prohibited from engaging in any commercial transaction between TCI Transport and a contractor in which the employee has a stake whether direct, or indirect, financial or otherwise. Employees may engage in related party transactions between TCI Transport and a contractor in which the employee has a stake where the transaction is arms-length and approved in advance by Senior Management; the approval or disapproval is of such a related party transaction is in the sole discretion of TCI which may be withheld for any reason. Employees are responsible to notify Senior Management if the employee's immediate family member is party to a transaction with Senior Management (including by way of example and not by way of limitation, Group CEO, Global COO, Regional COO, President, Vice President, and GM Global HR).

Ensuring Proper Acceptance of Gifts, Meals, Travel and Entertainment
We understand that making, giving or receiving gifts is common business practice and can promote good working relationships. The value of any such gift must be reasonable and cannot be intended to influence the recipient. Covering reasonable travel expenses of customers or foreign officials is acceptable if it is directly related to a presentation or demonstration of the company services and is within local law, standards and regulations.
- Reasonable entertainment expenses must be related to business purposes
- Payments must be made directly to the service provider
- A company representative should be in attendance; provided, however, that for reasonable cause, attendance may be excused.
- The entertainment expense must be directly related to a business matter.

Ensuring Proper Charitable Donations
We permit making charitable donations in the form of cash or support. However these donations may not be used as a cover for indirect payments that could be considered bribes. Local laws must be in compliance with all laws governing charitable donations from business organizations.

Ensuring Proper Contributions to Political Parties and Non-Governmental Organizations (NGO)
We do not allow employees to make any political contribution of any kind in the name of TCI or by utilizing TCI funds, assets, services or facilities. Personal contributions are lawful as long as they do not interfere with work responsibilities or give the appearance of a conflict of interest.

Creating and Maintaining Accurate Financial Reporting and Recordkeeping
We create, retain and dispose of all company records as part of the normal course of business in compliance with all corporate policies and guidelines, as well as all regulatory and legal requirements. All corporate records must be true, accurate and complete. In addition it must be promptly and accurately entered into our books in accordance with generally accepted accounting principles. We must not influence, manipulate or mislead an authorized audit conducted by taxing/labor authorities (or otherwise), nor interfere with any auditor engaged to perform an internal independent audit of TCI Transport's books, records processes or internal controls.

Using and Protecting Company Assets Responsibly
We require all employees to protect company assets and ensure their efficient use. These assets include tangible assets, such as office equipment, computers, cellular telephoness as well as intangible assets such as time and intellectual property and proprietary tools such as QQ Business Version, Wechat Business Version, Skype and Skype for Business. In order to protect the interests of the corporate network, TCI reserves the right to monitor internet and intranet use and to review all data and information contained on an employees company-issued computer or electronic device. Employees who use TCI systems and internet access to send or receive files or other data that would otherwise be subject to any kind of confidentiality or disclosure privilege waive whatever right they may have to assert such confidentiality or privilege from disclosure. The use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate will not be tolerated.

Safeguarding Confidential and Proprietary Information
We expect every employee to protect and not disclose confidential Company information, except when disclosure is authorized for a valid business purpose by the company or as required by law or in response to valid process, such as a subpoena or writ. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential customers, suppliers and vendors.

Part III Our Business Responsibilities

Promoting Fair Competition and Antitrust Requirements
We are committed to free and open competition in the market without collusion or cooperation among competitors. Any illegal price-fixing agreement is strictly prohibited. Any collusive agreement on essential terms, rates, fees, charges and conditions between competitors is prohibited. In all regions and countries where we do business, we are committed to competing fairly for suppliers and customers. To adhere to antitrust laws we must ensure the following:

Employees may not receive or disclose any information regarding pricing or terms and conditions regarding an unrelated third party from or to competitors, business partners, customers or suppliers.
Although participation in trade organizations is permitted, if that participation violates any of the prohibited conduct described above, then the membership or participation in such trade organization is prohibited.
Participation in loosely organized trade committees is discouraged. Moreover, participation is prohibited where the purpose of the trade committee is to discuss any aspect of market pricing.
If any matter is discussed which is contrary to open and free competition or another industry function, the employee must leave the room immediately and request that their departure and refusal to participate in such activities be noted in the minutes of the meeting. Resignation from the organization should be immediately considered and the subject matter intent with these policies. The subject which the employee found offensive should be brought to the attention of Management for consideration of any further action by TCI.

Preventing Bribery and Corruption
TCI is committed to compliance with anti-corruption laws, we prohibit giving anything of value, directly or indirectly to officials of foreign governments or foreign political candidates to obtain or retain business. We prohibit improper payments, such as bribes and kickbacks, as well as offers or promises to make improper payments, whether or not the offer or promise is successful. This includes charitable donations, payment of travel expenses, and delivery of products or services in lieu of cash, disproportionate entertainment expenses, or the transfer of other personal or financial benefits and payment or gifts.

Facilitation Payments Prohibited
The common and legal use of facilitation payment in certain countries is recognized as ordinary business practice. Facilitation payment refers to a payment of a small amount of money to expedite performance of routine governmental actions such as issuance of a license or visa. A facilitation payment is not a bribe because it is not paid to cause the official to change his or her mind. Rather it is a payment that expedites the official's performance. Facilitation payments (payments made to prioritize or secure the performance of a routine, non-discretionary government action to which TCI or our customer is entitled) are strictly prohibited.

Export Administration Compliance
TCI is committed to compliance with all export controls throughout the world. This is an ongoing commitment to promoting strict compliance with terms and conditions governing export controls. It is required that all employees comply with country specific export policies and regulations. Under no circumstances will exports be made by an individual operating on behalf of TCI that are contrary to the required export regulations. Employees may not re-export any commodity, technology, or software unless appropriate authorization has been obtained. Failure to comply with these regulations may result in the imposition of criminal/and or civil fines and penalties. In addition employees may be subject to disciplinary action and/or termination.

Our customer service
1. Customer First
1). Always be customer-centric, pay attention to customer needs and expectations, and provide quality services.
2). Respond promptly to customer inquiries and complaints, actively solve customer problems, and ensure customer satisfaction.

2. Professional and efficient
1). Have professional knowledge and skills to provide customers with accurate and efficient freight solutions.
2). Strictly abide by work procedures and standards to ensure safe and on-time transportation of goods.

3. Integrity and keeping promises
1). Contracts and commitments signed with customers must be strictly performed and no unauthorized changes or breaches of contract are allowed.
2). Maintain integrity, do not deceive customers, and establish a good reputation for the company.

Part IV Our Reporting & Investigation Procedures

Seek Guidance
Our Code includes useful guidance all employees should utilize to apply the principles of our Code to an ethical dilemma they may encounter in conducting their job. However, the correct way to act may not always be clear, even after reviewing our Code. Ask questions and seek guidance from Management before undertaking any decision or action that may violate any applicable law, rule, regulations, or company policy.

Report Concerns
All employees are responsible for understanding and adhering to the values and standards set forth in our Code. If there is a concern as to whether the standards are being met, individuals are encouraged to promptly utilize one of the following reporting options as felt comfortable to address such issues:
a. Option 1:
Report the concern to your Manager or HR Representative.
b. Option 2:*
Email Submission:
Complete The Code of Conduct Violation Form available on the Global HR Site:
Follow all instructions on the form. The report should be sent to Global HR.
c. Option 3:*
Mail Submission:
Complete The Code of Conduct Violation Form available on the Global HR Site:
Upon Completion, print and send to: TCI Transport - Att: Global HR Compliance, 127 Main Street, Chatham, New Jersey 07928
We take all reports seriously and will investigate all concerns raised that are consistent with the law and the TCI Code of Conduct. Option 2 and 3 allow you to submit your concern anonymously (where allowed by law). However, providing your name and contact information will enable HR and/or Management to contact you if additional information is needed during the review of the complaint/concern.
In every instance where improper behavior is confirmed to have occurred, appropriate action will be taken up to and including termination of employment based on the severity of the violation.

Translation, Amendment, Modification and Waiver of The Code
The Code of Conduct may be translated into other languages to facilitate familiarization and understanding for all employees. In the event of any discrepancy between the original English version and any translation, this English version shall prevail.

In addition The Code is subject to amendment from time to time in order to clarify policies and to include new information related to our global industry. TCI recognizes that in rare circumstances a waiver of strict application of the Code due to hardship or extreme difficulty in conducting business may be appropriate in the judgment of Senior Management.

This code of conduct is the company's basic requirement for employees. All employees should strictly abide by it and jointly create a good working atmosphere and corporate culture. If there is a violation of the Code of Conduct, the company will impose corresponding penalties depending on the severity of the case.