Ethics policy

 Effective date: October 26, 2025

Applies to: All employees, officers, contractors, temporary staff, interns, and third-party partners who act on behalf of Fulfillment Hub USA (FHU)

1) Purpose and Scope

This Ethics Policy describes the personal, organizational, and corporate standards of behavior expected at Fulfillment Hub USA. It exists to protect our customers, our people, and our brand, and to ensure we operate legally, fairly, and responsibly in every market where we work.

2) Our Principles

• Integrity: Tell the truth, keep commitments, do the right thing even when it is hard.
• Customer Trust: Protect customer data and deliver accurate, on-time fulfillment.
• Accountability: Own outcomes, escalate risks early, fix root causes.
• Respect: Maintain a safe, inclusive, harassment-free workplace.
• Compliance: Follow the law and our internal policies at all times.
• Safety and Quality: Meet or exceed regulatory, safety, and product handling standards.

3) Personal Standards of Conduct

• Professional conduct: Treat everyone with dignity. No harassment, bullying, or discrimination.
• Conflicts of interest: Disclose any outside activity, investment, or relationship that could influence your work. Do not supervise or approve work for close relatives or partners without written approval.
• Gifts and hospitality: Do not solicit gifts. Never accept cash or cash equivalents. Modest and infrequent business courtesies may be allowed only if they do not influence decisions and comply with local law. When in doubt, seek approval from Compliance.
• Social media and public statements: Do not speak on behalf of FHU unless authorized. Protect confidential and customer information.
• Substance use and fitness for duty: Be fit for work and comply with all safety rules.
• Use of company assets: Use systems, equipment, and funds only for legitimate business purposes.
• Accurate records: Enter time, inventory counts, and operational data truthfully.

4) Organizational Standards

• Data privacy and security: Handle personal data and customer data according to contractual obligations and applicable laws such as GDPR and CCPA. Use only approved systems. Report suspected incidents immediately.
• Information security: Safeguard access credentials. Follow MFA, password, and device policies. Store data only in authorized repositories.
• Confidential information and IP: Keep customer information, pricing, SOPs, and technology confidential.
• Fair employment: Provide equal opportunity. Make decisions based on merit and business need. Provide reasonable accommodations as required by law.
• Health and safety: Follow warehouse safety procedures, PPE rules, equipment certifications, lockout and tagout, and incident reporting.
• Environmental responsibility: Reduce waste, use responsible packaging options, and follow hazmat and disposal rules.

5) Corporate Standards

• Anti-corruption and bribery: Bribes, kickbacks, and improper payments are prohibited. Comply with anti-corruption laws such as the U.S. FCPA and the U.K. Bribery Act where applicable.
• Fair competition: Compete honestly. Do not share sensitive pricing or bid information with competitors.
• Trade compliance: Follow export controls, sanctions, customs, and import rules. Provide accurate documentation.
• Marketing and communications: Be truthful and support claims with evidence.
• Accurate books and records: All transactions must be recorded completely and accurately.
• Third-party risk: Perform due diligence on suppliers and partners. Contractually require ethical behavior and data protection.

6) Logistics and Fulfillment Obligations

• Product safety and handling: Follow storage conditions, lot control, FIFO or FEFO as required, and temperature or hazmat procedures.
• Inventory integrity: Count accurately, investigate variances, and prevent shrinkage.
• Carrier and shipping compliance: Use correct labels, documentation, and service levels. Honor cut-off times and customer SLAs.
• Kitting and value-added services: Work from approved work orders and SOPs. Validate outputs with QC checks.

7) Responsible Use of AI and Data

• Customer data: Do not input sensitive customer data into external tools without written approval.
• Transparency and human oversight: Use AI to assist, not replace, accountable human judgment for service decisions that affect customers.
• Data minimization: Use the least data necessary for the task.
• Bias and fairness: Monitor for biased outputs. Escalate issues and correct processes.
• Security: Use only approved AI systems and follow access controls.

8) Working With Suppliers and Partners

• Supplier Code of Conduct: We expect lawful labor practices, safe workplaces, environmental care, data protection, and anti-corruption compliance.
• Gifts from suppliers: Follow the same gifts and hospitality rules outlined above.
• Audit and remediation: We may assess compliance and require corrective actions.

9) Reporting Concerns

• Speak up: If you see misconduct, unsafe conditions, data risks, or policy violations, report promptly to your manager, HR, or Compliance.
• Anonymous reporting: If your region permits, you may report anonymously using our hotline or email option.
• No retaliation: Retaliation against anyone who reports in good faith or participates in an investigation is prohibited.

Contact: hr@fulfillmenthubusa.com

10) Investigations and Discipline

• Process: Reported concerns are reviewed promptly and fairly.
• Confidentiality: We protect identities to the extent possible and permitted by law.
• Outcomes: Violations may result in coaching, retraining, reassignment, termination, or referral to authorities where required.

11) Training and Acknowledgment

• Onboarding: All personnel must complete ethics and safety training.
• Annual refreshers: Periodic training may be required for anti-corruption, data privacy, information security, and safety topics.
• Certification: You may be asked to sign an acknowledgment that you understand and will follow this policy.

12) Governance and Updates

• Policy owner: Compliance and People Operations
• Review cadence: At least annually, or sooner if laws, risks, or operations change.
• Version control: The most recent version posted on our website is the governing version.

Plain-Language Summary

• Treat people with respect.
• Do not lie, cheat, harass, or discriminate.
• Protect customer data and company information.
• Do not take bribes or give bribes.
• Follow safety rules and the law.
• Report problems quickly without fear of retaliation.

This policy summarizes behavior we expect at Fulfillment Hub USA. It does not create a contract of employment and may be updated as our business or the law changes.