Ethical business practices Our Code of Business Ethics, combined All employees are required to read and with supporting policies, outlines our certify that they will comply with our Code. expectations for ethical business practices, GXO employees are asked to recertify to the from anti-corruption to international trade to Code following annual training and receive conflict of interest. additional compliance training relevant to role and location. GXO wins and awards business based on merit. Policies related to ethical business standards GXO does not tolerate bribery or corruption in are owned by the Ethics and Compliance any form, directly or indirectly, whether doing team with oversight from the Chief Legal business with a government entity, commercial Officer and Board-level Committees. The enterprise or individual. Employees may Chief Compliance and ESG Officer reports not authorize, offer to pay or accept bribes, on performance against these policies to kickbacks or gratuities; this includes offering or GXO management and the Board. making payments to third parties in situations where there is reason to believe that even Employees have a responsibility to report a portion of the payment will be offered to concerns or potential violations of our someone else for an improper purpose. policies. Violations may result in serious In addition, the company does not give or disciplinary action, up to and including receive business gifts of products, services or termination of employment. Posters hang in entertainment to improperly influence business every GXO location reminding employees decisions. Our policies outline clear guidelines of their responsibility to voice any concerns for gifts and entertainment that all employees and listing all the reporting mechanisms are required to follow. available to them. These posters are As a global company, GXO complies with all translated into multiple languages laws and regulations governing international and use local phone numbers for easy trade. GXO does not permit the export or toll-free dialing. import of goods, services or data without GXO policy strictly prohibits retaliation appropriate authorization. We prohibit doing against any employee for reporting in line business with or for any embargoed or with these policies, as outlined under the sanctioned country or any party subject to “speak up” section above. debarment or economic sanctions without appropriate government authorization. 72 | 2021 ESG Report ©2022 GXO Logisitcs, Inc. HOME E S G