Speak up culture We seek to foster a “speak up” culture at GXO. Every employee has the We take every concern seriously and have established a clear framework and process for addressing them. By the numbers responsibility to raise questions or concerns about values, ethics or other GXO maintains an enterprise-wide investigative program that seeks to protect the interests of the company standards without fear of retaliation. Employees are encouraged to voice and its shareholders by preventing, detecting and investigating potential misconduct and violations. The concerns to a supervisor or a representative of the Human Resources and/ internal investigations process is centrally overseen by GXO’s Ethics & Compliance team and is supported or ethics and compliance departments. But they have many other places to by a network of more than 200 cross-functional employees. This process is designed to facilitate the delivery turn if they prefer a different route. of clear findings, conclusions and investigative outcomes, which are shared to drive proactive and impactful In addition to many internal avenues to raise questions and concerns, risk management and facilitate effective information sharing with internal partners and stakeholders across GXO offers additional channels for employees and even third parties to all investigative functions. raise concerns in a confidential manner and, where legally permissible, All concerns are fully investigated and an action plan is implemented and tracked depending on the anonymously. These include: outcome. Each report is forwarded to an appropriate member of management, Human Resources or 1 Ethics Point, www.GXO.ethicspoint.com, Ethics & Compliance for prompt review. GXO evaluates each report carefully to determine whether further a website administered by a third party and investigation or action is necessary. Employees are required to cooperate fully with company investigations. available 24 hours a day, 7 days a week. We utilize an independent third-party system to manage concerns (Ethics Point) and track multiple metrics that are reported to leadership and the Audit Committee and external auditors, as appropriate. We also 2 A toll-free telephone service operated by an independent have an internal Ethics & Compliance quality assurance and governance process in collaboration with key third party 24 hours a day, 7 days a week. Local numbers functions, including Human Resources, Finance, Safety and Security. with translation services are provided in all 28 countries in which we operate. 3 A dedicated email account at GXO, monitored Ethics at GXO by GXO’s Ethics & Compliance Team. Learn more 4 about how Code of Business Ethics Direct reporting to the GXO Ethics Team. we do what we do 5 Read our policies Internal reporting to HR and business leaders HOME E S G ©2022 GXO Logisitcs, Inc. 2021 ESG Report | 71