Making the right decisions every day Our culture at GXO is about achieving results through Globally, the Ethics and Compliance team promotes By the numbers teamwork. We help each other succeed. We’re proud to the Code internally and, in partnership with Human support our customers, partners and team members. Resources, ensures that all employees receive, 100% We’re fair, respectful, lawful and honest. understand and agree in writing to abide by the of employees receive and are required Shared values Code and take part in relevant training programs. to sign GXO’s Code of Business Ethics All GXO team members are expected to comply with 5 hours We expect anyone working for, with or on behalf of GXO to the Code, all company policies and applicable laws, of training on average per employee related share our values—and make the right decisions every day. rules and regulations, and we expect our leaders to to Annual Compliance Education (ACE) We see a shared responsibility to: model our values and professional standards. Team members are required to acknowledge the Code • Act ethically and with integrity in all our business dealings and participate in annual training, which includes GXO’s global risk-based compliance program • Treat each other with dignity and respect topics such as ethics, building a respectful is built on a foundation of ethical culture. workforce and anti-corruption. GXO’s Annual • Comply with all applicable policies, laws and regulations Compliance Education (ACE) program includes • Uphold our commitment to our Code of Business up to five hours of training per person each year, Ethics (our “Code”) tailored to role and location. Our values and our commitment to making the right decisions Suspected violations of our code, policies or Continuous Improvement every day are embodied in our Code of Business Ethics, a guide other regulatory requirements are subject to for GXO employees to understand how our day-to-day decisions comprehensive investigation in line with our Speaking Up and Investigations support our ability to fulfill our responsibilities to each other, to internal compliance framework and subsequent our customers, investors and communities and to society. appropriate action, up to and including termination Auditing, Testing and Monitoring of employment. In addition to the Code, we have policies and professional Risk Assessment and Management standards that apply to every employee of GXO and to third Compliance with the Code of Business Ethics and parties acting on our behalf. Some of the topics addressed by supporting processes is reported regularly to the Training, Communication and Engagement our Code and supporting policies include anti-corruption and Audit Committee, which also has the responsibility bribery, human rights and anti-discrimination, workplace safety, to review and approve requests for waivers and Policies and Procedures (Code of Business Ethics) confidentiality and protection of company assets, conflict of promptly disclose any waivers that are granted interest, anti-competitive practices, information security and as required by law, regulation or applicable Ethical culture personal investments. listing standards. 70 | 2021 ESG Report ©2022 GXO Logisitcs, Inc. HOME E S G