This
Human Trafficking Policy (“Policy”) applies to GXO Logistics, Inc., including
all its subsidiaries, divisions, and other operating entities (collectively, “GXO”
or the “Company”). All directors, officers and employees of GXO, and third
parties acting on our behalf, are subject to and responsible for complying with
the requirements of this Policy. As used in this Policy, the term “Company” should
be read to include all persons and entities subject to this Policy.
To the extent that this policy differs
from the requirements of local laws or policies
which may have more onerous requirements than this policy, the terms of the local law or policy will prevail in relation to GXO’s operations within that
jurisdiction.
2.
OVERVIEW
GXO is committed to conducting business
in a manner that respects the human rights
and dignity of all people.
We will not tolerate any
conduct that contributes to, facilitates or encourages human trafficking, child labor, forced labor or compulsory labor. We support
government policies in the US and other countries that combat human trafficking, and we expect our customers, subcontractors and suppliers to respect human rights laws.
Human trafficking constitutes a violation of human rights in which the victims are deprived
of their fundamental freedoms. These activities include using force, fraud or
coercion to subject a person to involuntary servitude; obtaining labor from a
person by threats of serious harm to that person or another person; sex
trafficking, procuring commercial sex acts; and other activities that impede fundamental
freedoms.
GXO
prohibits employees, subcontractors, agents, vendors, partners and others with whom
GXO conducts business from engaging in practices relating to trafficking in
persons, including:
■ Engaging[WR3] in any form of
trafficking persons
■
Procuring sex acts during
the performance of a contract
■
Procuring or participating in sex acts
during working hours or using
GXO
assets
■ Using
forced labor in the performance of any work related to a contract
■ Destroying
or denying access to a person’s identity
documents such as drivers’ license, passport or other identity documents
■
Using recruiters that do not comply with local labor laws in the country
in which the recruiting takes place
■ Charging applicants recruitment fees
■ Failing to provide
return transportation to certain employees who are brought to a country for the
purpose of working with GXO
■
 |
Providing housing
that fails to meet host
country standards
■
Failing to provide
an employment contract
or work document where
required by law
3.
REPORTING
All persons
subject to this Policy must immediately report any misconduct or potential violations
of this Policy and/or applicable anti-discrimination laws. GXO does not permit
retaliation against any person who, in good faith, reports any concerns,
misconduct, and/or potential violations of Company policy or applicable laws.
Reports can be submitted directly to any supervisor, any member
of Human Resources, and/or the Ethics & Compliance Office at ethics@gxo.com. Additionally, you can visit
our Ethics website at https://ethics.gxo.com where
you can find alternative reporting options. Your concerns can be reported anonymously, unless otherwise prohibited by applicable local law. Please
see the Company’s Code of Business Ethics
for additional information
regarding reporting options.
Additional
information and guidance regarding this Policy
can be obtained from the Ethics & Compliance Office at
ethics@gxo.com.
4.
POLICY EXCEPTIONS
Any
exception to or deviation from this Policy must be approved in writing by the Company’s Chief Compliance
Officer.
5.
FAILURE TO COMPLY
Failure
to comply with this Policy could have serious consequences for the Company and
the individuals involved, including civil
or criminal prosecution, fines and possible imprisonment. Violations of this Policy
may also result in serious disciplinary action, including termination of
employment.