Code of Conduct

1. Core Principles

WideScale values and expects Partners to value the principles of Integrity, Respect, Compliance, and Responsibility. This means conducting business with honesty and integrity; treating everyone with dignity; adhering to all applicable laws, regulations, and internal standards; and holding oneself accountable for one's actions and decisions.

2. Slavery and Human Trafficking

WideScale and Partners must not, under any circumstances, resort to forced, bonded, involuntary, indentured, or compulsory labor, slavery, or human trafficking.

3. Child Labor

WideScale does not and Partners must not employ children who have not reached the legal working age under applicable laws and regulations.

4. Work Hours

Working hours, as well as break times and periodic days off, shall comply with all applicable laws and regulations. Workers shall not be required or allowed to work more than the maximum legally permitted number of regularly paid hours per week. Overtime must be voluntary.

5. Collective Bargaining

The rights of employees to form and join trade unions and bargain collectively must be respected in accordance with applicable law.

6. Discrimination, Abuse, and Harassment

WideScale does not and Partners must not discriminate against any person based on race, color, national origin, gender, gender identity, sexual orientation, disability, age, religion, or other characteristic protected by applicable law in hiring and employment practices. All individuals shall be treated with respect and dignity. WideScale's workers and Partners' workers shall not be subjected to corporal punishment or physical, verbal, sexual, or psychological abuse or harassment.

7. Safety

WideScale and Partners must provide their respective workers a safe, healthy, and sanitary working environment and shall have legally required procedures and safeguards in place to prevent workplace hazards and work-related accidents and injuries.

8. Hazardous Labor

Hazardous labor shall not be performed by any person under the age of 18 and must be performed in compliance with all applicable laws and regulations. Hazardous labor involves any work that by its nature or the circumstances in which it is undertaken creates a substantial risk of harm to the safety or health of the worker or coworkers if adequate protections are not in place.

9. Compensation

WideScale and Partners will fairly compensate their respective employees. Employees must be provided with wages and benefits that comply with all applicable laws and regulations, including appropriate compensation for overtime and other premium pay situations required by law.

10. Trade Compliance and Customs Integrity

WideScale operates as a licensed customs broker and freight forwarder. WideScale and Partners must conduct all trade and customs activities in strict compliance with applicable U.S. customs laws and regulations, including those administered by U.S. Customs and Border Protection (CBP), the Bureau of Industry and Security (BIS), and other relevant regulatory authorities.

WideScale and Partners must not:

• Submit or facilitate the submission of false, misleading, or fraudulent customs declarations, entry filings, or trade documents;
• Misclassify goods under the Harmonized Tariff Schedule (HTS) with the intent to reduce duties, evade regulatory requirements, or circumvent import or export controls;
• Undervalue or misrepresent the country of origin of goods in any customs filing;
• Participate in customs fraud, duty evasion, or any scheme designed to circumvent applicable trade laws; or
• Assist any party in evading denied party screening, sanctions compliance, or applicable export control requirements.

All classifications, valuations, and country-of-origin determinations made or facilitated by WideScale or its Partners must be accurate, defensible, and documented with reference to applicable CBP rulings, regulations, or established trade precedent.

11. Economic Sanctions and Denied Party Screening

WideScale and Partners must act in accordance with all applicable economic, trade, and financial sanctions, trade embargoes, anti-terrorism laws, and other restrictions administered by the Office of Foreign Assets Control (OFAC), the Bureau of Industry and Security (BIS), and other applicable authorities. WideScale and Partners must not facilitate transactions with sanctioned parties, entities, or countries. Partners must maintain adequate denied party screening procedures appropriate to their role in the supply chain.

12. Anti-Money Laundering

WideScale and Partners must thoroughly vet third parties to prevent potential involvement in money laundering activities and must monitor third-party relationships on an ongoing basis. Partners must report suspicious financial activities or irregularities to appropriate internal or external authorities and should train their employees to recognize and prevent illicit financial activity. WideScale reserves the right to terminate a Partner relationship upon evidence of involvement in money laundering.

13. Bribery and Corruption

WideScale does not tolerate bribery, kickbacks, or corruption in any form. All decisions are made solely on merit and integrity. WideScale does not and Partners shall not offer, promise, or accept any form of solicitation, gifts, or invitations tendered: (1) in a secret manner or by an unknown or unidentified person; (2) in the form of cash or cash equivalents; or (3) in a manner that breaches any applicable law, regulation, or rule. Gifts must be reasonable, proportionate, and transparently documented. Partners must avoid any engagement that contravenes applicable anti-corruption laws, including but not limited to the Foreign Corrupt Practices Act (FCPA).

14. Intellectual Property and Confidentiality

Partners must protect intellectual property and confidential information entrusted to them by WideScale, including information owned by WideScale's clients. This includes, without limitation, client freight profiles, classification histories, shipment records, carrier pricing, and proprietary operational data. Partners must report any actual or suspected mishandling of intellectual property or confidential information to WideScale as soon as practicable.

Partners shall not share screenshots, recordings, data exports, or other reproductions of WideScale's systems, tools, or client data with any person who is not an authorized WideScale employee or designee.

15. Data Privacy and Information Security

Partners that access, process, or store Personal Information or Shipment and Trade Data on behalf of WideScale must handle such information in a manner consistent with WideScale's Privacy Policy and applicable data protection laws, including the California Consumer Privacy Act (CCPA) where applicable. Partners must implement reasonable technical and administrative safeguards to protect Personal Information and must notify WideScale promptly in the event of an actual or suspected data security incident.

16. Environmental Protection

Equipment and facilities must be operated in compliance with all applicable environmental laws and regulations relating to waste disposal, emissions, discharges, and the handling of hazardous and toxic materials. WideScale and Partners should strive to minimize negative environmental impact and optimize the responsible consumption of energy, materials, and natural resources.

17. Conflicts of Interest

WideScale and Partners shall avoid engaging in any transaction or arrangement that involves a conflict of interest that has not been comprehensively disclosed to all relevant stakeholders. Partners must promptly disclose any actual or potential conflict of interest to WideScale.

18. Collusion and Fair Competition

WideScale and Partners are committed to the principle of free and fair competition. Partners must avoid collusive bidding, price fixing, price discrimination, market allocation, and other illegal or unfair trade practices prohibited by applicable antitrust or competition laws.

19. Whistleblowers and Complaints

WideScale's workers and Partners' workers must have access to a system to report complaints and concerns to their superiors. Workers must be able to report legal or ethical violations to the appropriate authorities without fear of retaliation and, where possible, while maintaining confidentiality and anonymity.

WideScale maintains an open-door policy for reporting concerns and will not retaliate against any worker or Partner for good-faith reporting of suspected violations of this Code or applicable law.

20. Enforcement and Audit Rights

WideScale reserves the right to end its business relationship with or pursue any other remedy available under applicable law against any Partner that does not adhere to this Code. Upon reasonable suspicion of a violation of this Code, WideScale reserves the right to audit Partners' relevant documentation upon fifteen (15) calendar days' written notice.

Contact

To report a concern or potential violation of this Code, please contact: