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GXO Logistics - Ethics - Integrity Matters

Code of Business Ethics

The Code of Business Ethics applies to all employees and sets expectations for conduct that are consistent with our core values and our ethical standards. It serves as the tool by which our organization communicates its commitment to the expectation of ethics and integrity for our employees as well as our business partners. The code of Business Ethics is intended to provide effective direction about the company’s standards for ethical behavior.

Message to employees

As a global leader in our industry, we have a responsibility to set an example that is beyond reproach. This goes to the heart of who we are as a company and as individuals.

Our culture at GXO is about achieving results through teamwork. We help each other succeed. We’re proud to support our customers, carriers and fellow employees. We’re fair, respectful, lawful and honest. These are the reasons why customers and investors believe in us.

Our Code of Business Ethics and Business Ethics Policies are intended to help you stay true to our culture by providing guidance about a range of situations.

Malcolm Wilson

CEO

Malcolm-Wilson-Chairman-GXO-Logistics

Documents

Code of Business Ethics

Business Partner Code of Conduct

Anti-Corruption Policy

Antitrust and Fair Competition Policy

Conflicts of Interest Policy

Conflicts of Interest Form

Data Protection Policy

EU Data Retention Policy

GDPR Privacy Policy

EU Workers Privacy Notice

Human Trafficking Policy

No Discrimination, Harassment or Retaliation Policy

Trade Compliance Policy

Third Party Due Diligence Policy

Insider Trading Policy

Securities Trade Monitoring Policy

Index de l’égalité femmes-hommes

UK Tax Strategy 2023

UK Gender Pay Gap Report

UK Gender Pay Gap Report – GXO ServiceTech

Ireland Gender Pay Gap Report

UK Excise Due Diligence Policy

Poland Tax Strategy 2021

Poland Tax Strategy 2022

UK Carbon Reduction Plan

UK Modern Slavery Statement

Italy Gender Equality Policy

Integrated Policy GXO Logistics Italy

GXO PDPA Privacy Policy

PDPA Workers Privacy Notice

Gifts and Entertainment Policy

Design Definition Compliance Notice

GXO Logistics - Ethics - Reporting Concerns

Reporting Concerns

If you are aware of, or suspect any conduct that violates the Code, policies, or the law, you must report it. Consider reporting it first to your supervisor, your local Human Resources representative or the Ethics and Compliance Office.

Report:

www.GXO.ethicspoint.com

[email protected]

Ethics Line

Whether you are a GXO employee, customer, supplier or a member of the general public, you may contact the GXO Ethics Line to report violations of the law or the Code of Business Ethics. The Ethics Line is operated by an independent company, is available 24 hours a day, 7 days a week and translation services are available. Where permissible under local law, the Ethics Line allows you to anonymously report a concern. Please refer to the chart below for the global Ethics Line telephone numbers.

Australia

1800 531 606

Belgium

0800 79 368

Chile

800 914 061

China

400 120 0184

Czech Republic

800 144 529

Finland

0800 415755

Germany

800 1820274

Hong Kong

800 930 167

Ireland

1 800851668

Italy

800 761 627

Malaysia

1 800 81 4756

Mexico

800 681 9210

Netherlands

0800 0221659

Poland

800 005 016

Portugal

800 181 412

Romania

0800 890352

Singapore

800 492 2514

Spain

900 983 443

Switzerland

0800225122

Taiwan

00801 49 1654

Thailand

18000 14 719

United Kingdom

0 8000 903695

United States

1-(844) 694-0719