Anti-Bribery & Corruption Policy

Purpose & Scope

This policy sets out Box Hub's position on bribery and corruption and explains how we expect our people and partners to conduct business honestly, everywhere we operate. It applies to every Box Hub employee, officer, and director, as well as contractors, agents, freight and logistics partners, and any third party acting on Box Hub's behalf.

It covers all interactions with customers, suppliers, carriers, government officials, and regulatory bodies, whether in the United States or abroad, and complements Box Hub's broader Code of Conduct.

Our Commitment

Box Hub maintains a zero-tolerance approach to bribery and corruption in any form. We comply with applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), and the anti-bribery laws of every country in which we do business.

No employee, contractor, or partner will suffer demotion, penalty, or other adverse consequence for refusing to pay a bribe or for reporting a genuine concern, even if that refusal results in a lost sale or delayed shipment.

What Counts as Bribery

Bribery is offering, promising, giving, requesting, or accepting anything of value in order to improperly influence a business or government decision. This is not limited to cash — it includes gifts, hospitality, favors, job offers, and other benefits offered with the intent to gain an improper advantage.

• Offering a bribe: Promising a payment, gift, or favor to win business, speed up a shipment, or influence an inspection or permit.
• Accepting a bribe: Requesting or accepting money, gifts, or favors from a customer, supplier, or carrier in exchange for preferential treatment.
• Facilitating a bribe: Knowingly assisting, authorizing, or turning a blind eye to bribery carried out by a third party on Box Hub's behalf.

Gifts, Hospitality & Entertainment

Reasonable, occasional gifts and hospitality are a normal part of business relationships and are not prohibited outright. However, they must always be modest in value, given openly, and never offered or accepted in exchange for a business decision.

• Gifts must be infrequent, of reasonable value, and appropriate to the relationship.
• Cash or cash-equivalent gifts (gift cards, loans) are never permitted, in either direction.
• Hospitality tied to an active bid, quote, or contract decision should be avoided or disclosed to a manager beforehand.
• When in doubt, employees should ask: "Would I be comfortable if this were made public?" If not, decline it.

Facilitation Payments

Facilitation payments — small, unofficial payments made to speed up a routine government action such as customs clearance, permitting, or inspection — are strictly prohibited, even in regions where such payments are locally common practice.

Employees who face pressure to make a facilitation payment while handling a shipment or import/export process should decline, document the request, and report it immediately through the channels outlined below.

Third Parties & Business Partners

Box Hub works with a network of freight carriers, customs brokers, depot partners, and sales agents. Anyone acting on our behalf is expected to meet the same anti-bribery standard set out in this policy.

• Third parties are screened before engagement, with particular attention to logistics and customs-facing roles.
• Contracts with agents and brokers include anti-bribery compliance terms.
• Box Hub reserves the right to terminate any partnership where a violation of this policy is identified.

Political & Charitable Contributions

Box Hub does not make political contributions or charitable donations in order to gain an improper business advantage. Any charitable giving made in the company's name is approved through proper internal channels and is never linked, directly or indirectly, to a pending business decision, contract, or government approval.

Reporting a Concern

If you suspect a violation of this policy — by a Box Hub employee, contractor, or business partner — we want to hear about it. Reports can be made in good faith without fear of retaliation.

Consequences of Non-Compliance

Any employee found to have violated this policy is subject to disciplinary action, up to and including termination of employment. Contractors, agents, and business partners found in violation are subject to termination of their agreement with Box Hub and, where applicable, referral to law enforcement or regulatory authorities.

Training & Policy Review

Employees in roles with exposure to customers, suppliers, freight partners, or government interactions receive anti-bribery training as part of onboarding and on a recurring basis. This policy is reviewed at least annually and updated as needed to reflect changes in law or business operations.