As the creators of the world’s largest ocean and air freight rate benchmarking and market analytics platform, our mission is to provide transparency in the ocean and air freight market. Xeneta upholds the highest standards of corporate behavior. We are dedicated to operating within ethical and professional standards, regulations, laws, internal policies, and the Xeneta values.

At Xeneta, we expect the same level of integrity and business conduct from our third parties as we do from our own employees. While it's impossible to foresee every ethical situation that may arise, we rely on our suppliers, partners, and other parties working with Xeneta to use sound reasoning and always maintain a high level of integrity.

The Xeneta Code of Conduct and Summit Guidelines, attached hereto, apply to all parties to ensure alignment with our values and provide consistent excellence for our customers, stakeholders, and communities.

Xeneta is dedicated to providing a welcoming, respectful, safe, and accessible environment for all. The Xeneta Summit fosters an environment where collaboration can thrive, innovation is abundant and encouraged, and all attendees are provided the opportunity to learn and grow. 

We ask that Xeneta staff and conference participants be mindful of the Xeneta Summit Guidelines, to help create an inclusive environment that is free of harassment, aggression, and intimidation. Xeneta maintains a zero-tolerance policy for sexual harassment, such behavior is unacceptable and will be met with strict consequences. Please be respectful in chats, meetings, comments, and other interactive conference components.

In the event that you need to report an incident, email: summit@xeneta.com 

Summit Guidelines

Introduction

At Xeneta, we strongly follow and encourage full and strict compliance with all applicable antitrust and competition laws, both when using our products and when attending events hosted by Xeneta. These guidelines are motivated by a firm respect for preserving and promoting fair competition in the market, a belief in antitrust and competition laws, and a recognition of the potentially severe consequences of violations of such laws.

Attending the Xeneta Summit requires full compliance with all applicable antitrust and competition law and the rules outlined in these guidelines.

These guidelines apply at all times during the summit, both at formal meetings and during informal discussions and conversations with other attendees.

Follow your own internal guidelines

As an attendee, you are responsible for complying with these guidelines as well as all relevant laws and regulations while attending the summit. We also advise you to consult your own legal advisor to get a full understanding of applicable rules.

You should follow your company’s internal policy regulations at all times during the Summit. Xeneta is not responsible for the content discussed in conversations between you and other attendees, so if you are ever in doubt about the topics you can discuss or, please refrain from discussing such topics and consult your legal advisor.

Avoid delicate topics

Do not disclose sensitive, confidential and not publicly released information, especially your company’s freight rates.

Refrain from engaging in coordinated actions. It's important to keep your partners uncertain about your own and your company's strategic moves in the market. This uncertainty can help maintain a competitive edge and ensure that your partners remain vigilant.

Give your opinion in generic terms when speaking about strategies. Do not refer to your concrete intentions or the decisions of your company.

Terminate and leave inappropriate discussions

Terminate any discussion that might be construed as raising antitrust risks and immediately consult your legal counsel. All conversations held during the Summit must be conducted consistent with these guidelines.

Do’s and don’ts

The following are some of the most critical “Do’s and Don’ts” for you as an attendee to comply with these guidelines. The list is not exhaustive.

DO:

1. Make sure you receive and familiarize yourself with the written agenda for the summit.
2. Make sure you have read and understood these guidelines and that you have a copy available at all times.
3. Seek advice from your legal counsel if you have questions about the antitrust or competition laws, your responsibilities under these laws, or any of the topics in these guidelines.
4. Pause and leave any discussion or meeting activities that appear to violate these guidelines and seek advice from your legal counsel.
5. Terminate any discussion or meeting which appears to violate these guidelines and make sure protests and exits are noted down.

DON’T:

1. Discuss company-specific strategies, bids, prices, rates, or features that can affect and change prices – e.g., discounts, costs, salaries, terms and conditions, warranties, rebates, or profit margins.
2. Discuss what is a fair or appropriate price or profit margin for other market members.
3. Discuss individual confidential company information, such as cost, production, capacities, inventories, sales, design, production, distribution, or marketing of products, including proposed customer territories (other than nameplate or publicly released information).
4. Discuss restrictions on volume, to blacklist or boycott other market members or to conspire to exclude or refrain other members from the market.

Code of Conduct 

This document outlines the expectations of Xeneta’s customers, suppliers, and service providers regarding business practices, including but not limited to their approach to human rights, the environment, and ethical practices in compliance with legal requirements.

All Xeneta customers, partners, suppliers, service providers, and other parties who work with or for Xeneta are defined as “Third Parties” with whom Xeneta has active commercial relationships.

Third parties are expected to comply with all relevant local and international laws and regulations in addition to this code. The former will take precedence if any law or regulation is more stringent than this code.

Legal Compliance

Third Parties shall conduct business in strict compliance with the applicable laws and regulations of the countries where both Xeneta and they operate, including but not limited to Norway, the US, the UK, and Germany. 

They must ensure the confidentiality and protection of suppliers and personnel by prohibiting retaliation against individuals who, in good faith, report questionable behavior or non-compliance with the applicable laws or this code of conduct.

Legal Competition 

Third Parties shall conduct their business in accordance with the principles of fair competition and in compliance with applicable antitrust and competition laws. They must not allow any exchange of information or deal with matters that may influence any decision related to purchases, price quotes, termination of contracts, extension of subscriptions, or any agreement that unlawfully restricts fair competition.

Anti-corruption

Third Parties shall comply with all the applicable domestic and foreign anti-bribery and anti-corruption laws, including but not limited to local anti-corruption law, the UK Bribery Act, and the United States Foreign Corrupt Practices Act. Third Parties shall not offer, pay, request, or accept any bribes, including, but not limited to, active bribes, passive bribes, and facilitation payments. They must implement internal mechanisms and processes to address corruption and fraud in their activities. We encourage Third Parties to report any suspicious activity.

Business Integrity 

Third Parties shall conduct all business with ethics and integrity. All business transactions must be conducted with transparency and maintaining accurate accounting records, strictly complying with all domestic and foreign laws applicable to fraud prevention and anti-money laundering (AML). Third Parties shall not enter into any agreement that may constitute Xeneta being involved directly or indirectly in any economic crime, and/or money laundering activities.

Conflict of Interest

Third Parties shall avoid any transactions, business deals, business partnerships, and/or situations that may generate or portray conflicts of interest with respect to Xeneta employees. All conflicts of interest should be reported to Xeneta on a timely basis.

Confidential Information and Intellectual Property 

Third Parties must handle information regarding contracts and commercial terms confidential. They must not disclose to third parties except with the express permission of the respective parties and by signing a non-disclosure agreement. It is forbidden to use Xeneta logos, trademark, and any other intellectual property rights in whole or in part without the prior permission of the respective teams in charge. Third Parties must take appropriate steps to safeguard and maintain confidential and proprietary information and only use such information for purposes authorized by Xeneta.

Trade Compliance 

Third Parties shall comply with applicable trade compliance laws and regulations that impact Xeneta operations as a "Web-based platform" company and undertake to perform its activities in compliance with all trade, customs, import, and export laws and regulations, sanctions, and embargoes applicable in the relevant territories.

Employment Contract and Employment Practices 

Third Parties shall comply with all labor laws applicable to each country where they operate, including Norway, Germany, the UK, and the US. All employees shall be paid and receive benefits as set forth in the applicable country laws. They must make sure they pay all labor taxes, social security contributions, and payroll taxes. They must provide equal conditions of employment, compensation, access to training, and career development opportunities. 

Modern Slavery 

Third Parties shall not withhold any employee documentation, subject to the worker's freedom. They must not force employees to exhaustive work routines, physically punish, and/or harass them. They shall not use any production units that use slave or unpaid labor. 

Discrimination, Diversity, and Inclusion 

Third Parties shall have a work environment that respects diversity and forbids any discrimination such as ethnicity, skin color, creed, gender, background, age, sexual orientation, physical or mental disability, pregnancy, marital status, labor union membership, political stance, etc. Third parties shall not discriminate against any individual in their employment or hiring processes.

Freedom of Expression 

Third Parties shall respect and encourage all kinds of freedom of expression provided that they exercise responsibility and ethics and are within the legal limits. 

Health and Safety 

Third Parties shall comply with all occupational health and safety laws applicable to the countries they operate in. Third Parties shall also provide training and implement preventive measures against accidents and illness in the workplace. 

Environment 

Third Parties shall comply with environmental laws applicable to each country they operate in and the requirements of the competent agencies. Third parties must take necessary measures to prevent and mitigate environmental damage in their activities.

Child Labor 

Third Parties shall only hire workers of legal working age and ensure that all company operations are free of any child labor or sexual exploitation of children as provided for by the International Labor Organization (ILO) standards. 

Gifts and Transparency 

Xeneta recognizes that exchanging gifts is a common practice in locations where Third Parties operate. Therefore, it is allowed to offer gifts and receive presents as long as it complies with the Xeneta anti-corruption and anti-bribery policy and the Xeneta Code of Conduct. Third Parties shall not accept or provide any gifts or favors to or from active or former government officials or commercial parties for or on behalf of Xeneta without obtaining prior approval from Xeneta.

Insider Trading

Third Parties in possession of any non-public information about a company are prohibited from buying or selling securities of that company. They are not allowed to engage in insider trading or inappropriate disclosure of non-public information, regardless of whether the information was obtained while working for or with Xeneta. They must comply with all applicable laws and regulations regarding insider trading.

Sanctions and Export Controls

Third Parties shall comply with the applicable economics, sanctions, and export control laws and regulations applicable to their business and avoid doing anything that would position Xeneta or themselves in a violation of applicable laws.

Social Media

Third parties must refrain from disrespectful, unprofessional, harassing, defamatory, discriminatory, and prohibited activity on social media platforms. Third parties are not authorized to act or speak on behalf of Xeneta unless explicitly authorized in writing by an authorized Xeneta representative.