Code of Conduct

General

CargoTracks is committed to uphold the highest standards of conduct. The standards, improved from time to time, apply to CargoTracks, its directors, officers and employees.

The standards are not exhaustive. The underlying principle of high standards applies to all issues even if they are not covered specifically in the standards. CargoTracks CEO or directors can be contacted to get answers for any questions relating to these standards.

Directors, Officers and Employees are expected to bring all violations to the attention of any non executive member of the Board of Directors. Please send emails to CEO.

Corporate Citizenship

CargoTracks shall be a good corporate citizen and shall comply with the letter and spirit of all laws governing its operations conduct its affairs in accordance with best moral, professional, legal and ethical standards.

Fair Dealing

CargoTracks shall deal with customers, suppliers, government, employees, competitors and community in a fair manner with honesty, integrity and ethics. CargoTracks shall not strive to take unfair advantage through any unfair practice.

Fair Behaviour in Market Place

CargoTracks intends to be competitive in adding value to its customers in the market place. However, CargoTracks shall be lawful and fair while being competitive. CargoTracks shall not indulge in violating laws applicable to competitive behaviour. CargoTracks shall not indulge in securing competitive advantage through illegal or unlawful means. Collection of intelligence about competition shall be through lawful means alone.

CargoTracks respects the intellectual property rights of its customers, suppliers and competitors fully. CargoTracks behaviour in respecting intellectual property rights shall strive to comply with laws that apply to its principal market, the United Kingdom in addition to the laws that apply to its operations.

Equal Opportunity Employer

CargoTracks is an equal opportunity employer. CargoTracks shall not discriminate on the basis of gender, nationality, race, colour, religion, marital status or age. CargoTracks believes diversity of people in the company adds value to the business. Hiring, promotion and compensation decisions shall be entirely based on fitment, appropriateness to work demands and market conditions alone.

Health and Safety

CargoTracks shall strive to provide and maintain a safe and healthy work environment. Compliance with all health and safety related law and regulation is a minimum commitment. CargoTracks expects its directors; officers and employees to be aware of the health and safety policies and practices and help all customers, contractors, and visitors comply with these policies and practices while in CargoTracks premises or while working on behalf of CargoTracks. CargoTracks directors, officers, employees and contractors designated to work in customer or supplier environments shall comply with the health and safety policies and practices in force in such environments. All accidents, however minor, are reportable to HR.

Environment

CargoTracks cherishes the need to keep our environment sustained for the future. CargoTracks shall comply with all laws and regulations relating to protection of Environment. CargoTracks shall be prompt in responding to any threats to environment. CargoTracks shall co-operate to the maximum extent with the Community in protecting the environment. CargoTracks shall comply with all record keeping and reporting obligations.

Financial Integrity and Reporting

CargoTracks shall maintain its accounts and report financial results in a true and fair manner consistent with applicable financial standards. CargoTracks shall maintain sufficient business and reporting controls consistent with its size to protect stockholders’ interest. CargoTracks will not falsify records or reports.

Improper or Questionable Payments

CargoTracks shall not make improper or questionable payments of company funds to anyone for obtaining or retaining business or securing any improper advantage.

Political and Charitable Contributions

CargoTracks shall not fund or support any specific political party or candidate for political office. CargoTracks assets shall not be used for any political campaigns. CargoTracks will not interfere with the employees’ right to have their own views on politics. Use of CargoTracks name to endorse a charitable organization or event is not permitted without the prior approval of the Board.

Government Inquiries

CargoTracks is committed to fairness, honesty and integrity in dealing with the government and regulatory agencies with which we interact.

CargoTracks and its employees, agents and contractors must cooperate with appropriate government inquiries and investigations. However, it is important to protect the legal rights of CargoTracks with respect to its confidential information. No financial information may be disclosed without the prior approval of the Chief Executive Officer.

Conflicts of Interest

CargoTracks expects its directors, officers and employees to have no conflict of interest in their dealings on behalf of CargoTracks, in their dealings in the market place or in their dealings with each other. In the unfortunate event of a conflict of interest arising, directors, officers and employees are expected to disclose such a conflict immediately to the CEO and an independent director.

Conflicts of interest arise, among other instances, when a director, officer or employee competes with CargoTracks business while being engaged with CargoTracks directly or indirectly converts CargoTracks business opportunity into a personal opportunity for him/her or relatives, uses privileged information received in the course of business for personal gain, uses business assets/property for personal purposes, uses business hours for unrelated purposes, receives improper personal benefits due to his/her position in CargoTracks accepts gifts or value from anyone dealing with CargoTracks or from a competitor, owns a material interest in any competitor, customer, supplier (2% shareholding in a public company is not considered material) is unable to act in CargoTracks best interest because of conflicts with private interests.

Confidentiality

All confidential or proprietary information received in the course of business from customers and suppliers are to be treated confidential and protected against disclosure and improper use.

Every director, officer and employee of CargoTracks shall enter into a legally enforceable “covenant to not disclose confidential information”. This obligation shall survive the termination of the engagement with CargoTracks.

CargoTracks shall not forgive wilful disclosure of confidential information and shall pursue maximum legal remedy and punishment for wilful disclosure. CargoTracks shall have in place systems and policies to prevent unauthorised access to premises, systems and data and to prevent unauthorised recording or copying of data.

Every director, officer and employee shall respect these policies to the fullest extent in letter and spirit. Information already available in public domain or known prior to disclosure by customer is not considered confidential or proprietary. Disclosure under compulsion from law is not a violation of this covenant.

Sexual Harassment

Sexual harassment includes deliberate or repeated unsolicited verbal comments, gestures or physical contact of a sexual nature including unwelcome sexual advances, requests for sexual favours and other verbal of physical contact of a sexual nature when submission to such conduct is expected explicitly or implicitly for hiring, promotion, compensation and other employment decisions or for a non hostile work environment. Every director, officer, employee shall ensure such a conduct is avoided. All complaints shall be handled in a timely, confidential and independent manner.

Use of Business Assets

Every director, officer, employee shall safeguard and protect all assets, including intangible assets, of CargoTracks in their individual or collective custody. Such assets shall not be used for any unrelated purposes or any personal benefits/purposes. Funds taken from CargoTracks shall be properly accounted for. Personal expenses or payments shall not be claimed as or treated as business expenses. CargoTracks technology assets are to be used exclusively for the purposes of CargoTracks business. Unauthorised access, use or extraction of data is prohibited. Access to internet is restricted to business purposes. All inward/outward communication through business assets, all data held in business assets are exclusively the property of CargoTracks and are subject to being monitored for appropriateness.

CargoTracks prohibits use of unauthorised or pirated software. All software installed on business assets should be legally usable by CargoTracks. Unauthorised installation of software is prohibited.

Intellectual Property

CargoTracks expects its directors, officers and employees to help develop and protect its intellectual property. All work/product employees created by directors, officers or employees while in employment are the exclusive property of CargoTracks.

Personal Relationship and Activities

CargoTracks cherishes professionalism and objectivity. Employees are discouraged from having personal relationship (other than simple friendship) with anyone who is:

  • employed by CargoTracks and reporting to them
  • dealing with CargoTracks as a customer or supplier through them

CargoTracks employees, while free to pursue their views as citizens, are expected to not bring harm to CargoTracks or its customers’ reputation or image through their non employment activity. CargoTracks reserves the right to determine whether any act is likely to harm reputation or image.

Internet, Email and Voice Communication

CargoTracks employees must exercise good judgment and act in a professional manner in communicating with outsiders (through letters, telephone conversations, voice mails, emails, chats, postings etc.) whenever they communicate on behalf of CargoTracks or its customers or whenever they communicate using a legitimately provided address of CargoTracks or its customers or whenever they communicate using the premises/technology assets of CargoTracks or its customers. All communication from CargoTracks premises/assets or on behalf of CargoTracks (or its customers) is CargoTracks property.

Drug and Alcohol Abuse

Substance abuse, including manufacture, sale or use of controlled substances in CargoTracks premises or while on CargoTracks business is prohibited.

Exclusivity of Employment

Employment as Whole time director, officer or employee with CargoTracks is full time. Acceptance of other employments while with CargoTracks is prohibited unless waived in writing a priority.

Transactions with Related Parties

Dealing with relatives or self on behalf of CargoTracks is prohibited. Relatives include spouse, siblings, children, parents, grandparents, grandchildren, aunts, uncles, nieces, nephews, cousins, step relationships, and in-laws. If such a deal is unavoidable, in each such instance, prior written approval must be taken from the Board of Directors and the CFO.