A company’s reputation is the bedrock on which its business is built. At Globaltrans, maintaining our good name is of paramount importance and we are well aware of how easily it could be damaged by actual or suspected unethical behaviour. We are committed to operating to the highest ethical and professional standards and to ensuring that all our business dealings are conducted openly and transparently.

Our Code of Ethics and Conduct sets out the ethical standards that our Group adheres to and how we expect our employees to act to maintain them. It describes the Group’s principles with respect to confidential information, anti-bribery, conflicts of interest and reporting concerns. Its purpose is to help our employees understand the Group’s core values and what is expected of them to ensure compliance with our policies and all relevant laws and regulations.

We do not tolerate any violations of the Code. All employees are required to read and fully understand the Code and sign an acknowledgement to this effect.



Our partners are an integral part of our business, and how they behave also reflects on us. Therefore, they must understand and commit to upholding the same ethical standards as we set for ourselves. Accordingly, in 2020 the Group formally adopted a Supplier Code of Conduct, based on the principles set out in the UN Global Compact, which describes what Globaltrans expects from its suppliers with regards to business ethics, human and labour rights, employee relations, health and safety and other related topics. By building on our shared values, Globaltrans and its suppliers can create stronger and more successful businesses.

In January 2021, Globaltrans established an ESG Committee to support and direct the Group towards improving its sustainability-related practices and policies and its reporting and transparency. Its creation reflects the Group’s conviction that behaving responsibly underpins our ability to deliver sustainable value for all our stakeholders. By assisting the Board with oversight of ESG-related issues, the Committee supports the development of a practical Group-wide approach to sustainability and disclosure.

The Committee's efforts were bolstered by the adoption in January 2021 of a formal ESG policy that set out formal ESG commitments and established lines of responsibility and accountability.

The ESG Committee consists of two Board members: Elia Nicolaou, Non-executive Director, who is the Chair, and John Carroll Colley, Independent Non-executive Director. In addition, Globaltrans CEO Valery Shpakov is actively engaged in all ESG-related matters, emphasising the importance of these issues for the Group.

Globaltrans has adopted a number of formal Group-wide policies that address human rights, freedom of association, data protection, diversity and inclusion, and supplier conduct. These documents are subject to ongoing review and monitoring to ensure their relevance and compliance with legal requirements. The Group requires all employees to acknowledge that they understand and accept the relevant policies. All the documents are publicly available and can be viewed on the Company’s website.

Globaltrans makes every effort to be an employer, partner and community member who values people and respects their fundamental rights and freedoms. We are committed to maintaining strong human rights and labour practices not just in our own operations and business network, but within the broader community as well. The Human Rights Policy we introduced in 2020 sets out the minimum human rights standards that everyone who works for and with Globaltrans must meet. To ensure that we are constantly progressing on this front, we regularly review our conduct, policies and training and integrate any changes or learnings required into our operations. Our approach is consistent with international human rights standards such as the UN Guiding Principles on Business and Human Rights. Our commitment to human rights is also clearly stated in our Code of Ethics and Conduct, Supplier Code of Conduct, and in our Diversity and Inclusion Policy.

We believe that working in a diverse and inclusive work environment is rewarding for our people and ultimately for our business. By treating everyone with dignity and respect, by providing equal opportunities regardless of ethnicity, gender, religious beliefs, nationality, age or any physical disability, we can create an environment where people can be themselves and excel in what they do. Our Diversity and Inclusion Policy details our commitment to creating an inclusive and welcoming environment. That commitment is supported at the highest levels within the Group and is reflected in our approach to new appointments and Board membership.

Alongside our commitment to inclusivity is our respect for all applicable labour laws and regulations and our recognition that it is a fundamental right of Globaltrans employees to form and join workers’ organisations and to engage in collective bargaining. This is enshrined in our Freedom of Association Policy, adopted in 2020, which reflects the Group’s commitment to respecting employees’ choices and maintaining a regular and constructive dialogue with them and their designated representatives.

Globaltrans has a zero-tolerance approach to bribery and corruption in all its forms. While this is detailed in our Anti-fraud Policy, we have always endeavoured to act ethically, professionally, fairly and with integrity in all our business activities and relationships. We are very clear on the standards of conduct that all employees must adhere to, and we provide guidance on how to avoid and recognise unacceptable behaviour. Our approach is consistent with all applicable regulations and we have established rules and procedures to deal with any alleged violations. We ensure that each employee understands the types of violations that can occur within their area of responsibility and closely monitor for any signs of potential non-compliance.

To support this, the Group maintains a Whistleblowing Policy which encourages the investigation and reporting of improper activities, including non-compliance with our Code of Ethics and Conduct, and helps fosters a culture based on honesty and good behaviour. We encourage employees to speak up and report any concerns that they may have. We provide confidential, safe and secure mechanisms for anonymous reporting of suspected violations, as well as safeguards and support for those who report such breaches.

Senior management meets regularly to discuss, inter alia, anti-fraud and anti-corruption measures. During 2022, no instances of alleged fraud, bribery or corruption were reported within the Group.

We respect and protect the confidentiality and security of our stakeholders’ personal information. We comply with the EU General Data Protection Regulation (GDPR) which was adopted in April 2016. Data privacy and security are of the utmost importance to the Group and we have a dedicated Privacy Policy that can be accessed on the Group’s website.



Last updated: 15.03.2024