Anti-Bribery & Anti-Corruption Policy

Effective Date: June 2026
Last Updated: June 2026

Corporate Governance | NewBreed Global

This policy reflects NewBreed Global's commitment to conducting business with integrity, transparency, accountability, and respect for the rule of law throughout the global logistics and transportation industry.

Purpose

NewBreed Global is committed to conducting business ethically and lawfully in every jurisdiction where we operate.

Bribery and corruption undermine fair competition, damage trust, expose organizations to significant legal and commercial risk, and weaken confidence in international trade.

This policy establishes NewBreed Global's commitment to preventing bribery, corruption, improper influence, and unethical business conduct.

Scope

This policy applies to:

Directors

Officers

Employees

Contractors

Consultants

Representatives

Agents

Suppliers

Business partners acting on behalf of NewBreed Global

Every individual associated with NewBreed Global is expected to uphold these standards.

Our Commitment

NewBreed Global maintains a zero-tolerance approach toward bribery and corruption.

We do not offer, authorize, request, solicit, receive, or knowingly participate in any form of bribery or improper business inducement.

Business decisions shall always be based on legitimate commercial considerations.

Prohibited Conduct

The following activities are prohibited:

Offering or accepting bribes.

Kickbacks.

Secret commissions.

Improper gifts intended to influence business decisions.

Facilitation payments where prohibited by applicable law.

False invoices or fraudulent documentation.

Concealment of improper payments.

Misrepresentation of commercial information.

Use of intermediaries to circumvent legal or ethical obligations.

Gifts, Hospitality, and Business Courtesies

NewBreed Global recognizes that reasonable business hospitality may support professional relationships.

However, gifts, meals, entertainment, or hospitality must never:

Influence independent business judgment.

Create an actual or perceived conflict of interest.

Violate applicable laws.

Be excessive or inappropriate.

Be exchanged in return for favorable treatment.

When in doubt, transparency should guide every decision.

Third-Party Relationships

Because NewBreed Global frequently collaborates with transportation providers, vessel owners, operators, inspection companies, freight providers, consultants, and other commercial partners, we expect those organizations to conduct business ethically and responsibly.

Where appropriate, NewBreed Global may perform reasonable due diligence before establishing or continuing business relationships.

Accurate Records

Business records must accurately reflect the nature of transactions.

No individual shall:

Create false records.

Conceal payments.

Misrepresent expenses.

Falsify commercial documentation.

Maintain undisclosed accounts relating to business activities.

Transparency supports trust and responsible commercial relationships.

Reporting Concerns

Individuals are encouraged to promptly report suspected bribery, fraud, corruption, unethical conduct, or violations of this policy.

Reports may be made without fear of retaliation in accordance with NewBreed Global's Compliance & Reporting Policy and Whistleblower Policy.

Compliance with Laws

NewBreed Global is committed to complying with applicable anti-corruption laws in the jurisdictions where we conduct business.

These may include laws governing:

Bribery

Corruption

Fraud

Financial crimes

International commercial transactions

Sanctions compliance

Recordkeeping

Where local laws impose higher standards than this policy, the higher standard shall apply.

Training and Awareness

NewBreed Global encourages ongoing awareness of ethical business practices and expects personnel engaged in commercial activities to understand the principles outlined in this policy.

As our organization grows, additional training and guidance may be provided to support consistent compliance.

Violations

Violations of this policy may result in corrective action, suspension of business relationships, termination of contracts, or referral to appropriate authorities where required by law.

NewBreed Global reserves the right to discontinue relationships with organizations or individuals whose conduct is inconsistent with our ethical standards.

Contact

Questions regarding this policy may be directed to:

NewBreed Global
601 Carlson Parkway, Carlson Center, Suite 1050
Wayzata, Minnesota 55305 USA

Email: [email protected]
Phone: +1 (866) 477-6299

Our Commitment

NewBreed Global believes that ethical conduct is fundamental to sustainable global commerce. Every shipment coordinated, every relationship established, and every commercial decision reflects our commitment to integrity, accountability, and responsible international business. We will never compromise these principles for commercial advantage, because trust is earned through consistent actions—not promises.