NewBreed Global Code of Business Ethics

Effective Date: January, 2026

Our Commitment

At NewBreed Global, trust is our most valuable asset. Since our origins in 2008, our organization has been built on the belief that successful global trade depends not only on transportation but on integrity, transparency, accountability, and long-term relationships.

We recognize that international logistics, marine transportation, vessel chartering, and commodity trading involve significant commercial responsibility. Every decision we make is guided by our commitment to protect the interests of our clients, business partners, and the broader global supply chain.

This Code of Business Ethics establishes the principles that guide our conduct in every transaction, partnership, and business relationship.

Our Core Values

Integrity

We conduct business honestly, professionally, and ethically. We do not knowingly participate in deceptive practices, fraudulent transactions, or activities that compromise the confidence placed in our organization.

Trust

Trust is earned through consistent actions. We strive to build lasting relationships by communicating openly, honoring our commitments, and acting responsibly throughout every engagement.

Due Diligence

We believe informed decisions reduce unnecessary risk. Whenever appropriate, we support clients through reasonable due diligence, verification, and logistics coordination processes designed to promote transparency and confidence.

Accountability

We accept responsibility for our decisions, communications, and professional conduct. When challenges arise, we work collaboratively and transparently toward practical solutions.

Professional Excellence

We continuously improve our knowledge, relationships, and capabilities to better serve our clients in an evolving global marketplace.

Ethical Business Practices

1. NewBreed Global is committed to conducting business fairly and lawfully.

2. We expect our directors, employees, contractors, consultants, representatives, and strategic partners to:

3. Conduct business honestly and professionally.

4. Treat all clientAs, suppliers, and partners with fairness and respect.

5. Avoid conflicts of interest whenever possible.

6. Protect confidential business information.

7. Comply with applicable laws and regulations.

8. Promote accurate and truthful business communications.

9. Support responsible international trade practices.

Client Relationships

Every client engagement is approached with professionalism, discretion, and respect.

We strive to:

1. Understand each client's operational objectives.

2. Communicate clearly regarding the scope of our services.

3. Coordinate transportation and logistics responsibly.

4. Maintain appropriate confidentiality regarding commercial information.

5. Foster long-term partnerships based on mutual trust.

Supplier & Business Partner Relationships

We seek to establish relationships with organizations that demonstrate professionalism, reliability, and ethical conduct.

Whenever practical, NewBreed Global considers factors such as:

1. Business legitimacy

2. Professional reputation

3. Operational capability

4. Regulatory compliance

5. Commercial reliability

6. Commitment to ethical business practices

Compliance

NewBreed Global supports compliance with applicable laws governing transportation, international trade, sanctions, anti-corruption, commercial transactions, privacy, and business operations in the jurisdictions in which we operate.

Where additional contractual requirements apply, those requirements shall govern the specific commercial relationship.

Anti-Corruption

NewBreed Global does not tolerate bribery, corruption, facilitation payments, kickbacks, or improper business inducements.

Business decisions must always be based upon legitimate commercial considerations.

Additional guidance is provided within our Anti-Bribery & Anti-Corruption Policy.

Confidentiality

We recognize that our clients frequently entrust us with commercially sensitive information.

We are committed to handling confidential information responsibly and using it only for legitimate business purposes, subject to applicable agreements and legal requirements.

Continuous Improvement

Global trade is constantly evolving.

NewBreed Global is committed to continuously improving its knowledge, procedures, industry relationships, and operational practices to better serve clients while promoting transparency, efficiency, and responsible logistics coordination.

Speaking Up

Employees, contractors, suppliers, and business partners are encouraged to raise concerns regarding unethical conduct, suspected violations of law, or behavior inconsistent with this Code.

Reports will be reviewed in accordance with our Compliance & Reporting Policy and Whistleblower Policy.

Our Commitment

At NewBreed Global, we believe that trust is not claimed—it is earned.

Every shipment coordinated, every relationship developed, and every decision made is an opportunity to demonstrate our commitment to integrity, professionalism, and responsible global commerce.

These principles define who we are, how we conduct business, and the standard to which we hold ourselves accountable.