Responsibility and Compliance

Glopaca BV and Glopaca International BV Rules of International Trade

Glopaca BV and Glopaca International BV are committed to the preservation of its reputation and integrity through compliance with applicable laws, regulations and ethical standards in each of the markets in which they operate. All employees are expected to adhere to these laws, regulations and ethical standards, and management is responsible for ensuring such compliance. Compliance is therefore an essential ingredient of good corporate governance. Glopaca BV, Glopaca International BV and its employees will avoid becoming involved in acts that are against the law and/or are regarded as improper in society, and that they safeguard the integrity of their business operations.

All members of the management of Glopaca BV and Glopaca International BV and all staff of both organizations are required to comply with our Code of Conduct which is available on our website.

Integrity risks are understood among other things as the risk of money laundering and the risk of terrorist financing. As internationally operating companies, Glopaca BV and Glopaca International BV comply with existing legislation with regard to the Anti Money Laundering and Counter-Terrorist Financing Act (Wwft). Client assessments constitute an important element in the set of measures available to prevent money laundering and terrorist financing.

Furthermore, Glopaca BV and Glopaca International BV operate in a wide variety of countries and with various kinds of end users. The European Union, the USA as well as the United Nations have issued restrictive measures (“sanctions”) against certain countries, businesses and persons in order to achieve a change of policy in these countries.

In all our our international trade operations, we comply with import and export laws wherever we do business. We follow all regulatory requirements, including those regarding classification, documentation, shipping and record retention. As a Dutch company, and given the nature of our business activities, we do not only comply with European – and U.N. regulations, but also with U.S. regulations that prohibit exports to certain countries, businesses and people. We carefully ensure that we conform to all legal requirements forbidding cooperation with countries or businesses that are subject to boycotts. If applicable, all necessary provisions will be taken in order to comply with specific requirements for individual transactions.

For each transaction we will ascertain that:

1) The goods shipped are not classified as dual use products;
2) The final customer is not a denied party or in any way identified, either specifically or by reference, on any applicable Sanctions List or owned or controlled by a denied party;
3) For shipments subject to US Sanctions Laws (only if applicable):
a) the shipment does not contain any unlicensed or non-exempt United States-origin items or any other items that are subject to U.S. export controls (e.g., goods produced outside the United States containing by value at least 10% US content or technology or 25% where applicable);
(b) the shipper and receiver of the goods are located outside of the United States and its territories and have not and will not receive or remit any United States Dollar (USD) payments for the goods being shipped, whether directly from the recipient or consignee, or indirectly from any other person (unless specifically permitted by license or exemption); and
(c) the shipper of the goods will not make any payment in USD to any organization involved in the transaction

In order to comply with existing and new regulations as described above and to ascertain transparency of financial transactions, the management of our companies will on a regular basis carry out client assessments in order to monitor our customers and their (financial) transactions. The principle goal is to know who we are doing business with and for what use the goods that are shipped through our companies are being used. In order to ensure this, we screen all of our existing and (potentially) new customers on a yearly basis. We do so by using the OFAC Specialty Designated List (SDL) list as maintained by the US Department Of The Treasury (https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx) as well as the information published by the Dutch Ministry of Foreign Affairs, responsible for the implementation of EU sanction policy (https://www.rijksoverheid.nl/onderwerpen/internationale-sancties).

In any case are our customers required to make payments to our companies from banking accounts that operate in their name. Glopaca BV and Glopaca International BV will return any payment coming from third and unknown parties.


Code of Conduct Glopaca BV and Glopaca International BV

Purpose of this Code of Conduct is our effort to maintain and strengthen trust among all of our employees, suppliers, customers, business partners, government agencies and all other stakeholders.

This Code of Conduct is applicable of all actions, actively and passively, of all employees and management of Glopaca BV and Glopaca International BV.

Each employee of our companies receives this Code of Conduct and this is on a yearly basis discussed and reinforced with each member of staff during the evaluation of their functioning. It is the management’s responsibility to ascertain that all employees understand this Code of Conduct and adhere to it.

Each interested party is encouraged to report any (possible) violation of this Code of Conduct to the management of our companies.

All members of staff of Glopaca BV and Glopaca BV have to comply with laws and regulations of all countries in which they operate on behalf of our companies.

It is strictly forbidden for all members of staff and management to accept and money or gifts in order to obtain orders, in exchange for any service or for whatever other reason.

Employees of Glopaca BV and Glopaca International BV will not reveal any confidential information about our companies, its employees or other stakeholders to any third party.

AKANY TSIMOKA

Because of our travels abroad we realize all too well that many in our world do not enjoy the basic needs for a life that we would wish for our families and kids. Water, food, shelter and eduction are fundamental rights for everybody. In the regions where we work, in Africa as well as in the Caribbean, children especially are very vulnerable.

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