Compliance

Responsible, systemized operations

GLS is a part of a group-wide program to identify and avoid compliance risks. In addition, GLS has adopted a group-wide policy to protect GLS and its employees while safeguarding the collaboration with business partners based on trust in the present and future.

The GLS Group focuses on three core areas:

• Competition Law
• Anti-corruption
• Sanctions list assessment

A cornerstone of the compliance system is a comprehensive training concept for employees – as compliance begins with them. The GLS Group's Compliance Team is the essential consulting and assessment authority for the three-stage policy. The compliance policy follows a uniform structure for the GLS Group.

Preventing Corruption

The GLS Group has a strict zero-tolerance policy towards bribery and corruption, which all the GLS Group managers see as their responsibility. Therefore, the GLS Group has created an anti-bribery guideline that defines the standards of behavior that apply to every employee and representative of the GLS Group.

Whistleblower Protection

We at GLS are committed to clear ethical principles. This is a pillar of our success as a business. All GLS staff bears responsibility for GLS living up to its prin-ciples; quite often, it is the misconduct of just a few that badly reflects on the reputation of a business as a whole. Hence, it is crucial for GLS to get notified of potential misconduct of its staff, its suppliers or third parties as early as pos-sible so that we can quickly act on it and efficiently remedy the situation.

There are various federal and state laws throughout the United State that are designed to protect individuals who report misconduct or illegal activities within organizations. GLS is committed to ensuring those who raise concerns covered under those laws have appropriate channels, adequate information, required data protection, and protection from retaliation. In furtherance of this commit-ment, GLS has established an internal reporting channel for the reporting of any work-related misconduct or wrongdoing, including unsafe, unethical, im-proper, or unlawful behavior. Through this internal reporting channel, whistle-blowers can inform GLS of potential work-related misconduct or wrongdoing. For example, whistleblowers may use the internal reporting channel to report the following:

•    bribery and corruption;

•    conflicts of interest; 

•    environmental, health, and safety violations; and

•    any other improper or unlawful behavior.

These reports will be treated with the utmost confidentiality to maximize the protection of whistleblowers and those mentioned in the report. GLS supports an environment where concerns can be raised without fear of retaliation with confidence that the concern will be addressed. Reports received by GLS will be handled professionally, treated confidentially, and investigated appropriately. GLS expressly prohibits retaliation against any individual who reports known or suspected work-related misconduct in good faith (which is reasonably believed to be true by the individual at the time reported).

The internal reporting channel is the Compliance Department.

Please contact the internal reporting channel via 1) EQS or 2) our ombudsman Dr. Rainer Buchert:

1)    EQS Integrity Line:

GLS - Home (integrityline.com)

2)    Dr. Rainer Buchert, Attorney-at-Law

Kaiserstraße 22

D-60311 Frankfurt am Main

Dr. Buchert can be reached as follows:

Tel.: +49 69 710 33 330 or +49 6105-921355

Fax: +49 69 710 34 444

E-Mail: kanzlei@dr-buchert.de

Please feel free to use the electronic contact form also:

Ombudspersons against corruption and commercial crime | Law Office of Buchert Jacob Partner (ombudsperson-frankfurt.de)

Do you have any questions in relation to the above? Please feel free to email us at compliance@gls-us.com

Code of Business Standards

The GLS Group's trust from customers, employees, business partners, and the public is a top priority.

To further strengthen this trust, the GLS Group has assigned itself a Code of Business Standards that establishes the company's fundamental values and standards of behavior in binding form for all employees.

The GLS Code of Business Standards forms the basis of all business decisions and regulates responsible interaction with all stakeholders.

Supplier Code of Conduct

The GLS Group expects its suppliers to respect the standards in this Supplier Code of Conduct, implement them using appropriate measures, and adhere to them in their business activities.

Sanctions (Updated regularly based on legal and regulatory requirements.)

The sending of goods or parcels is prohibited under all applicable sanctions laws. For example, because of the type of contents, the intended recipient or the country to or from which they are to be sent may be prohibited by sanction law. Sanctions laws include all laws, regulations, and orders imposing sanctions (including trade restrictions and economic sanctions) on countries, individuals, or entities, including those imposed by OFAC.

Learn more: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-informatio

Transparency Rule/Law

These links lead to the machine-readable files made available in response to the federal Transparency in Coverage Rule and include negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to enable researchers, regulators, and application developers to easily access and analyze data.

https://healthy.kaiserpermanente.org/front-door/machine-readable

https://healthcomp.sapphiremrfhub.com/