CORPORATE COMPLIANCE

Fracht FWO Inc. is committed to achieving excellence in all aspects of its business.  We recognize that understanding and meeting the needs of people—customers, employees, and members of our community—are the foundation of a successful business model.  These needs include ensuring our compliance with all applicable international, federal, state, and local laws and regulations.  We also maintain a closely-monitored QHSE program that meets ISO 9001:2015, BS OHSAS 18001:2007, and ISO 14001:2015 standards.

Upholding these standards and a respect for the rule of law not only helps facilitate smooth, timely transportation of your cargo, but also is the best way to avoid heavy civil and criminal penalties, such as heavy fines or in some cases jail time.

HOW TO COMPLY WITH LAWS AND REGULATIONS

Fracht FWO Inc.’s Compliance Team works diligently to ensure that all of Fracht’s employees are well-versed and fully trained in all programs that affect our business.  At Fracht, compliance with these programs is mandatory.

A small sampling of our compliance programs:

Anti-bribery

Code of Conduct

TSA Security Program

Export Compliance (CBP, BIS, and Census programs)

C-TPAT

ISO 9001:2015, ISO 14001:2015, BS OHSAS 18001:2007

Fracht FWO Inc.’s Compliance Team is always available to answer questions regarding compliance issues.

Customs-Trade Partnership Against Terrorism (C-TPAT)

Fracht FWO Inc. has been a C-TPAT member since 2009. C‐TPAT seeks to safeguard the world’s vibrant trade industry from terrorists and maintain the economic health of the U.S. and its neighbors. The partnership develops and adopts measures that add security but do not have a detrimental effect on trade.

By extending the United States’ zone of security to the point of origin, the customs‐trade

partnership allows for better risk assessment and targeting, freeing CBP to allocate inspectional

resources to more questionable shipments.

C‐TPAT members are considered low‐risk and are therefore less likely to be examined. The goal of these

arrangements is to link the various international industry partnership programs so that together

they create a unified and sustainable security network that can assist in securing and facilitating

global cargo trade. The partnership establishes clear supply chain security criteria for members that must meet in return provides incentives and benefits, such as expedited processing.

Anti-Bribery

The Owners of Fracht FWO Inc. (the Company) and its Executives expect that all of our officers, employees, and agents will always conduct Company business in accordance with the highest standards of ethical behavior and honesty.

The Company’s continued expansion of operations worldwide provides exciting new business opportunities while at the same time presents new challenges to our commitment to the highest ethical standards.

Among the most significant laws and regulations that govern the Company’s operations are those that prohibit the payment or receipt of money or things of value in order to receive a commercial benefit or personal advantage. Every country in which we operate  and those we expect to enter in the future have laws that make the corruption of its public officials a criminal offense. Such behavior, even without a specific law prohibiting it, is a clear violation of the Company’s code of business conduct and ethics.

This Anti-Bribery Policy was developed at the direction of the Company’s Board of Directors to provide clear guidance to all employees and to ensure a consistent approach to business practices throughout the Company’s operations.

Strict adherence to this Policy is absolutely necessary for the Company to sustain our first-class product and service culture. Violations of this Policy not only undermine the Company’s core values and business purpose and potentially subject the Company to penalties, but could also mean severe criminal penalties, including jail, and corrective action, including possible termination of employment from the Company for any individuals involved. Every Company officer, employee and agent is responsible for carefully reading and understanding this Policy and strictly complying with every aspect of its requirements.

Reporting Violations

Any transaction, no matter how small or seemingly insignificant, that might give rise to a violation of this Policy must be reported promptly by sending a detailed e-mail to compliance@fracht.com.

Your calls, detailed notes, and/or emails will be dealt with confidentially and only by those recipients who have a need to know for the sole purpose of carrying out the necessary investigations and follow-up.  As long as a report is made honestly and in good faith, you have the commitment of the Company that you will be protected from retaliation and that your rights will be enforced

Code of Conduct

Ethical behavior and fair business practices are key components for the success of the FRACHT GROUP. All employees of the FRACHT GROUP must deal fairly and honestly with customers, business partners, and competitors. Any manipulation, bribery, fraud, or misuse of confidential or proprietary information is prohibited.

The provisions of the law are paramount for our company. All employees and agents must observe and obey the laws and regulations in the context they act within. Breaches of the law must be avoided in all situations, especially the ones which are punishable with imprisonment or fines.

The reputation of the FRACHT GROUP is essentially characterized by the appearance, actions and behavior of each employee or agent. Inappropriate behavior can cause  significant and long-lasting damage to the company.  For the FRACHT GROUP, it is of great importance to ensure that the  recommendations and agreements of international organizations are followed and respected.

Reporting Violations

Any transaction, no matter how small or seemingly insignificant, that might give rise to a violation of this Policy must be reported promptly by sending a detailed e-mail to compliance@fracht.com.

Your calls, detailed notes, and/or emails will be dealt with confidentially and only by those recipients who have a need to know for the sole purpose of carrying out the necessary investigations and follow-up.  As long as a report is made honestly and in good faith, you have the commitment of the Company that you will be protected from retaliation and that your rights will be enforced.