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Grupo SGL International

Code of Ethics and Conduct

Integrity that connects. Trust that moves business.

At Grupo SGL International we understand that moving goods between countries involves much more than coordinating transportation. We handle sensitive information, customs documentation, financial resources, and relationships with authorities, suppliers, agents, carriers, and clients throughout the international chain.

Our Code of Ethics establishes the minimum conduct principles applicable to the companies that make up our holding, their employees, executives, and, where applicable, business partners. It draws on international good practices in human rights, labor, environment, and anti-corruption promoted by the United Nations Global Compact, as well as bribery prevention, detection, and response principles from ISO 37001:2025.

Section 1

Our Commitment

At Grupo SGL we do business under five fundamental principles: Integrity · Legality · Transparency · Security · Responsibility.

"No business outcome, savings, client, shipment, negotiation, or internal instruction justifies acting outside the law or our principles."

We expect every person representing Grupo SGL to act correctly even when no one is supervising their actions.

Section 2

Compliance with the Law

All our operations must comply with the laws and regulations applicable in the countries where we operate, particularly those related to:

  • International trade and customs
  • Prevention of money laundering and terrorism financing
  • Anti-corruption and anti-bribery
  • Logistics chain security
  • Foreign trade and applicable sanctions
  • Tax legislation
  • Labor legislation
  • Information and data protection
  • Occupational safety
  • Environmental protection

When our internal policies establish controls stricter than the legal minimum, our employees must also comply with those controls.

Section 3

Zero Tolerance for Corruption and Bribery

Grupo SGL maintains a zero-tolerance policy toward bribery, corruption, and extortion.

No employee, executive, representative, or third party acting on our behalf may offer, promise, deliver, solicit, or accept money, gifts, commissions, favors, or undue benefits for the purpose of influencing a decision.

This particularly includes our relationships with customs, port, tax, police, municipal authorities and other public officials.

Bribery prevention through policies, due diligence, financial and non-financial controls, and reporting mechanisms is part of the practices promoted by ISO 37001.

"At SGL we do not buy decisions. We compete with service, capability, and results."

Section 4

Anti-Money Laundering

Grupo SGL will not allow its companies, bank accounts, logistics services, documents, facilities, or business relationships to be used to legitimize funds or assets derived from illicit activities.

We will apply reasonable client and counterparty knowledge, identification, documentation, and unusual-transaction assessment processes, in accordance with applicable legislation and internal policies.

We reserve the right to refuse or terminate business relationships when integrity risks exist that cannot be satisfactorily clarified.

Section 5

Logistics Chain Security

Cargo security is everyone's responsibility.

Grupo SGL maintains a zero-tolerance policy toward: drug trafficking, smuggling, cargo contamination, arms trafficking, human trafficking, document forgery, cargo theft, and any illicit use of the logistics chain.

Every employee must immediately report any anomaly related to containers, seals, vehicles, documentation, facilities, cargo, suppliers, or persons that could represent a risk.

"No business relationship will take priority over the security of our logistics chain."

Section 6

Integrity of Customs Information

Our employees must never deliberately alter information related to:

  • Value of the goods
  • Origin
  • Tariff classification
  • Description
  • Quantity
  • Weight
  • Consignee
  • Commercial documentation
  • Permits
  • Certificates
  • Invoicing
  • Any other data required by an authority

We will not knowingly participate in operations intended to evade taxes, restrictions, controls, or customs responsibilities.

Section 7

Conflicts of Interest

Every employee must act in the organization's legitimate interests and promptly disclose any personal, family, financial, or business situation that could interfere with the objectivity of their decisions.

No person shall use their position within Grupo SGL to obtain undue benefits for themselves, family members, friends, or third parties.

When a real or potential conflict exists, it must be disclosed before participating in the corresponding decision.

Section 8

Gifts, Hospitality and Benefits

Only reasonable, legitimate, and transparent business courtesies that cannot condition a decision may be accepted.

Gifts, payments, trips, commissions, or benefits intended to obtain an undue advantage are prohibited.

Special care must be taken in any interaction with public officials.

Section 9

Confidentiality and Information Protection

Information about clients, rates, routes, suppliers, shipments, financial statements, systems, access, business strategies, and internal documentation must be protected.

It is prohibited to sell, disclose, copy, or use confidential information for personal or third-party benefit.

Credentials and technological access are personal and must be protected against unauthorized use.

Section 10

Fair Competition

We compete aggressively on service and results, but always legitimately.

We do not accept practices intended to illegally manipulate markets, prices, or bids, nor the unlawful acquisition of competitors' confidential information.

We respect our competitors and expect our employees to act professionally toward them.

Section 11

Human Rights and Decent Work

Grupo SGL promotes a work environment based on dignity, respect, and equal opportunity.

We reject child labor, forced labor, human trafficking, harassment, violence, and discrimination. These principles align with the fundamental standards promoted by the United Nations Global Compact.

Employment decisions must be based on ability, performance, conduct, and legitimate job requirements.

Section 12

Health and Safety

We are all responsible for promoting safe work environments.

Our employees must comply with the protocols applicable to offices, warehouses, yards, vehicles, ports, airports, and other facilities where they carry out their activities.

"No business urgency justifies deliberately putting a person's life or safety at risk."

Section 13

Environmental Responsibility

We recognize the impact that transportation and logistics activity can have on the environment.

We promote operational efficiency, waste reduction, digitalization, responsible use of resources, and the progressive adoption of solutions that contribute to more sustainable supply chains.

Environmental responsibility is likewise one of the business pillars contemplated by the Global Compact principles.

Section 14

Suppliers and Business Partners

We expect our agents, carriers, suppliers, contractors, and other business partners to maintain standards compatible with our principles.

Grupo SGL may carry out due diligence processes proportional to risk, before and during a business relationship.

A relationship may be reviewed or terminated when there is serious evidence of corruption, fraud, money laundering, drug trafficking, smuggling, labor exploitation, serious security violations, or other activities incompatible with this Code.

Section 15

Responsible Use of Resources

The Group's goods, vehicles, equipment, systems, facilities, brands, funds, and other resources must be used exclusively for authorized purposes.

Theft, fraud, forgery, misappropriation, or deliberately abusive use of corporate resources constitutes a serious violation of our principles.

Section 16

Reporting and Duty to Report

Every employee has the responsibility to report in good faith any conduct they consider illegal, fraudulent, unsafe, or contrary to this Code.

Grupo SGL must provide confidential channels to report these situations.

"We will not tolerate retaliation against anyone who files a good-faith report, participates in an investigation, or raises a legitimate concern."

Reports must be investigated with objectivity, confidentiality, and respect for due process.

Section 17

Responsibility of Our Leaders

Managers, directors, and supervisors have an additional responsibility.

"It is not enough to demand integrity: they must demonstrate it."

No leader may order, suggest, tolerate, or cover up conduct that would be unacceptable if performed directly by them.

Business results will never justify non-compliance with this Code.

Section 18

Non-Compliance

Violations of the Code may result in disciplinary measures in accordance with internal policies and applicable law, including termination of the employment or business relationship when appropriate.

When there are indications of possible crimes or legal infractions, Grupo SGL may report the facts to the competent authorities as appropriate.

Our Final Commitment

At Grupo SGL we understand that our reputation is not built solely on the number of containers we move, the countries we connect, or the operations we carry out.

It is built by the way we do business.

Every document we issue. Every cargo we manage. Every client we represent. Every decision we make.

Our international expansion must always be accompanied by integrity, security, and responsibility.

GRUPO SGL INTERNATIONAL

9 companies. One culture. One standard of integrity.

We move business around the world. Our ethics are not negotiable.