ETHICS POLICY

Carlton Freight Limited believes that high standards of business ethics are critical in today's business world and therefore places high priority on compliance with all legislative and regulatory requirements, and on the maintenance of high ethical standards, within each of the territories and jurisdictions in which it conducts its business.

Carlton Freight Limited commits to conducting itself, and expects all employees to conduct themselves, in an honest, ethical manner in all dealings on its behalf and to behave professionally and with integrity and fairness at all times. The Company applies these same standards to all dealings with customers, suppliers, stakeholders, and public officials. These standards also apply to associates or intermediaries of any party involved in company business activities.

The Company's policy is that businesses should compete enthusiastically and fairly in the marketplace and must comply with the relevant competition laws of each country in which it operates. No employee may, either directly or indirectly, offer, solicit, pay or accept a bribe, or other such advantage that may be construed as such, in any form. Any approach from an external party soliciting a bribe or other advantage must be reported through management. Corporate hospitality may only be offered to or accepted from a third party if it is modest in value and in compliance with any applicable law. All Company employees must maintain the confidentiality of price sensitive and commercial information and not use such information for their personal gain.

The Company recognises that it is important that all employees feel confident that they may freely and confidentially voice genuine concerns relating to possible business malpractice or breaches in ethical behaviour to the appropriate management level. In such circumstances the Company will respect the confidential nature of any communication and ensure the protection of any individuals acting in good faith from harassment or victimisation.

The Directors of Carlton Freight Limited are ultimately responsible for this Policy. The Company's management are responsible for ensuring that the Policy is enacted through integration into the Company's normal management systems and for implementing and communicating this policy within their own departments.

Carlton Freight Limited will regularly review and adapt our activities where necessary to comply with applicable laws and regulations and be consistent with maintaining the Company's high standards of ethics.

This policy will be reviewed on a regular basis.

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