GOSSELIN GROUP N.V. CODE

OF

CONDUCT

Originally Adopted: May, 2003 Revision: November, 2012

Contents Page

I. Message From The Chief Executive Officer ................................ 1 II. Statement of the Gosselin Group NV Code of Conduct ............... 2 A. Why a Code of Conduct Is Necessary – The Goals ........... 2 B. Coverage of Code of Conduct ............................................ 3 C. Gosselin Mission Statement ............................................... 3 D. Standards of Conduct ......................................................... 4 E. Ethics and Compliance Organization .................................. 6 F. Auditing and Monitoring ...................................................... 6 G. Reporting Violations ............................................................ 7 H. Disciplinary Actions ............................................................. 8 III. The Standards of Conduct And Related Policies and Procedures ................................................................................... 9 A. Antitrust and Competition Laws – Standard SC-1 .............. 9 B. Antitrust and Competition Laws – Policy PP-1 ................... 12 C. Anti – Corruption Policy

Anti-Kickbacks and Anti-Inducement, Bribery and Gratuities – Standard SC-2 ................................................................ 17 D. Auditing, Monitoring, and External Reporting – Standard SC-3 .................................. 18 E. Conflicts of Interest – Standard SC-4……… 20 F. Ethics and Legal Compliance – Standard SC-5 ................. 21 G. Ethics and Legal Compliance – Policy PP-5 ....................... 22 H. Financial Books and Records – Standard SC-6 ................. 27 I. Gifts, Meals and Entertainment – Standard SC-7 ............... 28 J. Gifts, Meals and Entertainment – Policy PP-7 .................... 29 K. Quality – Standard SC-8 ..................................................... 31 L. Quality – Policy PP-8 .......................................................... 33

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I. MESSAGE FROM THE CHIEF EXECUTIVE OFFICER Gosselin Group N.V. has adopted a Code of Conduct which has been in place and binding on our officers and employees since May 2003. The Code of Conduct has been updated since 2003 based both on Gosselin´s own perceptions of the need to do so as well as due to various changes in the laws and regulations which apply to our business. The Code of Conduct restates and formalizes standards of conduct which Gosselin officers and employees are required to meet and have been required to meet from the inception of Gosselin. Gosselin believes that this formalized Code of Conduct is essential for the following reasons. Gosselin’s mission is to provide superior quality and timely moving and storage services on a worldwide basis at a reasonable price; to cooperate with all industry partners in order to obtain the complete satisfaction of the customer; and to achieve a competitive price for our customers and a competitive return for investors. In order to demonstrate our commitment to this mission, we adopted the ISO 9002 program, established by the International Organization for Standardization. In addition, as a member of FIDI, Gosselin is obligated to comply with the standards of the FIDI Accredited International Mover Standards which also require the adoption and on-going implemementation of a comprehensive Code of Conduct. To further demonstrate this commitment, Gosselin has adopted, continues to update, implements and carries out frequent audits of Code of Conduct compliance. The Code of Conduct includes this Message, a Statement of the Code of Conduct, Standards of Conduct, and Policies and Procedures.

The Code of Conduct applies to every person working in our organization, including all subsidiaries and affiliates of Gosselin Group N.V. Whenever the term “Gosselin” is used in this Code, this means all managers, directors, officers and employees of Gosselin Group N.V. and all of its subsidiaries and affiliates. The Code demands that our work be done with the highest quality and in full respect of the applicable laws and regulations and in full respect of our employees, customers, partners, service providers, and government authorities – both in Europe and in the United States-- that regulate the industry in which we participate. By striving for quality, and treating everyone in our community with respect, Gosselin has built long-lasting relationships with our community. The trust we have earned from everyone in our community contributes to the success, stability and welfare of our organization.

Over the years, Gosselin has earned and maintained the trust of United States government agencies, including the Department of Defense and the Department of State, and this relationship also has contributed to the success of Gosselin. On the basis of this earned trust, Gosselin has even been selected by the White House Staff to handle logistics during a Presidential Visit to NATO and Europe in 2005. Gosselin extends its mission of respect and quality service to every United States government employee whose household goods and automobiles will be moved by Gosselin. Gosselin conducts its business under the laws, regulations and customs of many countries around the world. Gosselin’s Code of Conduct is designed to guide our conduct to meet the strictest of these laws, regulations and customs. More recently, Gosselin has been certified as an Authorised Economic Operator (AEO) by the

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European Commission authorities, and in turn is recognized by the United States as a “trusted trader” in the US supply chain security program, C-TPAT. These ceritifations are regarded by the Gosselin Management as earned privileges directly related to our on-going implementation and audit of full compliance with our Code of Conduct. We expect everyone to use the Gosselin Code of Conduct to guide our conduct in all aspects of our business in every part of the world.

Our Code of Conduct applies fully to Gosselin Group N.V. and to all of its subsidiaries and affiliates.

II. STATEMENT OF THE GOSSELIN CODE OF CONDUCT

A. Why a Code of Conduct is Necessary – The Goals

The Gosselin Code of Conduct includes the Message from the Chief Executive Officer, the Statement of the Code, the Standards of Conduct, and the Policies and Procedures. 1. The goals of the Gosselin Code of Conduct are:

a. To ensure compliance of our business practices with applicable domestic, European and United States laws and regulations;

b. To maintain ethical standards and integrity and respect for

employees, customers, suppliers and authorities;

c. To demonstrate our integrity, ethics, professionalism and responsibility, and our mission of quality and timely service, in all of our business activities with all of our customers, particularly our business activities with governments and international organizations;

d. To establish a corporate-wide system to timely educate and update

employees about lawful and ethical business practices; e. To reinforce a corporate and individual commitment to provide high

quality and timely moving and storage services;

2. We must strive to ensure that we, all of us, fully understand our Code of Conduct. For this reason the Code is both posted on the Gosselin Intranet site, and each employee is given not only training in the Code but also compliance is audited regularly as part of both the ISO-Standards audits and under the FIDI-FAIM Standards Program. Everyone must be committed to these goals. Only in this way will it continue to be clear to our business partners and customers that lawful operations and quality service is our top priority.

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B. Coverage of the Code of Conduct Our Code of Conduct applies fully to Gosselin Group N.V. and to all of its

subsidiaries and affiliates.

C. Gosselin Mission Statement

1. Highest standards for packing, shipping, storing, service, information and safety, and fair prices are the bases for a durable relationship with our customers. Gosselin employees have an obligation as individuals and as members of the Gosselin team to follow the law and Gosselin’s Code of Conduct. The following core values are the driving force of our mission and are expected of every employee.

a. RECOGNIZE that we are all responsible for the quality and

timeliness of our services and our agency network.

b. ACT as a member of a team and UNDERSTAND that a single weak link in the chain undermines work done by everyone else.

c. REALIZE that the quality of our services is based on the quality of

work of each individual whatever the function. d. EMPHASIZE our individual commitment to teamwork, solidarity,

and communication. e. WORK CLOSELY with Gosselin’s clients, suppliers,

subcontractors, and service agents to achieve total quality. f. DESCRIBE accurately all the services offered under each client’s

contract. g. PERSONALIZE the coordination and timely follow-up of

consignments. h. KNOW that ORGANIZATION affects quality. Everyone must be

organized. i. DEAL with the cause of problems; avoid discussions and battling

over the effects of problems. j. BE PROUD of and committed to preserving our proficiency in our

various activities, of our sense of initiative, our responsiveness, our eye for detail, our will to perfection, our dedication, and our thoroughness.

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k. IMPROVE your know-how every day and SHARE it. l. GET IT RIGHT the first time, at the right time, every moment.

2. Every employee is responsible for the Gosselin’s quality performance.

Every employee strengthens this performance by demonstrating a positive attitude and by providing a commitment to service.

3. The Gosselin management and employees will conduct themselves in an

ethical way and in accordance with our core values. Ethics will lead the way where there are no laws, or where the laws are unclear. Ethics is a corporate asset since it will lead to integrity that will help us in developing a responsible behavior while being aware of moral principles. Ethics will deepen the trust the employees and others have in Gosselin.

4. The participation in Gosselin’s ethics and compliance program will be part

of the evaluation process of every employee. 5. To provide maximum assurance that we meet the standards of the Code

of Conduct, all management personnel and employees will be provided regular staff-awareness training on the ethical business conduct requirements in the Code. This will keep Gosselin personnel up to date on any Code changes and will in provide periodic reminders of our ethical obligations in all of our business dealings on behalf of Gosselin. The staff-awareness training will be subject to regular internal and external audits. In addition, the updated version of Code is always posted on the Gosselin intranet website and is available for every person at Gosselin to consult at any time. Management will post in employee gathering places at Gosselin company installations notices encouraging Code-awareness and reporting of suspected violations to either supervisors or confidentially to Frans van Hoof (phone +32 475 25 05 65).

D. Standards of Conduct

Gosselin’s Standards of Conduct guide the decisions and actions of Gosselin and its employees. All Directors, officers, employees and independent contractors must accept the individual responsibility and duty to conduct Gosselin’s business in an ethical manner in full compliance with applicable laws. Because Gosselin conducts business around the world, our Standards of Conduct meet the highest and most complete set of ethical and legal standards and customs for all of the countries in which Gosselin does business. Certain Standards of Conduct also have an associated Policy and Procedure which establishes detailed guidance regarding how to comply with the relevant Standard of Conduct. Gosselin’s Standards of Conduct cover the following topics:

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1. Antitrust and Competition Laws

2. Anti-Corruption a) Anti-Kickbacks and Anti-Inducement, b) Bribery c) Gratuities

3. Auditing, Monitoring, and External Reporting

4. Conflicts of Interest 5. Ethics and Legal Compliance

This Standard of Conduct generally advises Gosselin’s employees that all of Gosselin’s operations must be conducted in accordance with the highest ethical and moral standards and in compliance with all laws wherever Gosselin does business. The Policy and Procedures associated with the Standard of Conduct for Ethics and Legal Compliance covers areas of law that are not specifically addressed in other Standards of Conduct or Policies and Procedures. These areas include: a. Employment – Health and Safety Matters b. Welfare at Work c. U.S. Federal Acquisition Regulations d. U.S. Federal Maritime Commission Regulations

6. Financial Books and Records 7. Gifts, Meals and Entertainment 8. Surface Deplyment and Distribution Command (SDDC) Regulations 9. Quality 10. Ratemaking

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E. Ethics and Compliance Organization Senior management will ensure that Gosselin, its Directors, officers, employees, and independent contractors will comply with the Code of Conduct, applicable domestic and foreign laws, and Gosselin’s high standards of business ethics.

1. Ethics and Compliance Committee

Gosselin’s Board of Directors (the “Board”) has constituted a Gosselin Ethics and Compliance Committee (the “Committee”) whose members are: Stephan Geurts, Sr, Chairperson Frans Van Hoof, Independent Ondernemingsraad Cees Corstjens The Ethics and Compliance Coordinator A representative of Walkiers &Co., independent certified public

accountants External legal counsel (Reed L. von Maur) will provide advice to any

member of the Committee concerning any matter brought to the Committee for review or decision.

2. Ethics and Compliance Coordinator

The Board has appointed an Ethics and Compliance Coordinator (the “Coordinator”). The Coordinator is Nathalie Luyckx. The Coordinator has the responsibility of the ongoing operation of the Code of Conduct, coordination of training for Code understanding, and shall make periodic written reports, no less than semi-annually, to the Committee concerning any perceived deficiency regarding the implementation of the Code requirements by management or employees.

F. Auditing and Monitoring

1. Management and all departments will be semi-annually audited. This audit will be conducted by the Coordinator. The audit will be followed by a report to the Committee. This report will contain a description of the object of the audit, and the compliance with the Code of Conduct. Any anomalies will be reported and improvements advised by the Coordinator.

2. In addition, periodic audits will be conducted by independent audit organization (Lloyds Register Quality Assurance, the official independent auditor of the ISO Standards organization, and Ernst & Young, the official independent auditor of the FIDI-FAIM Standards organization.) The independent audit shall be followed by a report to the Committee of any Code violations.

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3. The Committee will, after consultation with Gosselin legal counsel, decide on the improvements advised, or impose other improvements or actions, based upon the external and internal audits.

4. All decisions of the Committee are valid when taken with a normal majority

(i.e., 50% of the Committee members present plus one vote). 5. The Committee shall make periodic reports to the Board, no less than

semi-annually, summarizing major developments and major ethics and compliance issues.

G. Reporting Violations

1. Any employee who reasonably suspects violations of this Code of Conduct or any law shall immediately inform the Coordinator. All questions pertaining to the Code of Conduct may be submitted to the Coordinator. Alternatively, each employee is entitled to submit any information concerning suspected Code of Conduct violations anonymously and confidentially to Frans van Hoof and for this purpose are encourage to use the following “hotline” telephone number:_+32 475 25 05 65. These reports shall be maintained in strictest confidence and the employee making the reports shall not be subject to any retribution whatever. It is an affirmative part of Gosselin´s business ethics policy to encourage employees to report any suspected violation of this Code. Only by assuring that Gosselin conducts its business in accord with the business ethics principles set out in this Code can Gosselin maintain the confidence of its customers, the quality of its operations and the long-term commerciality of its operations. Gosselin will display in places where employees gather a notice clearly requesting the reporting of suspected violations of this Code, identifying the “hotline” number where such reports can be made anonymously and confidentially.

2. The Coordinator will immediately inquire into the matter reported or

suspected. If there is clearly no violation the Coordinator will inform immediately the employee who reported the matter or, if the report was anonymous, the Coordinator will report the results of the inquiry to the recipient of the anonymous report. . The Coordinator will prepare a written report and file a copy with the Committee and in addition with outside legal counsel.

3. If there is a violation the Coordinator will immediately inform the

employee’s supervisor, the Committee and Gosselin outside legal counsel and advise the steps to immediately end the violation and to take appropriate corrective action. The Coordinator will prepare a report and file a copy with the Committee and to outside legal counsel

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4. If the answer to the question is unclear, the Coordinator will draft a report, advising how the problem can be solved, and will submit the matter to the Committee. After discussing the problem, and receiving legal advice, the Committee will come to a decision and issue a report.

5. In order to encourage people to report reasonably suspected violations,

the Coordinator will not be authorized to reveal their name when they express the desire to be anonymous. Employees who put forward allegations against a colleague which are known to be false may not be protected by anonymity and may be subject to disciplinary action.

H. Disciplinary Actions

Gosselin will enforce its policies and legal compliance standards on a consistent basis; strict disciplinary action will be taken for violations, as appropriate. In response to a violation of the Code of Conduct, applicable domestic or foreign law, or Gosselin’s high standards of ethics, Gosselin will take disciplinary action, which may range from a verbal or written warning to termination of employment and referral of the matter to local criminal prosecution authorities, or other appropriate disciplinary action, regardless of level of responsibility within the organization. The severity of the disciplinary action, which will be determined by members of senior management (in consultation with the Coordinator, Committee, legal counsel and the employee’s supervisor, as may be appropriate), will be based on consideration of the facts and circumstances and other appropriate factors. Where appropriate, Gosselin may also take disciplinary action against supervisors who fail to detect or report misconduct on the part of employees or independent contractors under their supervision.

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III. STANDARDS OF CONDUCT AND RELATED POLICIES AND PROCEDURES

Standard of Conduct SC-1 Antitrust and Competition Laws

The United States and many other countries have enacted what are known variously as antitrust, monopoly, competition or cartel laws. The basic objective of these laws is to preserve free and open competition in the market place – an objective that Gosselin strongly supports. Simply stated, Gosselin is dedicated to compliance with the antitrust laws in all of its activities. All management and employees at every level of Gosselin Group, wherever located, must conduct their operations in strict compliance with all antitrust and competition laws that are applicable to such operations. Gosselin will not condone any conduct that could give rise to antitrust violations. Purpose While there are both case law and statutory exceptions to the basic ground rules regarding compliance with antitrust and competition laws, this standard of conduct and the accompanying policy and procedures provide a basic orientation regarding antitrust and competition risks. The purpose of the standard of conduct and policy and procedures is to familiarize Gosselin’s personnel with the general nature and overall sweep of the antitrust laws and to make sure the company’s policy of full compliance is understood and implemented at all levels. The standards and guidelines are not intended to provide employees with the means to act as their own legal counsel, but to help them recognize situations and potential problem areas which might have antitrust implications, and to require them to seek assistance from Gosselin external legal counsel, Mr. Reed von Maur (e-mail: vonmaur99@aol.com or cell +49 171 7097 628, if they have questions. Guidelines Antitrust laws vary in many respects from one country to another, but they have certain common principles. For example, under most antitrust and competition laws, it is illegal for two competing companies to agree to charge the same price for their products or services, to demand the same price from their suppliers, to limit production, to divide up or allocate customers or markets, or to boycott selected customers, competitors or suppliers. Even when there is no formal written agreement, the appearance of an informal understanding on such matters could be a problem. Therefore, it is important that Gosselin employees avoid discussing even the possibility of such anticompetitive

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arrangements with a competitor and that they immediately advise Gosselin legal counsel if a competitor tries to engage them in such discussions. For the same reason, except as authorized in advance, Gosselin employees may not discuss with competitors non-public information regarding prices that Gosselin will pay for services we buy, the prices Gosselin plans to charge for services we sell, or competitively sensitive subjects such as profit margins and marketing strategies. Below are brief statements of the principles set forth in the European and U.S. antitrust laws. Antitrust and competition are complex matters, and everyone must know that violations of these laws can have very severe consequences. If you have any questions regarding these issues please review our Antitrust and Competition Law Policy and Procedures and seek guidance from Gosselin legal counsel. European Antitrust Legislation In general the European treaty and Belgian, German and Dutch legislation on antitrust and competition prohibit any agreement between businesses, decisions by associations of businesses or any concerted practices which may affect trade and which have as their objective or effect the prevention, restriction or distortion of competition and, in particular, those which:

• directly or indirectly fix purchase prices or other conditions; • limit or control production, markets, technical development or investment; • share markets or sources of supply; • apply dissimilar conditions to equivalent transactions with other trading parties,

thereby placing them at competitive disadvantage Also, market dominance that limits or restricts fair and free competition in a similar way as described above is prohibited and may be penalized. Market dominance is regarded as the position of a market competitor or competitors that enables it/them to act independently from competition. Abuse of such a position is prohibited and may be penalized. Examples of abuse of a dominant position are charging different prices or imposing different trading terms without an objective commercial reason. United States Antitrust Laws Employees must be aware that even if a particular type of conduct is not specifically prohibited by the laws of a country where Gosselin operates, there are some situations where the U.S. antitrust laws could still apply – such as agreements in another country that have an anticompetitive effect on U.S. commerce. Also, because we may have contracts with the U.S. government, or operate as a subcontractor for companies which have direct contracts with the U.S. Government, a respected and important client, we must comply with the U.S. antitrust laws in connection with contracts involving the U.S. government. These laws and regulations apply to non-U.S. companies and individuals that trade with the U.S.

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U.S. law also has distinct exemptions from the antitrust laws, often called immunities. These include an exemption for any agreement or activity concerning the foreign inland segment of through transportation that is part of transportation provided in a United States import or export trade. This and other exemptions and immunities to the antitrust laws are just as intricate and complicated as the law, itself. Indeed, the Courts have disagreed with the Department of Justice over the applicability of these exemptions. We are outlining the general rules without any reference to exemptions and immunities, applying the most conservative approach. Never assume, without inquiry, that an exemption applies. If you have questions whether an activity or an agreement is exempt from the U.S. antitrust laws, please seek guidance from Gosselin legal counsel. Key provisions of the four principal U.S. federal antitrust laws are: Sherman Act. Section 1 of the Sherman Act prohibits contracts, combinations or conspiracies which unreasonably restrain trade or commerce. U.S. courts have decided that agreements between competitors which fix prices, lead to production capacity curtailments, allocate territories or customers or boycott third parties are per se or automatically unreasonable restraints of trade and violate this section. Section 2 of the Sherman Act makes it illegal for any firm to monopolize, attempt to monopolize, or to join or conspire with others to monopolize, any part of trade or commerce. It is not illegal to acquire monopoly power through superior products, services or skills or even through luck. What is prohibited is acquiring or attempting to acquire or maintain monopoly power through unfair tactics. Clayton Act. This Act prohibits (1) exclusive dealing arrangements where the seller conditions the sale or lease of goods upon the buyer’s refusal to deal in the goods of a competing seller and (2) tying arrangements in which the seller conditions the sale or lease of a desired product to the sale or lease of a separate product. Robinson-Patman Act. A seller cannot, under certain circumstances, discriminate in the price of a product between two competing customers or favor one competing customer over another in the granting of promotional services, facilities or allowances.

Federal Trade Commission Act. The FTC Act prohibits unfair methods of competition and unfair or deceptive acts or practices.

Both European and U.S. laws make a distinction between the so-called per se violations, and those analyzed under the rule of reason. Per se violations are always prohibited and may be punished; agreements subject to the rule of reason are those agreements that can limit competition but that can also have positive effects and provide a benefit to consumers. Whether dealing with per se or rule of reason activities, all employees should seek guidance according to the proper procedures in case of

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questions or uncertainties. U.S., European and domestic laws have severe penalties for violations, namely criminal sanctions, including imprisonment for individuals, fines, actions by private parties (who can recover treble damages under U.S. law) and injunctions. Policy and Procedures PP-1

Antitrust and Competition Laws

I. STATEMENT OF THE POLICY The United States and many other countries have enacted what are known variously as antitrust, monopoly, competition or cartel laws. The basic objective of these laws is to preserve free and open competition in the market place – an objective that Gosselin strongly supports. Simply stated, Gosselin is dedicated to compliance with the antitrust laws in all of its activities. All employees at every level of Gosselin Group, wherever located, must conduct their operations in strict compliance with all antitrust and competition laws that are applicable to such operations. Gosselin will not condone any conduct that could give rise to antitrust violations. II. DISCUSSION It is the policy of Gosselin to comply in all respects with antitrust laws and the public policies they represent. The United States antitrust laws, both state and federal, were enacted to promote healthy competition. The countries in the European Economic Community and many other foreign countries also have adopted affirmative antitrust laws which coincide with United States law in some respects and in other instances exceed those laws in regulatory effect or in severity of penalty. Responsible business people readily recognize the significant contributions those laws have made both to our economic freedom and to healthy relationships with our customers, suppliers and competitors. Gosselin strongly endorses a policy of antitrust compliance in operations of Gosselin and its subsidiaries wherever located. Directors, managers, and employees of Gosselin Group are expected to conduct their operations in a manner consistent with this policy and consistent with all applicable laws of any country pertaining to commercial competition. The United States antitrust laws apply to business activities that affect commerce within the United States or which have an impact on United States import commerce or the export business of a United States person or entity. The types of business activities to which Belgium and the various U.S. and foreign antitrust laws apply, and the effect of those laws, vary from country to country and advice of Gosselin legal counsel, Mr. Reed von Maur, should be obtained

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to assure that operations in those countries comply with all applicable legal requirements and Gosselin policy. It is widely understood that agreements with competitors to fix prices, to allocate markets or customers, to refuse to deal or to exclude competitors are generally forbidden by the antitrust laws in most countries. However, these are but a few of the acts prohibited by those laws. Gosselin’s policy of compliance with the antitrust laws places on each employee, officer or director the responsibility to understand them in order to avoid violations and to seek an explanation of them from Gosselin legal counsel if there is any uncertainty whatsoever as to the propriety of any act or transaction. The following policies and procedures are not intended to be a definitive statement of the antitrust laws. As stated, those laws are complex and are subject to court interpretation which can vary over time and from one court to another. To every rule there are exceptions and, in certain cases, these policies and procedures are stricter than those imposed by the antitrust and competition laws of Belgium, United States and various other countries. The principal purpose of the following is not to turn Gosselin management and employees into experts on antitrust and competition laws but to make you aware of some of the areas in which antitrust problems exist so that you will know what questions to ask Gosselin counsel, and when, and will be able to handle potentially dangerous situations before you have had a chance to consult with our counsel. III. GUIDELINES AND DOCUMENTATION A. Relations with Competitors It is possible that you may enter into contact with a competitor, which may also be a client or supplier in another area. This contact is acceptable as long as you do not exchange pricing information, customer lists, cost information, sales territories or other market information, output restrictions or other items that could affect competition. If you are uncertain, contact Gosselin legal counsel. If you receive any information of that nature from a source other than a competitor, be sure that the source can be identified in order to explain how and for what purpose the information was received. Trade associations perform useful and legitimate functions. However, because they provide the opportunity for representatives of competitors to meet or work together in cooperative efforts, they are susceptible to misinterpretations. Therefore, membership in any trade association should not be undertaken unless Gosselin legal counsel has advised that its purposes and practices are proper and lawful. Furthermore, no Gosselin employee is authorized to participate in any meetings with representatives of competitors, whether held by a trade association, professional society, management association, government advisory committee or otherwise, in which discussions range into improper areas. Any Gosselin representative finding themselves in such a situation must immediately disassociate themselves from the discussion and leave the meeting.

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While it is impossible to make a comprehensive list of “Do’s” and Don’ts,” the following considerations will serve as a guide to activities which should never be engaged in. This list does not include any reference to the applicable exemptions under the antitrust laws and is not a substitute for developing an understanding of the principles set forth in our standard of conduct and policy and procedures and for contacting Gosselin legal counsel with concerns and questions.

• Avoid even the appearance of collusion with competitors. • Don’t enter any agreement, understanding or even discuss with a

competitor any of the following (unless such discussion is necessary to a bona fide supplier/customer relationship between the Company and a competitor):

Prices, rates, discounts or other trading conditions Bids, contents of bids or intention to bid Profits, profit margins or costs Market shares or geographic market information Allocation of sales territories, customers or products

Selection or termination of distributors

• Don’t obtain information about competitors (especially about rates or prices) directly from them. Obtaining information about competitors from customers (as long as those customers are not also your competitors) and from published/public data is permissible.

• Do document the source of information obtained about competitors. For example, put the source of a competitor’s price list and the date it was obtained on the copy itself.

• Don’t provide Gosselin’s rates or rate sheets or other competitive information to a competitor.

• Do make all pricing/rate decisions independently of competitors, in light of company costs, market conditions and competitive rates.

• Don’t attend meetings with competitors (including trade association meetings or social gatherings, however informal) at which prices, rates, or any of the foregoing subjects are discussed. If any of these matters are raised, state that you will have to leave if discussions continue. Leave if they do continue and report the matter to Gosselin legal counsel as soon as possible.

• Do confine the discussion at trade association meetings to topics directly involved in the purpose of the meeting and which are on the meeting agenda. If you have a question about the agenda, consult with Gosselin legal counsel before attending the meeting.

• Do seek guidance from Gosselin legal counsel if you think an activity or an agreement may be exempt from the antitrust laws. Never assume application of an exemption.

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B. Relations with Customers Unlike arrangements with competitors, most “vertical” arrangements between Gosselin and its customers or service providers will be legal unless some anticompetitive effect can be demonstrated. Such arrangements are also far more likely to be embodied in specific contracts, rather than inferred from discussions, so there is less risk that ambiguous conduct will be misunderstood. However, there are several kinds of arrangements between Gosselin and its customers which should be avoided. For example, an agreement between Gosselin and a customer that Gosselin will cease doing business with a competitor of the customer’s would pose significant antitrust risk. The following arrangements may cause problems and violate the antitrust laws: resale price maintenance or vertical price fixing, refusals to deal, exclusive dealing, territorial and customer restrictions, tying arrangements (conditioning the purchase of one product or service on the purchase of another product or service), reciprocal dealing when caused by coercion and price discrimination. The following summarizes the area of relations between Gosselin and its customers; Gosselin employees should consult Gosselin legal counsel with any concerns or questions:

• Do treat customers consistently and make sure that Gosselin’s contractual

requirements are enforced in an even-handed, non-discriminatory way. • Don’t terminate or threaten to terminate a customer for any reason other than

good faith enforcement of Gosselin’s contractual rights. Customer terminations frequently result in litigation based on antitrust claims. It is imperative that each employee be guided by legal counsel as he or she proceeds.

• Don’t (without prior consultation with Gosselin legal counsel) enter into any agreement or other understanding, no matter how informal, or in any way coerce any of your customers so as to:

Prohibit them from using the services of a competitor Require them to purchase one product or service as a condition of supplying them with another product or service Require them to deal exclusively with Gosselin Enter into reciprocal sales or purchase arrangements (i.e., condition the purchase of their products or services on their purchase of our products or services)

• Don’t discuss with a customer the following topics: Selection, rejection, or termination of other customers or classes of customers Restrictions on Gosselin’s freedom to determine what products and services to sell to whom and at what rates

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C. Procedure to Follow in Case of Suspected Violation or Questions If you have a reasonable belief that a certain practice or agreement may violate the European or U.S. antitrust and competition laws, do not perform any further action in relation to the practice or agreement, immediately cease the practice or try to prevent it from happening and notify Gosselin legal counsel as soon as possible (R.L.von Maur, e-mail: vonmaur99@aol.com --mobile phone number: .+49 171 7097 628) As these issues are especially complex, it is understandable that you will have questions, or that you will be uncertain about what is permissible behavior. If you have questions or concerns, you will immediately advise your supervisor. He will present the matter to legal counsel. Any formal or informal agreements on which there are any questions regarding competition should have prior approval by legal counsel. Legal counsel will prepare a written summary of the question and of its analysis and opinion; as required by the given situation, Gosselin external legal counsel will consult in this connection with local area competition law specialists. The opinion will be converted into practical directions to the employee and his supervisor and given to both. Legal counsel can then acknowledge whether there is an antitrust violation. In the case of a violation, the practice in question will immediately cease. If the answer to the question is not clear, there will be further inquiry by legal counsel and, if needed, specialized help will be sought. During the inquiry, the practice will be suspended. Legal counsel will advise the Ethics and Compliance Committee and the department in question whether the practice can be continued or whether it must be terminated. If legal counsel advises that the indicated practice must be terminated, Gosselin will cause the practice to terminate immediately.

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Standard of Conduct SC-2 Anti-corruption Policy:

Anti-Kickbacks and Anti-Inducement, Bribery and Gratuities

Gosselin, its directors, employees, agents, and independent contractors must not:

a) offer, pay, solicit or receive any money, fee, commission, compensation or thing of value for the purpose of inducing the referral of business, or for the purpose of improperly obtaining or giving favorable treatment, in connection with any government or non-government contract;

b) corruptly offer or pay, directly or indirectly, to a government

employee anything of value with the intent to influence any commercial or government decision or conduct, or to influence a government employee or employee of any other commercial enterprise to aid in the commission or collusion, or to permit the commission of any fraud on a commercial or governmental agency; or

c) offer or pay, directly or indirectly, to a government official anything

of value for or because of any government decision or conduct performed or to be performed in connection with any government contract.

This Standard of Conduct prohibits kickbacks and other related improper commercial inducements (paragraph a.), bribery (paragraph b.), and gratuities (paragraph c.). Kickbacks, bribery and gratuities are distinct but related, and very serious criminal offenses, which provide criminal and civil fines and penalties for individuals and entities, and imprisonment for individuals. The prohibition clearly stated in this Standard applies to Gosselin´s dealings with both governmental and non-governmental organizations or their representatives. Many countries, including the United States, Belgium, Germany, the Netherlands, have adopted the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Also, the United States Anti-Kickback Statute requires prompt reporting to the United States government of suspected kickbacks in connection with certain government contracts. This Standard is related to the Gifts Standard and its Policy and Procedure, and in certain situations, both will need to be considered.

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Standard of Conduct SC-3 Gosselin Internal Controls for Code Awareness and Compliance

Auditing, Monitoring, and External Reporting Gosselin will conduct regular financial audits, including audits of rate determinations and of billings, to prevent duplicate billing, ensure the services are authorized and the charges are in conformity with rates, tariffs, quotations, agreements or tenders of service. In addition, regular audits will be conducted by both Gosselin´s Code of Ethics Compliance staff and by external auditors to monitor, report on and to assure staff awareness and compliance with the provisions of the Code throughout the Gosselin organization. A. Auditing. o ensure compliance with Gosselin’s Code of Conduct, applicable laws and regulations, and Gosselin’s high standards of business ethics, Gosselin will continue to conduct or cause to be conducted regular, periodic compliance audits by internal and external auditors and compliance staff who have expertise in the international moving industry. The purpose of these audits will be to assure that all who work within the Gosselin group of companies are regularly made aware of the business ethics principles to which Gosselin is committed as set out in this Code. In addition to providing awareness-training, Gosselin’s auditors and compliance staff are responsible for promptly reporting suspected violations of Gosselin’s Code of Conduct, applicable laws and regulations. In addition, as stated elsewhere in this Code, employees of Gosselin should report any such suspected violations either to the Ethics and Compliance Coordinator, to Gosselin´s external legal counsel or anonymously to Frans van Hoof See §G.1, p.8 of the Code for contact-reporting information. . Civil, administrative, or criminal law enforcement authorities will also have to be notified if there are violations of the law. Periodic internal reviews will be conducted by the Ethics and Compliance Coordinator in connection with regular audits carried out under the ISO-Program. These periodic internal reviews will assure that Code awareness at the employee-level of each subsidiary and affiliate of Gosselin is active and on-going. In this connection, it is noted that each new employee of Gosselin will be provided upon entry an explanation of the Code by the Ethics and Compliance Coordinator, and will in addition receive a copy of the Code. Further, the Coordinator will assure that the Code, as updated, is regularly made available to all employees on a current basis by have the updated version of the Code posted and available on the Gosselin intranet site. Periodic internal audits will assure through interview and other means that employees remain aware of the Code obligations and the availability of the Code via the Gosselin Intranet site. The audits will also assure that employees of Gosselin are kept aware that assistance in regard to understanding the Code requirements (including reporting of suspected violations) is available through the Coordinator. Each subsidiary of Gosselin will be audited individually each year for Code awareness and compliance; these audits are on-going throughout the year, in order that all subsidiaries are fully audited in compliance with the ISO demands.

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In addition to internal audits, Code awareness and compliance will also be subject to regular external audits. These audits will be conducted by the following organizations:

1. ISO External Auditor- Lloyds Shipping Registry, which is the independent auditing organization engaged by the ISO-Administration headquarters to audit Gosselin for compliance with all ISO standards. The Code of Conduct is specifically listed as one of the standards for which Gosselin is obligated to be periodically audited in order to maintain Gosselin´s certification of ISO-compliance. ISO certification is essential to Gosselin´s on-going business, and regards the ISO external audit function as essential. All employees are required to cooperate fully with the ISO certification external audit representatives.

2. FIDI-FAIM External Auditor – Ernst & Young is charged with periodic external audits of Gosselin in order for Gosselin to maintain its FIDI Certification position. Gosselin regards this certification as essential to the conduct of its business operations, and all employees of the Group are obligated to cooperate fully with Ernst & Young auditing team members. This audit is conducted every 2 years and regarding the Code will include an audit of staff awareness of the Code as well as Code compliance throughout the period of the audit.

Both the internal and external audits will be conducted periodically in order to track and document compliance with the Code principles and obligations, but also to assess the effectiveness of the business ethics awareness requirements of the Code and Gosselin´s internal control systems for reporting of Code compliance issues. The audit-process will include, among other things, interviews with employees (randomly selected), with management, with the Ethics and Compliance Coordinator and (where reports of suspected non-compliance have been made in the audited period) with Gosselin´s external legal counsel. Further, the auditing will review the internal reporting mechanisms provided in this Code for the reporting, anonymously or otherwise, of any suspected Code violation. 2. Reporting. Gosselin will report any suspected violations of this Code which indicate criminal activity to the responsible criminal authorities. Gosselin´s external legal counsel will be immediately informed of the suspected criminal activity and will advise Gosselin with respect to proper and complete reporting to appropriate criminal authorities. Gosselin will cooperate fully with any investigative authorities with respect to such reporting. In the event the US Federal Acquisitions apply to any transaction in regard to which suspected Code violations involving fraud, conflict of interest, bribery, or gratuity violations either under Title 18 of the US Code or a violation of the False Claims Act (31 USC §§ 3729 – 3733) have taken place, Gosselin will report such suspected violations

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immediately in writing to the Office of the Inspector General responsible for the procurement contract affected by the suspected violation or to the responsible contracting officer as US federal regulations may require. Gosselin will fully cooperate with any US government agency in connection with audits, investigations or corrective actions indicated by such suspected violations.

Standard of Conduct SC-4 Conflicts of Interest

Employee personal interests may not interfere with the Gosselin´s interests and full disclosure of potential conflicts must be made. Gosselin expects all employees to maintain loyalty to Gosselin. Conflicts of interest may arise when an employee’s position or responsibility presents an opportunity for personal gain apart from the normal compensation provided through employment. In addition, a conflict of interest may arise when an employee’s outside relationships might be adverse to the interests of Gosselin, produce conflicting loyalties, or interfere with effective job performance. If you find yourself in a situation where you believe a conflict of interest or the appearance of a conflict of interest exists, you are required to report this conflict to the Chief Ethics and Compliance Coordinator or legal counsel, Mr. Reed von Maur using the contact information give above at §G.1, p. 8 of this Code. Alternatively, employees may report such information anonymously to Frans van Hoof . Gosselin and its external legal counsel will immediately consult on any such report, and legal counsel shall advise Gosselin as to all steps appropriate to be taken in accord with this Code and applicable laws and regulations. Legal counsel shall make a report of the suspected violation as well as counsel´s advice to both Gosselin management and to the Ethics and Compliance Coordinator. The Coordinator shall monitor the full implementation of the steps advised to be taken and report accordingly to both management and to legal counsel.

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Standard of Conduct SC-5 Ethics and Legal Compliance

Ethical conduct and legal compliance have long been fundamental policies at Gosselin. The company’s worldwide business has flourished and grown over the years for this reason in addition to satisfying the public’s need for quality products and services at reasonable rates. It has been proven that high level of quality can only be maintained long-term if ethical business practices concerning all of Gosselin´s performances are fully maintained. Maintenance of the highest reputation for integrity is essential to Gosselin’s business and is not in any circumstances to be sacrificed for the sake of results. Gosselin management considers it essential that we continue to maintain the company’s excellent reputation for integrity, by conducting Gosselin operations in accordance with the highest ethical and moral standards and in compliance with all laws wherever Gosselin and its affiliates do business. Gosselin provides compliance guidelines on particular laws affecting specific areas of activity, as well as compliance presentations and periodic updates by Gosselin’s legal counsel and others. Employees should give careful attention to those guidelines and presentations. No supervisor or manager has the authority to require or approve any action by a Gosselin employee that would violate the law or Gosselin’s Code of Conduct. If an employee becomes aware of a situation that may involve a violation of any law or Gosselin’s Code of Conduct, the employee must bring the matter to the attention of his or her supervisor, the next level of management, or Gosselin legal counsel, or alternatively anonymously and confidentially to Frans van Hoof. No employee will suffer retaliation because of a report he or she makes in good faith. Gosselin will audit awareness of the Code obligations of all employees and will enforce its policies and legal compliance standards on a consistent basis; strict disciplinary action will be taken for violations of the Code , as appropriate, to and including termination of employment.

The Policy and Procedures associated with this Standard of Conduct covers areas of law that may not specifically be addressed in other Standards of Conduct or Policies and Procedures. These areas include: Employment – Health and Safety Matters; Welfare at Work; Federal Acquisition Regulations; and Federal Maritime Commission Regulations.

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Policy and Procedures PP-5 Ethics Awareness and Legal Compliance

I. STATEMENT OF THE POLICY Ethical conduct and legal compliance require employee awareness of the required standards, and have long been fundamental policies of the Gosselin Group. The company’s worldwide reputation and business has flourished and grown over the years for this reason in addition to satisfying the public’s need for quality products and services at reasonable rates. Maintenance of the highest reputation for integrity is essential to Gosselin’s business and is not in any circumstances to be sacrificed for the sake of results. II. DISCUSSION

It is Gosselin’s policy to conduct its business in compliance with all applicable laws, regulations and ethical standards. Gosselin’s Code of Conduct contains detailed Standards of Conduct and Policies and procedures regarding several areas of the law and ethical issues. In addition to meeting the standards and guidelines established elsewhere in the Code of Conduct, Gosselin employees must comply with the following guidelines.

III. GUIDELINES

A. Employment – Health and Safety Matters

1. As the employees are Gosselin’s main asset and guarantee for further success, all activities deployed will be according to the “Law of 4 August 1996 on the well-being of workers during the Execution of their Work” and the Royal Decrees in execution thereof (Codex), and the General Regulation on Employment Safety.

2. Refer to Guideline B of the Codex for the procedure regarding any

problems concerning violence, mobbing, pestering or sexual harassment, as well as workers’ safety matters.

3. Gosselin will not tolerate discrimination or harassment based on

race, religion, creed, national origin, sex, disability, age or any other relevant category.

4. Gosselin has adopted a strict anti-drugs and anti-alcohol policy and

enforces this policy on a zero-tolerance basis 5. All employees will behave themselves both in their internal activities

at Gosselin as well as in their dealings on behalf of Gosselin with

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others outside of the company in a manner respecting these values.

B. Welfare at Work

1. In case of violence, or harassment of any nature, please contact the prevention-advisor or the ombudsman, in this case the President of the Committee for Prevention and Protection at Work.

2. The prevention advisor will, according to the Codex, establish a file

and make recommendations to the employer to take appropriate action following acts of violence or harassment.

3. It is the victim’s free choice to first go to the ombudsman as

provided for in the Codex. The latter will negotiate and try to reconcile the parties concerned. If no reconciliation is possible the ombudsman will submit the complaint to the prevention advisor for further action.

4. All situations that may cause harm or discomfort to workers will be

reported to the Committee for Prevention and Protection. On the first following meeting of the Committee, the problem will be discussed in order to find a solution. All Committee decisions are binding.

C. Federal Acquisition Regulation

When trying to obtain contracts with the U.S. government, or while executing these contracts where Gosselin is either a contractor or a subcontractor to the US Government or any of its agencies, all Gosselin employees will strictly observe the requirements of the Federal Acquisition Regulation (“FAR”), including but not limited to the following rules.

1. Independent Price Determination

a. The prices will be determined independently, without, for the purpose of restricting competition, any consultation, communication, or agreement with any other offeror or competitor relating to those prices, the intention to submit an offer, or the methods or factors used to calculate the prices offered.

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b. The Gosselin prices or price-calculations, will not be knowingly disclosed to any competitor before bid opening or contract award.

c. No attempt will be made to induce any other concern to

submit or not to submit an offer for the purpose of restricting competition.

2. No contingent fees will be offered or given by any Gosselin

employee. Contingent fee means commission, percentage, brokerage, or other fee that is contingent upon the success that a person or concern has in securing a government contract.

3. There will be no efforts to prevent a subcontractor from doing

business with the US government.

4. Procedure to follow in the event of a suspected violation of this Standard, or in the event of any questions concerning this Standard and its operation:

a. If it is clear to you that a certain practice or agreement goes

against the principles or provisions of FAR or similar regulations indicated above, immediately make an end to it or seek to prevent from happening.. As this matter is rather complex it is understandable that you can have questions, or that you are uncertain whether what you are doing is permitted or not. In the case of any doubt in connection with this Standard, you must immediately submit the matter to your supervisor. He will analyze the matter and present it to legal counsel, Mr. Reed von Maur. Alternatively, you may submit the matter directly to legal counsel (contact information at §G.1, page 8 above) or anonymously to Frans van Hoof. Any formal or informal agreements on which there are any questions regarding FAR compliance must be submitted for review and approval by legal counsel in advance of any agreement being made or concluded.

b. Legal counsel will immediately review any questions

submitted with regard to this Standard, and will promptly prepare a report to both Gosselin management and to the Ethics and Compliance Coordinator indicating whether in his view a violation of this Standard has or may occur. If legal counsel concludes that the suspected or proposed activity or agreement constitutes a violation of any of the principles recited in this Standard, Gosselin management will

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immediately cause the activity to cease, or as appropriate direct that the intended activity or agreement not take place; and will take appropriate disciplinary action against any employee responsible for any violation. The Ethics and Compliance Coordinator will include the reported information, advice and remedial action in periodic audits, and will monitor compliance with the advice of legal counsel. In addition, the Ethics and Compliance Coordinator will prepare a report with recommendations to Gosselin management for the avoidance of any repeat of any determined Code violation. The recommendations will be reviewed by legal counsel and, when adopted by Gosselin, the Code of Conduct will be revised accordingly to reflect the recommended and approved change.

c. During the time of any inquiry by the legal counsel

concerning any reported suspected violation of this Standard or the Code, any suspected practice will be immediately suspended pending the results of legal review and investigation. . Legal counsel will then advise Gosselin management and the Ethics and Compliance Coordinator whether the questioned activity is compliance with these Standards and thus may be resumed, or whether the activity must be terminated. Any activity which external legal counsel determines has violated these Standards will be terminated and appropriate disciplinary action taken.

D. Federal Maritime Commission Regulations and AEO Compliance

When shipping goods to the United States some Gosselin employees or entities may be subject to the Federal Maritime Commission (“FMC”) Regulations. Every employee will act in full compliance with the standars and regulations applicable to Gosselin´s business when affected by the FMC Regulations. The individual standards of the FMS Regulations, particularly those involving customs-related and safety-security obligations concerning trans-Atlantic shipments handled by Gosselin will be regularly communicated to those employees dealing with these matters on behalf of Gosselin and the awareness of these standards on the part of the employees will be monitored and periodically audited. In this connection, Gosselin is subject to audit for the maintenance of its certification as an “Authorised Economic Operator” (AEO) recognized by the European Commission (Commission Regulation No. 197/2010). Trustworthiness, integrity and full awareness of the anti-fraud obligations by Gosselin employees involved in the customs-clearance and documentation elements of the Company as an AEO is are all essential things to maintain. Gosselin is committed to these high AEO-based standards in

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order to obtain and to maintain AEO-certification status, and will achieve this by training and awareness of the involved employees of these standards and related regulations. The Ethics and Compliance Coordinator will periodically audit the training and awareness of the Gosselin employees involved in these customs-related activities to assure the goals of the AEO certification.

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Standard of Conduct SC-6 Financial Books and Records

All of Gosselin’s assets, transactions and business information must be properly documented, fully accounted for and promptly recorded in the appropriate books and records in conformity with applicable accounting principles. Gosselin’s financial books and records will accurately reflect in reasonable detail all transactions, including any payment of money, transfer of property or furnishing of services. Gosselin will maintain proper books of record and account and will promptly enter only true and correct entries into its books and records. Gosselin will document in its books and records financial transactions and matters involving its assets and business in an accurate and timely manner. Additionally, Gosselin will maintain such books of record and account in material conformity with applicable government regulations and generally accepted accounting procedures, including the standards established by the International Accounting Standards Board. Gosselin employees are forbidden from using any funds or assets of Gosselin for any purpose that is prohibited under the Code of Conduct, applicable laws and regulations, or Gosselin’s high standards of business ethics.

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Standard of Conduct SC-7 Gifts, Meals and Entertainment

Gosselin, its directors, employees, agents, and independent contractors may never solicit, accept, offer or give gifts, favors or entertainment, in the performance of Gosselin’s business, if it will appear to obligate, or will actually obligate, the person who receives it, or if solicited or offered for the purpose of influencing the business decision of the person who receives it. Receiving or giving gifts of cash or cash equivalents is never allowed. The meaning and perception of the solicitation, acceptance, offer or giving of non-money gifts, gratuities or personal benefits or favors may be interpreted in a variety of ways by different people depending upon circumstances. Gosselin has implemented a Policy and Procedures in this area. All Gosselin directors, employees, agents, and independent contractors must be familiar with the Policy and Procedures, and when in doubt, must seek guidance from the Ethics and Compliance Coordinator, the Coordinator´sdesignee, or Gosselin´s external legal counsel, Mr. Reed von Maur, for this purpose. This guidance must be sought before any gift or gratuity is either given or accepted, no matter how small in value the gift or gratuity may seem. This general Standard relating to gifts and gratuities is also discussed in other parts of this Code of Conduct (for example, Standard of Conduct SC-2, Anti-Kickback, Anti-Inducement, Bribery and Gratuities, p. 18 above) and you should also refer to that as well. Stated simply: Gosselin has a general prohibition against any Gosselin employee either taking or giving any gifts or gratuities which may be related, or may even appear to be related, to any business of Gosselin in which any employee is involved in any way. When in doubt, do not either give or receive any gift or gratuity in connection with anything involving the business of Gosselin in which you are involved. The Gosselin Policy and Procedure (PP-7) relating to Gifts, Meals and Entertainment set out in the next part of this Code of Conduct must be reviewed and followed by all Gosselin employees.

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Policy and Procedures PP-7 Gifts, Meals and Entertainment

I. STATEMENT OF THE POLICY Gosselin, its directors, employees, agents, and independent contractors may never solicit, accept, offer or give gifts, favors or entertainment, in the performance of Gosselin’s business, if it will appear to obligate, or will actually obligate, the person who receives it, or if solicited or offered for the purpose of influencing the business decision of the person who receives it. Receiving or giving gifts of cash or cash equivalents is never allowed.

II. DEFINITIONS

A. A gift includes any object with value, and includes but is not limited to, meals, entertainment, favors, discounts service, personal benefit, loans, forbearance transportation, and lodging.

B. Entertainment includes sporting and cultural events, golfing fees, ski lift

tickets, charter boat trips and the like. III. DISCUSSION Soliciting gifts is not allowed. Accepting and giving gifts, as explained in the

above definitions, under certain limited circumstances are customary, and may properly promote the business of Gosselin. The Guidelines in this policy and procedure provide for limited exceptions under which gifts can be accepted, offered, or given. If there is any uncertainty, consult with the Chief Ethics and Compliance Coordinator or external legal counsel, Mr. Reed von Maur. Since the meaning and perception of the acceptance, offer or giving of non-money gifts, gratuities or personal benefits or favors may be interpreted in a variety of ways by different people, depending upon circumstances, consultation with the Ethics and Compliance Coordinator will often counter-balance misperception that a gift violates this policy.

IV. GUIDELINES

A. Gosselin, its directors, employees, agents and independent contractors may give or accept unsolicited gifts to or from a private business firm or individual doing or seeking to do business with Gosselin of $20 or less per occasion, with a limit of $50 aggregate per year per donor, without prior written permission of the Ethics and Compliance Coordinator, and if giving or acceptance complies with all other aspects of this policy and procedure. Cash will never be either given or accepted regardless of amount.

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B. Gifts which exceed the amount in Guideline A can only be offered, given,

accepted or retained upon the prior written permission of the Chief Ethics and Compliance Coordinator. If a function of the gift item is as a marketing device for the giver’s organization, this fact may weigh in favor of the Ethics and Compliance Coordinator’s approval, if the offer, giving, acceptance or retention complies with all other aspects of this policy and procedure.

C. Gifts of meals or entertainment which exceed the amounts in Guideline A

can only be offered, given or accepted upon the prior written permission of the Ethics and Compliance Coordinator. If the recipient of the meal or entertainment can reciprocate with a similar gift of equal value, this fact may weigh in favor of the Ethics and Compliance Coordinator’s approval, if the offer, giving or the acceptance complies with all other aspects of this policy and procedure.

D. If the gift is of a type that can be shared with co-workers, it must be shared

unless another use is authorized by the Ethics and Compliance Coordinator.

E. Gosselin directors, employees, agents and independent contractors may

accept or give gifts as defined above, and the Ethics and Compliance Coordinator may approve the offer, giving or acceptance, under Guidelines A, B, C, and D of this policy and procedure, only if all of the following criteria also are met:

1. It is not against the law or the policy of the other party’s country and

company. 2. It is consistent with customary business practices in the industry

and the country. 3. It is reasonably related to the business of Gosselin. 4. The cost of the gift is reasonable in relation to the nature and

circumstances of the gift. 5. Public disclosure of the facts would not embarrass the company or

the employee.

6. It does not violate Gosselin’s Code of Conduct in any other manner.

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Standard of Conduct SC-8 Quality and Performance Integrity

Quality and Performance Integrity arethe mission of Gosselin and must be the objective of every employee. This is also Gosselin´s principal competitive advantage. Every employee is obligated to work to a level of quality and with business inetrigty consistent with this Code and with the Standards required by the International Standards Organization (ISO) and by the Fédération Internationale des Déménageurs Internationaux (FIDI) Continual improvement of Gosselin’s performance is a permanent objective of the company. Gosselin’s sustained commitment to quality is demonstrated by the Gosselin “Quality Charter” and Gosselin’s accreditation by FIDI´s Accredited International Mover (FAIM) standards, the highest quality assurance standard for the international moving industry. In addition, Gosselin and its affiliates have been certified as meeting the Quality Management System Standards of the International Standards Organization (ISO). . Gosselin is committed to quality and excellence. Gosselin employees must work as a team, recognize that each person is an essential link in the quality-performance chain, and contribute quality work when performing every function required to conduct Gosselin’s business. Employees at all levels of the Gosselin organization are both the company´s principal assets and the driving force of the company and each person’s full involvement and commitment strengthens Gosselin. Quality performance, and our reputation for reliability and integrity, are the value added for our customers. All employees must be aware that Gosselin depends for its survial on the satisfaction and trust of its customers, and in order to exceed our customers’ expectations for quality and value, we must:

• Determine customer requirements and meet the requirements with the aim of enhancing customer satisfaction. This includes both requirements specified by the customer and also requirements not stated by the customer, but necessary for the customer’s approval of our services.

• Accurately describe all services offered under each customer’s contract.

• Understand and anticipate current and future customer needs.

• Monitor information relating to customer perception to decide whether the

company has met customer expectations and requirements; and when these requirements or expectations have not been met, to develop within your team at Gosselin concrete steps to avoid this happening in the future

• Determine the appropriate action to eliminate the causes of potential problems.

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In order to achieve total quality, Gosselin employees also must work closely with its suppliers and subcontractors. We must oversee our subcontractors and insist that they provide the same attention to quality as Gosselin employees do. Finally, Gosselin must comply with all statutory and regulatory requirements related to the international moving industry, including particularly those which relate to the integrity of Gosselin in all of its dealings with its customers, suppliers, subcontractors and agents. Compliance with all parts of the Code of Conduct is therefore essential to the assurance that Gosselin will continue to deliver highest quality performance to its customers, and will continue to keep customer confidence. The Gosselin Policy and Procedure (PP-9) relating to Quality and Performance Integrity

set out in the next part of this Code of Conduct must be reviewed and followed by all Gosselin employees

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Policy and Procedures PP-8 Quality and Performance Integrity

I. STATEMENT OF THE POLICY Quality and Performance Integrity are the mission of Gosselin and must be the objective of every employee. This is also Gosselin´s principal competitive advantage. Every employee is obligated to work to a level of quality and with business inetrigty consistent with this Code and with the Standards required by the International Standards Organization (ISO) and by the Fédération Internationale des Déménageurs Internationaux (FIDI) II. DISCUSSION

It is Gosselin’s policy to conduct all aspects of its business with the highest quality and with full business integrity. It is especially important that all customers receive quality services rendered in compliance with the Standards in the Code of Ethics. . Gosselin employees must meet the following guidelines for Gosselin to achieve its objective of quality.

III. GUIDELINES

A. Provide timely service: meet all pickup and delivery times. B. Use clean containers that are in good condition. C. Meet each customer’s expectations. D. Maintain a respectful and polite demeanor with colleagues and customers. E. Protect goods to prevent damage and loss. If goods are to be stored

outside, protect goods from the elements. F. Process claims in a prompt, responsive, and fair manner. G. Staff moving projects with reliable and qualified personnel. H. Use equipment and facilities that meet safety standards. I. Keep accurate records. J. Comply with the Standards in the Gosselin Code of Conduct and comply

with all applicable domestic and foreign laws.