C.H. Robinson Code of Ethics (English) PDF

Mission, Vision and Values
CODE OF ETHICS
©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 1

MISSION
OUR PEOPLE, PROCESSES, AND TECHNOLOGY IMPROVE
THE WORLD'S TRANSPORTATION AND SUPPLY CHAINS
AND DELIVER EXCEPTIONAL VALUE TO OUR CUSTOMERS.
VISION
ACCELERATING COMMERCE THROUGH THE WORLD’S
MOST POWERFUL SUPPLY CHAIN PLATFORM.
VALUES
E VOLVE CONSTANTLY
We try new things and never stop learning or challenging.
D ELIVER EXCELLENCE
We go the extra mile, because good enough is never good enough.
GWe
ROW TOGETHER
value relationships, and are smarter and stronger as a diverse and unified team.
E MBRACE INTEGRITY
We do what we say we will do, and we do what is right.

Table of Contents
A Message from Ben Campbell 4
Introduction 5
Policies 6
Mission, Vision and Values 6

Protection of Information Assets, Personal Data, and Company Property 7
Conflict of Interest 10
Records Management and Retention Policy 12
Electronic Data and Communications Policy 13
Non-Discrimination and Anti-Harassment Policy 18
Compliance with Law 21
Corporate and Worldwide Anti-Corruption Policy 21
Accurate Books and Records Policy 25
Compliance with U.S. Sanctions & Embargoes 27
Policy on Dealing with Government 28
Anti-Money-Laundering Policy 30
Fair Competition Policy 30
Procurement Policy 31
Advertising and Marketing Policy 32
Designated Spokesperson Policy 33
Compliance with Insider Trading 35
Anti-Boycott Policy 37
Compliance with the Code of Ethics 40
Additional Responsibilities for Supervisors & Managers 41

Reporting and Investigating Violations of the Code of Ethics 43

A MESSAGE FROM BEN CAMPBELL
Dear team,
As a member of C.H. Robinson there are guiding principles and policies set out in the Corporate Compliance
Program, which includes the Code of Ethics, that everyone must be aware of and adhere to. The compliance
guidelines are invaluable to the organization and our overall success. As employees of C.H. Robinson, we
are committed to the fundamental values of evolving constantly, delivering excellence, growing together
and embracing integrity. With these principles in mind we can create something truly innovative and
successful in our industry. We strive to accelerate commerce thorough the world’s most powerful supply
chain platform and can only do so with the support and drive of each and every employee. To be successful
as an organization we expect everyone from the top down to adhere to the principles in the Corporate
Compliance Program to gain and keep the confidence and support of customers, regulatory agencies, the
public and our employees. Most important of all, compliance is simply the right thing to do.
The Code of Ethics is designed to help demonstrate the policies and expectations that govern our
organization. It supports our efforts to create an adaptable, collaborative and compliant company culture.
With your help we can create solutions, manage execution, and develop ourselves and teams, all while
understanding the big picture of our everyday efforts to improve the worlds transportation and supply
chains. You are important in these efforts and our overall success. If you have questions or are in doubt of
your role as a member of the organization use the Code of Ethics as a helpful guide. It is also important to
understand your reporting obligations. If you see something that is not reflective of our company mission,
vision, values or policies, report it in good faith and with positive intention.
Thank you in advance for your continued commitment to the highest standards of business ethics and for
keeping the passion for success alive at C.H. Robinson.
Sincerely –
Ben Campbell
Chief Legal Officer and Secretary

INTRODUCTION
The C.H. Robinson Worldwide, Inc. Code of Ethics ("Code") requires every employee to comply with high
standards of business conduct and the law.
Our Code reflects our company culture and our abiding commitment to do what is right. The Code is also
necessary to effectively manage our business. All employees and directors, officers and board members
of C.H. Robinson and its subsidiaries are required to know and follow the Code, as well as all applicable
laws and regulations. If a situation arises where there may be a conflict between the Code and the laws of
the country in which you are located or doing business, you should consult with the Legal Department. We
are committed to doing business ethically and within the law where we are conducting business.
Nothing contained in this Code, or other communications relating to this Code, creates or implies an
employment contract or term of employment. C.H. Robinson continuously reviews its policies, and this
Code is therefore subject to modification.
Throughout this Code, the terms "C.H. Robinson" and "Company" refer interchangeably to C.H. Robinson
Worldwide, Inc. or any company, division, market unit or business unit, subsidiary, or majority-owned
venture of C.H. Robinson Worldwide, Inc. The Code applies to every C.H. Robinson employee and director
in any company, division, subsidiary, market unit or business unit, including joint ventures where C.H.
Robinson maintains management control.

POLICIES
MISSION
Our people, processes and technology
C.H. Robinson has a long standing history of improve the world’s transportation and
success by instilling high standards of ethics, supply chains, delivering exceptional value
respect and integrity at all levels of the to our customers and suppliers.
organization. We know how important it is do the
right thing when engaging in business practice VISION
and building relationships internally and Accelerating commerce through the world’s
externally. Our customers, carriers, and vendors most powerful supply chain platform.
have high expectations of us, and we have even
higher expectations of ourselves. We must exhibit VALUES
ethics and integrity in all we do; hold each other
Evolve constantly: We try new things and
accountable to the highest ethical standards; and
never stop learning or challenging.
report potential violations that pose a risk to our
customers, communities, employees, or our
Deliver excellence: We go the extra mile,
company’s reputation. Our company relies on our
because good enough is never good
values to ensure our mission and vision are being
enough.
met year over year. These values are critical to
build trust and respect in our company, industry Grow together: We value relationships, and
and with our employees, customers, carriers,
are smarter and stronger as a diverse and
vendors, and shareholders. We are deeply
unified team.
committed to ethical behavior and expect all
employees to demonstrate and live by the values Embrace integrity: We do what we say we
we share as an organization to help us succeed
will do, and we do what is right.
at our mission and vision. Values support our
vision and shape our culture. They guide our
decisions and relationships with our teammates,
customers, carriers, vendors and shareholders.
Together, our mission, vision, and values define
our focus as an organization, and how we will
continue to win as one.
member of our organization to ensure we treat
Our Board of Directors, and Executive partners internally and externally with dignity and
Leadership Team hold ourselves to the same respect.
high standards of conduct that we expect
It is important that these values are lived by, day
employees and managers to honor. For those
after day to maintain our reputation as a trusted,
who manage others, it’s your obligation to set the
respected and ethical leader in the industry. Each
right example for behavior and workplace
and every day, we have the opportunity to bring
conduct. It is the responsibility of each and every
our Mission, Vision & Values to life.

Protection of Information Assets, Personal Data, and Company Property

It is C.H. Robinson’s policy to ensure that all  Information obtained from the Company’s
information assets and third-party confidential confidential personnel files for purposes of
information are protected. Information assets are performing one’s job responsibilities
(a) confidential and/or secret business  Personally Identifiable Information
information, such as non-public financial data,
such as estimates of financial performance; Secret Information
business know-how and other sensitive business  Pre-filed Securities and Exchange
information, such as marketing strategies, Commission filing information
product launches, and pricing policies; plans for  Information related to the acquisition or
the acquisition or disposition or corporate assets; disposition by the Company of companies
information about customers; the Company’s or business units
attorney-client communications or other internal
 Current or pending litigation
business-related confidential communications;
(b) and any other formulas, devices, systems or  Person Health Information
other compilations of information, whether in a  Trade secrets and technology
verbal, printed, written, or electronically recorded
As a C.H. Robinson employee, you will have
or transmitted format and intellectual property,
access to certain information assets and third-
which includes all copyrights, patents,
party confidential information. It is important for
trademarks; and (c) trade secret information
you to know that you must not use or disclose
owned by the Company, which include
information assets and third-party confidential
information regarding the development of
information except when you are specifically
systems, business processes, products, know-
authorized to do so.
how and technology. All employees, because
they are information users, custodians, or You may not use information assets or third-party
stewards, must protect all information assets from confidential information for any personal gain or
misuse, theft, fraud, loss, and unauthorized use, advantage. This includes sharing such
disclosure, or disposal. The following are some information with individuals outside C.H.
additional examples of information assets. Robinson for their personal use as well as sharing
with fellow employees whose duties do not
Confidential Information
require that they have that information. This
 Business, financial, marketing and service restriction applies even if you developed or aided
plans associated with products and in the development of an information asset
services yourself.
 Pricing strategies
To the extent possible, make sure all information
 Designs and software service and know- assets are clearly marked "C.H. Robinson
how process Confidential and Proprietary Information" or “C.H.
 Business and product plans with outside Robinson Secret Information” and do not leave
vendors any information assets in places where persons
 Customer and/or Provider lists without authorization have access to it. If you
carry any information assets with you when you
 Internal databases
travel, keep it with you in a closed and locked
container. When you speak with others about

C.H. Robinson business, be cautious about what The use or release of business information
you say. Do not: through speeches, interviews, statements to the
press, or other means of communication requires
 Discuss with anyone outside the Company
prior approval of the Legal Department and a Vice
any products, prices, earnings, business
President, President, and/or Chief level
volumes, or capital requirements that have
employee.
not been made public by the Company
 Talk about confidential product If you have the business need to disclose certain
performance data, marketing or service information assets with a third party (including an
strategies, business plans, or other existing or prospective customer, carrier or
information which is confidential, or secret service provider), you must ensure such
unless authorized by the Company; or disclosure is protected through the use of a Non-
Disclosure Agreement (“NDA”). An NDA places
 Discuss information assets even with
protections, obligations, restrictions, and
authorized persons within the Company if
limitations on the use of Company information
you are in the general presence of others,
assets by third parties when disclosed to third
for instance, at a trade show reception or
parties. No information asset may be disclosed to
in an airplane.
a third party without the use of an NDA. Not all
If you even suspect that information is information assets may be disclosed to a third
Confidential or Secret information as described party, even under an NDA. Contact the Legal
above, do not disclose it to anyone, including Department for assistance in determining
family members or friends. whether a particular information asset may be
disclosed to a third party and to establish an
No employee shall disclose any confidential
appropriate NDA.
information belonging to a third party without first
obtaining the express written permission of such Even when you retire or leave the Company for
third party. Except when provided third party any other reason, you are bound by the same
confidential and/or proprietary information for obligations to protect C.H. Robinson information
legitimate business purposes, any employee who assets and confidential third-party information.
comes into possession of third party confidential After you leave, C.H. Robinson also continues to
proprietary information should immediately refer own any information asset that you developed or
that information to the Legal Department. assisted in developing while a C.H. Robinson
employee. If you have or are aware of confidential
If you have or are aware of confidential and/or
or proprietary information from a former
proprietary information of a third party, you have
employer, you may be legally or ethically bound
a legal and ethical obligation not to use such
by a nondisclosure obligation to your former
confidential and/or proprietary information for any
employer. C.H. Robinson expects and requires
purpose other than the purpose for which it was
you to fulfill this obligation. You should refrain
disclosed to the Company, and not to make any
from giving your fellow employees or from using
further disclosures of such confidential and/or
in C.H. Robinson's business any confidential or
proprietary information to any employee who
proprietary information belonging to any of your
does not have the need to know such information
former employers.
or to anyone else.
An individual shall not be held criminally or civilly
liable under any Federal or State trade secret law

for the disclosure of a trade secret that is made in Company Property
confidence to a Federal, State, or local It is the policy of C.H. Robinson to properly use
government official or to an attorney solely for the all company property, which means all property
purpose of reporting or investigating a suspected owned by C.H. Robinson, including Company
violation of law. An individual shall not be held funds, personal property, real property,
criminally or civilly liable under any Federal or intellectual property, software, trade secrets,
State trade secret law for the disclosure of a trade technology databases, and proprietary
secret that is made in a complaint or other information. All C.H. Robinson employees are
document filed in a lawsuit or other proceeding, if responsible for the proper use of company
such filing is made under seal. An individual who property, and must safeguard this property
files a lawsuit for retaliation by an employer for against loss, damage, misuse, or theft. No
reporting a suspected violation of law may employee may use company property for any use
disclose the trade secret to the attorney of the other than company business without Company
individual and use the trade secret information in approval.
the court proceeding, if the individual files any
document containing the trade secret under seal; You are personally responsible for all Company
and does not disclose the trade secret, except funds over which you exercise control. You must
pursuant to court order. take all reasonable steps to assure that C.H.
Robinson receives good value for company funds
Personal Data spent and must maintain accurate records of
Personal Data means any information that relates these expenditures. You must not use company
to an identified or identifiable natural or legal funds for any personal use.
person, including but not limited to names,
C.H. Robinson has obtained licenses for
addresses, telephone numbers, email addresses
computer software from outside vendors. This
and other personal identifiable information.
software and any related documentation may not
Except as is required to accomplish your regular
be reproduced unless the software developer has
day to day business efforts or as specifically
given authorization. Software and documentation
allowed by C.H. Robinson’s data protection
that C.H. Robinson has developed or enhanced
and/or privacy related policies, Personal Data
also may not be reproduced for any use that has
should not be disclosed to third parties. If you
not been authorized.
become aware of disclosures of Personal Data
not allowed by C.H. Robinson’s data protections You may use Company owned or licensed
and/or privacy related policies or this Code, software only if that use is job related. You may
please report such disclosures to the Legal not use it for any personal use, even if you helped
Department through the use of develop or enhance the software.
privacy@chrobinson.com and/or through the use
of an anonymous email at the Report an Incident You may not use (or allow others to use) C.H.
link on Worknet here. Please read more here. Robinson owned or leased equipment for any
personal use or any use other than for company
business without company approval.

Conflict of Interest
An employee must not engage in activities where The Company understands that special
his or her personal interests conflict or have the circumstances may require employees to
appearance of conflicting with the interests of participate in events hosted by a supplier for
C.H. Robinson. Whether a conflict exists is to be educational or informational purposes. This Policy
decided by the Legal and Human Resources does not prohibit participation in such events.
departments. Personal interest means any
Employees must not:
interest, whether financial or otherwise, that
would, or would appear to, influence a judgment  be employed outside the Company or
or decision in favor of another party dealing with serve as an officer, director or consultant
C.H. Robinson. or have an economic interest that could,
or might reasonably be thought to,
No employee or any member of their family shall
influence judgment or action in any
solicit or accept from an actual or prospective
business that competes with, provides
customer or supplier any compensation,
services or seeks to provide services to
advance, or loans (except from established
the Company; (An investment
financial institutions on the same basis as
representing less than 2% of a class of
available to other customers), or gifts,
outstanding securities of a publicly held
entertainment, or other favors which are of more
corporation is not a conflict of interest.)
than minimal or nominal value generally around
$50 or which the employee would not normally be  act in a manner that would affect their
in a position to reciprocate under standard objectivity in carrying out their Company
Company expense account procedures. This responsibilities;
does not include normal business entertainment  engage in outside employment that would
items such as meals and beverages, or conflict with Company business hours, or
contributions or donations to recognized the performance of Company
charitable and nonprofit organizations. Family assignments. Employees must not use
members include, but are not limited to, your Company time, materials, information, or
spouse, parent, children and their spouses, other assets in connection with outside
brother or sister, or the same by marriage. Also employment or other personal business
included are, aunt, uncle, niece, nephew, interests prohibited by this Policy.
grandparent, grandchild and other members of
No employee may directly or indirectly benefit, or
your household. Also included are romantic
seek to benefit, from their position as an
relationships and “step” or “half” family
employee from any sale, purchase, or other
relationships.
activity of the Company.
No employee who deals with individuals or

organizations doing, or seeking to do, business
with the Company or who makes
recommendations with respect to such dealings
may have any other direct or indirect personal
interest in any business transaction with the
Company.

Employees will not do business on behalf of the This applies to all regular employees.
Company with a close personal friend or relative;
Family members include, but are not limited to,
however, recognizing that such transactions
your spouse, parent, children and their spouses,
sometimes occur, they must be reported to a
brother or sister, or the same by marriage. Also
supervisor.
included are, aunt, uncle, niece, nephew,
Company employees are encouraged to grandparent, grandchild and other members of
participate in public service and charitable your household. Also included are romantic
activities so long as they do not create actual or relationships and “step” or “half” family
potential conflicts with the employee’s duties to relationships.
the Company. Prior to accepting an appointment
If family members might work together due to a
in public service, serving on the board of a
transfer or promotion, the Company will attempt
charitable institution or running for political office,
to transfer the employee to another available
an employee must obtain approval from a
position for which the employee is qualified. If you
supervisor and the Legal Department. C.H.
are aware or are involved in any conflict of
Robinson supports its employees’ participation
interest as noted above you must disclose all
as directors of for-profit corporations, provided
potential conflicts to your manager and/or the
such participation does not create a conflict of
Human Resources Department immediately to
interest or implicate other Securities and
ensure the Company can take appropriate
Exchange Commission (SEC) concerns. Service
measures to protect you and the company.
on for-profit boards must be approved by the
Chief Legal Officer and CEO. Employees who become immediate family
members or establish a romantic relationship
Employment of Friends and Relatives
may continue employment in their current
C.H. Robinson welcomes friends and family position as long as it does not involve one of the
members to be considered for employment under conditions above. Should one of the conditions
the usual hiring policies. However, to prevent occur the Company will attempt to transfer one of
situations of actual or perceived favoritism or the employees to an available position for which
conflict of interest, family members and the employee is qualified. If a transfer is not
employees in a romantic relationship may not feasible, the employees will be permitted to
have working relationships that: determine which of them will resign. If the
 Create a direct or indirect employees cannot make a decision, C.H.
supervisor/subordinate relationship; Robinson will decide who will remain employed.
 Have the potential to create an adverse Loans

impact on individual or team work C.H. Robinson prohibits loans or advancement of
performance; pay directly from the Company to employees or
 Control or influence the terms and their families.
conditions of employment.

Records Management and Retention Policy
Records Management and Retention Policy

This Records Management and Retention Policy personnel necessary to store, organize,
(“Policy”) has been developed to provide the and handle the vast number of records
employees of C.H. Robinson with a when retention is no longer required;
comprehensive set of guidelines for the  Privacy and security of records will be
management, handling and disposition of protected;
Company documents and information. These
 Destruction of records will take place in
guidelines have been established to assure the
compliance with standard procedures, in
Company’s compliance with all applicable state
order to avoid any inference that any
and federal laws and regulations, and to
record was destroyed in anticipation of a
accommodate the company’s need for access to
specific problem; and
its important business documents and records for
a reasonable period of time. This Policy is also  All destruction procedures will be
intended to ensure that the Company’s retention suspended when a record or group of
and storage of documents is conducted in an records are placed on legal hold, which is
efficient and cost effective manner. described below.
A current version of C.H. Robinson’s Records
Record Retention and Management
Retention Schedule is available on the Legal
C.H. Robinson’s Legal Department has the Department’s WorkNet portal. Please refer to the
authority to establish, maintain, and implement a country specific retention policy where
comprehensive Records Retention Schedule, applicable.
including updates and modifications thereto. It
also has the authority to approve uniform The Records Retention Schedule controls the
practices, procedures, and guidelines for the maintenance, storage and destruction of all
management, maintenance, and destruction of Company records. As a general rule, a record is
documents. Adherence to the Records Retention any compilation of information, regardless of its
Schedule is intended to assure that the following physical characteristics, which was created or
objectives are met: received by C.H. Robinson and which should be
preserved because of its business or evidentiary
 All records necessary for business value. The majority of the records covered by the
reasons will be retained for a period of Records Retention Schedule are paper
time that will reasonably assure their documents (or electronic images of paper
availability when needed; documents) which have been created or received
 All records required to be developed and by C.H. Robinson. However, records may also be
retained to document or support the in the form of computer tapes and discs,
company’s compliance with applicable microfilm, video and other electronic mediums.
federal, state, and local laws and The Records Retention Schedule applies to all
regulations will be developed and retained records maintained by C.H. Robinson regardless
for the required periods; of the format in which they are maintained.
 All records not necessary for legal or Legal Hold on Records
business purposes will be destroyed to
From time to time C.H. Robinson may be required
reduce the
to place a “legal hold” on a class or group of
high cost of space, equipment, and
records as the result of actual or threatened legal,

Receipt of Legal Documents by C.H. Robinson Employees
individual or administrative action. A “legal hold” Receipt of Legal Documents by C.H. Robinson
suspends all destruction procedures to preserve Employees
appropriate records under special circumstances. An employee served at home, on the job, or in the
The C.H. Robinson Legal Department is mail with legal documents relating to a C.H.
responsible for determining when a “legal hold” is Robinson activity must immediately contact the
required and the scope of records to which it individuals below.
applies. You will be notified if a “legal hold” is
placed on records for which you are responsible. Summons and General Subpoena
You are then required to locate, index and protect Complaints
the records affected by a “legal hold.” Any record Sara Ann Buesgens Sara Ann Buesgens
affected by a “legal hold” must not be destroyed +1 (952) 906-7056 +1 (952) 906-7056
under any circumstances. If you are unsure Security Issues Regulatory Agency
whether a particular record is affected by a Subpoenas
specific “legal hold,” you must protect and Ben Campbell Ben Campbell
preserve that record until you have requested and +1 (952) 937-7829 +1 (952) 937-7829
received clarification from the Legal Department. Writs of Affirmative Action
Garnishments/ Documents/EEOC
A “legal hold” remains effective until it is officially
IRS Levies Complaints
released in writing by the C.H. Robinson Legal
Carrier Resolutions Angie Freeman
Department. After you receive written notice that
+1 (952)-937-7780 +1 (952) 937-7847
a “legal hold” has been lifted, you may return all
Payroll Department Chris Feickert
affected records to their normal handling
+1 (952) 683-6949 +1 (952) 683-6733
procedures and retention schedule.
Secretary of State Other Issues
(Corporate)
Jane Rief Ben Campbell
+1 (952) 906-7011 +1 (952) 937-7829

Electronic Data and Communications Policy

C.H. Robinson has provided electronic systems regarding the use of these systems (including
and services, including Internet, e-mail, Internet sites accessed) and all messages
voicemail, instant messaging, mobile phone created, sent, stored or retrieved. Unless
access and stored messaging systems, and other applicable local law provides otherwise, you
electronic systems and forms of communications should have no expectation that any of this
(“Electronic Systems”) as tools for conducting information, data, or communications is private or
Company business. Access to the Company’s confidential. As permitted by local law, the
Electronic Systems is a privilege that is approved Company may, and routinely does, access,
by management and granted based on job retrieve, and delete employees’ internet, e-mail,
responsibility. Use of these tools requires voice mail, instant message and other
responsible and ethical use. By using the communication tool usage, including file
Electronic Systems provided by the Company, attachments and Internet sites visited or
you are agreeing that you accept the terms of this attempted to visit. You should have no
policy. All employees must take care to ensure expectation that any matter stored in, created,
that accessing the Internet and other use of the received, or sent over the Company’s Electronic
Company’s Electronic Systems does not violate Systems is private or confidential. Use of
this policy or any other Company policy. passwords does not in any way diminish the
Company’s rights to access materials on its
Only employees and others expressly authorized
Electronic Systems, or create any privacy rights
by the Company may use the Company’s
of employees in the messages and files on such
Electronic Systems.
Electronic Systems. Every C.H. Robinson
Nothing herein is intended to prohibit an employee is responsible for using the Electronic
employee’s rights under any and all applicable Systems in accordance with this policy and all
laws. In addition, the Company will not construe other Company policies. As additional forms of
or apply this Policy in a manner that prevents electronic and other communications become
employees from communicating with each other available, the Company will continue to monitor
about the terms and conditions of their those forms as well, as permitted by local law.
employment.
Acceptable Uses of the Internet and other
Company Property - No Expectation of Privacy Electronic Systems
(as permitted by local law)
C.H. Robinson provides its employees with e-
All Electronic Systems provided by the Company, mail, Internet, instant messaging, and other
all material or data created or stored on such electronic systems for business purposes.
systems, the e-mail addresses assigned to Employees accessing these services are
employees, and all communications through or representing C.H. Robinson and must only use
using these systems are the property of and these tools in an ethical and lawful manner.
belong to the Company. Consistent with local Usage and communications should be for
laws, the Company and other persons it may business reasons, including:
authorize (including governmental or law
enforcement authorities) have the right to access,  To communicate with employees,
monitor, use or disclose any data or files created vendors, or clients regarding matters
or stored on its Electronic Systems, information within an employee’s assigned duties;

 To acquire information related to, or any third party that has disclosed information to
designed to facilitate the performance of us. Consult the company’s confidentiality policy
regular assigned duties; and for guidance about what constitutes confidential
 To facilitate performance of any task or information. Do not use company trademarks,
project in a manner approved by an logos, or reproduce company material on your
employee’s supervisor. site.
All traffic to and from the Internet must travel Be respectful to the company, our employees, our
through the approved Company gateway in order customers, our partners and affiliates, and others
to assure maximum security, virus protection, (including our competitors). Do not post any
monitoring, and systems management material that is obscene, defamatory, profane,
capabilities. libelous, threatening, harassing, abusive, or
hateful to another person or any other person or
Social Networking and Blogging entity. This includes, but is not limited to,
Online social networking, blogging or any other comments regarding C.H. Robinson, and C.H.
form of online publishing or discussion activities Robinson employees, suppliers and competitors.
are subject to all of the Company’s policies and In addition, you should not make knowingly or
procedures. You are personally responsible for recklessly false statements about the Company’s
what you write. products or services, or the products or services
of its customers, vendors or competitors. You
Write in the first person and use your personal
also should not post content, images or video of
email address when your social media activity
yourself that identifies you as a Company
relates to the Company unless you have received
employee and depicts you engaging in illegal
prior authorization in writing to speak on the
conduct, such as acts of violence or the illegal
Company’s behalf. You should not represent or
use of drugs, or in conduct that violates any
suggest in any social media activity that you are
Company policy.
authorized to speak for the Company, or that the
Company has reviewed or approved your Finally, be aware that the company may request
content. If that will not be obvious from the that you confine your website or weblog
content or context of your post, you should commentary to topics unrelated to the company
specifically state: “The views expressed on this (or, in rare cases, that you temporarily suspend
website/weblog are mine alone and do not your website or weblog activity altogether) if it
necessarily reflect the views of my employer. I am believes this is necessary or advisable to ensure
not authorized to make statements on behalf of compliance with securities regulations or other
C.H. Robinson.” laws.
Remember that as soon as you identify yourself Unacceptable Use of the Internet and Electronic
as being part of C.H. Robinson, you are in some Systems
way representing the business. Include your Employees may not attempt to gain access to
name and role with C.H. Robinson when information or data, including computer files or e-
discussing C.H. Robinson related matters or mails, of other employees to which they have not
topics in the industry. been given authorized access by the Company.
Do not disclose any information that is Likewise, any attempt to masquerade as another
confidential or proprietary to the company or to person, alter messages, or otherwise attempt to
send a communication or create a document to

make it appear as if it were created or sent by attached graphics. Such usage can result in the
someone else is prohibited. loss of network efficiency for all employees and
impede the system. Therefore, such use should
The Company’s Electronic Systems may not be
remain minimal and business-related only.
used to create, view, print, transmit or download
material that is defamatory, sexually-related, The use of executable files, programs or utilities
sexually-explicit, racist or similarly offensive, shall be limited to the programs contained in the
including but not limited to slurs, pictures, “Approved Software List” developed by the I.T.
cartoons, epithets or anything that may be department. If additional software not contained
construed as harassment or discrimination based in the Approved Software List is needed, such
on race, color, religion, sex (including software must be evaluated, approved and
pregnancy), sexual orientation, gender identity, licensed by the I.T. department prior to download
marital status, age, national origin, disability, and/or installation.
military service or status, or any other protected
Think before you write
category.
E-mail and instant messages are a permanent
The Company’s Electronic Systems may not be form of communication. It should be noted that
used for personal gain; solicitation of non- although a message or file is deleted or erased, it
company business, or on behalf of any political is still possible to recreate the message. Please
cause, religious group, or membership think carefully before you send an e-mail or
organization; the transmission of destructive files instant message, make sure you cannot be
or programs (e.g. viruses, malware or self- misunderstood, say what you mean and ask
replicating code); or any illegal or unethical use. yourself if e-mail is the best way to communicate
Unauthorized and illegal uses include: gambling, what you want to say.
violation of copyright, trademark or other material
protection laws, copying of software in a manner Think before you open
inconsistent with vendor’s license agreements, Employees shouldn’t open electronic mail
providing confidential Company or customer attachments unless they were expected from a
information outside of the Company, sending known and trusted sender. Unexpected
Company information or e-mail to yourself at a attachments should by verified by the sender
personal e-mail address or to a third party for through a secondary method of communication
purposes other than as authorized for furthering before opening them.
the legitimate business goals of the Company, or
using Internet based e-mail services such as Remote Access Users
Yahoo, Hotmail or AOL through the Company’s Remote employee access to resources on the
Electronic Systems. internal corporate network should be approved by
management and based on job responsibility.
Internet access consumes resources of the
Authorized users may only gain access to the
Company’s computer network, including cabling
Company network through the Company’s
and server processing. Employees should
remote authentication process, including
minimize use of real-time Internet updates, audio
providing a network user ID and password. Any
and video streaming media (e.g. Internet radio or
additional remote access mechanisms are
TV using “RealPlayer” or “Windows Media
prohibited. All the provisions of this Electronic
Player”), MP3 files, downloading of large files,
mass e-mails, chain messages, and e-mails with

Data and Communications Policy apply fully to and unacceptable uses of C.H. Robinson’s
remote access use. Electronic Systems. A violation of this policy may
result in disciplinary action up to and including
Mobile Devices
termination. This also includes any lost and/or
Devices enabling mobile operations including but stolen devices, including but not limited to
not limited to: laptops, personal digital assistants, laptops, mobile devices or any other company
smart phones, and USB storage devices equipment or information as this causes
(Flash/Thumb/U3 drives etc.) should be significant risk to the Company. You also will be
approved by management and are provided responsible for violations of this policy by others,
based on job responsibility. Personal use devices such as friends or family members, if you allowed
should never be connected to the network or its or permitted their use of the Company’s
component systems. Any data stored on Electronic Systems.
approved devices should be considered
Company Confidential Information. Any lost or Electronic Data and Communications Policy
stolen devices should be reported immediately to C.H. Robinson will provide, on request, additional
the IT Service Desk at 1-952-937-6752. information regarding the C.H. Robinson
Information Security Policy. Requests can be
Passwords
made by contacting privacy@chrobinson.com
The Company provides password security to with the subject line, “Information Security Policy
employees to safeguard access to its systems Request.”
and data. Each employee is responsible for
protecting the confidentiality of passwords.
Passwords should never be shared or stored in
readable form in computers or written down and
left in a place where unauthorized persons might
discover them. Employees should never share
passwords with other employees (including
supervisors), or individuals external to C.H.
Robinson. Authorized options exist via myQ and
Outlook in the event there is a valid business
reason for a C.H. Robinson employee to access
another C.H. Robinson employee’s email
information. The Service Desk can assist in these
instances.
Violations
These guidelines are intended to provide
employees with general examples of acceptable

Non-Discrimination and Anti-Harassment Policy

It is the policy of C.H. Robinson to give equal Sexual Harassment is defined as:
opportunity in employment, training,
Unwelcome sexual advances, requests for
compensation, promotion and all other terms and
sexual favors and other verbal or physical contact
conditions of employment to each individual
of a sexual nature constitutes sexual harassment
without regard to race, color, religion, gender
when:
(including pregnancy), sexual orientation, gender
identity, marital status, age, national origin,  submission to such conduct is made either
disability, military service or status, or any other explicitly or implicitly a term or condition of
legally protected category. We provide an individual’s employment;
reasonable accommodation to applicants and
 submission or rejection of such conduct by
employees with disabilities to enable them to be
an individual is used as a basis for
considered for and perform available positions for
employment decisions affecting such
which they are qualified.
individual; or
It is a violation of this policy for any employee to  such conduct has the purpose or effect of
cause or allow any form of discrimination to unreasonably interfering with an
occur. individual’s work performance or creating
an intimidating, hostile or offensive
Anti-Harassment Policy
working environment.
Harassment is a form of discrimination and is
strictly prohibited. Harassment can occur based No employee, whether in a management position
on any protected category, such as race, national or otherwise, shall engage in any unwelcome
origin, religion, age, gender (including physical contact or touching of another employee.
pregnancy), sexual orientation, etc. Harassment Sexual contact or touching is strictly prohibited.
based on sex can present unique issues, Words and actions also can be harassment just
including the possibility of unwelcome sexual like demands for sexual favors or unwelcome
advances. It is a violation of C.H. Robinson policy physical contact. For example, employees must
for any person to suggest, threaten or insinuate, not:
either explicitly or implicitly, that any employee’s
submission to, or rejection of, sexual advances  make harassing or threatening comments
will in any way, either positively or negatively, or gestures based on gender or any other
affect their working conditions. protected category;
 make unwelcome sexual insinuations or
Supervisors are also responsible to ensure that
innuendoes;
no activities are allowed to take place at work or
at Company-sponsored events that create a  make unwelcome suggestions or
harassing, intimidating, hostile, or offensive work invitations to social engagements;
environment based on sex or any other protected  use sexually oriented or degrading words
category. to describe an employee;
 use offensive or demeaning terms or
actions which have a sexual or other
improper connotation;

 make other verbal remarks or comments C.H. Robinson also will not tolerate harassment
or engage in other activities that of or by non-employees, such as customers,
unreasonably interfere with an individual’s dealers, contractors, visitors, or others.
work performance, or that create an
Disciplinary Action for Violation
intimidating, hostile, or offensive working
environment based on sex or other C.H. Robinson will not tolerate discrimination or
protected category; or harassment based on gender or any other
protected category within the work environment
 make inappropriate remarks about an
or at Company-sponsored events. If C.H.
employee’s physical appearance or
Robinson concludes that such discrimination or
anatomy, suggestions about an
harassment has occurred, appropriate
employee’s personal or sexual habits, or
disciplinary actions will be taken, up to and
threats of a sexual nature.
including termination of anyone involved in
Harassment on the basis of any other protected discrimination or harassment and those
characteristic is also strictly prohibited. Under this condoning or permitting such discrimination or
policy, harassment is verbal, written or physical harassment. The appropriate action will depend
conduct that denigrates or shows hostility or on the following factors: a) the severity, frequency
aversion toward an individual because of his or and pervasiveness of the conduct; b) prior
her race, color, religion, sex, sexual orientation, complaints made by the complainant; c) prior
gender identity or expression, national origin, complaints made against the respondent; and d)
age, disability, marital status, citizenship, genetic the quality of the evidence (e.g., first-hand
information, or any other characteristic protected knowledge, credible corroboration).
by law, or that of his or her relatives, friends or
associates, and that: Obligation to Report
C.H. Robinson requires each employee to help
a) has the purpose or effect of creating an
keep the Company free from discrimination or
intimidating, hostile or offensive work
harassment. If you see any form of harassment,
environment,
report it to your supervisor, the office or
b) has the purpose or effect of departmental manager, Human Resources, the
unreasonably interfering with an Legal Department, or utilize the anonymous
individual’s work performance, or reporting process. Any employee aware of
c) otherwise adversely affects an possible violations of these policies is required to
individual’s employment opportunities. report the situation so that it can be investigated
and appropriately addressed.
Any type of conduct which unreasonably
interferes with an employee’s work performance If you’re unsure whether a violation has occurred,
or which creates a hostile or intimidating working discuss it with your manager. Your manager will
environment based on gender or any other know or have the resources to determine whether
protected category is prohibited. the activity violates a corporate policy and what
steps should be taken. If for some reason you feel
Display or dissemination of materials (such as
that you cannot talk to your supervisor or a
cartoons, articles, pictures, etc.), which have a
member of management, or you wish to remain
sexual, racial, or other protected nature that is not
anonymous, you can talk to Navex, an
necessary for work may constitute harassment.
independent company trained to listen to

complaints and issues regarding C.H. Robinson’s depends in part on the successful implementation
Code of Ethics. Navex will take your information of these policies.
and pass it on to the Company for investigation
Managers and supervisors are encouraged to
and resolution. To report a violation
consult with Human Resources or the C.H.
anonymously, click here. This is not a dispute
Robinson Legal Department with any questions
resolution process. This is simply a process
or for assistance in investigating or addressing
which the Company uses to invite employees to
any possible violations of this Policy.
raise issues so that the Company can determine
whether policies have been violated and, if they No Retaliation for Reporting Suspected
have, take appropriate follow-up action. It is not Violations
sufficient to report a complaint of harassment or
C.H. Robinson prohibits any employee or
discrimination to any other person or department.
Company representative from retaliating in any
C.H. Robinson will take all reasonable measures way against anyone who has articulated any
to prevent harassment, including prompt concern regarding harassment, discrimination or
investigation of any complaint of harassment, and other violations of Company policies. No adverse
immediate and appropriate disciplinary action, action will be taken against a complaining
where warranted. employee as a result of making the complaint,
regardless of the outcome of the investigation,
Managerial Responsibility unless the complaint was not made in good faith.
Managers and supervisors have special No retaliation of any kind will occur or be tolerated
responsibilities when it comes to discrimination, for reporting an incident of suspected
including any form of harassment. discrimination or harassment.
Not only must managers and supervisors conduct Investigations will commence immediately upon
themselves in a manner consistent with these notification of the complaint, and will be
policies, they are also responsible for establishing conducted as expeditiously as possible. While the
and maintaining a climate in the workplace free Company cannot guarantee confidentiality of all
from discrimination or harassment, where all aspects of the investigation, it will make every
applicants and employees enjoy equal effort to protect the privacy interest of the
employment opportunity. Managers and accused offender and the alleged victim.
supervisors must be alert for incidents of
To the extent you have any further questions; you
discrimination or harassment and take prompt
should contact your supervisor, Human
corrective action in accordance with C.H.
Resources or the Legal Department.
Robinson policy. Their success in their jobs

Corporate and Worldwide Anti-Corruption Policy
Compliance with Law

It is C.H. Robinson’s policy to comply with the region’s Employee Handbook. Any Company
local, state, and federal constitutions of the employee should contact the Legal Department
countries in which we are conducting business for any questions about compliance with laws or
and all applicable laws. More specific details on this policy.
local, state and federal laws can be found in your

It is the policy of C.H. Robinson that all ‒ All C.H. Robinson employees in
employees of C.H. Robinson and its subsidiaries Global Forwarding and Project
fully comply with the U.S. Foreign Corrupt Logistics offices ;
Practices Act (“FCPA”) and similar worldwide ‒ All Sourcing employees;
anti-corruption statutes like the U.K. Bribery Act
‒ C.H. Robinson employees in certain
of 2010 and the OECD Anti-Bribery Convention.
offices along the U.S-Canadian and
The FCPA prohibits U.S. companies from,
U.S.-Mexico Borders;
directly or indirectly, making improper payments
to a foreign government official, politician, or ‒ All Executives;
political party to obtain or retain business or gain ‒ All Finance Managers;
an unfair advantage. The FCPA also requires that
‒ All Expats; and
companies keep accurate records of transactions
and transfers of assets, whether domestic or ‒ All Internal Audit employees
international. Employees must recertify and retake this training
every three (3) years except for employees in
As part of this worldwide anti-corruption program
certain designated countries (15 CFR 740,
at C.H. Robinson the following personnel are
Supplement No. 1 – Group E) where the training
required to undergo computer-based FCPA
is required every year. The training covers the
training that includes a test:
FCPA and other worldwide anticorruption
 All C.H. Robinson employees outside of statutes like the U.K. Bribery Act of 2010.
the US.
Specifically, the FCPA prohibits:
 Within the US:
“Making of an offer, promise to pay, payment
or authorization of a payment of money, a gift,
promise to give, or authorization of a gift or

anything of value to a foreign governmental A “routine governmental action” is one which is

official, political party or party official, ordinarily and commonly performed by a foreign
candidate for political office or any third party official but does not include any decision by a
knowing the thing of value will go to any such foreign official to award new business or to
person to influence an act or decision in an continue to do business with C.H. Robinson.
official capacity, or to induce a violation of a According to the U.S. Department of Justice’s
lawful duty, to secure an improper advantage, Guide to the U.S. Foreign Corrupt Practices Act
or to induce the person to influence a (2012) routine governmental actions include:
decision or act of a foreign government in
 Processing governmental papers, such as
order to obtain or retain business.”
visas and work orders;
The FCPA anti-bribery provisions apply to corrupt  Providing police protection, mail pick-up
payments made to any (1) foreign official; (2) any and delivery or scheduling inspections
foreign political party of official thereof; or (3) any associated with contract performance or
candidate for foreign political office. The definition transit of goods;
of “foreign official” includes any officer or
 Providing phone service, power and water
employee of a foreign government or any
supply, loading and unloading of cargo, or
department, agency, or instrumentality thereof, or
protecting perishable goods from
of a public international organization, or any
deterioration; or
person acting in an official capacity for or on
behalf of any such government or department,  Actions of a similar nature.
agency, or instrumentality, or for or on behalf of The FCPA prohibits a corrupt offer, payment,
any such public international organization. promise to pay, or authorization of the payment
Foreign government officials include not only of any money, offer, gift or anything of value to a
direct employees of a national, state, provincial or foreign official. The statute takes into
local government but also employees of state consideration that improper benefits can take
controlled enterprises. many forms such as gifts, meals or travel
The FCPA contains a narrow exception and expenses. First, the FCPA allows a small gift or
permits facilitation or expediting payments made token to show gratitude or respect in business.
in furtherance of “routine governmental actions” Also, items of nominal value like reasonable
(see below) related to nondiscretionary acts. C.H. meals, entertainment expenses or company
Robinson discourages and advises against such promotional items are generally permissible
payments and only in the rare situation will a under the FCPA. For example: it is permissible for
facilitation payment be permissible (e.g., expedite C.H. Robinson to pay the reasonable and bona
the process for an import permit if required in the fide travel, food and lodging expenses for a
country of import). C.H. Robinson only allows a foreign official provided that the payment is for
facilitation payment in the amount of $50 or less expenses that relate directly to the promotion,
per occurrence. Any situation requiring a demonstration, or explanation of C.H. Robinson
payment above this amount requires prior products or services, or to the execution or
approval of the Legal Department. C.H. Robinson performance of a contract with the foreign
also requires that any person who makes such a government or agency. However the offering or
payment must properly record and note it as such providing a gift or paying for a meal or travel
(“FCP”) in the system. expense must be lawful under the written laws
and regulations of the host country; and it must

be offered or given under circumstances in which  Agent’s relations with government

this practice is widely accepted and customarily officials;
practiced. Giving gifts, paying for meals, travel or  Third party consulting agreements that
entertainment made with a corrupt intent in return include only vaguely described services;
for official acts or to obtain or retain business are
 Requests for checks payable to “cash”;
prohibited even if they are otherwise valid under
the conditions stated above in this paragraph.  Unusual bonuses;
The FCPA does not contain a financial threshold  Media reports;
as to what is a justifiable, accepted or reasonable
 Unusual rebates; or
gift, payment or expense. Therefore, under this
Policy C.H. Robinson prohibits expenditures or  Other suspicious conduct.
payments made by employees to foreign officials The FCPA requires C.H. Robinson to maintain a
for any gifts, travel, meals and/or lodging system of internal accounting controls to ensure
expenses exceeding $50 per occurrence per that assets are safeguarded, transactions
person. Any payment to exceed $50 will require conform to management’s authorizations, and
review and approval by the Legal Department. In accounting records are complete and accurate.
no event shall any one foreign official receive FCPA regulations forbid a person from falsifying
more than $500 in travel, lodging or gifts over the accounting records and making misleading
course of the same fiscal year. financial statements to auditors or the Securities
and Exchange Commission. These accounting
Even if no payment or gift is made to a foreign
standards and record keeping requirements
official, payments made to third parties such as
apply to all employees of C.H. Robinson and
representatives or agents may constitute a
each of its subsidiaries.
violation of the FCPA if an employee is aware that
there is a substantial certainty that the third party C.H. Robinson employees will at all times strictly
will engage in an improper action to influence a comply with the accounting standards of the
foreign official by passing on all or a portion of the FCPA and C.H. Robinson’s internal accounting
payment. Under the FCPA a person “knows” in controls, including those requirements set out in
regards to certain conduct or circumstances if the the C.H. Robinson Accurate Books and Records
person is (1) aware that he/she is engaging in Policy.
such conduct, that such circumstance exists, or
In furtherance of these standards, the following
that such result is substantially certain to occur;
principles illustrate requirements that will govern
or (2) has a firm belief that such circumstance
your actions.
exists or that such result is substantially certain to
occur. Therefore, C.H. Robinson employees All financial and accounting records of C.H.
should be careful and look for certain potential Robinson shall be maintained so as to reflect
“red flags” when dealing or using third parties accurately, openly, and completely the
such as: operations and transactions of C.H. Robinson.
 The country in question is known for No false, artificial, or misleading entries in the
bribery; books and records shall be made.
 The reputation of the local agent or
No undisclosed or unrecorded funds or assets
representative;
shall be established or maintained.
 Unusually large or small commissions;

No payment shall be made with the intention or

understanding that all or any part of it is to be
used for any purpose other than that described in
the documents supporting the payment.
Employees certifying the correctness of the

records, including vouchers or bills, shall have
reasonable knowledge that information is correct
and proper.
Transactions shall be executed in accordance

with management’s general or specific
authorization.
Transactions shall be recorded as necessary to

permit preparation of financial statements in
conformity with generally accepted accounting
principles and the requirements of the U.S.
Securities and Exchange Commission and to
maintain accountability for assets.
Access to assets shall be permitted only in

accordance with management’s general or
specific authorization.
The recorded accountability for assets shall be

compared with the existing assets at reasonable
intervals, and appropriate action is taken with
respect to any difference.
The above requirements and principles are

illustrative only. If you have any questions or
concerns about the accounting standards and
record keeping requirements, you should contact
the Controller or Director, Internal Audit.

Accurate Books and Records Policy

It is C.H. Robinson’s policy to make and keep Some examples are:
detailed, accurate and complete financial records
 Time reports
for the time periods they are needed for business
purposes and as required by law.  Employee expense account records
 Invoices received by C.H. Robinson
Company Financial Records
 Invoices issued by C.H. Robinson
Accurate and reliable corporate financial records
shall be maintained at all times. All funds and  Recordings in the general ledger
other assets and all transactions for C.H.  Accounting journal entries
Robinson must be reflected in full detail and
 Contracts
promptly recorded in the appropriate C.H.
Robinson books. Accepted accounting principles  E-mails relating to transactions
must be used for all recording.  Transactions include all payments of
money, transfers of property, and
C.H. Robinson financial records must reflect an
furnishing of services.
accurate and verifiable record of all transactions.
Information that you record and submit to another All records and information must truthfully and in
party, whether that party is inside or outside C.H. reasonable detail reflect the substance of the
Robinson, must be accurate, timely, and transaction. There is no materiality standard. All
complete. You must not use any report or record transactions must be recorded correctly
to mislead those who receive them or to conceal regardless of amount. Examples of violations
anything that is improper. include:
Expense accounts are a particularly important  Records that fail to record improper
financial record. Employees are entitled to transactions;
reimbursement for reasonable business  Records that are falsified to disguise
expenses only if the expenses are actually aspects of improper transactions that were
incurred. For example, to submit an expense otherwise recorded correctly;
account for meals not eaten, miles not driven, or
 Records that correctly set forth the
airline tickets not used is dishonest reporting.
quantitative aspects of the transaction but
For purposes of this policy, financial records fail to record the qualitative aspects that
include all information pertaining to financial would have revealed their illegality or
transactions which are executed on C.H. impropriety.
Robinson’s behalf, including the proper recording The Records Management and Retention Policy
of all transactions, records received and kept in has been developed to provide all employees of
C.H. Robinson’s files related to financial C.H. Robinson with a comprehensive set of
transactions and all information recorded in the guidelines for the management, handling and
accounting records and financial statements of disposition of company documents and
C.H. Robinson. information, including financial records.

Applicable Laws and Regulations  Transactions are executed and access to

U.S. law, including the U.S. Foreign Corrupt assets is permitted only in accordance
Practices Act (“FCPA”), requires that C.H. with management authorization; and
Robinson’s financial records accurately reflect all  Transactions are recorded in a way so as
transactions, including any payment of money, to permit financial statements to be
transfer of property or furnishing of services. prepared in accordance with GAAP.
These transactions must be recorded accurately
No “Private” Business Records
regardless of whether the transactions are legal
at the place where the transaction occurs. Concerning transactions entered on behalf of
C.H. Robinson, there is no such thing as a
The FCPA establishes the following requirements “private” business record. Notes that you
with regard to record-keeping and maintain for your individual use at home are
communications. All employees are responsible subject to investigation and disclosure just as files
to comply with the following requirements: maintained on Company property are. All
Records pertaining to C.H. Robinson, including
 C.H. Robinson’s financial statements,
any you keep off of Company property, are
accounting records and all transaction
subject to the requirements of this Policy.
supporting documentation must accurately
reflect all transactions. Penalties
 All disbursements of funds and all receipts Dishonest reporting, both inside and outside the
must be properly, accurately and promptly Company, is not only strictly prohibited, it could
recorded. lead to civil or even criminal liability for you and
 All transactions must be recorded in C.H. Robinson. This includes reporting
reasonable detail to accurately and fairly information or organizing it in a way that is
reflect the substance of the transaction. intended to mislead or misinform those who
receive it. Particularly serious would be the
 No undisclosed or unrecorded fund may
external reporting of false or misleading financial
be established for any purpose.
information. This policy applies to all C.H.
 No false or artificial statements or entries Robinson employees, regardless of whether they
may be made for any purpose in the are U.S. citizens or not and regardless of whether
records of C.H. Robinson or in any the transaction at issue takes place within or
internal or external correspondence, outside the U.S.
memoranda, or communication of any
type, including telephone or wire Approval
communications. No transactions will be recorded in the accounts
 No employee shall intentionally allocate of the Company unless it is within the scope of
costs to contracts when those costs are written policies and procedures or is specifically
contrary to contract provisions or accepted and formally approved by designated individuals.
accounting practices.
Auditing
 The FCPA also requires C.H. Robinson to
Compliance with this corporate policy will be
devise and maintain a system of internal
tested and evaluated by the Company’s Internal
accounting controls sufficient to provide
Audit Department in connection with the ongoing
reasonable assurances that:
internal audit process.

Compliance with U.S. Sanctions & Embargoes (Transactions in Sanctioned and Embargoed
Countries) & the Prohibition on doing business with Restricted or Denied Persons/Entities
Compliance with U.S. Sanctions & Embargoes (Transactions in Sanctioned and

Embargoed Countries) & the Prohibition on doing business with Restricted or
Denied Persons/Entities
a. Sanctioned & Embargo Policy meets a statutorily defined exemption or
C.H. Robinson prohibits business with any exception. Absent one of these three C.H.
country the United State Government considers Robinson does not allow any U.S Office or
sanctioned or embargoed (unless authorized by overseas office/branch to ship any product to the
the U.S. Government) and does not allow any countries or engage in any business there.
transaction with a denied or restricted entity. Both b. Corporate Screening Process
the U.S. Treasury Department, Office of Foreign
Separate from its Sanction & Embargo Policy
Assets Control (“OFAC”) and the U.S. Commerce
C.H. Robinson maintains a comprehensive
Department, Bureau of Industry and Security
screening process for all shipments (exports,
(“BIS”) prohibit doing business in certain
imports, foreign to foreign etc.) in it is global
countries and forbid the exportation or
forwarding system. There are a total of thirteen
reexportation of certain commodities as well. The
(13) persons/entities in every transaction (e.g.,
countries OFAC presently maintains
shipper name and contact) that C.H. Robinson
comprehensive sanctions against and that BIS
screens against various U.S. prohibited persons
labels as “terrorist supporting” (15 CFR 740,
lists (e.g., OFAC Specially Designated National
Supplement No. 1) are Cuba, Iran, Syria, Sudan
List) as well as certain foreign lists (e.g.,
and North Korea. Although U.S. foreign policy
Japanese Proliferator Concerns). C.H. Robinson
can change over time these countries presently
centralizes its global screening process in certain
pose the greatest risk to C.H. Robinson as a U.S.
corporate employees known more formally as the
Company. The definition of “U.S. Persons”
Corporate Screening Team. The Corporate
includes: U.S. citizens, U.S. permanent resident
Screening Team performs all screenings for all
aliens, entities organized under U.S. law, foreign
shipments and records each review in the global
branches of U.S. companies that are not
forwarding system for future auditing purposes. If
separately organized under local law, and any
any positive hit is recorded against a list the
persons regardless of nationality physically within
transaction is terminated and the branch user,
the U.S.
branch manager and customer will be contacted
C.H. Robinson’s existing policy (C.H. Robinson’s and notified by C.H. Robinson’s Corporate
Sanction & Embargo Policy) only permits certain Screening Team.
items (medicine, medical product, food,
If there are any questions regarding C.H.
humanitarian relief etc.) to be exported to certain
Robinson’s business with sanctioned or
countries above if one of three conditions are
embargoed countries or our corporate screening
met: (1) the shipment is accompanied by a U.S.
process please contact the Legal Department.
Government issued License; (2) the shipment is
The written Sanction and Embargo Policy can be
authorized pursuant to a U.S. Government issued
found on WorkNet or you may contact the Legal
authorization; (3) the shipment is first reviewed or
Department for a copy.
approved by designated compliance experts and

Policy on Dealing with Government

It is C.H. Robinson’s policy to comply fully with all Corporate and Worldwide Anti-Corruption Policy
regulations and laws related to entering into a of this Code (page 21), any nominal gift giving
contract with the government and which governs (e.g., C.H. Robinson t-shirts) or meals etc.
contacts and dealings with government between a C.H. Robinson employee and a
employees and officials. government official is permissible only if it is
lawful under the written laws and regulations of
Businesses engaged in contracting with the
the specific country in which it occurs, is tied to a
government are legally required to report certain
legitimate business purpose, and there is no
information relating to contract negotiation, and
corrupt intent. For what is a nominal or
specifically to cost and pricing. This information
acceptable gift please refer back to the above
must be current, accurate, and verifiable. It must
cited sections on page 21. Where doubt or
also be complete up to and including the date of
uncertainty exists, you should contact the Legal
the contract. During contract negotiation with the
Department.
government, you should be prepared to
forthrightly disclose the significance of all material Federal law governs the appearance of conflict in
information. All statements, correspondence, and the employment, as an employee or contractor,
other communications should be accurate and of former government employees who go to work
truthful. for government contractors. Before you hire or
contract for the services of any former
Government employees, including government
government employee, you should clear the
procurement officials, whether at the national,
hiring with the Legal Department.
state, or local government levels, are subject to
special laws and regulations governing their Discussions with government employees
receipt of gifts and gratuities from organizations regarding future employment with C.H. Robinson
with which they do business. As stated in the can provide the appearance of improper
influence. You should never discuss the
possibility of future employment with any
government employee who is involved in the
negotiation, execution, and/or administration of a
government contract that C.H. Robinson is
associated with or of any with any government
employee who is involved in the regulation of any
industry which C.H. Robinson conducts business
in.
It is absolutely essential that the proper

procedures are followed in recording costs and
charging the government. It is particularly
important to make sure that all costs are allocated
to the proper account. It is never proper to charge
other accounts. If it becomes necessary to
transfer a charge, the transfer should be carefully

documented and recorded. Incorrectly charging All employees must avoid the appearance of
costs is a federal offense. involving C.H. Robinson in their personal political
activities. If a planned contribution or activity
Federal and state law prohibits parties seeking
could in any way be looked upon as involving
government contracts from soliciting or obtaining
Company funds, property, or services, you should
from government employees any “proprietary or
consult the Legal Department. When you speak
source selection” information (information about
out on public issues make sure that you do so as
bids by competitors or information regarding the
an individual. You should not give the
procurement process that would adversely affect
appearance that you are speaking or acting for
the fairness of the process) regarding a
C.H. Robinson.
government contract. This means you are
prohibited both from attempting to obtain the
information from the official, as well as receiving
the information even when the government
employee is willing to disclose it.
It is C.H. Robinson’s policy that all government

requests for interviews or documents be referred
to the Legal Department in order to facilitate a
prompt and thorough response to the
government. As an employee, you are entitled to
have counsel present to advise and assist you in
responding to governmental requests for
information or documents. Therefore, any time
you are approached by someone claiming to be a
government investigator, you should contact the
Legal Department before answering any
questions or producing any documents.
Employees who are participating in government
interviews are responsible for giving answers that
are truthful, complete, concise, accurate, and
unambiguous.
It is C.H. Robinson’s policy to comply with all

federal, state, local, and foreign laws regarding
political contributions. When corporate political
contributions are legal, contributions shall be
made only from funds allocated for that purpose
and only with the written approval of C.H.
Robinson’s Chief Executive Officer.

Fair Competition Policy
Anti-Money-Laundering Policy
Money-laundering in any form is strictly prohibited obtained. If an employee suspects that a
by C.H. Robinson. Under no circumstances proposed transaction or transfer involves
should any employee participate in or allow the illegally-obtained funds, they should decline to
commencement of any transaction at C.H. execute the transaction or transfer and report the
Robinson that involves any funds that the situation to their supervisor or the Legal
employee knows or suspects were illegally Department.
Fair Competition Policy

It is C.H. Robinson’s policy to sell our products The following are rules on how to treat customers
and services on their merits, not through the who are involved in contract negotiations with
disparagement of our competitors, their products competitors.
or services. False, misleading, or disparaging
Up until the moment a customer or prospective
remarks about individuals or their organizations,
customer has reached a mutual agreement with
products, or services are against company policy.
a competitor, C.H. Robinson has a right to
It is C.H. Robinson’s policy not to interfere in the
compete fairly and aggressively for that
business relationships of our competitors.
customer’s business;
No employee should make false, misleading, or
C.H. Robinson employees are not obligated to
disparaging comments about any competitor or
accept the statements of a competitor as to the
their products or services. Just as we want to
status of negotiations with a customer or
avoid competitors commenting unfairly about
prospective customer, nor must we accept the
C.H. Robinson, we want to avoid commenting
statements of a competitor as to the existence of
unfairly about them.
a contract;
When a customer (or prospective customer) tells
C.H. Robinson employees have a right to
C.H. Robinson that they have a contract for
communicate directly with a customer or
service with a competitor, C.H. Robinson
prospective customer as to the status of
employees then must do nothing to interfere with
negotiations or contracts between that party and
or cause a wrongful breach of that contract.
competitors.

Procurement Policy
Procurement Policy
C.H. Robinson purchases and leases billions of Robinson does not and will not deal on such
dollars’ worth of goods and services. The integrity terms.
of our business depends, in part, on proper
Participating in group boycotts, which is an
procurement. Responsible procurement
arrangement between C.H. Robinson and other
practices have a positive effect on shareholders,
purchasers that they will not buy from a particular
customers, regulators, and employees. It is C.H.
supplier or suppliers, is prohibited. If you are
Robinson’s policy to make purchasing decisions
approached by anyone proposing a group refusal
based on merit, regardless of the supplier of the
to do business with a particular supplier, you
product or services.
should immediately reject the proposal and report
C.H. Robinson prides itself on having an open- the incident to the Legal Department. Restrictive
door policy with respect to potential suppliers. We Agreements and Exclusive Dealing Agreements
will give fair and impartial consideration to every are against C.H. Robinson policy. We discourage
supplier and potential supplier. any supplier contract provision that restricts C.H.
Robinson’s freedom of choice in the selection of
No business with suppliers or other third parties
a product or service or in choosing to do business
should be affected by a personal conflict of
with another supplier.
interest, by favoritism, or by bias of any sort. The
practice of reciprocity, purchasing goods or All contract provisions (including those
services from another business on condition that arrangements which involve Exclusive Dealing or
it purchases goods or services from C.H. other Restrictive Agreements with suppliers and
Robinson is strictly prohibited. If a supplier customers) should be reviewed by the Legal
suggests any form of reciprocity, you should Department before an agreement is reached.
immediately make it clear to the supplier that C.H.

Advertising and Marketing Policy
Advertising and Marketing Policy

It is against C.H. Robinson’s policy to use any
false or misleading advertising or unlawful
sweepstakes or promotional give-a-ways in
connection with the sale or marketing of products
or services. It is appropriate to advertise C.H.
Robinson’s products aggressively using
techniques such as price comparisons or sales or
to develop lawful sweepstakes or promotions;
however, these techniques should only be used if
they are lawful and not false, deceptive or
misleading.
The advertising of products and services and the

marketing of such products and services through
the use of sweepstakes and/or promotional give-
a-ways is subject to numerous laws and
regulations. If you participate at all in
advertisement, sweepstakes and/or promotional
give-a-ways, you are encouraged to seek legal
advice from the Legal Department if you have any
concerns regarding the legality of any advertising
of C.H. Robinson products or services.
It is C.H. Robinson’s policy to avoid any price

advertising that is false or deceptive. Price or
value comparisons of products offered by C.H.
Robinson with products offered by our
competitors are generally permissible if genuine
and truthful.

Designated Spokesperson Policy
Designated Spokesperson Policy

It is C.H. Robinson’s policy to make clear, It is C.H. Robinson’s policy to channel the
accurate, complete, timely, and consistent disclosure of information about the company
disclosure of material information (any through specifically authorized and designated
information that a reasonable investor would spokespersons. Officers or employees who
consider important when deciding whether to buy, receive requests for media interviews must
hold or sell stock) about the Company. It is contact the designated spokesperson. The
furthermore C.H. Robinson’s policy that spokesperson will determine whether the officer
disclosure of previously non-public information be or employee may grant the interview, will make
made equally available to all segments of the the appropriate arrangements, and will advise the
market. This is true for all situations where officer or employee of the scope of the interview.
information is conveyed, no matter how The designated spokesperson may also choose
informally. to be present during the interview.
To achieve these goals more fully, C.H. Robinson In addition, the designated spokesperson and the
has centralized disclosure by appointing Legal Department must review and approve all
designated spokespersons who are the only C.H. company communications materials before they
Robinson personnel authorized to provide are distributed externally. This includes materials
broadly-disseminated information about C.H. such as sales brochures, sales presentations that
Robinson outside the company. The designated include new information that has not been
spokespersons are the Chief Executive Officer, previously approved, websites, advertisements,
the Chief Financial Officer and the Director of and newsletters. This review is to ensure that
Investor Relations. All contact with the media and confidential, non-public information is not
the investment community (e.g., press releases, inadvertently disclosed, that all information is
answers to reporter’s questions, etc.) must go accurate, and to provide as much consistency as
through these spokespersons. possible in our external communications.

There are a number of policies related to
information disclosure that all C.H. Robinson’s
employees should understand. These policies
include:
 C.H. Robinson does not disclose

proprietary information unless legally
required to do so;
 C.H. Robinson does not discuss possible
future financial performance except in very
general terms;
 C.H. Robinson does not discuss pending
rate activity, tariff filings, etc, until all
appropriate parties have been notified;
 C.H. Robinson does not disclose
information about employees other than
biographical information for certain key
employees.
Only authorized employees are allowed to make

postings to company-sponsored external
websites. Online social networking, blogging or
any other form of online publishing or discussion
activities on websites that are not company-
sponsored are individual communication
exchanges, and are not corporate
communications.
Only the company-designated spokespersons

are authorized to broadly-disseminate
information about C.H. Robinson outside the
company. If you participate in activities of social
networking, blogging, or any other form of online
publishing or discussion, please refer to the
section Social Networking and Blogging within
the Electronic Data and Communications Policy.

Compliance with Insider Trading

If you have knowledge of insider information securities only during a quarterly trading window,
and/or if you trade in C.H. Robinson securities or which shall open on the third trading day after the
the securities of other companies trading on the release of quarterly earnings results to the public
U.S. stock exchange, you are subject to U.S. and shall remain open through the last day of the
securities laws, as well as any other securities or second month of the quarter. In addition, all
insider trading laws that may apply to you locally. financial insiders are subject to the preclearance
requirement within this policy. Financial insiders
The law prohibits a director, officer or employee
include all directors, executive officers and other
of C.H. Robinson Worldwide, Inc. (the
employees with access to financial reporting
“Company”), who is aware of material nonpublic
information who are identified on a quarterly
information relating to the Company, from directly
basis.
or indirectly through family members or other
persons or entities, (a) buying or selling securities If a financial insider has established a pre-
of the Company (other than pursuant to a trading arranged trading program (a “10b5-1 Program”)
plan that complies with SEC Rule 10b5-1 as that (a) meets the requirements of Rule 10b5-1
described below), or engaging in any other action promulgated under the Securities Exchange Act
to take personal advantage of that information, or of 1934, (b) was established at a time when the
(b) passing that information on to others outside financial insider was not in possession of material
the Company, including family, friends or nonpublic information, and (c) was approved in
affiliated entities. advance by the Company’s Chief Legal Officer,
then that person may sell or purchase Company
In addition, the law prohibits all employees who
securities while in possession of material
learn of material nonpublic information about a
nonpublic information or during other periods in
company with which the Company does
which the Company has required or
business, including a customer or supplier of the
recommended the suspension of trading, so long
Company, from trading in that company’s
as any sales or purchases are made pursuant to
securities until the information becomes public or
the 10b5-1 Program.
is no longer material.
Material Information.
It is the policy of the Company to comply fully with
the laws on insider trading. Therefore, if you have Material information is any information that a
obtained any material nonpublic information reasonable investor would consider important in
relating to the Company, or to another company making a decision to trade in securities. Any
with which C.H. Robinson has done or is doing information that could be expected to affect the
business, you may not buy or sell securities of Company’s stock price, whether it is positive or
such company or engage in any other action to negative, should be considered material.
take advantage of, or pass on to others, that Common examples of information that may be
information. regarded as material includes:
In addition, the Company’s policy is to prohibit  Information about a transaction that will
certain financial insiders from trading during a significantly affect the financial condition
closed period, and to require pre-clearance of all of a company;
trades by executive officers. All financial insiders  Projections of future earnings or losses;
of the Company may purchase or sell Company

 News of a significant sale of assets or the responsible for the transactions of these other
disposition of a subsidiary; persons or entities and therefore should make
 Changes in dividend policies of a them aware of the need to confer with you before
company or the declaration of a stock split they trade in the Company’s securities.
or the offering of additional securities; Violations of Policy
 Certain changes in management; Failure to comply with the Company’s Insider
 Significant new products or discoveries; Trading Policy may subject an employee or
 Impending bankruptcy or financial liquidity director to Company-imposed sanctions,
problems; including termination of employment or removal
from the Board for cause, whether or not the
 The gain or loss of a substantial customer
failure to comply results in a violation of law.
or supplier.
Event-Specific Blackout Periods
When Information is “Public.”
From time to time, an event may occur that is
If you are aware of material nonpublic
material to the Company and is known by only a
information, you may not trade until the
few directors or officers. So long as the event
information has been disclosed broadly to the
remains material and nonpublic, Section 16
marketplace (such as by press release or an SEC
Insiders and such other persons as are
filing) and the investing public has had time to
designated by the Chief Legal Officer may not
absorb the information fully. As a general rule,
trade in the Company’s securities. Any person
information should not be considered fully
made aware of the existence of an event-specific
absorbed by the marketplace until after the
blackout should not disclose the existence of the
second business day after the information is
blackout to any other person. The failure of the
released. If, for example, the Company were to
Chief Legal Officer to designate a person as
make an announcement on a Monday, you may
being subject to an event-specific blackout will
not trade in the Company’s securities until
not relieve that person of the obligation not to
Thursday. If an announcement were made on a
trade while aware of material nonpublic
Friday, Wednesday generally would be the first
information.
eligible trading day.
Who to Call for Assistance
Transactions by Family Members or Others.
If you have questions about our Insider Trading
The Insider Trading Policy also applies to your
Policy or its application to any proposed
family members who reside with you, anyone else
transaction, please contact Ben Campbell, by
who lives in your household, and any family
phone at (952) 937-7829 or by email at
members who do not live in your household but
ben.campbell@chrobinson.com, or Troy A.
whose transactions in Company securities are
Renner, by phone at (952) 937-6721 or by email
directed by you or are subject to your influence or
at troy.renner@chrobinson.com. Ultimately,
control (such as parents or children who consult
however, the responsibility for adhering to our
with you before they trade in Company
Insider Trading Policy and avoiding unlawful
securities). In addition, the Insider Trading Policy
transactions rests with the individual employee,
applies to entities (e.g., family trusts, foundations
officer or director. To see a copy of the policy in
or similar entities) whose transactions in
its entirety, click here or contact the legal
Company securities are directed by you or are
department.
subject to your influence or control. You are

Anti-Boycott Policy
Anti-Boycott Policy
It is C.H. Robinson’s policy to comply with all U.S. the export of goods and services from those
laws and regulations governing attempts to countries to Israel. However, the Arab boycott
boycott countries friendly to the U.S. Employees also precludes dealings with firms and persons in
of C.H. Robinson may not make any agreements, third countries which have been “blacklisted” by
take any action, or provide any information that the boycotting countries for doing business in or
might assist a boycott, which violates these laws with Israel. Complying with or supporting any
and regulations. aspect of the boycott of Israel is prohibited by this
Policy.
This policy applies to every C.H. Robinson
employee in any company, division, controlled-in- Prohibited Acts under the Anti-Boycott Laws
fact subsidiary, U.S. or foreign, or market unit or The Anti-Boycott Laws prohibit C.H. Robinson,
business unit, including joint ventures where C.H. including its divisions, controlled-in-fact
Robinson maintains management control. The subsidiaries, and controlled joint ventures
laws referred to in this Policy include the Tax anywhere in the world from engaging in the follow
Reform Act of 1976, the Export Administration Act acts:
of 1979, as amended, and the Internal Revenue
Service and Commerce Department regulations  refusing or agreeing to refuse to do
which implement these Acts (the “Anti-Boycott business with or in Israel or with any entity
Laws”). or person resident in Israel under an
agreement with a boycotting country or in
While the Anti-Boycott Laws prohibit C.H. fulfillment of a requirement or request by a
Robinson from doing anything that complies with boycotting country;
or supports a boycott not supported by the U.S.
 discriminating against any individual on
government, the principal boycott targeted by the
the basis of race, religion, sex or national
Anti-Boycott Laws is a boycott of Israel enforced
origin or against any corporation or
by members of the Arab League. The primary
organization on the basis of the race,
boycott bars the importation of Israeli goods and
religion, sex or national origin of its
services into the boycotting countries and bars
employees, officers, directors or owners;
 furnishing information about the race,
religion, sex or national origin of any
individual or about the race, religion, sex
or national origin of the employees,
officers, directors, or owners of any
corporation or organization;
 furnishing information about C.H.
Robinson’s or any other person’s past,
current or proposed business relations
with or in Israel, with an entity organized
under the laws of Israel, with any national
or resident of Israel, or with any person or
entity on or believed to be on a blacklist;

Anti-Boycott Policy
 furnishing information about whether any take any action or refrain from taking any action
person is a member of or has made which could be considered in furtherance or
contributions to charitable or fraternal support of a prohibited boycott (a “Boycott
organizations which support Israel; or Request”) to the U.S. Department of Commerce.
 implementing letters of credit which Because C.H. Robinson is required to report this
contain terms or conditions which violate information to the authorities in a prescribed form
the Anti-Boycott Laws. and within a specified time, you must immediately
Exceptions to Prohibited Acts report any Boycott Request to the lawyer
supporting your organization or the Legal
C.H. Robinson may engage in the following
Department. No further action may then be taken
actions without violating the Anti-Boycott Laws:
in response to the Boycott Request without
 Comply with or agree to comply with a specific authorization from the responsible
request from a boycotting country that lawyer.
prohibits the import of goods from Israel or
Illustrations of Prohibited and Permissible Acts
provided by an individual or organization
under the Anti-Boycott Laws
resident in Israel;
 Comply with a request from a boycotting The Anti-Boycott Laws contain numerous specific
country that goods not be shipped on a examples of prohibited and permissible acts in
carrier of Israel other than pursuant to a relation to a prohibited boycott. The following are
specific route of shipment; merely a few examples of prohibited and
permissible acts under the Anti-Boycott Laws.
 Comply with the import and shipping
document requirements of the boycotting Prohibited: Refusing to use a specific carrier or
country with respect to naming the country insurance company in respect of a shipment of
of origin of goods, the name and goods because you know that the carrier or
nationality of the carrier, the route of insurance company is on the Arab blacklist for
shipment and the name, nationality and doing business with Israel.
address of the supplier;
Permitted: In shipping goods to a particular
 Comply with the unilateral and specific
boycotting country, you select carriers only from
selection by a boycotting country of
among carriers you know call at ports in the
carriers, insurers, and suppliers of goods
boycotting country.
or services; and
 Comply with the boycotting country’s Prohibited: Stating the origin of goods in negative
export requirements with respect to terms, such as a statement that “the goods
shipments of exports from the boycotting covered by this invoice are not of Israeli origin.”
country to Israel, a business concern Permitted: Agreeing as a condition of a contract
organized in Israel or any national or with a boycotting country that services rendered
resident of Israel. pursuant to the contract will not be provided by
Reporting Requirements residents or nationals of Israel.
C.H. Robinson, its subsidiaries, affiliates, agents, Prohibited: Discriminating against any U.S.
and representatives must promptly report the person on the basis of race, religion or national
receipt of any request to supply any information, origin. For example, you may not discourage

Anti-Boycott Policy
Israeli nationals from applying for jobs in Arab Prohibited: Responding to a questionnaire from a
countries, even if you know they would not be boycotting country seeking information about the
able to get a work permit. race, religion or national origin of the members of
the board of directors of any C.H. Robinson
Permitted: Replacing persons to whom the Arab
company.
government refuses to give a work permit on the
basis of such persons’ race, ethnicity or Permitted: In opening a new subsidiary or branch,
nationality. a boycotting country requires information on the
nationalities of the members of the board of
Prohibited: Furnishing any information about
directors of the shareholder; you can provide
whether C.H. Robinson or any other person has
information on the nationalities of such persons,
any business relationship with or in a boycotted
but not information about their race, religion or
country. For example, you may not sign a
national origin.
statement stating that C.H. Robinson has no
dealings with Israel or is not on the Arab blacklist. In all cases, it is prohibited to take any action
which has as its purpose the evasion of the
Permitted: Furnishing normal business
prohibitions set out in the Anti-Boycott laws. For
information in a commercial context. For
example, you cannot sell goods to Saudi Arabia
example, as part of a tender for a contract in a
through a shell corporation which signs
boycotting country, you may furnish copies of
statements saying that it will not deal with Israel.
C.H. Robinson’s annual report which describes
its business and locations of worldwide The above examples are illustrative only and by
operations for the purpose of demonstrating C.H. no means intended to be complete. To the extent
Robinson’s financial fitness, technical you have any further questions, contact the Legal
competence and professional experience. Department.
Prohibited: You choose from among a list of Penalties

carriers, insurers, or suppliers of goods provided Violations of the Anti-Boycott Laws are subject to
by and acceptable to the boycotting country. severe penalties. These penalties may include
Permitted: You agree to use a specifically named denial or suspension of export privileges, civil and
carrier, insurer, or supplier of goods named by the criminal penalties, and even imprisonment for
boycotting country. individuals.

Compliance with the Code of Ethics
COMPLIANCE WITH THE CODE OF ETHICS

In order to maintain an effective compliance
program, C.H. Robinson has set up a Compliance
Committee whose responsibility it is to provide
oversight of administration and enforcement of
the Company’s Code of Ethics.
The Compliance Committee is made up of the

following individuals:
 Chief Financial Officer,

 Chief Human Resources Officer,
 Chief Legal Officer, and
 One or more Vice Presidents of
Operations.
Upon hire and annually thereafter, all employees
In order to ensure the effectiveness of its Code of
will be required to review the Code. Each
Ethics, C.H. Robinson has procedures for:
employee must certify that he or she has received
 Verification of the prompt distribution of the documents, read and understood their
the Code of Ethics to new and existing contents and agrees to abide by the letter and
employees; spirit of each. In addition, each employee will be
required annually to certify that they have not
 Verification of training on the Code of
committed any violations and are not aware of
Ethics for new employees, and periodic
any violations by others. Managers are
training on key Code sections, as
responsible for ensuring that their employees
warranted;
comply with the Code.
 Verification of the certification process by
which employees affirm that they have From time to time, C.H. Robinson will find it
read and understand the Code of Ethics; necessary to have auditors and investigators
involved in the process of reviewing and auditing
 Verification of the use of the e-mail
the effectiveness of our Code of Ethics. It is
Compliance Hotline (“Hotline”) to report
necessary that you fully cooperate with their
violations including review of the number
investigations.
of reported violations as well as other
information received through the Hotline; After a prompt and thorough investigation of a
 Verification of the internal investigation compliance issue, an employee determined to
and discipline process, including the have engaged in a violation will be subject to
confidentiality and thoroughness of the discipline under this policy, up to and including
investigations and documentation; and termination. It is the policy of C.H. Robinson to
apply its discipline in a reasonable and consistent
 Verification that reprisals are not being
fashion; however, the form of discipline which is
taken against employees who report
appropriate will be case-specific.
violations.
There are certain offenses and violations which
are so serious that immediate dismissal is proper

in all cases. For guidance as to these particular address minor violations, while serious violations
offenses and violations, contact Human may merit a full and formal investigation by
Resources or the Legal Department. counsel.
Determining whether a violation occurred is There are, however, certain principles which will
perhaps the most important step in the process of be constant from case to case.
enforcing the Code of Ethics. Given the variety of
In all cases, the employee will be given advance
possible violations, and the range of
notice and an opportunity to explain his or her
circumstances in which they can occur, C.H.
actions.
Robinson cannot employ a uniform procedure for
the investigation and determination of violations. In all cases, the supervisors or managers
In some cases, informal meetings between directing the investigation will carefully document
supervisors and employees may be sufficient to all actions taken and decisions reached.

Additional Responsibilities for Supervisors & Managers
Additional Responsibilities for Supervisors & Managers

You play a unique role in creating an open and
trusting environment where employees are
comfortable asking questions or talking about
ethical issues. You are also responsible for
preventing intimidation or retaliation against
those who report suspected violations or
cooperate with any investigations.
Start by setting a good example in all actions and

decisions. Demonstrate your personal
commitment to the ethical and legal principles in
this Code by:
 Demonstrating what it means to act with

integrity; Making sure all employees
understand and comply with all laws and
the Code;
 Incorporating control measures in
business processes and conducting
compliance reviews as appropriate;
 Supporting employees who, in good faith,
ask questions and raise concerns; and
 Taking immediate action if you become
aware of violations of this Code or the law
and reporting them immediately.

Reporting and Investigating Violations of the Code of Ethics
Reporting and Investigating Violations of the Code of Ethics

Employees are required to promptly report any
known or suspected violations of the laws or the
Code of Ethics. Employees may report incidents
to their supervisor, the Legal Department, Human
Resources, or click here to report violations
anonymously. Reports of suspected violations of
the law or of company policy will be promptly,
discreetly and thoroughly investigated.
Employees who report violations of the law or of
the Code of Ethics in good faith will not be subject
to retaliation. Failing to report or condoning a We take reasonable precautions to maintain the
violation of the law or Code of Ethics may lead to confidentiality of those who report violations of
disciplinary action up to and including the law or the Code of Ethics. This confidentiality
termination, unless such reporting is prohibited by includes both the confidentiality of the person
law in the country where the employee is located. making the report as well as the person about
This is not the case in the U.S. whom the report is made. There may be
instances, however, where we cannot assure this
Any report submitted will be documented and the confidentiality for reasons beyond our control. To
reporting party may request information uphold the integrity of the investigation,
regarding the final disposition of the report. employees involved or who have made reports
are asked to maintain confidentiality of the
Most reports should be addressed to your
information involved in the investigation.
immediate supervisor. If you feel uncomfortable
reporting a problem to your supervisor, you can It is absolutely forbidden for any employee to
report violations anonymously, or report your punish or conduct reprisals against another
concerns to the Legal Department or Human employee who has reported a suspected violation
Resources. of the law or of the Code of Ethics. This includes
anything affecting the employee’s working
We will take all reasonable steps to investigate
conditions or status; including, but not limited to
reported violations promptly and thoroughly. All
wages, hours, bonuses, and work stations.
employees are expected to cooperate fully with
internal investigations.

©2017 C.H. Robinson Worldwide, Inc. All Rights Reserved.

C.H. Robinson Code of Ethics (English) PDF

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C.H. Robinson Code of Ethics (English) PDF

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Mission, Vision and Values

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 1

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 2

Mission, Vision and Values 6

Compliance with the Code of Ethics 40

Additional Responsibilities for Supervisors & Managers 41

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 3

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 4

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 5

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 6

Protection of Information Assets, Personal Data, and Company Property

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 7

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 8

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 9

No employee who deals with individuals or

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 10

 Have the potential to create an adverse Loans

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 11

Records Management and Retention Policy

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 12

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 13

Electronic Data and Communications Policy

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 14

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 15

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 16

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 17

Non-Discrimination and Anti-Harassment Policy

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 18

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 19

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 20

Compliance with Law

Corporate and Worldwide Anti-Corruption Policy

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 21

anything of value to a foreign governmental A “routine governmental action” is one which is

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 22

be offered or given under circumstances in which  Agent’s relations with government

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 23

No payment shall be made with the intention or

Employees certifying the correctness of the

Transactions shall be executed in accordance

Transactions shall be recorded as necessary to

Access to assets shall be permitted only in

The recorded accountability for assets shall be

The above requirements and principles are

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 24

Accurate Books and Records Policy

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 25

Applicable Laws and Regulations  Transactions are executed and access to

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 26

Compliance with U.S. Sanctions & Embargoes (Transactions in Sanctioned and

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 27

Policy on Dealing with Government

It is absolutely essential that the proper

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 28

It is C.H. Robinson’s policy that all government

It is C.H. Robinson’s policy to comply with all

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 29

Fair Competition Policy

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 30

©2018 C.H. Robinson Worldwide, Inc. All Rights Reserved. 31

Advertising and Marketing Policy

The advertising of products and services and the

It is C.H. Robinson’s policy to avoid any price