Code of Conduct

Last updated April 20, 2022

At United Global Trading Corp. (UGTC), we are proud to be a leading international trading company dedicated to delivering exceptional products and services to our customers worldwide. Our success is built on a foundation of strong ethical principles, professionalism, and a commitment to excellence.

Our core values – Trust, Relationships, Adaptability, Diversity, and Excellence (T.R.A.D.E.) – guide our actions and decisions every day. These values shape our corporate culture and drive us to continually improve and innovate, ensuring we exceed our customers’ expectations.

By embracing our Code of Conduct and championing our TRADE Core Values, we are confident in our ability to generate value for our customers, employees, and stakeholders, all while making a positive impact on the environment and society.

Table of Contents

Introduction and Purpose

United Global Trading Corp. (UGTC) is committed to conducting business ethically, responsibly, and in compliance with all applicable laws and regulations. Our Code of Conduct serves as a guide for our employees, directors, officers, agents, contractors, consultants, and other representatives of the Company. This Code of Conduct reflects our core values – Trust, Relationships, Adaptability, Diversity, and Excellence (T.R.A.D.E.) – which form the foundation of our corporate culture.

Scope and Applicability

This Code of Conduct applies to all employees, directors, officers, agents, contractors, consultants, and other representatives or vendors associated with UGTC. Everyone is expected to adhere to the principles and guidelines set forth in this document.

Ethical Principles and Core Values - T.R.A.D.E

At UGTC, we embrace the following ethical principles and values:

  1. Trust: Build and maintain trust with our customers, suppliers, partners, and colleagues by being reliable, honest, and transparent in all our business interactions.

  2. Relationships: Build and maintain strong, long-lasting relationships within the global supply chain community and with our customers. We are committed to working closely with our suppliers to ensure that we can continue to provide our customers with the best possible products and services. 

  3. Adaptability: Embrace change and remain agile, responsive, and resilient in the face of evolving market conditions, regulations, technology, and customer needs. Our ability to adapt enables us to remain competitive and achieve long-term success in the global marketplace.

  4. Diversity: Value and promote diversity and inclusion within our organization and in our business relationships, recognizing that diverse perspectives and experiences contribute to better decision-making and a more innovative and successful company.

  5. Excellence: Strive for the highest standards of quality and performance in our products, services, and operations, and consistently deliver exceptional value to our customers and stakeholders.

Our Workplace

  1. Employee Privacy

  • UGTC respects the privacy of all employees and is dedicated to protecting their personal information. Personal information shall be collected, used, and disclosed only as required for legitimate business purposes or as required by law.
  • Employees must respect the privacy of their colleagues by refraining from sharing or discussing any confidential or personal information about others without consent, unless required by law or for legitimate business purposes.

  1. Equal Employment Opportunity

  • UGTC is committed to providing equal employment opportunities for all individuals, regardless of race, color, religion, gender, age, national origin, disability, sexual orientation, gender identity, or any other protected status.
  • All employment decisions, including recruitment, hiring, promotion, compensation, and termination, shall be made based on merit, qualifications, and job-related criteria without regard to any protected status.


  1. A Respectful Work Environment

  • UGTC is dedicated to maintaining a work environment free of discrimination, harassment, and bullying. All employees are expected to treat each other with respect, dignity, and professionalism.
  • Any form of harassment, including sexual harassment, racial or ethnic slurs, derogatory comments, or bullying, is strictly prohibited, and will not be tolerated.
  • Employees are encouraged to report any incidents of discrimination, harassment, or bullying to their supervisor, the human resources department, or UGTC’s Compliance Officer, without fear of retaliation.

  1. Teamwork and Collaboration

  • UGTC values teamwork and collaboration as crucial elements of our success. All employees are expected to work cooperatively with their colleagues, contribute positively to team dynamics, and share knowledge and expertise to help achieve common goals.
  • Employees should actively participate in team activities, meetings, and discussions, and maintain open lines of communication to foster a supportive and collaborative work environment.

  1. Safe and Injury-Free Workplace

  • UGTC is committed to providing a safe and healthy work environment for all employees. We comply with all applicable health and safety laws, regulations, and best practices.
  • Employees are expected to follow all safety policies and procedures, report any unsafe conditions or incidents, and actively participate in any safety briefings or initiatives.
  • Employees should never engage in activities that pose a risk to their own safety, the safety of their colleagues, or the public.

  1. Drug-Free Workplace

  • UGTC is committed to maintaining a drug-free workplace. Employees are prohibited from using, possessing, distributing, or selling illegal drugs, controlled substances, or prescription medications without a valid prescription while at work or representing the company. Drug and alcohol testing may be conducted as permitted by law.

Doing Business with Integrity

  1. Conflict of Interest

  • Company representatives must avoid situations in which their personal, financial, or other interests may conflict or appear to conflict with the best interests of the Company. This includes, but is not limited to, having significant financial interests in competitors, suppliers, or customers; engaging in outside employment that interferes with job performance or compromises company interests; or using company resources for personal gain. If a potential conflict of interest arises, it must be disclosed to a supervisor or the UGTC Compliance Officer for guidance and resolution.

  1. Gifts and Entertainment

  • All gifts and hospitality provided or received by the Company, or its representatives must be reasonable, proportionate, and in line with local customs, laws, and business practices.
  • Gifts and hospitality must not be offered or accepted with the intention or expectation of receiving or providing an undue advantage or influencing business decisions.
  • Employees must report and obtain approval from their supervisor or the UGTC Compliance Officer before offering or accepting any gifts or hospitality that exceed the company threshold. Please refer to the Gifts and Entertainment Policy for company reporting thresholds and further information.

  1. Compliance with Laws and Regulations

  • All employees must comply with all applicable local, national, and international laws and regulations relevant to their job responsibilities and UGTC’s business operations. This includes, but is not limited to, import/export laws, trade regulations, customs compliance, and tax laws.
  • As an international trading company, UGTC operates throughout the world and employees must be aware of and adhere to the specific requirements in each country where we conduct business. The company will provide briefings and training for employees stationed in or traveling to foreign countries on relevant customs, laws, and regulations.
  • Employees are encouraged to ask questions and seek guidance from their supervisor or the UGTC Compliance Officer if they are unsure about any legal or regulatory requirements.

  1. Sales Practices and Advertising

  • UGTC is committed to honest, ethical, and transparent sales practices and advertising. All communications, promotions, and marketing materials must accurately represent our products and services and be in compliance with applicable laws and regulations. Employees must not engage in misleading, deceptive, or manipulative sales tactics or make false claims about our products or services.
  • Additionally, employees are expected to respect the intellectual property rights of others, including trademarks, copyrights, and patents, when creating advertising or promotional materials.

Abide by Fair Trade Principles

  1. Fair Competition and Anti-Trust

  • UGTC is committed to fair and ethical competition. Employees must comply with all antitrust and competition laws and avoid any activity that could be construed as anti-competitive, such as price-fixing or market manipulation.

  1. Anti-Corruption and Bribery

  • UGTC has a zero-tolerance policy for bribery and corruption. All employees must comply with the U.S. Foreign Corrupt Practices Act and any other applicable anti-bribery and anti-corruption laws. Employees are prohibited from offering, giving, soliciting, or receiving any form of bribe or kickback including:
    • Offering, promising, or giving bribes or other undue advantages to public officials, private individuals, or business entities.
    • Requesting, agreeing to receive, or accepting bribes or other undue advantages.
    • Facilitation payments, or “grease payments,” made to expedite or secure government contracts.

Protection of Company Assets

UGTC employees involved in financial processes are responsible for maintaining accurate and transparent financial records. All financial reporting must adhere to applicable laws, regulations, and accounting standards.

Reporting and Whistleblower Protection

UGTC encourages employees to report any suspected violations of this Code of Conduct, company policies, or applicable laws and regulations. Employees can report their concerns to their supervisor, the Compliance Officer, or through the company’s anonymous reporting channel. UGTC is committed to protecting whistleblowers and maintaining the confidentiality of their identity to the extent possible, consistent with applicable laws and the need to conduct a thorough investigation.

Enforcement and Disciplinary Action

Violations of this Code of Conduct may result in disciplinary action, up to and including termination of employment or termination of contracts with third parties. In some cases, legal repercussions may also apply.

Training and Communication

UGTC is committed to providing regular training on this Code of Conduct and promoting open communication about ethical concerns. Employees are expected to participate in training sessions and familiarize themselves with the principles and guidelines outlined in this document.

Periodic Review and Updates

UGTC will periodically review and update this Code of Conduct to ensure its continued relevance and effectiveness. Employees will be informed of any significant changes and are expected to comply with any updates.

By implementing and enforcing this Code of Conduct, United Global Trading Corp. demonstrates its commitment to conducting business ethically and responsibly, fostering a positive work environment, and upholding its reputation for integrity. This commitment not only protects the Company and its stakeholders but also contributes to a fair and transparent global marketplace.