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Aramex Legal

Website Terms of Use

The terms of use for this Aramex website, www.aramex.co.za (the “Website”) operated by Aramex PJSC (“Aramex”) are applicable to all users (“you” and “your”) of the Website. By accessing the Website, you are deemed to agree to the following terms and conditions, the Privacy Policy; and any other relevant policies, terms and conditions and notices (collectively referred to as the “Terms of Use”) which are currently applicable or will be applicable to your use of the Website, without qualification.
If you do not agree to these Terms of Use, then you must stop using or accessing the Website.

1. Intellectual Property Rights

All intellectual property rights in the contents of the Website are owned by Aramex, its affiliates, or its licensors and is protected by copyright, trademark, and other applicable laws.

All content included on the Website, including without limitations text, graphics, logos, button icons,images, software, films, audio clips, downloads, interfaces, code, software, and the compilation of all content on the Website is the exclusive property of Aramex or its licensors and is protected by international copyright, trademark, and other applicable laws.

All trademarks, logos, service marks and trade names displayed on this Website are the registered and/or unregistered trademarks of Aramex or its affiliates, or third party trademark or trade name holders.

No part of the Website may be copied, reproduced, modified, transmitted, stored or exploited forcommercial gain, as part of any other website or in any other form, whether electronic or otherwise,without the prior written consent of Aramex, except that you may print or download to your harddrive or other storage device extracts from the Website for your own personal or internal business use. Any other use, including the reproduction, modification, distribution, transmission,republication, display, or performance, of the content of the Website is strictly prohibited and constitutes breach of these Terms of Use. Your use of the Website does not entitle you to any intellectual property rights in the contents of the Website other than limited right of use granted to you under these Terms of Use. Any unauthorized use of the Website may result in a violation of intellectual property laws, the laws of privacy and publicity, and communication regulations and statutes.

2. Use of Website

You may not use any “page-scrape”, “robot”, “spider” or other automatic device, program, algorithm or methodology, or any similar or equivalent manual process, to access, acquire, copy or monitor any portion of the Website, or in any way reproduce or circumvent the navigational structure or presentation of the Website, to interrupt or attempt to interrupt the operation of the Website, to obtain or attempt to obtain any materials, documents or information through any means not purposely made available through the Website.

You may not attempt to gain unauthorized access to any portion or feature of the Website, or any other systems or networks connected to the Website, or to any of the services offered on or through the Website, by hacking, password “mining” or any other illegitimate means.

We reserve the right, at any time, to restrict or terminate your access to, or use of the Website if you breach these Terms of Use or for any other reason whatsoever without notice. Termination or restricting your access or use will not waive or affect any other right or relief to which we may be entitled, at law or in equity.

3. Linking

The contents of the Website may include links to third party websites (“Linked Sites”). These links are provided to you only as a convenience, and are beyond the control of Aramex.

The inclusion of any Linked Site does not imply Aramex’s endorsement of that Linked Site. You acknowledge that your use of, or reliance on, any Linked Site will be at your own risk. Aramex recommends that you carefully review the privacy policy and all terms and conditions of Linked Sites that you visit.

Aramex may prohibit links to the Website and you must remove or cease any link at Aramex’s request. You will not frame any part of the Website content by including advertising or other revenue generating material, without the prior written consent of Aramex.

4. Registration

There are two kinds of users of the Website, “Aramex Account Customers” and “Aramex Non- Account Customers”. While there is no requirement to register and create an Aramex Account, such registration will provide you access to extra functionality available in the Website.

In order to become a registered Aramex Account Customer, which, you (or your company, if you are registering with the Website on behalf of the company you work for (“Company”)) must complete the Aramex registration process. If you are registering with the Website on behalf of the company you work for (“Company”), the Company must have an existing account with Aramex (such as a business account for warehousing or commercial freight forwarding and you may be required to confirm your Company’s account number). Once Aramex has received your application for registration, you will receive an email confirming that your application has been accepted. You must click on the link contained in this email to activate the registration. Aramex reserves the right to reject any application for registration at its sole discretion.

By completing the registration process on behalf of your Company, you warrant that you have the authority to bind your Company, and that you will ensure that any other employees of the Company who use the Website comply with these Terms and Conditions. These Terms and Conditions will be in addition to the terms of any contract you have entered into with Aramex in relation to your account.

You must log in using your username and password. You must ensure that your password is kept secure and confidential and not revealed to any other person. You acknowledge that you are entirely responsible for your password and you must notify Aramex immediately of any unauthorized use of your password or any other breach of security relating to your account. You acknowledge and agree that Aramex accepts no responsibility for any loss or damage occurring as a result of the fraudulent use of your password, and you release Aramex from all claims arising from the unauthorized use of your password.

You acknowledge that Aramex assumes no responsibility whatsoever for ensuring that any information concerning you or your Company is current, complete or accurate and you agree to maintain and update any such information.

You or Aramex may terminate your registration at any time and for any reason without written notice. Once your registration is terminated by Aramex, you will not be able to access any part of then Website intended for registered users without Aramex’s prior consent.

Where you use the Website to request that Aramex carries out a task on your behalf, we will send an email to the address you submit during the registration process to confirm that we have received your request. Although Aramex makes every effort to ensure the services offered on the Website are as reliable as possible, the nature of the Internet means that we cannot be held liable for any requests in respect of which we do not confirm to you that we have received.

6. Charges

All prices listed on the Website are, to the best of Aramex’s knowledge, accurate at the time of printing. However, the Website may contain inadvertent inaccuracies or typographical errors. These will be corrected at Aramex’s discretion, as they are found.

In addition, all prices listed are subject to change at any time without notice. The information on the Website may be updated regularly so inaccuracies may occur during the process.

Aramex reserves the right at any time to charge a fee for access to certain parts of the Website. However, in no event will you be charged for such access unless we obtain your prior agreement to pay.

You acknowledge and agree that any rate or time estimate shown by the Rate Calculator or the Transit Time Estimator or other such tool on the Website for estimating a rate or time is an estimate only and may be different from the actual rates or times for domestic or international carriage of any shipments tendered to Aramex. This may be due to a number of causes including, without limitation, actual dimensions of your shipments, local charges and any unanticipated delays in shipping.

7. Submitted Materials

You may submit material through the Website provided that:

a) you warrant that you own or control all rights (including all intellectual property rights) to any submitted material, and that the submitted material complies with these Terms of Use;
b) you grant Aramex a non-exclusive, royalty-free, perpetual, irrevocable and fully transferable license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute and display your submitted material throughout the world in any media; and

c) you acknowledge there is no obligation of confidentiality in relation to the submitted material.

You may not upload, distribute or otherwise publish any content on this Website that:

a) infringes the rights of third parties, including without limitation intellectual property rights;
b) breaches any applicable local, national or international law or regulation or these Terms of Use;
c) is fraudulent, or has any fraudulent purpose or effect; d) is contrary to public policy and/or accepted moral standards, including but not limited to: obscene or offensive messages; pornographic or sexually explicit images; defamatory or libelous material; material harmful to minors; material promoting discrimination based on race, sex, religion, nationality, disability, sexual orientation or age; material likely to harass, upset, or alarm a third party or cause a third party to harm themselves;
e) is inconsistent with reasonable use of the Website.

8. Indemnity

You agree to defend, indemnify and hold harmless Aramex and its affiliate companies and their respective officers, directors, employees, agents and representatives from any and all claims, losses, liabilities, expenses, damages and costs (including reasonable legal fees) arising or resulting directlyor indirectly from or out of your breach of any of these Terms of Use, or any activity you conduct inconnection with the Website. Aramex reserves the right, but not the obligation, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you. In such instances, you agree to cooperate fully with Aramex in the defense of such matter.

9. Export

You assume all responsibility for compliance with all laws and regulations of any country from which you may access the Website regarding access, use, export, re-export and import of any content appearing on or available through the Website.

10. Data Entry

Aramex may retain any data that you provide in the course of using the Website and will do so in accordance with our Privacy Policy. You acknowledge that Aramex may delete this data at any time. You acknowledge that you are solely responsible for maintaining a back-up copy of such data and that Aramex will not be responsible for its loss or deletion.

11. Terms of Carriage

You acknowledge and agree that domestic and international carriage by Aramex of any shipments tendered to Aramex through the Website will be governed by the terms, conditions and limitations of liability set out in the applicable terms and conditions, which are incorporated into these Terms of Use by reference.

12. Limitation of Liability

The Website makes certain information and material available to you as a service, either through Aramex, its suppliers, or otherwise. The information and material provided on the Website is provided “as is”, has not been prepared by taking into account the particular objectives, situation or needs of any individual users, and is without warranties of any kind either express or implied.

Aramex does not warrant or make any representations regarding the use or the results of the use of the Website or in Linked Sites in terms of their correctness, accuracy, timeliness, reliability, or otherwise. Aramex will not be responsible for errors or misstatements or be liable, whether in contract, tort (including negligence) or otherwise, for any loss or damage however caused (including direct, indirect, consequential, special losses, or loss of profits). You release Aramex from all claims arising from any statement or representation made on the Website. Your sole and exclusive remedy for any of the foregoing or any dispute with Aramex, our affiliates, and their respective officers, directors, employees, shareholders or agents of any of them, is to discontinue your use of the Website.

To the fullest extent permissible pursuant to applicable law, Aramex excludes all responsibility and liability in relation to the Website, and disclaims all warranties, express or implied, including without limitation implied warranties of merchantability and fitness for a particular purpose. Aramex does not warrant that the functions contained in the Website will be uninterrupted or error-free, that defects will be corrected, or that the Website or the server that makes it available, are free of viruses or other harmful components.

To the maximum extent permitted by law, Aramex, you will indemnify Aramex, its officers and employees against all costs, expenses and damages incurred in connection with any claim brought by a third party against Aramex arising from a breach by you of any of the Terms of Use. You acknowledge that the limitation/exclusion of liability of Aramex, and your indemnity to Aramex, will also apply to all affiliates of Aramex, including any parent or subsidiary companies.

13. Waiver

Aramex’s failure to enforce the strict performance of any provision of the Terms of Use will not constitute a waiver of its right to subsequently enforce such provision or any other provisions of the Terms of Use.

14. Amendments

Aramex reserves the right to change the Terms of Use at any time and without providing you with notice of such changes. You agree that your continued use of the Website constitutes your acceptance of the modified Terms of Use, and you agree that all previous versions of the Terms of Use are superseded by the modified version. You should check these Terms of Use each time you access the Website to check for updates. These Terms of Use were last updated on November 12, 2015.

15. Headings

Headings in these Terms of Use are for convenience only and do not affect the interpretation of these terms and conditions.

16. Severability

If any of these conditions shall be deemed invalid, void, or for any reason unenforceable, that condition shall be deemed severable and shall not affect the validity and enforceability of the remaining conditions.

17. Law

Your use of the Website and these Terms of Use are governed by and construed in accordance with the laws and regulations of the Emirate of Dubai and the federal laws of the United Arab Emirates applicable in the Emirate of Dubai.

18. Contact

If you have any questions, concerns or complaints in relation to the Website or the Terms of Use please contact Aramex by sending an email to feedback@aramex.org.

 

Privacy Policy

The Aramex Group (“Aramex”) has drafted this Privacy Policy in order to explain Aramex’s policy regarding the use of any personal information it collects on Aramex customers and users of other services provided by Aramex (such as Aramex’s websites and applications). This Privacy Policy’s goal is to allow those customers and users to understand how their personal information may be handled by Aramex, as well as the rights they have in relation to their personal information. 

In general, Aramex will handle personal information shared by customers or users, as well as other information which may be gathered by Aramex in connection with services provided, in a lawful, fair and transparent manner. Aramex has considered internationally recognised principles, and where necessary, specific localised principles on the protection of personal data when defining its policies, such as the principles of purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

This Privacy Policy does not cover the use of personal information on customers and users related to Aramex SMART. For more information on this, please visit the Aramex SMART website, at: https://smart.aramex.com/.

Table of Contents

Privacy Policy 1

  1. Controller and Data Protection Officer 3
  2. Personal Data processed 3
  3. Name, contact details and other Personal Data 3

Aramex retail outlets 4

Aramex websites 4

Aramex applications 4

Consignees 4

  1. Data related to users’ devices 4

Aramex mobile applications 4

  1. Data related to your location 5

Aramex mobile applications 5

  1. Call recordings 5
  2. Shipment Inspection 5
  3. Shipment history 6
  4. Special categories of Personal Data 6

Aramex websites and applications 6

  1. Personal Data related to criminal convictions and offences 7
  2. Other persons’ Personal Data 7

Aramex websites and applications 8

  1. Browsing data 8

Aramex websites and applications 8

  1. Cookies, SDKs and tracking technologies 8

Aramex websites 8

Aramex applications 9

  1. Purposes of processing 9
  2. Grounds for processing and mandatory / discretionary nature of processing 10
  3. Recipients of Personal Data 12
  4. Transfer of Personal Data 13
  5. Retention of Personal Data 13
  6. Data subjects’ rights 14
  7. Amendments 16


1. Controller and Data Protection Officer

The controller regarding all personal data processing carried out via websites or applications managed by Aramex is Aramex International LLC, with registered offices at P.O. Box 95946, Dubai, United Arab Emirates.

Aramex International LLC acts as a joint controller with each individual local Aramex Station, regarding personal data related to customers of a given local Aramex Station, or to consignees of shipments delivered by (or on behalf of) that local Aramex Station. Please refer to the relevant section on the Aramex website (available here) in order to understand which Aramex Station may act as a controller regarding those personal data in your location.

When acting as joint controllers, Aramex International LLC and the relevant local Aramex Station are jointly responsible for ensuring that all rules regarding the handling of your personal data are respected. You can exercise your rights as a Data Subject against either one by:

  • Submitting an online support request (here); or
  • Reaching out to your relevant local Aramex Station.

Aramex has appointed a Group Data Protection Officer. To contact the Aramex DPO, please submit an online support request (here).

Aramex has also appointed a representative for local Aramex Stations which are established outside of the EU/EEA, under Art. 27 GDPR:

Aramex Nederland B.V.

Fokkerweg 300, 1438 AN, Oude Meer, P.O. Box 728, 2130 AS Hoofddorp, the Netherlands.

To contact the Aramex EU/EEA Representative, please submit an online support request (here).


2. Personal Data processed

 

When providing services to customers, users or consignees, whether through physical retail outlets, websites or applications managed by Aramex (jointly referred to as the “Aramex Services”), Aramex will collect and process information regarding those customers / users / consignees (as individuals) which allows their identification either by itself, or together with other information which is available. Aramex may also be able to collect and process information regarding other persons in this same manner, where those customers / users / consignees choose to provide it to Aramex.

This information may be classified as “Personal Data”, and can be collected by Aramex both when shared by customers / users / consignees (e.g., upon signing up for an account on an Aramex website, when placing an order for delivery services, when preparing a shipping document at retail outlets), by analysing users’ behaviour (e.g., when browsing Aramex websites or using Aramex applications) or when disclosed to Aramex by other sources (e.g., Aramex’s customers, entities providing sanction-list screening services to Aramex).

These Personal Data may include the following categories: 


3. Name, contact details and other Personal Data


  • Aramex retail outlets

When requesting services from Aramex at a physical retail outlet, you will be asked to submit Personal Data concerning yourself. This may include your name, surname, telephone number, address, delivery address, copies of your government-issued identification cards and information related to your credit card (if you use these cards as a payment method). You can find the relevant information relating to each Aramex’s physical retail outlet stores here.

  • Aramex websites

In various sections of Aramex’s websites – including, in particular, account creation pages and forms – you will be asked to submit Personal Data concerning yourself, such as your name, phone / mobile number, e-mail address, gender, date of birth, country of residence and postal address, as well as, in certain cases, information related to your company of employment and position in that company. Where services provided over these websites require payment, you will also need to disclose information as to your preferred mode of payment (e.g., PayPal, credit card).

 

Whenever you participate in surveys, promotions or contests which may be available on Aramex’s websites, as well as whenever you decide to communicate with Aramex via contact details provided on those websites (or, otherwise, by telephone with Aramex Customer Service), Aramex may collect additional Personal Data which you choose to provide, as far as this is necessary in order to address your request or query. This is also the case regarding information which you choose to disclose in certain sections of Aramex websites which allow your participation in public forums, or the sending of messages directly to Aramex.

  • Aramex applications

When creating an account on Aramex applications, you will be asked to submit Personal Data concerning yourself, such as your name (first and last), mobile number, e-mail address and information regarding the credit card to be used as a payment method – number, name, expiry date and card verification number – as well as your shipping address (based on your location, or selected on a map).

  • Consignees

Aramex may receive Personal Data concerning yourself from its customers, in order to allow Aramex to complete shipments from those customers to you, as a consignee. In this case, Aramex may also collect Personal Data from you upon shipment delivery. This may include, in particular, your name, surname, telephone number, address and delivery address, as well as, in certain cases, copies of your government-issued identification cards and information related to your credit card (if you use these cards as a payment method, where applicable).


4. Data related to users’ devices

  • Aramex mobile applications

When choosing to install Aramex applications, you grant permission to Aramex to set up the selected application on your mobile device (“Device”), as well as to access Personal Data and other information stored on your Device which are needed in order to successfully install the application (e.g., Device model, operating system version, screen resolution, network connection type, language, etc.). This collection of information is inherent to the process of installing and setting up Aramex’s applications and, as such, you may not object to it unless you uninstall the application from your Device.

Once an Aramex application has been installed, you may be asked to allow the application to send and read SMS messages from your Device, in order to send you an SMS verification code and to grant you automatic access to the application, upon successful receipt of this code. When using Aramex applications, access may also be requested to your Device’s storage (e.g., when you register shipping addresses on an application), camera (e.g., so that you can scan your credit card in order to insert its details as a payment method in the applications) and Internet access, among other functions where necessary.

5. Data related to your location

  • Aramex mobile applications

Once you have installed an Aramex application, you may be asked to consent to the application accessing your Device’s location, even when you are not using the application, as well as to your Device’s map functionalities. This is meant to allow Aramex to provide more precise and useful Aramex Services to you via the application, in particular, by allowing you to pinpoint your location, register a shipping address based on your current location (as opposed to searching on a map), track your shipments in real-time (on the day of delivery), ensure correct delivery of your shipments, and so on.

If you believe that the continuous access to your location is too invasive, you can configure your Device in a way to share your position only when the applications are in use. If even this is too invasive, you can always revoke the sharing of your position from the Device settings and simply provide a physical address, zip code or state for the Aramex Services you are interested in (or manually pin your relevant address on a map within the applications).


6. Call recordings

When you contact Aramex’s Customer Support team over the phone, Aramex will store a recording of the call held between you and the Aramex Customer Support agent – this is done, primarily, to retain evidence of service-related requests or complaints handled over the phone (to allow Aramex to demonstrate how they were handled), and for service quality monitoring/training purposes. You will be notified of this through a pre-recorded message presented at the start of the call.


7. Shipment Inspection

In order to lawfully provide the Aramex Services, Aramex may be required to physically inspect the shipments which are to be delivered in connection with those Aramex Services, in particular to confirm that any applicable legal shipment restrictions (e.g., due to country of origin or destination, or type of goods shipped) or trade embargoes are respected.

These inspections will be carried out only to detect whether the terms of any applicable legal restrictions regarding incoming and outgoing shipments are respected. In particular, Aramex will not carry out an in-depth inspection of any documents or other items which might reveal Personal Data on the sender, consignee or third persons, unless this is strictly necessary for these compliance purposes. As a result of an inspection, if your shipment is rejected (due to a conflict with, for example, applicable legal import or export restrictions), Aramex will either attempt to arrange for the return of the shipment to its origin (where legally possible to do so) or destroy the shipment, as required by the applicable laws.

Aramex maintains logs of all inspection activities performed, including details on the origin and destination countries of the shipment, the name of the shipper and consignee, a general description of the shipment contents (e.g., “documents”, “shower curtains”, etc.), the country of origin of those contents, the contents’ Harmonized System (HS) code, and the air waybill number for the shipment.


8. Shipment history

Aramex will keep logs of details, actions taken and interactions had with you in connection with deliveries made at your request (as a shipper), as well as of deliveries made to you (as a consignee). This may include information such as shipment order date/time, shipment contents (generic description), shipper details (name, contact details, billing address), consignee details (name, contact details, delivery address), delivery method, delivery status, delivery date/time, delivery location, number of failed delivery attempts, preferred communication channel for delivery updates, number of returned deliveries, and so on.

These data will be collected from shipment records, but also from logs generated from the different channels through which you may interact with Aramex (such as our applications and websites, our call centres and SMS/instant messaging channels).


9. Special categories of Personal Data

Aramex does not typically need to process more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation, in order to provide the Aramex Services. Though this information may potentially be inferred from some of the Personal Data collected by Aramex (e.g., goods to be shipped), it is not the intention of Aramex to process those categories of Personal Data, and those categories of Personal Data will not be specifically processed for any purpose (other than to provide the Aramex Services).

  • Aramex websites and applications

Certain areas of Aramex websites and applications may include free text fields where you can write messages to Aramex, or otherwise allow you to post various types of content, which may contain Personal Data. Where these fields are completely free, you may use them to disclose, or may post content which discloses (inadvertently or not) more sensitive categories of Personal Data such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation

Aramex asks that you do not disclose any sensitive Personal Data in these free text fields or in your posts on Aramex websites or applications, unless you consider this to be strictly necessary. While Aramex does not intend to collect sensitive Personal Data on customers or website / application users (except where this is explicitly stated by Aramex), this may occur where those individuals voluntarily choose to disclose those data.

If you do disclose sensitive Personal Data to Aramex in this manner, then Aramex will process those Personal Data only to the extent that they are adequate, relevant and not excessive regarding the purposes of processing described in this Privacy Policy (see below, Purposes of processing). This will be done, in particular, where necessary to perform a contract with you or to answer a request you make, or otherwise where Aramex can be said to have a legitimate interest in processing those data, due also to the fact that, when you decide to disclose sensitive Personal Data through Aramex websites and applications, you may be manifestly making those Personal Data public.


10. Personal Data related to criminal convictions and offences

In order to lawfully provide the Aramex Services, Aramex may be required to screen customers / users / consignees against applicable government denied parties, sanctions and watch lists, as well as politically exposed persons databases. Aramex may also be required to confirm whether its customers or users are allowed to export goods outside of their country of location upon requesting Aramex Services, and/or that customers / users / consignees meet other requirements necessary for customs clearance purposes.

This process may involve asking for a copy of your national identification documents or passport, as well as accessing information on prior sanctions or limitations (of a criminal nature or otherwise) which may have been imposed upon you by order of a court or other competent authority. Aramex will only access this information where this is authorised under the applicable law, and solely to the extent necessary to comply with any legal requirements which may apply.

As a result of a screening exercise, if you are identified as a partial or potential match on any applicable lists, you may be asked to provide further information to confirm your identity (such as a copy of your national identification documents or passport, if you have not been asked for this already). If you are identified as an exact match, Aramex will not be able to complete your shipment; in this case, Aramex will either attempt to arrange for the return of the shipment to its origin (where legally possible to do so) or destroy the shipment, as required by the applicable laws.

Aramex maintains logs of all screening activities performed, including details on the origin and destination countries of the shipment, the name of the shipper and consignee, a general description of the shipment contents (e.g., “documents”, “shower curtains”, etc.), the country of origin of those contents, the contents’ Harmonized System (HS) code, and the air waybill number for the shipment.


11. Other persons’ Personal Data

When requesting Aramex Services, you may decide to provide information on other persons which is relevant for the correct provision of those services (e.g., where you wish to have a delivery made to another person – i.e., a consignee – you will be required to provide information on the consignee). This may include information such as those persons’ name, delivery address and phone number.

In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding those Personal Data, and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Aramex against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide to Aramex.

As Aramex does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Aramex; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Aramex this information.

  • Aramex websites and applications

Additionally, as mentioned in the previous section, certain areas of the Aramex websites / applications include free text fields where you can write messages to Aramex, or which otherwise allow you to post various types of content. These messages and content may (inadvertently or not) include Personal Data related to other persons. Other sections of Aramex’s websites may ask you to submit Personal Data related to third parties, such as other contact persons in your company or your relatives who are employees of Aramex.

The final two paragraphs of the above subsection (regarding your liability for Personal Data on other persons which you choose to share with Aramex, and your obligation to ensure that you are lawfully entitled to do so) also apply in full in this case.


12. Browsing data 

  • Aramex websites and applications

The operation of Aramex’s websites and applications involves the use of computer systems and software procedures, which collect information about website and application users as part of their routine operation. While Aramex does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the websites or applications, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.

These data are used to compile statistical information on the use of the websites and applications, as well as to ensure their correct operation and identify any faults and/or abuse.


13. Cookies, SDKs and tracking technologies

Aramex may process your Personal Data through cookies, SDKs (Software Development Kits) and similar technologies to improve your experience on Aramex’s websites or Aramex applications.

  • Aramex websites

Information regarding the use of cookies on each of our websites can be found in the Cookie Policy made available on each website.

  • Aramex applications

Information regarding the use of SDKs and tracking technologies on Aramex applications can be found in the SDK Policy which is made available on each applications. 


14. Purposes of processing

Aramex intends to use the above Personal Data, collected in connection with the provision of Aramex Services, for the following purposes:

  • Generally, to allow Aramex to provide Aramex Services to you, including (without limitation) express, freight and logistics services, as well as to allow you to request and receive Aramex Services which are specifically delivered through Aramex’s websites and applications (“Service Provision”). This may include the use of Personal Data in order to (for example):
    • Create shipment labels and airway bills;
    • Track shipment deliveries;
    • Provide updates to customers on shipment status through online portals;
    • Contact consignees in order to narrow down and confirm delivery addresses, and ensure successful completion of deliveries;
    • Allow users to create registered accounts and participate in forums and discussions on Aramex websites and applications;
    • Process payments for Aramex Services, including those requested via Aramex websites or applications;
    • Sending alerts to users regarding Aramex applications, via push notifications on user Devices.
  • To gain a better understanding of your preferences in relation to the Aramex Services, based on prior interactions we have had with you (such as deliveries made for you), and better tailor Aramex Services to you, in order to increase their efficiency and improve your experience (“Service Analytics”). This may include the use of Personal Data in order to (for example):
    • Complete or correct inaccurate delivery addresses;
    • Identify the timeslots which you prefer for receiving shipments;
    • Identify whether you prefer picking up shipments yourself (at a retail store or drop-off point), or having shipments delivered to you;
    • Identify your preferred communication channel for shipment updates (SMS, e-mail, apps, phone calls, etc.);
    • Determine the likelihood of any obstacles which may arise to correct and timely service delivery.
  • For future marketing, promotional and publicity purposes (“Marketing”). This may include the use of Personal Data in order to (for example):
  • Allow you to participate in contests and promotions held or sponsored by Aramex;
  • Send you direct marketing messages, through e-mail, SMS, push notifications (on mobile devices) or telemarketing calls;
  • Send you surveys and other messages aimed at market research, through e-mail, SMS, push notifications (on mobile devices) or telemarketing calls;
  • Show you advertisements related to Aramex goods and services on other websites and platforms, by sharing limited amounts of your Personal Data (for example, your e-mail address) with third-party website/platform providers.
  • To create a profile of you as a user of Aramex’s websites / applications, through the use of Marketing cookies or SDKs (see Cookies, SDKs and tracking technologies, above) and by collecting and analysing information on the preferences you select and choices you make in Aramex’s websites / applications, as well as through your Device data (e.g., IFDA). This information will be used to personalise the Aramex Services provided through the websites and applications, where possible, to suit your preferences and choices, as well as to serve you with information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias (“Profiling”);
  • To keep records of requests, complaints or transactions carried out over the phone between you and an Aramex Customer Support agent, to prove that those requests, complaints or transactions took place at a given date and time, as well as for quality assurance purposes – namely, to incidentally confirm that Aramex Customer Support agents provide high-quality support to Aramex customers (“Call Recording”);
  • For compliance with laws which impose upon Aramex the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
  • For development and administration of Aramex’s websites and applications, in particular by use of data analytics regarding how you and other users use those websites / applications, as well as the information and feedback you provide, in order to improve Aramex’s offerings (“Analytics”);
  • To prevent and detect any misuse of Aramex’s websites or applications, or any fraudulent activities carried out through the Website (“Misuse/Fraud”). 


15. Grounds for processing and mandatory / discretionary nature of processing

Aramex’s legal bases to process your Personal Data, according to the purposes identified in Purposes of processing above, are as follows:

  • Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Aramex your Personal Data for these purposes; however, if you do not, Aramex will not be able to provide any Services to you.
  • Service Analytics: processing for this purpose is generally based on Aramex’s legitimate interests, namely, in improving the efficiency and effectiveness of the Aramex Services, as well as improving the Aramex customer/consignee experience. You are allowed to object to this, and also to ask for more information about the assessments carried out by Aramex regarding its legitimate interests, by sending us a support request (please see Data subjects’ rights, below, for more information).
  • Marketing: processing for this purpose is based on your consent. It is not mandatory for you to give consent to Aramex for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to (aside from not being able to receive further marketing communications from Aramex). Any consent given may also be withdrawn at a later stage (please see Data subjects’ rights, below, for more information).
  • Profiling: processing for this purpose is based on your consent, given by accepting the use of Marketing cookies or SDKs (see Cookies, SDKs and tracking technologies, above). It is not mandatory for you to give consent to Aramex for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding Aramex’s websites and applications). Any consent given may also be withdrawn at a later stage (please see Data subjects’ rights, below, for more information).
  • Call Recording: processing for this purpose is generally based on Aramex’s legitimate interests, namely, in retaining evidence of requests, complaints and transactions carried out with Aramex customers over the phone – so that Aramex can demonstrate when they took place, and ensure that they are properly addressed by Aramex – and in ensuring that Aramex Customer Support agents provide high-quality assistance to Aramex customers (by incidentally reviewing calls held by each agent). You are allowed to object to this, and also to ask for more information about the assessment carried out by Aramex regarding its legitimate interests, by sending us a support request (please see Data subjects’ rights, below, for more information).

In some jurisdictions, Aramex may not be legally allowed to record phone calls you take part in without your consent. Where this is the case, processing for this purpose will be based on your consent. In this case, it is not mandatory for you to give consent to Aramex for use of your Personal Data for this purpose, though you may be redirected to another communication channel in order to address your support request with Aramex. Any consent given may also be withdrawn at a later stage (please see Data subjects’ rights, below, for more information).

  • Compliance: processing for this purpose is necessary for Aramex to comply with its legal obligations. When you provide any Personal Data to Aramex, Aramex must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.

In some cases – notably regarding screening of senders/consignees against existing blacklists or the inspection of shipments – Aramex may base the related processing activities on its legitimate interests, namely, in ensuring that any applicable shipment restrictions are complied with. You are allowed to object to this, and also to ask for more information about the assessment carried out by Aramex regarding its legitimate interests by sending us a support request (please see Data subjects’ rights, below, for more information).

  • Analytics: processing for this purpose is generally based on Aramex’s legitimate interests, namely, in understanding how users interact with Aramex’s websites and applications through collected browsing data and to improve them accordingly, with the aim to providing a better user experience. You are allowed to object to this, and also to ask for more information about the assessment carried out by Aramex regarding its legitimate interests by sending us a support request (please see Data subjects’ rights, below, for more information).

Where Statistics cookies or SDKs are specifically used to collect this information (see Cookies, SDKs and tracking technologies, above), this is based on your consent, given by accepting the use of Statistics cookies or SDKs (see Cookies, SDKs and tracking technologies, above). It is not mandatory for you to give consent to Aramex for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to. Any consent given may also be withdrawn at a later stage (please see Data subjects’ rights, below, for more information).

  • Misuse/Fraud: processing for this purpose is generally based on Aramex’s legitimate interests, namely, in preventing and detecting fraudulent activities or misuse of Aramex’s websites and applications (for potentially criminal purposes), and ensuring the security of Aramex’s websites and applications. You are allowed to object to this, and also to ask for more information about the assessment carried out by Aramex regarding its legitimate interests by sending us a support request (please see Data subjects’ rights, below, for more information).


16. Recipients of Personal Data

Your Personal Data may be shared with the following list of persons / entities (“Recipients”):

  • The specific Aramex customer on behalf of which Aramex is providing Aramex Services to you, where are a consignee;
  • Entities engaged in order to screen Aramex customers and consignees against applicable government denied parties, sanctions and watch lists, as well as politically exposed persons databases, as required or authorised by the applicable law; 
  • Individuals or entities engaged in order to provide Aramex Services on Aramex’s behalf (e.g., couriers, call centre agents, service partners, hosting providers or e-mail platform providers), as well as persons authorised by Aramex to process Personal Data needed to carry out activities strictly related to the provision of the Aramex Services (e.g., Aramex employees), who are bound to obligations of confidentiality, may only process Personal Data under Aramex’s instructions and must comply with security measures set by Aramex;
  • Persons, companies or professional firms providing Aramex with advice and consultancy regarding accounting, administrative, analytics, legal, tax, financial and debt collection matters related to the provision of Aramex Services;
  • Entities engaged as data processors, to carry out processing activities related to Marketing, Profiling and/or Analytics on Aramex’s behalf, where you have consented to processing of your Personal Data for these purposes (e.g., SMS engines, certain third-party cookie providers);
  • Third-party providers of websites and online platforms, to carry out processing activities related to Marketing (in particular, displaying Aramex advertisements on their websites / online platforms):
  • Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
  • Companies within the Aramex Group (which may also assist in providing Aramex Services to a customer / user / consignee, depending on his/her location); and
  • Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;6. Transfer of Personal Data

Considering Aramex’s worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. In particular, whenever you rely on Aramex Services for any cross-border operations (such as the delivery of a shipment from one country to another), Personal Data may be transferred to the receiving country.

Aramex implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, in particular regarding transfers of Personal Data from within the EEA to outside the EEA. As a rule, whenever an adequacy decision from the European Commission is not available for the recipient country, Aramex enters into agreements with recipients containing standard data protection clauses adopted by the European Commission, or otherwise relies on any other more appropriate lawful transfer mechanisms available under the applicable data protection law.


17. Retention of Personal Data 

Personal Data processed for Service Provision will be kept by Aramex for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of Aramex Services, Aramex may continue to store this Personal Data for a longer period, as may be necessary to protect Aramex’s interests concerning potential liability linked to the provision of Aramex Services.

Personal Data processed for Service Analytics, as well as Analytics which are based on Aramex’s legitimate interests (analytics performed on browsing data; see Purposes of processing, above), will be aggregated as soon as feasible, and thus will be kept as Personal Data only for the period deemed strictly necessary to allow for such aggregation. 

Personal Data processed for Analytics, where based on your consent (analytics performed using Statistical cookies or SDKs; see Purposes of processing, above), will be kept by Aramex from the moment you give consent until the moment you withdraw the consent given. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by Aramex, in particular as may be necessary to protect Aramex’s interests concerning potential liability linked to this processing.

Personal Data processed for Marketing and Profiling will be kept by Aramex from the moment you give consent until the moment you withdraw the consent given. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by Aramex, in particular as may be necessary to protect Aramex’s interests concerning potential liability linked to this processing.

Personal Data processed for Call Recording (in particular, the recordings themselves) will be kept by Aramex, as a rule, for up to 1 year from the date on which a call to the Aramex Customer Support team is made. In jurisdictions where Aramex may only legally record phone calls you take part in with your consent, call recordings may be retained from the moment you give consent until the moment you withdraw the consent given.

However, in the event that selected call recordings are reasonably necessary for Aramex to establish, exercise or defend against legal claims, or otherwise to protect Aramex’s interests concerning potential liability linked to the provision of the Aramex Services, they may be kept for a longer period.

Personal Data processed for Compliance will be kept by Aramex for the period required by the specific legal obligation or by the applicable law. In particular, logs related to screening or inspection exercises carried out by Aramex will be kept for up to 5 years, after which they will be archived. Archived logs will only be accessed where this is reasonably necessary for Aramex to establish, exercise or defend against legal claims, or otherwise to protect Aramex’s interests concerning potential liability linked to the provision of the Aramex Services. 

Personal Data processed for Misuse/Fraud will be kept by Aramex for as long as deemed strictly necessary to fulfil the purposes for which it was collected, unless you validly object to the processing of your Personal Data for these purposes (please see Data subjects’ rights, below, for further information).


18. Data subjects’ rights

Under the Regulation, you, as a data subject, are entitled to exercise the following rights before Aramex, at any time:

  • Access your Personal Data being processed by Aramex (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
  • Correct or update your Personal Data processed by Aramex, where it may be inaccurate or incomplete;
  • Request erasure of your Personal Data being processed by Aramex, where you feel that the processing is unnecessary or otherwise unlawful;
  • Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
  • Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Aramex, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller; or
  • Withdraw your consent to processing (for Marketing, Profiling, Analytics and, where applicable, for Call Recording).

Regarding processing purposes which are based on our legitimate interests (see Purposes of processing, above) you are also entitled to object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Aramex from processing your Personal Data. If you do, then we will only continue processing your Personal Data for the purpose in question if we can demonstrate that we have a compelling legitimate interest to continue doing so, or if we need to in order to establish, exercise or defend against any legal claims.

Please note that most of the personal information you provide to Aramex can be changed at any time, including your e-mail preferences, by accessing the user profile you can create on Aramex’s websites and applications.

You can also withdraw consent regarding processing for Marketing by selecting the appropriate link included at the bottom of every marketing e-mail message received. Specifically, regarding Marketing carried out via push notifications, you can withdraw this consent via the options made available through Aramex’s applications, or through your Device’s settings:

You can withdraw consent regarding processing for Profiling and Analytics performed using Marketing or Statistics cookies, SDKs or other tracking technologies by using the consent management platform made available on Aramex websites / tracking settings made available on Aramex applications.

Aside from the above means, you can also exercise your rights described above by sending us a support request via Aramex’s websites, by filling out the form available here.

In any case, please note that, as a data subject, you are also entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out by any Aramex Station is unlawful. If you are located within the EU, you are entitled to file these complaints with supervisory authorities located (1) in the Member State of your habitual residence, (2) in the Member State of your place of work or (3) in the Member State where you believe the unlawful processing occurred.

19. Amendments
This Privacy Policy entered into force on September 11, 2023. Aramex reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Aramex will inform you of any substantial changes as soon as they are introduced (through a pop-up on Aramex’s website, and through e-mail notifications sent to customers / users / consignees included in Aramex’s mailing lists). Changes will be binding as soon as they are published.

Cookie Policy

Aramex South Africa [Pty] Ltd. (“Aramex”) has drafted this Cookie Policy in order to explain Aramex’s policy regarding the use of any personal information it collects on visitors of the Aramex website (i.e., aramex.co.za) (the “Website”) through cookies which may be stored on and accessed from visitors’ devices when they use or visit aramex.co.za. This Cookie Policy’s goal is to allow those visitors to understand how their personal information may be handled by Aramex through cookies, as well as the rights they have in relation to their personal information. 

In general, Aramex will handle personal information collected through cookies, in a lawful, fair, and transparent manner. Aramex has considered internationally recognised principles on the protection of personal data when defining its policies, such as the principles of purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

The controller regarding all personal data processing carried out via cookies that Aramex uses on the Website, is Aramex South Africa [Pty] Ltd., with registered offices at 3 Henna Dolf West Richmond Park, Milnerton, Western Cape, 7441.

You can exercise your rights as a Data Subject against Aramex by submitting an online support request (here) or by sending a written request to Aramex at the following address: privacy@aramex.com. Aramex has also appointed a Group Data Protection Officer. To contact the Aramex DPO, please submit an online support request (here).

This Cookie Policy is part of Aramex’s Privacy Policy. For more information regarding Aramex’s personal data processing activities, please read Aramex’s Privacy Policy (accessible here). 

COOKIES

Definitions, characteristics, and application of standards

Cookies are small text files that may be sent to and registered on your computer by a website you visit, to then be re-sent to the same site when you visit it again. It is thanks to these cookies that the website can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within the website.

Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.

When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).

There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.

According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical/necessary cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).

On the other hand, “profiling/marketing cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law.

Types of cookies used by the Website

The Website uses the following types of cookies: 

  • Necessary cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Aramex services made available via the Website.
  • Preference cookies, which are used to activate specific website functions and to configure the Website according to your choices, in order to improve your experience.
  • Statistics cookies, which allow Aramex to understand how users make use of the Website, and to track traffic to and from the Website.
  • Marketing cookies, which are used to observe the preferences you reveal through your use of the Website and to send you advertising messages in line with those preferences.

Aramex also uses third-party cookies – i.e. cookies from websites / web servers other than Aramex’s own website, which are owned by third parties. These third parties will either act as independent data controllers from Aramex regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) or as data processors for Aramex (processing personal data on Aramex’s behalf). For further information on how these third parties may use your information, please refer to their privacy policies:

Provider

Cookie types and purposes 

Further information

Google (Analytics, DoubleClick, YouTube, AdSense)

Necessary cookies

  • Estimate users’ bandwidth on pages with integrated YouTube videos.
  • Measure bandwidth that determines whether the user gets the new or old player interface.
  • Allow the reCAPTCHA system to function, so that human users can be distinguished from bots.
  • Determine whether a user’s browser accepts cookies.

 

Preference cookies

  • Store users’ video player preferences for embedded YouTube videos.
  • Track the views of embedded videos on YouTube pages.

 

Statistics cookies

  • Generate statistical data about how users make use of our website.
  • Allow the tracking of users across devices and marketing channels.
  • Store data about what YouTube videos a user has seen.
  • Register anonymous statistical data for embedded YouTube-videos.

 

Marketing cookies

  • Record and report users’ actions after viewing or clicking on advertisements displayed on our website, to measure advertisement effectiveness and for targeted advertising.
  • Store information about how the user uses the website to present them with relevant ads and according to the user profile.

Bombora

Advertising Cookies

  • Advertising cookies: These cookies are used to make advertising messages more relevant to you.  They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
  • Collect information that is used either in aggregate form, to help understand how websites are being used or how effective marketing campaigns are, or to help customize the websites for visitors.

Aramex uses Google Analytics on the Website. This is a tool developed by Google and used to collect information, which permits evaluation of the use of the Website, analysis of your behaviour and improvement of your experience with the Website. You can obtain more information about how to opt out of Google Analytics at: https://tools.google.com/dlpage/gaoptout.

First-party cookies present on the Website

In detail, the first-party cookies present on the Website are as follows: 

Name

Cookie types and purposes

Duration

trx_addons_is_retina

This cookie is used for checking if the user has a retina display.

1 day

 

Cookie settings

You can choose not to consent to the use of certain cookies, or otherwise withdraw your consent (and thereby block or delete) certain cookies, via the cookie consent management platform made available to you on the Website.

You can also change your cookie settings through your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:

CAUTION: If you block or delete any Necessary cookies used by the Website through your browser settings, the Website may become impossible to browse, certain of its services or functions may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

AMENDMENTS
This Cookie Policy entered into force on September 11, 2023. Aramex reserves the right to partly or fully amend this Cookie Policy, or simply to update its content, e.g., as a result of changes in applicable law. Aramex will inform you of any substantial changes as soon as they are introduced (through a pop-up on Aramex’s website, and through e-mail notifications sent to customers / users / consignees included in Aramex’s mailing lists). Changes will be binding as soon as they are published.

Our Commitment to Protection

At Aramex, we take protecting our customers’ sensitive information seriously and are constantly monitoring our information and data to prevent fraudulent or suspicious behavior.

We strive to protect you and encourage you to be aware of any potential fraudulent behavior by malicious parties using the Aramex brand. Below are some tips for how you can recognize fraud to ensure that sensitive information is kept secure.

Recognize Fraud

Recognizing phishing and scam e-mails and other types of communications is key to protecting yourself against fraud and theft. Common warning signs of online scams include:

  • Requests for Money: Unexpected requests for money in return for delivery of a package, often with a sense of urgency, and used to trick people into sending money and provide personal information such as usernames, passwords, and credit card details.
  • Requests for Personal Information: Requests for personal and/or financial information for the purpose of committing theft, identify theft and other crimes.
  • Deceptive Domain Names: Links to misspelled or slightly altered website addresses (e.g. aramx.com / aramxpress.org / aramexcourier). If you doubt the integrity of any website using the Aramex brand, please visit our global website: www.aramex.com or contact Aramex Global Customer Care Center at GlobalCareCenter@aramex.com.

Types of Fraud

Fraudulent Emails and Email Scams: These are the most common online scams. Such emails attempt to trick you by pretending to come from a reputable source, such as from Aramex (for example from what appears to be an Aramex email). They will try to get you to share sensitive personal, account information or send a payment. They may also ask you to enroll in winning a prize or entering a competition.

We urge customers to be suspicious of any request not coming directly from an Aramex employee or domain name.

Identity Theft: This occurs when someone tricks you into disclosing/providing personal, financial or account information. Posing as well-known companies, information thieves usually send out e-mails or contact you by telephone asking you to reply or direct you to a fraudulent web page that asks you to provide personal information, such as your credit card number or account password, or even your Aramex credentials.

Credit Card Fraud: In some instances, credit card fraud occurs when someone’s physical credit card is lost or stolen by another party who uses it. Credit card fraud is driven primarily by the compromise of credit card account data during their normal course of usage. Stolen credit card data is often used to attempt fraudulent online purchases.

Spam and Viruses: In our industry, customers usually receive an email suggesting that Aramex is attempting to deliver a package and request that you open the email attachment to prompt the delivery. This attachment may be a computer virus. Unless you are expecting to receive an email like this, please do not open the attachment and report it to Aramex Global Customer Care Center at (GlobalCareCenter@aramex.com).

Package Tracking Emails: In some cases, customers receive an email containing a tracking number. This number can be verified by inserting it into the “Track Shipment” box on www.aramex.com. If there are no tracking results returned, it is not a valid tracking number, and Aramex did not send the email. Please report this email to Aramex Global Customer Care Center at (GlobalCareCenter@aramex.com).

Activation Key: Messages with activation keys are only sent to complete your registration after downloading the Aramex mobile app. If you receive messages without attempting to register on our mobile app, then we urge you to ignore it. Aramex will never ask for you activation key over phone or email; for your account’s security, please do not share your key with anyone.

Doing Our Part

The security of your personal information is important to us. At Aramex, we recognize industry standards and employs appropriate administrative, technical and physical security safeguards to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing. We continually invest in latest world-class technologies to minimize all potential risks for the benefit of our customers, and we remain committed to ensuring we meet the most stringent security requirements and fostering a security culture within our organization. Our commitment to Information Security is always audited and has been recognized by international accreditation bodies such as the British Standards Institution (BSI), as our security measurements are ISO 27001:2013 certified.

Our corporate website and mobile App use several security techniques including secure servers. All your personal information, including your credit card details, are encrypted before leaving your browser or device. Our payment platform has also been certified for compliance with payment card and data security industry standards (i.e. PCI-DSS).

Doing Your Part

Aramex will keep these measures under review and enhance them from time to time as necessary. It is important for you to protect against unauthorized access to your login information, including your password. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, Aramex cannot guarantee the absolute security of your personal information.

Contact Us

For any comments or questions on Aramex’s Customer Protection and Fraud Prevention Measures, please contact Aramex Global Customer Care Center at (GlobalCareCenter@aramex.com).

Disclaimer:

Aramex does not, and will not request you to provide any personal or payment information through traditional mail or via email. Being aware and protecting your sensitive information is the best way to prevent fraud. If you receive a request for personal or payment information through these types of communications, please do not reply or cooperate with the sender and immediately report the case to Aramex Global Customer Care Center at (GlobalCareCenter@aramex.com).

Aramex accepts no responsibility for any costs, charges or payments made as a result of fraudulent activity. It is important to be mindful of the above ways your information and data can be stolen to prevent any fraud in the future.v

Competition Ts & Cs:

  1. Aramex South Africa’s decision is final and no correspondence will be entered into.
  2. Employees of the Aramex South Africa brand and their marketing agencies are not eligible to win.
  3. The competition will run from the 4th of April to the 31st of July 2022.
  4. Every parcel sent through DropBox will qualify as an entry.
  5. Unlimited entries are allowed.
  6. Aramex South Africa reserves the right not to appoint any winners.
  7. Winner will be announced before the 31st of August.
  8. Aramex South Africa reserves the right to change the prize without notifications.
  9. If the winner does not claim his/her prize within 10 working days they will forfeit the prize.
  10. Aramex South Africa acknowledges that the promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook and Instagram.

1.        Policy Purpose

The nature of our business and geographical spread often requires interactions with various officials in the public and private sectors around the world. Our Code of Conduct, Applicable Anti-Corruption Laws “Applicable Laws” and this Anti-Corruption Policy “Policy” establish certain limits on these interactions.

This Policy is drafted to provide awareness about Aramex’s stance of zero tolerance for corruption and commitment to fair and ethical business practices to avoid violations of the Applicable Laws. Such violations might lead to severe penalties, fines or reputation damage; therefore, it is vital that we not only understand the importance of this Policy but comply with it in our daily transactions.

This Policy:

  • Advises the laws applicable to our business worldwide, as well as the importance of complying with these laws;
  • Describes the various forms of corruption;
  • Illustrates situations where corruption might arise and the recommended course of action; and
  • Details the avenues of support to be used for reporting compliance concerns and gaining additional guidance.

2.        Applicability

This Policy applies to all employees of Aramex and its worldwide Related Parties [1], including officers, directors, full-timers, part-timers, contract and temporary employees. It covers all aspects of work, transactions, activities and business endeavors.

3.        Applicable Laws

Aramex is committed to fair and ethical business practices and avoiding corruption of all kinds, including bribery of Government Officials[2] and private (non-government) individuals and entities. We abide by all applicable anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA) of the United States, the U.K. Bribery Act (UKBA), the United Nations Convention against Corruption (UNCAC) and the local laws in every country in which we operate (“Applicable Laws”).

Some countries in which we operate may have laws stricter than those mentioned in this Policy. As a general rule, we follow the most stringent law, regulation or policy applicable to our business in these countries.

The combination of Applicable Laws and our global presence requires maximum alertness to corruption and full awareness of how to recognize and eliminate it from any transaction we are part of. In case of any doubt about what is expected of you under the Applicable Laws or this Policy, you must seek guidance from the Compliance or Legal Departments.

4.        Responsibility (Call for Action)

As employees and Related Parties of Aramex, we are all responsible to uphold the company values and to conduct business with integrity and honesty. The following actions must be taken to fulfill our commitment to fair and ethical business practices:

  • Step away from situations that involve corruption or those that may be viewed as involving corruption.
  • Stay alert to any red flags suggesting wrongdoing by another employee or a Related Party.
  • Support and encourage other employees and Related Parties to comply with this Policy.

4.1.       Reporting Violations

If you have any questions or concerns, or if you witness potential violations of this Policy, you must share your concerns with us. We operate under a “no retaliation” policy, which means that we will never retaliate against anyone who reports a concern to us in good faith. Additionally, your report will be treated with the highest level of confidentiality and we will endeavor to ensure that your identity is not disclosed.

You must report any known, suspected or attempted violations of this Policy to the Compliance Department at Community – Risk and Compliance Team<aramex.compliance@aramex.com>.

If you prefer, you may anonymously report concerns through the Compliance Hotline at Service Center – Whistle Blowing <whistleblowing@aramex.com>.

Additionally, you may request the guidance of the following resources when you are uncertain about any obligations under this Policy:

  • Compliance Department;
  • Legal Department; or
  • Direct Manager (unless the nature of the issue makes doing so inadvisable).

5.        What is Corruption?

Corruption is the misuse of a position of trust to gain an unfair business or personal advantage. It usually takes place through acts of bribery, which includes the offering, promising, giving, accepting, or authorizing payment or anything of value or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward of anything of value that is offered, promised, given or accepted in order to gain any unfair business or personal advantage.

Bribes can take many forms, including but not limited to:

  • Gifts (exceeding nominal/low value).
  • Entertainment and Hospitality (lavish meals, alcohol, hotel accommodations, shows, sporting events or other high-price events).
  • Travel (plane tickets, ticket upgrades or trip expenses).
  • Facilitation Payments[1].
  • Kickbacks
  • Favorable Contracts.
  • Business Opportunities.
  • Charitable or Political Contributions.
  • Stock Options.

Bribes can be provided or received in many ways, including:

  • Directly: a customer requesting an expensive dinner, drinks, gift or a cash payment as a necessary precondition to discuss potential business for Aramex (same case applies if somebody did the same on behalf of Aramex).
  • Indirectly: a government official asking for a cash payment through a third party (i.e. consultant or agent) before granting Aramex the right to do business in a certain area or a specific way.
  • Kickbacks: an agent offering commission on any profit they gain from selling Aramex’s services in exchange of Aramex choosing them over other agents, or a customer requesting commission on Aramex’s sales in exchange of ensuring Aramex is selected over other suppliers (same case applies if somebody did the same on behalf of Aramex).

Values Checkpoint!

Scenario:

I understand Aramex’s commitment to abide by high ethical standards and prevent bribery or other corrupt acts, but what if this Policy causes me to lose business for the company and my sales target?

Response:

At Aramex, Doing the Right Thing is one of our most important values. We urge you to do the right thing, rather than engaging in an improper and potentially illegal behavior just to gain business opportunities, prevent the company from losing business or achieve your sales target.

5.1.       Red Flags

A red flag is a fact, event, or set of circumstances, or other information that may indicate a potential compliance concern for illegal or unethical business conduct.

While performing day to day work, Aramex employees and related parties may come across red flags that should trigger concern and appropriate action.  While the following examples are not exhaustive and may not in themselves constitute or indicate a violation of this Policy or the Applicable Laws, they may be indicators of potential current or future non-compliance.

Red Flag Examples:

  • Training, travel or entertainment costs exceeding reasonable levels.
  • Substantial gifts are requested for directly/indirectly.
  • Expense claims or petty cash payments are made without sufficient documentation and evidence.
  • Something of significant value is requested in return for inclusion on a tender or before a contract is awarded.
  • A commission payment is requested for carrying out normal work.
  • Requests for travel including family members.
  • Requests for payments to charities in exchange for business contracts.
  • Tasks are done more quickly or efficiently than usual.
  • Gaining preferential treatment in customs clearance procedures.
  • Unjustifiable requests that payments be made to multiple accounts.
  • Refusal to properly follow accounting procedures/policies.
  • Inaccurate, inflated, suspicious or unusual invoices.
  • Engaging incompetent suppliers/consultants/agents; lacking the staff, facilities, or expertise to perform substantial work.
  • Consultants “consulting agreements” include vaguely described services.
  • Requests that do not seem in the best interest of our business.
  • Someone who never goes on vacation in order to avoid or prevent anyone else from having contact with a particular supplier or customer.
  • A governmental employee (for example, a customs employee) insisting on using a specific vendor for supplies or subcontracting.
  • Payments in a country (jurisdiction) not related to the transaction.
  • Suspicious or inadequate termination of a business relationship.

Values Checkpoint!

Scenario:

I handle an account for a customer who told me a new vendor is offering the same price of Aramex but throwing in an additional annual training for a week for him and he is welcome to bring his spouse. The trip is an all-inclusive week long to the Bahamas. My customer informed me that such a trip is important to give a well-deserved vacation for him and his spouse, and he is inclined to go with the new vendor if we cannot match the offer. I am leaning towards matching the offer in order not to lose the business.

Response:

You should not agree to the customer’s request. Agreeing to give the customer his wish of a paid all-inclusive vacation as well as for his spouse constitutes a bribe. You should decline this offer and discuss it with your direct manager. Additionally, you should report this incident to the Compliance Team.

 

Scenario:

I work in the procurement department. Recently, a supplier came to visit our facilities. We met regarding a potential new supply contract, and the supplier knew that we were also meeting with other potential suppliers about the same. As he was leaving, the supplier offered me what appeared to be a pearl necklace as a gift for my wife in return of my hospitality. I did not think the pearls were real, so I accepted it.

Response:

You should not have accepted the gift without knowing its true value because the circumstances under which it was given indicate that the supplier’s motivation was to influence your decision on whether to give his company the contract. You should have declined the gift, or if you accepted it because you were concerned that declining would be rude or perceived as an insult, you should have immediately visited your Compliance Department to disclose the gift and turn it over for handling.

6.        Guidelines

This section provides guidance on specific transactions, with reference to Aramex’s requirements and expectations and should be used as a reference to make sure the transactions and business relationships comply with our Code of Conduct and this Policy.

6.1.       Gifts, Entertainment and Hospitality

Doing business often involves giving and receiving some common courtesies, such as discussing a sales agreement over lunch, meeting with clients for dinner or accepting promotional items at a trade show. However, it is not always easy to identify whether providing gifts, entertainment or hospitality would be considered a corrupt act under Applicable Laws.

Under certain circumstances, it is permissible by the Applicable Laws to provide modest gifts or a meal or other entertainment as a social amenity, and this Policy is not meant to hinder your ability to build relationships with external parties and compete in the market, but rather, it should help you identify acceptable and legal business courtesies.

Generally, gifts, entertainment and hospitality are permissible, provided that:

  • There is no expectation that the gift, entertainment or hospitality is given or received in exchange of any return, favor or business advantage from the receiver.
  • The gift, entertainment or hospitality is infrequent, reasonable and proportionate in amount under the circumstances.
  • Your direct manager, Compliance Department and Legal Department are always consulted regarding the acceptability of the offering under Applicable Laws and this Policy.

For more details, you must read and follow the COM 1151 – (B) Aramex Gifts, Entertainment and Hospitality Policy

6.2.       Third Parties

Engaging Third Parties is a necessary part of our business. They provide materials and services necessary to build our services, represent our brand in global markets and reach new customers.

Applicable Laws prohibit corrupt acts made indirectly through Third Parties acting for or on behalf of the company. Essentially, these third parties are an extension of Aramex, and any corrupt acts they carry out while conducting business for us might create liability for our company.

Accordingly, the most important step the company can take to protect itself from liability for improper acts made by Third Parties is to choose them and monitor them carefully.

The company should never enter into any relationship with a third party who, for instance, will have substantive interaction with government officials on behalf of the company without an inquiry into the third party’s background, qualifications and reputation.

Therefore, we must only choose business partners that would fairly represent our brand and values

For more details, you must read and follow the Third Parties’ Due Diligence Policy.

6.3.       Political Contribution

To remain free from corruption, we need to be aware of requests for political contributions by counterparties or government officials in exchange for influencing a transaction or spurring the completion of a pending deal. For example, a potential customer might state that he will buy Aramex products if we make a contribution to a government department, organization, political party or group with which the customer or his relatives are associated. Political contributions are especially concerning because they are hard to trace back to the person, group or company that requested them.

To minimize the possibility of corruption, we cannot make political contributions on Aramex’s behalf without obtaining the prior written approval of the Sustainability Department.

Under no circumstances can a political contribution be made to gain an improper advantage, or it would otherwise violate this Policy and Applicable Laws.

For Political Contributions, you must read and follow the Political Contributions and Involvement Policy.

6.4.       Charitable Contributions

As a global company, we can help those in need through charitable contributions. However, charitable contributions, like political contributions, can be a devious way to give bribes. This can occur when counterparties or government officials request donations to charities with which they are associated as a prerequisite to or part of a transaction with us.

To minimize the possibility of corruption, we cannot make charitable contributions on Aramex’s behalf without obtaining the prior written approval of the Sustainability Department.

Under no circumstances can a charitable contribution be used to gain an improper advantage, or otherwise violate this Policy and Applicable Laws.

For Charitable Contributions, you must read and follow the Charitable Donations and Sponsorships Policy.

Values Checkpoint!

Scenario:

We engaged an agent to help facilitate an agreement with a new customer. The agent informed us that the customer’s representative would conclude the contract with Aramex if we directed an initial lump-sum payment to a charity that his wife has organized. I informed the agent that this is against our Policy and we cannot make this payment to conclude negotiations.

Response:

In this case, you lived up to our values. The customer’s representative required Aramex to make a charitable contribution in order to secure a business advantage. Any payment made to secure such an advantage is against our Policy, even if it is made for a good cause.

6.5.       Facilitation Payments

Facilitation payments or “grease payments” are offers or payments made to a government official to expedite or secure the performance of a routine governmental action, such as issuing permits or releasing shipments held at customs.

Facilitation payments are prohibited under this Policy. Although there is a narrow exception for facilitation payments under the FCPA, such payments are prohibited under the UKBA and the laws of many other countries. Therefore, in order to ensure compliance with the Applicable Laws, Aramex prohibits facilitation payments altogether.

The prohibition extends to payments made by third parties or business partners on behalf of Aramex.

Values Checkpoint!

Scenario:

We engaged an agent to help us submit a bid for a warehouse construction. The agent informed us that to begin the bidding process, we would need to be granted a permit by the local government authorities, and that the permit could take up to 90 days to be granted. The agent said she could make a small payment to one of the officials at the government to expedite the issuance of the permit. I told the agent to go ahead with the payment.

Response:

Facilitation payments are against our Policy. In this case, you have not lived up to our values and the needed disciplinary action will be exercised considering the scenario and circumstances.

6.6.       Government Officials

A government official is any officer or employee of a government, any public international organization (i.e. United Nations, the World Bank, or the International Monetary Fund) or any department, agency of a government or of any public international organization, or any person of a company, entity, or any other organization owned or controlled by, or acting in an official capacity on behalf of, any of the mentioned before.

Activities and dealings with government officials are highly regulated under the Applicable Laws. Employees should always consult the Compliance and Legal Departments to ensure that they are acting in accordance with this Policy and Applicable Laws.

Providing anything of value to a government official is prohibited under this Policy and is considered a violation of Applicable Laws.

Values Checkpoint!

Scenario:

Sara is trying to obtain a permit to get permission to use a particular piece of property for a warehouse in a new location. She knows that these permits are limited, and there are competitors also trying to get a permit for that same location. A local official takes Sara aside and says that he will favor her request over those of the competitors if she, personally, gives him $5,000 in cash. He explains that this is how business is done, and if she doesn’t do it, then he will issue the permit to a competitor who does pay. Sara doesn’t want to lose business for the company, so she makes the payment.

Response:

Sara did not live up to our values. The local official that Sara offered payment to, is likely considered a government official under Applicable Laws, and the payment is a bribe because it was made to gain an improper business advantage.

6.7.       Exception for Extenuating Circumstances

There are certain situations where you are permitted to make a payment that is otherwise not allowed under the Applicable Laws or this Policy. These situations are rare and the payment is allowed only if extenuating circumstances exist when a demand is made for a payment that could lead to bodily harm or other safety threats. For example, when a payment must be made immediately to ensure safe passage out of a particular place.

The threat could be to yourself, your family members, your colleagues or their family members.

Employees should make whatever payment is necessary to protect their personal safety, and then, as soon as reasonable, report the nature of the incident and related payment to the Compliance and Legal Departments.

7. Accounting and Recordkeeping

All transactions must be recorded accurately and transparently. Proper and accurate record keeping ensures that all dealings and transactions are free of corruption. Therefore, we must comply with all accounting regulations and standards, as well as our internal policies.

Furthermore, when making expenditures on behalf of Aramex, we must properly record the details of all transactions, accounting for all funds and benefits received as part of these transactions.

Extra care must be taken to ensure that the treatment of any gifts, entertainment, hospitality or other benefits provided to officials in the public and private sectors, comply with the Applicable Laws, this Policy and Aramex’s accounting and recordkeeping requirements.

To comply with these requirements, all employees and related parties must:

  • Follow company’s accounting requirements as set out in the standard policies and procedures.
  • Accurately record all transactions, even when the transaction might violate the Applicable Laws and this Policy.
  • Never agree to requests for false invoices or for payments of expenses that are unusual, excessive, or inadequately described.
  • Never make any payments to anonymous accounts that are not in the name of neither payee nor the entity known to be controlled by the payee.

Proper recordkeeping is essential to our compliance with the Applicable Laws and for us to maintain and uphold the spirit of this Policy, furthermore, to establish that the company has adequate procedures in place to prevent corruption.

8. Non-Compliance Disciplinary Measures

Beyond the legal and financial penalties that Aramex and its employees could suffer because of non-compliance with the Applicable Laws and this Policy, failure to comply can also result in disciplinary actions, as permitted by law, up to and including termination of employment.

Additionally, some laws call for disciplinary fines reaching tens of millions of dollars as well as imprisonment that could reach up to 20 years for violators.

Managers who fail to supervise employees’ compliance with this Policy may also be subject to disciplinary actions. Managers should lead by example and be a resource for employees who have questions or need advice.

For Compliance Disciplinary, you must read and follow the COM 1151 – (E) Aramex Non-Compliance Disciplinary Policy.

9.        Conclusion

Thank you for reading our Anti-Corruption Policy. The information in this Policy supplements our Code of Conduct, serves as a manual to help you face potential corruption with confidence and gives you the tools necessary to make the right decision.

Most importantly, this Policy demonstrates our commitment to supporting you as an Aramex employee or related party, and our genuine interest in helping you make decisions in accordance with our values.

If a situation does not feel right, you have our full support to walk away from it and seek further guidance from various resources within the company as described in the “Reporting Violations” section of this policy.

For further information on our values and commitment to ethical conduct, please see the following resources:

  • Aramex Code of Conduct.
  • Gifts, Entertainment and Hospitality Policy.
  • Conflict of Interest Policy.
  • Third Parties Due Diligence Policy.
  • Anti-Money Laundering Policy.
  • Non-Compliance Disciplinary Actions Policy.

10.        References

Aramex.net à Infohub à Compliance à Policies & Standards:

  • COM 1151 – (B) Aramex Gifts, Entertainment and Hospitality Policy
  • COM 1151 – (E) Aramex Non-Compliance Disciplinary Policy

1.        Policy Purpose

The purpose of the Aramex Gifts, Entertainment and Hospitality Policy (“Policy”) is to give clear instructions to Aramex employees and other Related Parties[1] when receiving or offering gifts, entertainment or hospitality.

Business gifts, entertainment and hospitality on a modest scale are commonly used to build goodwill and strengthen working relationships. It is part of business and cannot be avoided, however, Aramex discourages and forbids any unethical gifts, entertainment or hospitality whether in fact or appearance. Additionally, “allowable and ethical” gifts, entertainment or hospitality should not be considered as favors with an expected return.

Offering or accepting occasional meals, small company souvenirs and tickets to sporting and cultural events may be appropriate in certain circumstances.

Occasionally, it may also be appropriate to accept or provide offers involving travel to business events with business associates. However, if offers of gifts, entertainment or hospitality are frequent or of substantial value, they may create the appearance of, or an actual, conflict of interest or illicit payment.

This Policy:

  • Advises the laws applicable to our business worldwide, as well as the importance of complying with these laws;
  • Describes acceptable and non-acceptable gifts, entertainment, and hospitality;
  • Illustrates situations where unethical situations might occur and guidance on how to handle them; and
  • Details the avenues of support to be used for reporting concerns and gaining additional guidance.

2.        Applicability

This Policy applies to all employees of Aramex and its worldwide Related Parties, including officers, directors, full-timers, part-timers, contract and temporary employees. It covers all aspects of work, transactions, activities and business endeavors.

3.        Applicable Laws

Aramex is committed to fair and ethical business practices and avoiding corruption of all kinds, including bribery of Government Officials[2] and private (non-government) individuals and entities. We abide by all applicable anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA) of the United States, the U.K. Bribery Act (UKBA), the United Nations Convention against Corruption (UNCAC) and the local laws in every country in which we operate (“Applicable Laws”).

Some countries in which we operate may have laws stricter than those mentioned in this Policy. As a general rule, we follow the most stringent law, regulation or policy applicable to our business in these countries.

The combination of Applicable Laws and our global presence requires maximum alertness to corruption and full awareness of how to recognize and eliminate it from any transaction we are part of. In case of any doubt about what is expected of you under the Applicable Laws or this Policy, you must seek guidance from the Compliance or Legal Departments.

4.        Responsibility (Call for Action)

As employees and Related Parties of Aramex, we are all responsible to uphold the company values and to conduct business with integrity and honesty. The following actions must be taken to fulfill our commitment to fair and ethical business practices:

  • Step away from situations that involve corruption or those that may be viewed as involving corruption.
  • Stay alert to any red flags suggesting wrongdoing by another employee or a Related Party.
  • Support and encourage other employees and Related Parties to comply with this Policy.

4.1.       Reporting Violations

If you have any questions or concerns, or if you witness potential violations of this Policy, you must share your concerns with us. We operate under a “no retaliation” policy, which means that we will never retaliate against anyone who reports a concern to us in good faith. Additionally, your report will be treated with the highest level of confidentiality and we will endeavor to ensure that your identity is not disclosed.

You must report any known, suspected or attempted violations of this Policy to the Community – Risk and Compliance Team <aramex.compliance@aramex.com>.

If you prefer, you may anonymously report concerns through the Compliance Hotline at Service Center – Whistle Blowing <whistleblowing@aramex.com>.

Additionally, you may request the guidance of the following resources when you are uncertain about any obligations under this Policy:

  • Compliance Department;
  • Legal Department; or
  • Direct Manager (unless the nature of the issue makes doing so inadvisable).

5.        What are Gifts, Entertainment, and Hospitality:

5.1.       Gifts

Anything of value, including cash[1] and cash equivalent, merchandise, gift certificate, gift basket, token of appreciation, prize, discount, air ticket upgrade, loan, favor, sample, promotional item, product, service or promise of any of the aforementioned.

5.2.       Entertainment and Hospitality

Any travel, transportation, lodging, hotel accommodation, dining, tour, cultural event, social event or sporting event and/or other entertainment.

6.        Guidelines

This section provides guidance with reference to Aramex’s requirements and expectations, and must be used as a reference to ensure that all gifts, entertainment and hospitality transactions comply with our Code of Conduct and this Policy.

6.1.       General Guidelines

The following are general guidelines for offering or accepting any type of gifts, entertainment or hospitality:

  • A gift, entertainment or hospitality that may constitute the appearance of, or an actual, conflict of interest or illicit payment is not allowed under any circumstances.
  • A gift, entertainment or hospitality can be justifiable if there is a clear business reason for it, and the total cost must not exceed USD 50 in value and must be approved by the Station/Country Manager and the Accounting Manager.

Exceptions to gifts, entertainment, or hospitality that exceed USD 50 must be properly approved as follows:

  • From USD 50 up to USD 100 by the Station/Country Manager and the Regional Financial Controller.
  • From USD 100 up to USD 500 by the Regional CEO and the Regional Financial Controller.
  • Over USD 500 by the CEO, CFO or COO.
  • Cash or cash equivalents are not permissible under any circumstances.
  • No gift, entertainment or hospitality may be offered to or accepted from Government Officials.
  • No gift, entertainment or hospitality is offered or accepted during the bidding phase to a contract or contract renewal.
  • All gift, entertainment or hospitality of any value, must be properly reported, approved, logged and recorded.
  • Offered or accepted gifts, entertainment, or hospitality must not constitute the appearance of, or an actual luxurious, unethical, or culturally inappropriate form (i.e. alcohol, narcotics, adult entertainment).

6.2.       Offering or Accepting Gifts Guidelines:

  • It is only acceptable to offer or accept gifts that have the company’s logo on them. These include t-shirts, mugs, pens, calendars, pen holders, stress balls, notebooks or similar items.
  • No multiple gifts per individual are allowed, unless it is a bundled pack of lower value items such as a logoed pen, calendar and a mug. In this case the bundled pack is considered one gift but should not be repeated.
  • All exceptions to the gifts guidelines must be properly approved by Station/Country Manager and the Regional Financial Controller.

Values Checkpoint!

 

Gift Value Test:

If you are not sure about the value of a gift received or offered, a quick test would be to ask yourself to forfeit the gift or throw it away. If you hesitate because you believe the gift has value, then it might be considered an improper gift.

6.3.       Offering or Receiving Entertainment and Hospitality Guidelines:

  • No multiple or repeated dining, tours, cultural events, social events or sporting events and/or entertainments per individual are allowed.
  • Business related activities such as seminars, presentations and meetings should be the major part of any invitation program. Necessarily, non-business-related activities such as dinners, social events, cultural events and sports events should be a small part of the whole program.
  • Travel and accommodation expenses associated with any invitation should not be offered or received.
  • All travel and accommodation expenses for invited Aramex employees or representatives of Aramex should not be accepted and should be fully paid by Aramex.
  • All travel and accommodation expenses for invitees should not be offered and should be fully paid by the invitees.
  • Business and first-class tickets are not allowed under any circumstances.
  • Per diems and pocket money are not allowed to be offered to or received from a third party under any circumstances.
  • Travel and accommodation expenses are not allowed to family members, relatives or friends.
  • All exceptions to the entertainment and hospitality guidelines must be properly approved by the Station/Country Manager and the Regional Financial Controller.

Values Checkpoint!

 

The Front-Page Test:

When you are thinking how to handle a situation, consider how it would look on the front page of the newspaper. How would you feel if everyone is sharing your decision and activities on social media?

  • If you are having a hard time defending something to the public, then maybe, you need to rethink your actions.

Scenario:

My colleague and I are planning to take a customer to an expensive resort in the Swiss Alps for a weekend of skiing, all expenses paid by Aramex. He is a good customer, and we are looking to expand the business with him. Plus, we have become friends with this customer and often get together with him and his family for dinner after working hours, so I know he is looking forward to it and Aramex will be rewarded for our effort.

 

Response:

In this situation, you did not live up to our values. Our guidelines on entertainment state that we can provide reasonably valued and modest entertainment to external parties. Taking the customer for such an expensive trip is not in alignment with these guidelines, particularly when he is also becoming a friend. If you are even considering such a trip, you must consult with the Compliance or Legal Department prior to committing to this.

6.4.       Offering Gifts, Entertainment or Hospitality to Government Officials Guidelines:

Our policy is not to offer gifts, entertainment, or hospitality to Government Officials, but if a very specific circumstance appears, it may be approved after careful consideration.

In addition to the previously mentioned guidelines, it should as well be:

  • Consistent with local laws.
  • Directly related to the promotion, demonstration, explanation of products and services, execution of a contract or establishing a business relationship with the Government Official’s employer/organization.
  • Openly processed through the Government Official’s employer/organization.
  • Properly documented, supported with official receipts.
  • Properly approved by the Regional Financial Controller and Regional CEO.
  • Discussed with the Compliance Department for advice.

Values Checkpoint!

Scenario:

A new regulation was imposed to restrict pollution output. As a result, we have modified our vehicles in a remote area of our network. Furthermore, we sought advice from the government office to have a pre-inspection of the results of our efforts. The Government Official informed us that they are always willing to support companies with pre-inspections, however, we must pay for the Officials’ travel and accommodation to the remote place as per the government’s written policy. I am going to request for funding for the Official’s travel and accommodation and consult with our Compliance Department before proceeding.

Response:

In this case, you lived up to our values. You are only going to offer the Government Official hospitality expenses after consulting with the Compliance Department. Additionally, a written policy by the government that such expenses should be paid by the companies supports the diligent way you are going to conduct this transaction. Just make sure to get the needed approvals.

7.        Gifts, Entertainment and Hospitality Forms and Logs

All gifts, entertainment and hospitality transactions must be logged and filed using the form in “Appendix A” or COM 1151 – (H) Improper Gifts, Entertainment, and Hospitality Request Form available on infohub.

  • The form should be completed and approved prior to accepting or offering gifts, entertainment or hospitality.
  • The approval follows the mandate previously detailed in the “General Guidelines” of this Policy.
  • Once the form is completed and approved, it must be sent to the Accounting Department for filing and logging.
  • The log must include at least the following details:
  • Requester Name.
  • Approver Name/s.
  • Type (Receiving/Offering).
  • Type (Gift, Entertainment or Hospitality).
  • Receiver/Offeror Name.
  • Receiver/Offeror Company.
  • Business Need.

8.        Accounting and Recordkeeping

All transactions must be recorded accurately and transparently. Proper and accurate recordkeeping ensures that all dealings and transactions are free of corruption. Therefore, we must comply with all accounting regulations and standards, as well as our internal policies.

Furthermore, when making expenditures on behalf of Aramex, we must properly record the details of all transactions, accounting for all funds and benefits received as part of these transactions.

Extra care must be taken to ensure that the treatment of any gifts, entertainment, hospitality or other benefits offered to officials in the public and private sectors, comply with applicable laws, this Policy and Aramex’s accounting and recordkeeping requirements.

To comply with these requirements, all employees and related parties must:

  • Follow Company’s accounting requirements as set out in the standard policies and procedures.
  • Accurately record all transactions, even when the transaction might violate the applicable laws and this Policy.
  • Never agree to requests for false invoices or for payments of expenses that are unusual, excessive, or inadequately described.
  • Never make any payments to anonymous accounts that are not in the name of neither payee nor the entity known to be controlled by the payee.

Proper recordkeeping is essential to our compliance with the applicable laws and for us to maintain and uphold the spirit of this Policy, furthermore, to establish that the Company has adequate procedures in place to prevent corruption.

9.        Non-compliance Disciplinary

Beyond the legal and financial penalties that Aramex and its employees could suffer as a result of non-compliance with applicable laws and this Policy, failure to comply can also result in disciplinary actions, as permitted by law, up to and including termination of employment.

Additionally, some laws call for disciplinary fines reaching tens of millions of dollars as well as imprisonment that could reach up to 20 years for violators.

Managers who fail to supervise employees’ compliance with this Policy may also be subject to disciplinary actions. Managers should lead by example and be a resource for employees who have questions or need advice.

For Compliance Disciplinary, you must read and follow the COM 1151 – (P) Non-Compliance Disciplinary Policy

10.        Conclusion

Thank you for reading our Gifts, Entertainment and Hospitality Policy. The information in this Policy supplements our Code of Conduct, serves as a manual to help you face potential corruption with confidence and gives you the tools necessary to make the right decision.

Most importantly, this Policy demonstrates our commitment to supporting you as an Aramex employee or related party, and our genuine interest in helping you make decisions in accordance with our values.

If a situation does not feel right, you have our full support to walk away from it and seek further guidance from various resources within the company as described in the “Reporting Violations” section of this policy.

1.        Accounting and Recordkeeping

All transactions must be recorded accurately and transparently. Proper and accurate recordkeeping ensures that all dealings and transactions are free of corruption. Therefore, we must comply with all accounting regulations and standards, as well as our internal policies.

Furthermore, when making expenditures on behalf of Aramex, we must properly record the details of all transactions, accounting for all funds and benefits received as part of these transactions.

Extra care must be taken to ensure that the treatment of any gifts, entertainment, hospitality or other benefits offered to officials in the public and private sectors, comply with applicable laws, this Policy and Aramex’s accounting and recordkeeping requirements.

To comply with these requirements, all employees and related parties must:

  • Follow Company’s accounting requirements as set out in the standard policies and procedures.
  • Accurately record all transactions, even when the transaction might violate the applicable laws and this Policy.
  • Never agree to requests for false invoices or for payments of expenses that are unusual, excessive, or inadequately described.
  • Never make any payments to anonymous accounts that are not in the name of neither payee nor the entity known to be controlled by the payee.

Proper recordkeeping is essential to our compliance with the applicable laws and for us to maintain and uphold the spirit of this Policy, furthermore, to establish that the Company has adequate procedures in place to prevent corruption.

2.        Non-compliance Disciplinary

Beyond the legal and financial penalties that Aramex and its employees could suffer as a result of non-compliance with applicable laws and this Policy, failure to comply can also result in disciplinary actions, as permitted by law, up to and including termination of employment.

Additionally, some laws call for disciplinary fines reaching tens of millions of dollars as well as imprisonment that could reach up to 20 years for violators.

Managers who fail to supervise employees’ compliance with this Policy may also be subject to disciplinary actions. Managers should lead by example and be a resource for employees who have questions or need advice.

For Compliance Disciplinary, you must read and follow the COM 1151 – (P) Non-Compliance Disciplinary Policy

3.        Conclusion

Thank you for reading our Gifts, Entertainment and Hospitality Policy. The information in this Policy supplements our Code of Conduct, serves as a manual to help you face potential corruption with confidence and gives you the tools necessary to make the right decision.

Most importantly, this Policy demonstrates our commitment to supporting you as an Aramex employee or related party, and our genuine interest in helping you make decisions in accordance with our values.

If a situation does not feel right, you have our full support to walk away from it and seek further guidance from various resources within the company as described in the “Reporting Violations” section of this policy.

  • Support and encourage other employees and Related Parties to comply with this Policy.

4.1.       Reporting Violations

If you have any questions or concerns, or if you witness potential violations of this Policy, you must share your concerns with us. We operate under a “no retaliation” policy, which means that we will never retaliate against anyone who reports a concern to us in good faith. Additionally, your report will be treated with the highest level of confidentiality and we will endeavor to ensure that your identity is not disclosed.

You must report any known, suspected or attempted violations of this Policy to Community – Risk and Compliance Team <aramex.compliance@aramex.com>.

If you prefer, you may anonymously report concerns through the Compliance Hotline at Service Center – Whistle Blowing <whistleblowing@aramex.com>.

Additionally, you may request the guidance of the following resources when you are uncertain about any obligations under this Policy:

  • Compliance Department;
  • Legal Department;
  • The Human Resources Department; or
  • Direct Manager (unless the nature of the issue makes doing so inadvisable).

5.        What is a Conflict of Interest?

Conflict of interest is a situation in which a person or organization is involved in multiple interests, financial or non-financial, one of which could possibly impair the motivation or decision-making of that individual or organization.

Conflicts of interest can create potential divided loyalties between your personal interests and your obligations to Aramex, potentially adversely affecting the way you perform your duties at Aramex. A conflict of interest may unconsciously influence you, and even the mere appearance of a conflict of interest can cause your actions, reputation and integrity to be questioned.

Conflicts of interest have the following main types:

5.1.       Actual Conflict of Interest

An actual conflict of interest involves a direct conflict between an employee’s or a Related Party’s current duties and responsibilities, and existing personal interests. Actual conflicts of interest occur when there is a clear evidence that a person is not putting the company’s interest first but instead seeking to benefit themselves, their relatives, close friends or other parties.

5.2.       Perceived (Apparent) Conflict of Interest

A perceived or apparent conflict of interest can exist where it could be perceived, or it appears to others, that an employee’s or a Related Party’s personal interests influence the performance, actions, or duties and responsibilities – whether or not this is in fact the case. For example, there could be a situation where your actions are in the best interest of Aramex, but to an outsider viewing the situation, it appears that a conflict of interest exists.

5.3.       Potential Conflict of Interest

A potential conflict of interest arises when an employee, or a Related Party, has a personal interest that could conflict with their duties and responsibilities in the future, usually due to change in circumstances. In other words, something might happen in the future that will become a conflict, however as it stands, there is nothing to do about it.

For example, assume that you are a procurement officer at Aramex and your spouse was approached to work as a sales officer for a big supplier, this is still a potential conflict, but if she accepts the job, the potential conflict will become an actual conflict.

Values Checkpoint!

Scenario:
I am a Country Manager, and my brother has applied for a vacancy to work in our station as an Accounting Manager. He is very qualified and might be reporting directly to me. Would this be a conflict of interest? What type of a conflict of interest will this be if he is hired?

 

Response:

Yes, this has potentially all three types of a conflict of interest:

Potential: since your brother applied for the vacancy, there is the potential of him reporting to you (if he is hired) which constitutes a potential conflict of interest.

Perceived: When a close relative works with an employee at the same company and in the same team, there is a perceived conflict such as a perceived preferential treatment.

Actual: if he is hired and reports directly to you, then you and your brother will have an actual conflict of interest.

5.4.       Red Flags

A red flag is a fact, event, or set of circumstances that may indicate a potential compliance concern for illegal or unethical business conduct. Although some conflicts of interest might be hard to identify, there are some clear warning signs to look out for.

While performing day to day work, Aramex employees and Related Parties may come across red flags that can create or lead to a conflict of interest, which should trigger concern and appropriate action.

The following examples are not exhaustive and may not in themselves constitute or indicate a violation of this Policy or the Applicable Laws, they may be indicators of potential current or future non-compliance.

Red Flag Examples:

  • Accepting gifts, entertainment and hospitality (exceeding nominal/low value).
  • Charitable or political contributions.
  • Holding government jobs/appointments/elected positions.
  • Employment and/or supervision of close relatives.
  • Working for and/or Investing in competitors, suppliers, related parties, and/or customers.
  • Taking business opportunities that rightfully belong to Aramex.
  • Working for other organizations.
  • Steering business to specific vendor, supplier or consultant regardless of quality and need.

To learn more about these red flags, please go to the guidelines in “Section 7” of this Policy.

6.        Identifying and Disclosing Conflicts of Interest

Employees and related parties are responsible for identifying and disclosing their own conflicts of interest. If you are aware of or even suspect that you may have a conflict of interest, you must immediately disclose it in accordance with this Policy.

Disclosing information about conflicts of interest helps ensure that you are not placed in a position of choosing between a personal interest and the interests of Aramex. It allows Aramex to evaluate the relevant circumstances and facts to determine if an actual conflict exists. Ultimately, it helps protect Aramex’s brand and reputation, in addition to the reputation of individuals and Related Parties.

6.1.       Identifying Conflicts of Interest

To properly identify conflicts of interest, consideration should be given to whether an employee or a Related Party could be influenced, or appear to be influenced, by personal interests while performing their roles.

Employees and Related Parties need to consider:

  • If they, or someone associated with them, would benefit or be harmed, directly or indirectly, now or in the future, by a decision they may be involved in.
  • Whether they, or someone associated with them, has received a gift or benefit from another person or business who would benefit from a decision they may be involved in.
  • Whether a member of the public would view their decision as being influenced by their personal interests or associations with other persons/entities.

6.2.       Conflict of Interest Declaration Form

On a yearly basis, every employee and Related Party must fill in the “Conflict of Interest Form” in “Appendix A” or COM 1151 – (D) Conflict of Interest Declaration Form available on infohub. Moreover, the same form should be filled whenever a conflict of interest is identified. This is important to properly review conflict of interest situations and determine the appropriate actions to be taken.

Once the form is completed, the original signed copy should be handed to the Direct Manager and the Human Resources Department (for employees) and to the Procurement Department (for related parties).

In the conflict of interest declaration form:

  • New Employees will be requested by the Human Resources to disclose any conflict of interest they are aware of when they commence employment with Aramex.
  • Every existing employee will be annually requested by Human Resources to disclose any conflict of interest they are aware of, including those previously disclosed.
  • Every existing employee must immediately report any conflict of interest to the Direct Manager and the Human Resources when a conflict of interest occurs or upon becoming aware of a conflict of interest.
  • Related Parties will be requested by the Procurement Department to disclose any conflict of interest they are aware of when they commence business with Aramex.
  • Every Related Party will be annually requested by Procurement Department to disclose any conflict of interest they are aware of, including those previously disclosed.

Remember, you have an ongoing obligation to disclose any conflict of interest you are aware of, so keep this Policy in mind whenever there are any changes in business strategies or your work circumstances (i.e. you are promoted or transferred to a different department or country) as this may create a conflict of interest that did not exist before.

6.3.       Reviewing and Managing Conflicts of Interest

After the form is submitted, Aramex will conduct follow up activities and ask more questions about the situation, to determine the best course of action to be taken.

Disclosing a situation does not mean that there will always be a conflict of interest. Each situation is unique, and we will always try to work out the best solution to any conflict.

  • On receipt of the written declaration, the Direct Manager must assess the situation and determine whether a potential or actual conflict exists.
  • The Direct Manager must bring the conflict situation to the Station/Country Manager for consideration and a decision regarding resolving the conflict.
  • If necessary, the Station/Country Manager should seek advice from the Human Resources, Legal or Compliance Departments to determine the appropriate action to manage or resolve the conflict.
  • Meanwhile, the Direct Manager is to advise the employee not to take further action in relation to the conflict until a decision is made by the Station/Country Manager.
  • Conflicts of interest may be resolved or managed in a variety of ways, the choice of strategy will depend on the assessment and the advice received.

Some ways to resolve or manage a conflict are:

  • Restrict: restrictions are placed on the employee’s involvement in the matter of creating the conflict.
  • Remove: the employee is removed from their involvement in the matter of creating the conflict.
  • Recruit: an independent third party (i.e. internal or external) is used to oversee part or all of the process that deals with the matter of creating the conflict.
  • Renounce: the employee renounces the personal interest that is creating the conflict.
  • Resign/Relocate: the employee resigns or relocates from his/her current position.
  • Once a decision is made, it will be clearly relayed to the employee in writing, stating what actions and expectations are required by the employee.
  • Formal written records should be kept of all reassessments, decisions made, and actions taken in relation to any conflict of interest.

7.        Guidelines

This section provides guidance on specific transactions, with reference to Aramex’s requirements and expectations and should be used as a reference to make sure that all transactions and business relationships comply with our Code of Conduct and this Policy.

7.1.       Accepting Gifts, Entertainment and Hospitality

The acceptance of gifts, entertainment and hospitality could lead to a conflict of interest, if they are meant to influence decision-making or impair judgment towards a certain action.

For more details, you must read and follow the COM 1151 – (B) Aramex Gifts, Entertainment and Hospitality Policy

7.2.       Charitable and Political Contributions

Charitable and political contributions could lead to a conflict of interest, if they are meant to influence decision-making or impair judgment towards a certain action.

For Charitable and Political Contributions, you must read and follow the policies located at:

Charitable Donations and Sponsorships Policy

Political Contributions and Involvement Policy

Values Checkpoint!

 

Scenario:
My children attend a private school, and recently the school has started a fundraiser for a new gymnasium. They are struggling to raise the money needed to start construction and need additional donations. I know that Aramex supports the communities we operate in and this seems like a great opportunity to give back. Can I use $500 of company funds to donate on behalf of the company to my children’s school?

Response:
No. All charitable donations need to be properly reviewed and approved. It might seem like a conflict of interest because your children will directly benefit from the donation as they are attending the school and will be using the gymnasium. Aramex supports the communities that we operate in but in a way that is responsible and will not create the appearance of a conflict of interest.

7.3.       Holding Government Positions

Working for a government[1], or being closely related to a government official can sometimes cause a conflict of interest. It does not matter if the government job was by appointment, an elected position, or other basis; the guidelines remain the same. Because government officials create laws, set policies, and act in a position of power in public and private sectors, it could appear to be a conflict of interest for an Aramex employee to serve as a government official. Employees must disclose any sort of government employment to Aramex as soon as possible and typically before start working for the government.

There are also laws in some countries that deal with hiring current and former government officials that we must abide by. Disclosing your government job will not necessarily preclude you from working with Aramex.

7.4.       Employment and/or Supervision of Close Relatives

Aramex respects that our employees value strong family relationships and might consider family members for positions at our company. However, it is of utmost importance that

Close Relatives[1] who are candidates for Aramex positions are considered under the same standards as other candidates, and that Aramex employees who happen to be close relatives are not given preferential treatment.

If you have a family member who is interested in an Aramex position, you should disclose it in accordance to this Policy. If you think that a certain employee is receiving preferential treatment because of family relations, you should report your concerns to the Compliance Department.

Other relatives from the bigger family circle (i.e. grandparents, grandchildren, aunts, uncles, relatives-in-law, cousins, nephews, nieces. . . etc.) might have the same influence of Close Relatives on decision-making and might impair judgment, leading to a conflict of interest. Consequently, the same disclosure and reporting rules of this Policy apply.

In all cases, you should never be in a position that you oversee or are overseen by a family member. Additionally, you should never work in departments that may influence or complement each other, such as working as a Procurement Manager while your wife is the Accounting Manager.

Values Checkpoint!

Scenario:
My sister is an experienced supply chain specialist and is looking for a new job. I recently came across an internal announcement about a need for supply chain manager. I think she would be a great fit for the job, can I recommend that she apply for the job?

Response:
Yes. You can recommend that your sister apply for the job. The knowledge and networking communities of Aramex’s employees are of our most valuable assets. Our policy on hiring family members is not meant to keep us from legitimately hiring qualified candidates who are also members of your family. However, we need to be sure that other employees are involved in the hiring process and it is not your sole decision or influenced by you.

7.5.       Working for and/or Investing in Competitors, Suppliers, Business Partners or Customers

Doing work for competitors is always a conflict of interest.  The company does not allow employees to work for both Aramex and competitors. As Aramex operates in a very competitive business landscape, we need to ensure that the integrity of our data and employees is uncompromised. If someone works for a competitor, they risk violating confidentiality relating to business secrecy or being viewed as not fully dedicated to their employers.

Similarly, working for Aramex’s suppliers, vendors, business partners, or customers can likely constitute a conflict of interest. This can create a conflict because employees can be

regarded as being on both sides of a deal where the best interests of both parties cannot be attained.

Some types of investments that could cause a conflict of interest are the ones that are made in the business of our competitors, suppliers, business partners and/or customers. An investment in suppliers or other business partners, could influence an employee to retain these business partners even when doing so is not in the best interest of Aramex.

If you invest in or considering investing in other organizations, you should disclose this to Aramex well before the investment is made.

Values Checkpoint!

 

Scenario:
Our company has been a long-time partner with one of our biggest air freight providers and has established a mutually beneficial relationship. I oversee operations with this service provider. I know that Aramex’s business makes up a substantial portion of revenue for the service provider and we are about to sign a new contract with them soon. Since I am

knowledgeable about their operations and believe they are a reputable and successful company, would it be okay for me to buy some stock in this service provider?

Response:
No. Buying shares in this service provider, creates a conflict of interest because you would be impacted by Aramex’s determination to retain this service provider. You should not invest in competitors, business partners, or similar companies without discussing the matter with the Compliance or Legal Departments.

7.6.       Taking Business Opportunities that Rightfully Belong to Aramex

While doing business and day-to-day work, you may learn of opportunities that you could take advantage of to increase your personal income. This personal enrichment can come in the form of money, tangible benefits, avoidance of losses or other advantages. Any business opportunities that you learn about in the course of your employment with Aramex must be used exclusively for the benefit of the company.

Values Checkpoint!

Scenario:
My colleagues worked on a contract and lost it due to pricing issues. I decided to tell a friend and take the account with him where we could meet the price requirements of the customer. As a result, I worked on the account on my free time and delivered the services to the customer without affecting my work at Aramex. Would this be considered a conflict of interest?

Response:
Yes. You should not approach any customer of Aramex to perform work even if the contract did not materialize. Aramex might still do business with the customer and you will be in conflict because you are personally benefiting through your association with Aramex.

7.7.       Working for Other Organizations

Doing work for other organizations, freelancing or doing entrepreneurial work while being employed at Aramex can sometimes, but not always, be a conflict of interest.  In all situations, written pre-approval is required prior to accepting another job outside of Aramex.  It is not allowed to consider work opportunities from other organizations that are in the same industry as Aramex as these companies can be competitors, suppliers or business partners.  Employees are not allowed to work for Aramex while starting businesses that could operate in the same industry as Aramex or be a competitor.

Aramex does not put a complete restriction on doing work for other organizations but any other work you perform must not affect your ability to effectively perform your duties at Aramex. It may be acceptable to take another job with a company that operates outside of Aramex’s industry and does not compete with Aramex.  If you are considering taking another job, please talk to your Direct Manager and Human Resources Department before doing so, to determine if a conflict of interest exists.

Our policy of allowing work in other companies provided it does not represent a conflict, as mentioned above, is driven by the true entrepreneurial spirit that Aramex encourages its employees to undertake.

In some countries, however, it might be against the law to have more than one occupation or to work for more than one employer. In these countries, we expect employees to abide by the local laws.

Values Checkpoint!

Scenario:
I recently got a second job working for a restaurant on the weekends. As far as I know, Aramex and the restaurant do not have business dealings together. I took the job before speaking to my supervisor about it and I want to be sure there is not a conflict of interest, what should I do?

Response:
You should disclose that you are doing work for another company as soon as possible. It would have been better if you let your supervisor know about your other job opportunity before you accepted it, so Aramex could have determined beforehand if a conflict of interest

exists. Even if a conflict seems unlikely, we should always get pre-approval before accepting other employment opportunities.

7.8.       Steering Business to a Specific Vendor, Supplier or Consultant Regardless of Quality or Need

Aramex selects suppliers and business partners based on factors such as price, reliability, reputation and quality. We should not base purchasing or hiring decisions on personal, friendships, relationships, or other non-business-related factors.

There can appear to be a conflict of interest when an Aramex employee awards a contract to or hires a supplier that is a close friend or relative. In such case, you should disclose this and ask to remove yourself from the decision-making process. Removing yourself from the decision-making process does not mean that the potential supplier will automatically be excluded.

This is not meant to silence our employees while selecting business partners, but to ensure that we base our decisions on what is best for Aramex. In fact, the company values crucial input from employees based on legitimate business needs. While we can recommend potential suppliers to Aramex, we need to make sure they are hired based on objective criteria and not on personal relationships alone.

8.        Non-compliance Disciplinary

Beyond the legal and financial penalties that Aramex and its employees could suffer because of non-compliance with the Applicable Laws and this Policy, failure to comply can also result in disciplinary actions, as permitted by law, up to and including termination of employment.

Additionally, some laws call for disciplinary fines reaching tens of millions of dollars as well as imprisonment that could reach up to 20 years for violators.

Managers who fail to supervise employees’ compliance with this Policy may also be subject to disciplinary actions. Managers should lead by example and be a resource for employees who have questions or need advice.

For Compliance Disciplinary, you must read and follow the COM 1151 – (E) Aramex Non-Compliance Disciplinary Policy

9.        Conclusion

Thank you for reading our Conflict of Interest Policy. The information in this Policy supplements our Code of Conduct, serves as a manual to help you face potential corruption with confidence and gives you the tools necessary to make the right decision.

Most importantly, this Policy demonstrates our commitment to supporting you as an Aramex employee or related party, and our genuine interest in helping you make decisions in accordance with our values.

If a situation does not feel right, you have our full support to walk away from it and seek further guidance from various resources within the company as described in the “Reporting Violations” section of this policy.

For further information on our values and commitment to ethical conduct, please see the following resources:

  • Aramex Code of Conduct.
  • Anti-Corruption Policy.
  • Gifts, Entertainment and Hospitality Policy.
  • Third Parties Due Diligence Policy.
  • Anti-Money Laundering Policy.
  • Non-Compliance Disciplinary Actions Policy.

10.        References

Aramex.net à Infohub à Compliance à Policies & Standards:

  • COM 1151 – (B) Aramex Gifts, Entertainment and Hospitality
  • COM 1151 – (E) Aramex Non-Compliance Disciplinary Policy

Aramex.net à Infohub à Compliance à Forms:

 

Appendix A:

Aramex Conflict of Interest Declaration Form

 

Aramex expects every employee and Related Party (as defined in the Policy) to consider Aramex’s best interest as the only criteria for their business professional decisions and actions, and never to compromise Aramex’s interests.

A conflict of interest exists if the employee, or Related Party, has actual or potential personal interest or connection that may influence his/her judgment to be based on criteria other than Aramex’s best interests (hereafter “conflict”).

Conflicts can create potential divided loyalties between your personal interests and your obligations to Aramex, potentially adversely affecting the way you perform your duties at Aramex. A conflict may unconsciously influence you, and even the mere appearance of a conflict can cause your actions, reputation and integrity to be questioned.

Conflict includes any not-for-profit or for-profit businesses for which an Aramex employee, or related party, or a close relative is an employee, officer, director, owner, majority shareholder, or consultant.

1.        Policy and Purpose Statement

The purpose of the Aramex Anti-Money Laundering Policy (“Policy”) is to give clear instructions to Aramex employees and other Related Parties[1] on identifying, avoiding, and disclosing money laundering activities.

This Policy:

  • Describes the various stages of money laundering;
  • Illustrates situations where money laundering might arise and the recommended course of action in each situation; and
  • Details the avenues of support to be used for reporting compliance concerns and obtaining additional guidance.

2.        Applicability

This Policy applies to all employees of Aramex and its worldwide Related Parties, including officers, directors, full-timers, part-timers, contract and temporary employees. It covers all aspects of work, transactions, activities and business endeavors.

3.        Applicable Laws

Aramex is committed to fair and ethical business practices and avoiding direct or indirect illegal activities and corruption of all kinds, including money laundering. We will abide by all applicable laws, including the local anti-money laundering laws in every country in which we operate (“Applicable Laws”).

Some countries in which we operate may have laws stricter than those mentioned in this Policy. As a general rule, we follow the most stringent law, regulation or policy applicable to our business in these countries.

The combination of Applicable Laws and our global presence requires maximum alertness to money laundering and full awareness of how to recognize and eliminate it from any transaction we take part in. In case of any doubt about what is expected of you under the Applicable Laws or this Policy, you must seek guidance from the Compliance or Legal Departments.

4.        Responsibility (Call to Action)

As employees and Related Parties of Aramex, we are all responsible for upholding the company values and conducting business with integrity and honesty. The following actions must be taken to fulfill our commitment to fair and ethical business practices:

  • Step away from situations that involve money laundering or may be viewed as acts of money laundering.
  • Stay alert to any red flags suggesting wrongdoing by another employee or a related party.
  • Support and encourage other employees and Related Parties to comply with this Policy.

4.1.       Reporting Violations

If you have any questions or concerns, or if you witness potential violations of this Policy, you must share your concerns with us. We operate under a “no-retaliation” policy, which means that we will never retaliate against anyone who reports a concern to us in good faith.

Additionally, your report will be treated with the highest level of confidentiality and we will endeavor to ensure that your identity is not disclosed.

You must report any known, suspected or attempted violations of our Policy to Community – Risk and Compliance Team <aramex.compliance@aramex.com>.

If you prefer, you may anonymously report concerns through the Compliance Hotline at Service Center – Whistle Blowing <whistleblowing@aramex.com>.

Additionally, you may request the guidance of the following resources when you are uncertain about any obligations under this Policy:

  • The Compliance Department.
  • The Legal Department.
  • The Finance Department.
  • Direct Manager (unless the nature of the issue makes doing so inadvisable).

5.        What is Money Laundering?

Money laundering is the process of taking the proceeds of criminal activity and making them appear legal. In other words, it is the process by which criminally obtained money or other assets “criminal property” are exchanged for “clean” money or other assets with no obvious link to their criminal origins. Money laundering can be used by terrorist organizations, drug dealers, those engaged in bribery, human trafficking, and by anyone who receives money through illegal activities.

Money laundering usually occurs in three stages:

5.1.       Placement Stage:

Placement is introducing/depositing of funds into financial institutions or the conversion of cash into negotiable instruments. The money derived from criminal activities is often initially introduced to the financial system by breaking up large amounts of cash into less noticeable smaller sums, that are then deposited directly into a bank account, or by purchasing a series of monetary instruments (i.e. coins, currency, stock, securities, travelers’ cheques . . . etc.) that are then collected and deposited into accounts at another location.

Placement is the most difficult step for the launderer while the proceeds of crime are most apparent and most easily detected.

5.2.       Layering Stage:

Layering involves the transfer of funds in an attempt to hide the funds’ true origins and separate the illicit money from its source. This “layering” of financial transactions is done to obscure the audit trail and dissolve the link with the original crime.

Once the money has been placed in the financial system, the launderer engages in a series of conversions or movements of the funds to distance them from the source. For example, the launderer may transfer the funds to a series of bank accounts situated in different jurisdictions that usually have strict bank-secrecy laws.

5.3.       Integration Stage:

This is the final stage of the money laundering process. Integration involves the movement of layered funds, which are no longer traceable to their criminal origin, into the financial world where they are mixed with funds of legitimate origin. The launderer invests the funds in real estate, luxury goods or any other business ventures thereby enabling the funds to enter the

economy in a legitimate manner. This is a common way for the launderers to enjoy the illegal proceeds without drawing attention to themselves.

5.4.       Red Flags

A red flag is a fact, event, or set of circumstances, or other information that may indicate a potential compliance concern for illegal or unethical business conduct. Although some money laundering activities might be hard to identify, there are some clear warning signs to look out for.

While performing day to day work, Aramex employees and Related Parties may come across red flags that can create or lead to a money laundering activity, which should trigger concern and appropriate action.

The following examples are not exhaustive and may not in themselves constitute or indicate a violation of this Policy or the Applicable Laws, they may be indicators of potential current or future non-compliance.

Red Flag Examples:

  • Insufficient or suspicious information.
  • Reluctance to provide detailed information about the business.
  • Use of unusual or suspicious identification documents that cannot be verified.
  • Use of unjustifiable foreign addresses.
  • Large payments made in cash.
  • Unjustified requests to open multiple accounts.
  • Request for business transactions to be made through a third party that has no apparent connection to the business.
  • Request for business transactions to be made through a country/jurisdiction that has no apparent connection to the business or has high risk of money laundering and/or funding of terrorism.
  • Multiple partial payments from various parties on behalf of a single customer.
  • Ownership structure is overly and unjustifiably complicated.

6.        Know Your Customer (KYC)

Know Your Customer (KYC) is a process of identifying and verifying the identity of customers and ascertain information relevant to doing business with them, and is exercised during the opening and maintaining of their accounts. KYC is an ethical practice that is applied to all types of customers. Furthermore, the KYC processes and requirements vary according to the nature, size and type of customers (individual or company).

Some jurisdictions are highly regulated with regards to data protection and privacy (i.e. The General Data Protection Regulation (GDPR) of the European Union) and might prohibit obtaining or maintaining specific individual information. To minimize the possibility of non-compliance, you must consult with the Information Security Department.

6.1.       KYC for Individuals

At the point of opening an account for an individual customer, we are required to obtain the following information:

  • Full name as per official ID or passport.
  • Address
  • Email address.
  • Phone number.
  • Copy of ID for verification (official ID or passport).

6.2.       KYC for Companies

At the point of opening an account for a company, we are required to obtain the following information:

  • Company name.
  • Contact person.
  • Email Address.
  • Phone number.
  • Copy of the trade license.
  • Copy of corporate registration. (This may vary in name and description based on the country and jurisdiction; we look for a government issued document certifying the company is registered in the country it operates and/or the country of origin if different).
  • Names of owners (if not a public shareholding company).
  • Names of officers of the company. (This includes the top executives (CEO, COO, CFO, and other executives).

All data obtained should be uploaded on the Customer Relationship Management (CRM) system and database, then a screening of customers must be performed against denied/restricted parties lists prior to accepting the customer and starting business.

7.        Guidelines

This section provides guidance on specific transactions, with reference to Aramex’s requirements and expectations and should be used as a reference to make sure the transactions and business relationships comply with the Aramex Code of Conduct and this Policy.

7.1.       Insufficient, Suspicious or Fictitious Information

Customer information should be clear, accurate and legitimate and we must do our diligence to obtain the same.

In case the customer is reluctant to provide information, or the received information is insufficient, suspicious or false, then there may be an intent to hide an illegal or unethical activity or accept business that might be illegitimate. The proper action here is to raise the matter to any of the parties as identified in the “Responsibility” section of this policy.

7.2.       Large Payments of Cash

Large payments of cash pose a higher risk of money laundering; therefore, they are not accepted at Aramex.

All payments should comply with Aramex’s Finance/Accounting policies, procedures and guidelines. A specific financial guideline is that cash payments should be minimal and in small amounts such as for walk-in cash customers.

7.3.       Opening Multiple Accounts

Customers with multiple accounts for the same beneficial owners or controlling parties for no justifiable business reason, constitute a potential risk of money laundering. An apparent

business reason for having multiple accounts could be different business locations, countries or regions.

In case a customer requests to open multiple accounts for no apparent business reason, then there may be an intent to hide an illegal or unethical activity or accept business that might be illegitimate. The proper action here is to raise the matter to any of the parties as identified in the “Responsibility” section of this policy.

7.4.       Payments Through Unrelated Country or Third Party

Payments from unrelated third parties or from countries that are not related to the shipper or consignee constitutes a risk of money laundering. Moreover, such payments, if made in cash, pose an even higher level of risk.

In case the payor or payee is not the beneficiary of the transaction, is in another country from the beneficiaries, or has no apparent tie to the transaction, then there may be an intent to hide an illegal or unethical activity or accept business that might be illegitimate. The proper action here is to raise the matter to any of the parties as identified in the “Responsibility” section of this policy.

Values Checkpoint!

Scenario:

The finance manager of our customer for many years wanted to change the paying method of her business from bank transfers to cash payments. During her visit to our offices, she explained that since most of their sales are in cash, it would be easier and makes more sense to just pay us in cash. She works for a VIP customer and her business is over $100,000 every month. I do not see a problem with this as they are a customer that we have known for many years and has a good reputation.

Response:

At Aramex, Doing the Right Thing is one of our most important values. You should not accept such change in payment method because large cash transactions are against our policy. We only accept small cash payments from walk-in customers. Additionally, the fact that our customer, for many years, wants to change the payment method from bank transfer to cash payments, may indicate/lead to a potential money laundering activity.

 

Scenario:

A prospective customer in “Country A” wants to ship some valuable gems to “Country B” but requested to put a description on the shipment as decorative stones with low value. His explanation is that he does not want to alert authorities in “Country B” and expose him to possible investigations. Additionally, he does not have papers for the gems from “Country A” authorities since these are heritage gems in his family for generations. The customer seems decent and sincere, and I believe in helping and finding solutions for customers to offer good customer care.

Response:

At Aramex, Doing the Right Thing is one of our most important values. You should not accept to ship these gems, even if the customer looks decent and sincere. In doing so, you may be supporting the smuggling of gems, which could be stolen out of “Country A” into “Country B” where another arrangement might make the gems legal. Additionally, changing the description

of an international shipment is fraudulent and could prevent combating of crime at both the origin and destination.

8.        Conclusion

Thank you for reading our Anti-Money Laundering policy. The information in this Policy supplements our Code of Conduct, serves as a manual to help identify money laundering activities and gives you the knowledge and tools necessary to make the right decision.

Most importantly, this Policy demonstrates our commitment to supporting you as an Aramex employee or related party, and our genuine interest in helping you make decisions in accordance with our values.

If a situation does not feel right, you have our full support to walk away from it and seek further guidance from various resources within the company as described in the “Reporting Violations” section of this policy.

For further information on our values and commitment to ethical conduct, please see the following resources:

  • Aramex Code of Conduct.
  • Anti-Corruption Policy.
  • Gifts, Entertainment and Hospitality Policy.
  • Third Parties Due Diligence Policy.
  • Conflict of Interest Policy.
  • Non-Compliance Disciplinary Actions Policy.

1. Background

Aramex has direct and indirect trade exposure to various US sanctioned countries. Out of the current list of sanctioned countries; Aramex has direct presence in Iran through its Iranian subsidiary, whereas exposure to other sanctioned countries is on transactional basis only. We have a limited but regular number of cross-border shipments going to and received from the sanctioned countries such as Iran, Syria, and Cuba. For the purposes of this Policy, a sanctioned country is defined as a country or territory which is the target of economic and trade sanctions based on US foreign policy and national security goals (each a “Sanctioned Country”, and together, “Sanctioned Countries”).

Aramex takes compliance very seriously and has an established Trade Compliance division within its Risk and Compliance function that serves as a gatekeeper for shipments going into Sanctioned Countries. The role of the Trade Compliance division is to undertake reviews on products and sanctions’ screening of all persons (both entities and individuals) involved in a transaction, to cover trade exposure to Sanctioned Countries, and to ensure that Aramex complies at all times with applicable international laws and regulations.

Most of the global banks in different jurisdictions are extremely cautious and risk averse when dealing with any kind of financial transaction that may have a direct or indirect connection to any trade or business related to Sanctioned Countries or nationals of Sanctioned Countries, even where such trade or business is in compliance with the relevant international laws. We continue to face increased levels of scrutiny from various financial institutions on this subject and have been advised not to use Aramex’s bank accounts with such institutions to facilitate any financial transactions that could be directly or indirectly related to Sanctioned Countries.

2. Action Plan

Aramex’s global policy, on all financial transactions in relation to shipments and customers (corporate and individuals) associated with Sanctioned Countries, shall be as follows:

  1. All shipments involving Sanctioned Countries shall be transacted strictly on a cash basis for both cash and credit customers in local currency only. No funds shall be received or paid by Aramex in relation to any Sanctioned Countries through banks and bank accounts notified by Management from time to time, and shall instead be held in other accounts (referred to as ring-fenced accounts). No US dollars can be part of this transaction.
  2. All international express shipments related to any Sanctioned Countries will be carried on ‘Free In & Free Out’ basis. This would mean that any money collected by the origin/destination Aramex entity is not split with the Aramex destination/origin entity (as the case may be) directly or indirectly. Therefore, such shipments shall not be part of any intercompany billing transactions through Aramex International LLC (“AIL”). Accordingly, funds received at origin or destination in relation to such shipments, depending on the payment terms, will remain in cash with the relevant Aramex entity and will be held in ring-fenced accounts. No US dollars can be part of this transaction.
  3. Funds in relation to freight shipments shall be paid in two parts: Consignor shall pay for the first leg of the transportation (from origin to the destination port) at origin, and the consignee shall pay for the local leg of the transportation (clearance and delivery) at destination. No intercompany billing shall take place through Aramex Special Logistics LLC (“ASL”), as Aramex entities shall be dealing directly with each other (without ASL as an intermediary) with regards to any shipment related to Sanctioned Countries. This is applicable for both cash and credit customers. Funds will be held by the relevant Aramex entity in a ring-fenced account. Additionally, no US dollars can be part of this transaction in both legs.
  4. All cash amounts collected by Aramex entities for shipments related to Sanctioned Countries in accordance with this Policy shall be utilized towards the cash expenses of the relevant Aramex local entity. Such Aramex entity may, subject to internal approvals, open a separate bank account with one of the local banks selected by the Aramex Group Treasury Team to deposit such surplus cash, if any. In all events, such funds shall not, at any point in time, be mixed with any other bank balances held at banks and bank accounts notified by Management from time to time, and will be held in a ring-fenced bank account.

3. Applicability

This Policy is effective immediately. This Policy applies to all employees of Aramex and its worldwide related parties, including officers, directors, full-timers, part-timers, contract and temporary employees. All Aramex employees involved in transactions (financial or operational) involving Sanctioned Countries are expected to adhere by this Policy and all other compliance policies issued by the Risk and Compliance function from time to time and communicated to all Aramex staff. Records must be maintained to demonstrate compliance with this Policy.

In case of any doubt about what is expected of you under the applicable laws or this Policy, you must seek the guidance of the Risk and Compliance function or the Treasury department.

If you have any questions or concerns, or if you witness potential violations of this Policy, you must share your concerns with Risk and Compliance function or the Treasury department. This Policy will be reviewed regularly and any updates shared.

4. Disciplinary Action

Failure to comply with this Policy can result in disciplinary actions, as permitted by law, up to and including termination of employment and subsequent personal liability.

The level and type of disciplinary action is driven by the non-compliance’s nature, scope, intent and materiality of potential consequences.

Where We Stand

It is Aramex policy to comply with all applicable import and export trade compliance regulations and laws as well as other mandatory trade sanctions in the countries in which Aramex conducts business. Compliance failures can result in fines, criminal penalties, adverse publicity and suspension or revocation of the Aramex import or export privileges. Aramex employees involved in import and export activities are responsible to ensure compliance with applicable trade regulations and laws.

This policy applies to Aramex, all Aramex subsidiaries, branch offices, affiliates, and other Aramex entities, wherever located.

 

Trade Compliance

It is Aramex intent to comply with both the letter and the spirit of the laws governing its imports and exports activities. This Policy sets forth Aramex commitment to comply with applicable import and export control laws and regulations involving the import and export.

Aramex must submit accurate and complete import declarations to government authorities. Aramex will use reasonable care to ensure compliance with applicable import regulations regarding designated importer of record, import tariff classification, valuation, origin, duties and import tax payment, payment to the supplier, duty preference programs, temporary imports, bonded warehouse, duty drawback programs, and so forth impacting Aramex importation activities.

It is Aramex’s policy to carefully observe the export control laws and regulations of all applicable jurisdictions impacting its exports and re-exports of shipments.

Aramex respects all international and national embargo regulations and tries to it best capabilities to adhere to those regulations

Aramex will make sure that there are proper import or export licenses from local governments where we conduct our business.

 

Responsibility of Employees

  • To understand and abide by the Trade Compliance
  • All Aramex employees involved in import and/or export activities are responsible to understand their roles to ensure compliance with applicable trade regulations and
  • To report any witnessed or suspicious trade compliance activity on the Whistleblowing System on Aramex’s Intranet: https://www.aramex.net/apps/directory/WB_Requests.aspx

 

Responsibility of Management:

  • The Compliance Department establishes policy and oversees the Aramex import and export trade compliance operations to ensure efficient flow of services across international borders and strict compliance.
  • The Legal Department is responsible to act as the legal advisor to the Global Compliance Department on legal matters impacting Aramex import and export
  • The Compliance Department is responsible to ensure that Aramex employees have sufficient training and resources to carry out their responsibilities under this
  • To provide all employees with a clear whistleblowing
  • To address reported incidents of Trade Compliance by investigating them, confirming their validity, taking corrective action and protecting the whistleblower from any retaliation All investigation must be done while maintaining confidentiality of the incident.
  • It is the responsibility of the Compliance Department to conduct periodic reviews of the Aramex Trade Compliance Program to ensure that the company is complying with applicable trade

 

Whistle Blowing/Reporting Process

  • Anyone who has faced, witnessed or heard of an incident of violation of this policy must report the incident on the Whistleblowing System on Aramex’s Intranet: https://www.aramex.net/apps/directory/WB_Requests.aspx. All reports are received only by the Chief Compliance Officer and the Head of the Audit Team who are authorized to review reports and take necessary
  • The Chief Compliance Officer and/or the Head of the Audit Team take action within 5 days of receiving the Action might include informing Station/Country Managers and/or HR to carry on investigation with the complainant, the accused party and any other related party.
  • After the investigation is complete, the HR representative will discuss the results of the investigation with the complainant and the In case the any party is dissatisfied, the party has the right to appeal within 10 working days from the date of completing the investigation. The appeal will be forwarded to the Regional HR Manager and/Regional Area Manager.

Corrective Action:

In cases where the investigation evidence validates a breach of Trade Compliance Policy, the appropriate corrective action will be implemented by the HR Representative and the Station/Country Manager within 10 working days of the findings, unless an appeal is filed by the alleged party. Corrective action includes but is not limited to:

  • Oral/written warning
  • Requirement to provide a written apology
  • Requirement to take Business Ethics training sessions or any training deemed necessary or related
  • Suspension without pay for a maximum period of 60 working days
  • Loss of employment
  • Civil and criminal liability and local

Disclaimer: The validity, construction, operation and effect of this policy shall be governed by, construed and interpreted in accordance with the laws of the local relevant jurisdiction and the international laws for political engagement.

Competition Ts & Cs:

  1. Aramex South Africa’s decision is final and no correspondence will be entered into.
  2. Employees of the Aramex South Africa brand and their marketing agencies are not eligible to win.
  3. The competition will run from the 4th of April to the 31st of July 2022.
  4. Every parcel sent through DropBox will qualify as an entry.
  5. Unlimited entries are allowed.
  6. Aramex South Africa reserves the right not to appoint any winners.
  7. Winner will be announced before the 31st of August.
  8. Aramex South Africa reserves the right to change the prize without notifications.
  9. If the winner does not claim his/her prize within 10 working days they will forfeit the prize.
  10. Aramex South Africa acknowledges that the promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook and Instagram.