All Rights Reserved © 2025

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President’s Statement

To all Rehoboth employees, contractors, and partners,

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Rehoboth Terminal LLC is built on principles of integrity, lawful conduct, and service excellence

within Port Everglades. Our team operates in a secure, regulated environment that forms part of

the United States maritime infrastructure and critical supply chain. This Code of Conduct sets the

standards of behavior and compliance expected of everyone representing Rehoboth.

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Every employee is entrusted with protecting our clients, our community, and our nation’s ports.

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Lousder Jacques

President – Rehoboth Terminal LLC

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1. Purpose and Applicability

This Code defines the ethical, operational, and regulatory requirements that govern Rehoboth

Terminal LLC and all its personnel. Compliance with this Code is a condition of employment and

contractual engagement.

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2. Ethical and Legal Compliance

Rehoboth maintains absolute adherence to U.S. laws and international standards governing

terminal and maritime operations, including FCPA, OFAC, BIS (EAR), OSHA, USCG (33 CFR

Part 105), EPA, and MARPOL. No employee may offer or accept bribes or improper advantages.

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3. Operational and Environmental Stewardship

As an MTO handling RoRo and containerized cargo, Rehoboth must prevent environmental

contamination and maintain safe yard conditions. Personnel shall comply with:

- ACC-PEV-11 Cargo Acceptance Policy – Golden Rules

- Environmental Response SOP (SPCC-equivalent)

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Immediate reporting of any spillage or contamination is mandatory. Coordination with licensed

environmental contractors and Port Everglades Environmental Control is required.

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4. Trade and Vessel Compliance

When supporting vessels engaged in foreign or Cuba-authorized voyages, Rehoboth applies the

Accordia Cuba Trade SOP & Checklist. Cargo and clients must be screened for OFAC

compliance. Unauthorized or restricted cargo must not be handled.

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5. Homeland Security and Facility Protection

Rehoboth operates as part of the U.S. critical maritime infrastructure. All operations must conform

to the Facility Security Plan (FSP) with full adherence to local, state and federal authorities (key

among them: USCG, USCBP). Employees must wear within and secured and restricted areas

clear lanyard identification badges (Federal TWIC Cards, Port Authorities IDs) and report

unauthorized access or suspicious behavior to Port Security or BSO.

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6. Health, Safety, and Workplace Conduct

Rehoboth is committed to a safe, inclusive, and respectful workplace. Employees shall comply

with OSHA standards, use PPE, prohibit discrimination, and handle information confidentially.

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7. Reporting and Whistleblower Protection

Employees must report violations to Legal Affairs or HR. Reports may be confidential. Retaliation

against good-faith reporters is prohibited.

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8. Disciplinary Measures

Any breach of this Code or referenced policy may result in disciplinary action, including retraining,

suspension, termination, or legal referral.

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9. Referenced Policies and SOPs

ACC-PEV-11 Cargo Acceptance Policy – Golden Rules (July 2025)

Environmental Response SOP (Aug 2025)

Facility Security Plan (Continuous)

Accordia Cuba Trade SOP & Checklist (Aug 2025)

Anti-Bribery & Gift Policy (June 2025)

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