DSV Code of Conduct January 2022 - English

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1 DSV Code of Conduct

DSV
CODE OF CONDUCT
JANUARY 2022
2 DSV Code of Conduct

CONTENTS

INTRODUCTION BY THE CEO ...................................... 3 CONFLICTS OF INTEREST ........................................... 12


Suppliers and customers ................................................. 12
ANTI-BRIBERY AND CORRUPTION ............................. 4 Employment of related parties......................................... 12
Bribery ............................................................................. 4 Monetary loans to employees ......................................... 12
Facilitation payments ....................................................... 5
Kickbacks ........................................................................ 5 HUMAN RIGHTS ............................................................ 13
Money laundering or financing Compliance with UN human rights .................................. 13
of terrorism or other criminal activities ............................. 5 Fighting modern slavery .................................................. 13
Ensuring health and safety at work ................................. 14
GIFTS AND DONATIONS ............................................ 6
Reasonable gifts, travel expenses, entertainment, etc .... 6 ENVIRONMENTAL IMPACT .......................................... 14
Donations to charity ......................................................... 6 Sustainable and innovative transport
Contributions to political candidates, and logistics systems ...................................................... 14
political parties, etc. ......................................................... 7 Complying with public authority requirements ................. 14
Careful selection of suppliers .......................................... 14
COMPETITION ................................................................ 8
Limitation of competition .................................................. 8 SPEAK UP ...................................................................... 15
Trade organisations ......................................................... 8 Possible sanctions .......................................................... 15
Meetings, conferences and vendor events ...................... 9 Ask for assistance ........................................................... 15
Contact us ....................................................................... 15
PROCESSING OF INFORMATION............................... 10
Confidential material and information ............................ 10
Use of inside information ............................................... 10
Data privacy................................................................... 11
Responsible conduct ..................................................... 11
Online behaviour ........................................................... 11
3 DSV Code of Conduct

INTRODUCTION
BY THE CEO
The DSV Code of Conduct is based on the values of DSV All DSV companies and employees must If you are about to do something and are
and applies to all employees, management and the Board of follow national legislation as well as in doubt, ask yourself the following
international regulations while following questions:
Directors. The Code sets standards for our ethical this corporate Code of Conduct. The Code
behaviour and serves as a tool to help you understand cannot cover every issue that may arise • Is it consistent with the Code?
DSV’s policies and to support our vision, strategy and across our global organisation, and
• Is it lawful?
therefore you should always use common
corporate values. sense when conducting business on
• Is it ethical?
behalf of DSV.
• Will it reflect well on me and
The DSV Group’s reputation and business
DSV?
depend on its familiarity and compliance
with all applicable laws, rules and • Would I want to read about it in
regulations. That is why, as a DSV the newspaper?
employee, you have an obligation to
comply with these. You are expected to • Would my family and friends
read, understand and adhere to the approve of it?
Group’s policies and procedures and to
ask questions in case of uncertainty about If the answer is “no” to any of these
any public laws or policies. questions, avoid doing it. If you are still
uncertain, ask for guidance. Keep asking
I strongly encourage you to act promptly if until you are certain or report the issue
you are faced with or suspect non- through the relevant channel.
compliance with the Code of Conduct.
Bring the issue forward through the DSV
Whistleblower Programme, your
immediate manager, country management
or any other internal channel you feel
comfortable using.

Jens Bjørn Andersen

CEO, DSV Group

Jens Bjørn Andersen

Director Ejecutivo del Grupo DSV


4 DSV Code of Conduct

ANTI-BRIBERY AND BRIBERY

Bribery refers to the offering, promising,


You must not accept or offer a bribe of
any kind.

The prohibition of bribery includes


CORRUPTION giving, accepting or soliciting of an
advantage or anything of value as an
incentive to influence an act that is illegal,
instances where it takes the following
forms:
unethical or a breach of trust. The benefit
DSV has a zero-tolerance approach towards bribery and exchanged can include anything of value
• Charitable donations
corruption and complies with applicable anti-bribery and and is not only limited to monetary • Payment of travel expenses
corruption legislation, particularly the US Foreign Corrupt transfers (e.g. favours, gifts, loans, etc.).
• Delivery of products and/or services
Practices Act and the UK Bribery Act. The Code of Conduct DSV prohibits bribery without exception,
describes the specific rules to address bribery and including in instances where bribery is • Disproportionate entertainment
accepted as normal business practice. expenses
corruption to ensure all employees do not take part in it. The
rules described do not prohibit normal and appropriate • Transfer of other personal or financial
benefits
hospitality given or received. If you are in doubt, please
contact your immediate manager or country management If you are asked to pay a bribe, the
incident, including who asked for the bribe,
must be recorded and reported to the DSV
country management, Group Compliance
or through the DSV Whistleblower
Programme.

Example of offering a bribe:

Ofrecer un soborno:
Offering to pay for a hotel stay for a This would be an offence since
potential customer and partner, but only the offer is given to gain a
if he/she agrees to do business with commercial and contractual
Ofrecer
DSV. un soborno: advantage.

Ofrecer un soborno:
Example of receiving a bribe:

A supplier offers your nephew a job but


makes it clear that in return you are It would be an offence for you to
expected to use your influence to ensure accept the offer because you
that DSV continues to do business with would be doing so to gain a
the supplier. personal advantage.
5 DSV Code of Conduct

FACILITATION PAYMENTS KICKBACKS MONEY LAUNDERING OR FINANCING


Facilitation payments – sometimes also called “grease” A kickback is a payment or a form of negotiated
OF TERRORISM OR OTHER CRIMINAL
payments – are small payments made to public officials to bribery where a commission given to someone for ACTIVITIES
secure or speed up routine or necessary processes, facilitating a commercial transaction such as a
which the public official is already duty-bound to perform contract. Kickbacks are also considered bribery, and it Money laundering is the act of concealing or disguising
without the need for payment. Such payments may seem is therefore prohibited for DSV employees to give or money obtained from criminal activities and making them
harmless, partly because the sums involved are usually receive kickbacks to or from business partners. appear to have originated from legitimate sources or
small and partly because they are often regarded as part constitute legitimate assets.
of local custom or culture but are still considered bribes Kickbacks, as referred to here, must not be compared to a
normal bonus programme between the customer and Funding terrorism operations may involve concealing the
and therefore prohibited. source of funds or their intended use.
DSV.
You must not make facilitation payments or accept You must not engage in money laundering or any
such practice in any country by any parties, including Example of offering kickbacks:
activity that facilitates money laundering or the
third parties acting on behalf of DSV. funding of terrorism or any other criminal activities.
You get in contact with a potential new customer but
It makes no difference whether facilitation payments are have difficulties in convincing the buyer to choose
You should be cautious of customers unwilling to give all
permitted or commonly accepted according to local law or DSV as their transport and logistics company. You
required information or insisting on payments in cash.
local practice. agree that if the buyer selects DSV, they will
personally receive a percentage of the value of their If in doubt, always report such issues to the DSV country
The only exception is if a DSV employee reasonably purchases with DSV. management, Group Compliance or through the DSV
believes that their own or others’ life, health or safety may Whistleblower Programme.
be at risk. In these instances, making the payment is not
a violation.
Such an arrangement would be considered a
If you are asked or forced to make a facilitation payment, kickback.
the incident, including who asked for the payment, must
be reported to and recorded by the DSV country
management, Group Compliance or through the DSV Example of receiving kickbacks:
Whistleblower Programme.
Recibir
You arecomisiones
responsibleclandestinas:
for hiring road transport suppliers.
You get in contact with a new road transport supplier
Example of offering a facilitation payment: and consider hiring this company even though you
have some concerns about whether the supplier can
Recibir comisiones clandestinas:
You need a permit. The issuance of the permit usually deliver on quality. You express your concern to the
takes two weeks. You offer the public official handling supplier and suddenly they offer you a percentage of
the permits a small sum of money to issue the permit all sales to be paid to you personally – the higher the
in one day. sale, the
Recibir higher theclandestinas:
comisiones payment to you.

By doing so, you make the person speed up the Such an arrangement would be considered a
issuance process. This is a facilitation payment. kickback.
6 DSV Code of Conduct

Example of unreasonable gifts:


GIFTS AND DONATIONS REASONABLE GIFTS,
TRAVEL EXPENSES, DSV is currently looking for a new
ENTERTAINMENT, ETC. supplier, and you are supporting the
Entertainment, hospitality and the exchange of gifts are selection of one of the suppliers that
You are allowed to accept and offer gifts if have bid on the contract. During the
considered common practice and part of building and the value does not exceed a reasonable negotiation period, one of the suppliers
maintaining business relationships throughout the world. level and the gift, entertainment or has offered concert tickets to you.
hospitality is not intended to influence the
However, we must be careful that the exchanges DSV is
recipient. What is considered reasonable
involved in do not constitute bribes, nor can they be will vary depending on the country and
perceived by others as an unfair influence. culture. As a rule of thumb, the value of a This is an unacceptable gift as it is not
gift should not exceed twice the estimated related to the business conducted with
hourly wage of the recipient. DSV and is offered during a sensitive
period. You cannot accept the gift.
You are not allowed to accept or offer
cash equivalent gifts, such as gift cards.
If in doubt, contact your immediate
Paid travel expenses, hotel
manager or country management.
accommodation and restaurant visits
must be directly related to the business
conducted with DSV.

Regardless of the value of the gift or


DONATIONS TO CHARITY
hospitality, you should always be aware of DSV recognises the important role played
the timing of the exchange to ensure that it by DSV companies in supporting local
cannot be perceived by anyone as a bribe communities.
or an unfair influence. For example, you
cannot accept or offer gifts, entertainment Support and donations to charity are
or hospitality during a tender process or acceptable and may involve DSV’s
negotiation of a sourcing agreement. global charity partner Red Cross | Red
Crescent or local community initiatives.
Example of reasonable gifts:
Support and donations may be in the form
Tickets/admission fees to events or of cash, services or materials and must be
similar with business partners as well reasonable and approved by the relevant
as pens, calendars and small country management.
promotional items.
It must be verified that any payments to
community organisations are not used as a
cover for fraud, considered bribery or could
be perceived as an unfair advantage.
Contributions or sponsorships must be
open, transparent and in accordance with
applicable legislation.
7 DSV Code of Conduct

CONTRIBUTIONS TO
POLITICAL CANDIDATES,
POLITICAL PARTIES, ETC.
Acting as a representative of DSV, you are
not allowed to engage in any political
activities or support election campaigns,
political parties, political organisations or
politicians on behalf of DSV.

DSV funds, property or services must


not be used to support political
purposes.
8 DSV Code of Conduct

Agreements, regardless of contract


COMPETITION form, must always be negotiated in
compliance with fair competition
Example of price-fixing:

Ejemplo de fijación de precios:


principles. Local trade associations (e.g. freight
DSV is committed to complying with all applicable forwarding associations) sometimes
competition and anti-trust legislation at all times. To ensure issue fixed tariffs for local services, e.g.
Ejemplo de fijación
an “import de precios:
fee”. Several freight
we do not breach legislation, you must be aware of
LIMITATION OF forwarders have historically observed
situations that could have an impact on competition. such fixed tariffs.
COMPETITION
Ejemplo de fijación de precios:
You must not conclude any contracts or
agreements, formal or informal, that
have the purpose or is likely to have the However, such a practice may be
effect of substantially limiting interpreted as price-fixing and is
competition. therefore considered a violation of the
DSV Code of Conduct.
You must not participate in or be a party
to:
• Price-fixing
• Market sharing (dividing markets)
• Limitation or controlling of TRADE ORGANISATIONS
production or capacity
On a number of occasions, trade
• Exchange of information
organisations have been connected to
concerning prices or other terms
cartels and other price-fixing agreements.
and conditions regarding DSV
DSV has therefore adopted a strict position
companies, suppliers or other
on this subject.
related third parties
• Meetings, conferences, forums, You must restrict your own and DSV
committees, etc. organised by a memberships of trade and industrial
trade or industrial organisation organisations, trade committees and the
and which may have an anti- like to an absolute minimum, and any
competitive effect. membership should be passive.

All DSV companies must keep an updated


If you become aware of or are confronted record of all national trade and industry
with anti-competitive or questionable organisation memberships.
activities, you must report it to your local
country management, Group Compliance
or through the DSV Whistleblower
Programme.
9 DSV Code of Conduct

MEETINGS, CONFERENCES AND Examples of potential conflicts:


Note: Similarly, DSV staff must never
VENDOR EVENTS The following non-exhaustive list of potential conflicts with competition approach any competitor in any way similar to
laws may provide some guidance as to when particular caution is the examples given below:
DSV employees should avoid participating in vendor required.
events where competitors are also present, as such
events have a likelihood of creating price-fixing
arrangements or discussions hereof.
You are approached by a competitor wishing to discuss or compare Such action may be an attempt to engage in
You are advised to proceed with caution not only in pricing policies. illegal price-fixing.
physical meetings but also when participating in virtual
forums (telephone meetings, social media forums, Skype You are approached by a competitor wishing to discuss or compare Such action may be an attempt to engage in
meetings, webcasts, etc.) where information may be capacity, forecasts, investments, technical developments, etc. illegal limitation and controlling of
published or shared. capacity.
You must not discuss business-related or potentially
competition-restricting topics with competitors. You You are approached by a competitor offering DSV an exchange of Such action may be an illegal exchange of
must ensure that you never share commercially information regarding the company’s prices, price changes, mark- business information.
sensitive information. ups, price differentials, surcharges, discounts, allowances, credit
terms and conditions, volumes, customers, suppliers, market share,
You should always consider and seek approval from your etc.
immediate manager or the relevant DSV country
management or, alternatively, Group Compliance before
participating in events where competitors are present and You are approached by a competitor who offers to refrain from Such action may be an attempt to illegally
business-related topics might be discussed formally or undercutting DSV’s prices or approaching certain markets or certain divide markets.
informally. customers if DSV refrains from approaching certain other markets
or customers or from undercutting the competitor’s prices.
If agreements are made during participation in events
such as conferences, workshops, auctions and forums,
You are approached by another company with an offer to Such action may be an attempt to illegally
they must always, regardless of contract form, be
coordinate bids for tenders or to blacklist or boycott certain divide markets or eliminate, prevent,
negotiated in compliance with fair competition principles.
competitors, customers or suppliers. restrict or distort competition.
When attending a meeting or industry forum and the
discussion falls on matters presumed to be in conflict with
competition law, you must leave the room immediately You are approached by another company or several companies Such action may be an attempt to illegally
and request that your departure and refusal to participate with an offer to collectively approach a customer or supplier. eliminate, prevent, restrict or distort
is noted in the minutes of the meeting. If minutes are not competition.
prepared at the meeting, employees must request the
preparation of such minutes. If the request is not
accommodated, employees must write their own minutes
and inform country management and Group Compliance You are approached by another company and asked to make the Such action may be an attempt to illegally
accordingly. conclusion of the contract dependent upon the acceptance of eliminate, prevent, restrict or distort
supplementary obligations that have no connection with the subject competition.
of the contract.
10 DSV Code of Conduct

PROCESSING OF CONFIDENTIAL MATERIAL


AND INFORMATION
Inside information means non-published
specific information of a “precise nature”
about the DSV Group, its securities (shares

INFORMATION You are not allowed to disclose any


confidential or proprietary information
or corporate bonds) or market conditions
deemed likely to have a significant effect on
the pricing of DSV shares or DSV corporate
received during or after employment at
You must respect and protect the confidentiality of DSV to unauthorised individuals or third bonds if disclosed to the market.

information belonging to DSV, our customers, suppliers and parties. Information of a “precise nature” means
other business partners, and we expect you to be loyal to Confidential or proprietary information may confidential information about
circumstances which exist or may
DSV’s strategy and corporate values. only be disclosed to a third party if
reasonably be expected to happen, or an
authorised in writing through a non-
disclosure agreement or if disclosure is event which has occurred or may
required by law. reasonably be expected to occur; and is
specific enough to enable a conclusion to
Confidential and proprietary information be drawn as to the possible effect of such
includes all non-public information that circumstances or event on the DSV shares
could be of use to competitors or harmful to or DSV corporate bonds.
DSV, our customers, suppliers and other
business partners if disclosed. It is up to you to assess whether
information should be considered “inside
If you are in doubt whether information information”. If you are in doubt, ask your
should be classified as Confidential immediate manager or Group Compliance.
Information, ask your immediate
manager or Group Compliance. If you have or can obtain inside information,
you are considered an “Insider”.

You are prohibited from trading DSV


shares or corporate bonds, directly or
USE OF INSIDE indirectly, while being in possession of
INFORMATION inside information.

DSV A/S is a public limited company listed The prohibition includes the
on NASDAQ Copenhagen (Denmark), and encouragement of others (including
therefore DSV and its employees are relatives, friends and colleagues) to buy or
subject to strict rules regarding the use of sell DSV securities or disclose inside
inside information. information to the said group of people.
11 DSV Code of Conduct

DATA PRIVACY RESPONSIBLE CONDUCT ONLINE BEHAVIOUR


To comply with data privacy legislation, DSV has issued As a DSV employee, you are expected to support DSV encourages the use of social media and other online
binding corporate rules ensuring that collected personal DSV’s strategy and corporate values. You should platforms for business communication and networking
data is not corrupted, copied, stolen, disclosed, misused consider the impact of our brand and avoid any purposes.
or accessible to persons without adequate authorisation damaging or derogatory communications, whether
and approval. online or elsewhere. All posts on personal social media platforms such as
LinkedIn, Facebook, Twitter, etc., should be considered
• Personal data is any information related to an When communicating in the public domain and such public and should not contain confidential information.
individual person that can be used to identify the communication could be perceived as being related to
person, directly or indirectly (name, photo, email DSV, the following activities are not permitted: Posts and comments on social media should be
address, bank details, employment information, a formulated so that it is clear that they reflect personal
computer IP address, etc.) • Messages or postings, including comments or views and not those of the company, unless posted by an
content about race, gender, disabilities, age, sexual authorised representative of DSV.
• Sensitive personal data is any personal data revealing orientation, pornography, religious beliefs and
racial or ethnic origin, political opinions, religious practices, political beliefs or national origin,
beliefs, etc. irrespective of whether such message or posting is
disclosed on an identified or anonymous user basis.
You must only store personal data (including
sensitive personal data) in Outlook, OneDrive, and • Messages or postings containing statements on any
other personal drives for a short period of time until subject that could be mistakenly interpreted as the
further processed, and personal data should only be standpoint of DSV.
shared if you have a legitimate reason to do so.
Deletion of data must follow internal applicable • Publication of defamatory and/or knowingly false
procedures. material about DSV, our employees and/or
customers or suppliers.
All personal data (including sensitive personal data) to be
stored in a central system, e.g. HR systems, etc., must be • Any form of fraud or piracy of copyrighted materials,
forwarded or uploaded to the relevant system. When data such as films or music and/or commercial software or
is uploaded, the e-mail and/or data must be deleted from other proprietary materials.
your personal files and Outlook.
• Downloading of commercial software or any
Questions about the handling of personal data (including copyrighted materials belonging to a third party,
sensitive personal data) should be directed to your Local unless downloading is covered by or permitted under
Privacy Responsible or alternatively to Group an agreement concluded by DSV.
Compliance.
This applies regardless of whether the communication
occurs online or elsewhere, from a private or company-
owned device, during the workday or outside office hours.
12 DSV Code of Conduct

SUPPLIERS AND In such cases, the Board of Directors of the


CONFLICTS OF INTEREST CUSTOMERS
relevant national DSV company or Group
Management must be informed about
You must not participate in any significant conditions, such as
A conflict of interest occurs when a person is confronted commercial transactions between a DSV quantity/volume, price and terms of
company and a supplier or customer in payment.
with choosing between or prioritising their professional
which you have direct or indirect
obligations and their own personal interests. You must interests, financial, private or otherwise,
EMPLOYMENT OF RELATED
always conduct business in DSV’s best interest. It is the unless the transaction is made on an PARTIES
responsibility of all employees to exercise sound judgement arm’s length basis (on market
conditions). There must be no direct or indirect
regarding conflicts of interest and to seek advice from their reporting relationship between related
immediate manager when in doubt. Furthermore, the transaction must be parties employed by DSV. This refers to all
approved in advance by the board of stages of employment, from the time of
directors of the relevant DSV company. appointment and if a relationship develops
This rule is subject to an annual triviality after joining DSV. A direct reporting
limit of EUR 5,000 below which relationship is the reporting relationship
transactions need not be disclosed or between an employee and his/her
approved. immediate manager. An indirect reporting
relationship is the reporting relationship
This also applies to transactions where the between two employees in the same
other party, whether an individual or a reporting line, but with other managers
corporation, is related parties to country between them.
management members. Related parties
include, but are not limited to: Appointing or keeping related parties in the
same unit should always be carefully
• Family members and their companies considered, even if there is no direct or
indirect reporting relationship.
• Own companies
Appointments and all other aspects of the
• Other companies in which the employment must always be based on
relevant member of management has qualifications, performance, skills and
significant influence experience.
Transactions where the connection is with
country management members must be MONETARY LOANS TO
approved in advance by Group EMPLOYEES
Management. This rule is subject to an
annual triviality limit of EUR 5,000 below Employees are not allowed to receive
which transactions need not be disclosed monetary loans from DSV.
or approved.
This prohibition includes monetary loans to
related parties of the employee.
13 DSV Code of Conduct

COMPLIANCE WITH UN • The remuneration of DSV employees


HUMAN RIGHTS HUMAN RIGHTS should meet or exceed statutory or
agreed national industry minimum
DSV supports and is committed to standards.
complying with applicable human rights,
• DSV supports a constructive dialogue
DSV strongly believes that human rights are fundamental labour laws and regulations, and the ILO
between employer and employee.
Declaration on Fundamental Principles and
and should be protected at all times, as established under Rights at Work. • DSV complies with current national
the International Labour Organisation (ILO) Conventions legislation and agreed standards for
You must recognise and support equal
and Recommendations. We are committed to fair human rights and adopt a stance against
employee working hours and
environments.
employment practices and equality of opportunity and discrimination, differential treatment,
treatment. All people who carry out services for DSV, harassment, inappropriate or unreasonable
interference with work performance,
whether directly as DSV employees or indirectly as whether based on nationality, race,
employees of our suppliers, must be treated decently and disability, or gender, including gender
FIGHTING MODERN SLAVERY
with dignity. identity or gender expression, sexual, DSV is committed to the fight against
religious, or political orientation or ethnic or human trafficking, forced labour and
social background. debt servitude and has established a
Modern Slavery Statement to avoid any
The following rules always apply:
form of modern-day slavery or human
• Physical, sexual, mental or verbal trafficking in our supply chains and in any
abuse is prohibited, as is any threat of part of our business.
abuse or any other form of
The Modern Slavery Statement is available
intimidation.
on www.dsv.com.
• Forced employment and working
Employees must report any instance of
conditions resembling servitude are
human trafficking, forced labour or debt
prohibited.
servitude to their country management, to
• The employment of children contrary Group Compliance or through the DSV
to ILO Convention C138 on minimum Whistleblower Programme.
working age for children is prohibited.

• Employees have the right to join a


union and to collective bargaining.

• Employees of DSV must receive a


letter of confirmation of their
employment conditions if required by
national legislation.
14 DSV Code of Conduct

ENSURING HEALTH AND


SAFETY AT WORK ENVIRONMENTAL IMPACT
Safeguarding the well-being and supporting As one of the global leading providers of transport and
the actions of DSV’s employees are
essential to the success and future of DSV.
logistics services, DSV is committed to take on its share of
A healthy and safe physical and the responsibility to reduce the environmental impact
psychological working environment should through reducing our CO2 emissions.
contribute to creating job satisfaction,
avoiding work-related illness and
preventing accidents at work for all DSV
employees.

All employees are entitled to a healthy,


safe and secure workplace where no one is
exposed to unnecessary risk.

All DSV managers are accountable for


creating a healthy and safe work
environment for employees and third
parties, which includes maintenance of
equipment. SUSTAINABLE AND COMPLYING WITH PUBLIC CAREFUL SELECTION OF
Safety must be ensured through INNOVATIVE TRANSPORT AUTHORITY REQUIREMENTS SUPPLIERS
appropriate instructions, which must be AND LOGISTICS SYSTEMS
observed. Managers must establish an Through our employees, DSV wants to DSV's suppliers are selected based on the
understanding of essential safety measures To the extent possible, you must look for, lead an open and constructive dialogue criteria formulated in the DSV Supplier
within their area of responsibility and and offer, sustainable and innovative with authorities, shareholders, customers, Code of Conduct, which is distributed to
initiate improvements when necessary. transport and logistics systems that suppliers and other stakeholders about the suppliers and available on www.dsv.com.
continually reduce the environmental environmental impact related to the
Although DSV and its managers have activities of the DSV Group. The DSV Supplier Code of Conduct
impact of DSV, our customers and our describes what is considered appropriate
the primary responsibility, all DSV
suppliers. business conduct by suppliers when they
employees are responsible for their own
health and safety when performing their You should always aim to contribute to perform services on behalf of or supply
work and must therefore comply with all the constant development and services or products to DSV.
safety regulations and processes as well as improvement of the reduction of CO2 You must ensure that suppliers are
exercise proper care to prevent accidents. emissions, so that our services reflect familiar with the DSV Supplier Code of
DSV prohibits the consumption or being the environmental considerations. Conduct and take relevant steps to
under the influence of drugs or alcohol at
ensure compliance.
work.
15 DSV Code of Conduct

Employees should use any channels they ASK FOR ASSISTANCE


SPEAK UP feel comfortable using when raising
concerns, whether through their immediate If you need assistance or have questions or
manager, local HR, country management, concerns about the DSV Code of Conduct,
All employees are encouraged to speak up when they know Group Compliance or the DSV you should consult your immediate
of or suspect any irregularities or improper actions that Whistleblower Programme. manager or Group Compliance.

have been committed or are likely to be committed. All employees making reports in good faith CONTACT US
Employees are also urged to report any concerns of will be protected from retaliation. The
identity of a reporter will always be Group Compliance
suspected breaches of the principles and rules outlined in protected and not disclosed to anyone not +45 43 20 30 40
this Code of Conduct or applicable laws and regulations. involved in an investigation into the report. group.compliance@dsv.com
Employees who wish to keep their identity
anonymous when raising concerns, can do
so safely through the whistleblower system.
DSV Whistleblower Program
POSSIBLE SANCTIONS https://dsv.whistleblowernetwork.net
All reported or known breaches of the Visit our DSV Whistleblower Program at
principles stated in this will be objectively dsv.com
investigated and followed up with
appropriate sanctions, leading up to and
potentially including termination of
employment.

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