Ethics & Compliance

who we are is what we do

Ethics & Compliance

Business Ethics & Corporate Citizenship

In order to maintain and develop our good reputation in the global market, it is important that we generate our results in an ethical manner. The Digital Customs Services name must always be associated with respect for human rights, proper working conditions and social & environmental considerations.

Since 2010, DCS has maintained the company’s Ethics Handbook detailing our internal rules and requirements regarding human rights, labor rights, anti-corruption and fair competition. The Ethics Handbook is updated when new or revised legislation is issued and complemented by compliance manuals and online training programs for the above issues along with data privacy and export control.

Transparency about ethical issues is important for maintaining an ethics culture in the company. To track ethical behavior, DSC monitors the number of dismissals due to unethical behavior.

Good corporate citizenship means being intentional and thoughtful about the value we generate as a company—not only for our shareholders, but also for our people, our planet, and future generations. It means applying the same level of commitment, rigor, and sincerity to changing lives as we do to building cutting-edge technology for our customers. For that, we commit not only to standards our compliance team sets, but also the ones set by local and international NGOs.

In this respect, we became signatory to the Ethics Declaration of TEID and the Professional Standards of Ethics for Customs Consultants of IGMD.

Our Core Values

Our core values give us a framework for leadership and daily decisions, and help us enjoy our time at work. Sounds so simple, but too often companies get caught up in politics, ivory-tower attitudes, and market mania instead of focusing on the things that probably made them successful in the first place. Their core values; here are ours:

Integrity

We uphold the highest standards of integrity in all of our dealings and actions

Good Corporate Citizenship

We thrive to be a good corporate citizen with high respect to the global community in which we live and work

Commitment

We develop services and products that make a positive difference in our customers’ business practices

Accountability

We are accountable for delivering our commitments, both social and commercial.

COP 2018

COP 2019

COP 2020

COP 2021

TEID Membership Statement

IGMD Ethics Statement

Our Code of Conduct

What is “DCS Code of Ethics and Business Conduct”?

The values and principles of business ethics serve as our compass; the DCS Code of Ethics and Business Conduct (“Code”) is the road map that helps us stay on course with those values.

The Code sets basic requirements for business conduct and serves as a foundation for our company policies, procedures and guidelines, all of which provide additional guidance on expected behaviors.

Why do we have a Code, and why must we follow it?

To continue to operate and maintain our reputation as a company that puts first the needs of the people we serve around the world, we must each learn, understand and comply with our Code.

Complying with our Code is about creating an open and honest environment where we can achieve our best work legally and with integrity. And, we can be proud of how we overcome our challenges and achieve our successes.

Whenever we become aware of a violation of the Code, Company policy or the law, we will act to address the problem and prevent future occurrences. Depending on the circumstances, corrective and preventive steps might include training, counseling and disciplinary actions up to and including termination of employment.

You have a responsibility to speak up when you are in a situation or are aware of a situation that you believe may violate or lead to a violation of the Code, Company policy or the law. Our Escalation Procedure can offer guidance on how to bring attention to a matter of concern.

Every manager’s responsibility

As a manager and a leader, you have a special and important responsibility to set an example and act in a manner consistent with our Code. Here are important guidelines you should follow:

  • Act as a role model, demonstrating ethical behavior in the performance of your duties
  • Make objective business-related decisions
  • Review the Code at least once a year with your team
  • Help your team understand the Code and Company policies, and direct them to resources to help them live the Code every day
  • Ensure that your team is aware of, and properly trained on, the relevant laws, regulations and Company policies that govern the business activities in which they engage on Company’s behalf.
  • Create an environment that fosters and enables ethical behavior, where employees are comfortable speaking up without fear of retaliation.
  • Take seriously any concern raised by an employee that compromises the Code and determine if the issue should be escalated. If so, escalate the matter as soon as possible.
  • Take corrective or preventive action when someone violates the Code.
  • Fully support any investigation.

Speak-up! Every employee’s responsibility

To fulfill our ethical responsibilities and maintain and enhance our culture and reputation, we rely on our employees to help enforce the Code. If you think there is a violation of the Code, or if you think an activity or behavior could lead to a violation, it is your responsibility to speak up.

Whether you report anonymously or give your name, you should provide as many details as possible, so the issue can be addressed thoroughly and promptly. In addition, you have a responsibility to cooperate in an investigation.

Our Company does not tolerate retaliation against anyone who raises a concern under this Code or assists with an investigation.

Any employee who engages in retaliation will face disciplinary action, which could include termination of employment.

DCS requires all employees to put compliance and ethics first.

All employees must…

  • Act ethically and with integrity in all business dealings
  • Know and follow the Code and DCS policies, and comply with the law
  • Report all alleged, potential, or actual violations of DCS’s Code, or policies or the law using the available reporting channels
  • Fully cooperate with compliance investigations, e.g., making your devices available for inspection (when legally permissible) and answering questions truthfully during an investigation
  • Complete all mandatory compliance education courses and other DCS Compliance and Ethics Program requirements in a timely manner

WHAT it means

DCS has the privilege of doing business that affects many stakeholders including governments, foreign and global corporations. We have the responsibility to know and follow the laws and regulations that apply to our business as well as the standards of doing business of our partners.

WHY it matters

While compliance with laws and regulations is mandatory, it also shows our commitment to acting as a responsible corporate citizen. It demonstrates we care about and respect the people we serve. In addition, non-compliance with laws and regulations can result in civil and criminal fines and penalties, imprisonment and other commercial or personal disciplinary actions.

HOW we do it

Our Company has comprehensive policies, procedures and required training that help employees comply with laws and regulations. Any conflict between local laws and regulations and this Code of Ethics and Business Conduct should be brought to the attention of the Ethics and Compliance Officer

The Code outlines DCS’ ethical guidelines; grouping them according to three main sections:

  • DCS and our employees
  • DCS and our external partners
  • DCS and the society

The Code is a reference and the table of contents provides a quick overview of the subjects discussed. The compliance guidelines are aimed at all DCS employees.

Undoubtedly, there will be questions and dilemmas which the Code does not clearly answer. In those situations, you should contact your manager or Your ethics and compliance officer , which provides advice and guidance on business-related ethical dilemmas. Asking for advice and guidance is better than jeopardizing DCS’s reputation. Below are the answers to general questions.

Who should comply with the ethical guidelines?

Everyone who works for DCS must follow our ethical guidelines. This applies equally to employees, managers, consultants, trainees and students. In addition, if you are a manager, you are especially responsible for ensuring that your employees know and understand the guidelines and DCS’s expectations concerning correct behavior.

What happens if I violate the ethical guidelines?

You must never take part in anything which may harm or discredit DCS’ name or reputation. You are responsible for your actions and DCS can terminate your employment contract if you choose to ignore our ethical guidelines.

What to do if I am in doubt concerning the guidelines?

If you are in doubt as to whether you are acting correctly, you can take the ethical test, see next page.

If this does not remove your doubt you should ask your manager or contact your ethics and compliance officer

How do I report violations of the guidelines?

You must take immediate action if you become aware of circumstances that conflict with the ethical guidelines or that could harm or discredit DCS in any other way. You should contact your manager or the Ethics and Compliance Officer via the ethics hotline.

How are local laws balanced against the ethical guidelines?

All companies, business units, departments and employees within DCS must, as a minimum, comply with the local laws of the countries in which they are operating. In the situations where DCS’s ethical guidelines are stricter than the local legislation, the ethical guidelines must be complied with. If you witness a discrepancy between local legislation and our ethical guidelines, you must contact your ethics and compliance officer .

The ethical test

If you are uncertain whether you are acting ethically, you should ask yourself the following four questions. If you answer ‘no’ to one or more of them, you should refrain from doing it and consult with your Ethics and Compliance Officer.

  • Do I comply with relevant rules, regulations and policies?
  • Am I acting loyally towards DCS?
  • Am I prepared to be held accountable?
  • Is this compatible with Our Behaviors?

Why are human rights also the responsibility of companies?

Business has a global presence and, consequently, every company is operating in areas where human rights are being challenged. It is the duty of each government to protect its population against human rights violations but as a socially responsible company, DCS must support the respect for human rights.

We are responsible for making sure that we are not complicit in Human Rights violations in our business decisions and activities, and that we use our influence to secure dignity for all.

How to use the Ethics Hotline in case of violations
You can visit the internet site (etik@dcs.com.tr).

  • Your report will always be treated confidentially.
  • You can choose to be anonymous.
  • Concerns raised in good faith will never result in retaliation.
  • Irrespective of the report raised, all cases will be treated with professionalism.
  • The Ethics and Compliance, which is responsible for dealing with ethical cases, will always follow up on reports.

Related compliance policies and guidelines

  • DCS anti-corruption policy
  • Environmental issues
  • Reporting of unethical behavior
  • Roles and responsibilities with respect to ethical cases
  • DCS anti-corruption manual
  • DCS competition compliance manual
  • IT code of conduct
  • Handling of emails
  • Personal use of social media
  • Professional use of social media
  • Global recruitment
  • DCS code of conduct for suppliers

Employees

DCS expects our employees to have integrity and be mutually respectful. DCS respects the employees’ right to express themselves freely and encourages open dialogue and constructive feedback between managers and employees. We believe that different views and experiences contribute to developing the innovative solutions which make us competitive on the global market.

The following applies to all employees:

  • You must treat your colleagues honestly and fairly.
  • You should not hesitate to propose new ideas for solutions to work-related problems.

In DCS’ view, one of the prerequisites of running a sound and efficient business is to have a good and safe working environment where employees can work without being injured or becoming ill. The working environment refers to all physical, chemical and psychological conditions at the workplace that affect the employees’ health and well-being. We are working proactively to prevent working environment problems, for example by minimizing the use of substances which could be harmful to humans or the environment.

The following applies to all employees:

  • You must stay informed and updated with regard to the working environment and safety in the workplace.
  • You must follow the instructions given to you.
  • You must use the personal protective equipment required to perform your work.
  • You must not expose yourself or others to unnecessary physical or psychological strains.
  • You must contribute to identifying causes of work accidents and participate in the prevention of recurrences.
  • You are jointly responsible for creating a positive working atmosphere.

The following applies to all managers:

  • You must ensure that your employees receive training and comply with all requirements related to working environment and safety.
  • You must continuously identify the needs for extra training, which could prove necessary to maintaining a high level of safety.
  • You must ensure that your employees are continuously briefed on learning points from work accidents, which will prevent recurrences.
  • You must take action on matters, which create a negative working atmosphere.

DCS respects cultural differences and wishes to treat each employee with dignity. We do not tolerate discrimination in the workplace, and we want to ensure that employees are not subjected to unfair discrimination. It is important for DCS’ development that all employees have opportunities to develop their potential. Discrimination in the workplace eliminates this opportunity.

The following applies to all employees:

  • You must not take part in bullying, discrimination, harassment due to gender, age, nationality, ethnicity, caste, religion, sexual orientation, disability or political opinion etc. Also, you are not allowed to talk or act in a way that creates a hostile work environment for others.
  • You must intervene or contact your manager or HR, if you or others are discriminated against.

The following applies to all managers:

  • You must ensure that all of your employees are treated equally and are evaluated according to qualifications and performance.
  • You must not discriminate against any employee e.g. on the basis of gender, age, nationality, ethnicity, caste, religion, sexual orientation, political opinion, or non-disqualifying physical or mental disability etc. This applies to all employment decisions and terms and conditions of employment.

DCS respects the employees’ right to privacy. This right applies to both our current employees and when recruiting and employing new employees. We strive to ensure compliance with existing rules relating to the protection of personal data.

The following applies to managers and HR staff

  • Registration of employees’ personal information shall only be work-related, and you must treat and store the information in a secure manner and in line with statutory provisions. You should observe that all employees have the right to read their own personal data.
  • You must ensure that DCS only orders health tests which are absolutely necessary, or which the employees have specifically requested, and you may not use health tests for discriminatory purposes.
  • You must not inquire about applicants’ health, unless it is relevant for the work performance or safety, or necessary for complying with relevant legislation. Also, you must not inquire about the applicant’s private life, political affiliation, sexual orientation and religion, or intimate questions regarding family circumstances, including pregnancy.
  • If you hire recruitment consultants, you must inform them about the above-mentioned guidelines regarding the protection of personal data and the use of health tests.
  • Forced labor and employment conditions DCS does not tolerate forced labor. This includes slavery, human trafficking or any other forms of involuntary work. We respect our employees’ right to a healthy balance between working hours and leisure time and we avoid systematic use of excessive hours of work.

The following applies to managers and HR staff:

  • You must ensure that each employee has an employment contract or is covered by written terms specifying conditions for employment and termination, so it is clearly evident that the employee is employed voluntarily.
  • You must ensure that all new employment contracts or other written terms of employment require the employee to comply with DCS’ ethical guidelines.
  • You must ensure that the weekly work time for employees working in production/hourly paid employees is maximum 48 hours. Overtime can be necessary, e.g. in peak seasons, but must not exceed 12 hours per week (i.e. maximum 60 hours) on average in a period of four running months. Any deviating arrangements concerning working hours and overtime must be agreed with the employees. You must always comply with stricter rules in local law or collective agreement, if applicable.
  • You must ensure that employees are allowed no less than 24 consecutive hours of rest in every seven-day period.
  • You must ensure that salary, including payment for overtime, is in accordance with local law or collective agreement.
  • You should avoid using salary deduction as a disciplinary measure, except if an employee grossly neglects important duties (e.g. safety rules) and where other sanctions are insufficient. Each salary deduction must be:
    • In accordance with local law or collective agreement,
    • Limited so that the net salary is sufficient to satisfy the basic needs of the employee and his/her family and not below applicable minimum wage,
    • In accordance with local guidelines communicated in advance. The guidelines must include grounds and extent of deductions and
    • Approved by immediate superior and HR.
    • You should generally avoid work-related debt obligations for your employees, e.g. avoid that they pay fees to recruitment agencies.
    • You must only use prison labor if the prisoners have voluntarily agreed to the employment, and if wages and working conditions are in accordance with local laws and resemble conditions that apply for the rest of the workforce. Also, prison workers must be supervised by a public authority or other independent party.
DCS respects a child’s right to development and education and, therefore, we do not tolerate child labor.

The following applies to managers and HR staff

  • If you employ a juvenile between 15 and 18 years of age, you must ensure they are over the local minimum age for employment, and over the local age for completing compulsory school. Also, the juvenile must not perform dangerous work, must not work at night, and they must have more breaks than employees aged over 18 years.

A trusting relationship between DCS and its employees requires that confidential information is not disclosed to unauthorized persons. Confidential information is information, which is not normally accessible to third parties, which is critical to DCS’ business, and/or cannot legally be submitted to third parties without prior approval. This includes e.g. information about DCS’ strategy, technology, products, prices, employees and business partners.

The following applies to all employees:

  • You must not use DCS’ confidential information for personal purposes.
  • You must not disclose DCS’ confidential information to others outside DCS.
  • You must not disclose confidential information about business partners to third parties.
  • You must ensure that information in your possession (e.g. on your computer, telephone, or in your documents is not accessible to unauthorized persons).

DCS provides electronic communication tools to employees for work-related purposes. Private use of these tools is permitted in moderation, and only if this does not affect the employee’s work.

The following applies to all employees:

  • You must only use communication tools for approved purposes, and you must always comply with DCS’ IT policies.
  • You must not use your DCS telephone in a way that incurs additional non-business related costs for the company.
  • You must not use DCS’ communication tools to run your own company.
  • You must not use DCS’ communication tools for illegal, offensive or intimidating communication, or communication which violates copyrights, trademarks or people’s right to privacy.
  • You must not distribute information that contributes to creating a hostile atmosphere or an unproductive workplace.
  • You must not distribute chain letters, computer viruses or other material that can inconvenience others or cost them money.
  • You must protect information (e.g. passwords) that can be used to gain access to DCS’ systems.
  • You must immediately contact the IT ServiceDesk, if you suspect a breach in IT security (e.g. a virus attack), which could threaten DCS’ information systems.

DCS wants to be a healthy and safe workplace. If DCS suspects that working environment or safety-related conditions are being neglected as a result of alcohol or narcotic use, we have the right to conduct relevant investigations.

The following applies to all employees:

  • You must not consume alcohol or be under the influence of alcohol during working hours, unless it is related to celebrations or other similar events that are approved by management.
  • You must not possess, consume, be under the influence of or encourage others to take illegal or controlled drugs during working hours. The only exception is drugs properly prescribed and consumed, provided that safety is not jeopardized.

All forms of theft, embezzlement or fraud at the workplace or misuse of the DCS name, products, property or information are not tolerated, and may lead to dismissal and legal action.

The following applies to all employees:

  • You must not misuse DCS’ credit cards or cash funds.
  • You must not deceive DCS in connection with the recording of travel, working hours or holidays.
  • You must not add false expenses to your expense account, intentionally increase your expenses, or charge DCS for private purchases.
  • You must not use DCS’ letterhead or DCS’ name or trademark for personal or unauthorized purposes.
  • You must not wrongfully take DCS property or remove such items from the company premises without having obtained your manager’s written approval.
  • You must not copy materials that are protected by copyright or require a license (including software).

DCS does not want to support certain political parties, or the interests of political parties. However, DCS’ management can approve memberships of industrial organizations or organizations which operate within the framework of the agreements that the DCS Group has entered (e.g. the UN Global Compact).

The following applies to all employees:

  • You must not use the DCS name or trademark for political activities of any character.
  • You must not distribute personal political opinions using DCS letterhead or your DCS email address.
  • You must not provide money or other forms of support to political parties on behalf of DCS.
  • You must not use items bearing DCS’ name or trademark for personal participation in political activities.
  • You may be a member of an industrial organization, if your manager has approved the membership.

DCS expects its employees to make DCS aware at all times of actual or potential conflicts of interest.

A conflict of interest arises when an employee could potentially give preference to personal interests in situations when his or her duties and responsibilities to DCS should come first.

The following applies to all employees:

  • You must speak to your manager if you are in any doubt as to whether you find yourself in a potential conflict of interest.
  • You must never misuse your position at DCS or DCS’ name for personal gain.
  • You must use your full resources for DCS.
  • You need written approval from your manager, if: “ You have your own company as a sideline activity. “ You work for, own more than 5% of, or have any other financial interest in a company which buys from or sells to DCS.
  • You invest in a company and, in your job at DCS, you have influence on business-related decisions pertaining to the cooperation with this company.
  • You must inform your manager, if: Your immediate family is employed at, owns more than 5% of, or has a significant financial interest in a company which competes with, buys from or sells to DCS, and, in your job at DCS, you have influence on business-related decisions pertaining to this company.
  • You must not encourage any of DCS’ business partners to do business with a company in which you have financial interests without first having informed the business partner about your financial interests.
  • You may not have influence in business-related decisions at a competitor.
  • You must under no circumstances:
    • Work for, own more than 5% of, or have any financial interest in a company which competes with DCS.
    • Help relatives, friends or other close relations to achieve supplier or distribution agreements or other financial agreements which involve DCS.

The following also applies to managers:

  • You must ensure that no individual employee can process all elements of a financial transaction on behalf of DCS (i.e. from the transaction’s initiation, approval and payment to reporting) without involving others.
  • You must assess all reports from your employees regarding conflicts of interest and ensure your decisions are documented in writing.
  • You must ensure that spouses or partners are not each other’s superior or subordinate, and try to avoid situations in which partners or spouses are employed in the same department because this could cause unnecessary conflicts at the workplace. If you enter into a relationship with one of your employees, you must inform your immediate manager.
  • You must under no circumstances hire relatives, friends or other close relations at DCS.

Busıness partners

DCS does not tolerate corruption. Corruption is the misuse of one’s position, of any kind, for one’s own or DCS’ profit. Corruption includes, among other things, bribery, money laundering, extortion, protection payments and nepotism (preferential treatment of one’s relatives or friends). Bribery is when you give or receive an item of value (an offer, promise, grant, gifts/money or a loan) and, thereby, are expected to give or receive undue advantages, i.e. advantages which cannot be obtained honestly and legally.

Corruption is punishable and can have severe consequences for both DCS and the employees involved. DCS risks being sentenced to pay large fines and compensation, extensive audits by authorities, exclusion from tenders and a poor reputation. The employees involved risk personal fines, personal liability damages, dismissal and imprisonment.

DCS works actively against corruption via its member-ship of the UN Global Compact and World Economic Forum’s (WEF) Partnering Against Corruption Initiative, among other things.

Our anti-corruption rules are explained in detail in the DCS Anti-Corruption Manual, which particularly targets employees who have contact with business partners and authorities. The manual is available on the DCS intranet under Group Compliance.

DCS’ guidelines regarding anti-corruption apply to all DCS companies, including subsidiaries and joint ventures where DCS has a controlling interest. In some countries, DCS uses distributors, agents and consultants who act on our behalf. We may be held liable for any violation of legislation and other unethical behavior by these third parties and, therefore, third parties must also comply with the guidelines of the anti-corruption manual.

The following applies to all employees:

  • You must not engage in any form of corruption. “ You must contribute to ensuring that third parties acting on behalf of DCS do not engage in corruption. If you enter into agreements with external partners, including local authorities, you must ensure compliance with the rules of DCS’ anti-corruption manual.
  • You must not enter into any secret agreement with a public official, customer, supplier or third party prior to a decision concerning a purchase or sales order.
  • You must refuse to receive any payments which do not correspond to the service that a business partner is obliged to deliver.
  • You may not perform business transactions which include incentives to obtain personal gains or fraud of any character.
  • If you receive an offer from a public or private business partner that resembles corruption in any form, you must immediately report it to your manager or the Ethics Hotline.
  • If you are in doubt whether you are acting correctly, you should discuss the issue with your manager or contact Your ethics and compliance officer .

The following also applies to managers:

  • You must ensure that employees who have contact with business partners and local authorities know the rules outlined in the DCS Anti-Corruption Manual, and that relevant employees participate in the Anti-corruption Compliance Program.

DCS does not tolerate money laundering. Money laundering takes place when money acquired through illegal activities, including terrorism, is channeled through legal business activities.

The following applies to all employees:

  • You must refuse cash payments or checks issued by an unknown third party.
  • You must avoid transactions, which bypass registration or reporting requirements.
  • You must avoid transactions, which involve countries or areas which have a reputation for money laundering or are known as tax havens (unless the business has its main activity in such a place).
  • You must avoid making payments in countries where DCS has not received a service, unless there is a good reason to do so and we can be open about it “ You must avoid deviations from norms such as insufficient, suspicious or false payment information.

DCS is against the use of facilitation payments. Facilitation payments are small symbolic amounts which are paid to lower ranking public officials to perform a routine task, to which you are entitled, and where non-payment would result in considerable delay or other inconvenience to the company or its employees.

Examples of facilitation payments are an extra payment to cross a border, to establish a telephone line, or to obtain a visa or other kinds of approval.

The following applies to all employees:

  • You must always avoid paying facilitation money, unless non-payment would endanger your health or your personal safety – or all other options are depleted and the amount is insignificant.
  • If you, as an exception, pay a facilitation fee, you must try to keep the payment to a minimum, and you must try to get a receipt.
  • If you have paid a facilitation fee, you must ensure that the amount is recorded as a facilitation payment in Concur. The book-keeping requirement also applies if business partners have paid a facilitation fee on behalf of DCS. Reporting and transparency is required by law and is a vital element in the fight against facilitation payments.

DCS does not pay criminals for protection against violence towards people or vandalism of property.

The following applies to all employees:

  • If you are asked to pay protection money, you must report this to your manager or the Ethics Hotline.

The following also applies to managers:

  • You must report all approaches about protection money to the Ethics Hotline.

Gifts in business relationships should generally be avoided or limited to the extent possible. However, in many countries, it is normal business practice and a sign of respect to exchange gifts. Customs vary widely between countries, and the line between what is considered appropriate and inappropriate can be very fine. Large gifts can be perceived as an attempt to obtain an undue advantage or to influence a decision.

We are confident that our employees will use common sense and judgment when they give or receive gifts or entertainment, and will never provide gifts with the purpose of obtaining a competitive advantage. In order to ensure transparency and to protect DCS employees from the suspicion of bribery, the value of all gifts must be reported.

The following applies to all employees:

  • You must only give or receive gifts or business entertainment if this does not bind DCS or the recipient either morally or legally.
  • You must not give or receive gifts with a value exceeding the equivalent of two hours’ wages (your gross salary). It is unacceptable to receive several gifts over a short period of time from the same giver or for such gifts to be given to the same recipient; whether small or large. Therefore, you must always inform your manager about the gifts you give or receive.
  • You must not give or receive gifts in the form of money or loans from business partners. This also applies to members of your own family or the family of the business partner.
  • You must not participate in or organize business entertainment without any business content or purpose and where your presence is not required. Entertainment must always be of a reasonable size and must not be extravagant.
  • You should be aware that gifts and entertainment for public officials are subject to special rules. Gifts and entertainment are only allowed to consist of a symbolic amount and must have a legitimate business purpose. All gifts and entertainment for public officials must be approved in advance and reported to the Ethics and Compliance officer and General Manager.
  • Furthermore, employees who have contact with business partners and local authorities must also comply with the rules set by DCS’ Anti-Corruption Manual. The manual is available on the intranet under Group Compliance.

DCS may support local organizations via donations and sponsorships as long as the local management agrees that they are relevant to DCS’ interests and they support Our Behavior. Donations or sponsorship may never confer any undue advantages upon DCS, meaning advantages which cannot be obtained honestly or legally, or can be perceived as bribery.

The following applies to all employees:

  • You must ensure that recipients of sponsorship and donations do not end up in a conflict of interest, where reciprocity is expected.
  • You must ensure that the recipient of a donation or sponsorship is not a current or potential business partner.
  • You must ensure that the recipient of a donation or sponsorship is not connected to a public company or a public official, with whom DCS would like to have a business relation.
  • You must ensure that the recipient organization has a purpose and a reputation which is in line with DCS’ values and interests.
  • You must ensure that the recipient has a real need for the donation, and has submitted a written application.
  • You must be able to demonstrate the benefit of the sponsorship to DCS.
  • You must report agreements about donations and sponsorship to your manager.
Competition laws forbid all forms of written or oral agreements or concerted practices with competitors regarding prices, allocation of markets or customers, misuse of a dominant market position, or other situations where free competition is obstructed or limited. It is crucial for DCS that the rules are not violated. Violations can result in major fines, liability damages and loss of business, as well as lost reputation. Our competition rules are explained in detail in the DCS Competition compliance manual, which particularly targets employees who have contact with business partners and industry associations. The manual is available on the DCS intranet under Group Compliance.

The following applies to all employees:

  • You must comply with the guidelines in the DCS Competition Compliance Program.
  • You must not enter into any illegal agreement with a competitor, regardless of whether the agreement is written or oral, or whether it is an unspoken agreement.
  • You must not misuse DCS’ dominant position in a market.
  • You must not exchange sensitive business information (such as prices, price development, discounts, etc.) with a competitor or a representative of a competitor.
It is important for DCS to have information about competitors’ conditions, but the information must always be gathered in an ethical manner and in accordance with the laws and regulations, which protect personal and corporate intellectual rights.

The following applies to all employees:

  • You must only gather information about our competitors using lawful sources, and never from competitors.
  • You must not unjustifiably receive, pass on or use confidential information which rightfully belongs to others.

society

Openness and honesty about DCS’ activities are important to us and our stakeholders, i.e. employees, business partners, the press and the communities in which we operate. Therefore, we communicate our financial, social and environmental results in a true and transparent manner, and we present both our successes and our challenges.

The following applies to all employees:

  • You must communicate openly and honestly, with respect for the people you communicate to and about.
  • You must assist in ensuring that DCS has a good relationship with the local community.
  • You must only make public statements about DCS’ overall strategy, financial situation or express company views on religious and political matters with the approval from your manager or DCS Media Relations.

The following also applies to managers:

  • You must ensure that any problems within your area are discussed with employees and that relevant authorities are informed, if needed.
  • You must have an ongoing dialogue with the relevant authorities to make sure that DCS is aware of new rules and regulations and is able to respond proactively.
  • You must ensure that all relevant documents are stored and are accessible to DCS and local authorities.

In many countries, DCS is a prominent company in the local community and has major significance for the people who work and live there. It is, therefore, important that we “keep our house in order” and have a good relationship with the local community. We respect the rights of the local inhabitants and the local culture, and we are aware that marginalized and vulnerable groups may exist in some local communities.

The following applies to all managers:

  • You must ensure that your employees adhere to local laws and to DCS’ guidelines.
  • You must have an ongoing dialogue with relevant local stakeholders to ensure that DCS knows their needs and expectations.

DCS works proactively to prevent pollution and to produce our products with the least possible energy consumption and the least negative impact on the environment. We have made a commitment to continuously improve our environmental efforts, to promote environmental responsibility and to contribute to the development and diffusion of environmentally-friendly technologies.

The following applies to all employees:

  • You must take the environment into consideration in your daily work tasks.
  • You must follow the environmental instructions given to you.
  • You must contribute to identifying causes of environmental incidents and participate in preventing recurrences.
  • You must contribute to saving energy and other resources.

The following also applies to managers:

  • You must be a role model in reducing the environmental impact, including the energy consumption.
  • You must ensure that your employees have received environmental sensitivity training and comply with all environmental requirements.
  • You must ensure that DCS’ activities do not adversely affect the possibilities for diversified plant and animal life (bio diversity).

You are not alone!

We have processes, guidance and procedures in place to help you follow this Code, company policy and the law. Take advantage of the breadth of capabilities, resources and expertise that exist globally within DCS, including:

The Ethics and compliance officer can explain and answer questions regarding the quality, safety, efficacy and regulatory compliance of our products and supply chain processes, including environmental, health and safety.

The managers and senior leadership are available to answer questions and are generally most familiar with the Company guidelines that apply to the business activities in your organization.

Human Resources can explain and answer questions about employment policies, benefits and workplace issues.

Our ethics hotline is available 24 hours a day, seven days a week. It is secure and confidential. Employees can choose to remain anonymous but are encouraged to identify themselves and to provide as much information as possible so the Company can conduct an efficient and effective investigation of the reported issue.

Speak-up Culture & Ethics Hotline

We operate with the awareness that our actions may affect our clients of whom reputation and integrity are our responsibility as much as the effectiveness of their customs clearance operation.

For your questions and notifications, you can contact the Ethics and Compliance Manager via the email address etik@dcs.com.tr.

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