
Copyright DCS Digital Customs Services | 2021
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.
Our Code of 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.
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.
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:
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…
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.
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.
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:
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.
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.
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.
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
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.
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 .
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.
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).
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.
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.
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.
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:
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.
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.
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.
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.
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).
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.
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.
DCS does not tolerate money laundering. Money laundering takes place when money acquired through illegal activities, including terrorism, is channeled through legal business activities.
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.
DCS does not pay criminals for protection against violence towards people or vandalism of property.
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.
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.
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.
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.
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.
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.
Copyright DCS Digital Customs Services | 2021
Kurulduğumuz günden bu yana, şirketimizin iki temel ilkesi “hizmet kalitesinde mükemmellik” ve “yüksek operasyonel verimlilik” oldu.
Geride bıraktığımız 20 yılı aşkın süre boyunca dijital teknolojilerin etkin kullanımı ve çalışanlarımıza yaptığımız yatırımlar sayesinde sizlere verdiğimiz hizmeti en üst seviyede tutmaya gayret ettik.
Bu gayreti geleceğe taşıyacak yeni iş modelimiz ile hizmetlerimizi dijital çağın gereklerine göre yeniden tasarladık.
Yeni ticari unvanımız, iş modelimiz ve internet sayfamız ile 2021 yılına merhaba diyoruz!
Güler Dinamik Gümrük Müşavirliği A.Ş. olan şirket unvanımız DCS Dijital Gümrük Hizmetleri A.Ş. olarak değişmiştir.
Yenilik, gelişim ve dönüşüm odağında tüm paydaşlarımıza ve ülkemize hizmet vermeye var gücümüzle devam edeceğiz.
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