Copyright DCS Digital Customs Services | 2021
Supplier Code of Ethics
and Business Conduct
and Business Conduct
We Rely on
Trustworthy
Supplier Relationships
We Rely on Trustworthy Supplier Relationships
DCS has a strong commitment to economic, environmental and socially sustainable development.
As an exemplary leader within its core businesses, DCS strongly believes that it is in the mutual interest of both DCS and its suppliers to meet the present and future requirements of markets and society. This includes demonstrating responsibility towards the people taking part in the manufacturing and delivery of products and services.
In order to make its position clear to all suppliers, DCS has established the DCS Supplier Code of Ethics and Business Conduct (the “Code”).
The Code describes DCS’s corporate social responsibility requirements for suppliers. As a condition of doing business with DCS, we expect suppliers to comply with these requirements. It is our intention to maintain this Code in a spirit of constructive dialogue and in partnership with suppliers, for the mutual benefit of both parties.
DCS Sustainable Procurement Statement
DCS’s commitment to global citizenship includes our procurement activities. We recognize that purchasing decisions present an opportunity to have both a social and environmental impacts which support doing business in a responsible and sustainable manner. DCS’s values around Sustainability Procurement include, but are not limited to, the following:
Supplier Code of Ethics & Business Conduct
You must use discretion and care to ensure that expenditures on DCS personnel or representatives are reasonable and in the ordinary and proper course of business and could not reasonably be construed as bribes or improper inducement or otherwise violate applicable laws and/or regulations.
In no event should you offer or accept business meals or attend business functions at establishments featuring adult entertainment.
In any case, business courtesies offered cannot be construed as intended to influence the judgment of the recipient so as to secure unfair preferential treatment or gain improper advantage. A general guideline for evaluating whether a business courtesy is appropriate, is whether public disclosure would be embarrassing to you, to DCS or to the recipient.
You are responsible for ensuring that acceptance of any business courtesies, gifts, or entertainment is proper and could not reasonably be construed as an attempt by the offering party to secure favorable treatment or otherwise violate applicable laws and/or regulations.
Environmental considerations are an integral part of DCS business practices. Supplier shall commit to reducing the environmental impact of its manufacturing process.
Pollution Prevention and Resource Reduction
Supplier shall avoid pollution and actively strive to reduce material consumption.Chemicals and Hazardous Materials
Supplier shall ensure that chemicals and hazardous materials are handled, stored and disposed in an environmentally safe way,Air Emissions
Supplier shall ensure that air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled and treated as required by law prior to discharge.Wastewater and Solid Waste
Supplier shall ensure that wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required by law prior to discharge or disposal.Recycling and Reuse of Materials and Products
Supplier shall contribute to the recycling and reuse of materials and products to the extent possible.Republic of Turkey, has laws and regulations, usually referred to as antitrust or competition laws, that prohibit unlawful restraint of trade. You must comply with these laws at all times. These laws are designed to protect consumers and competitors against unfair business practices and to promote and protect healthy competition. DCS is committed to observing rigorously the applicable antitrust or competition laws of all countries it makes business.
Such laws prohibit agreements or actions that reduce competition without benefiting consumers. Among those activities generally found to violate antitrust or competition laws are agreements or understandings among competitors to:
- fix or control prices;
- structure or orchestrate bids to direct a contract to a certain competitor or reseller (bid rigging);
- boycott specified suppliers or customers;
- divide or allocate markets or customers; or limit the production or sale of products or product lines for anti competitive purposes.
Such agreements are against public policy and are against DCS policy.
You must never engage in such practices or discussions of such matters with DCS, other DCS partners, or representatives of other companies. You must refrain from discussions with competitors about
- prices,
- costs,
- profits or profit margins,
- production volumes, or
- bids or quotes for a specific customer’s business.
Agreements or other arrangements which involve exclusive dealing, bundled or tie-in sales agreements with customers about resale prices, other restrictive arrangements with suppliers or customers, charging different prices to competing customers, or pricing below cost raise substantial risks under the antitrust or competition laws.
Unfair methods of competition and deceptive practices are also prohibited. Examples of these include:
- making false or misleading representations about your products or services or DCS’s products or services,
- falsely disparaging a DCS competitor or its products or services,
- making product or service claims without facts to substantiate them or
- using DCS’s or another company’s trademarks in a way that confuses the customer as to the source of the product or service.
DCS respects the intellectual property rights of others and expects other companies to respect its intellectual property rights. You are responsible for protecting DCS’s intellectual property rights. An important element of such protection is maintaining the confidentiality of DCS’s trade secrets and proprietary information. You must respect the intellectual property of DCS and not use DCS’s patented technology or reproduce copyrighted software, documentation, or other materials without written permission.
In the course of working with or for DCS, you must not use proprietary information, patented technology or copyrighted software, documentation, or other materials of third parties without authorization.
You must safeguard confidential information by not transferring, publishing, using, or disclosing it other than as necessary in the ordinary course of business or as directed or authorized by DCS. You must observe applicable data privacy standards. Materials that contain confidential information or that are protected by privacy standards should be stored securely and shared only internally with those employees with a need to know. For example, confidential information may include, but is not limited to:
- marketing and sales plans,
- competitive analyses,
- product development plans,
- non-public pricing,
- potential contracts or acquisitions,
- business and financial plans or forecasts,
- internal business processes and practices,
- prospect, customer, and employee information
You are required to protect confidential information (which includes “personal information”) to which you have access in connection with your services to DCS. You are required to abide by all applicable laws such as KVKK and DCS policies when collecting or processing the relevant confidential information.
The term “conflict of interest” describes any circumstance that could cast doubt on your ability to act with total objectivity with regard to DCS’s interests. DCS wants its Supplier’s loyalty to be free from any conflicts of interest. Conflict of interest situations may arise in many ways. If you feel that you have an actual or potential conflict with DCS or any of its employees, you must report all pertinent details to DCS.
DCS affirms the principle of equal employment and business opportunities without regard to any protected characteristic, including but not limited to:
- race,
- religion,
- national origin,
- skin color,
- gender,
- gender identity,
- age,
- disability,
- pregnancy,
- marital status,
- national origin/ancestry,
- military status,
- sexual orientation
DCS policy prohibits harassment in any form, and DCS expects that you provide a work environment free from harassment. We require that you practice and promote a work environment free from harassment, as appropriate under applicable laws and beyond.
All companies doing business with DCS must ensure that their operations are in compliance with all applicable laws and regulations. Additionally, they must agree to abide by our Supplier Code of Conduct, which reflects our company’s expectations about ethical business and employment practices.
With the cooperation of our employees, customers, contractors and suppliers, we are committed to environmental management and we incorporate environmental considerations into our procurement processes.
DCS gathers and evaluates key suppliers’ environmental performance data to make informed choices, assess options with lower environmental impact and review the environmentally preferable offerings of existing suppliers.
DCS is committed to ethical business conduct and the responsible sourcing of goods and services throughout supply chain.
DCS’s direct suppliers must also acknowledge their commitment to worker safety and fairness, environmental responsibility and ethical business.
This Code is applicable to you as a DCS Supplier, and to all personnel employed by or engaged to provide services to you (either “Supplier” or “you”). DCS requires that you comply with all laws and regulations applicable to your business, wherever conducted and with this Code.
Moreover, Supplier shall take all necessary actions to ensure Supplier’s compliance with this Code, without undue delay. The Supplier is solely responsible for the costs of complying with the Code. If DCS finds or suspects incidents of non-compliance with the Code related to Supplier and informs supplier hereof, DCS expects the Supplier to investigate and correct issues of non-compliance as soon as possible and within an agreed timeframe. If the Supplier does not show willingness to correct these issues DCS will consider terminating the business relationship with Supplier. Any such termination of any business relationship between DCS and Supplier is considered a termination for cause and does not entitle Supplier to any kind of compensation.
If Supplier uses sub-suppliers for its supplies to DCS, the Supplier shall use his best endeavors to ensure that its sub-suppliers comply with the Code.
DCS may conduct announced audits at the Supplier’s sites, including the Supplier’s manufactoring facilities in order to verify that the Supplier is in compliance with the Code. Audits may be performed either by DCS employees or by a third-party auditor chosen by DCS.
In order to verify the Supplier’s compliance with the Code, Supplier shall be prepared to provide DCS access to relevant and reasonably requested information and documentation, during an audit. All auditors carrying out such audits are bound to confidentiality by written agreements. All information and results obtained in connection with a such audits will be handled confidential by DCS and will only be shared with the subject Supplier.
DCS will only use such information for internal purposes.
Compliance means not only observing the law, but also conducting corporate business in a way that recognizes your ethical responsibilities and fulfills them. Where local laws or industrial regulations are less restrictive than this Code, you must comply with the Code, even if your conduct would otherwise be legal. On the other hand, if local laws are more restrictive than the Code, you must always, at a minimum, comply with those laws.
DCS maintains open and frank business dealings with all Suppliers and strives to develop mutually advantageous relationships. DCS expects you to adhere to high ethical standards and to avoid engaging in any activity that involves even the appearance of impropriety.
You must not make or promise to make corrupt payments of money or anything of value, directly or indirectly, to any government or public international organization officials, political parties, or candidates for political office, or any company director, officer, employee, or agent of a commercial customer or supplier, for the purpose of obtaining or retaining business or securing any improper advantage.
You must accurately document all transactions related to your contract with DCS and relevant order forms in your financial books, records, statements, and in reports and other documents provided to DCS and prevent side agreements, whether oral or written.
The handling and disbursement of funds related to DCS business transactions must be pursuant to a duly authorized written DCS contract with clearly defined procedures.
Documents must not be inappropriately altered or signed by those lacking proper authority. No undisclosed or unrecorded fund or asset related to any DCS transaction may be established or maintained for any purpose.
Your financial books, records, and statements shall properly document all assets and liabilities and accurately reflect all transactions of your company related to DCS products and services, and your business records must be retained in accordance with record retention policies and all applicable laws and regulations.
DCS’s policy is to report its financial results and other significant developments fully, fairly, accurately, timely, and understandably. DCS expects you to comply with this policy, and with all applicable laws and regulations.
DCS respects the children’s right to development and education. Therefore, DCS does not accept the use of child labor as a part of the full-time work force at the Supplier. This includes employing children under the age of 15, children younger than the legal minimum age, or children younger than age of completing compulsory school.
Juvenile (children between the age of 15 and 18) are only allowed to be employed by Supplier, provided that the work complies with local laws and the ILO Minimum Age Convention.
In general, all children under the age of 18:
- must not be employed in hazardous work
- must not work night shifts
- are entitled to more breaks than adults
The Code does not permit forced or involuntary labor at the Supplier. This includes forced prison work, work on a forced contract, slavery and other forms of work, which are done against one’s will or choice.
DCS does not tolerate employment which confines the employee in unreasonable debt bondage.
DCS supports the fundamental human right to have sound working conditions. Supplier must ensure a good and safe working environment which complies with all applicable rules and laws. As a minimum:
- Workers must not be exposed to dangerous work without being properly protected.
- Workers must be provided personal protection equipment and be instructed in its proper use.
- Facilities must comply with applicable laws and rules about construction safety as well as fire protection – and fire alarms.
- Facilities must provide appropriate light and ventilation
- All dangerous materials must be stored in safe places and used in safe and controlled ways.
- All machinery must be properly maintained and shielded.
- Facilities for meals, resting and sleeping, must, if provided, be kept clean and safe.
DCS expects you and your employees to compete fairly and ethically for all business opportunities. Your employees who are involved in the sale or licensing of products/services, the negotiation of agreements, or the delivery of services to DCS are expected to understand and honor the terms of contractual agreements. You must ensure that all statements, communications, and representations to DCS are accurate and truthful.
You must strictly observe the laws, rules, and regulations that govern the acquisition of goods and services by any governmental entity of any country and the performance of government contracts.
Activities that may be appropriate when dealing with non-government customers may be improper and even illegal when dealing with government. If you deal with any governmental entity, including public international organizations, you are responsible for learning and complying with all rules that apply to government contracting and interactions with government officials and employees, including but not limited to the following requirements:
- In dealing with government employees and officials, you shall not give or offer, either directly or indirectly, any gratuity, gift, favor, entertainment, loan, or anything of monetary value to any government official or employee except as may be permitted by applicable law.
- You shall establish appropriate internal controls and advance approval mechanisms over any such payments or gifts to or on behalf of government officials to ensure compliance with laws and regulations.
- You shall not provide, attempt to provide, offer, or solicit a kickback, directly or indirectly, to obtain or reward favorable treatment in connection with any transaction.
Report to DCS any conduct, including conduct of any DCS employee, that you believe in good faith to be an actual, apparent, or potential violation of this Code. Prompt reporting of violations is in the best interest of everyone. Reports will be handled as confidentially as possible.
DCS maintains an “open door” policy with regard to your questions, including any questions related to business conduct and ethics. To report an incident, you may contact DCS’s Ethics and Compliance Officer
The Supplier Code of Ethics and Business Conduct places you and DCS in the forefront with those corporations throughout the world that emphasize the importance of honest business conduct and solid business ethics.
Our standards can be met only with your cooperation.
DCS trusts that you will recognize that you must adhere to the standards of this Code. You agree to abide by the terms of this Code and acknowledge that compliance with this Code is required to maintain your status as an DCS Supplier.
Effective Third Party Risk Management
We work systematically with supplier management and our Code of Conduct for Suppliers defines the Group’s environmental and social requirements.
All suppliers must sign the Code of Conduct and we perform regular supplier audits to verify compliance. Supplier risk assessment forms the basis of measures taken with the individual supplier.
The risk assessment model includes the location of the supplier which ensures that the highest priority is given to suppliers in the areas which pose the greatest risk of non-compliance.
Our Compliance Program
Digital Customs Services supports the growing international focus on regulation and legislation in areas such as anti-corruption, competition law, export control, and good business ethics. We have implemented a compliance program to anchor and sustain our ethical guidelines at all levels in our company. Our compliance program cover ethics, anti-corruption, competition law, data privacy and export control, human rights, conflicts of interest and diversity.
Internal compliance program and control mechanisms have been established to minimize the risk of rule violations. These programs contain clear ownership, policy setting, operational procedures, digital monitoring as well as recurring training and awareness activities. The new Data Privacy regulation came into effect in 2018. A data privacy handbook and e-learning activities has been developed and were rolled out in the first quarter of 2018.
