Code of conduct

DLL is firmly committed to conducting business with integrity and in compliance with the letter and the spirit of the law and other generally accepted rules and standards of business conduct of the countries and communities in which we operate. The general standards are reflected in DLL’s Code of Conduct and related group policies.

If you have any questions concerning the DLL Code of Conduct or this document, please refer them to your local representative. If you wish to report a concern directly to DLL related to a perceived violation of our Code of Conduct, you may do so by directly contacting our Group Compliance Department via the following email: globalconduct@dllgroup.com

Speak Up

It is crucial for us to have a robust reporting system that enables us to listen to anyone that might have any concern or suspect in relation to a potential breach of law, company policy or unethical behavior. DLL is committed to listening and acting upon your concerns or suspects.

Our values are rooted in respect, and we encourage you to Speak Up if you become aware of incidents of harassment or discrimination, abuse of power, bullying, fraud, corruption, conflict of interest, or any other behaviors contrary to our Code of Conduct. We will endeavor to do what is necessary so that our company is managed in line with our ethical commitments, and you can help us achieve this goal.

If you wish to report a concern related to a perceived violation of our ethical commitments, you may do so by using our Speak Up reporting channels and directly contacting:

  1. Our third-party independent provider. Use code 67521.
  2. This telephone number: +31 (0)800 0222931. Use code 67521.
    In both cases, you will receive an individual case number. Please note the number down and keep it safe.
  3. Our Group Compliance Department via the following email: globalconduct@dllgroup.com

We encourage you to use our abovementioned reporting channels made available for you by DLL (and as further described in more detail below) - before reporting to any competent authority that might be legally available to you in your country.

In order to report to a public source and be qualified as protected disclosure under applicable law, a prerequisite (in certain jurisdictions) is to have at least made a report to an external competent authority.

The following sensitive categories of allegations/ complaints are in scope of Speak Up:

  • corruption
  • criminal offences
  • breaches of legal obligation
  • miscarriages of justice
  • specific dangers to public health, safety or the environment
  • human rights violations
  • abuse of authority
  • unauthorized use of public funds, property or resources
  • gross waste or mismanagement
  • conflict of interest
  • fraudulent financial disclosures made by government agencies/officials and regulated corporations
  • protection of privacy and personal data

 

Below you will see:
A. How to report a compliance concern
B. What happens after I have sent my report?
1. Acknowledgement
2. Triage
3. Escalation
4. Confidential investigation
5. Decision and reply to you

IMPORTANT: If your message is not related to concerns or suspects about a potential breach of law, company policy or unethical behavior, but is more about dissatisfaction related to our products or services, the distribution of our products, etc., please give us your feedback via the complaints handling web page.

 

How to report a compliance concern?

'Speak Up', our third party independent provider reporting system, is available any time (24/7, 365 days a year).
  1. You can choose to use a web form or call a toll-free phone number and leave a message.
    Telephone number: +31 (0)800 0222931
    Website: https://www.speakupfeedback.eu/web/dllexternal/nl
    Access code: 67521
    In order to facilitate an actionable and effective review of your concern, please include a detailed description of your concern (who, what, when, how) and supporting evidence (e.g. copies of documents, screenshots or names of witnesses) that can corroborate your report. Please note that general assertions cannot be investigated.
  2. In both cases, you will receive an individual case number. Please note the number down and keep it safe.
  3. This case number is your personal key to the Speak Up System and to the report you have filed. It allows you to track the progress of your case and to provide additional information. You will be asked to enter this number each time you access the system.
  4. We take all non-compliance concerns seriously and will take the appropriate action on each report. We will keep you informed on our progress whilst processing your concern.
  5. At any time you can go back into the website, and track the progress of your case using your case number.
  6. We are committed to improving our Reporting System and reserve the right to make changes in the future.

 

What happens after I have sent my report?

1. Acknowledgement
Our Compliance professionals will acknowledge receipt of your message within seven days. If your initial report does not include enough information / evidence, we will get in touch to ask you to provide more information / evidence.

At any time you can go back into the website, and track the progress of your case using your case number.

2. Triage
Each report is reviewed carefully. We will open a case if your report includes minimum actionable information and evidence. The investigation will be led by our Regional Compliance Officer or by Corporate in the region/country where the incident is said to have taken place.

3. Escalation
Reports that contain serious allegations will be escalated to the Head of Group Compliance.

4. Confidential investigation
The investigation will be professionally and confidentially handled – we will only involve people who need to be involved. Our Compliance Officers may conduct confidential interviews with our members, contractors or anybody they feel is relevant to the investigation.

As a general practice, it takes around three months for an investigation to be concluded. In any event, timelines established by applicable laws and regulations will be applied and respected.

5. Decision and reply to you
After reviewing all the findings of our investigation, we will decide if a violation has occurred, and take action as appropriate. You will be informed accordingly within three months after acknowledgement of your report and you will receive reasoned information about the follow-up given to the report, for example, on planned or taken measures. At any time you can go back into the website, and track the progress of your case using your case number.

Important Notice
Non-retaliation commitment: DLL prohibits retaliation of any type against an employee, individual or entity and will take action accordingly. In addition, DLL also protects the rights of the implicated persons.