Global code of conduct

At De Lage Landen International B.V. (DLL), doing business the right way is a key to our success. That means high standards of integrity in everything we do. Knowing that many of our partners have the same high standards, DLL has prepared this summary of the DLL Global Code of Conduct to assure our partners that DLL conducts business ethically and in accordance with all applicable laws.

General Statement
DLL and its subsidiaries, including the joint-ventures controlled by DLL are 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. The general standards are reflected in the DLL Global Code of Conduct.

The DLL Global Code of Conduct covers the following areas:

  • Integrity
  • Skill, Care, and Diligence
  • Conflict of Interests
  • Anti-Bribery, Gifts and Entertainment
  • Regulator Relationships
  • Community Relationships
  • Customer Relationships
  • Company Resources and Information
  • Supervisor Responsibilities

Key Concepts

  • DLL and its members will at all times obey the laws, rules and regulations of all countries and communities where it operates.
    • With respect to Anti-Corruption and Anti Bribery laws, DLL applies a no-tolerance principle. DLL prohibits any form of bribery or corruption in any form
  • DLL cooperates fully with regulators and government authorities.
  • DLL believes in fair competition.
  • DLL intends to only engage with reputable, qualified customers.
  • DLL treats Customer, Vendor and Supplier information as confidential.
  • DLL will always be honest when communicating with customers.
  • Sustainability – Environmental, Social and Governance
    • Business units should be aware of and try to minimize through appropriate policies and programs, the environmental impact of their activities.
    • Business units should respect and promote human rights (as described in the UN Declaration on Human Rights) and labor standards (as described in the ILO Declaration on Fundamental Principles & Rights at Work and related conventions), and use their influence to have suppliers do the same.
    • DLL will not work with companies engaged in illegal behavior
  • DLL is committed to complying with all applicable human and civil rights and applicable labor laws in order to provide equal employment opportunities to members and job applicants and to maintain a workplace free from illegal discrimination, harassment, intimidation and retaliation.
  • DLL’s Compliance Program includes but is not limited to the following activities:
    • Newly hired employees are screened in advance, employees transferred to an integrity sensitive position require re-screening, and Compliance responsibilities are covered in new member training.
    • Regular mandatory on-line compliance training for all members is required, tracked and reported to Compliance Officers and the DLL Executive Board.
    • In the framework of the Compliance program, audits and investigations can be performed on the activity of the members. The outcome is dealt with by the Compliance Officers and they can use this information to address weaknesses and improve processes.
    • DLL has a uniform process for preventing, detecting and investigating incidents, and includes corrective actions.
    • All allegations of unethical behavior are investigated, and disciplinary actions are effectuated in cooperation with Human Resources.

Whistleblower Policy

  • DLL maintains a Whistleblower policy and Trusted Person Network intended as a mechanism for members to report suspected violations of the Code of Conduct through a dedicated channel.
    • A Speak Up Point has been established to assist DLL members to report suspected irregularities
    • Reporting can be done confidentially, and anonymously if permitted by local legislation.
    • Reporting can be done online via a country specific website, or via a dedicated telephone number created for each country

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: General Compliance Email: corporatecompliance@dllgroup.com