To establish general patterns of behavior and action for all DK Group (herein DKG) employees, without exception, and for the group’s stakeholders”.
This document’s objectives are the following:
• To establish general patterns of action and behavior.
• To define a mandatory ethical standard in outline form to govern how the persons subject to the Code of Ethics behave at work.
• To create a set of rules on standard conduct for stakeholders (such as collaborators, suppliers, customers, shareholders and partners) involved in relations with any of the DK Group companies.
The Code of Ethics applies obligatorily to all companies controlled by the DK Group and all stakeholders involved in relations with any of the various DK Group companies.
3. Sphere of Distribution
4. This document’s sphere of distribution includes all directors, senior management, the management team, middle management and employees of the DKG and the foundations linked to the group. These persons are referred to henceforth as “persons subject to the Code of Ethics.”
“Our definitions: to leave you in no doubt about certain concepts in the Code of Ethics”.
Shareholder: Owner of one or more shares and/or other units of interest in a company and therefore a partner in the company.
Good faith: The conviction, on the part of persons subject to the Code of Ethics, that the right thing is being done.
DK Group Code of Ethics: The ground rule of the DKG Labs, which establishes certain general patterns of action that must be observed by all persons within the scope of this document. No internal rules or regulations of a DK Group firm may go against the Code of Ethics.
Query: Any submitted question or concern regarding the behavior of persons subject to the Code of Ethics or persons in DKG stakeholder groups with respect to compliance with the Abertis Group Code of Ethics, the group’s local codes of ethics and/or internal rules or regulations implementing codes of ethics.
Stakeholders: Organizations or individuals that may be significantly affected by the activities of any of the DK Group companies, and whose actions can affect our organization’s ability to pursue its strategies successfully and reach its objectives. The DKG stakeholders are its suppliers, its customers, its shareholders/partners, its collaborators, governments and not-for-profit organizations.
Confidential information: Written or oral information dealing with contents such as (but not limited to) technical, financial and business information, models, names of potential customers or partners, proposed business transactions, reports, maps, market forecasts, data, analyses, working papers, compilations, comparisons, studies or other documents whose release may directly or indirectly harm the owner of the information.
Persons Subject to the Code of Ethics
• Every person subject to the Code of Ethics must inform the proper Ethics and Crime Prevention Committee of all cases of non-compliance with the Code of Ethics and local codes of ethics that come to his or her knowledge.
• Persons subject to the Code of Ethics must help create a culture of compliance with the Code of Ethics, local codes of ethics and the rules and regulations applicable to the DK Group. To do so, it is vital to comply with the rules applicable to the DK Group and encourage other employees to do the same.
• Any person subject to the Code of Ethics who is a senior executive, on the management team or in middle management and/or has the power to represent any DK Group firm and/or holds controlling and organizational powers must evaluate his or her subordinates according to their compliance with the rules applicable to them.
DK Group’s Guiding Principles
• We stand on the ethical principles of integrity, honesty and transparency, constantly maintaining behavior based on good faith. • We comply with the legislation applicable in each of the countries where the DK Group is present, the DK Group’s internal rules and regulations and the rules and regulations set by our business unit.
• Ethical conduct and compliance with rules and regulations are more important than the DK Group’s bottom line.
• If there is ever any conflict between the applicable legislation and the DK Group’s applicable internal rules and regulations, legislation always prevails.
• We keep the personal situation of persons subject to the Code of Ethics from conflicting directly or indirectly with the interests of any of the firms in the DK Group.
• We take an exacting approach to handling information.
• We use and protect the company’s assets appropriately.
• We guarantee equal opportunities and freedom from discrimination for persons subject to the Code of Ethics.
• We guarantee no reprisals will be taken for any query/ notification made in good faith about noncompliance with the DK Group Code of Ethics, the Code of Ethics Regulation in India or local codes of ethics.
Respect for the Environment
All actions of DK Group firms that might harm the environment are subject to preventive action to favor the environment, promote greater environmental responsibility and favor the development and spread of environmentally friendly technologies. Any act by the DK Group that may imply some damage and/or threat to the environment must be reported immediately to the Corporate Ethics and Crime Prevention Committee or the proper local committee, depending on where the damage and/or threat occurs.
Respect for the Fight Against Corruption
DK Group firms and the foundations linked to the DK Group roll out action to combat corruption in all its potential forms, both active or passive, whether by persons subject to the Code of Conduct or by stakeholders of the DK Group
The Fight Against Corruption
The DK Group does not tolerate any act of corruption of any sort. The DK Group forbids persons subject to the Code of Ethics, group suppliers and partners to perform any act that might create the appearance that a crime of corruption has been committed under the legislation applicable in that country or to offer or receive any kind of advantage to or from any individual or legal person belonging to the public sector or the private sector, on the domestic or international scale, and/or to perform any act whose object is to compromise the objectivity and transparency of any decision-making process so as directly or indirectly to benefit DK Group firms and/or persons subject to the Code of Ethics. Corruption is hunted down and reported on both the domestic and the international stage. In most jurisdictions, criminal or administrative liability in matters of corruption is attached not only to the firm and/or individual that committed the act, but also to the parent company of the DK Group. That is why the DK Group has its prevention of corruption rules and applies them to all Abertis Group firms and the foundations linked to the DK Group. Business units can develop their own prevention of corruption rules tailored to their country’s corruption legislation and local traditions and customs, provided that they neither stray from nor contradict the DK Group rule. Anyone who has any doubts about a situation or observes a case of corruption must inform the proper Ethics and Crime Prevention Committee.
Personal Data Protection
Personal data processing must be done in such a way as to guarantee data privacy and at all events to comply with the applicable legislation.
Intellectual and Industrial Property Protection
Intellectual and industrial property created by employees of the DK Group is the property of the DK Group firm it belongs to
All persons subject to the Code of Ethics must strive to protect patents, brand names, copyrights, trade secrets and other information subject to intellectual and industrial property rights held by firms in the DK Group. Moreover, it is fundamental to respect the legitimate intellectual and industrial property rights of third persons.
All Persons subject to the Code of Ethics must respect the principles and rules of fair competition and must not violate competition defense laws. The business’s legal office must vet in advance all agreements between DK Group firms and third parties that might have a negative effect on competition. Moreover, every acquisition of a new business for the DK Group must undergo oversight in advance by the competent DK Group legal offices. They will analyze the risk of negative market impact and if necessary, will contact the competent competition authorities before the new acquisition is finalized to request a decision on the operation’s legality.
We Take an Exacting Approach to Handling Information
The DK Group looks on information and knowledge as one of its main assets, an asset that is vital for business management. Information and knowledge are therefore especially protected. For that reason, persons subject to the Code of Ethics must treat information and knowledge in such a way as to safeguard these things:
- Veracity: Information veracity is a core principle, so when persons subject to the Code of Ethics have any information to report, either inside or outside the organization, they must give the truth. All the DK Group’s internal and/or external economic transactions must be clearly and accurately reflected in the correct disclosures and records.
- Business Secrets: Persons subject to the Code of Ethics must respect business secrets, which are confidential, even after the persons are no longer employed by the DK Group. When the confidential information in question belongs to DK Group firms, persons subject to the Code of Ethics must not reveal the information to third parties (including friends and family) unless they have to for business reasons and they are authorized to reveal the information by the proper Ethics and Crime Prevention Committee. In this case, the confidential information must not be used to the personal benefit of the person in question or third parties. The DK Group’s information and communication systems and their procurement must comply with the DK Group’s security standards.
The DK Group’s information and communication systems and their procurement must comply with the DK Group’s security standards.
The DK Group does not tolerate workplace harassment of any sort. The DK Group guarantees that persons subject to the Code of Ethics and stakeholders have equal opportunities and are free from discrimination on the grounds of sex, race, country of origin, religion, belief, age, sexual orientation, nationality, ideology, marital status or disability. Equal opportunities apply to hiring, promotion within the group and personal and career advancement.
The DK Group will promote reconciliation policies that facilitate the necessary balance between personal/family life and work. Relationships among persons subject to the Code of Ethics must be governed by mutual respect, integrity, transparency, and trust and by conduct that safeguards the personal dignity of all. In addition, persons subject to the Code of Ethics must act in the spirit of cooperation, making what knowledge or resources they can available to the other organizational units and persons in the DK Group to facilitate the achievement of the DK Group’s objectives and interests.
“Ethics and knowledge of the legislation applicable to the DK Group form a pillar on whose basis our employees are screened and promoted”
a. Screening and Promotion
Persons subject to the Code of Ethics are screened and promoted on the basis of their competencies, job performance, and career integrity. Proof and substantiation of competencies, job performance, and career integrity are required in screening and promotion.
All persons subject to the Code of Ethics must complete the mandatory training courses made available by the DK Group, where they will learn about the legislation and internal rules and regulations applicable to them, depending on the functions and activities they perform within the DK Group. Senior management, the management team, and middle management must assess how well the people working with them know the standards applicable to them, among other parameters. This same assessment parameter also applies to senior executives, the management team and middle management in their turn.
Communication with persons subject to the Code of Ethics concerning performance assessment and expectations must be clear.
d. Working Conditions
Working conditions must be safe for the health of persons subject to the Code of Ethics. The DK Group likewise ensures that its suppliers apply occupational health and safety rules and regulations. The DK Group will provide its employees with the resources and knowledge needed to enable them to perform their functions safely in a healthy environment. The consumption and possession of drugs and alcohol are not allowed at work (with the exception of company celebrations where moderate alcohol consumption is permitted, subject always to the country’s legislation, traditions, and customs).
The DK Group focuses on conceiving, designing and rendering top-quality services to our customers, services that give our customers the kind of value that makes our services different from everything else on the market. Therefore, the DK Group encourages a commitment to quality by providing the resources and measures needed to ensure top quality in its services. Persons subject to the Code of Ethics must undertake to treat customers fairly, provide customers with accurate information and always seek excellence in the services they provide.
Supplier selection processes must comply with the principles of fairness, objectivity, and transparency. Selection is based primarily on the criteria of quality, cost and timely delivery. When persons subject to the Code of Ethics are selecting suppliers, they must avoid situations in which their personal interests clash with the interests of the firms in the Abertis Group. In the event of any clash of interest, the case must be reported to the proper Ethics and Crime Prevention Committee on the Declaration of Conflict of Interest form.
All procurement contracts must include anti-corruption clauses and clauses accepting the DK Group Code of Ethics and local codes of ethics. Environmental and social clauses may have to be included too, depending on the nature of the service. Moreover, the suppliers who are engaged must respect the principles of behavior and action established in the United Nations Global Compact.
The contract terms and conditions agreed to by the parties will be respected as well.
Knowledge of and Training in the DK Group Code of Ethics
Each year all persons subject to the Code of Ethics in the DK Group must turn in an Annual Declaration of Compliance, which confirms that they have read and know the DK Group Code of Ethics. In addition, the HR office of each business unit will give all new DK Group recruits who are considered subject to this Code of Ethics a copy of the Code of Ethics, the Code of Ethics Regulation in India, the prevention of corruption rules and the Compliance Policy to read and sign along with a form containing the Annual Declaration of Compliance with the DK Group Code of Ethics.
Compliance with the DK Group Code of Ethics
All persons subject to the Code of Ethics must comply with the Code of Ethics. Stakeholders in their turn must comply with those points of the Code of Ethics that pertain to them. Non-compliance by persons subject to the Code of Ethics will be punishable according to labor legislation and other applicable rules and regulations, depending on the nature of the relationship between the persons in question and DK Group firms. Non-compliance may entail dismissal from employment or discontinuance of services. The consequences of failing to comply with this Code of Ethics, the Code of Ethics Regulation in India and local codes of ethics will affect not only the guilty person, but also every person subject to the Code of Ethics whose acts or omissions enabled the non-compliance. If any stakeholder organizations fail to comply with those points of this Code of Ethics and the internal standards of any DK group firm that affect them, the DK Group firms will end their relations in the most appropriate way.
Channels of Information
The DK Group has established certain formal channels, which are supervised by the chairpersons of the proper Ethics and Crime Prevention Committees, to enable all persons subject to the Code of Ethics and stakeholders to do the following:
- Submit any questions about the interpretation of this Code of Ethics, their local codes of ethics or the applicable legislation and internal rules and regulations.
- Report cases of non-compliance with this Code of Ethics, local codes of ethics and the applicable legislation and internal rules and regulations. Persons subject to the Code of Ethics and stakeholders may submit their queries and notifications by these channels: The ethical channels established by each DK Group firm in its local code of ethics.
The DK Group reserves the right to run checks within the bounds of the law to verify the application of the Code of Ethics and forestall activities that might affect information confidentiality, integrity, availability, and lawfulness.