DIM Anti Corruption Code User Guide

DIM Anti Corruption Code

The mission of the DIM BRANDS INTERNATIONAL Group (hereinafter referred to as “DBI”) is to provide the best possible service and support to its customers, while respecting its values of integrity. In order to fulfil this mission as it continues to grow, DBI has decided to structure its business around four key values that must be shared by all DBI employees and partners, and for which DBI must set an example: expertise, respect, transparency and fairness. Integrity and the fight against corruption and influence peddling are fundamental principles for DBI, and faithfully mirror its cherished core values of transparency and fairness. Committing an act of corruption or of influence peddling is a serious offence that can have extremely damaging legal and financial consequences for DBI, its employees, its shareholder, as well as for its customers, and that can cause lasting damage to DBI’s reputation.

Yog li no, DBI tau lees paub txwv tsis pub thiab rau txim rau ib qho kev coj cwj pwm tsis tsim nyog los ntawm nws cov thawj coj, cov neeg ua haujlwm, cov neeg sab nraud thiab qee zaus cov neeg koom tes xws li cov neeg ua haujlwm ib ntus thiab cov kws pab tswv yim hauv txhua lub tuam txhab koom nrog DBI, ob qho tib si hauv Fab Kis thiab txawv teb chaws (tom qab no "Collaborator(s)").

For this reason, DBI’s management decided to draw up an Anti-Corruption Code that forms part of DBI’s Code of Conduct and, more generally, of DBI’s compliance programme, which includes in particular mandatory anti-corruption training. I am counting on you to read this Anti-Corruption Code carefully, then apply and implement it in your day-to-day activities reporting any situations of concern, where applicable, in order to promote DBI’s values and its commitment to combating corruption.

François RISTON, Thawj Tswj Hwm

OUR COMMITMENT AND PRINCIPLES IN THE FIGHT AGAINST CORRUPTION

DIM Brands International1 (hereinafter referred to as “DBI” or “the Group”) has adopted a zero-tolerance policy towards corruption and other breaches of probity. The Anti-Corruption Code and DBI’s internal principles form the basis of our commitment. DBI employees may not engage in acts of corruption, whether public or private, active or passive, or in influence peddling.

• We will not offer, attempt to offer, authorise or promise bribes, facilitation payments, kickbacks or anything of value, to a public official or private party in order to obtain or retain business or an improper advantage. Ib yam li ntawd, peb yeej tsis koom nrog kev xiab nyiaj lossis txais nyiaj rov qab los ntawm tsoomfwv lossis cov tog neeg ntiag tug.
• We obtain information about our business partners in accordance with our procedures for evaluating third parties.
• We always maintain accurate accounting records and registers, which honestly describe payments made by or on behalf of DBI to prevent company funds from being used for illegal purposes.
• We apply our company principles concerning gifts and invitations so as never to embarrass our partners or give the impression that we expect any inappropriate favour in return.
• We avoid situations of conflict of interest so that the impartiality of our decisions can never be questioned.

1 DIM Brands International suav nrog txhua lub tuam txhab ncaj qha lossis ncaj qha los ntawm DBI Lux Holdings SARL.

• We follow the principles set out in this code in order to identify situations that could lead to acts of corruption, and we react appropriately to prevent such situations.

Furthermore, we never ask any third parties to do anything that we are not authorised to do ourselves. These include, but are not limited to, our commercial intermediaries, suppliers, consultants and influencers, who, when acting on our behalf, must comply with the prohibition on bribery.
Bear in mind that a bribe does not have to be accepted to be illegal. It is illegal to offer or promise a payment for the purpose of bribery, even if the payment is not ultimately made or is declined.

KEV PAB CUAM

Txoj Cai Tiv Thaiv Kev Ua Phem Txhaum Cai no (tom qab "Txoj Cai") siv rau txhua tus neeg ua haujlwm DBI, suav nrog cov thawj coj, cov tub ceev xwm, cov neeg ua haujlwm ruaj khov thiab ib ntus, cov tub ntxhais kawm thiab cov tub ntxhais kawm. Nws kuj tseem siv tau rau DBI cov chaw muag khoom, cov neeg siv khoom thiab cov neeg koom tes hauv txhua lub teb chaws uas Pab Pawg tam sim no (tom qab no suav nrog hu ua "cov koom tes"). Txoj Cai Tiv Thaiv Kev Txhaum Cai yuav raug siv rau 1 lub hlis tom qab nws kev sib txuas lus rau Pawg Neeg Ua Haujlwm Pabcuam Tib Neeg (WSC).

SIV TXOJ CAI tiv thaiv kev noj nyiaj txiag

Our risk mapping has enabled us to identify certain of our operational activities that are susceptible to corruption. The present Code sets out the general principles applicable to DBI. However, where local regulations are more restrictive than the rules set out below, you must apply the more stringent rule.

Txoj Cai tau teeb tsa DBI cov lus cog tseg rau kev tawm tsam kev noj nyiaj txiag thiab pab nthuav tawm peb cov kev coj noj coj ua. Nws:

• Explains what corruption is;
• Muab examples of situations to help you identify it more clearly;
• Explains the attitude to adopt and the procedures to follow in order to prevent it and to remedy it if it occurs.

Muab ntau qhov xwm txheej uas muaj kev noj nyiaj txiag tshwm sim, Txoj Cai no tsis tuaj yeem ua tiav. Txawm li cas los xij, nws yog ib qho cuab yeej siv tau los pab koj txiav txim siab zoo tshaj plaws rau cov xwm txheej. Yog tias muaj kev tsis ntseeg, hu rau koj tus thawj tswj hwm kab los yog Tus Thawj Saib Xyuas Kev Ua Raws Cai.

If you have any questions about the rules and their application, please refer to the dedicated page.
Intranet link: France – Code of conduct

You can also contact your Compliance Officer:
DBI.Compliance@dim.com

PAUB TIAS LUG PHEM

Txhua lub tuam txhab DIM Brands International, hauv Fab Kis thiab txawv teb chaws, yuav tsum ua raws li Fabkis txoj cai lij choj ntawm kev pom tseeb, tiv thaiv kev noj nyiaj txiag thiab kev ua lag luam niaj hnub (lub npe hu ua "Sapin 2" txoj cai), nrog rau lwm txoj cai tiv thaiv kev noj nyiaj txiag thiab cov kev cai siv tau. Feem ntau ntawm cov kev cai lij choj no muaj daim ntawv thov txawv teb chaws, uas txhais tau tias, piv txwv liample, our company’s activities throughout Europe must comply with both the local law of the individual countries and the French ‘Sapin 2’ law. In addition, the “Sapin 2” law requires the implementation of a plan for the prevention and detection of corruption and influence peddling based on the eight mandatory measures deployed by DBI. Breaches of these laws seriously damage a company’s reputation and can result in severe criminal and civil penalties, including substantial fines for the company and imprisonment for the employees involved, whatever their hierarchical level.

8 tus ncej ntawm peb txoj haujlwm tiv thaiv kev noj nyiaj txiag

• Corruption risk mapping
• A Code of Conduct and associated procedures and models
• Checking the integrity of third parties
• Accounting controls
• Training sessions for managers and employees
• Internal controls to evaluate the effectiveness of the programme
• Disciplinary measures
• An internal alert system

YUAV UA LI CAS?
Kev noj nyiaj txiag yog kev cog lus, muab, thov lossis lees txais - ncaj qha lossis tsis ncaj - "ib yam khoom muaj nqis" txhawm rau kom tau txais "advan tsis raugtage".

Kev noj nyiaj txiag tuaj yeem ua haujlwm lossis tsis ua haujlwm:

• Active kev noj nyiaj txiag tshwm sim qhov twg ib tug neeg muab los yog muab ib yam khoom uas muaj nuj nqis nyob rau hauv pauv rau ib tug undue advantage.
• Passive kev noj nyiaj txiag tshwm sim qhov twg ib tug neeg thov los yog txais ib yam khoom muaj nqis nyob rau hauv rov qab rau ib tug tsis ncaj ncees advantage los yog pom zoo siv lawv lub hwj chim.

Corruption can be public or private:

• Corruption is said to be public where the bribed party is a public official. (See the definition of a public official in the chapter on Relations with public authorities and officials).
• Corruption is considered private where the bribed party is not a public official. (See the chapter on Relations With Third Parties).

“Things of value” or bribes can take numerous forms:

• Money,
• Free products,
• Gifts and invitations unrelated to business,
• Promises of employment.
• Charitable donations or sponsorship relating to entities (e.g. non-profit associations) in which the bribe-taker has a personal interest,
• Payment of invoices unrelated to the services provided,
• Kickbacks, etc.

In all countries, corruption is prohibited and severely punished in all its forms, whether active or passive, public or private, direct or indirect.

If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com

INFLUENCE PEDDLING yog dab tsi?
Influence peddling txhawj xeeb txog kev sib raug zoo nrog pej xeem cov neeg ua haujlwm. Nws yog hais txog kev siv los ntawm ib tus neeg ntawm nws txoj haujlwm lossis kev cuam tshuam, tiag tiag lossis xav tau, los cuam tshuam qhov kev txiav txim siab thaum kawg los ntawm ib tus neeg ua haujlwm pej xeem.

It involves three parties:

• The beneficiary who provides benefits,
• The intermediary who uses the credit he has because of his position,
• The public official who holds the power of decision.

Qhov kev coj ua no raug txwv tsis pub siv rau txhua tus neeg ua haujlwm. Tsis tas li ntawd, txhawm rau lav qhov siab tshaj plaws ntawm kev coj ncaj ncees, DBI tau txais kev txhais dav dav ntawm kev cuam tshuam peddling thiab txuas ntxiv kev txwv tsis pub rau nws cov kev sib raug zoo nrog cov tog neeg ntiag tug.

Kuv yuav ua li cas?

Influence peddling involving a public official: 

Qhov xwm txheej
DBI has an outlet in a poorly served area and wishes to change it. A neighbouring town has a dynamic shopping centre and you are responsible for obtaining a commercial lease there. You believe that the support of the local councillors is necessary to obtain the requisite authorisations. During a conversation, a local councillor offers to use his influence to help you obtain the necessary permits in exchange for DBI’s sponsorship of the football club he chairs.

The appropriate reaction
As the councillor is personally involved in the football club, any money paid to the club is likely to benefit him directly. The direct link between financial support for the club, the councillor’s personal involvement in the club, and the councillor’s intervention in an administrative procedure in favour of DBI bears all the hallmarks of influence peddling. You should therefore refuse this proposal and follow the official administrative procedure. You should also immediately contact your line manager or Compliance Officer to inform them of this solicitation.

Peb tej ntsiab cai: At DBI we never ask favours of public officials or elected representatives. We respect the applicable procedures without seeking to influence decisions through prohibited means.

Using the influence of a private party

Example: DBI is negotiating a strategic partnership with a major retailer to increase the visibility of DBI products in their shops. A colleague suggests using the services of an independent consultant whom he knows to be on very good terms with the company’s negotiators. However, the agency states that it will charge an exceptional commission to use its connections. This type of service and its associated commission are not generally applied by DBI.

The appropriate reaction
The use of a service provider must be based on its actual expertise, and not on the friendly relations it claims to have. Any payment to a service provider must be in return for a deliverable. In this case, the commission requested does not seem to correspond to a genuine service. You should refuse this proposal and explain to your colleague that such practices are strictly prohibited by DBI. You should also immediately contact your line manager to make them aware of the situation.

If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com

FACILITATION PAYMENTS

A facilitation payment is a small sum of money paid to a public official (generally requested by the public official and paid in cash) in order to speed up the completion of a routine administrative procedure such as the issue of a work permit, a visa, police intervention, customs clearance or any other type of public service At DBI, we formally prohibit any facilitation payments made by an employee or intermediary acting on our behalf.

Kuv yuav ua li cas?

The situation
You are responsible for the smooth transit of goods from an Asian supplier. The carrier contacts you to inform you that the goods are being held up at  customs. Given the importance of this delivery, they offer to pay an  additional customs fee to speed up the clearance process and ensure faster  delivery.

The appropriate reaction
You must categorically refuse the carrier’s proposal. You should also immediately contact your line manager to inform him of this request.
Our principles: At DBI, we never ask civil servants for a favour. We respect administrative procedures without trying to speed them up by paying sums  that are not due, even if they are only small amounts.

If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com

KHOOM PLIG THIAB KEV PAB CUAM

Kev muab khoom plig lossis caw tus neeg koom tes ua lag luam tuaj yeem pab tsim kev lag luam zoo. Cov no yog cov kev ua haujlwm zoo tib yam ntawm lub neej ua lag luam thiab tsis ua, xws li, ua rau kev noj nyiaj txiag. Txawm li cas los xij, thaum lub hom phiaj ntawm qhov khoom plig lossis kev tos txais qhua yog cuam tshuam rau kev ua haujlwm lossis tsis ua haujlwm ntawm ib tus neeg ua txhaum cai ntawm lawv txoj cai, kev cog lus lossis kev ua haujlwm, qhov no yog kev ua txhaum cai.

Yog li, yog tias muaj nuj nqis lossis zaus ntawm khoom plig thiab kev tos txais ntau dhau, lossis yog tias lawv tau muab rau kom tau txais kev pom zoo lossis cuam tshuam rau kev txiav txim siab, lawv yuav raug pom tias yog kev sim ua kev noj nyiaj txiag thiab nthuav tawm DBI thiab nws cov neeg ua haujlwm rau kev nplua hnyav thiab kev nplua rau pej xeem. Yog li ntawd, peb yuav tsum tau ceev faj thiab ua txhua yam kom pom tseeb.

Txhua tus neeg ua haujlwm DBI yuav tsum ua raws li peb cov khoom plig thiab kev tos txais qhua uas tau teev tseg hauv qab no:
Khoom plig yog yam khoom muaj nqis, khoom lossis kev pabcuam muab lossis tau txais los ntawm DBI tus neeg ua haujlwm, nrog rau kev lom zem muab lossis tau txais uas tsis tuaj koom los ntawm tus neeg caw.

They can take different forms (non-exhaustive list):

• Material goods (chocolates, wine, computers, etc.).
• Tickets for cultural and sporting events.
• Complementary items or discounts on products.

Kev tos txais qhua yog hais txog zaub mov, kev pabcuam, khoom noj khoom haus, kev mus ncig, kev pabcuam thiab kev lom zem ncaj qha ntsig txog kev sib tham txog kev lag luam lossis cov xwm txheej tuaj koom los ntawm tus neeg caw. Rau example, following a business conference, if you offer a business partner a ticket to a sporting event that you are not attending, this is a gift. If you attend the sporting event with the business partner, it is classed as hospitality

Exception: Marketing events organised by DBI, such as product launches, and other collective events are not considered gifts or hospitality. Any  event attended by more than 10 people is considered a group event.

Yuav ua li cas:

• Make sure that the gift or invitation has a legitimate business purpose
• Make sure not to exceed the maximum threshold of 250 euros (excl. VAT) per person per year for any gifts or hospitality received or offered.
• Make your offer of a gift, trip or hospitality transparent and open, so that you feel at ease when you explain it or mention it in front of other people.
• Always declare the gift, gesture of hospitality or trip, in full transparency, when requesting reimbursement via an expense claim.
• If your project exceeds the authorised threshold or if you are in any doubt, consult the Compliance Officer before committing yourself.

It is strictly forbidden to:

• Offer a gift or invitation to a public official holding administrative authority.
• Offer or receive gifts or hospitality during a tender procedure or commercial negotiation.
• Offer gifts or invitations with the aim of obtaining from the recipient an undue advantage for DBI.
• Offer cash or any equivalent, such as cash, gift cards, prepaid cards, etc.
• Offer a gift or hospitality in violation of the recipient’s internal policy, which may be stricter than that of DBI.
•  Pay for or give invitations to illegal entertainment or entertainment that could be perceived as immoral.
   Offer a gift or a gesture of hospitality to the friends or family of a business partner or public representative. The term “family” refers to a spouse, companion, cousin, sibling, child, parent, romantic partner or any person sharing the household.
   Offer or accept a gift or hospitality exceeding the maximum value of 250 euros excluding VAT per person per year. All exceptions must be pre-approved by DBI’s Compliance Officer
   Use your own personal funds (e.g. sums for which you will not claim reimbursement from DBI) to circumvent the restrictions on gifts and hospitality, and never ask a third party to do this for you.

Kuv yuav ua li cas? 

Examplwm 1
You are in charge of negotiations with a wholesaler and learn that the wholesaler’s manager is a basketball fan. You plan to offer her tickets for the next big match, which should make it easier to negotiate the annual rates. However, the price of the tickets exceeds 600 euros.

The appropriate reaction
The €250 limit has been exceeded. You must comply with company policy so as not to compromise the integrity of the negotiations. Propose alternatives that comply with DBI policy to establish a relationship of trust with the wholesaler, without resorting to personal advantages lossis kev coj ua uas tuaj yeem pom tias tsis tsim nyog.

Examplwm 2
During negotiations with one of your suppliers, you receive a gift. Although you are not sure of its value, you have serious doubts as to whether it meets the €250 threshold.

The appropriate reaction:
The gift comes in the middle of negotiations with this supplier, a time when the acceptance of gifts is particularly sensitive. In accordance with DBI rules (set out above), you must inform your line manager. Given the circumstances, you should not accept the gift. You may also seek advice from the Compliance Officer.

If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com

Kev tsis sib haum xeeb ntawm kev txaus siab

Kev tsis sib haum xeeb tshwm sim thaum peb tus kheej nyiam cuam tshuam los yog tuaj yeem cuam tshuam nrog peb lub peev xwm los txiav txim siab raws li kev tsim nyog thiab qhov zoo tshaj plaws ntawm DBI. Peb cog lus tias yuav tsum ua kom pom tseeb hauv qhov txiaj ntsig zoo tshaj plaws ntawm DBI, thiab tsis txhob cia peb cov kev txiav txim siab los txhawb kev nyiam ntawm tus kheej.

Yuav ua li cas:

• Self-assess your personal situation – you are responsible for identifying and disclosing any risk situations.
• Report any situation that could give rise to a conflict of interest to your line manager and discuss it openly. Keep a record of the discussion and the outcome of the decision for future reference.
• Remove yourself from any situation in which the impartiality of your decision cannot be guaranteed or can be questioned.
• Comply with the formal prohibition on participating in any decision in which you have a conflict of interest, or are likely to have, or could give the impression of having, a conflict of interest.

Dab tsi tsis ua:

• Do not do business directly with a supplier or partner in which you or a member of your family has a financial interest.
• Do not do business directly with a supplier or partner who employs a member of your family.
• Never take part in a decision to hire a member of your family or a candidate recommended by a supplier, customer or public official you may know.

Exampnqe 1:
You are in charge of sponsorship operations at DBI. The daughter of a very close friend of yours is the French junior fencing champion. Koj tus phooj ywg nug koj tias DBI puas tuaj yeem txhawb nqa nws tus ntxhais kom nws tuaj yeem koom nrog European Championships.

The appropriate reaction:
If you authorise this sponsorship, the personal link could call into question the impartiality of your decision. You should disclose this situation to your team and your line manager and refrain from taking part in the decision. In this case, you should consult your Compliance Officer for advice on how to manage the situation in accordance with the company’s ethical rules.

Exampnqe 2:
You are in charge of selecting one of DBI’s service providers, a call for tenders is issued and you receive several proposals. Among the three service providers with the most favourable terms and conditions is your mother’s company.

The appropriate reaction:
Given the family link with one of the service providers, your impartiality could be called into question. You must immediately report this situation to your team and your line manager. You are prohibited from taking part in any decision concerning this provider. In this type of situation, you must also inform your Compliance Officer to ensure that the procedure is carried out transparently and in compliance with company rules.

LOBBYING

The company undertakes to conduct its lobbying activities in a legal, transparent and ethical manner. Any interaction with elected representatives or other public officials, whether local, national or international, must comply with the laws in force and must not seek to unduly influence public decisions. Lobbying activities must be carried out in accordance with the principles of integrity and responsibility. Employees must ensure that all communications with public authorities are documented and comply with regulations. Any attempt at illegal lobbying or corruption is strictly prohibited and must be reported immediately to the company’s management.

Kuv yuav ua li cas?

Example:
DBI has launched a new product – menstrual panties. You are responsible for registering this product on the list of products and services reimbursed by social security. A PR consultant from the pharmaceutical sector offers to facilitate relations with the health authorities in exchange for a substantial fee. This intermediary claims to be able to secure the inclusion of DBI on the list of products reimbursable by social security, which would represent a strategic commercial asset.

The appropriate reaction:
The amount of remuneration paid to intermediaries and the methods used must be scrupulously analysed. Excessive remuneration of intermediaries is often a sign of corrupt practices. You should consult your purchasing department and your Compliance Officer to ensure that the contract to be concluded includes anti-corruption clauses and describes precisely the service expected and the limits of the intermediary’s involvement.

SPONSORSHIP, PATRONAGE THIAB DONATIONS

Kev txhawb nqa yog ib feem ntawm txoj kev lag luam. Nws yog cov txheej txheem kev sib txuas lus uas suav nrog kev muab nyiaj txiag, khoom siv lossis kev txhawb nqa tib neeg rau ib tus neeg, kev tshwm sim lossis lub koom haum sib pauv rau cov txiaj ntsig kev tshaj tawm. Patronage thiab donations, ntawm qhov tod tes, tsis koom nrog ib qho ntawm cov neeg tau txais txiaj ntsig.

These operations help to strengthen the brand’s image and are an effective way of supporting causes and projects that are in line with DBI’s values. However, they can be used to conceal an undue advantage nyob rau hauv cov ntsiab lus ntawm kev noj nyiaj txiag thiab kev dag ntxias. Kev txhawb nqa thiab kev txhawb nqa kev ua haujlwm yog li ua rau muaj kev ua txhaum cai, nyiaj txiag thiab lub koob npe nrov rau DBI.

Yuav ua li cas

• Ensure that the operation and the identity of the beneficiary of the sponsorship or patronage comply with DBI’s values and rules.
• Check the legitimacy of the aim pursued by the sponsorship or patronage operations.
• Formalise operations within the framework of written agreements, in accordance with the models in force within DBI.

Dab tsi tsis ua

• Do not carry out sponsorship or patronage operations with the aim of obtaining an advantage or undue influence.
•  Do not accept a sponsorship or patronage operation without an approved agreement.
• Do not make donations to political parties.

Kuv yuav ua li cas

Example: During checks carried out as part of the procedure relating to sponsorship operations, you discover that the president of the beneficiary organisation is also the commercial director of a DBI supplier.

The appropriate reaction: It is necessary to inform the Compliance Officer and analyse the real reasons for the sponsorship. If there is a direct link between the sponsorship and commercial conditions negotiated with the supplier or personal benefits for the commercial director, then you must abandon the sponsorship operation to avoid any risk of it becoming part of a corruption scheme.

Kev sib raug zoo nrog pej xeem cov cai thiab cov neeg ua haujlwm

Hauv ntau lub tebchaws, txoj cai tswjfwm kev ua txhaum cai nrog cov neeg hauv kev lag luam ntiag tug txawv ntawm cov neeg ua haujlwm nrog pej xeem. Cov tom kawg raug rau txim hnyav dua. Kev txiav txim siab tuaj yeem ua rau kev tshem tawm daim ntawv tso cai rau kev xyaum, kev nplua hnyav thiab kev tshaj tawm kev rau txim ua rau peb lub koob npe nrov.

Yog li ntawd, peb yuav tsum ua tib zoo saib xyuas thiab siv qhov ceev faj tshaj plaws thaum sib tham nrog cov neeg sawv cev pej xeem lossis cov tswv cuab ntawm lawv tsev neeg. Lub ntsiab lus ntawm pej xeem sawv cev yog dav, yog li nws yog ib qho tseem ceeb kom paub koj tus kheej nrog lub tswv yim:

Cov nom tswv pej xeem

• Tus neeg sawv cev ntawm tsoomfwv, txawv teb chaws lossis lub tebchaws,
• Tus neeg sawv cev ntawm tsoomfwv lub koom haum;
• Elected representative
• Any person holding a public office or a legislative, administrative or judicial position.

Other third parties considered a public official 

• Employee of a state-owned or state-controlled company;
• Employee of a public international organisation (World Bank, United Nations, International Monetary Fund, etc.);
• Private person officially mandated by a public body or company
• Representative or employee of a political cabinet.
• Candidate in a political election

Yuav ua li cas:
All payments made to public officials must be supported by receipts. If in doubt, immediately inform your legal manager or your local ethics and Compliance Officer.

Dab tsi tsis ua:

• Never pay a facilitation payment to speed up an administrative procedure unless there is an imminent threat to your health or safety.
• Never try to influence a public official.
• Never use an intermediary to influence a public official.

Kuv yuav ua li cas?

Exampnqe 1:
The mayor of your local authority has issued a decree ordering the closure of your sales outlet for failure to comply with fire safety regulations. During a discussion with her, you understand that she would be prepared to revoke this order if you provide financial support to a local sports club of which she is president.

The appropriate reaction:
You must not accept this proposal. Instead you must immediately alert your line manager and your Compliance Officer so that together we can define the right course of action.

Examplwm 2
DBI has a Seveso-classified plant. You are in charge of renewing the operating permit. Because of shortcomings revealed during a previous inspection, you are afraid that the permit will not be renewed this year. A colleague suggests that you approach the Prefect and offer to sponsor a number of local clubs and associations in exchange for renewal of the permit.

The appropriate reaction:
You should turn down your colleague’s proposal and explain the reputational and criminal risks of such an agreement.

Exampnqe 3:
You are in charge of obtaining a grant to set up a new outlet in a rural area. The site is promising, but obtaining the grant would maximise the site’s profitability. The public official in charge of awarding the grant contacts you and suggests that you will be awarded the grant if you choose her husband’s company to carry out all the work required to set up the new outlet.

The appropriate reaction:
You must not accept the proposal. Instead you must immediately alert your line manager, your legal department and your Compliance Officer so that together they can define the right course of action.

Kev sib raug zoo nrog peb tog

DBI’s business involves regular interaction with a wide variety of third parties (partners, subcontractors, suppliers, principals, customers, buyers, sellers, etc.). These various business relationships may expose DBI to risk of corruption. Where the business relationship involves selection, this must be based on objective criteria relating to the quality of the third party’s offer. In addition, it is essential to carry out due diligence on these third parties to ensure their level of integrity.

Qee lub lag luam kev lag luam tau paub tias muaj ntau yam kev txwv tsis pub siv, yog li peb yuav tsum tau ceev faj tshwj xeeb. Qhov no yog qhov teeb meem, rau example, le:

• Kev tsim kho kev lag luam hauv qhov dav dav ntawm lub sijhawm, suav nrog kev ua haujlwm tu, kho kom zoo nkauj thiab kev ruaj ntseg ntawm qhov muag.
• Cov kev pabcuam kev txawj ntse muab los ntawm cov kws pab tswv yim lossis cov koom haum ua lag luam, uas nws cov khoom xa tuaj tsis tshua pom tseeb.

Nws yog ib qho tseem ceeb uas yuav tsum tau ua raws li cov txheej txheem kev ntsuam xyuas thib peb txhawm rau txheeb xyuas cov theem ntawm kev ncaj ncees ntawm cov neeg thib peb ua ntej nkag mus rau hauv, txuas ntxiv lossis txuas ntxiv kev sib raug zoo ntawm kev lag luam.

Yuav ua li cas:

• Third parties are selected on the basis of objective criteria in line with DBI policy.
• Follow DBI’s procedure for evaluating third parties, in particular the VMRF form for new suppliers and the internal form for new customers.
• Ntsuam xyuas kev ncaj ncees ntawm cov neeg muab khoom raws li cov txheej txheem kev soj ntsuam thib peb thiab qhia rau koj tus neeg ua haujlwm ncaj ncees thiab ua raws cai tam sim yog tias tsis ntseeg.
• Formalize tag nrho cov lus cog tseg thiab xa tuaj rau hauv daim ntawv cog lus pom zoo los ntawm tus neeg tso cai hauv DBI.
• Sib txuas lus nrog peb cov kev cog lus tiv thaiv kev noj nyiaj txiag rau cov neeg muab khoom, txhua qhov chaw lawv nyob.

Dab tsi tsis ua:

• Do not pursue a relationship with a supplier who does not respect our ethical commitments.
• Do not start working with a supplier or customer without the VMRF or forms being validated.
• Do not work with a supplier with whom you have a conflict of interest.

Kuv yuav ua li cas?

Examplwm 1
You are responsible for checking that DBI suppliers comply with the company’s principles. One of your Asian suppliers asks you to disregard his latest audit, which mentions a violation of the ban on the use of forced labour. In exchange, he offers to send you something of great value

The appropriate reaction:
Refuse the supplier’s offer and report the behaviour to the Compliance Officer. The Group’s quality procedure must be followed.

Examplwm 2
You are in charge of DBI’s distribution strategy. A local intermediary contacts you and informs you that he has established relationships with several local retailers who are willing to distribute DBI products. The intermediary suggests that in order to ensure rapid co-operation and promote the visibility of your products, additional financial support could be provided to the retailers.

The appropriate reaction:
Refuse the intermediary’s offer and report his behaviour to the Compliance Officer.

Examplwm 3
You are in charge of negotiating with the commercial landlord of a shopping centre for the allocation of a strategic outlet. The lessor suggests that he is in a position to facilitate the allocation of this outlet, but makes you understand that this will only happen if you agree to give him a discreet consideration, outside the formal framework of the transaction.

The appropriate reaction:
Refuse the lessor’s offer and report his behaviour to the Compliance Officer.

CEEB TOOM TXOG HNUB NYOOG LI CAS
Thaum peb ntsib ib qho xwm txheej uas zoo li txawv txav rau peb, lossis qhov uas peb tsis xis nyob, peb yuav tsum nug peb tus kheej cov lus nug hauv qab no:

• Are laws and regulations adhered to?
• Does this comply with the Anti-Corruption Code?
• Is it devoid of self-interest?
• Can I justify my decision?
• Would I be embarrassed if my decision was made public?

NYEEM NTAWV TXOJ CAI TSHIAB

Peb txhua tus muaj lub luag haujlwm rau kev tshaj tawm cov xwm txheej uas peb ntseeg tias yog qhov cuam tshuam rau Txoj Cai Tiv Thaiv Kev Cuam Tshuam no. Txawm hais tias peb muaj kev paub ncaj qha lossis tsis ncaj nraim ntawm qhov tseeb, nws yog qhov zoo dua los qhia peb cov kev tsis txaus siab kom ua ke peb tuaj yeem xav txog txoj hauv kev zoo tshaj plaws los tiv thaiv DBI thiab tag nrho nws cov neeg ua haujlwm.

Peb tuaj yeem tiv tauj peb tus thawj tswj hwm kab, tus thawj coj ntawm tib neeg cov peev txheej lossis DBI Tus Thawj Saib Xyuas Kev Ua Raws Cai. Ntxiv rau cov channel no, DBI muab peb cov kab kev coj ncaj ncees suav nrog xov tooj hu xovtooj thiab Navex, ib qho kev tshaj tawm online. Navex tso cai rau cov ntawv ceeb toom xa mus kom ruaj ntseg thiab tsis pub leej twg paub, thaum muab qhov muaj peev xwm ntawm kev qhia tsis qhia npe.
Xov tooj: 08.05.22.31.59

Navex alert tool: EthicsPoint – DIM Brands International
DIM Brands International yog lub luag haujlwm rau lub kaw lus thiab lav kev tiv thaiv ntawm cov neeg tawm xov xwm tawm tsam ib qho kev ua lossis kev hem thawj ntawm kev ua pauj, txawm tias qhov kev xav tsis thoob tom qab tus neeg xa xov liaison ua tsis raug.

Peb tej ntsiab cai

• We listen to every alert with care and seriousness.
• Every alert is treated with the highest standards of confidentiality.
• Whistleblowers can remain anonymous using Navex software.
• We inform whistleblowers of the action taken on their reports, subject to the necessary confidentiality.
• Whistleblowers are protected against reprisals or threats of reprisals.
• As managers, we encourage a culture of free speech and sympathetic listening.

Yog xav paub ntxiv
Yog xav paub ntxiv, saib qhov kev nthuav qhia ntawm txoj kab ncaj ncees.

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