4 DSV Code of Conduct ANTI-BRIBERY AND CORRUPTION DSV has a zero-tolerance approach towards bribery and corruption and complies with applicable anti-bribery and corruption legislation, particularly the US Foreign Corrupt Practices Act and the UK Bribery Act. The Code of Conduct describes the specific rules to address bribery and corruption within DSV so that no employees take part in it. The rules described do not prohibit normal and appropriate hospitality given or received. If you are in doubt, please contact your immediate manager or country management. BRIBERY Bribery refers to the offering, promising, giving, accepting or soliciting of an advantage or anything of value as an incentive to influence an act that is illegal, unethical or a breach of trust. The benefit exchanged can include anything of value and is not only limited to monetary transfers (e.g. favours, gifts, loans, etc.). DSV prohibits bribery without exception, including in instances where bribery is accepted as normal business practice. You must not accept or offer a bribe of any kind. The prohibition of bribery includes instances where it takes the following forms: • Charitable donations • Payment of travel expenses • Delivery of products and/or services • Disproportionate entertainment expenses • Transfer of other personal or financial benefits If you are asked to pay a bribe, the incident, including who asked for the bribe, must be reported to the DSV country management, Group Sustainability & Compliance or through the DSV Whistleblower system, Integrity Line . Examples of bribes: Offering a bribe: Offering to pay for a hotel stay for a potential customer and partner, but only if he/she agrees to do business with DSV. This would be an offence since the offer is or can be viewed as being given to gain a commercial and contractual advantage. Receiving a bribe: A supplier offers your nephew a job but makes it clear that in return you are expected to use your influence to ensure that DSV continues to do business with the supplier. It would be an offence for you to accept the offer because you would be doing so to gain a personal advantage.
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