5 Supplier Code of Conduct FACILITATION PAYMENTS Facilitation payments – sometimes also called “grease” payments – are small payments made to public officials to secure or speeds up routine or necessary processes, which the public official is already duty-bound to perform without the need for payment. Such payments may seem harmless, partly because the sums involved are usually small and partly because they are often regarded as part of local custom or culture but are still considered bribes and therefore prohibited. As a DSV Supplier, you are strictly prohibited from making facilitation payments or accepting such practice in any country by any party. It makes no difference whether facilitation payments are permitted or commonly accepted according to local practice. The only exception is if you reasonably believe that your or another person’s life, health or safety may be at risk. In these instances, making the payment is not considered a violation of the Code, but must be reported to your DSV contact person. Example of a facilitation payment: Offering a facilitation payment: You need a permit. The issuance of the permit usually takes two weeks. You offer the public official handling the permits a small amount of money to issue the permit in one day. By doing so, you make the person speed up the issuance process. This is a facilitation payment. KICKBACKS A kickback is a payment or a form of negotiated bribery where a commission given to someone for facilitating a commercial transaction such as a contract. Kickbacks are also considered bribery, and it is therefore prohibited for DSV Suppliers to give or receive kickbacks to or from other business partners. Kickbacks, as referred to here, must not be compared to a normal bonus programme between the Supplier and DSV. Examples of kickbacks: Receiving kickbacks: You are responsible for hiring road transport subcontractors to provide DSV with transportation services. You get in contact with a new road transport subcontractor and consider hiring this company even though you have some concerns about whether the subcontractor can deliver on quality. You express your concern to the subcontractor and suddenly they offer you a percentage of all sales to be paid to you personally – the higher the sale, the higher the payment you will receive. Such an arrangement would be considered a kickback. MONEY LAUNDERING, FINANCING OF TERRORISM AND OTHER CRIMINAL ACTIVITIES Money laundering is the act of concealing or disguising money obtained from criminal activities and making it appear to have originated from legitimate sources or to constitute legitimate assets. Funding terrorism operations may involve concealing the source of funds or their intended use. You must not engage in money laundering or any activity that facilitates money laundering, funding of terrorism and any other criminal activities. GIFTS AND HOSPITALITIES Entertainment, hospitality and the exchange of gifts are considered common practice and part of building and maintaining business relationships throughout the world. However, DSV suppliers should be careful that the exchanges do not constitute bribes or can be perceived by others as an unfair influence. As a DSV supplier, you are allowed to accept and offer gifts if the value does not exceed a reasonable level and the gift, entertainment or hospitality is not intended to influence the recipient. What is considered reasonable will vary depending on the country and culture. As a rule of thumb, the value of a gift should not exceed twice the estimated hourly wage rate of the recipient. It is not allowed to accept or offer cash equivalent gifts, such as gift cards. Paid travel expenses, hotel accommodation and restaurant visits must be directly related to the business conducted with DSV. Regardless of the value of the gift or hospitality, you should always be aware of the timing of the exchange to ensure that it cannot be perceived as a bribe or an unfair influence. DIRECT POLITICAL CONTRIBUTIONS When acting in the capacity of a representative of DSV, engaging in direct political contributions is strictly prohibited. Direct political contributions include monetary and in-kind endorsements for election campaigns, parties, organisations, or politicians on behalf of DSV. This prohibition does not apply to suppliers’ personal choices or political beliefs, as long as these cannot be confused or misinterpreted as representing those of DSV.
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