FOREWORD BY FOUNDERS AND CHAIRMANS
Placing ethics at the heart of our business conduct is a powerful moral commitment, and the principle of trust is essential to the sustainable development of our business. This culture of integrity is of course based on compliance with laws and regulations, but equally on commitment to the values of the Group. It must be embodied by every one of DSV’s employees in their daily activities, whatever their nationality, location, position or seniority in the business and companies.
Since 2009, when our company built by founders, Code of ethics become our first major of issue after vision and mission, our Code of ethics has defined the major principles which frame and guide our daily actions. This Code provides a framework for what is expected from each of us in our professional activities, and when we are in contact with our employees, customers, shareholders and business partners. It also defines our commitment to the environment, whichwe are dedicated to protecting and on which we wish to minimize our impact, and to society at large, in which we intend to fully play our part as a good corporate citizen, engaged and responsible.
This is the fourth edition of our Code of ethics since 2009 and it provides us with the opportunity to restate what shapes our ethical approach, at a time when our transformation into a establish fashion and elegance company.
The Code of ethics powerfully reaffirms our commitment to respect for human rights, not only for all our employees, but also for all those who work in our supply chains and contribute to our value creation. We mobilize all our energy and vigilance to combat child labor, forced labor, human trafficking and the exploitation of the most vulnerable groups, in particular migrants, as well as to combat all violence and discrimination, especiallyagainstwomen.
This updated version also enables us to recall all the progress made in better preventing and detecting corruption and influence-peddling, in particular since 2009, the setting up of our Compliance Organization and the international network of Brand Compliance Officers within our Houses. They oversee strict compliance with all applicable laws and regulations in this area by defining the necessary policies and procedures, and supporting all our employees accordingly. We practice zero tolerance towards corruption, influence-peddling and any form of fraud, and it is vital that each and every one of us is aware of this.
Finally, it is particularly important to recall here that the ethical whistleblowing system thatDSVCLOTHESset up severalyearsago,and which enables any individual to report a violation or suspected breach of our Code and its principles, is now available not only to DSVCLOTHES employees, but also to external and temporary staff working for the Group in all service providers and external partners with whom we have a contractual relationship.
This mechanism is essential, and enables us to identify any possible shortcomings in adhering to our principles, as well as the remedial steps necessary. Protecting those who report such shortcomings to us selflessly, and in good faith, is an essential commitment throughout the Group.
This Code is a guide intended to provide a framework for all our activities, and to protect the group, itssuccess andlongevity.I trust that you willfamiliarize yourself with itandapplyitonadaily basis.Everything has been set up within the Group to support and help you fulfil this requirement;Iam counting on you.
Chairman and Chief Executive Officer
COMMITMENT BY DSVCLOTHES EXECUTIVE COMMITTEE
As members ofthe DSVCLOTHES Executive Committee, we are collectively incharge of the conduct of the Group’s business and fully aware of our individual responsibility to disseminate, explain and live every day the principles of the DSVCLOTHES Code of ethics in all the activities of the Group and its Houses wherever we operate in the world. It is a moral imperative and, beyond that, a guarantee of continuity and success for the Group.
In particular, it is our individual and collective responsibility to demonstrate every day, through the power of personal example and conduct, the comprehensive applicability of the ethical principles that guide our Group management.
The DSVCLOTHES Code of ethics was presented to and reviewed by the DSVCLOTHES Board of Directors before being circulated to all employees in the Group.
The Group’s governing bodies apply the following principles at all times:
- Members of the Group’s Executive Board and the directors of the Group comply with the rules defined by the Group and the internal regulations of the Board, supported by regular training courses, particularly in matters pertaining to conflicts of interest.
- Within the Board of Directors, the aim of the Sustainable Development Committee is to assist the Group in the design, implementation and monitoring of good governance consistent with the Group’s stringent requirements in the area of sustainabledevelopmentandethics.
- Remuneration for executive directors includes a variable component based on effectively promoting a culture of performance and integrity within the Group.
OUR ETHICAL PRINCIPLES IN THE CONDUCT OF BUSINESS
The dsvclothes and Group makes sure that it behaves in an honest and responsible manner.
To take an ethical approach to business in all circumstances is a guarantee of business continuity. Our success and sustainable development in our markets depends on the confidence of our customers, employees, shareholders, business partners and local communities. This trust is built over time, and must be earned every day. Ethics in a business environment covers many issues which may sometimes appear contradictory. This is especially true of a Group operating across all continents, in countries with different cultures at varyingstages ofeconomic development.
However, these differences can be structured around a few simple but powerful shared principles, which should guide our actions in a spirit of responsibility and common sense. The Dsvclothes Code of ethics was drawn up in 2009 following the Group’s built in 2009. It is regularly updated and pursues a twofold ambition:
- to set out the ethical principles of the Group simply and methodically,
- to address all employees of the Group and, above and beyond them, all our stakeholders.
The ethical principles we all share are to:
- act with integrityand a sense of
- comply with laws and
- respect the dignity and rights of every
- act with respect for the natural
- use the company’s assets and resources in the interests ofthe Group
- encourage our employeesin theircommunity involvement and sustainability
- respect business
The Group’s ethical principles of business conduct aim to respect the following key international references (notabene: we just make these for references):
- The United Nations Universal Declaration of Human Rights and the European Convention on Human Rights;
- Various International Labor Organization conventions, in particular conventions 29, 105, 138, 182 (child labor and forced labor), 155 (occupational health and safety), 111 (discrimination), 100 (equal remuneration), 87 and 98 (freedom of association, protection of the right to organize and collective bargaining);
- The OECD Guidelines for Multinational Enterprises;
- The United Nations Convention on the Rights of the Child;
- The 10 Principles of the United Nations Global Compact and associatedSustainable Development Goals (SDG);
- The UNGP (United Nations Guiding Principles on Business and Human Rights);
- The United Nations Women’sEmpowerment
The application of ethical principles in our daily activities may give rise to questions, and must be constantly encouraged and reinforced by example, an in-depth knowledge of the subjects,trainingandthe rightto question.
In addition to the Code of ethics, which is the basis and frame of reference for the Group’s ethical business conduct, there are other documents with which it is essential to be familiar and which must be correctly applied. It is therefore the responsibility of each individual toenhance their knowledge of the topics affecting them, based on their specific responsibilities, by reading the documents which complement the Code, in particular the Compliance Manual and its associated policies and procedures. Similarly, every year each employee in the Group must take the compulsory training course or courses on ethics developed for all employees of the Group worldwide.
Every groups employee must be familiar with the Code and its principles, and question themselves before acting, particularly if they have any doubts about their conduct, be vigilant, ask for help if they do not know how to resolve the ethical dilemma which confronts them, and report any problem or breach of the Code.
We undertake to prevent and penalize any breach of the Group’s Code of ethics, and to put in place all the corrective and remedial actions necessary.
OUR PRINCIPLES OF BUSINESS PRACTICE AND BEHAVIOR TOWARDS OUR PRINCIPAL STAKEHOLDERS
In addition to the references listed above, the DSVCLOTHES and Group considers it important to recall and clarify the principles of practice and behavior shared byall of us, and expected ofevery individual in respect of the different audiences and stakeholders with whom we are in regular or occasional contact.
This therefore concerns:
- the employees of the Group,
- our customers and consumers,
- our shareholders and the financial markets,
- our business partners and our competitors,
- the environment,
- society at large.
THE EMPLOYEES OF THE DSVCLOTHES AND GROUP
Managers: a key role in respecting our ethical rules and promoting a culture of integrity
In order to help all employees succeed in their duties according to the rules and ethical principles of the Group, Managers have the specific responsibility of embodying the ethical values and principles of the Group by setting a personal example, and ensuring that the Code of ethics is properly applied and respected by their teams. They are guarantors of the dissemination of key messages and good practices within the Group. They are at the forefront of listening to and supporting their teams should an ethical question or dilemma arise, encouraging them to express their doubts and questions freely.
We undertake to respect and implement the following values and rules in our professional relationships:
Integrity, loyalty and responsibility
We have an obligation to act with integrity, loyalty and a sense of responsibility. In particular, we will ensure that we do not get involved in situations that could prove to be fraudulent (corruption, conflicts of interest, misappropriation of assets, communication of fraudulent information etc.) or malicious.
In general, in our daily actions associated with our professional activities, at our usual place of work or when we are travelling on business, we will ensure that we respect the ethical principles of the Group, safeguard the interests and the image of the Group and of its Houses.
Respect for human rights and laws
We owe our colleagues and staff respect and fair treatment, and the guarantee of a motivating work environment which respects the dignity and rights of all individuals, fostering development and well-being. We will promote a human resources policy that contributes to professionalism, motivation and job satisfaction for all by offering opportunities for training, mobility and internal promotion, and by developingthe employ abilityof each individual.
We provide a working environment that respects human rights and labor laws, and complies with laws and regulations on the environment, health and safety in all the countries in which we operate.
We ban child labor and forced labor.
We encourage dialogue and respect the free exercise of unions’ rights within the context of local laws and regulations.
Non-discrimination, diversity and equality and reasonable of opportunity
At DSVCLOTHES we believe that diversity is a source of creativity and innovation, and therefore of economic performance. We are careful to develop an inclusive approach in which all differences are taken into consideration, so that everyone is given the opportunity to be themselves. This is why we take care to spread a culture of equality at all levels of the organization and offer our teams an open and stimulating work environment, free from any discrimination, which contributes to the success of the Group. We promote equality of opportunity and treatment. Within this context, we affirm our commitment to greater diversity and gender parity in all roles and positions, and at all levels in the Group hierarchy, in particular by putting an end to the waste of female talent through the whole chain of command.
Well-being at work, work-life balance
To ensure that our employees maintain a good balance between their working lives and personal lives, and to promote the well-being of each individual at work, DSVCLOTHES seeks to facilitate a supportive working environment which is caring and productive. For this purpose, the Group implements policies and mechanisms to facilitate each individual’s daily life, and improve the quality of life at work: remote working, parental leave, portal solution for best managing the work-life balance, psychological support service, wellness days, etc.
Furthermore, as the Group we committed to combatting violence against women via our further foundation.
In their daily exchanges and interactions with the Group’s internal or external stakeholders, all employees undertake to:
- protect business confidentiality by respecting agreements signed and the principles of confidentiality prohibiting any unauthorized disclosure;
- strictlylimitthedisclosure ofinformation exclusively to the personsconcernedand duly authorized;
- keep and protect all confidential data for which they are responsible;
- pay particular attention to written and/ or verbal information disclosed in public
Protection of employee personal data
We have always recognized the value of our employees’ and teams’ data, and as such, we respect and protect their privacy.
To this end, all employees of the DSVCLOTHES Group benefit from the following rights:
- fair and transparent information before any new processingofdata,andpriorconsent if appropriate,
- right to object to processing if there is a legitimate interest,
- right to access and correct data,
- accessto their data islimitedtoa restricted number of people,
- right to be forgotten after they have left the company, provided the necessary conditions have been met.
As DSVCLOTHES operates in the fashion and beauty sectors, some of its employees may have data available to them with a potentially high market value. The Group is aware of the risk of data breaches, and therefore also undertakes to enhance data security.
Responsible use of the Group’s assets
Every employee undertakes to avoid the misuse, waste or inappropriate use of all the Group’s resources. In particular, for all material resources (telephone, vehicle, computer, etc.), all employees undertake to comply with the rules for their use of which they have been informed. For intangible resources (internet, email, etc.), personal use may be tolerated on an occasional basis, provided it does not adversely affect correct performance of professional activities.
Reasonable use of social networks and personal websites
We encourage staff to be ambassadors for the Group and/or their House. However, only the persons duly authorized to do so within the Group and/or the Houses may communicate on behalf of the Group and/or its Houses. Talking about the Group is permissible, but not on behalf of the Group.
Every employee represents the professional values of the Group in the public and private sphere, including on social networks and personal websites. We therefore have an obligation to act with integrity and professional discernment when we express our views on subjects that are directly or indirectly connected to the Group, in order to preserve DSVCLOTHES’s image and reputation. We must ensure that there is no possible confusion between our opinions and personal interests and those of the Group. For this reason, employees acting under their real identity, or whose identity is associated with their place of work on social networks and discussion forums, must mention that they are acting on their own behalf and that their views do not reflect the image or the stance ofthe Group onthe topics addressed.
Training and ethics awareness
Training and ethics awareness programs are available to all employees of the Group worldwide. This program, which is renewed every year, gives everyone the tools to understand what is expected of them and to guide their actions in full compliance with the Group’s ethical principles by the use of specific scenarios and relevant examples. Attendance is compulsory.
OUR CUSTOMERS AND CONSUMERS
Honesty, safety and quality
We provide our customers and consumers with the very best professional service to ensure that they are satisfied and to earn their trust. Through its Houses, the Group designs and markets products or services that comply with current standards and regulations in terms of quality, safety, industrial and intellectual property rights, and provides transparent, reliable and fair high-quality information.
Our public relations and advertising are based on honesty and fairness, and always keep customer and consumer safety in mind.
Protection of personal and confidential data
Our customers retain the power to make decisions about the information that they entrust to us, and we ensure that the confidential nature of their private data is preserved by respecting the commitments we have made to them and in accordance with applicable laws.
We respect the right of individuals to retrieve, correct or erase data, and use back-up devices (both physical and digital) for the data collected.
The Group recognizes the value of the data that its customers and contacts have entrusted to it. Operating in the fashion and beauty sectors, the Group possesses customer data with a potentially high market value. Being aware of the risk of data breaches, the Group has focused not only on complying with the General Data Protection Regulation, but also ensuring that it provides the best possible protection for its customers’ data.
To equip itself in the best possible way to combat the risk of data breaches, the Group has set up the necessary confidentiality policies between its brands, its different departments and entities.
We have set up a cross-functional approach involving all functions, all countries and all the Group brands under the supervision of a Group CEO, in order to best manage any potential riskconcerning the data thatwe control.
OUR SHAREHOLDERS AND THE FINANCIAL MARKETS
We practice a style of corporate governance that reflects best current practice and standards. We have to earn the trust and support of our shareholders and the financial markets by using the Group’s resources in a responsible and efficient way. We owe it to them to provide honest, precise and accurate financial information. We commit to allow fully applicable accounting, financial and (in the future when IPO) stock exchange standards and regulations.
OUR BUSINESS PARTNERS AND OUR COMPETITORS
We are committed under all circumstances to fair and equitable business relationships.
The Group publicizes its ethical principles which must guide the conduct of business by its employees, as well as by its business partners, particularly in regards to compliance with laws and regulations, the prevention of any form of corruption, including influence-peddling, and conflicts of interest.
Corruption, influence-peddling, facilitation payments
DSVCLOTHES strictly prohibits corruption in any form whatsoever, including influence-peddling, and intends to prevent it by complying with the anti-corruption laws applicable in each country in which the Group operates. The Group exercises zero tolerance in this respect.
Active corruption consists of illegally offering or promising an advantage to a person at any time, whether directly or indirectly, which is aimed at inciting that person to act or refrain from acting. The concept of passive corruption refers to the situation of the person corrupted. Corruption is subject to criminal penalties, whether the person corrupted works in the public or private sector. “Offering an advantage” means offering anything of value (money, of course, but also for example vouchers, various kinds of invitation, gifts, donations,
job promises, reimbursement of travelling expenses, etc.).
As far as “influence-peddling” is concerned, this consists of offers, promises, donations, gifts or advantages of any kind offered directly or indirectly to a person for themselves or for another person, to encourage them to abuse, or because they have abused, their real or assumed influence for the purpose of obtaining distinctions, jobs, contracts or any other favorable decision from a public authority or public administration.
We ban facilitation payments throughout the Group, which means the payment of an unofficial sum of money with the aim of facilitating, guaranteeing or speeding up the execution of an administrative decision.
Financing of political organizations, unions, cultural or charitable organizations in the name of or on behalf of the Group for the purpose of obtaining material, commercial or personal advantage, whether direct or indirect, is also totally prohibited.
Gifts,benefits in kind,entertainment, donations and sponsorship
Every employee must ask himself or herself the question as to whether a gift, favor or invitation, whether received or offered, is intended by the person offering it to influence the person receiving it.
our employees and business partners must never promise, offer, give, request or accept goods or services such as gifts, services or entertainment for the purpose of obtaining an advantage or exerting any influence whatsoever.
The very fact of requesting, accepting or encouraging the granting of gifts from existing or potential suppliers, customers or partners
may entail a conflict of interest, or even an act of corruption.
As the value of gifts does not automatically lead to the conclusion thata conflictof interest or an act of corruption exists, each employee is invited to provide his or her line management with evidence of transparency and vigilance in respect of the reasonforandlegitimacy of the offer.
Donations and sponsorship deals must similarly be transparent and duly justified. Any planned donation to a charitable organization must have been audited and approved in advance.
In case of doubt, the employee must contact his or her line manager and consult the applicable local procedures.
Conflicts of interest
DSVCLOTHES employees must not place themselves in situations in which their personal interests, or those of their families or close relatives, may conflict with the interests of their House or of the Group, or would risk damaging their independence of judgement, their professional integrity or the image or reputation of the Group. This is what is called a conflict of interest situation.
The following situations may give rise to a conflict of interest and are to be avoided, as they run counter to the interests of the Group:
- working, even on a voluntary basis, for a third party with interests which conflict with those of
- maintaining personal, financial or commercial interests and fostering situations which could interfere with the actions and/ or the decision-making of
- maintaining inappropriate working relationships withimmediatesuperiors or
- receiving gifts or invitations which could influence personal
- influencing the selection or choice of a service provider for furthering personal interests or those of
If an employee is faced with the risk of a conflict of interest, he or she must immediately inform their direct or indirect superior, or any other relevant body or directorate (Human Resources Department, Internal Audit Department, Compliance Organization, Compliance Officer) and refrain from any involvement in the relationships which his House or the Group maintains with the third party concerned until a solution has been found.
Fraud generally refers to an act of deception against an individual or a company in order to incite the person or company to supply money, goods or other major resources (such as valuable information) illegally.
Frequent examples of fraud cover:
- identity theft;
- falsified or fraudulent bank transfers;
Fighting fraud is an essential ethical undertaking for the proper conduct of our business, and constant vigilance is required. Any fraudulent act is reprehensible, and disciplinary measures can be taken.
Competition law is intended to guarantee that all companies engage in fair competition in order to offer high- quality products and services at the best prices. We believe in free, open and fair competition, a factor in economic and social progress in terms of prices and the quality and scope of the offer, in the interests of the consumer. We intend to comply strictly with regulations applicable to competition in all markets where the Group operates.
Commitments by our suppliers and subcontractors
Respect for human rights and fundamental freedoms are DSVCLOTHES’s core ethical commitments and must be upheld by all of its employees and stakeholders. Tothis end, our Code of ethics draws on major international references on ethics and human rights.
We require our suppliers to comply with the principles defined in the Group Suppliers’ Charter. We prohibit child labor and forced labor. The Group carries out checking procedures and does not knowingly work with partners who do not share these essential principles at the heart of their businesses and inthechoiceoftheirownservice-providers.
The Group is therefore committed to regularly assessing its main suppliers; DSVCLOTHES and its Houses provide support and advice to them (training program, development of skills, sharing good practice and so on) to ensure that they comply with its Code of ethics and Suppliers’ Charter.
The Group has further set out Sustainability Principles which are systematically communicated to every supplier with which the Group has a contractual relationship; these restate all the fundamental principles and guidelines that complement and specify the major principles of the Suppliers’ Charter,and are available on the Group’s website.
Taking into account the activities specific to the Luxury industry, and specific problems associated with modeling, the DSVCLOTHES Group has furthermore developed a charter on working relationships and the well-being of models which promotes high standards of integrity, responsibility and respect towards the persons concerned.
Finally, the Group puts its Statement on Modern Slavery online on its website.
TO CONTACT US ABOUT COMPLIANCE CODE OF ETHICS
The names of the Brand Compliance Officers are available to employee son the Group’s data.