Koda Dij-Gendeliyê ya DIMê

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.

Ji ber vê yekê DBI soz dide ku her tevgerên ne guncaw ji hêla rêveber, karmend, hevkarên xwe yên derveyî û carinan ên wekî karmendên demkî û şêwirmendên di nav hemî pargîdaniyên DBI de, hem li Fransayê û hem jî li derveyî welêt (ji vir û pê ve "Hevkar(an)") qedexe bike û ceza bike.

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, Serok

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. Bi heman awayî, em qet bertîl nadin û ji rayedarên giştî an partiyên taybet bertîlan qebûl nakin.
• 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 hemû şîrketên ku rasterast an nerasterast ji hêla DBI Lux Holdings SARL ve têne kontrol kirin, dihewîne.

• 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.

QERBÛNA SERLÊDANÊ

Ev Koda Dij-Gendeliyê (ji vir û pê ve "Koda") ji bo hemî karmendên DBI-yê, tevî rêveber, efser, karmendên daîmî û demkî, şagirt û stajyeran derbas dibe. Ew her weha ji bo dabînker, xerîdar û hevkarên DBI-yê li hemî welatên ku Grûp lê heye derbas dibe (ji vir û pê ve bi hev re wekî "hevkar" têne binavkirin). Koda Dij-Gendeliyê dê mehek piştî ragihandina wê ji Komîteya Civakî ya Karkeran (WSC) re bikeve meriyetê.

BIKARANÎNA KODA DIJÎ GENDELIYÊ

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.

Kod pabendbûnên DBI-yê ji bo têkoşîna li dijî gendeliyê destnîşan dike û dibe alîkar ku çanda me ya exlaqî belav bibe. Ew:

• Explains what corruption is;
• Pêşkêş dikeamples 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.

Ji ber cûrbecûr rewşên ku gendelî tê de çêdibe, ev Kod nikare berfireh be. Lêbelê, ew amûrek pratîkî ye ku ji we re dibe alîkar ku hûn biryara herî guncaw ji bo rewşê bidin. Ger di gumanê de bin, bi rêveberê xwe yê xetê an Karmendê Pabendbûnê re têkilî daynin.

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

FÊMKIRINA ÇARÇOVEYA QANÛNÎ

Hemû şîrketên DIM Brands International, li Fransa û derveyî welêt, divê pabendî qanûna Fransî ya li ser şefafiyet, têkoşîna li dijî gendeliyê û modernîzekirina pratîkên karsaziyê (ku wekî qanûna "Sapin 2" tê zanîn), û her weha qanûnên din ên dijî gendeliyê û rêziknameyên têkildar bin. Piraniya van qanûnan sepandina derveyî welat hene, ku tê vê wateyê ku, bo nimûneample, 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 stûnên bernameya me ya dij-gendeliyê

• 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

GENDELÎ ÇI YE?
Gendelî kiryara sozdan, dayîn, daxwazkirin an qebûlkirina - rasterast an nerasterast - "tiştekî bi qîmet" e ji bo bidestxistina "avancek neheq".tage”.

Gendelî dikare çalak an pasîf be:

• Gendelîya çalak wê demê çêdibe ku kesek tiştekî bi qîmet li hember avansa neheq pêşkêş dike an dide.tage.
• Gendelîya pasîf çêdibe dema ku kesek tiştekî bi qîmet di berdêla avansek neheq de dixwaze an qebûl dike.tage an jî qebûl dike ku bandora wan bikar bîne.

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

BAZARKIRINA BANDORÊ ÇI YE?
Bandorkirina li ser têkiliyên bi rayedarên giştî re têkildar e. Ew behsa bikaranîna meqam an bandora xwe, ya rastîn an texmînkirî, ji aliyê kesekî ve dike da ku bandorê li biryarek bike ku di dawiyê de ji aliyê rayedarekî giştî ve tê girtin.

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.

Ev pratîk ji bo hemû karmendan bi fermî qedexe ye. Wekî din, ji bo misogerkirina asta herî bilind a exlaqê, DBI pênaseyeke berfireh a bazirganiya bandorê pejirandiye û qedexeyê berfireh dike bo têkiliyên xwe yên bi aliyên taybet re.

Derewînê bedew û biçûk?

Influence peddling involving a public official: 

Rewş
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.

Prensîbên me: 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

PEREYÊN ASANÎNA

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.

Derewînê bedew û biçûk?

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

DIYARIYÊN Û MÊVANXWAZÎ

Pêşkêşkirina diyariyek an vexwendina şirîkek karsaziyê dikare bibe alîkar ku têkiliyek karsaziyê ya baş ava bibe. Ev kiryarên asayî yên jiyana karsaziyê ne û wekî wusa, kiryarên gendeliyê pêk naynin. Lêbelê, dema ku armanca diyariyê an mêvanperweriyê bandorkirina li ser pêkanîna an nekirina kiryarek ji hêla kesekî ve ye ku erkên xwe yên qanûnî, peymanî an pîşeyî binpê dike, ev kiryarek gendeliyê pêk tîne.

Ji ber vê yekê, heke nirx an pirbûna diyariyan û mêvanperweriyê zêde be, an jî heke ew ji bo bidestxistina alîkariyek an bandorkirina biryarekê werin pêşkêş kirin, ew dikarin wekî hewldanek ji bo gendeliyê werin fêm kirin û DBI û karmendên wê bi cezayên giran ên sûc û sivîl re rû bi rû bikin. Ji ber vê yekê divê em baldar bin û her gav bi zelalî tevbigerin.

Divê hemû karmendên DBIyê pabendî siyaseta me ya diyariyan û mêvanperweriyê ya li jêr hatî destnîşankirin bin:
Diyarî tiştên bi nirx, kelûpel an xizmet in ku ji hêla karmendek DBI ve têne pêşkêş kirin an wergirtin, û her weha şahiyên ku têne pêşkêş kirin an wergirtin û kesê vexwendî beşdar nabe.

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.

Mêvanperwerî ji bo xwarin, xizmet, vexwarin, rêwîtî, mayîn û şahiyê tê wateya ku rasterast bi nîqaşên karsaziyê an bûyerên ku kesê vexwendnameyê dide ve girêdayî ne. Bo nimûneample, 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.

Çi bikin:

• 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.

Derewînê bedew û biçûk? 

Example 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 advantagpratîk an rêgezên ku dikarin wekî ne guncaw werin dîtin.

Example 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

Nakokîyên Berjewendiyan

Nakokiya berjewendiyan wê demê derdikeve holê ku berjewendiyên me yên şexsî destwerdanê dikin an jî xuya dikin ku destwerdanê dikin li ser şiyana me ya dayîna biryarekê bi tenê li ser bingeha lîyakatê û li gorî berjewendiyên çêtirîn ên DBI. Em soz didin ku her gav bi zelalî li gorî berjewendiyên çêtirîn ên DBI tevbigerin, û qet nehêlin ku biryarên me ji ber berjewendiyên şexsî bin.

Çi bikin:

• 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.

Çi neyê kirin:

• 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.

Example 1:
You are in charge of sponsorship operations at DBI. The daughter of a very close friend of yours is the French junior fencing champîyon. Hevalê te ji te dipirse gelo DBI dikare sponsorîya keça wî bike da ku ew bikaribe beşdarî Şampiyoniya Ewropî bibe.ampionships.

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.

Example 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.

LOBÎKIRIN

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.

Derewînê bedew û biçûk?

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.

SPONSORÎ, PATRONAZÎ Û BEXŞ

Sponsorgerî beşek ji rêbazeke bazirganî ye. Ew teknîkeke ragihandinê ye ku tê de piştgiriya darayî, madî an mirovî ji bo kesek, bûyerek an rêxistinekê li hember feydeyên reklamê tê dayîn. Ji aliyê din ve, patronaj û bexş ji aliyê sûdmend ve ti berdêlekê nagirin nav xwe.

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 advantagdi çarçoveya gendelî û planên sextekarîyê de. Ji ber vê yekê operasyonên sponsorgerî û patronajê ji bo DBI xetereyek sûc, darayî û navûdengê diafirînin.

Çi bikin

• 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.

Çi neyê kirin

• 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.

Derewînê bedew û biçûk

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.

TÊKILÎYÊN BI DESTHILATÊN GEL Û KAR MAFÎYAN RE

Li piraniya welatan, qanûn sûcên ku bi kesên di sektora taybet de tên kirin, ji yên bi rayedarên giştî re cuda dibîne. Yên paşîn bi tundtir têne cezakirin. Mehkûmkirin dikare bibe sedema betalkirina lîsansa pratîkê, cezayên giran û weşandina cezayên ku zirarê didin navûdengê me.

Ji ber vê yekê, divê em di dema têkiliyê de bi nûnerên giştî an endamên malbatên wan re hîn bêtir baldar bin û bi baldarî tevbigerin. Pênaseya nûnerê giştî berfireh e, ji ber vê yekê girîng e ku hûn xwe bi vê têgehê aşina bikin:

Karbidestên giştî

• Nûnerê hikûmetekê, çi yê neteweyî be çi yê biyanî be,
• Nûnerê rêxistineke hikûmî;
• 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

Çi bikin:
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.

Çi neyê kirin:

• 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.

Derewînê bedew û biçûk?

Example 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.

Example 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.

Example 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.

TÊKILÎYÊN BI ALÎYÊN SÊYEMÎN RE

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.

Tê zanîn ku hin sektorên karsaziyê bi kiryarên qedexekirî tijî ne, ji ber vê yekê divê em bi taybetî hişyar bin. Ev rewş, bo nimûne, wiha ye.ample, bi:

• Sektora înşaetê bi wateya herî berfireh a peyvê, tevî karên lênêrînê, xemilandin û ewlehiya xala firotanê.
• Xizmetên rewşenbîrî yên ji hêla şêwirmendan an ajansên kirrûbirrê ve têne peyda kirin, ku encamên wan kêmtir berbiçav in.

Ji bo verastkirina asta durustiya aliyên sêyemîn berî destpêkirina têkiliyek karsaziyê, nûkirin an berdewamkirina wê, pir girîng e ku meriv bi prosedûra nirxandina aliyê sêyemîn re tevbigerin.

Çi bikin:

• 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.
• Li gorî prosedûra nirxandina partiya sêyemîn a têkildar, yekparebûna dabînkeran binirxînin û heke di gumanê de bin, tavilê Berpirsê Etîk û Pabendbûnê yê xwe agahdar bikin.
• Hemû pabendbûn û encamên pêwîst di peymanekê de ku ji hêla kesekî destûrdar di nav DBI de ve hatî pejirandin fermî bikin.
• Pabendbûna me ya dijî-gendeliyê ji dabînkeran re, li her deverê ku ew lê ne, ragihînin.

Çi neyê kirin:

• 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.

Derewînê bedew û biçûk?

Example 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.

Example 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.

Example 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.

NASÎNA REWŞEKE RÎSKÊ BILIND
Dema ku em bi rewşek ku ji me re neasayî xuya dike, an jî em pê rehet nabin re rû bi rû dimînin, divê em van pirsan ji xwe bipirsin:

• 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?

RAPORKIRINA REWŞEKE FIKARAN

Em hemû berpirsiyar in ji ragihandina rewşên ku em bawer dikin li dijî vê Qanûna Dij-Gendeliyê ne. Çi em rasterast an nerasterast ji rastiyan agahdar bin, her gav çêtir e ku em gumanên xwe parve bikin da ku em bi hev re rêya çêtirîn ji bo parastina DBI û hemî karmendên wê bifikirin.

Em dikarin bi rêveberê xwe yê xetê, serokê çavkaniyên mirovan an jî Karmendê Pabendbûnê yê DBIyê re têkilî daynin. Ji bilî van kanalan, DBI xeta etîkê ji me re peyda dike ku ji xeta germ a telefonê û Navex, bernameyeke ragihandina sûcan a serhêl pêk tê. Navex dihêle ku hişyarî bi ewlehî û nepenî werin şandin, di heman demê de îhtîmala raporên anonîm peyda dike.
Hejmara telefonê: 08.05.22.31.59

Navex alert tool: EthicsPoint – DIM Brands International
DIM Brands International berpirsiyarê sîstemê ye û parastina agahderan li dijî her kiryar an gefên tolhildanê garantî dike, her çend gumanên li pişt agahderan xelet derkevin jî.

Prensîbên me

• 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.

Ji bo bêtir agahdarî
Ji bo bêtir agahdarî, pêşkêşkirina xeta etîkê bibînin.

FAQ

What is DBI's stance on corruption?

DBI has a zero-tolerance policy towards corruption and other breaches of probity. Employees are prohibited from engaging in any form of corruption or influence peddling.

What is DBI's stance on corruption?

DBI has a zero-tolerance policy towards corruption and other breaches of probity. Employees are prohibited from engaging in any form of corruption or influence peddling.

Belge / Çavkanî

Koda Dij-Gendeliyê ya DIMê [pdf] Rehbera bikaranînê Qanûna Dijî Gendeliyê, Qanûna Dijî Gendeliyê, Qanûna Gendeliyê, Qanûn

Çavkanî

• Manual Bikarhêner