Kode Anti Korupsi
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Informasi produk
Spesifikasi:
- Brand: DIM Brands International
- Versi: 1 - 2025
- Anti-Corruption Code
Pandhuan Panggunaan Produk
Using the Anti-Corruption Code:
The DIM Brands International Anti-Corruption Code is designed to
ensure that all employees, partners, and collaborators adhere to
the values of integrity, transparency, and fairness. It is
essential to understand and implement this code in all day-to-day
activities to uphold the company’s commitment to fighting
korupsi.
Understanding the Legal Framework:
It is crucial to familiarize yourself with the legal framework
surrounding corruption, influence peddling, facilitation payments,
gifts and hospitality, conflicts of interest, lobbying,
sponsorship, patronage, donations, and relations with public
authorities and officials. Understanding these concepts will help
you identify and avoid potential risks.
Reporting a Worrying Situation:
If you encounter any situations that raise concerns related to
corruption or unethical behavior, it is important to report them
promptly. Reporting such instances can help uphold DBI’s values and
prevent any potential harm to the company’s reputation.
FAQ
What is the scope of application of the Anti-Corruption
Kode?
The Anti-Corruption Code applies to all DBI employees,
directors, officers, permanent and temporary staff, apprentices,
trainees, as well as suppliers, customers, and partners in all
countries where the Group operates.
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.
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DIM Brands International Anti-Corruption Code
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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.
DBI therefore undertakes to prohibit and punish any inappropriate behaviour by its managers, employees, external and occasional collaborators such as temporary staff and consultants within all companies belonging to DBI, both in France and abroad (hereinafter the “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 anticorruption 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, Chairman
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DAFTAR ISI
RELATIONS WITH THIRD PARTIES
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OUR COMMITMENT AND PRINCIPLES IN THE FIGHT AGAINST
RECOGNISING A HIGH-RISK SITUATION
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KORUPSI
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REPORTING A WORRYING SITUATION
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RUPA APLIKASI
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USING THE ANTI-CORRUPTION CODE
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UNDERSTANDING THE LEGAL FRAMEWORK
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WHAT IS CORRUPTION ?
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WHAT IS INFLUENCE PEDDLING?
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PEMBAYARAN FASILITASI
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GIFTS AND HOSPITALITY
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KONFLIK KEPENTINGAN
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LOBBYING
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SPONSORSHIP, PATRONAGE AND DONATIONS
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RELATIONS WITH PUBLIC AUTHORITIES AND OFFICIALS
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OUR COMMITMENT AND PRINCIPLES IN THE FIGHT AGAINST
KORUPSI
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. Similarly, we never engage in bribery or accept kickbacks from public officials or private parties.
· 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 includes all companies directly or indirectly controlled by DBI Lux Holdings SARL.
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· 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. Intranet link: Ethics & Compliance Page
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RUPA APLIKASI
This Anti-Corruption Code (hereinafter “the Code”) applies to all DBI employees, including directors, officers, permanent and temporary staff, apprentices and trainees. It also applies to DBI’s suppliers, customers and partners in all countries in which the Group is present (hereinafter collectively referred to as “partners”). The Anti-Bribery Code will come into force 1 month after its communication to the Works Social Committee (WSC).
USING THE ANTI-CORRUPTION CODE
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.
The Code sets out DBI’s commitments to combating corruption and helps to disseminate our ethical culture. It:
· Explains what corruption is; · Provides 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.
Given the diversity of situations in which corruption occurs, this Code cannot be exhaustive. Nevertheless, it a practical tool to help you make the decision best suited to the circumstances. If in doubt, contact your line manager or Compliance Officer.
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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
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UNDERSTANDING THE LEGAL FRAMEWORK
All DIM Brands International companies, in France and abroad, must comply with the French law on transparency, combating corruption and modernisation of business practice (known as the “Sapin 2” law), as well as other anti-corruption laws and appliable regulations. The majority of these laws have extraterritorial application, which means that, for example, 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.
The 8 pillars of our anticorruption programme
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
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WHAT IS CORRUPTION ?
Corruption is the act of promising, giving, soliciting or accepting – directly or indirectly – “a thing of value” in order to obtain an “undue advantage”.
Corruption can be active or passive:
Active corruption occurs where a person offers or gives a thing of value in exchange for an undue advantage.
Passive corruption occurs where a person solicits or accepts a thing of value in return for an undue advantage or agrees to use their influence.
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.
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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
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WHAT IS INFLUENCE PEDDLING?
Influence peddling concerns relations with public officials. It refers to the use by a person of his or her position or influence, real or supposed, to influence a decision ultimately made by a public official.
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.
This practice is formally prohibited for all employees. Furthermore, in order to guarantee the highest levels of ethics, DBI has adopted a broad definition of influence peddling and extends the prohibition to its relations with private parties.
What should I do? Influence peddling involving a public official: Situation 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
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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.
Our principles: 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.
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If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com
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PEMBAYARAN FASILITASI
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.
What should I do? 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
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GIFTS AND HOSPITALITY
Offering a gift or inviting a business partner can help to build a good business relationship. These are ordinary acts of business life and do not, as such, constitute acts of corruption. However, when the purpose of the gift or hospitality is to influence the performance or non-performance of an act by a person in breach of their legal, contractual or professional obligations, this constitutes an act of corruption.
Thus, if the value or frequency of gifts and hospitality is excessive, or if they are offered in order to obtain a favour or influence a decision, they may be perceived as an attempt at corruption and expose DBI and its employees to heavy criminal and civil penalties. We must therefore exercise caution and always act transparently.
All DBI employees must comply with our gifts and hospitality policy defined below:
Gifts are things of value, goods or services offered or received by a DBI employee, as well as entertainment offered or received which is not attended by the person inviting.
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.
Hospitality refers to meals, services, refreshments, travel, accommodation and entertainment directly related to business discussions or events attended by the person extending the invitation. For example, following a business conference, if you offer a business partner a ticket to a sporting
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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.
What to do: 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.
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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.
What should I do? 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 advantages or practices that could be perceived as inappropriate.
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.
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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
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KONFLIK KEPENTINGAN
A conflict of interest arises when our personal interests interfere or may appear to interfere with our ability to make a decision based strictly on merit and in the best interests of DBI. We pledge to always act transparently in the best interests of DBI, and never to allow our decisions to be motivated by personal interests.
What to do: 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.
What not to do: 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.
Aku kudu piye?
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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 champion. Your friend asks you if DBI could sponsor his daughter so that she can take part in the 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.
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.
If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com
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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.
What should I do? 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
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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. If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com
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SPONSORSHIP, PATRONAGE AND DONATIONS
Sponsorship is part of a commercial approach. It is a communication technique that involves providing financial, material or human support to a person, event or organisation in exchange for advertising benefits. Patronage and donations, on the other hand, do not involve any counterpart on the part of the beneficiary.
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 in the context of corruption and fraudulent schemes. Sponsorship and patronage operations therefore entail a criminal, financial and reputational risk for DBI.
What to do 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.
What not to do 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.
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What should I do 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. If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com
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RELATIONS WITH PUBLIC AUTHORITIES AND OFFICIALS
In most countries, the law treats offences committed with people in the private sector differently from those with public officials. The latter are punished more severely. Convictions can lead to the withdrawal of a licence to practice, heavy fines and publication of sanctions damaging our reputation.
We must therefore be all the more attentive and exercise the utmost caution when interacting with public representatives or members of their families. The definition of public representative is broad, so it is important to familiarise yourself with the concept:
Public officials
Agent of a government, foreign or national,
Agent of a government organisation ;
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
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What to do: 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.
What not to do: 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.
What should I do? 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
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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.
If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com
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RELATIONS WITH THIRD PARTIES
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.
Certain business sectors are known to be rife with prohibited practices, so we need to be particularly vigilant. This is the case, for example, with:
The construction sector in the broadest sense of the term, including maintenance work, decoration and point-of-sale security
Intellectual services provided by consultants or marketing agencies, whose deliverables are less tangible.
It is essential to comply with the third-party assessment procedure in order to verify the level of integrity of third parties before entering into, renewing or continuing any business relationship.
What to do: 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.
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Assess the integrity of suppliers in accordance with the applicable third-party assessment procedure and inform your Ethics and Compliance Officer immediately if in doubt.
Formalise all commitments and deliverables in a contract approved by an authorised person within DBI.
Communicate our anti-corruption commitment to suppliers, wherever they are located.
What not to do: 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.
What should I do? 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
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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.
If you have any questions, please contact the Group Compliance Officer at the following email address: DBI.Compliance@dim.com
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RECOGNISING A HIGH-RISK SITUATION
When we are faced with a situation that seems abnormal to us, or with which we are not at ease, we should ask ourselves the following questions:
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?
REPORTING A WORRYING SITUATION
We are all responsible for reporting situations that we believe are contrary to this Anti-Corruption Code. Whether we have direct or indirect knowledge of the facts, it is always preferable to share our doubts so that together we can consider the best way to protect DBI and all its employees.
We can contact our line manager, the head of human resources or DBI’s Compliance Officer. In addition to these channels, DBI provides us with an ethics line comprising a telephone hotline and Navex, an online whistleblowing programme. Navex allows alerts to be submitted securely and confidentially, while offering the possibility of anonymous reporting.
Telephone number: 08.05.22.31.59 Navex alert tool: EthicsPoint – DIM Brands International
DIM Brands International is responsible for the system and guarantees the protection of whistleblowers against any act or threat of reprisals, even if the suspicions behind the whistleblowing turn out to be wrong
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Our principles
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
ngrungokake.
To find out more
To find out more, see the presentation of the ethics line.
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Dokumen / Sumber Daya
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DIM Anti Corruption Code [pdf] Pandhuan pangguna Anti Corruption Code, Anti Corruption Code, Corruption Code, Code |