Ethics and Compliance
DCC seeks to achieve the highest standards of business ethics and compliance in all our activities. Ensuring that these standards are met is the responsibility of the leadership team in each business in the Group. They are supported in this regard by a central Group Compliance function and, in our Energy and Technology divisions, by dedicated compliance personnel.
The key message of the Group compliance programme is that directors, managers and employees across the Group should be ‘Doing the Right Thing’ at all times. This means not merely following the laws and policies that apply to their work, but also exercising good judgement to ensure that their actions are seen as fair and ethical.
Business Conduct Guidelines
Our Group Business Conduct Guidelines set out the general standards that are expected of directors, managers and employees across the Group in a range of areas, including anti-bribery and corruption, protection of personal information and competition law. The Guidelines are available in all of the major languages used by employees of the Group. A copy of the Guidelines has been provided to every employee.
Compliance Policies and Training
The Group also maintains more detailed policies on a range of relevant areas, complementing the general requirements set out in the Business Conduct Guidelines. The areas covered by more detailed policies include health and safety, anti-bribery and corruption, competition law, information security, diversity and equal opportunities and share dealing. Depending on the nature of their role, employees of the Group receive more detailed training on those policies.
Having reviewed and updated our Business Conduct Guidelines during 2014, we updated other key compliance policies in 2015 to ensure they accurately reflect the activities of the Group, current regulatory requirements and best practice.
Employees across the Group are required to raise a concern if any of our activities are being undertaken in a manner that may not be legal or ethical, and are supported if they do so. Concerns can be raised with a member of management in the business where the employee works, with the Head of Group Legal & Compliance or externally with SafeCall, a third party facility independent of DCC and available in multiple languages and on a 24 hour basis. Employees may raise concerns anonymously if they wish. Our internal policies make clear that retaliation against any employee who raises a concern is prohibited. Where concerns are raised, they are investigated in an appropriate and independent manner.
The Audit Committee has oversight responsibility for our whistleblowing facilities and how they operate.
World’s Most Ethical Certification
Following an application made in late 2015, DCC was again recognised by Ethisphere as one of the World’s Most Ethical Companies for 2016. This certification reflects our commitment to high standards of business conduct and how that commitment is translated into practice through our compliance policies and procedures.