Company Policy

Compliance / Code of conduct

DAKO WORLDWIDE TRANSPORT GmbH is an international forwarding logistic and transport company specialized in the transportation of industrial investment goods including heavy and bulky machinery and equipment up to complete industrial plants such as cement factories, power plants, iron & steel plants, petrochemical plants and oil & gas equipment etc. on a worldwide basis. This includes local transport in the country of destination up to construction site and if required, delivery on foundation. DAKO WORLDWIDE with its head office in Düsseldorf / Germany works on an international basis for clients in Europe and overseas.

DAKO WORLDWIDE TRANSPORT GmbH forms part through its major partner VNMO Speditionsgesellschaft mbH of the DACOTRANS INTERNATIONAL S.A. Group, with head office in Luxemburg, as holding company and counts on about 25 sister and daughter companies in the following areas:

• North, Central and South America
• Near / Middle East
• Central and Eastern Europe, Russia, Ukraine
• Asia, India, Pakistan
• North and West Africa

The management, the employees and the partners of DAKO WORLDWIDE TRANSPORT GmbH strictly abide by compliance rules and a Code of Conduct which defines the basic requirements of the company as well as suppliers of services. DAKO WORLDWIDE TRANSPORT GmbH herewith declares:

Compliance standards

DAKO WORLDWIDE´s compliance standards are operated as compliance at all levels of DAKO WORLDWIDE´s activities. The corporate policies – Code of Ethics and Compliance (CoEC) and the Anti-Corruption Compliance Policy (ACCP) are basis of our activities. These corporate regulations are mandatory for all DAKO branches worldwide including sister companies, employees, agents and subcontractors.

Compliance systems

The CoEC and ACCP meet or exceed the legal requirements stipulated in the following acts, among others, and are regularly updated:

• Foreign Corrupt Practices act (USA)
• UK Bribery Act 2010

DAKO WORLDWIDE´s management, partners and employees regularly take part in compliance training sessions which are provided in writing respectively face to face in special sessions, subject to the individual risk level.

Business relationship

DAKO WORLDWIDE expects business partners to observe the fact that openness and transparency are keys to a trustworthy business practice. This means to observe the following principles:

• Avoid conflicts of interest
  DAKO WORLDWIDE and their partners make decisions based solely on objective criteria and do not allow themselves to be guided by personal interests and relationships.
• Prohibition of corruption
  DAKO WORLDWIDE partners and employees do not tolerate corruption. They insure that their employees, subcontractors and partners do not grant, offer or accept any bribes, kickbacks, inadmissible donations or other inadmissible payments or benefits to or by customers, officials or other third parties. This also applies to payments to accelerate administration matters.
• Invitations and gifts
  DAKO WORLDWIDE does not tolerate that any business partners, suppliers and agents offer any form of invitations or gifts which must be considered as inappropriate benefits to unduly influence decisions. Neither do they ask for nor accept such benefits.
• Corporation with authorities
  DAKO WORLDWIDE and their management and employees are not allowed to offer any part of bribery or facilitations to any official agent or government employee.
• Agents
  Cooperation with agents can only be in line with the laws in force in the country the business is taking place.

Fair behavior in the market

DAKO WORLDWIDE is a fair and responsible participant in the international logistic market and lives up to its contractual obligations. DAKO WORLDWIDE expects the same from its business partners and especially expects the observation of the following principles:

• Free competition
  DAKO WORLDWIDE complies with the applicable antitrust legislation, especially DAKO WORLDWIDE does not enter into any anti-competitive agreements with competitors, suppliers or customers.
• Restricted articles
  DAKO WORLDWIDE will make sure that they comply with all applicable legal provisions for exporting and importing goods (especially dual use), services and information.

Anti-Money Laundering

• DAKO WORLDWIDE only conducts business relationships with business partners of whose integrity DAKO WORLDWIDE is convinced. They insure that the applicable legal money laundering provisions are observed.

Assets and business secrets

• Confidential data, business secrets and company assets must be protected. DAKO WORLDWIDE expects business partners to especially observe the following principles:
• Know-how, patents, trade and business secrets
  DAKO WORLDWIDE and their business partners respect the know-how, patents, trade and business secrets of third parties as well as those of DAKO WORLDWIDE. This is understood without any explicit prior written consent.
• Managers, employees, partners and business partners of DAKO WORLDWIDE observe all laws in force to protect the personal data of customers, suppliers, employees and other parties concerned.

Legal compliance

Managers, employees, partners and business partners of DAKO WORLDWIDE

• comply with the laws of the applicable legal system(s).

Respect for the basic human rights of employees

Managers, employees, partners and business partners of DAKO WORLDWIDE

• promote equal opportunities for and treatment of its employees irrespective of skin color, race, nationality, social background, disabilities, sexual orientation, political or religious conviction, sex or age;
• respect the personal dignity, privacy and rights of each individual;
• refuse to employ or make anyone work against his will;
• refuse to tolerate any unacceptable treatment of employees, such as mental cruelty, sexual harassment or discrimination;
• prohibit behavior including gestures, language and physical contact, that is sexual, coercive, threatening, abusive or exploitative;
• provide fair remuneration and guarantee the applicable national statutory minimum wage;
• comply with the maximum number of working hours laid down in the applicable laws;
• recognize, as far as legally possible, the right of free association of employees and to neither favor nor discriminate against members of employee organizations or trade unions.

Prohibition of child labor

Managers, employees, partners and business partners of DAKO WORLDWIDE

• employ no workers under the age of 15 or, in those countries subject to the developing country exception of the ILO Convention 138, to employ no workers under the age of 14.

Health and safety of employees

Managers, employees, partners and business partners of DAKO WORLDWIDE

• take responsibility for the health and safety of its employees;
• control hazards and take the best reasonably possible precautionary measures against accidents and occupational diseases;
• provide training and ensure that employees are educated in health and safety issues;
• set up or use a reasonable occupational health & safety management system.

Environmental protection

Managers, employees, partners and business partners of DAKO WORLDWIDE

• act in accordance with the applicable statutory and international standards regarding environmental protection;
• minimize environmental pollution and make continuous improvements in environmental protection;
• set up or use a reasonable environmental management system.

Supply chain

Managers, employees, partners and business partners of DAKO WORLDWIDE

• use reasonable efforts to promote among its suppliers compliance with this Code of Conduct;
• comply with the principles of non-discrimination with regard to supplier selection and treatment.

All managers, employees, business partners and partners of DAKO WORLDWIDE are required to acknowledge receipt of this Code of Conduct as well as any amendments of this Code of Conduct if this is delivered.

If a question arises as to whether any action complies with DAKO WORLDWIDE policies or applicable laws, you should present this question directly to the below mentioned party. All managers, employees and partners have the commitment of DAKO WORLDWIDE that these persons will be protected from retaliation. However, DAKO WORLDWIDE reserves the right to discipline anyone who knowingly makes a false accusation or provides false information.

Any violation or non-compliance with the Code of Conduct must be immediately reported. Reports should contain as much specific information as possible to allow for proper assessment. Any violation of the Code may result in disciplinary action.

The report can be either made to the compliance officer as mentioned below or to the supervisory board of DAKO WORLDWIDE TRANSPORT.

Contact Compliance Officer
Name: Ralf Grosskopf
Title: (Senior Project Manager)
Phone: +49 / 211 / 55026410
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Düsseldorf, 15th of August 2016