Exertis Benelux Code of Conduct
INTRODUCTION
At Exertis, we aim to build successful long-term relationships with all our suppliers. We work continuously with you to ensure that your products are brought to market in the most effective way and that buyers of your products receive a high level of support.
We want to build this relationship on a sustainable basis, one that works in the long term for both you and us. Therefore, it is important that everything we do is not only commercially focused but also ethical and legal. This approach protects both your business and your reputation, as well as ours. We are committed to this approach across every area of our organization.
To help us with this, we have developed this Code of Conduct, which outlines the key ethical and legal standards that apply to the business we do together. Please take the necessary steps to comply with the standards outlined in this Code of Conduct, including sharing it with the relevant individuals within your organization.
By adhering to the standards in this Code of Conduct, we will develop a business relationship that is sustainable in the long term. Every individual who interacts with us, at any level of seniority, should feel free to raise concerns about whether these standards are being followed by Exertis.
If you have a concern, we would like to know. To the extent that it is legally possible, we will treat all reports confidentially. Please contact me directly or use our dedicated email address [email protected].
Tim Griffin
Managing Director
DCC Technology & Exertis Group
"BY FOLLOWING THE STANDARDS OF THIS CODE, WE CAN DEVELOP A BUSINESS RELATIONSHIP THAT IS SUSTAINABLE IN THE LONG TERM"
ABOUT US
Exertis is one of the largest and fastest-growing technology distribution and specialized services suppliers. Exertis is the trade name for the companies in the DCC Technology division, one of the four divisions within DCC PLC, a FTSE 100 organization. We are a global distributor of consumer, business, and enterprise products.
Exertis is a leader in technology distribution, driving innovation and adding value through our specialized services.
At Exertis, our core business is the distribution of products and services from the world's leading and emerging technology companies, approximately 2,400 of which are active. We are a key part of the channel that ensures the products and solutions of our suppliers reach businesses and consumers through our network of resellers and retailers.
01 Health & Safety
Principle
Ensuring the health and safety of everyone we deal with is fundamental to business performance and long-term business success. There is no task so important that you cannot choose to perform it safely.
What this means
- We will always support you when you choose to work safely.
- If anyone in your company believes that safety is at risk, they should feel empowered to intervene and stop the work.
- Our suppliers must comply with all applicable health and safety laws and regulations, providing a clean, safe, and healthy workplace designed to prevent accidents, injuries, and illness during work.
- Suppliers working at an Exertis location must work in a manner that (i) ensures their own safety and the safety of others, and (ii) complies with applicable health and safety requirements, including our policies and procedures.
- Suppliers must provide their employees, including new or reassigned employees, with regular and documented health and safety training.
- Any emergencies that may impact Exertis operations must be reported immediately.
- You will facilitate reasonable HSE inspections by us. You will also provide us with accurate HSE performance information when requested.
02 Employment
Principle
Exertis adheres to internationally recognized human rights standards, including the United Nations Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. We ask our suppliers to do the same.
What this means
In particular, you must ensure that your employees and other workers:
- are provided with a safe working environment;
- are paid fairly and on time for the work they do;
- are not subjected to any form of coercion by their employer, such as having to repay large loans or having their passports withheld;
- are not discriminated against based on gender, disability, religion, age, ethnicity, marital status, sexual orientation, or any other status protected by applicable law;
- are not subjected to any form of slavery; and
- are not younger than the legal minimum age for employment.
You must notify us immediately if at any time you are unable to meet these standards.
In many countries, national laws set standards that are at least as high as those contained in human rights standards. Where this is the case, national laws must be followed. However, when national laws do not provide an adequate level of protection, human rights standards must be followed. If there is a conflict between national laws and international human rights standards, we expect you to comply with national laws while also striving to protect human rights.
03 Environmental Protection
Principle
We expect you to comply with all laws and regulations that support the protection of the environment.
What this means
You will ensure that your activities are carried out in compliance with all applicable environmental laws and regulations, including:
- the use of natural resources such as water;
- the granting of permits for certain activities, storage, and emissions;
- the safe transportation of products;
- the reuse of packaging and other forms of waste; and
- carbon emissions.
You must comply with our environmental protection policies and procedures when working for Exertis, including in the case of spills or the release of products that impact the environment or third parties.
04 Bribery and Corruption
Principle
You will not engage in bribery or any other form of corrupt activity.
What this means
Bribery can occur when a person does not act in the best interests of the organization they represent because of a personal benefit they have received or expect to receive from a third party.
You will maintain and communicate an appropriate policy within your business that makes it clear that no employee of yours may offer, give, or accept bribes.
More specifically, gifts, hospitality, sponsorship, or other benefits that you offer or receive in connection with the work you do for Exertis should be modest and not intended to improperly influence the outcome of a decision.
05 Confidential Information
Principle
You will not improperly share or use confidential information that you should not have access to.
What this means
While we always want to stay informed about market developments, we do not want you to share confidential information with us that we should not have received. Nor should you share confidential information that you have about us with third parties.
If you accidentally send us confidential information that we should not have received, you must notify us immediately. And if you inadvertently share confidential information about Exertis with a third party, you must also notify us immediately.
06 Data Protection and Privacy
Principle
You will collect and use personal information carefully and in accordance with relevant data protection and privacy laws.
What this means
We may collect information about our employees, customers, or other individuals, and you may process that data on our behalf. When this is the case, you must always comply with relevant data protection and privacy laws and ensure that all employees handling that information understand that it must be used safely and for legitimate purposes. You must maintain appropriate IT and management controls to ensure that personal information is used correctly.
You must immediately notify us of any incidents – such as a data security breach – involving information you process on our behalf.
07 Competition Law (Antitrust)
Principle
You will take all reasonable steps to ensure that you are fully compliant with applicable competition law (also known as antitrust law).
What this means
You acknowledge that Exertis will always act independently in making its commercial decisions.
As stated in Article 5, you may not share confidential information about us with any of our competitors, nor may you share any confidential information you have about our competitors with us.
It is illegal for us to agree with you on the price at which we will sell your products or to have an agreement or arrangement that sets a floor under the prices at which we sell them.
The same applies to our customers. It is illegal for us to tell them at what price they must sell your products or to require or encourage them to keep their prices above a certain level.
You will ensure that you provide appropriate training to the relevant employees within your company about applicable competition laws.
08 Compliance with Taxation Laws
Principle
You will not engage in or facilitate the deliberate underpayment of taxes owed.
What this means
You will accurately declare all income and be transparent with the tax authorities regarding your transactions. You will take reasonable steps to prevent your employees, contractors, or representatives from facilitating tax evasion by third parties.
You will immediately notify us if you have concerns regarding the actions of your employees, contractors, or representatives in relation to your transactions with Exertis, or if you suspect that another party in our supply chain may have engaged in tax evasion.
09 Intellectual Property
Principle
You will not sell products or provide services that intentionally or clearly infringe on the intellectual property rights of third parties.
What this means
You will respect the intellectual property rights of third parties by only using trademarks, designs, and technology that have been lawfully obtained and for which a license has been granted.
10 Product Safety & Quality
Principle
We respect the rights of consumers of the products we sell. Every product you sell to us must be safe, meet the relevant standards, and be accompanied by the legally required product information.
What this means
You must ensure that every product you sell to us is safe for its intended purpose and complies with all relevant standards for that product. You will provide or make available relevant product safety documentation as legally required. You must also immediately notify us if you suspect that a product is unsafe or does not meet the relevant standards for that product.
If applicable, you will make efforts to address customer concerns regarding the products you sell to us in a satisfactory manner.
11 Export Controls and Sanctions
Principle
You will strictly comply with and without exception conduct your business in accordance with all applicable laws and regulations regarding export control, sanctions, and embargoes.
Some governments impose restrictions on products (including their components, materials, designs, and technology) and may prohibit the delivery of controlled products to certain recipients and users or make it subject to a license. They may also enforce restrictions on doing business with certain countries, industry sectors, organizations, or individuals.
You will carry out appropriate controls to ensure that the products—whether hardware, software, information, or services—that you sell comply with applicable export control and sanction laws.
You must advise us and provide the export control classification information, along with supporting documentation and/or copies of applicable licenses or exemptions if any of the products you sell are classified as dual-use products or otherwise subject to export control restrictions.
12 Conflict Minerals
Principle
We will not sell products that contain restricted "conflict minerals."
What this means
The US and the EU have passed laws that restrict the use of minerals from conflict-affected countries and regions. We rely on you to ensure that the products we purchase from you do not contain conflict minerals and, in particular, comply with the requirements of US and EU legislation in this regard.
You must perform and document appropriate and ongoing due diligence in your own supply chain to ensure that conflict minerals are not used or introduced. You must make evidence of your due diligence available to us upon request, and you must immediately notify us of any violations you become aware of.
13 Compliance
Principle
You have appropriate internal policies and procedures in place to cover your legal and ethical obligations, including the areas addressed in this code of conduct. You will ensure that you maintain adequate, accurate, and secure records to demonstrate your compliance with the code.
What this means
We expect you to have a suitable set of internal controls in place to ensure compliance with the standards contained in this code. These control mechanisms must be supported by clear leadership on ethical and compliance issues from senior personnel in your company.
Maintaining records of your internal controls, such as risk assessments, policy statements, training, and other internal communications, is important as it allows you to demonstrate that you have carried out those controls should issues arise in the future.
Just as we communicate with you about the topics covered in this Code, it is your responsibility to communicate your policies on these topics to your suppliers, representatives, and other third parties involved in your business.
We will take appropriate action when a supplier fails to comply with the standards outlined in this Code of Conduct. This may include not placing further orders and terminating our agreement.