1.1
In DFDS A/S Group Procurement we are committed to pursuing a responsible and sustainable approach to
procurement, based on recognized global standards such as ISO and HSE standards and the universally
recognized ten principles of the United Nations Global Compact relative to Human Rights, Labour,
Environment, Anti-corruption, Health & Safety, Anti Human Trafficking, UK Anti Bribery, Modern Slavery,
Anti Money Laundering, Export Control, US/UN/EU member states/UK Global Sanctions, the EU Privacy
Directive (GDPR) and general business ethnics and on a strict and continuous observance of national and
international rules (hereinafter the “Rules”).
1.2
As our suppliers are an extension of our business, we may cause adverse impacts through our purchasing
practices too; thus, DFDS A/S expects all our suppliers to meet the expectations set forth in this Supplier
Code of Conduct (the “SCoC”). Failure to establish systems to manage impacts on these four areas of
fundamental responsibility may impact our suppliers’ ability to do business with DFDS A/S in the future.
1.3
The terms of this SCoC apply to first-tier suppliers, parent, subsidiary or affiliate entities, as well as all
others with whom they do business, including, suppliers, subcontractors, joint venture partners and other
third parties. It shall be suppliers’ responsibility to ensure that their business relationships also have
processes to manage their adverse impacts on the Rules.
1.4
In the case of business relationships such as non-controlled joint ventures partnerships, etc., we endeavour
to engage with such business partners to influence the implementation of principles and standards of this
SCoC towards mitigating sustainability risks in supply chains.
2.1
This SCoC sets the minimum expectations from suppliers and is based on our commitment to recognized
global standards such as ISO and HSE standards and to the United Nations Global Compact’s principles,
as derived from the International Bill of Human Rights, International Labour Organisation’s Declaration on
Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and
the United Nations Convention Against Corruption, and made operational by the United Nations Guiding
Principles on Business and Human Rights.
2.2
DFDS A/S expects suppliers to adhere to applicable laws of their areas of operation. Where national laws
provide for better or lesser protection of the Rules, the higher standard shall apply. Where there is a
conflict between national law and the provisions of this SCoC, the supplier shall report this to DFDS A/S
and try - to the extent possible - to honour the SCoC’s provisions while adhering to national regulation.
2.3
Our suppliers are required to acknowledge and commit to the adherence of responsible business principles
of the SCoC. We assess our suppliers’ compliance with the SCoC through a combination of audits, self-
assessments and documentation reviews. Conducted directly or through our partners within our Responsible
Procurement Programme. Suppliers are expected to cooperate in answering questions and to fully
collaborate with DFDS A/S in improving their systems of managing adverse impacts on the Rules. Suppliers
should address any gaps in the implementation of this SCoC by establishing and implementing a time-
bound improvement plan in consultation with DFDS. Periodic reviews and follow-up audits as per our
internal procedures can be conducted to monitor the compliance levels.
2.4
We expect suppliers to adopt a policy statement that is fully committed to the international principles and
standards set forth in this SCoC. The policy statement shall be approved by the suppliers’ senior
management and made publicly available. It shall stipulate expectations regarding the Rules from
personnel, business partners and other parties directly linked to suppliers’ operations, products and/or
services.
2.5
We expect and encourage our suppliers to develop and implement relevant management systems,
appropriate for a company of their size and industry to ensure compliance with applicable laws and
regulations and the requirements of the SCoC. As we are aware that the establishment of such processes
takes time and resources, we are open to collaborate with our suppliers, share knowledge and experience,
and ensure that our purchasing practices do not negatively impact their abilities to meet the requirements
of the SCoC.
3.1
The Due Diligence Process
We expect suppliers to establish a process of continuous due diligence in relation to their actual and
potential adverse impacts on the Rules. The process shall:
a) regularly assess potential and actual impacts on the areas of fundamental responsibility,
b) integrate impact assessment findings across relevant internal processes and functions, so as to ensure
the prevention and mitigation of identified adverse impacts; and
c) account for and report to DFDS A/S how impacts are being addressed.
3.2
Reporting System
a) We expect our suppliers to have a reporting system to ensure that employees can voice grievances
anonymously and without fear of reprisals on any aspect of this SCoC. All grievances should be
investigated in a fair and timely manner.
b) We expect that suppliers account for and report to DFDS any relevant impact or breach to the SCoC.
c) We also welcome anyone within or outside of DFDS to report any potential or actual violations of this
SCoC. We do not tolerate retaliation against persons making reports in good faith. Concerns can be
reported directly to DFDS representative or managers or through the DFDS whistleblowing system.
3.3
Actions
The objective of this SCoC is to establish a basis for positive development of responsible procurement
practices through regular dialogues and ongoing working relationships. However, in the incident of material
breach of the SCoC, we reserve the right to take actions up to termination of contracts or in severe cases, to
take legal actions against any first-tier suppliers, parent, subsidiary or affiliate entities, as well as all
others with whom they do business, including, suppliers, subcontractors, joint venture partners and other
third parties.
3.3.1 If a supplier discovers or is informed that it causes or contributes to an adverse impact, the supplier shall
enable access to remedy through legitimate processes for those affected and/or inform the relevant
authorities. The remediation process must be legitimate, accessible, predictable, equitable, transparent,
aligned with international principles, continually updated and based around dialogue.
3.3.2 If a supplier did not cause nor contribute to an adverse impact, but is linked to it through its value chain,
the supplier shall use its leverage to make the causing entity prevent reoccurrence, provide remedy for
those affected and inform the relevant authorities.
4.1
Health & Safety
Suppliers are expected to provide a safe, secure, and healthy working environment for all of their workforce.
Suppliers are expected to:
- ensure that all employees are aware of their rights and responsibilities regarding health and safety;
- provide necessary training and equipment to prevent accidents and injuries;
- report all incidents and near misses to the relevant authorities;
- investigate and address all incidents and near misses;
- ensure that all employees are aware of the emergency procedures and protocols in place;
- ensure that all employees are aware of the procedures for reporting incidents and near misses.
4.2
Environmental Principles
Suppliers should establish processes that cover all impacts on the external environment, as stated in the
Rio Declaration on Environment and Development. Emergency procedures to prevent and mitigate
environmental impacts should be in place. Suppliers should:
- reduce, reuse and recycle waste;
- minimize the use of hazardous substances;
- ensure that all employees are aware of their responsibilities regarding environmental protection;
- provide necessary training and equipment to prevent environmental impacts;
- report all environmental incidents and near misses to the relevant authorities;
- investigate and address all environmental incidents and near misses;
- ensure that all employees are aware of the emergency procedures and protocols in place;
- ensure that all employees are aware of the procedures for reporting environmental incidents and near misses.
4.3
Labour Principles
Suppliers should establish processes that cover all impacts on labour, as stated in the International Bill of
Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and
Rights at Work. Suppliers should:
- respect the rights of all employees to freedom of association and collective bargaining;
- ensure that all employees are aware of their rights and responsibilities regarding labour;
- provide necessary training and equipment to prevent labour-related incidents;
- report all labour-related incidents and near misses to the relevant authorities;
- investigate and address all labour-related incidents and near misses;
- ensure that all employees are aware of the emergency procedures and protocols in place;
- ensure that all employees are aware of the procedures for reporting labour-related incidents and near misses.
4.4
Human Rights
Suppliers should establish processes that cover all impacts on human rights, as stated in the International Bill
of Human Rights. Suppliers should:
- respect the rights of all individuals to freedom from discrimination and harassment;
- ensure that all employees are aware of their rights and responsibilities regarding human rights;
- provide necessary training and equipment to prevent human rights-related incidents;
- report all human rights-related incidents and near misses to the relevant authorities;
- investigate and address all human rights-related incidents and near misses;
- ensure that all employees are aware of the emergency procedures and protocols in place;
- ensure that all employees are aware of the procedures for reporting human rights-related incidents and near misses.
4.5
Anti-Corruption
Suppliers should establish processes that cover all impacts on anti-corruption, as stated in the United
Nations Convention Against Corruption. Suppliers should:
- prevent and detect corruption in all its forms;
