Our responsibilities

Our responsibilities

We respect the laws and regulations (both national and international) applicable in the countries in which we operate.

It is important to understand and adhere to the laws of the country you are working in. Please make sure that you are in close contact with your local management or legal department if you need any support. If local laws or regulations conflict with Dutch laws or this Code of Conduct you need to find the solution by talking with (higher) Draka management or in collaborating with the Compliance Officer.

For more information on this issue, please refer to your local management or to the Compliance Officer.

We deal fairly, respecting the rights of employees, governments, customers, suppliers and competitors.

As Draka we do not want you to take unfair advantage of anyone through improper behaviour like manipulation, misrepresentation, concealment or any other malpractice. Therefore it is vital that we are honest to our clients and keep our promises to them. Clients must never be misinformed about our products.

In dealing with suppliers we only have contact with suppliers who comply with our company policies and the law.

At Draka we promote (fair) competition and comply with “fair competition” and antitrust laws. We will avoid contacts with competitors, suppliers, government agencies and other parties that are, or appear to be, engaging in unfair competition or the restriction of free trade and free competition. We will neither discuss prices or territories with competitors nor will we accept bribes.

Relations with governments and other companies should be honest and fair, and should not be corrupted by improper payments. Therefore, we don’t pay bribes.

We do not accept any kind of sexual, racial or other harassment. This includes all improper behaviour that is violent, disrespectful, abusive or humiliating.

At Draka we do not tolerate improper personal behaviour. When behaviour creates an intimidating, hostile or offensive working environment it is not accepted and will be sanctioned. Improper behaviour includes belittling subordinates or co-workers, derogatory comments, and grave insults. Management has a specific role to prevent harassment on the working place and to report this to HR.

For more information on this issue, please refer to your HR-policy (if available) or to your local management.

We respect and safeguard Human Rights.

Draka respects and safeguards fundamental Human Rights in its operations, as provided by the United Nations’ Universal Declaration of Human Rights. All use of bonded or child labour is not tolerated and we do not co-operate with suppliers or sub-contractors who are accessory to an infringement of such Human Rights.

We are committed to providing a safe and healthy work environment for all Draka employees.

It is our shared responsibility that we all look after health and safety within the organization. Employees will refrain from using or distributing alcohol or drugs when reporting for work, while working, or while on the company’s premises.
There is no excuse for not following obligatory safety procedures. Draka safety procedures should always meet the standards set by law.

Our books and records are kept, maintained and audited in accordance with internationally recognized professional standards.

You are responsible to be accurate in the records that you help create or maintain, including expense accounts, financial records or any other official Draka document. You are not allowed to include any false or misleading information in business records.

Draka is a listed company and therefore we are obliged to follow strict procedures for the release of company information to the public to prevent insider trading. When communicating company information externally you must always be in close contact with the legal department and the communication department, especially when responding to questions from the media.

In the course of your employment with Draka, you may become aware of information about Draka or other companies that is not known by the general public. The use of such non- public information (or inside information) is not only unethical but also forbidden by law. You are not allowed to use inside information on the stock market for your own financial interest or that of others.

For more information on this issue, please refer to the Financial Accounting Policy, the Audit Policy and/or Regulations on the holding of and effecting transactions in shares(if available or applicable) or to your local management.

We protect the assets and respect the property rights of the company, customers and other employees.

Draka holds the property rights for objects, literature and product characteristics (patents, copyrights, and trademarks). You should only use company resources for legitimate business purposes. Company assets should be used in a way that is compliant with the company’s policies.

For more information on this issue, please refer to your HR-Policy (if available) or to your local management.

We avoid conflict of interest or an appearance of conflict that might arise because of economic or personal self-interest.

A conflict of interest occurs when you or someone close in your private life, has a personal interest that conflicts with the business interest of Draka. As a Draka employee your primary business activity should be in line with the goals of Draka. A conflict of interest should be made known to your manager, who will give guidance on how to deal with this.

For more information on this issue, please refer to your local management or to the Compliance Officer.

Political activities must be undertaken as a private individual not as a Draka employee.

If you are engaged in political activities you must do so as a private individual and ensure that your personal views are not represented or perceived as the views of Draka.

Providing or authorizing, on behalf of Draka, payments, contributions or free use of company facilities, either directly or indirectly, to any politician, political party or organization, or candidate for public office, is not allowed.
Draka will withhold itself from political activities. However, Draka will have the right to make its opinions known to political representatives.

For more information on this issue, please refer to your local management or the Compliance Officer.

We only provide and accept appropriate business gifts.

In some cultures it is custom to present a business gift. At Draka we want to limit this custom as much as possible. Therefore Draka employees may only give and accept appropriate business gifts. A gift should never influence your judgment or the judgment of a gift recipient.

To help you maintaining this responsibility, it is recommended that when you give a business gift, you should always give something with the Draka logo on it. That way the gift is transparent for everyone.

For more information on this issue, please refer to your local management or the Compliance Officer.

Compliance

The Board of Management is responsible to disseminate this Code of Conduct throughout the organization and provide processes and procedures to ensure compliance. To this end, the Board of Management will:

Nominate a Compliance Officer for the organization who will ensure that:

• Management will certify that all employees have read and are in compliance with this Code on an annual basis.


• Violations of the Code are investigated rigorously and without bias.


• Appropriate action will be taken when violations occur.


• All Draka employees are encouraged and are provided with channels to provide information on violations.


• Violations and actions are communicated to the Board of Management.

All employees are required to take notice of this Code of Conduct and its underlying policies.

Every employee is responsible for being compliant with the Draka Code of Conduct and policies.

Every manager has to take care that their employees are compliant with the Code of Conduct and the underlying policies.

Non- compliance with (parts of) this Code of Conduct and the underlying policies can lead to disciplinary actions or dismissal.