Code of Conduct

Introduction

All DigiHaul colleagues, managers and Board Members are called on to breathe life into our Code of Conduct and thus contribute to the success of our company:

• Familiarise yourself with our Core Values and Standards.
• Remain up to date with our policies through training.
• Be engaged and report any violations.
• Act as a role model for integrity and respect.

Board members and Senior Managers in particular have a special role to play in implementing the Code of Conduct:

• Create a culture characterised by mutual respect, openness and trust.
• Do everything you can to promote the implementation of the Code of Conduct.
• Ensure that colleagues under your supervision comply with the Code of Conduct and act as a role model of these values in your daily work.
• Inform and advise your team about the standards and values set out in the Code of Conduct.
• Provide opportunities for others to voice concerns openly and directly.

When confronted with a challenging situation, consider these questions in regard to your conduct:

1. Is my action or decision legal?
2. Does it comply with the values and standards of this Code of Conduct and other DPDHL Group policies?
3. Is it free of personal conflicts of interest?
4. Could my action or decision withstand public review? What would it look like in the Media?
5. Will my action or decision protect DigiHaul and the broader DPDHL Group’s reputation as a company with high ethical standards?

If the answer to each question is “yes”, your action or decision is most likely correct and compliant with DigiHaul’s Code of Conduct.

If in doubt, ask your line manager, the HR or Commercial Heads of Department and keep asking until you are sure.

The rules and standards outlined here serve as an “ethical compass” that guides colleagues in their day-to-day work and help ensure our core principles continue to be embraced. It will ensure that the conduct of all DigiHaul employees toward each other and toward business partners, customers and investors, is characterised by mutual respect.

Respect also means observing applicable legal regulations that apply in all areas of operations and conducting our business in a responsible, fair and ethically irreproachable way.

The DigiHaul Board of Management endorses the values outlined in this Code of Conduct and expects all colleagues to be role models in their daily work and to contribute to a Company culture that reference and embrace our core values.

As such, we are committed to promoting and maintaining the highest possible ethical standards in relation to all of its business activities.  The Company’s reputation for maintaining lawful business practices is of paramount importance to it and this policy is designed to preserve these values.

DigiHaul Core Values

The DigiHaul Code of Conduct is underpinned by its core values.

1. We build relationships on trust and respect.

Honesty and loyalty to each other and our customers is at the very core of everything we do.

2. Our passion is our purpose.

We love what we do and we embrace new ideas and opportunities.

3. We get the job done.

When our customers need us, we’re quick to respond and can be trusted to do what’s right.

4. We’re experts you can rely on.

Every member of the DigiHaul family has a valuable contribution to make and we’re continually developing our people to be the best in the business.

5. Our customers are our world.

Our daily mission is to provide nothing but excellent service and solutions.

6. The future of freight is in our hands.

We think innovatively and act responsibly, creating stability and growth for our business, our people and our customers.

Anti-Corruption & Anti Bribery

DigiHaul has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships.

One of the Company’s core values is to build relationships on trust and honesty via sound, responsible and fair business operations.  It is committed to promoting and maintaining the highest possible ethical standards in relation to all of its business activities. The Company’s reputation for maintaining lawful business practices is of paramount importance to it and this policy is designed to preserve these values.

This policy sets out the Company’s position on any form of bribery and corruption and provides guidelines aimed at:

• Ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK, but also in any other country within which DigiHaul may carry out its business or in relation to which its business may be connected.
• Enabling employees and persons associated with the Company to understand risks associated with unlawful conduct and to enable and encourage them to be vigilant and to effectively recognise, prevent, avoid and report any wrongdoing, whether by themselves or others.
• Providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with.
• Creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or other unethical conduct.

All colleagues and associated persons are expected to adhere to the principles set out in this policy.

The key UK legislation on which this policy is based is the Bribery Act 2010 and it applies to the Company’s conduct both in the UK and abroad.

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is an offence in the UK to:

• Offer, promise or give a financial or other advantage to another person (i.e. bribe a person) whether within the UK or abroad, with the intention of inducing or rewarding improper conduct.
• Request, agree to receive or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct.
• Bribe a foreign public official.

An individual can be held personally liable for any such offence.

It is also an offence in the UK for an employee or an associated person to bribe another person in the course of doing business intending either to obtain or retain business, or to obtain or retain an advantage in the conduct of business, for the Company. The Company can be liable for this offence where it has failed to prevent such bribery by associated persons.  As well as an unlimited fine, it could also suffer substantial reputational damage in connection with this offence.

All colleagues and associated persons are required to:

• Comply with any anti-bribery and anti-corruption legislation.
• Act honestly, responsibly and with integrity.
• Safeguard and uphold the Company’s core values by operating in an ethical, professional and lawful manner at all times.

Receipt and Disclosure of Gifts

It is the aim of DigiHaul to ensure high levels of customer and client satisfaction. Occasionally, satisfied customers, clients or other third parties may seek to reward employees with gifts.  Whilst the Company has no desire to stop deserving employees receiving a small token of gratitude or appreciation from a customer or client, we do recognise that there is the potential for abuse.

DigiHaul does not believe that it is appropriate for its colleagues to accept anything of greater value than small tokens of appreciation from customers, clients, suppliers, contractors or from any other person or organisation with which the Company has, or might have, business connections.

This is because it is important to ensure that no employee acts in any way that is inconsistent with the integrity of the business by accepting a gift in circumstances where it could influence, or be seen to influence, that employee’s business decisions or actions.

The giving of business gifts to clients, customers, contractors and suppliers may only be permitted, if the following requirements are met:

• The gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage.
• It complies with local laws.
• It is given in the Company’s name, not in the giver’s personal name.
• It does not include cash or a cash equivalent (such as gift vouchers).
• It is of an appropriate and reasonable type and value and given at an appropriate time.
• It is given openly, not secretly.
• It is approved in advance by either DigiHaul CEO, COO or CFO.

The Company promotes a culture of honesty and transparency in the practice of receiving gifts. All employees are under an obligation to report the receipt of gifts, including the nature of the gift and the identity of the sender, to their line manager as soon as they are offered.

In all instances the receipt of a gift, whatever the value must be authorised by DigiHaul CEO, COO or CFO.
Where the gift is deemed to be of low value, authorisation is likely to be awarded, although limited to one per individual in any 12 month period. Subsequent low value gifts offered in a 12 month period, if authorised, will be raffled among remaining staff with the proceeds donated to one or more of DigiHaul’s chosen Charities.

Anything of higher value will not be authorised and should be politely declined and the offer logged against the supplier.

Failure to report the receipt of any gift from any party constitutes a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the employee liable to summary dismissal.

If the Company discovers a supplier or contractor has been used wholly or mainly because of the incentive of a free gift and, as such, the employee has not acted in the best interests of the Company, this will also constitute a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the gravity of the offence, it may again be treated as gross misconduct and could render the employee liable to summary dismissal.

Small gifts that are genuinely given as a token of appreciation are acceptable, provided always that the employee properly declares the gift in line with this policy and provided they do not subsequently treat the sender of the gift more favourably than other clients, customers, suppliers or contractors.

This policy does not apply to promotional gifts i.e. items such as pens, mugs, calendars or stationery that bear the company name or logo of another organisation, provided that these have no significant financial value.

Conflict of Interest

DigiHaul expects all colleagues to maintain high ethical standards in dealing with conflicts of interest. A conflict of interest exists if your private activities or relationships could, or could appear to, result in you no longer being able to perform your duties for DigiHaul or the wider DP DHL Group, independently and objectively.

Relationships that could lead to a conflict of interest include family ties, partnerships with business partners and competitors, or shares or investments in their companies.

Colleagues must notify the line manager immediately where a conflict of interest exists or has the potential to exist. Measures to evaluate and deal with the conflict of interest will be taken and documented in consultation with HR.

Diversity & Inclusion

The diversity of our employees is our genuine strength. DigiHaul promote an inclusive work environment that values the diversity of our employees and in which everybody feels accepted and can be their best every day.

It is DigiHaul’s firm belief that diversity and inclusion contribute to our company’s success.

The main criteria for employee selection and promotion are skills and qualifications. We expressly reject any form of discrimination based on gender, ethnic and national origin, race, skin colour, religion, age, disability, sexual orientation and identity or any other characteristic protected by law.

All colleagues are called on to contribute to an environment of respect that precludes any kind of harassment, including workplace bullying, unwelcome sexual advances, unwanted physical contact, inappropriate propositions, or a working environment tainted by insulting jokes and remarks or demeaning comments.

We do not tolerate any kind of violence in the workplace, including but not limited to threatening and intimidating behaviour.

Colleagues are encouraged to speak up if they feel that they or others are being disadvantaged or, worse, discriminated against.

Social Media

Respect, tolerance, honesty and integrity toward employees, customers and the general public also apply to the use of social media. As employees of the company, we must always express ourselves in a respectful and professional manner. Misuse of intellectual property or publication of confidential or internal data and information is prohibited.

Any internal matters must remain internal. Without exception, treat all sensitive and business information pertaining to DigiHaul, the DPDHL Group, its partners and our suppliers as strictly confidential. Do not mention clients, partners or suppliers without their consent.

Information that is posted on our internal social networks is also confidential. Do not share it on public social networks without consent.

Working with Suppliers

DigiHaul’s business relies on effective relationships with our Suppliers. As part of our on-boarding process, we share with our Carrier partners our basic principles of ethical behavior, compliance with legal standards and respect for the environment.

We expect them to base their actions on the same principles and invite them to confirm the adoption of our standards by singing up to the DPDHL Group Supplier Code of Conduct.