Question 1

Business integrity

Accepted Answer

Damen conducts its business with integrity. This means that it obeys the laws and regulations of the countries in which it operates and that Damen is a reliable partner. Damen is open and transparent about the way it conducts its business.

It recognises that violations of laws and regulations can have serious consequences for both Damen, individuals involved as well as our business partners. Damen expects the same integrity standard from its stakeholders in doing business. Damen does not allow bribery and/or any other forms of unethical business practice in its companies or by its employees. No employee may receive, make, offer, promise or authorise any payment, gift or other undue advantage which is, or may be construed as being a bribe.

See our Anti-bribery & Corruption Policy to learn in more detail how we maintain our business integrity and avoid bribery and corruption. Damen Holding holds an ISO 37001 (Anti-bribery & corruption) certification.
For more information about gifts and hospitality in this context, reference is made to our Personal & Business Integrity Policy.

Question 2

Conflicts of interest

Accepted Answer

In doing business, Damen recognises that employees may have personal, financial, political and other professional interests that are not directly linked with their activities for Damen.

Damen expects that employees avoid conflicts of interests between their private dealings and their responsibilities towards Damen. It places team interest above individual interest. Potential, apparent and direct conflicts of interest need to be reported to the direct manager and resolved, according to the company’s conflict of interest procedure.

Damen does not participate in, or supports political parties. We do not make any payments or donations to political parties or their institutions, agencies or representatives. Damen does not facilitate political donations by employee action committees.

For more information concerning conflicts of interest, sponsoring and donations, see the Personal & Business Integrity Policy.

Damen and our employees ensure that integrity risks for entering into and maintaining a business relationship with partners such as customers, suppliers and service providers are identified and managed according to our internal procedures. Damen will not cooperate, be it directly or indirectly, in money laundering, fraud and/or financing of terrorism. All business transactions and payments shall be accurately and completely recorded in accordance with our accounting principles and local laws and may be subject to audit.

See the Financial Compliance Policy to learn more about financial control obligations.

Question 3

Export control and sanctions

Accepted Answer

Today’s international marketplace is a very competitive and complex arena for businesses to navigate, and the threat of incurring into import and export controls and sanctions is real.

“Export Compliance” is the specialized discipline which covers the act or process of being in conformity with external applicable regulations, guidelines and relevant laws concerning all activities related to the import and export of products (which can be goods, services as well as tangible or intangible assets). Developing an effective Export Compliance Policy is an invaluable way for a company not only to contribute to international markets security, but also to protect essential company interests. It’s vital to Damen’s success to comply with all applicable laws, regulations and procedures wherever it operates.

Damen is committed to comply with export and import controls in the countries where we conduct business, including (economic and humanitarian) sanctions that may apply to our business activities. It has a dedicated Export Compliance team that reports to the Group Compliance Officer.

See the Export Compliance Policy to learn more about compliance on import and export control and sanctions.

Question 4

Compliance and Reporting

Accepted Answer

Damen expects that all our colleagues, including temporary colleagues, subcontractors, volunteers and trainees comply with the Code of Conduct and all Damen Policies. Colleagues are also encouraged to discuss questions concerning the Code of Conduct and dilemmas in the workplace with each other and their supervisors.

Infringement of the Code of Conduct and any of the Damen Policies is specifically prohibited. We understand that where work is done, mistakes can be made. We learn from mistakes as they give us the opportunity to improve. Conscious infringement of the Code of Conduct or Damen Policies, however, such as fraud, bribery or unresolved conflicts of interest may lead to appropriate sanctions. As a company, Damen has the responsibility to report violations of the law to the relevant authorities.

We encourage all individuals to speak up and raise their concerns regardless of the matter or (the rank of) individuals involved. There are several reporting channels available, as set out in our Whistleblower Policy. Individuals reporting in good faith will be protected against retaliation at all times. Retaliation is a violation of our Code of Conduct and Whistleblower Policy and Damen will take appropriate action towards individuals that retaliate against others.

See the Damen Code of Conduct and Whistleblower Policy to learn more about Damen’s compliance standards and the available reporting channels.

Compliance

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