Ethics Policy

This policy applies to all DART employees, associates, secondees, agency staff and third parties who work for and on DART’s behalf. It applies to the goods and services we procure, our direct operations and the services and goods we provide. The policy sets out the ethics that we apply to ourselves and to our business. It is intended to be high-level. Other policies provide detailed guidance on particular matters. 

What you should do 

Using the policy is not just being familiar with our ethics: we want all those who work for us to be looking for improvements in what we do and reporting where we could do better. This alone is generally ethical. We strongly support employees who raise genuine ethics concerns in good faith.

Law 

Compliance with law is just the start point. Of course, we expect all our staff, operations, contractors, suppliers and subcontractors to obey all statutory requirements where they operate, and for all their activities. This, though, is the minimum: beyond the law, we expect all to operate with the highest moral standards. 

Human Rights 

We commit to maintaining and promoting the UN’s Universal Declaration of Human Rights through our policies, procedures and practices. Human rights are part of the backdrop to our decision-making. 

We try to work with business partners who conduct themselves in a way shared with our respect for human rights and ethics. We work with our customers so that our fulfilling their business needs does not infringe human rights. Likewise, we should ensure that our employees’ and suppliers’ operations do not infringe human rights, while allowing for the variety of existing cultures. 

Child Labour 

We do not accept products that may have had child labour involved in making them. If the country of manufacture does not have law on the minimum employment age, the minimum age we accept for those who manufacture our goods is 15, and where local law permits a lower age, the minimum is 14. Children must not be economically exploited or work in hazardous conditions, or be in work that interferes with their education, or is harmful to their health or damaging to their physical, mental, spiritual, moral or social development. We do not work with any enterprise involved in child labour in any way. All enterprises that deal with us must respect child rights and wherever possible help children develop themselves in fields such as education, sports and to develop into good members of society. 

Environment 

We are committed to preserving, sustaining, and where possible improving the environment, doing what we can to minimise environmental impact. 

Local Communities 

We want to support and assist the communities where we operate by conducting our business with respect and consideration. We aim to minimise disturbance and ensure that local communities gain advantage from our operations, such as good employment opportunities, high quality services and products. 

Business Practice Standards 

Bribery and corruption 

We do not engage in any form of bribery or corruption. More details about this are in our Anti-Bribery and Corruption policy. Sales of our services and products and our purchases of services and products from our suppliers are exclusively on the basis of quality, performance, price, value and/or for our benefit. 

Political contributions 

We do not make contributions to political parties. 

Products and Processes 

Our employees must always conduct themselves ethically, presenting products accurately to customers. Utmost care will be taken in delivering the correct quantity and an acceptable quality of products and services. 

Competition 

We compete fairly and in an ethical manner. Our future growth will come from providing our customers with a high level of service and high-quality products. 

We do not discredit competitors unfairly. When in contact with competitors, we avoid discussing our and their confidential information and make no attempt whatever to improperly acquire their trade secrets or any other confidential information. 

Employees 

We commit to improving individual and business performance by employing the best people at all levels and creating a safe and constructive environment for all employees. We and all the enterprises we contract with must provide their employees with working conditions (and living quarters where applicable) that are safe and clean. 

Employee Rights 

We take employee rights seriously. We respect freedom of association and the right to collective bargaining. Employment for us and our contractors must be freely chosen with no use of forced, bonded, involuntary or prison labour, and without discrimination on the basis of gender, parentage, colour, ethnicity, culture, religion or other belief, sexual orientation or marital status, maternity, age, caste, place of birth, language, or disability. Employees must be free to leave their employer after reasonable notice. 

We do not tolerate bullying or harassment (defined as unwanted behaviour a person finds intimidating, upsetting, embarrassing, humiliating or offensive) of any kind, including racial, sexual, physical or of any other kind, towards anyone. All must conduct themselves ethically in private, as well as in their professional lives. 

We give our employees the chance to self-develop and to advance with us. We promote in a fair manner based on individual performance, ability and other similar factors. We do not accept favours or any unethical practices towards promoting. 

Terms of employment 

We believe in giving employees terms of employment that where possible go beyond national law. We take these responsibilities very seriously: employees must work under a fair contract that is written and understandable. We regard national legal wage rates as a bare minimum: we encourage all the enterprises we work with pay sufficient wages to meet basic needs and to provide some discretionary income. Similarly, employment terms must require working hours that treat national laws as a bare minimum. Staff should not frequently work more than 48 hours per week and must have at least one day off for every 7 day period, on average. Overtime must be infrequent, voluntary, not exceed 12 hours per week, and compensated at a premium rate. 

Disciplinary measures must be recorded and wages not deducted as a disciplinary measure. No wage deductions must be made unless national law allows it or the employee has allowed it without pressure. 

Health & safety 

We place the highest priority on promoting employees’ health and safety at work, monitoring health and safety standards. Every employee must be trained on Health and Safety when they start employment and must promote it. 

Pre-employment screening and selection 

We regard hiring the best possible personnel as the principal basis to give our customers high quality service and products. We carry out pre-employment screening in an ethical manner, with candidates being hired because of their ability and similar qualities. 

Confidential information 

We take our data protection responsibilities very seriously. Employees must not use confidential information for personal gain, nor disclose it to any third party during or after their employment. Our data protection policies provide more detailed requirements. 

Professional behaviour 

We expect all to behave professionally, not least in respect for others. We expect particular care in relation to IT, including not misusing it, bringing to the workplace via email, the internet or social media material that is (for example) discriminatory, obscene, abusive, defamatory or inappropriate in other ways, or damaging our (or others’) cyber-security. 

Conflicts of interest 

Every employee must avoid business, financial or other direct or indirect interests or relationships which conflict or appear to conflict with our interests, or which divide their loyalty to us. Employees must not undertake any activity affecting our integrity or reputation. 

Monitoring and Enforcement 

We recognise that different countries have different cultures and laws. However, we see the ethics outlined above as universal and right except where local laws differ; in which case, the local law must take precedence. In such instances, the relevant personnel or supplier should inform one of our senior management. 

Monitoring 

Without wishing to be intrusive, we will monitor behaviour. All the enterprises we work with must tell us about where each product is made, as well as any information relevant to implementing this ethics policy. We reserve the right to make unannounced visits (by us or an independent party) to any place sites where people work directly or indirectly for us. 

Enforcement 

We shall write into our contracts a right to terminate for non-compliance with this ethical policy – including that we are not liable for resulting costs incurred by the infringing party. 

All our employees, partners, suppliers and subcontractors must adhere to these principles. We have emphasised throughout that this document is no more than a start point and all staff and the enterprises we work with must work continuously to work at high ethical standards.

Ryan Paterson 
Managing Director 

12 July 2021