COMPLIANCE

Fair competition and commitment to ethical and lawful business are important prerequisites for the long-term success of the DOUGLAS Group.

COMPLIANCE AT DOUGLAS GROUP

The DOUGLAS Group Compliance Management System contains individual compliance standards and processes and as such represents a substantial component of our governance system serving the prevention and monitoring of certain risks.

It contains standards and processes to ensure our adherence to applicable laws and internal policies, along with a regularly updated regulation radar. Acting responsibly and with integrity towards our customers, business partners and the general public is a given at the DOUGLAS Group. Communication and regular training ensure our employee’s awareness and understanding of compliance topics and policies. Our network of country compliance officers provides them with additional support and assistance on compliance matters.

Visual of the DOUGLAS Group Compliance Management System

The DOUGLAS Group corporate culture has a fundamental influence on the perception of Compliance in our organization. Internal policies provide guidance on ethical and lawful business activity to safeguard compliance within the company. The DOUGLAS Group Code of Conduct outlines the group’s commitment to responsible business practices and applies to all employees.

The DOUGLAS Group considers fair competition and a commitment to ethical and lawful business practices as essential to its long-term success as a retail company. Accordingly, the DOUGLAS Group Compliance Management System contains standards and processes to ensure the group’s adherence to applicable laws and internal policies and to prevent violations of law. The Compliance Management System thereby serves to protect the company from potential risks and from financial and reputational damage.

The foundation of the Compliance Management System is a risk-based approach deriving from the company’s own risk landscape to enable early identification and mitigation of potential compliance risks. Such risk assessment provides the opportunity to establish an individual compliance program tailored to the DOUGLAS Group.

Based on the risk evaluation, adequate compliance processes and measures support the DOUGLAS Group in implementing certain corporate governance principles and standards. This applies specifically to the provisions on the fight against bribery and corruption as well as on competition and antitrust violations. The DOUGLAS Group applies due care to the choice of its business partners. The DOUGLAS Group Supplier Code of Conduct serves to ensure that our suppliers acknowledge generally accepted compliance standards. Identification and management of compliance violations are essential to protect the DOUGLAS Group from financial liability and reputational damage. Confidential ways to report potential compliance violations and adequate follow-up measures aim to guarantee a proper case management.

In addition to a central Compliance Organization headed by the Chief Compliance Officer, with a direct reporting line to the Chief Financial Officer, Compliance Officers in the countries support the entities in implementing compliance measures to adequately address potential risks.

Communication and training serve to enable continuous awareness and understanding of compliance topics and policies. Additionally, the Group-wide compliance organization provides employees with the opportunity to seek advice from their compliance contacts at any time and in critical situations.

Compliance monitoring measures aim to safeguard a consistent implementation of the DOUGLAS Group Compliance Management System across the countries. The performance of compliance audits serves to detect potential compliance violations and helps identify adequate process improvement.

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Ethics & Integrity

The DOUGLAS Group culture is shaped by integrity, ethical and lawful conduct. Our objective is to ensure that all activities in the company and towards our business partners are marked by integrity, respect and responsibility, every day and everywhere in all the countries in which we operate. We created a code of conduct that serves as our company guideline on integrity and ethical behaviour.

The DOUGLAS Code of Conduct sets out the standards of behaviour that apply to everyone at the DOUGLAS Group and illustrates our ethical principles of respect and responsibility, appreciation and honesty, diversity and tolerant behaviour in everything we do. By maintaining an open dialogue we jointly contribute to a Group-wide cooperation of trust and teamwork and strengthen our corporate culture.

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Third Party Compliance

The DOUGLAS Group appreciates long-term relationships with its business partners and places great importance on them respecting ethics and integrity, social and environmental responsibility, and human rights. We therefore expect our business partners to comply with applicable laws and to share our commitment to responsible business conduct by acknowledging our supplier code of conduct.

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Reporting Concerns

The DOUGLAS Group strives to maintain an open business climate and high business ethics. Our external reporting service provides our business partners with an opportunity to confidentially and anonymously report compliance violations. The report may include information regarding criminal offences and violations of EU law or national laws within a business context with the DOUGLAS Group, including potential human rights violations or environmental issues.

All messages are processed confidentially and handled by the DOUGLAS Group Compliance Office. The incident may be reported via the Whistleblowing Web Portal.

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WHISTLEBLOWING WEB PORTAL