The DPO Centre Supplier Code of Conduct
This Code of Conduct outlines the standards and principles that The DPO Centre Group expects of all its Suppliers, consistent with our core values of Respect, Adapt, and Deliver. Our aim is to build long-term relationships with Suppliers who are also committed to these values. This Code of Conduct supports the development of those relationships by setting out certain standards that we expect all Suppliers we work with to follow.
Our Code is not designed to provide specific guidance on every situation we may encounter and where we might need to answer the question, “What is the right thing to do?” It does, however, provide principle-based guidance that helps us think about difficult questions, promoting consultation and encouraging us to voice our concerns.
The development of long-term relationships requires clear and open communication. If you have concerns that this Code of Conduct is not being followed, you should feel free to raise those concerns with the Group business you are dealing with, or please contact The DPO Centre’s Group Compliance team at dpo@dpocentre.com. We will treat all notifications confidentially to the maximum extent we can. If you have concerns, we want to know about them. We look forward to building a mutually beneficial business relationship with you.
1. Application
This Supplier Code of Conduct shall govern the relationship between The DPO Centre and the Supplier. The term “Supplier” as used in this document refers to a legal or natural person who, under a contractual agreement, provides any type of goods, services, or expertise to The DPO Centre Ltd or its subsidiaries.
2. Compliance
We require our Suppliers to ensure full compliance with all applicable laws and international standards. This includes the Universal Declaration of Human Rights, the core conventions of the International Labour Organisation on labour standards, and all applicable local, national, and international laws concerning anti-corruption, fair competition, non-proliferation and export controls, sanctions and embargoes, environment-health-safety protection, permits and licenses to operate, as well as secrecy and privacy protection.
Suppliers must have effective policies and procedures in place to ensure compliance with all applicable regulations.
3. Anti-bribery & Corruption
Bribery is the offering, promising, giving, requesting, or receiving of money or anything else of value (including employment) to any person, organisation, or government official in order to induce that person to do something improper and is further defined in the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act. This usually concerns attempts to obtain or retain business or secure some other improper advantage.
Corruption is a form of dishonest or unethical conduct by a person, often to acquire personal benefit. It may include many activities, including bribery, fraud, forgery, theft, extortion, etc.
Any commission or bonus arrangements must be formalised, transparent, and agreed upon between The DPO Centre and the Supplier’s entity, and not with any individuals.
The DPO Centre does not tolerate any form of bribery in any of our business dealings. We require our Suppliers to be familiar with and comply with all applicable anti-corruption laws and regulations regarding anti-corruption, as well as the applicable anti-bribery and corruption laws and regulations of all locations where they operate, to conduct their activities with the same zero tolerance towards corrupt practices, and to have appropriate and adequate policies and trainings in place to prevent such activities.
4. Gifts, Entertainment, Incentives & Payments
We are committed to strengthening all of our relationships with vendors, customers, Suppliers, and other business associates. We do not provide gifts or entertainment to influence business decisions, and we do not make illegal or unethical payments. In all situations, we must exercise good judgement and moderation and avoid creating any perception of inappropriate conduct.
When business entertainment is appropriate, or in the rare event that a gift is given or received, employees and contractors should ensure that the gift/entertainment follows these criteria:
- Has a clear business purpose
- Cannot be perceived as a bribe or improper payment
- Does not violate applicable laws or ethical standards
- The individual accepting the gift would not feel uncomfortable discussing it with his or her manager/colleagues or disclosing it publicly
- It is not inappropriately lavish or excessive
- It is not a frequent or recurrent gift from the same person or entity
The DPO Centre expects its Suppliers to have the same level of reasonable judgements and appropriate conduct when taking business decisions. Any offering or receipt of any gifts or business courtesy shall be permitted only in compliance with applicable legislation. Suppliers are expected to conduct appropriate trainings on a regular basis.
5. Anti-competition
Competition law is legislation that promotes or seeks to maintain market competition by regulating anti-competitive conduct by companies.
We will take all steps necessary to ensure that we are fully compliant with applicable competition and antitrust laws. We are committed to ethical, fair, and vigorous competition. We will sell services based on their merit, quality, functionality, and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors.
We expect our Suppliers to do business in compliance with applicable antitrust laws and regulations. Our Suppliers should not enter any sort of arrangements to fix prices or control the market or otherwise try to restrict or impact competition regulations improperly.
6. Confidentiality
We are committed to maintaining the highest degree of integrity in all our dealings with potential, current, and past employees, contractors, vendors, customers, and Suppliers, both in terms of commercial confidentiality and the protection of all personal information received. We apply the same standards to our dealings with all vendors, customers, Suppliers, and associates.
We expect our Suppliers to have the same degree of diligence with their suppliers and employees and to respect any confidentiality undertakings they may have with The DPO Centre. All confidential information must be handled in accordance with EU & UK General Data Protection Regulations (GDPR) and other applicable data protection laws.
7. Conflict of Interest
We all have a responsibility to ensure that our personal activities and interests do not conflict with our responsibilities.
Conflicts of interest can cause an individual to act out of interests that are divergent from those of The DPO Centre or their colleagues or their business partners, which may impact the individual’s and Company’s reputation, integrity, and trustworthiness.
Conflicts of interest may involve:
- Outside work, employment, or other activities
- Political activities or contributions
- Any other arrangement or circumstance, including family or other personal relationships that could be perceived as a conflict of interest, divergent from the best interests of the company
We expect our Suppliers to avoid conflicts of interest or situations that may look like a conflict of interest and to disclose any conflict that Supplier is aware of and/or should be reasonably aware of upon entering a business relationship with The DPO Centre. Suppliers must disclose any actual or potential conflicts of interest in writing to The DPO Centre prior to or during the engagement to office@dpocentre.com.
8. Respect for Human and Workers’ Rights
We expect our Suppliers to comply with fundamental human and workers’ rights. All employees must be treated with respect and dignity and shall not be verbally or physically harassed, abused, threatened, or intimidated.
9. No Modern Slavery, Human Trafficking, or Child or Forced Labour
The DPO Centre has zero tolerance for slavery and human trafficking in all its business dealings. The DPO Centre is committed to the prevention of slavery and human trafficking in all its forms and will not tolerate or condone it within any part of its business or supply chains.
We require our Suppliers to not engage in the use of forced, child, or bonded labour, slavery, or trafficking of persons and to enforce the prohibition of any such forms in their own supply chain. Suppliers should allow employees to freely choose to work or to leave employment.
The term ‘child’ refers to any person under the higher minimum age defined in the UNGP or the legal age for employment where the work is performed. We expect our Suppliers to comply with applicable laws and regulations on pay, benefits, working hours, and the rights of individuals to join trade unions and participate in collective bargaining.
10. Health & Safety
The DPO Centre regards the management of health and safety as an integral part of its business and as a management priority.
Compliance with current health and safety legislation is therefore regarded as the absolute minimum standard acceptable.
Our Suppliers are expected and encouraged to be proactive on health and safety issues as part of the continued development of the health and safety environment within their premises. Likewise, our Suppliers shall ensure that their own work is without risks to themselves and others as far as reasonably practicable.
11. Records and Reporting
All information The DPO Centre produces is considered a record, regardless of how the information is maintained. Examples of records include financial, accounting, technical specifications, sales reports, HR files, health & safety reports, marketing information, business plans, etc. Additionally, emails, instant messages, and text messages fall into this category. This may be considered as The DPO Centre’s intellectual property.
Our Suppliers shall ensure that they take all necessary measures to ensure the security and integrity of The DPO Centre’s or our customers’ intellectual property and protected information they will receive in the course of their business with The DPO Centre. Such information shall not be used for any other purposes than the one it’s initially intended for without prior written authorisation from The DPO Centre’s authorised representative.
12. Data Protection
We are committed to fulfilling our obligations, and we expect our Suppliers to maintain the highest degree of compliance with data protection laws. We expect our Suppliers to inform us promptly upon the occurrence of any data breaches involving The DPO Centre’s personal data. Any data breach involving The DPO Centre’s data must be reported immediately and no later than 24 hours after discovery.
13. Environmental Protection
We are committed to protecting and preserving the environment to the best of our obligations. We are integrating environmental issues into our activities, and we aim at ensuring that all our Suppliers set the highest standards for their environmental performance. We expect our Suppliers to always be fully compliant with any environmental legislation and other requirements, including REACH or WFD.
14. Tax Evasion
Tax evasion is an illegal practice whereby a person, organisation, or company behaves dishonestly and intentionally avoids paying his true tax liability.
Suppliers must not engage in or facilitate tax evasion, and Suppliers are expected to comply with all applicable tax evasion legislation and regulations.
15. Conclusion
This Supplier Code of Conduct represents an integral part of the contractual agreement between The DPO Centre and the Supplier, unless The DPO Centre and the Supplier, in a separate commercial agreement signed by The DPO Centre, agree that the Supplier’s own Code of Conduct or similar internal guidelines adequately satisfy all above-mentioned principles and their implementation and thus may be applied in lieu of The DPO Centre’s Supplier Code of Conduct.
Suppliers grant The DPO Centre the right to assess, by means of targeted questionnaires or third-party audits, compliance with certain or all of the above-listed principles.
The DPO Centre at any point shall have the right to propose corrective actions to the Supplier. If the Supplier is found not to have met the above-listed requirements, The DPO Centre may terminate its contract(s) with the Supplier.
Last updated: 26/07/2025