Business conduct

Our approach to business conduct

Good governance and compliance with applicable laws and ethical standards are fundamental to how we do business. We also recognise the positive contribution to society from working with suppliers and customers who share our values. Fostering a corporate culture that protects employees and other stakeholders, promotes responsible supply chain practices, prevents corruption, and safeguards whistleblowers is vital to our success.

DCC Energy’s BUSINESS CONDUCT AMBITION

To operate in accordance with the highest standards of ethics, compliance and corporate governance.

Our goal

TO PREVENT CORRUPTION

We measure this objective by assessing incidents of bribery and corruption in our operations or supply chain
Our goal

TO PROTECT HUMAN RIGHTS

We measure this through the ongoing assessment of human rights risks within our operations and supply chain

OUR PROGRESS

6,801

Employees completed Code of Conduct training

Number of convictions for violation of anti-corruption and anti-bribery laws

Material data privacy breaches

1 /

OUR APPROACH

There are three key elements that support and enable our approach to Business Conduct, firstly the Board provides direction and oversight of our business conduct culture. Secondly we have a Code of Conduct that applies to all employees in DCC Energy and sets the framework for achieving the highest standards. Thirdly we have a range of policies that set out our approach and expectations regarding a range of topics including human rights and supply chain integrity.

Board Oversight of Culture

The Board ensures an effective culture of business conduct and highest standards through a range of activities, including: employee surveys, site visits, internal audits, and workforce engagement directives. In addition, a range of relevant reports are provided to the Board across topics such as employee engagement and compliance, whistleblowing, code of conduct training, succession and talent development, safety performance and any disputes and regulatory investigations.

Code of Conduct

Our Code of Conduct sets out our commitment to high standards of business conduct. It provides practical guidance for employees of the DCC Energy group on a range of areas including competition law, anti-bribery and the protection of personal information. A copy of the Code is provided to every employee when they join.

Our Policies

We have a range of relevant policies that our employees are required to comply with. These include: The Supply Chain and Integrity Policy, The Human Rights Policy, Group Health and Safety Policy, Group Environment Policy, Inclusion and Diversity Policy and Supplier Code of Practice. Please see links below to download these policies.

ENSURING CYBER SECURITY AND IT RESILIENCE

Personal data held by the Group may be subject to accidental exposure or deliberate theft, potentially resulting in regulatory, financial or reputational harm. Emerging risks include the increasing sophistication of cyberthreats, including those enabled by artificial intelligence. In response to evolving cybercrime trends, the Group has continued to strengthen its mitigation measures and resources. We have introduced an internal policy on the Acceptable Use of Generative AI to ensure IT integrity and data protection standards remain robust while enabling responsible use of AI technologies.

Cyber Security Measures

Our Group IT Security team sets cyber security standards and provides detailed technical guidance to Group businesses to protect against attacks and support effective incident response. This is supported by user training and awareness programmes, including education on threats such as social engineering.  

IT Resilience

Each Group business is required to regularly complete a business impact assessment on its critical systems and maintain a corresponding disaster recovery plan setting out recovery actions in the event of a significant failure. These plans are tested at appropriate intervals. An increasing proportion of the Group’s key IT platforms are cloud‑based, reducing the complexity of managing system failure risk.