Environmental & Social Information • Jul 15, 2022
Environmental & Social Information
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Our commitment to responsible business – a message from the board
Speaking up confidentially Speaking up without fear of retaliation
| Human rights | |
|---|---|
| Non-discrimination and equal opportunities |
|
| Safe work environment |
Our business relationships
| Conflicts of interest | 11 |
|---|---|
| Bribery | 12 |
| Dealing with authorities | 12 |
| Gifts, hospitality and entertainment |
13 |
| Donations and sponsoring | 13 13 |
| Financial crimes prevention | 14 |
| Fraud | 14 |
| Economic sanctions | 14 |
| Market transparency |
|---|
| Selecting suppliers |
| Fair and free competition |
| Treatment of inside information |
10 Protecting our assets 19
| Communications | 20 | |
|---|---|---|
| Company property | 20 | |
| Intellectual property | 21 | |
| Vouchers | 21 | |
| Data privacy | 22 | |
| Cyber / information security | 22 |
| Our commitment to responsible | 4 |
|---|---|
| business – a message from the board | |
| Scope | 5 |
| Our values |
Together, we set out to always deliver an amazing experience – fast, easy, and to our customer's door. In order to continue to achieve our vision, we must manage our business responsibly and continue to earn and keep the trust of our customers and partners. This relies on all our Heroes doing the right thing and making the right decisions in big and small ways, every day.
To guide us, we act within the framework of ethics, integrity, and applicable laws, and always in the interest of Delivery Hero. Our values of aiming higher and delivering solutions allow us to drive the industry forward and bring new innovations to life. Our third value, we are Heroes because we care, influences our engagement with our communities and each other. Together our foundational values underpin all our actions and keep us on the right path towards achieving our ambitions.
The Code of Conduct is binding for all of us and translates our corporate values into practical guidelines and advice on making responsible decisions, even in difficult situations.
For additional and specialized guidance for your daily work, more detailed internal policies are available on the Compliance Portal. You may however also find yourself in some difficult or unclear situations that have yet to be covered in our existing guidelines. In these cases, please do not hesitate to speak up and ask your manager or the relevant team for advice.
By following our Code of Conduct, we can ensure that we live our values in our day to day work. Thank you for all that you do to help make Delivery Hero the world's trusted leading local delivery platform and such an incredible place to work.
Yours, Niklas, Emmanuel and PJ
Niklas Östberg Chief Executive Officer
Emmanuel Thomassin Chief Financial Officer
Bongjin Kim Chief Creative Officer
Johannes Bruder Chief Product Officer
Christian Hardenberg Chief Technology Officer
Ana Mitrasevic Senior Vice President, People
Delivery Hero is a truly global company, made up of employees with diverse cultures and backgrounds. Our Code of Conduct plays a vital role in enabling us to work together, by providing the information and support we need to act with integrity and respect. Our Code of Conduct helps us make the right decisions in line with our values, supporting our reputation in the markets and the communities we operate in.
The Code of Conduct applies to all Heroes, meaning all full and part-time employees, contractors, managers, and the members of our C-Level and executive board. Everyone at Delivery Hero is expected to know and follow the guidelines outlined in this document, and to remind others of them when appropriate. They apply to all companies of the Delivery Hero group.
We live up to the Code of Conduct by adhering to applicable laws and regulations, internal policies and guidelines, as well as ethical business practices.
Throughout the different phases and stages of Delivery Hero's growth, it is vital to stay focused on what really matters to us.
Our values remind us of what Delivery Hero stands for and serve as a guiding light for how we conduct our activities.
We always aim higher
We deliver solutions
We are Heroes because we care
77 Speaking up confidentially Speaking up without fear of retaliation
Delivery Hero is committed to doing business with integrity and fairness, with respect for the law and our values.
In most situations putting our Code of Conduct into practice is straightforward but sometimes, despite this commitment, Heroes might feel that something is wrong, or observe an act that concerns them or seems to violate our Code of Conduct or our other internal policies. The earlier we speak up, the more likely we can prevent serious problems from arising – or at least minimize their impact. So, however hard it may be, we must speak up immediately when we become aware of an ethics or compliance concern.
Delivery Hero will carefully review all reported issues and where appropriate, will take action.
Delivery Hero will aim at protecting the confidentiality of the reported issue and where possible also the involved persons. For severe compliance breaches, Delivery Hero has also set up a whistleblower hotline, managed by the central Compliance Team, which allows for fully anonymous reporting.
Delivery Hero cares about protecting the persons that raise concerns and does not tolerate any form of retaliatory action against Heroes who report issues in good faith or participate in an investigation. If a Hero feels they have been retaliated against, they should reach out to their manager or to the Compliance Team immediately.
It is essential that all Heroes feel safe when asking questions or raising concerns in order to create and maintain a safe and comfortable work environment. It also gives Delivery Hero the opportunity to deal with issues, should they arise. Silence may worsen a situation and reduce trust.
● If we feel uncomfortable or have a question, we should not hesitate to speak up and raise the issue with our manager or People Partner;
● For all compliance or ethical matters, we turn to our Compliance Team;
● For anonymous reporting of severe compliance breaches, Delivery Hero has set up an anonymous third party whistleblower hotline which is managed by the central Compliance Team.
Delivery Hero's Compliance Portal has a dedicated section to the importance of speaking up. It details the available internal and external channels, including an FAQ on the topic and further explanation on the protection of whistleblowers.
| Human rights | 9 |
|---|---|
| Non-discrimination and equal | 9 |
| opportunities | |
| Safe work environment | 9 |
Delivery Hero respects the dignity and individual rights of its Heroes and all people, and believes that we can play a positive role in the communities in which we operate. We highly regard both the right to freedom of association and the right to engage in collective bargaining in accordance with applicable laws and regulations. We condemn all forms of exploitation and discrimination such as forced labor, child labor and human trafficking.
Delivery Hero stands behind a policy of equal opportunities for all applicants and Heroes regardless of ethnicity, color, gender, gender identity or expression, religion, age, national origin, ancestry, sexual orientation, disability or any other situation in accordance with local laws. We are committed to providing a workplace that is free from discrimination, harassment, intimidation, and abuse.
Delivery Hero is dedicated to providing a safe, supportive, and inclusive work environment where we all feel valued. We respect all applicable laws, rules, practices, and precautions to protect ourselves, our Heroes, and our customers. This includes working free from the influence of any drugs or alcohol that could prevent work activities from being conducted safely. We all have a responsibility to immediately communicate accidents and unsafe practices or conditions to our direct managers.
We want a workplace founded on respect, integrity, and accountability where all employees have the opportunity to reach their best performance - being creative, courageous, and confident. We value our diversity and promote a healthy, supportive, and inclusive work environment.
Delivery Hero has zero tolerance for discrimination and harassment. If any Hero feels like they may have witnessed discrimination or harassment, they should speak up for themselves and others (see page 4, We speak up!).
Our Diversity and Inclusion Team seeks to cultivate an environment of belonging, where different identities are represented, as well as welcomed and celebrated. To learn more about their strategy and projects, check out the Diversity and Inclusion Page.
In case of further questions Heroes can find the Anti-Bullying and Anti-Harassment Guidelines on our Compliance Portal.
13
| Conflicts of interest |
|---|
| Bribery |
| Dealing with authorities |
| Gifts, Hospitality and Entertainment |
| Donations and Sponsoring |
| Financial crimes prevention | 14 |
|---|---|
| Fraud | 14 |
| Economic sanctions | 14 |
At Delivery Hero, we act within the framework of ethics, integrity, and applicable laws, and always in the interest of the company. If a Hero encounters a situation in which competing loyalties could cause them to pursue a personal benefit for themselves, their friends, or family at the expense of Delivery Hero, they are likely in a situation of conflict of interest.
Personal investments or business interests in suppliers, vendors, or competitors are strongly discouraged but may be allowed in limited circumstances with prior written consent of Delivery Hero and if authorized in accordance with labor agreements. The preferential treatment of certain business partners out of private interest is not tolerated.
Working in the same department, being members of the same management team, or being in a position of authority over a close (romantic or familial) relationship can also lead to conflicts of interest which should be disclosed and may require certain re-arrangements.
A Hero's outside business activities must not compete with or reflect adversely on Delivery Hero or give rise to a conflict of interest. Heroes must not engage in any outside activity that is likely to involve disclosure of Delivery Hero's proprietary information or that is likely to divert time and attention from their responsibilities at Delivery Hero.
Many conflicts of interest or potential conflicts of interest may be resolved or avoided if they are appropriately disclosed to the Compliance Team and approved.
When a conflict of interest situation arises, the integrity of Delivery Hero's decision-making process is at risk.
Heroes should:
In case of further questions about situations that constitute conflicts of interest, and their disclosures, Heroes can find our Conflict of Interest Policy on our Compliance Portal or reach out to our Compliance Team.
Bribery refers to the giving or offering of money or other forms of reward to a recipient in order to influence their behavior, which they would otherwise not alter. We do not tolerate any form of bribery or corruption.
To keep our Heroes and the company away from a criminal offense under applicable laws, offering or accepting a bribe in any form, directly or indirectly, is strictly prohibited.
It is important to exercise great care and act with the highest level of integrity when interacting with public officials. In particular, we should never offer directly or indirectly any unlawful benefits, such as money, goods, or other forms of reward, to a public official with the aim to influence their decisions. Please consult with the Compliance Team when interacting with public officials and other public authorities in order to show due diligence in the execution of the company's activities.
Corruption is a serious crime that undermines social and economic development and weakens the fabric of modern-day society. We stand for a world free of corruption and bribery and are strongly committed to compliance with all applicable anti-bribery laws.
Heroes should:
● Keep in mind that benefits of any kind intended to influence decisions are off limits.;
● Be reminded that granting benefits to officials or holders of political office always requires prior permission from their manager and the Compliance team.
● Speak about their concerns with their manager or the Compliance Team.
Our Anti-Bribery and Anti-Corruption Policy, available on the Compliance Portal, outlines the ethical standards for doing business at Delivery Hero worldwide.
As a general rule, in cases where external parties are involved, Heroes should exercise great caution when giving or accepting any gifts, hospitality or entertainment. However, where it is in the best interest of the business, giving or receiving low-value gifts, hospitality or entertainment on behalf of Delivery Hero is permitted.
Heroes must use their best judgment to assess whether they may give or accept a gift in accordance with our Gifts, Hospitality and Entertainment Policy.
Our commitment to society is embodied by philanthropic sponsorship and social activities, including donations to charities and non-profit organizations, as well as other benefits to the community.
Donations and sponsorships shall always be provided pursuant to the terms of the applicable laws, and they shall never be associated, either directly or indirectly, with any unlawful act, or undue advantage for Delivery Hero. No contributions, gifts, or payments may be made on behalf of Delivery Hero to any political party, candidate, lobbying organization, and the like without following the approval process.
To protect our business and ourselves it is essential that we avoid any behavior that raises questions about our integrity and strictly follow all applicable anti-bribery laws.
Heroes should:
● Keep in mind to never give or accept any kind of benefit which may give the impression that they are only doing so to receive or make a favor in return
Delivery Hero's policies on gifts, hospitality and entertainment, as well as, donations and sponsoring are documented in the Business Ethics Policy available on the Compliance Portal.
Delivery Hero is committed to preventing all forms of financial crimes, especially money laundering, terrorist financing, sanctions/trade embargo violations, and fraud. We fulfill our legal obligations to prevent such activities through the implementation of appropriate oversight systems and controls aimed at their detection, disruption and deterrence.
Fraud is an illegal act characterized by deceit, concealment, or violation of trust to secure an unlawful gain. We must all aim to be familiar with the different types of fraudulent behavior that might occur within our area of responsibility at Delivery Hero and speak up when we become aware of red flags. For details about the different types of fraud that can occur and how these should be reported, please reach out to our Compliance Team or read the Anti-Fraud Policy.
Economic sanctions are defined as the cancellation of trade and financial relations for foreign and security policy purposes. Sanctions may be comprehensive, such as prohibiting commercial activity with regard to an entire country, or they may be targeted, such as blocking transactions by and with particular businesses, groups, or individuals. Non-compliance with economic sanctions can have a significant impact on Delivery Hero, from penalties to criminal prosecution or even the designation of the company as a sanctioned party. All employees within the Delivery Hero Group shall be mindful of economic sanctions, especially if they are based in countries targeted by economic sanctions.
All criminal activities behind financial crimes threaten our way of life. To protect our reputation and avoid any possible criminal liability, we need to be vigilant about our business activities and prevent Delivery Hero group products and services from being used for criminal purposes.
It is our responsibility to speak up when we see or notice something that concerns us! Heroes can always reach out to the Compliance Team or submit a report anonymously through Whistleblower Hotline.
In case of further questions Heroes can find Anti-Fraud Policy and Sanctions Policy on our Compliance Portal.
| Market transparency | 16 |
|---|---|
| Selecting suppliers | 16 |
| Fair and free competition | 17 |
| Treatment of inside information | 18 |
Delivery Hero can only establish and maintain the public's confidence, as well as the trust of our various stakeholders, by preparing our accounting and reporting based on generally accepted accounting principles. We therefore diligently comply with all statutory rules for accounting and financial disclosures, and don't tolerate any interference with our financial reporting or any manipulations of our accounts.
We always aim to ensure that our service providers and suppliers follow the same high ethical standards as we do at Delivery Hero. Therefore, we use due diligence when selecting them and ask them to agree to our Supplier Code of Conduct before entering into a commercial agreement.
We are committed to building and maintaining the trust of our investors and other stakeholders and firmly believe in transparency and integrity when reporting our finances and selecting our suppliers.
Heroes can always seek advice
Our procurement guidelines are documented in our Procurement Policy available on the Compliance Portal.
Delivery Hero competes vigorously in the sectors in which it operates but in a manner that is fair, honest, ethical and legal. We conduct our activities in accordance with competition laws that apply within the EU as well as in other countries where Delivery Hero does business. These laws apply to any relationships with competitors, customers, service providers, and suppliers.
Some agreements between competitors risk being anticompetitive and unfair to customers. Delivery Hero complies with competition laws and strictly forbids written or verbal ("gentlemen's") agreements between competitors that reduce competition. For example price-fixing, bid-rigging, allocations of customers or territories, agreements not to deal with third parties...
We aim not to participate in practices that require exclusivity, excessive pricing, "tying/bundling" (conditioning the sale of a product on the purchase or sale of another product), or impose non-competes where these practices are not compliant with local competition law rules.
To avoid practices that may result in allegations of a violation of competition laws, we apply the following rules:
Antitrust and competition laws are designed to encourage and protect free and fair competition in open and transparent markets. Violations of these principles can cause penalties and negative consequences for all of us.
Heroes should remember not to discuss commercially sensitive information with competitors and when unsure they should always align with the Antitrust Team.
The Antitrust Team periodically organizes specific trainings on dawn-raids, the use of language and general antitrust trainings. Heroes interested in attending, can always reach out to the Antitrust Team.
Delivery Hero treats inside information with the highest standards of confidentiality. Inside information is information, which, if it became publicly known, would likely have a significant effect on the company's share price, bonds and derivatives.
As a general rule, we strictly do not undertake or incite insider dealings. Heroes in the possession of inside information must not make use of such inside information when trading with Delivery Hero shares or financial instruments, irrespective of the source of such knowledge.
The misuse of inside information in the market is a criminal offense and hence strictly prohibited. This also applies to inside information relating to other companies which is obtained in the course of work. The Capital Market Team however cannot assess the qualification of such external information as being insider information.
Heroes should ask themselves:
Or reach out to our Capital Market Team.
In case of further questions Heroes can find the Capital Markets Compliance Guidelines and Insider List Guidelines on our Compliance Portal to learn about the rules governing inside information.
| Communications | 20 |
|---|---|
| Company property | 20 |
| Intellectual property | 21 |
| Vouchers | 21 |
| Data privacy | 22 |
| Cyber /Information Security | 22 |
Delivery Hero is excited to communicate transparently and clearly with everyone from employees and customers to shareholders and business partners. However, our corporate reputation is essential to our business success, so whatever form the communication takes, we think carefully about what we want to say.
Heroes should always provide true and accurate information with respect to our business and services. If a Hero is contacted and asked to discuss company business with any members of the press, investors, or market analysts, they should politely advise the outside party that they are not authorized to discuss the subject and refer them to our Corporate Communications Team. Similarly, when using social media, Heroes should let the outside party know that they do not speak on behalf of the company. All Heroes should treat company information with care and confidentiality. We only share company information if we are certain we may, even among co-workers.
To protect the company, Heroes should not disclose any confidential business information to anyone outside Delivery Hero, even to close relationships, unless the disclosure is properly authorized by Delivery Hero in advance or in agreement with a clearly defined, legitimate business need.
We handle Delivery Hero's resources and equipment with care. Company assets are only to be used for explicit business purposes.
We take our responsibilities to all our stakeholders seriously and do our best to protect the company and its business assets and information.
Heroes can always contact our Corporate Communications Team when they are unsure whether any intended social media post meets the company criteria or not.
In case of further questions Heroes can find the Media Relations, Social Media and Conference Policy is available on our Compliance Portal.
We protect Delivery Hero's property which includes intellectual property, business strategies, financial data, and other confidential information, as well as physical assets. Our ideas, inventions, innovations, and technical know-how are at the heart of our delivery platforms, which makes them extremely valuable assets.
During their employment or service, Heroes may create intellectual property such as works or products, including code, images, designs, marketing materials, and documents. This intellectual property belongs to Delivery Hero and is only used as advised and for the benefit of the company.
Heroes are always welcome to use staff discounts and vouchers for online food ordering, but only in the way intended. This means that we do not hand out staff discounts or company vouchers we receive from Delivery Hero to someone else on the staff or someone we know privately because they are non-transferable. However, Heroes can place an order from their accounts to treat friends or family members.
We always do our best to protect our intellectual property, while treating confidential information belonging to others with the same respect.
Heroes should ask themselves:
Unsure if you can share information? Reach out to our Intellectual Property team.
Want to know more about Delivery Hero vouchers and benefits? Visit the Delivery Hero Benefits Website.
We are aware of the highly sensitive nature of our customers', employees', shareholders', and suppliers' personal data, and handle all such information with the utmost confidentiality and care to protect it in compliance with applicable laws. A variety of technical and organizational measures, aimed at ensuring the confidentiality of personal data, support us in these efforts. We are responsible to ensure high standards of data protection and follow the policies intended to protect Delivery Hero's information.
We respect the extensive rights of those individuals whose data we are collecting, processing and using. Delivery Hero places the highest importance on maintaining data security, as this has a significant influence on business success and the company's image among the general public.
We protect the company, customer and employee data with all reasonable and appropriate technical and organizational measures to safeguard our data from different threats. For this reason Heroes take care to:
When data that should be kept private gets in the wrong hands, bad things can happen. A breach at our organization can put proprietary data in the hands of a competitor or fraudulent entities.
If a Hero suspects a data breach is happening or becomes aware of any situation in which data could be compromised, including the loss or theft of a laptop or handheld device, the issue should be reported to the Cyber Security Incident Response Team (CSIRT) without delay.
If the breach is related to personal data, Heroes should reach out to the Data Protection Team.
In case of further questions Heroes can find the Group Data Protection Policy and Information Security Policy on our Compliance Portal.
Delivery Hero SE, Compliance Team, Email: [email protected]
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