Introduction
All employees including Directors of DPD Ireland are required to perform the duties and activities of their position with the highest level of integrity and independence, in a professional and ethical manner. They must also ensure that they avoid or eliminate any conflict of interest or situation that could reasonably be perceived as a conflict of interest and immediately report it to their manager.
Although this policy details certain behaviours that may lead to a conflict of interest or the appearance of a conflict of interest, it is impossible to anticipate all situations that could lead to one. Employees may also inadvertently find themselves in a situation that leads to or could be perceived as a conflict of interest; these situations must also be disclosed.
Compliance with this policy is a condition of employment. Failure to comply with these provisions may result in disciplinary action, up to and including termination of employment.
Purpose and Scope
This policy applies to all employees of DPD Ireland as well as contractual third parties or partners doing business with the company. All are expected to abide by the provisions of this policy that are reasonably applicable to them.
Definition of a Conflict of Interest
A Conflict of Interest is a situation in which a person has a personal interest that is likely to or that can affect or appear to affect the independent, impartial and objective exercise of their professional activities. The personal interest (economic, emotional, political, financial, etc.) may be direct or indirect and may concern the person and/or their close relations.
In the performance of their duties, the Concerned Person might be likely to take a decision potentially influenced by interests other than those of the company for which they work.
This situation is not in itself reprehensible. A Conflict of Interest is not an offence by itself but may facilitate the commission of illegal practices.
However, the existence of such interests may be problematic and may require the implementation of measures to remedy the potential or actual Conflict of Interest to avoid breaching internal procedures of the company and, where appropriate, exposing the Concerned Person to disciplinary sanctions and/or damaging the reputation of DPD Ireland.
Thus, the Policy is first a support tool for each Concerned Person, in order to deal with situations of potential or actual Conflict of Interest that they may encounter in the course of their professional activity within the company.
Action or Behaviours to Avoid
Below, you will find some situations, behaviours or events that should be avoided at all costs by employees, managers or other contractual third parties doing business with the company
Personal Interest
Employees must ensure that no conflict exists or could appear to exist between their personal interests and those of DPD Ireland, potential competitor, customer, partner, vendor, supplier or other business entity in which you have a direct or indirect financial interest.
Employees must not -
Take part in or attempt to influence any DPD Ireland decision or any business dealings with a current or potential competitor, customer, partner, vendor, supplier or other business entity and which you have a direct or indirect financial interest ;
Use the premises, equipment, supplies or services of other employees of DPD Ireland to promote their personal interests;
Use confidential information for their personal benefit during or after employment with DPD Ireland;
Be in a position where they could benefit directly or indirectly from a DPD Ireland business transaction ( e.g. supplier of goods or services, contract, licence or partnership);
Give preferential treatment to any supplier or other person doing business with DPD Ireland in order to serve their personal interests;
Invest in, own, have an interest in, or be an employee of an organisation that might have an interest, direct or indirect, in any DPD Ireland commercial transaction, except in the case of a widely held public company whose dealings with DPD Ireland do not represent a substantial portion of its total business.
This should not be interpreted as an exhaustive list of all circumstances that could lead to a real or perceived conflict of interest.
Family, Friends and Romantic Relationships
Employees and managers must not:
Use their position or contacts at DPD Ireland to promote their personal interests or those of a family member or person with whom they have a close personal or professional relationship;
Take part in or attempt to influence any DPD Ireland related decision or business dealings (including those concerning current or potential customers, partners, vendors or suppliers) that may benefit or appear to benefit a relative, close personal friend or a business enterprise in which a relative or close personal friend is involved or has a direct or indirect financial interest;
DPD Ireland generally does not permit work situations where a manager directly or indirectly manages a relative or a person with whom he/ she has a romantic relationship. If you are aware that DPD Ireland plans to hire your relative or a person with whom you have a romantic relationship for a position that directly or indirectly reports to you, you must disclose that information immediately
If, during the course of your employment, a romantic relationship develops between you and another DPD Ireland employee within your direct or indirect reporting chain, you both must promptly disclose that information. Although employees involved in a consensual relationship are individually responsible for disclosure, a manager's failure to report such a relationship will be grounds for appropriate disciplinary action
** Please refer to ‘Personal & Family Relationships At Work’ policy
Relationships and Favouritism
Employees shall not grant or appear to grant preferential treatment to a person with whom they have a close personal or professional relationship. In some situations, past relationships may also give rise to a perceived conflict of interest and should be treated as such.
If an employee is in a situation where they could make a decision (e.g. hiring, evaluation, discipline, promotion, reward, any other form of discretionary control or the awarding of a contract) involving, directly or indirectly, a person with whom they have a close personal or professional relationship, the employee must:
Disclose the potential conflict to his/her manager
Refer the decision to the manager or someone designated by him/her
Refrain from making any recommendations or conveying views related to the decision
In addition, if an employee is in a position of authority over a person with whom they have a close personal or business relationship, the manager must change the hierarchical relationship between the employee and that person. The manager may also take other measures to reduce the appearance of conflict of interest, if necessary
** Please refer to ‘Personal & Family Relationships At Work’ policy
Outside Business Activities
Employees are permitted to engage in outside employment or activities as long as they inform their manager prior to starting such activity, and to the extent that -
it does not compete with or reflect adversely on DPD Ireland or give rise to a conflict of interest;
it does not engage in any outside activity that is likely to involve disclosure of DPD Ireland’s proprietary information or that is likely to divert time and attention from your responsibilities at DPD Ireland;
it could not be reasonably perceived as compromising the integrity, independence and impartiality expected from DPD Ireland or bring DPD Ireland into disrepute;
it does not inappropriately exploit the employees connection with DPD Ireland;
it does not restrict your availability or efficiency;
it does not involve acting as a spokesperson for another organisation.
Employees are permitted to act as board members of an organisation external to DPD Ireland, if their participation meets the criteria, and if authorised by their manager beforehand. You cannot serve as a board member or technical adviser of a competitor or of a company that may reasonably be expected to become a competitor
Employees may be permitted to write books or work on other creative projects that are not in competition with DPD Ireland as long as they respect the criteria for outside activities as mentioned above and obtain prior written authorisation from their manager
You are not required to seek approval for the following activities -
Any affiliation with a Trade Association, Professional Association or such organisation related to your work or position at DPD Ireland. All memberships of such associations must be recorded in the “Trade Association & Society Memberships” Log. Please contact your manager to arrange access to this log;
Participation in non-profit Civic or charitable activities, including serving as a member of a board of directors or technical advisory board. However, you must obtain approval if the entity is a DPD Ireland customer or expect to receive or seek a contribution from DPD Ireland;
Positions with co-op boards and similar entities where the sole purpose of such participation would be to hold title to and/or manage real property in which you can or do reside;
Positions with holding companies, trusts or other non-operating entities established solely for purposes of you or your family's investment, estate or tax planning or to hold you, your family's property or other Investments that would not otherwise require disclosure under this policy.
If the manager considers the outside activity to be inappropriate, considering the criteria mentioned above, they must inform the employee in writing and the employee must avoid, discontinue or modify their participation in such activities accordingly. Disclosures and their assessment by the manager must be documented.
Gifts, Hospitality & Other Benefits
Accepting a gift, a benefit or another offer of hospitality for oneself or for a colleague, family member or friend can lead to uncomfortable situations or to real or perceived conflicts of interest.
Please refer to ‘Hospitality & Gifts’ policy’ for more details
Examples of Conflicts of Interest
In the course of their professional activities, Concerned Persons may be confronted with various instances of potential or actual Conflicts of Interest.
The following measures could be put in place to address Conflicts of Interest and subsequent risks.
Example 1 – Hiring a Relative
A BU is looking for a Marketing Manager. HR has selected three job applications and forwarded them to the Marketing Director. HR learns that the Marketing Director is receiving two additional candidates, including his son-in-law.
How shall the Marketing Director act in such a situation?
The Marketing Director shall disclose, as soon as possible, his family relationship to his Line Manager and to HR
The Marketing Director shall withdraw from the recruitment process
Example 2 – Transport Company
A family member of the Concerned Person has just been recruited by a transport company with which DPD Ireland works regularly. In the course of their activities within the company, the Concerned Person has access to confidential information likely to be of interest to said transport company.
How should the Concerned Person act in such a situation?
the Concerned Person shall notify their Line Manager as soon as they are informed of their family member’s new position
the Concerned Person shall not disclose confidential information to their family member.
How should the Line Manager act in such a situation?
The Line Manager shall remind the Concerned Person not to disclose confidential information to their family member;
Depending on the situation, the Line Manager may consider changing the Concerned Person’s position, in conjunction with HR.
Declaring a Conflict of Interest
Employees are required to declare any Conflict of Interest immediately, as soon as it arises. Declarations can be made by completing the Conflict of Interest Declaration form which is submitted to the Ethics Officer for consideration.
Appendix 1
Appendix 2
CG Doc No. 3 Issue 2.0
Issue date: 1st February 2024
Revision date: 15th January 2025
Documented by: Jess Lumley
Approved: Patricia Lennon