Anti-Trust Charter

Why this Charter?

De Haan is taking a clear stand against cartels, which restrict competition among suppliers to the detriment of customers. De Haan pledges to abide by the highest ethical standards and to free and fair competition. The Anti-Trust Charter is a declaration of commitment and covers their employees (whether permanent, fixed-term or temporary) and any associated third parties providing services to or on behalf of De Haan.
The Anti-Trust Charter will be integrated into the FAIM quality standard.

What is a Cartel?

A cartel is an agreement, concerted practice or conspiracy among competitors to fix prices, submit collusive tenders, divide or share markets and, more generally, restrict competition.
A cartel is regarded as the most egregious violation of Anti-Trust laws in most jurisdictions, which may lead to the imposition of significant fines as well as, in certain jurisdictions, criminal penalties.

Zero Tolerance Policy

Involvement in a cartel is unacceptable. It is against De Haan’s core values of competing freely and fairly, based on the added value of our products and services.
The laws and regulations that sanction cartel conduct are in place in most jurisdictions. These laws and regulations are designed to promote free and fair competition and to protect customers.

Charter Statement

De Haan commits to legal and ethical behavior, and to refrain from engaging in any business that will harm the interest of our company, FIDI, other affiliates, clients, or the industry. De Haan will take steps to ensure they are fully informed of applicable Anti-Trust laws and regulations in connection with cartel conduct and other Anti-Trust violations, and will monitor their employees and business partners to ensure full and continual compliance.

Legal Compliance

De Haan will ensure that they are aware of all applicable laws and regulations covering anticompetitive practices in all the jurisdictions in which they operate, and that they will obey and uphold those laws and regulations.
De Haan will ensure they are aware of, and are complying with, applicable laws and regulations in connection with cartels.

Ethical behaviour Statement

De Haan pledges to take a zero-tolerance approach to cartel conduct. At all times, De Haan will act professionally, fairly and with the utmost integrity in all business dealings and relationships. Ethical standard will apply wherever De Haan operates.

Code of Conduct - commitment to the values of De Haan

By agreeing and committing to this Charter, everyone undertakes to:

1. Never make direct or indirect (via third parties including agents, suppliers or customers) contact with an actual or potential competitor or other third party, the object of which is to engage in cartel behavior.
2. Never propose or reach an agreement, whether directly or indirectly, formally or informally, with actual or potential competitors, regarding any sensitive competition-related issues, including:

• Fixing prices
• Dividing or sharing markets, customers or territories
• Rigging a competitive bidding process

3. Report any indication or initiative of improper anticompetitive business conduct by an actual or potential competitor in accordance to your internal reporting procedure, including but not limited to, reporting to your legal department and/or to the relevant Anti-Trust authorities.
4. Not to participate in a meeting of a trade association in which sensitive competition-related issues are discussed. If such subjects are raised during a meeting, employees of De Haan must immediately ask for the discussion to end. If not, they must leave the meeting and ask for that to be noted in the minutes of the meeting.
5. Ensure that all internal and external correspondence, including e-mails and texts, and documents, discussions and public statements do not contain any statements that might be misinterpreted by third parties or Anti-Trust authorities and courts in the context of a potential Anti-Trust investigation.
6. Maintain independent judgement in pricing or selling of any products and/or services.
7. Limit any information discussed during commercial negotiations, with or disclosed to competitors or other third parties, to that which is strictly necessary for completing or assessing the transaction.

 Monitoring and Enforcement

• Employees can find this policy in our Quality Manual “KAM handboek” (Chapter: Werkvoorschriften).
• The KAM and Facility Manager will review the policy as needed and make any revisions necessary.
• Periodic reminders of this policy will be provided to all employees (at least once per year).
• If De Haan makes any changes to its Anti-Trust Charter this will be updated in the Anti-Trust Charter on their website by means of a hyperlink. In this way customers, suppliers, business contacts, employees, and other people De Haan has a relationship with, will always be able to follow the latest Anti-Trust Charter.

In case of any Anti-Trust complaints these can be reported directly to our KAM and Facility Coordinator at phone: +31-78-6920333 or email: quality@dehaan.nl, attn. KAM and Facility Coordinator.