Introduction
At Dansk Audit Institut (DAI), we work as an accredited certification body conducting independent audits and certifications in accordance with international standards, including ISO/IEC 27001. Our services help organizations document compliance with recognized standards and thereby strengthen confidence in their management systems. This is a responsibility we take very seriously.
We aim to be a responsible, reliable, and environmentally conscious company, towards our customers, shareholders, employees, suppliers, partners, and the society in which we operate. We want to build and maintain trust with all our stakeholders, and we conduct our business in a responsible, ethical, and lawful manner in compliance with national and international requirements as well as accreditation regulations.
To support this, we have developed this Code of Conduct (CoC), which sets out the principles we wish to promote within DAI together with our employees. The CoC establishes how we treat each other, how we deliver our services to customers, and how we interact with other stakeholders such as suppliers, partners, tax, and regulatory authorities. It also describes the principles that reflect our commitment to good corporate governance.
DAI follows the UN Global Compact principles as an integral part of our business operations. The CoC is approved annually by the Executive Board.
Purpose and Scope
The purpose of this Code of Conduct is to define DAI’s overall level of responsibility and goals in key areas. The purpose is not to regulate every specific detail – this is done through internal policies and guidelines. The Code of Conduct applies to all employees, suppliers, freelancers, and everyone acting on behalf of DAI, including the Board of Directors.
It is the responsibility of employees, suppliers, freelancers, and everyone acting on behalf of DAI to read, understand, and comply with the principles in the Code of Conduct. Violation of the principles may expose DAI to reputational damage as well as legal and regulatory sanctions. In the event of a violation of the principles in the Code of Conduct, the behavior must be stopped immediately. Improper business practices or direct violations of the principles must be reported to company management. We also expect all our business partners to comply with the same principles.
Business Principles
DAI has established a set of business principles to ensure compliance with our Code of Conduct. Compliance with laws and regulations is central. It is DAI’s goal to always comply with applicable local laws and rules, as well as requirements from EU regulations in all our activities, products, and services. This means that DAI’s management systems and processes are continuously adapted, updated, and developed in line with applicable legal requirements and business needs.
Pricing
We have established guidelines and procedures, including control processes, for pricing to ensure that only relevant criteria are used. We do not use an individual customer’s marital status, religion, race, or ethnic background as a pricing factor. Our pricing is transparent, and it is always clear to our customers what they will pay.
Communication
Customer communication focuses on ensuring transparent, balanced, and easily understandable information. No information is hidden or written in fine print, and we strive to ensure that all marketing and product materials are professional, comprehensive, accurate, balanced, and not misleading. We ensure transparency and a fair case-handling procedure with customer-centric focus.
ESG
ESG is integrated into investments. It is DAI’s position that environmental, social, and corporate governance (ESG) factors affect long-term results, risk, and value for all companies. Therefore, ESG factors are integrated into our investment activities, both in relation to investment analyses, decision-making processes, reporting, and active ownership.
Data and Privacy Protection
At DAI, we collect general information and personal data. We only collect data for specific and legitimate purposes. Data is not sold, and the customer always has access to their collected information. Data is only stored as long as necessary. We comply with the General Data Protection Regulation (GDPR). We ensure that data is stored and processed in a way that does not compromise the customer’s right to privacy.
Data Ethical Governance
Data ethics encompasses the moral responsibilities related to the collection, protection, and use of personally identifiable information and how it impacts individuals. Data ethics governance is part of DAI’s overall governance, and we strive to ensure that ethics are incorporated into all decisions as well as day-to-day operations.
Working with Data
When working with data, we follow the “5 Principles of Data Ethics for Business Professionals”.
- Ownership
The first principle of data ethics is that an individual owns their personal information. Just as taking an item that doesn’t belong to you is considered theft, it is both illegal and unethical to collect someone’s personal data without their consent.
- Transparency
In addition to owning their data, individuals have the right to know how it will be collected, stored, and used. When gathering data, you must act transparently.
- Privacy
Another ethical responsibility when handling data is safeguarding the privacy of data subjects. Even if a customer grants permission to collect, store, and analyze their personally identifiable information (PII), it does not mean they want it to be publicly accessible.
- Intent
When discussing any matter of ethics, intent matters. Before collecting data, you must ask yourself why you are doing it, what you aim to achieve, and what changes you expect to make with the insights gained. If your intent is to exploit others, take advantage of your subjects’ weaknesses, or pursue any harmful purpose, it is unethical to collect their data.
- Outcomes
Even with good intentions, data analysis can unintentionally harm individuals or groups. This is referred to as disparate impact and is recognized as unlawful under the Civil Rights Act.
We Use Artificial Intelligence Responsibly
At DAI, we use artificial intelligence to support our daily work, for example, to assess risks or manage work processes. This helps us provide our clients with a good and efficient experience. To ensure the responsible use of artificial intelligence, we follow five ethical principles:
- Care: AI must be developed and used with caution and respect.
- Professional Security: AI should be used within a defined framework, grounded in the latest technological knowledge and subject to rigorous testing.
- Reliability: AI must be trustworthy, fact-based, and free from bias.
- Transparency: AI must be understandable, and models should only be used for their intended purposes.
- Data Security: AI must comply with data protection laws and be safeguarded against cybercrime.
Cyber and Data Security Requirements
At DAI, we take data protection and cybersecurity seriously. We have established procedures, control systems, and technologies to ensure the confidentiality, integrity, and availability of information. Both data protection and cybersecurity are integrated factors in DAI’s security efforts. We place great emphasis on the protection and handling of information and on strengthening the company’s data and cybersecurity, which must always be at a high level for both employees and external partners.
We regularly carry out risk assessments and contingency planning. In addition, we have internal procedures that result in a high level of security in applications, systems, and infrastructure. We recognize the risks associated with data protection and cybersecurity. Therefore, we ensure that employees receive adequate training. All existing and new employees are required to complete e-learning to achieve knowledge and focus on data protection and cybersecurity. To confirm our commitment, the company must at a minimum comply with ISO27001 and ISO27701 standards.
Tax Obligations
DAI always strives to comply with all applicable tax laws, rules, and regulations in every jurisdiction in which we operate. The company pays taxes in the country where its actual business activities take place. All taxes are paid on time. We do not engage in aggressive tax planning or tax structuring aimed at artificially reducing the group’s taxable income. In tax matters, we ensure that our subsidiaries operate within the legal and regulatory frameworks for planning and reporting taxable income. The financial results of the group companies are always reported according to local laws and recognized accounting principles.
Business Ethics
We avoid conflicts of interest. DAI’s employees, suppliers, and partners are expected to act in the best interest of DAI. No employee may use their position to promote their own interests. In situations where personal interests conflict with DAI’s interests, the employee is obligated to defer the decision to a person not in conflict with DAI’s interests.
Prevention of Money Laundering and Terrorist Financing
DAI always complies with legislation on the prevention of money laundering and terrorist financing, including UN and EU regulations on increased risk and financial sanctions. Our goal is to actively contribute to preventing money laundering and terrorist financing, avoid being misused for money laundering or terrorist financing, and maintain a strong reputation in relation to preventing and combating money laundering and terrorist financing. We do not accept corruption or bribery.
DAI aims to be part of a professional, proper, and trustworthy business environment. Therefore, we do not accept gifts or benefits that could influence or appear to influence individual and/or business decisions or the motives and interests of our business activities. We expect that all employees, customers, suppliers, and other partners act according to the same principles. Employees may only accept gifts or benefits from third parties if appropriate, based on a legitimate business reason, and correctly registered.
Fair Competition
It is our policy to compete in compliance with all applicable antitrust and competition laws wherever DAI conducts business. We treat competitors with respect and appropriate behavior in competitive situations. We do not engage in price-fixing agreements or market-sharing agreements with our competitors.
Human Rights and Labor Practices
Respect for Human Rights
At DAI, we are committed to complying with applicable laws on human rights, labor rights, and employment conditions. We respect internationally recognized human rights and the UN Global Compact principles on human rights. Our aim is not to violate these principles and conventions. This applies to our business operations, supply chain, products, and investments.
We Do Not Tolerate Discrimination
At DAI, we respect the human rights of each individual, and we do not tolerate any form of discrimination, bullying, or harassment, including sexual harassment. All employees are treated fairly and equally, regardless of age, ethnic background, sexual orientation, disability, health, political affiliation, or race.
DAI seeks to be a diverse workplace – a workplace where diversity is accepted and considered a strength. We therefore work to maintain and develop openness to counteract any form of discrimination and to ensure equal opportunities for all. We do not tolerate discriminatory practices in recruitment, job assignments, promotions, compensation, or other benefits, nor in general workplace behavior.
High Standards for Health and Safety
At DAI, we maintain high standards for both physical and mental health and safety. Our goal is to minimize work-related accidents and illnesses as well as reduce sick leave as much as possible. In addition, employees are required to take all reasonable precautions to maintain a healthy and safe working environment to avoid personal injury or endangering others.
We aim to promote employee engagement, health, job satisfaction, and professional development. This includes development of management practices, support for competence development, and ensuring a safe and healthy working environment.
Right to Freedom of Assembly and Association
At DAI, employees have the right to freedom of assembly and association in the workplace, and they are free to choose to be members of organizations in accordance with Danish law. Trade unions recognized as negotiation partners and parties to general agreements in the field may participate in collective bargaining. Employees serving as representatives will not be treated worse than other employees.
We Do Not Accept Child Labor
At DAI, we have zero tolerance for all forms of forced labor and child labor, which we strongly condemn. We are committed to exercising due diligence and care and have procedures in place to avoid directly or indirectly contributing to forced labor or child labor, for example, through our supply chain or investments. We are also committed to contributing to the elimination of such practices if we become involved in them.
Environment and Climate Change
At DAI, we always strive to comply with current laws and regulations on environmental protection and the prevention of climate change.
Furthermore, we strive to:
- Improve our climate and environmental performance and integrate climate and environmental considerations into our business operations and activities.
- Reduce resource consumption (e.g., energy, water) and promote the efficient use of these resources.
- Reduce pollution, CO₂ emissions, and waste resulting from business activities.
- Promote and implement initiatives to foster greater environmental responsibility and a sustainable future—for example, by focusing on recycling and repair.
We aim to raise awareness of climate and environmental issues, educate employees, and encourage participation in any event organized by DAI. We encourage customers, suppliers, and other business partners to adhere to similar climate and environmental responsibilities.
Whistleblowing
DAI uses the national whistleblower reporting system at https://whistleblower.dk/ , allowing anyone to report unlawful behavior. All whistleblower reports are investigated promptly and confidentially, and whistleblowers are protected. If you observe inappropriate business or personal conduct by one of our employees that may represent a potential or actual violation of this Code of Conduct and its principles, you are encouraged.
