Code of Conduct

Organizational Code of Conduct:

Delcon and its employees must, at all times, comply with all applicable laws and regulations. Delcon will not condone the activities of employees who achieve results through violation of the law or unethical business dealings. This includes any payments for illegal acts, indirect contributions, rebates, and bribery. Delcon does not permit any activity that fails to stand the closest possible public scrutiny.

All business conduct should be well above the minimum standards required by law. Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing Delcon’s operations.

Employees uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor, who, if necessary, should seek appropriate legal advice.


General Employee Conduct:

Delcon expects its employees to conduct themselves in a businesslike manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job.

Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials on their computer.


Conflicts of Interest:

Delcon expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of Delcon. Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage. Regardless of the circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to their supervisor.


Outside Activities, Employment, and Directorships:

All employees share a serious responsibility for Delcon’s good public relations. Their readiness to help with charitable, educational, and civic activities brings credit to Delcon and is encouraged. Employees must, however, avoid acquiring any business interest or participating in any other activity outside Delcon that would, or would appear to:

  • Create an excessive demand upon their time and attention, thus depriving Delcon of their best efforts on the job.
  • Create a conflict of interest - an obligation, interest, or distraction - that may interfere with the independent exercise of judgment in Delcon’s best interest.


Relationships with Clients and Suppliers:

Employees should avoid investing in or acquiring a financial interest for their own accounts in any business organization that has a contractual relationship with Delcon, or that provides goods or services, or both, to Delcon if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of Delcon.


Gifts, Entertainment, and Favours:

Employees must not accept entertainment, gifts, or personal favours that could, in any way, influence, or appear to influence, business decisions in favour of any person or organization with whom or with which Delcon has, or is likely to have, business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with Delcon might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.


Kickbacks and Secret Commissions:

Regarding Delcon’s business activities, employees may not receive payment or compensation of any kind, except as authorized under Delcon’s business and payroll policies. In particular, Delcon strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others. Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law.


Organization Funds and Other Assets:

Employees who have access to Organization funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in Delcon’s policies and procedures or other explanatory materials, or both. Delcon imposes strict standards to prevent fraud and dishonesty. If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that Delcon can promptly investigate further.

When an employee’s position requires spending Organization funds or incurring any reimbursable personal expenses, that individual must use good judgment on Delcon’s behalf to ensure that good value is received for every expenditure.

Organization funds and all other assets of Delcon are purposed for Delcon only and not for personal benefit. This includes the personal use of organizational assets, such as computers.


Organization Records and Communications:

Accurate and reliable records of many kinds are necessary to meet Delcon’s legal and financial obligations and to manage the affairs of Delcon. Delcon’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.

Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:

  • False expense, attendance, production, financial, or similar reports and statements
  • False advertising, deceptive marketing practices, or other misleading representations


Dealing with Outside People and Organizations:

Employees must take care to separate their personal roles from their Organization positions when communicating on matters not involving Organization business. Employees must not use organization identification, stationery, supplies, and equipment for personal or political matters.

When communicating publicly on matters that involve Organization business, employees must not presume to speak for Delcon on any topic, unless they are certain that the views they express are those of Delcon, and it is Delcon’s desire that such views be publicly disseminated.

When dealing with anyone outside Delcon, including public officials, employees must take care not to compromise the integrity or damage the reputation of either Delcon, or any outside individual, business, or government body.


Prompt Communications:

In all matters relevant to customers, suppliers, government authorities, the public and others in Delcon, all employees must make every effort to achieve complete, accurate, and timely communications - responding promptly and courteously to all proper requests for information and to all complaints.


Privacy and Confidentiality:

When handling financial and personal information about customers or others with whom Delcon has dealings, observe the following principles:

  • Collect, use, and retain only the personal information necessary for Delcon’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
  • Retain information only for as long as necessary or as required by law. Protect the physical security of this information.

Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation


Declaration of Conflict-Free Minerals

Delcon Oy does not to purchase and refuse to use conflict minerals, or their derivatives that may directly or indirectly finance or benefit armed groups through mining or mineral trading in the Democratic Republic of Congo (DRC) or an adjoining country. “Conflict Minerals" are metals such as gold (Au), tantalum (Ta), tungsten (W) and tin (Sn) derived from minerals being sourced from mines in Democratic Republic of Congo (DRC) or an adjoining country (conflict areas) which are controlled by non-government military groups, or unlawful military factions the coverage on human rights violations in the Democratic Republic of the Congo (DRC) and environmental issues resulting from the extraction of minerals.

Delcon Oy herein declares that the products, materials are DRC Conflict-Free.

Economic Sanctions

The management of Delcon Oy complies with all the requirements of economic sanctions set by the Finnish Government and the EU's Executive Board in all circumstances. The situation will be monitored actively from State Department bulletins and from