Acting ethically

We strive to work with honesty and integrity, according to the highest ethical and legal standards. With respect for each other and those with whom we do business.

Code of Conduct

In our company, we work together with many thousands of people, for a multitude of customers. In order to know from each other how we want to work together, it is important that we have common rules of conduct, laid down in a code of conduct. Such a code of conduct gives direction to our daily activities and describes which rules apply within our company: formal, informal and ethical. We launched our updated code of conduct in January 2019.


During the year, all our people received training on behaviour and ethical conduct, where they learned about:

  • privacy

  • anti-bribery and anti-corruption

  • competition law

  • security

  • health and wellbeing

  • the code of conduct

Every two months, we focussed on a topic from the code of conduct that included posters, articles, discussions on Yammer (similar to Twitter, but only for employees), training courses and team meetings.

The Privacy, Risk & Compliance Team saw that awareness of ethical behaviour increased through these activities. This was reflected, among other things, in a higher number of reports and requests for advice. We use the feedback from our people to further develop communication and training about ethical conduct.

  • Almost 95% of our people have completed the modules on the code of conduct. We are also making it compulsory for every external person we hire to follow the training modules.

  • Training hours: corporate 4000 x 2.5 hours and customer-facing 4,500 x 0.5 hours

Whistleblower Procedure

The code of conduct also indicates how internal and external employees should act if they suspect malpractices or violations are taking place. An important factor in this respect is that they feel safe to report such matters. We encourage them to do so, and promise to protect everyone who acts in good faith.

We offer our people different ways to report a complaint if they suspect wrongdoing. In 2019, we saw an increase in reports, as we focussed on this topic and had internal discussions about it. We also saw an increase in the quality of incident reports. Each notification contains more information so that we can better assess the consequences and the priority. This, in turn, means we can act faster and more efficiently. We safeguard the necessary information. The quality of the reviews is better. The disciplinary measures resulting from the reviews range from a warning to instant dismissal.