Ethics and Business Conduct
Dana is committed to doing business in an ethical manner and with respect for our people and the communities in which they live. We believe that this commitment will benefit our customers and other stakeholders affected by Dana’s activities. For many reasons, it is, quite simply, the right thing to do. We recognize, however, that Dana is but one link in a supply chain to the end user that is long and global. Therefore, it is essential that our suppliers also understand and appreciate the standards of business conduct that are expected of any company that does business with Dana.
This Guide identifies our expectations concerning business conduct that are essential for companies that do business with Dana. We also believe that these Standards will serve to advance the performance of our companies to our mutual benefit. Therefore, compliance with Dana’s Supplier’s Business Conduct Guide is a mandatory component of all Dana purchase contracts.
We appreciate your thorough review of the standards set forth in this Guide.
Respect for People
We expect every Dana supplier to abide by all applicable employment laws. We believe every person should determine for his or herself whether employment is in his or her best interests. We believe that children should not be placed in a position of making this determination. Therefore Dana will not allow the use of labor by children under the age of sixteen unless as part of a government authorized job training or apprenticeship program that would clearly be beneficial to the individuals participating. We expect that our suppliers will not use of any forced or involuntary labor in any form, including human trafficking or physically abusive disciplinary practices.
Dana also expects its suppliers to provide employee wage and benefit levels that satisfy basic needs in light of local conditions. We also expect suppliers to abide by all applicable laws related to limits on regular and overtime working hours and compensation. And, we expect our suppliers to respect freedom of association of its employees in accordance with local laws.
Safe and Positive Workplace
We believe that a diverse workforce fosters creativity and enthusiasm. We expect our suppliers to encourage a positive and diverse workplace by not tolerating harassment or discrimination, including that involving race, color, religion, sex (including pregnancy, child birth or related medical conditions), national origin, age, disability, sexual orientation, gender identity, or any other basis protected by law.
Dana also expects its suppliers to provide its employees with a safe and healthy work environment and to abide by all applicable health and safety laws.
Environmental Protection and Product Content
We expect that our suppliers will abide by all local environmental laws and regulations. In addition, we believe that Dana suppliers should work to minimize waste, prevent pollution, and conserve energy. We also encourage our suppliers to seek external verification concerning their environmental performance, such as through the ISO 14001 certification process. Dana suppliers are expected to use materials that conform to all legal and regulatory requirements and which also satisfy Dana’s product content rules identified in our Supplier Quality Manual. Dana is also committed to adherence with “End of Vehicle Life” and “Registration, Evaluation, Authorization, & Restriction of Chemicals (“REACH”) requirements. Dana suppliers are expected to cooperate fully with Dana to satisfy these and other recycling and environmental and health protection initiatives.
Conflict Minerals and Other Product Origin Obligations
Dana is committed to compliance with U.S. laws related to use of “conflict minerals”. As a Dana supplier, you are expected to respond to all requests for information related to product content and origin.
When requested, you are expected to provide information related to product content and about country of origin Dana suppliers are expected to take all reasonable safety measures in connection with the design and manufacture of products it sells to Dana. It is the obligation of every Dana supplier to inform Dana immediately if a question concerning safety of a product sold to Dana arises.
Gifts, Favors and Entertainment
Dana will select its suppliers on the basis of total value, including quality, price and services offered. Therefore, suppliers should not give gifts, favors or entertainment to Dana people that is of significant value (greater than $100) or that is inappropriate or unbecoming to Dana employees. Dana employees are required to adhere to a corporate policy governing gifts and entertainment. You must not try to unfairly influence a Dana employee through inappropriate gratuities. Ask your Dana contract representative if any potential gift or entertainment is allowable under Dana’s policies. And, if a Dana person solicits you for a gift or a favor, you should report that matter to the Dana Office of Business Conduct.
It is Dana policy that bribes, kickbacks, or other improper payments may not be offered or paid directly by or on behalf of Dana anywhere in the world to any officer, agent or employee of any customer, supplier, or competitor, or to a third party if you know or have reason to suspect that any part of the payment will be given or offered as a part of an improper payment. This includes, but is not limited to, payments to government officials. If you are acting on Dana’s behalf in any manner, you must comply with this policy. If you are performing services for Dana, you may be required to certify and provide evidence of your understanding and compliance with this policy.
Negotiating Fairly and Honestly
Information which you give to Dana during the course of negotiations or otherwise must be accurate. You must not attempt to improperly influence the course of negotiations through any deceptive means. You must abide by all laws and regulations that may affect our business together, including laws related to fair competition and trade practices.
Good Ethics is Good Business
As we do business together, we believe that adherence to the above principles will serve both of our companies well. If you have any questions concerning whether particular conduct related to your supply of goods or services to Dana is appropriate, we invite you bring that matter to the attention of your business contact at Dana. He or she will provide assistance or will seek additional guidance as appropriate.
Questions and Concerns
If you have any questions or concerns related to any of the matters identified in this Guide, please contact your Dana Purchasing representative or you may contact Dana’s Office of Business Conduct in the USA at 1-877-261-2560 or at DanaOfficeofBusinessConduct@dana.com.