The purpose of this Code of Ethics is to establish the standards of conduct that should guide the daily work of DIKAR S. Coop employees in their relationships with its stakeholders, including:
The provisions of this Code of Ethics apply to DIKAR S. Coop and its Group (hereinafter referred to as “DIKAR”) and are binding on all worker-members, employees and directors, regardless of their responsibilities, position within the organisation, type of contractual relationship (employment or membership) or place of work.
DIKAR will also seek to ensure that consultants and suppliers working with the Group embrace the principles and values set out in this Code of Ethics.
DIKAR is a cooperative dedicated to the manufacture and marketing of sporting firearms, leisure and sporting goods. We see product quality, after-sales service and lean management as key competitive advantages that enable us to achieve high levels of efficiency and profitability while ensuring the satisfaction of our customers and members.
The following values define our philosophy, guide our daily conduct and support our long-term success:
Among these values, we would like to highlight Ethical Relationships, which are based on the following principles:
The importance these values have achieved within DIKAR requires them to be translated into clear standards of conduct that are respected throughout the cooperative. The Code also defines unacceptable practices in order to promote a widely accepted standard of business ethics.
Compliance with the principles and standards of conduct set out in this Code is mandatory, without prejudice to the obligations established under applicable law and the cooperative’s internal regulations.
It should be noted that this Code of Ethics does not, in itself, constitute a Disciplinary Code, and breaches of its provisions do not automatically result in disciplinary action. However, certain violations may lead to disciplinary proceedings where the conduct also constitutes an offence under the Disciplinary Regime set out in the Cooperative’s Articles of Association, either because it falls directly within the defined offences or because it represents a form of conduct covered by them.
All individuals subject to this Code of Ethics have been expressly informed of its scope and content, and the full text is available on the Company’s intranet.
DIKAR is committed to complying with all applicable laws and regulations, fully understanding their purpose and scope.
Compliance with the law is a fundamental requirement for all worker-members, employees and directors of DIKAR and its Group.
DIKAR has established a range of internal policies and procedures to support compliance with applicable legislation. Knowledge of and compliance with these internal rules is mandatory for all worker-members, employees and directors. Among the most significant are:
Preventing the illegal trafficking of firearms, their essential components and ammunition is of particular importance. In this regard, DIKAR aligns itself with society and the relevant authorities by recognising the importance of this effort and is committed to establishing and maintaining the structures and procedures required by applicable legislation and international standards.
This commitment forms the foundation of the ethical conduct expected from everyone within the organisation.
DIKAR is committed to providing its employees with a safe working environment, free from risks that could affect their physical or psychological health. As part of this commitment, DIKAR has implemented an Occupational Risk Prevention Plan and a Policy for the Prevention of Conflict and Harassment.
Del mismo modo, DIKAR será el garante de que todos sus miembros, independientemente de su relación laboral o societaria o de su sexo, origen y religión, dispongan de igualdad de oportunidades laborales, de promoción y de desarrollo.
Loyalty to the organisation is demonstrated through conduct that is consistent with its mission, aligned with its best interests and protective of its reputation. A conflict of interest exists whenever an employee’s personal interests conflict, or appear to conflict, with the interests of the organisation.
The relationship between DIKAR and its employees must be based on the loyalty that arises from shared interests. Accordingly, the organisation respects employees’ participation in social, financial, business or public activities, provided these are lawful, do not create unfair competition or conflict with their responsibilities at DIKAR, and do not compromise their independence or professional commitment. Whenever there is any doubt about a potential conflict of interest, employees must inform their direct manager.
DIKAR has a Conflict of Interest Prevention Policy.
DIKAR’s image and reputation are closely linked to the relationship between its employees and society as a whole. Therefore, all DIKAR employees must take the utmost care to protect and uphold the company’s image and reputation in all their professional activities.
Employees must avoid any activity that could harm DIKAR’s interests or reputation, while also ensuring that suppliers and business partners uphold the same standards.
Employees must exercise particular care when making public appearances. They must obtain prior authorisation from their direct manager before speaking to the media, participating in professional conferences or seminars, or taking part in any other public event where they are identified as DIKAR employees.
Under no circumstances may DIKAR employees engage in unethical practices to influence the decisions of third parties for the purpose of obtaining any benefit for the organisation or for themselves.
No employee may directly or indirectly offer, give, request or accept cash payments, gifts, benefits in kind or any other advantage to or from any person acting on behalf of a public or private entity, political party or candidate for public office, with the intention of improperly obtaining or retaining business or securing any other undue advantage.
DIKAR employees must always act in accordance with applicable laws and must never engage in or tolerate bribery, whether directed towards the organisation, its employees or by the organisation towards third parties.
Gifts, invitations and hospitality may only be offered or accepted for legitimate business purposes. They must be socially appropriate and of such a nature that, if publicly disclosed, they would not cause embarrassment to either the recipient or the giver.
DIKAR has an Anti-Corruption Policy, a Grants Policy and a Procurement Policy.
DIKAR does not engage in political activities or make financial contributions of a political nature. However, anyone within the organisation is free to participate in political activities in a personal capacity, in their own time and using their own resources. In doing so, they must make it clear that their views and actions are their own and do not represent those of the organisation.
Sponsorships are carried out in exchange for opportunities to promote DIKAR’s brands. Financial sponsorships are managed transparently, meaning that the identity of the recipient, together with the purpose and justification of the sponsorship, must be properly documented. DIKAR also provides sponsorship through the participation of its employees in events organised by third parties.
Likewise, as a responsible cooperative and an organisation committed to creating a positive social impact, DIKAR participates in foundations and associations, particularly those related to culture and education, that make a meaningful contribution to the communities in which they operate. Such sponsorships and participation in events, foundations and associations are never undertaken in exchange for competitive advantages or for any other inappropriate purpose that could damage DIKAR’s image or reputation.
Donations and sponsorships are governed by the Anti-Corruption Policy.
The following is considered confidential information:
All employees have a duty to maintain discretion, secrecy and confidentiality regarding any information they handle in the course of their work. Employees must not disclose confidential information without DIKAR’s authorisation, either during their employment or after it has ended.
In compliance with applicable data protection legislation and its confidentiality commitments, DIKAR is committed to protecting all information relating to its employees and stakeholders.
DIKAR has a Privacy and Confidentiality Policy and an Information Security Policy.
All DIKAR transactions, events and business activities must be recorded clearly, accurately and in accordance with applicable regulations in the organisation’s records.
This information must always be communicated truthfully, completely and in a clear, understandable manner. Under no circumstances may information that is known to be false, inaccurate or misleading be provided if it could cause others to make decisions based on incorrect assumptions.
In addition to fully cooperating with our external auditors and any competent authorities requesting information, the Governing Board will carry out regular oversight to ensure the reliability of financial information and the accuracy of the organisation’s records.
The Governing Board of DIKAR has ultimate responsibility for establishing, maintaining and ensuring an effective Internal Control System over Financial Reporting (ICSFR), designed to ensure that the financial information filed with the Register of Cooperatives, relating both to the cooperative itself and to the Group, is complete, reliable and timely.
The Management Board and the external auditors are responsible for designing and implementing effective control procedures that ensure the ongoing reliability of the financial information disclosed to third parties through official reporting. To this end, they will provide the cooperative with sufficient human and material resources, while ensuring that those involved in preparing financial information receive the training necessary to perform their duties effectively.
In this regard, the following principles must be observed:
The Code of Ethics is primarily communicated through the following channels:
All employees are required to be familiar with this Code of Ethics and to act in accordance with its principles. They are also expected to help ensure compliance by reporting any breaches they become aware of.
DIKAR also seeks to ensure that consultants and suppliers adopt the principles and standards set out in this Code of Ethics. In such cases, the person responsible for engaging the consultant or supplier must ensure they are made aware of the Code. DIKAR reserves the right to terminate any contract with consultants or suppliers who fail to comply with its provisions.
To ensure compliance with this Code of Ethics, the Governing Board has appointed a Compliance Committee whose responsibilities include:
To provide all employees with an additional communication channel beyond the normal management structure, DIKAR has established a confidential internal Ethics Channel managed by the Compliance Committee. Through this channel, employees can request guidance on the interpretation of the Code, seek clarification on situations that may raise ethical concerns, and report potential breaches of its principles.
These communications should be submitted by email and include the following information:
Employees who fail to comply with any of the ethical principles set out in this Code of Ethics will be subject to disciplinary measures in accordance with DIKAR’s internal regulations, without prejudice to any other legal or contractual liabilities that may apply.
This Code of Ethics enters into force on the approval date indicated on the cover page.
The Code of Ethics applies to all employees from the date of its initial communication following approval and, for new employees, as part of the onboarding process. For consultants and suppliers, where applicable, it becomes effective upon acceptance of the relevant engagement or purchase order.
The Compliance Committee reviews proposed amendments and carries out an annual review of the Code of Ethics. Any resulting updates must be approved by the Governing Board and are communicated to all employees through DIKAR’s established communication channels.