Your Duty to Seek Advice and to Report #

If you have concerns about improper or questionable behavior or suspected violations of this Code, you should consult quickly with your supervisor, Chief of Party/Team Leader, their deputies, Human Resources, the Global Director of Safeguarding, or the Ethics and Compliance Officer. Unless you are a victim, you are expected to report your concerns or allegations as soon as possible. Remember that you can also do this confidentially and anonymously—without fear of retaliation—through DAI’s ethics hotline or ethics website. If you fail to report suspected ethical violations committed against someone else or against DAI, you could be considered culpable.

Timely notification is best as it permits DAI to address issues expeditiously—before any more harm is done—and it allows us to inform our clients if we need their involvement. We recognize that fear of retaliation is a serious concern in reporting incidents and allegations. But it’s better to report late than not at all.

If you are victim, for example of sexual exploitation or bullying, DAI recognizes that reporting can be more difficult. The protection of the victim is our paramount concern. By reporting your concern, you enable DAI to take appropriate action and to put a stop to the misconduct. Please remember that you can report anonymously through the ethics hotline or the ethics website as well as to Human Resources, your supervisor, Chief of Party/Team Leader, the Global Director of Safeguarding, or the Ethics and Compliance Officers. How you report is your choice.

Training Requirements #

Periodically, you will be required to take DAI training on ethics, anti-harassment, and safeguarding during on-boarding and annually as well as other training related to the Code. At the completion of the annual trainings, you are required to provide a written certification that you have reviewed, understand, and agree to comply with DAI’s Code of Business Conduct and Ethics; and that you are not personally aware of any violations of the Code by others. This certification is your pledge to honor and fully comply with the Code’s provisions. You are subject to disciplinary action, up to and including termination, if you fail to do so.

Your Responsibility as an Employee #

You should feel safe in reporting concerns and/or allegations, and confident that DAI will respond appropriately. You can, and should, make decisions and take actions on issues when it falls within your authority to do so. When you see something, say something. You are also responsible for:

• Following DAI’s Code of Business Conduct and Ethics.
• Taking annual ethics, anti-racism, anti-harassment, and safeguarding training and participating in supplemental reviews and meetings to ensure that you are fully aware of the issues involved.
• Notifying your supervisor, senior leadership, Ethics and Integrity Officer, or the ethics hotline if you suspect fraud, conflict of interest, bribery, facilitation payments, kickbacks, gratuities, or other corrupt practices, or any violations of the Code.
• Notifying the Global Director of Safeguarding, senior leadership, the ethics hotline, your supervisor, Human Resources, or Ethics and Integrity Officer if you suspect violations of DAI’s anti-harassment or safeguarding policies.
• Seeking assistance or clarification to avoid unethical or illegal conduct prior to taking any action that may be questionable.

Your Responsibility as a Manager, Supervisor, or Chief of Party/Team Leader #

If you are a DAI manager, supervisor, or Chief of Party/Team Leader—or deputy—you are responsible for ensuring that your direct and indirect reports understand and follow the Code. You must establish and maintain a workplace culture of respect in which employees feel comfortable doing what’s right and uncomfortable doing wrong. Make yourself available for questions and elevate issues or allegations immediately to the proper level. You must take great care in handling ethical, racism, and safeguarding reports to protect the reporter from threats of retaliation.

No investigative steps should be taken until the matters is elevated to the Ethics and Integrity Officer, Global Director of Safeguarding, or appropriate manager and next steps have been agreed upon. Leaders must be ethical role models, demonstrating integrity, accountability, and respect for everyone, and regularly communicate DAI’s expectations for ethical conduct while professionally and personally supporting these expectations. DAI employees must regularly hear that their leaders take ethical behavior and compliance seriously.

Ethics and Compliance Officers #

Ethics and Compliance Officers are the primary point of contact for questions, concerns, and allegations related to possible ethics or compliance violations, and for the receipt of any such allegations. They monitor and log all issues, coordinate reviews and investigations, communicate with individuals making allegations, ask follow-up questions as necessary, and provide information on the resolution of ethics issues.

The Chief Executive Officer has delegated authority to the Chief Ethics and Integrity Officer to make necessary disclosures to U.S. Government clients; the Ethics and Compliance Officers in Europe are responsible for disclosure of matters pertaining to their clients’ projects. When there is disagreement on the necessity for disclosure, the Chief Executive Officer makes the final decision. The Chief Ethics and Integrity Officer reports to the General Counsel and has a “dotted-line” reporting relationship to the Chair of the Finance, Audit, and Compliance Committee of the DAI Board of Managers.

Global Director of Safeguarding #

The Global Director of Safeguarding is the primary point of contact for questions, concerns, and allegations relating to SEAH. The Global Director of Safeguarding conducts or oversees investigations into SEAH and provides technical support to projects so they can better prevent and respond to SEAH. The Global Director of Safeguarding reports to the Chief Ethics and Integrity Officer.

Ethics and Safeguarding Committees #

An Ethics and Safeguarding Action Committee is convened in response to ethics, safeguarding, and racism allegations. It is chaired by the Chief Ethics and Integrity Officer, or Global Director of Safeguarding and its members may include Internal Audit, Human Resources, Contracts, General Counsel, the Diversity, Equity and Inclusion Lead, project management, and others as necessary.

The Global Ethics and Safeguarding Committee provides input to the Global Ethics and Safeguarding Program and is chaired by the Chief Ethics and Integrity Officer. The committee includes Ethics and Compliance Officers, the General Counsel, the Diversity, Equity and Inclusion Lead, and representatives from across the global organization.

Executive Leadership and Board of Managers #

DAI’s Global Executive Team (GXT) is responsible for setting and reinforcing a culture of ethical behavior and compliance. The GXT ensures that all employees are trained and meet the ethical standards laid out in the Code and holds them accountable for compliance. GXT members monitor risks and issues to inform changes needed in policy and practice. The General Counsel is a member of the GXT and has a direct reporting line to the Chair of DAI’s Board of Managers.

The Board oversees DAI’s Global Ethics and Safeguarding Program and ensures it is appropriate and effective. It ensures that DAI employs best practices, benchmarked against other firms, and promulgates up-to-date policies and procedures in response to evolving risks and regulations. The fact that most members of the Board are external to DAI contributes to its independent perspective. Ethics and Compliance Officers and heads of Internal Audit report regularly to the Finance, Audit, and Compliance Committee and the full Board of Managers.