Ethics & Compliance

We are committed to conducting our business in a professional, ethical and responsible manner.

All our employees and relevant business partners in every region in which we operate, are:

  • subject to strict codes of conduct
  • given regular training and support so they understand their obligations and can comply

Our suppliers are also expected to comply with the law in every relevant jurisdiction and adhere to equivalent ethical standards.

David Brown Santasalo Ethics & Compliance documents are made available for free download below. Updated versions of these documents will be uploaded as they become available.

DB Union Statement of Investment Principles
The Trustee of the DB Union Pension Plan in the UK is required to maintain a Statement of Investment Principles (SIP) which sets out the principles for investing the Plan’s assets. The latest version is available via the link in the table below. Any questions on this should be directed please to


Ethics & Compliance

TitleVersionDateDownload link
Anti-Facilitation of Tax Evasion Policy2.021 August 2023Download
Energy Policy 20221.05 May 2022Download
Environmental Policy 20222.05 May 2022Download
DBS Anti-Corruption Compliance Policy 20221.031 January 2022Download
Supplement to DBS Anti-Corruption Compliance Policy 01.20221.031 January 2022Download
Bribery and Corruption 20181.024 May 2019Download
Cookie Policy 20204.007 December 2020Download
COVID Secure UK 20201.012 May 2020Download
Data Protection Policy 20181.025 May 2018Download
DB Union Statement of Investment Principles (SIP)1.0July 2023Download
DB Implementation Statement – Year Ended 30 September 20231.0January 2024Download
DBS Environmental Social Governance 20211.019 October 2021Download
DBS Gearwatch Cookie Policy June 20211.015 June 2021Download
Gender Pay Gap Report 20213.027 September 2020Download
General Data Protection Regulations (GDPR) 20181.024 May 2018Download
Modern Slavery 20234.009 August 2023Download
Privacy Statement 20181.027 June 2018Download
Supplier Code of Conduct 20231.021 November 2023Download
Third Party Code of Conduct 20243.025 January 2024Download
Unbedenklichkeitserklärung 20211.017 March 2021Download

Copies of these Ethics & Compliance documents, can also be found in our resources section.