About Us

Code of Conduct

Since 1979, DeJong has been committed to the highest standards of business conduct. We base our relationships with employees, and with suppliers, contractors and consultants (collectively, “Suppliers”), on efficient, fair and lawful practices.

A number of our customers have asked us to formally adopt a Code of Conduct (“Code”) and to distribute it throughout our supply chain. We ask that you review the following Code, and ensure that you and your employees, representatives and subcontractors comply with it. Please contact us if you have any questions.

DeJong Code of Conduct

1. Ethical Principles

It is important to us that the company, DeJong employees and our Suppliers:

  • Obey applicable laws and regulations governing our business conduct.
  • Be honest, fair and trustworthy in our activities and relationships.
  • Avoid all conflicts of interest between work and personal affairs.
  • Encourage fair employment and workplace safety practices.
  • Protect the environment.
  • Encourage a culture where ethical conduct is recognized and valued.

2. Requirements for DeJong Employees

All DeJong employees are required to comply with these requirements:

Improper Payments

  • Always adhere to the highest standards of honesty and integrity in all contacts on behalf of DeJong. Never offer bribes, kickbacks, illegal political contributions or other improper payments to any customer, government official or third party. Follow the laws of the United States and other countries relating to these matters.
  • Do not give gifts or provide any entertainment to a customer or supplier without prior approval of DeJong management. Make sure all business entertainment and gifts are lawful and disclosed to the other party’s employer.
  • Employ only reputable people and firms as DeJong representatives, and understand and obey any requirements governing the use of third party representatives.

International Trade Controls

  • Understand and follow US international trade control and customs laws and regulations, including those relating to licensing, shipping and import documentation and reporting, and record retention requirements.
  • Never participate in boycotts or other restrictive trade practices prohibited or penalized under United States or applicable local laws.

Money Laundering Prevention

  • Follow all applicable laws that prohibit money laundering and that require the reporting of cash or other suspicious transactions.


  • Never acquire, use or disclose individual information in ways that are inconsistent with applicable privacy and data protection laws, regulations and treaties.
  • Maintain secure business records containing personal identifying information, which is protected by applicable privacy regulations. This provision applies irrespective of the form or medium in which the records are stored.

Supplier Relationships

  • Only do business with suppliers who comply with local and other applicable legal requirements and this Code.
  • Follow applicable laws and government regulations covering supplier relationships.
  • Provide a competitive opportunity for suppliers to earn a share of DeJong’s purchasing volume, including small businesses and businesses owned by the disadvantaged, minorities and women.

Regulatory Excellence

  • Be aware of US regulatory requirements applicable to our business.
  • Gain a basic understanding of the key regulators and the regulatory priorities that affect our business.
  • Promptly report any red flags or potential issues that may lead to a regulatory compliance breach.
  • Always treat regulators professionally and with courtesy and respect.
  • Assure that coordination with business or corporate experts is sought when working with or responding to requests of regulators.

Complying with Competition Laws

  • Never propose or enter into any agreement or understanding with a DeJong competitor to fix prices, terms and conditions of sale, costs, profit margins or other aspects of the competition for sales to third parties.
  • Do not enter into any agreements or understandings with others to allocate markets.
  • Do not enter into any agreements or understandings with DeJong customers restricting resale prices.
  • Never propose or enter into any agreements or understandings with suppliers that restrict the price or other terms at which DeJong may resell or lease any product or service to a third party.

Environment, Health & Safety

  • Conduct your activities in compliance with all relevant environmental and worker health and safety laws, regulations, policies and guidelines.
  • Ensure that all new product designs or changes or service offerings are reviewed for compliance with DeJong guidelines.
  • Use care in handling hazardous materials, or operating processes or equipment that use hazardous materials, to prevent unplanned releases into the workplace or the environment.
  • Report to DeJong management all spills of hazardous materials, any concern that DeJong products are unsafe, and any potential violation of environmental, health or safety laws, regulations or company practices.

Fair Employment Practices

  • Extend equal opportunity, fair treatment and a harassment-free work environment to all employees, co-workers, consultants and other business associates without regard to their race, color, religion, national origin, sex (including pregnancy), sexual orientation, age, disability, veteran status or other characteristic protected by law.

Security and Crisis Management

  • Implement plans to address security of employees, facilities, information, IT assets and business continuity.
  • Protect access to DeJong facilities from unauthorized personnel.
  • Protect IT assets from theft, misappropriation or unauthorized disclosure.
  • Create and maintain a safe working environment.
  • Ensure proper business continuity plans are prepared for emergencies.
  • Report any apparent security lapses.

Conflicts of Interest

  • Financial, business or other non-work related activities must be lawful and free of conflicts with one’s responsibilities to DeJong.
  • Report all personal or family relationships, including those of significant others, with current or prospective suppliers you select, manage or evaluate.
  • Do not use DeJong equipment, information or other property (including office equipment, e-mail and computer applications) to conduct personal or non-DeJong business without prior permission from the appropriate DeJong manager.


  • Keep and report all DeJong records, including any time records, in an accurate, timely, complete and confidential manner. Only release DeJong records to third parties when authorized by DeJong.
  • Follow DeJong policies and generally accepted accounting principles, standards, laws and regulations for accounting and financial reporting of transactions, estimates and forecasts.
  • Financial statements and reports prepared for or on behalf of DeJong must fairly present the financial position, results of operations and/or other financial data for the periods and/or the dates specified.

Insider Trading or Dealing and Stock Tipping

  • Never buy, sell or suggest to someone else that they should buy or sell stock or other securities of any company while you are aware of significant or material non-public information (“inside information”) about that company. Information is significant or material when it is likely that an ordinary investor would consider the information important in making an investment decision.
  • Do not pass on or disclose inside information unless lawful and necessary for the conduct of DeJong business—and never pass on or disclose such information if you suspect that the information will be used for an improper trading purpose.

Intellectual Property

  • Identify and protect DeJong intellectual property in ways consistent with the law.
  • Consult with DeJong counsel in advance of soliciting, accepting or using proprietary information of outsiders, disclosing DeJong proprietary information to outsiders or permitting third parties to use DeJong intellectual property.
  • Respect valid patents, trademarks, copyrighted materials and other protected intellectual property of others; and consult with DEJONG counsel for licenses or approvals to use such intellectual property.

Responsible Sourcing of Minerals

  • Reasonably ensure that any tantalum, tin, tungsten or gold in products manufactured by DeJong do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Exercise due diligence to ascertain the source and chain of custody of these minerals. Make due diligence measures reasonably available to customers upon customer request. See our Conflict Minerals Policy.

3. Requirements for Suppliers, Contractors and Consultants (collectively, “Suppliers”)

DeJong adheres to the following policies, and will only do business with Suppliers that do the same.

Forced Labor

  • Avoid using forced, prison or indentured labor. Workers should not be subject to any form of compulsion, coercion or trafficking in persons in violation of the U.S. Government’s zero tolerance policy or other applicable laws or regulations.

Minimum Age

  • Avoid employing workers younger than sixteen (16) years of age or the applicable required minimum age, whichever is higher. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is deemed hazardous or is likely to jeopardize the health or safety of young workers.

Human Rights

  • Respect employees’ human rights. Observe applicable laws and regulations governing wages and hours. Prohibit unlawful discrimination, harassment and retaliation.

Health & Safety

  • Provide workers a workplace that meets applicable health, safety and security standards.

Environmental Compliance

  • Observe applicable environmental laws and regulations.

Lawful Business Practices

  • Maintain and enforce policies requiring the company and its employees to adhere to lawful business practices, including a prohibition against bribery of government officials.

Business Practices and Dealings with DeJong

  • Never offer or provide, directly or indirectly, anything of value, including cash, bribes, gifts, entertainment or kickbacks, to any DeJong employee, representative or customer or to any government official in connection with any DeJong purchase, transaction or business dealing. Such prohibition includes the offering or providing of any consulting, employment or similar position by a Supplier to any DeJong employee (or their family member or significant other) involved with a DeJong purchase. DeJong also prohibits a DeJong Supplier from offering or providing DeJong employees, representatives or customers or any government officials with any gifts or entertainment, other than those of nominal value to commemorate or recognize a particular DeJong Supplier business transaction or activity. In particular, a DeJong Supplier shall not offer, invite or permit DeJong employees and representatives to participate in any Supplier or Supplier-sponsored contest, game or promotion.

Business Entertainment of DeJong Employees and Representatives

  • Respect and comply with the business entertainment (including travel and living) policies established by DeJong and governing DeJong employees and representatives. A DeJong Supplier is expected to understand the business entertainment policies of DeJong before offering or providing any DeJong employee or representative any business entertainment. Business entertainment should never be offered to a DeJong employee or representative by a Supplier under circumstances that create the appearance of impropriety.

Collusive Conduct and DeJong Purchases

  • Do not share or exchange any of DeJong’s price, cost or other competitive information, or undertake any other collusive conduct with any other third party concerning any proposed, pending or current DeJong purchase.

Intellectual Property and Other Data and Security Requirements

  • Respect the intellectual and other property rights of others, especially DeJong. In that regard, a DeJong Supplier shall:
  • Only use DeJong information and property (including tools, drawings and specifications) for the purpose for which they are provided to the Supplier and for no other purposes.
  • Take appropriate steps to safeguard and maintain the confidentiality of DeJong proprietary information, including maintaining it in confidence and in secure work areas and not disclosing it to third parties (including other customers, subcontractors, etc.) without the prior written permission of DeJong.
  • If requested by DeJong, only transmit information over the Internet on an encrypted basis.
  • Observe and respect all DeJong patents, trademarks and copyrights and comply with such restrictions or prohibitions on their use as DeJong may from time to time establish.
  • Comply with all applicable rules concerning cross-border data transfers.
  • Maintain all personal and sensitive data, whether of DeJong employees or its customers in a secure and confidential manner, taking into account both local requirements and the relevant DeJong policies provided to the Supplier.

Trade Controls and Customs Matters

  • Never transfer any DeJong technical information to any third party without the express, written permission of DeJong. Comply with all applicable trade control laws and regulations in the import, export, deemed export, re-export or transfer of goods, services, software, technology or technical data, including applicable licensing requirements and any restrictions on access or use by unauthorized persons or entities. Ensure that all invoices and any customs or similar documentation submitted to DeJong or governmental authorities in connection with transactions involving DeJong accurately describe the goods and services provided or delivered and the price thereof.

Responsible Sourcing of Minerals

  • Reasonably ensure that any tantalum, tin, tungsten or gold in products manufactured by DeJong do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Exercise due diligence to ascertain the source and chain of custody of these minerals and make these due diligence measures reasonably available to customers upon request. (For more information, see DeJong’s Conflict Minerals Policy.)

Use of Subcontractors or Third Parties to Evade Requirements

  • The use of subcontractors or other third parties to evade legal requirements applicable to the Supplier and any of the standards set forth in this Code is prohibited.

4. Raising an Integrity Concern

  • Subject to local laws and any legal restrictions applicable to such reporting, each DeJong Supplier is expected to promptly inform DeJong of any integrity concern involving or affecting DeJong, whether or not the concern involves the Supplier, as soon as the Supplier has knowledge of such integrity concern. A DeJong Supplier shall also take such steps as DeJong may reasonably request to assist DeJong in the investigation of any integrity concern involving DeJong and the Supplier.

5. Additional Provisions

  • The foregoing standards are subject to modification at the discretion of DeJong. Please contact us if you have any questions about these standards and/or their application to particular circumstances.
  • Each DeJong Supplier is responsible for ensuring that its employees and representatives understand and comply with these standards. DeJong will only do business with those Suppliers that comply with applicable legal and regulatory requirements and reserve the right, based on its assessment of information available to DeJong, to terminate, without liability to DeJong, any pending purchase order or contract with any Supplier that does not comply with the standards provided in this Code.
  • This Code is not intended to create any rights for third parties, including workers.