This policy describes how DK Company ensures that ethical principles are established, forming the framework for DK Company’s handling of data,
making ethical assessments of DK Company’s handling of data and describing a process for handling ethical dilemmas.


This policy applies to all handling of data in the entire DK Company Group. The policy applies to personal information as well as other data.
In addition, the policy applies to the handling of selected partners, to the extent that DK Company can influence these. Finally, the policy also applies
to all technologies and processes influenced by DK Company.


The following principles form the basis for DK Company’s responsible processing of data and supplement the security and personal data law
measures we already comply with:

1. Dedication to data ethics

Management has appointed a person responsible for data ethics, and a panel has been set up to make data ethics assessments.
Management takes the lead and helps to ensure that the principles are integrated into the day-to-day work. Management also ensures that a data ethics policy
is prepared and approved, and that it is balanced against the company’s other interests.

2. Responsible for handling of data

The organisation takes responsibility for the processing of data and ensures that the processing of partners’ data only takes place when necessary
and for clearly defined purposes, is mapped and in accordance with laws, rules and conventions, so that risks of unintended consequences when using data
are reduced to the extent possible.

3.Guidelines for and control of third parties’ handling of data

It must be ensured that IT suppliers act in accordance with our instructions, are processing data in a secure way, are dedicated to ensuring ethical handling of data
and have knowledge of and a data ethics policy. Generally, data is not sold or passed on unless there is an obligation to do so.
The use of new technology must be assessed on the basis of these data ethics principles.

4. Value, transparency and safety for customers

Data is used to create value for our customers in terms of effective and personalised access to the right solutions and offers.
Transparency is part of the solution design to the effect that, as far as possible, customers have direct insight into data about themselves
and the processing being carried out. This means that customers can remain confident that data is protected to the extent possible.
It is assessed whether any negative consequences (for example monitoring, exclusion or stigmatisation) will impact customers when new processing
of personal data is initiated – also in relation to the use of new technologies.

5. Employees are being trained, and handling of data is being controlled

All relevant employees have the opportunity and are under a duty to undergo training in safe, legal and ethical data processing.
The security work, personal data law issues and data ethics dilemmas are handled, and measurable annual controls are carried out with security,
processing of personal data and data ethics.


This policy is reviewed and approved at least once a year by DK Company’s Management
Compliance with the policy is assessed on the basis of management-approved controls.
The policy forms the basis for the data ethics statement in connection with Management’s Report.