Our Business the Right Way

Corporate Opportunities

While conducting Dover business, we may come across opportunities that we ourselves would like to pursue. We may not take for ourselves any business opportunities that we discover while using Dover property or information, or through our position with Dover, unless expressly waived in writing by Dover. Just as we may not personally benefit from such opportunities, we cannot assist anyone else in doing so. Remember, we owe a duty to Dover to advance its legitimate business interests whenever possible. Therefore, we cannot in any way attempt to compete with Dover.

Political and Charitable Contributions

We encourage giving personal time and funds to support the political candidates and charitable causes of your choice. However, we cannot use Dover resources—either directly or through reimbursements—or the Dover name when making contributions to or involving ourselves in such activities without first obtaining permission. If you ever feel pressured or coerced to do so, report the incident to one of the additional resources listed in “Ask Questions & Voice Concerns.” Your choice to support or not support any political or charitable cause will have no bearing on your position within Dover, nor your potential for future advancement.

Audits and Investigations

We are expected to cooperate with any internal or external auditors, as well as government investigators or regulators, that request information in connection with any audit or investigation of Dover. We may not attempt to improperly influence any auditor, regulator, or investigator reviewing Dover’s records, nor may we encourage anyone else to do so. If a government investigator asks you to take part in inspections or interviews, or requests documents or information, prior to complying with such requests, you must immediately notify your supervisor and the Dover Law Department and follow your company policy.

Anti-Bribery and Anti-Corruption

Offering or paying bribes, other improper payments, or things of value to win business or obtain an unfair advantage is unacceptable no matter where we are doing business, even if business is lost or difficulties occur as a result (for example, delays in obtaining permits or licenses). Offering, paying, accepting, or soliciting bribes and other corrupt payments may violate multiple anti-corruption laws and expose individuals and Dover to civil and criminal liability and severe penalties. Almost all countries have laws that prohibit bribery, corruption, and kickbacks. Some of these laws apply to activities outside the countries’ borders. Corruption, extortion, or embezzlement in any form, including involving any third party, is strictly prohibited.

It is our duty to follow local and other applicable anti-corruption laws that apply in all countries where we do business. For additional information, refer to our Global Anti-Corruption Policy, which can be found on www.integritycounts.com.

Gifts, Meals, Entertainment, and Travel Benefits

The offer or receipt of gifts, meals, entertainment, and travel benefits can be an excellent way to foster positive business relationships. However, there are strict rules governing these practices to ensure they are never given or received as an improper incentive or bribe. Therefore, it is important to understand and abide by our Code, Dover policies, and the law when offering or accepting any gifts, meals, entertainment, or travel benefits with customers, suppliers, or other business partners or their family members. Please see our Global Anti-Corruption Policy, which can be found on www.integritycounts.com, for important limits and guidance in this area.

Government Interactions

It also is important to understand and abide by our Code, Dover policies, and the law when offering gifts, meals, entertainment, and travel benefits to government officials and employees of government-owned or government-controlled entities, and to remember that Dover does not permit “facilitating payments,” except in extraordinary circumstances. For additional information, refer to our Global Anti-Corruption Policy, which can be found on www.integritycounts.com.

When working with potential or existing government customers, it is critical that we abide by the various laws, regulations, and procedures that apply to government contract work. These rules are often much more strict and complex than those that govern our sales to commercial customers. If your work involves marketing or selling to, contracting with, or working on projects for a federal, state, or local government agency, it is your responsibility to know and follow all the specific rules that apply to those customers and their projects. For additional information, refer to our Federal Supplement to this Code, which can be found on www.integritycounts.com. Talk to your supervisor and the Dover Law Department if you have any questions or concerns about these rules or how they apply to the work you do.

Selection and Use of Third Parties

We should all work together to select and work only with third parties who share our commitment to the values and principles in our Code, our Third Party Guidance, and our Supplier Code of Conduct, which can be found on www.integritycounts.com. Our comprehensive compliance vetting program screens third parties who provide goods and services to Dover.