Supplier Code of Conduct


  1. Preamble

    Delivery Hero is committed to operating responsibly, including in how we source and whom we work with. We evaluate and select our suppliers beyond the basis of economic criteria. We consider environmental protection, compliance with human rights, labor, and social standards, as well as anti-corruption practices. 

    We expect our suppliers to comply fully with applicable laws and adhere to internationally recognized environmental, social and corporate governance standards (ESG). Our approach is drawn from the principles established by the United Nations Global Compact, the United Nations Guiding Principles, and Human Rights, and the International Labor Organization's Declaration on Fundamental Principles and Rights at Work.

  2. Scope

    The Supplier Code of Conduct of the Delivery Hero Group which is applicable to Delivery Hero SE, all its subsidiaries, and all its affiliated companies (in the following “DH Group”, "Delivery Hero", “company” or “we”) is relevant to all our suppliers, including agents, trading companies, service providers, their subcontractors and every member of the supply chain (hereafter: “Suppliers”).

    Our Suppliers shall accept our Supplier Code of Conduct (CoC) and adhere to our principles at all times, i.e. in all situations involving any entity of the Delivery Hero Group directly or indirectly. Our Suppliers should aim to establish appropriate training measures to allow their managers and employees to gain an appropriate level of knowledge and understanding of the applicable laws, regulations, and generally recognized standards, as well as standards expected by Delivery Hero.

    Riders and their potential employers will also need to comply with any policies, guidelines, or training that Delivery Hero may implement for riders in relation to their services.

  3. Human Rights & Labor Standards

    Delivery Hero respects human rights as set out in the United Nations Universal Declaration of Human Rights. We require our employees and suppliers to treat others with fairness, respect, and equality. We expect suppliers to respect the rights of their employees and contractors, and to comply with all relevant legislation, regulations, and directives in the country in which they operate. If such relevant local laws do not exist, suppliers are in any case expected to adhere to our Code of Conduct.

    Requirements set out below cover Delivery Hero's expectations on a range of human rights-related issues. Also, Delivery Hero expects suppliers to enable their employees and other stakeholders to report concerns or potentially unlawful practices at the workplace. 

    1. Forced Labor, Child Labor, Human Trafficking and Slavery

      Delivery Hero expects suppliers NOT to:

      • use any form of forced or involuntary labor.
      • participate in any way with human trafficking, specifically the recruitment, transportation, transfer, harboring, or receipt of persons by improper means (such as force, abduction, fraud, or coercion).
      • employ or use workers who fail to meet minimum age requirements. Minimum age is determined to be whichever is higher between applicable child labor laws in the country of operation or the ILO requirements (general minimum age for admission to employment or work at 15 years (13 for light work) and the minimum age for hazardous work at 18 (16 under certain strict conditions)). In such instances where light work is used, it must meet with the definition used by the ILO that such work does not harm a child's health and development and does not prejudice attendance at school and participation in vocational training.
    2. Working Hours, Wages & Benefits

      Delivery Hero expects suppliers to:

      • Pay all workers the greater between the minimum legal wage or a wage that meets the local industry standards. 
      • Comply with working hours following local laws.
      • Pay full-time workers at a level that allows them to meet their basic needs in the jurisdiction where no legal minimum wage exists. 
      • Comply with all other applicable local laws and regulations regarding wages, working hours, and benefits, such as overtime, maximum hours, and employee benefits.
    3. Non-discrimination & Professional Standards

      Delivery Hero expects suppliers to:

      • Aim for the highest possible professional standards. In particular, to maintain a respectful and dignified relationship with everyone the supplier engages with, this includes its own suppliers, customers, and employees, as well as customers and employees of Delivery Hero. The supplier's engagement should be free of harassment, abuse of any kind, harsh and inhumane treatment; 
      • Not discriminate against people based on personal characteristics, including but not limited to gender, gender identity or expression, sexual orientation, race, ethnicity, faith, and mental & physical disabilities; and
      • comply with local laws and regulations.
    4. Health & Safety

      Delivery Hero expects suppliers to:

      • Provide a safe and healthy working environment, taking proactive action to prevent and minimize injury and ill health of their workers. 
      • Understand and eliminate hazards and risks to occupational health and safety. 
      • Continually work to improve the management of occupational health and safety.
      • Provide the appropriate Personal protective equipment (PPE) aligned with the level of risk exposure of their activities.
      • Provide training to their staff about the risks they are exposed to and on how to conduct their activities in a safer way to avoid accidents and illness.
      • Comply with all applicable occupational health and safety laws and regulations.

        Where suppliers' activities include chemicals or other materials that pose a health risk to humans, we expect suppliers to abide by the following requirements in addition to those listed above:

      • Ensure an appropriate health and safety management system is in place.
      • Be proactive in identifying, reducing, or avoiding risks to people.
      • Chemicals or other materials that pose a risk to humans must be identified and handled in such a way that handling, use, storage, and disposal are carried out safely. 
      • Ensure they have emergency and contingency plans in place in the case of accidents and incidents.
    5. Freedom of Association

      Delivery Hero expects suppliers to uphold the freedom of association and the right to collective bargaining under applicable laws.

  4. Environment Impact

    Delivery Hero is committed to preserving the environment and combating climate change. We want to work with organizations that share these goals. 

    As a minimum, we expect suppliers to:

    • Comply with all applicable environmental laws and regulations.
    • Minimize the negative environmental impacts of their operations, products and supply chains, including but not limited to air pollution, greenhouse gas emissions, water discharge, hazardous waste disposal, and poisonous substances. 
    • Use resources efficiently, apply energy-efficient and environmentally friendly technologies and reduce waste, as well as emissions to air, water, and soil.

      Where suppliers' activities include chemicals or other materials that pose a risk to the environment, we expect suppliers to abide by the following requirements in addition to those listed above:

    • Ensure an appropriate environmental, health, and safety management system is in place.
    • Be proactive in identifying, reducing, or avoiding risks to the environment and people.
    • Chemicals or other materials that pose a risk to the environment must be identified and handled in such a way that handling, use, storage, and disposal are carried out safely.
    • Ensure they have emergency and contingency plans in place in the case of accidents and incidents.
    • Suppliers are expected to comply with the Minamata Convention aiming to eliminate, reduce and manage risks from involvement in the production and disposal of mercury-containing products, the PoPs Convention aims to eliminate, reduce and manage risks from the production or use of certain persistent organic pollutants and the and the Basel Convention aiming to eliminate, reduce and manage risks from the import and export of waste.
  5.  Bribery & Conflict of Interest 
    1. Anti-Bribery & Anti-Corruption

      Bribery refers to the giving or offering of money, goods, or other forms of reward to a recipient to bring about a change of their behavior or decisions in the interest of the giver, which the recipient would otherwise not alter. 

      Delivery Hero does not tolerate any form of bribery or corruption. Offering or accepting a bribe in any form, directly or indirectly, is strictly prohibited. Suppliers shall fully comply with applicable national and international regulations and are expected to conduct business in a professional, fair and lawful manner. Therefore, suppliers are expected to have established processes for sharp controls and regulations to prevent any kind of bribery and corruption.  

      Suppliers are expected to comply with all applicable anti-bribery and anti-corruption laws and requirements.

    2. Conflict of Interest

      A conflict of interest may arise at any time when competing loyalties could cause you to pursue a personal benefit. Suppliers are requested to take reasonable steps to avoid any conflict of interest, real or apparent, in connection with their cooperation with Delivery Hero. Suppliers shall not enter into a financial or any other relationship with a Delivery Hero employee that creates any actual or potential conflict of interest for Delivery Hero or its employee. Suppliers understand that a conflict of interest arises when the material personal interests of the Delivery Hero employee are inconsistent with the responsibilities of his/her position with the company. Suppliers are required to disclose all potential conflicts of interest and take necessary actions to correct them. Even the appearance of a conflict of interest can be damaging to Delivery Hero and its suppliers and are to be disclosed and approved in advance by Delivery Hero management.

  6. Unfair Business practices
    1. Collusion

      Delivery Hero competes vigorously in the sectors that it is active in but is committed to doing so in a manner that is fair, honest, ethical, and legal. We expect all suppliers to conduct their activities in a manner consistent with applicable antitrust and competition laws. Antitrust and competition laws are designed to encourage and protect free and fair competition. These laws exist within the EU Member States as well as in other countries where Delivery Hero does business and apply to any relationships with competitors, customers, service providers, and suppliers.

      Antitrust and competition laws prohibit practices that include: (1) Agreements or arrangements (including informal understandings, such as oral “gentlemen’s agreements”) between competitors that reduce or restrict competition with each other, such as price-fixing, bid-rigging, allocations of customers or territories or agreements not to deal with third parties, and (2) Other practices, such as requiring exclusivity, excessive pricing, “tying/bundling” (conditioning the sale of a product on the purchase or sale of another product), or imposing non-competes where these practices have an unreasonable impact on competition such as where these unduly exclude competitors or exploit other parties.

    2. Due Diligence & Prevention of Financial Crimes

      Delivery Hero is committed to preventing all forms of financial crimes, especially money laundering, terrorist
      financing, sanctions violations, trade embargoes, and frauds. Our suppliers are expected to pass any check from Delivery Hero aimed at their detection, disruption, and deterrence.

      We at Delivery Hero use due diligence when selecting our service providers and suppliers. Our procurement process is based on objective and comprehensible criteria, using a documented procedure. We always aim to ensure that our suppliers follow the same high ethical principles of conduct as we do at Delivery Hero. Hence, our suppliers are obligated to conduct an appropriate due diligence process within their whole supply chain.

    3. Management Systems

      Our suppliers must have stringent monitoring and controlling processes including functional controls with clear allocated responsibilities that are respectively documented. Suppliers are also obliged to implement local rules and regulations, including tax laws, to ensure compliance with the principles of this CoC. 

    4. Protection of Intellectual Property/ Company Assets

      Delivery Hero assets comprise intellectual property, designs, patent rights, copyright, trademarks and/or service marks, logos, and other distinctive brand features, business strategies, financial data, and other confidential information, as well as physical assets (hereafter: “intellectual property and company assets”). Suppliers do not acquire any rights over Delivery Hero’s intellectual property and company assets. Suppliers are obliged to protect and respect Delivery Hero’s intellectual property and company assets. Any use of Delivery Hero’s intellectual property and company assets by the Supplier requires prior authorization from Delivery Hero. Suppliers shall not contest or challenge, or take any action inconsistent with or that may damage or impair ownership of the intellectual property and company assets of Delivery Hero. Suppliers shall not apply or register as a trademark any of Delivery Hero’s trademarks.

      Disclosure towards third parties requires the prior written consent of Delivery Hero.  Required disclosure towards authorities under applicable laws or regulations, shall where legally permissible, be notified in advance by the supplier to Delivery Hero. Sub-suppliers shall be obliged accordingly by the supplier.

    5. Data Protection & Security

      Suppliers shall provide complete and accurate information to facilitate third-party due diligence efforts undertaken by Delivery Hero and comply with the applicable laws and regulations in the country or countries where they operate.

      Suppliers shall handle and protect personal data and confidential information provided by Delivery Hero in the course of their relationship with Delivery Hero against unauthorized access, unlawful use, disclosure, loss, alteration, damage, and destruction.

      Suppliers are expected to use security controls that meet Delivery Hero’s requirements to maintain and protect the information, including physical and digital assets, obtained from DH. Suppliers are responsible to maintain up-to-date technical and organizational measures and to confirm on a periodic basis, compliance with those.

      Suppliers shall notify Delivery Hero of any suspected or actual data breach concerning the services provided. Third Parties shall assist Delivery Hero in any investigations in response to a data or information breach.

      General Data Protection Regulation (GDPR requires data controllers to sign a data processing agreement (DPA) with any parties that act as data processors on their behalf and process personal data under the instructions of Delivery Hero SE as the controller. Whether it is an email client, a cloud storage service, or website analytics software, you must have a data processing agreement with each of these services to achieve GDPR compliance. 

      Suppliers of Delivery Hero SE are subject to GDPR requirements. Where a supplier is acting as a processor on behalf of other DH Group companies, they are subject to GDPR if they are either domiciled in the territory of the EEA or under certain further conditions, even if they are not domiciled within the territory of the EEA. The supplier will respect Delivery Hero’s assessment as to whether or not they fall within the scope of the GDPR.

      If not domiciled within the EEA, or transferring personal data to countries outside the EEA, we expect suppliers to provide an adequate level of protection to the fundamental rights of individuals (data subjects). For international transfers, Delivery Hero expects appropriate safeguards to prevent unauthorized access by government bodies in countries outside the EEA to data within the scope of the GDPR.

      Hence an international transfer may take place if the supplier has one of the below measures in place:

      Supplier is a white-listed country (Andorra, Argentina, Canada (commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland, South Korea, and Uruguay)

      Supplier will sign the standard contractual clauses certified by the EU Commission (SCCs)

      Supplier has Binding Corporate Rules (BCRs) as a mechanism for international transfers

      In the abovementioned cases, the supplier will also duly support Delivery Hero in performing any data transfer impact assessments (TIAs) as may be required for Delivery Hero to meet its GDPR obligation to always provide an adequate level of protection for personal data.

  7. Food & Food Contact Packaging

    Food and Food contact packaging materials must be produced, manufactured, packed, stored, and distributed in compliance with all relevant local, regional, and international legal and regulatory requirements according to Codex Alimentarius General Principles of Food Hygiene. Food and Food contact packaging must be sourced from safe reputable certified suppliers to any recognized Global Food Safety Initiative (GFSI) benchmarked standard or alternatively, the supplier must have demonstrated commitment to achieve certification via the GFSI global markets program or have a valid certification from a recognized national or international food safety standard. Food and Food contact packaging suppliers must always maintain valid certification against a recognized GFSI, international, or national food safety standard issued by a reputational accredited third-party certification body or competent national authority.

    The supplier must comply with relevant dietary religious requirements (i.e. Halal or Kosher) where this is required. The supplier must possess a valid certification by an accredited, recognized, credible certification body. The supplier must also ensure that the certification is performed according to the religious requirements (i.e. Halal or Kosher) in the market where the product will be used or sold and is recognized by the local relevant competent authorities. Packaging materials must be verified for the absence of hidden non-approved ingredients, wording, or pictorials according to religious requirements.

    In the event of serious food safety issues, outbreaks, and legal violations or in case of food safety or any relevant certifications are suspended, withdrawn, or expired, suppliers must notify immediately their local, regional, or central Food Safety and Quality Management point of contact at their corresponding supplying DH entity. Food and Food Packaging suppliers must demonstrate that all violations and non-conformities identified during the audit have been closed off and verified by the external auditing company or competent national authority. A copy of the official audit report shall be made available to the local, regional, or the central food safety point of contact .

    The supplier should demonstrate its commitment to continuous improvement. Third-party auditing companies must be a reputable accredited certification body recognized by the Delivery Hero Food Safety and Quality Management central team or by the regional or local DH entity food safety responsible person in charge.

    It is essential that riders maintain the highest standards of hygiene when delivering food. Riders should operate in accordance with the relevant food safety laws and hygiene practices to ensure food delivered to the customers is safe and clean.

  8. Food Preparation Equipment & Machinery

    All equipment and machinery used for food must meet the legal requirements of the supply of machinery regulations which include hygiene, safety by design, affixing the appropriate conformity marking (i.e. CE in EU ), a Declaration of Conformity (DoC), and suitable instructions for use, cleaning, and maintenance. The DoC and/or Instructions must state conformity with Hygiene requirements for food machinery and Hygiene Requirements for the Design of Machinery or equivalent international, regional, or local harmonized standard and guidance (i.e. EU Directive guidance).

    All equipment and machinery used for food to be ‘designed and constructed in such a way as to avoid any risk of infection, sickness or contagion’. Equipment must be designed and constructed so that:

    • They can be cleaned before each use and can be easily dismantled for cleaning where necessary;
    • Materials coming into contact with food satisfy
    • certain conditions as to suitability and surfaces in contact with food are smooth, have minimum edges, recesses, etc.;
    • Cleaning or disinfecting chemicals can be completely discharged from the machine;
    • Insects, organic matter, etc. cannot accumulate in areas that cannot be cleaned;
    • Machine lubricants etc. cannot come into contact with foods.
    • Instructions must be provided to indicate recommended cleaning products and methods for cleaning, disinfection, and rinsing.
    • Meet the relevant safety guarding and control systems requirements.
  9. Whistleblowing

    We expect all suppliers to promptly report any suspicious acts or any non-compliance with this CoC. To do so, all suppliers have the following three options available to them:

    • contact their respective Delivery Hero Group business representative
    • reach out via the Delivery Hero whistleblowing tool:
    • Get in touch via email to

      Adherence to the underlying CoC is of the utmost importance to Delivery Hero. If there is a suspicion of non-compliance or a violation of one or more points of the CoC listed above, DH reserves the right to re-assess the supplier. If this suspicion is confirmed, the business partnership will be reevaluated and possibly terminated according to our contractual rights and applicable law. Should the confirmed suspicion be related to a violation of fundamental human rights or laws (for example, child labor), then the relationship shall immediately be terminated, and legal proceedings initiated where applicable. Delivery Hero takes a hard stance against such violations and does not want to be associated with them.

      If you require assistance with any matter related to this policy, please contact: