Anti-Corruption Policy

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This Anti-Corruption and Compliance Policy establishes the principles, standards, and guidelines for preventing, detecting, and addressing corruption, bribery, and unethical business practices within DGS Data Governance Systems LLC, including all affiliates and subsidiaries. This policy ensures compliance with applicable laws, international best practices, and reinforces our commitment to ethical business conduct.

This policy applies to:

• All employees, officers, contractors, and agents working on behalf of DGS.
• All business transactions and activities, regardless of location.
• Third-party vendors, suppliers, and partners, who must comply with the principles outlined in this policy as part of our Third-Party Risk Management framework.

DGS is committed to conducting business with the highest level of integrity and transparency. We strictly prohibit all forms of bribery, facilitation payments, kickbacks, extortion, or any unethical practice that could influence business outcomes or provide an undue advantage. Compliance with this policy is mandatory for all employees and business partners.

• No Offering or Accepting Bribes: Employees and representatives must not offer, promise, give, or accept bribes, whether directly or indirectly, to influence business decisions or gain an improper advantage.
• Facilitation Payments: Small payments made to expedite routine government actions are strictly prohibited unless legally unavoidable.

DGS acknowledges that business courtesies can be part of professional relationships, but they must always comply with ethical and legal standards.

• Acceptable Limits: Gifts, hospitality, and entertainment must be reasonable, modest, infrequent, and must never be used to gain undue influence.
• Reporting Requirements: Any gift or hospitality exceeding a predefined threshold must be reported and documented in the Gifts and Hospitality Register.
• Strict Prohibition: DGS prohibits gifts, hospitality, or any benefits that create a conflict of interest or an impression of impropriety.
• For detailed guidelines, refer to our Gifts and Hospitality Policy.

• Political Contributions: DGS strictly prohibits any political donations, sponsorships, or contributions that could create conflicts of interest or undue influence in business relationships.
• Transparency Requirement: Any approved donations must be compliant with applicable laws and properly documented.

 DGS strictly prohibits any form of political donations, sponsorships, or contributions that could improperly influence business relationships. Any approved charitable donations or sponsorships must be made transparently, comply with applicable laws, and be properly documented to ensure they are reasonable and in good faith. 

• Employees and third parties must avoid and disclose any situation where personal interests may conflict with the company’s business.
• Any potential conflict of interest must be promptly reported to management.

DGS conducts thorough due diligence on third parties, including contractors, agents, and business partners, to ensure compliance with anti-corruption laws.

• Screening & Risk Assessment: Third parties are evaluated based on their integrity, reputation, and adherence to ethical business practices.
• Contractual Obligations: All third-party contracts must include anti-corruption clauses requiring compliance with this policy and applicable laws.
• For more details, refer to our Third-Party Risk Management Policy.

 To ensure full compliance with anti-corruption laws and corporate integrity principles, DGS enforces strict controls over business-related expenses, travel, and entertainment.

📌 General Principles:

• Business travel, meals, and entertainment must be reasonable, justifiable, and aligned with business purposes.
• Expenses must comply with all applicable laws, industry regulations, and company policies.
• Any activity or expense that could create the appearance of improper influence, favoritism, or bribery is strictly prohibited.

📌 Pre-Approval and Authorization:

• Any travel-related expenses (e.g., flights, lodging, meals, per diem) must be pre-approved by senior management.
• Sponsorship of third-party travel (e.g., vendors, partners, government officials) must go through enhanced due diligence to ensure compliance.

📌 Expense Reimbursement and Documentation:

• Employees must submit itemized and detailed receipts for all reimbursable expenses.
• Expense reports should include a clear business justification for each expenditure.
• Misrepresentation or falsification of expenses will result in disciplinary actions up to and including contract termination.

📌 Prohibited Expenses:
The following expenses are not permitted under any circumstances:
🔹 Personal expenses that are unrelated to official business.
🔹 Excessive entertainment beyond reasonable business customs.
🔹 Cash advances or per diem payments that are not properly documented.
🔹 Expenses for family members or guests accompanying employees on business trips.
🔹 Travel upgrades (e.g., first-class flights, luxury accommodations) unless pre-approved for specific business needs.

📌 Monitoring and Compliance:

• All business-related travel and entertainment expenses are subject to internal audits and compliance reviews.
• Management conducts periodic reviews to ensure compliance and detect any irregularities.
• Any non-compliance will result in corrective actions, disciplinary measures, or termination of employment/contract.

For detailed guidelines, refer to our Expense and Travel Policy.

DGS encourages employees and third parties to report any suspected violations of this policy confidentially and without fear of retaliation.

• Reporting Channels: Reports can be submitted through our secure Ethics & Compliance Reporting System at https://dgs-online.com/ethics-reporting.
• Confidentiality and Non-Retaliation: Whistleblowers will be protected from any form of retaliation or adverse consequences.

DGS provides training programs on anti-corruption laws, internal policies, and best practices for recognizing and reporting potential violations.

• Mandatory Training: All employees and relevant third parties must complete periodic ethics and compliance training.

• Internal Controls: DGS maintains robust internal controls to prevent and detect corruption, including transaction monitoring and financial audits.
• Periodic Reviews: Regular audits are conducted to ensure compliance and improve risk mitigation measures.

• Zero Tolerance Policy: Any employee or third party found violating this policy will face disciplinary action, which may include contract termination and legal consequences.
• Legal Proceedings: Severe violations may result in civil or criminal prosecution.

This Anti-Corruption and Compliance Policy reflects DGS’s commitment to integrity, transparency, and corporate responsibility. Adherence to this policy is mandatory, and non-compliance will not be tolerated.

• Approved by: Senior Management / Board of Directors
• Effective Date: January 1, 2021

For any questions or concerns about this policy, please contact the Compliance Department at compliance@dgs-online.com.