Anti-Corruption Policy

Purpose: This Anti-Corruption Policy establishes the standards and guidelines for preventing, detecting, and addressing corruption and bribery within our organization, including affiliates and subsidiaries. The policy aims to ensure compliance with applicable laws and uphold the highest ethical standards in all business dealings.

Scope: This policy applies to all employees, contractors, officers, and agents of the company, including affiliates and subsidiaries. It covers all business activities and transactions, regardless of location.

Policy Statement: Our organization is committed to conducting business ethically and legally. We strictly prohibit all forms of corruption, including bribery, kickbacks, and other illicit payments or advantages. This policy outlines the expectations and responsibilities for maintaining a corruption-free environment.

Key Provisions:

Prohibition of Bribery and Corruption:

• No Offering or Accepting Bribes: Employees and representatives must not offer, promise, give, or accept any form of bribe, whether directly or indirectly, to influence business outcomes or gain an improper advantage.

• Facilitation Payments: Small payments made to expedite routine government actions (facilitation payments) are prohibited, except where necessary to avoid immediate harm or legal consequences.

Gifts and Hospitality:

• Acceptable Limits: Gifts and hospitality offered or received must be reasonable, modest, and infrequent. They must not influence, or appear to influence, business decisions or outcomes.

• Reporting Requirements: Any gifts or hospitality exceeding a specified value must be reported and recorded in the company's gifts and hospitality register.

Conflict of Interest:

• Employees must avoid situations where personal interests conflict, or appear to conflict, with the interests of the company. Any potential conflicts must be disclosed promptly to management.

Third Parties:

• Due Diligence: The company conducts thorough due diligence on third parties, including contractors, agents, and business partners, to ensure they uphold our anti-corruption standards.

• Contracts: All contracts with third parties must include anti-corruption clauses that require compliance with this policy and relevant laws.

Reporting and Whistleblowing:

• Reporting Mechanism: Employees are encouraged to report any suspected violations of this policy through designated channels, such as an ethics hotline or email.

• Protection for Whistleblowers: The company ensures that individuals who report concerns in good faith are protected from retaliation or adverse consequences.

Training and Awareness:

 Our company recognizes the importance of training and awareness in maintaining a robust anti-corruption framework. While we currently do not provide formal training, we are actively developing comprehensive training programs for our employees and relevant third parties. These programs will focus on anti-corruption laws, our internal policies, and best practices for recognizing and reporting potential issues. We are committed to launching these initiatives shortly, ensuring that all personnel are well-equipped to uphold our ethical standards and compliance requirements. This strategic approach is part of our broader commitment to fostering a transparent and accountable organizational culture. 

Compliance and Monitoring:

• Internal Controls: The company maintains robust internal controls to prevent and detect corruption. These controls include financial audits, monitoring of transactions, and periodic assessments of corruption risks.
• Audits and Reviews: Regular audits and reviews are conducted to ensure compliance with this policy and to identify areas for improvement.

Enforcement and Disciplinary Actions:

• Consequences of Violations: Any employee or third party found to be in violation of this policy will face disciplinary actions, which may include termination of employment or contract, and legal proceedings.

Conclusion: This Anti-Corruption Policy underscores our commitment to integrity and ethical business conduct. All employees and representatives are responsible for understanding and adhering to this policy. Management is responsible for enforcing this policy and ensuring that our business operations are conducted with the highest ethical standards.

Approval and Effective Date:This policy is approved by the Senior Management/Board of Directors and is effective from 2021-01-01.

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