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.

All employees, contractors, business partners, and collaborators acknowledge and accept their commitment to uphold this Policy and comply with all applicable anti-corruption laws and regulations.

Violations of this Policy will result in disciplinary measures, up to and including termination of employment or business relationships.

Corruption: Any act of offering, giving, receiving, or soliciting something of value to improperly influence the actions of another party.

Bribery: Any offer, promise, or payment—directly or indirectly—of anything of value to a person to influence their decision or gain an undue advantage.

5.1 Prohibition of Bribery and Corruption
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.
 

5.2 Gifts, Hospitality, and Business Courtesies
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.
 

5.3 Prohibition of Political Donations and Sponsorships
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.
 

5.4 Conflict of Interest
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.
 

5.5 Third-Party Due Diligence
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.
 

5.6 Business Travel, Expenses, and Entertainment
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: Expenses must be reasonable, justifiable, and aligned with business purposes.

· Pre-Approval and Authorization: Travel-related expenses must be pre-approved by senior management.

· Expense Reimbursement and Documentation: Itemized receipts and clear business justifications are required.

· Prohibited Expenses: Personal expenses, excessive entertainment, cash advances without documentation, and family-related expenses are strictly prohibited.

· Monitoring and Compliance: All expenses are subject to internal audits and compliance reviews. Non-compliance will result in corrective actions.
 

5.7 Whistleblowing and Reporting Mechanism
DGS encourages employees and third parties to report any suspected violations 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.
 

5.8 Training and Awareness
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.
 

5.9 Compliance Monitoring and Auditing
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.
 

5.10 Enforcement and Disciplinary Actions
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 Policy complements and integrates with the DGS Code of Ethics, AML/CFT Policy, and other relevant policies, forming a holistic compliance framework.

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: June 4, 2025

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