Code of Ethics Policy

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DGS Data Governance Systems LLC is committed to maintaining the highest ethical standards in all its business operations. This Code of Ethics and Business Conduct serves as a guiding framework for employees, contractors, business partners, and stakeholders, ensuring that our actions align with integrity, transparency, and compliance with legal and regulatory obligations.

This document integrates various policies and provides references to key compliance guidelines. For additional details on specific topics, refer to our related policies, linked within this document.

• Commitment to Truth: We conduct all business dealings honestly and transparently, fostering trust with clients, partners, and stakeholders.
• Accountability: Employees and representatives must take responsibility for their actions and decisions, acknowledging mistakes and implementing corrective measures.

• Diversity and Inclusion: DGS is committed to fostering an inclusive workplace where all individuals are treated with dignity and respect.
• Non-Discrimination: We prohibit any form of discrimination based on race, gender, sexual orientation, religion, disability, or other legally protected characteristics.
• Prevention of Harassment and Abuse: We strictly prohibit harassment, bullying, and abusive behavior in any form.

• Information Protection: Employees must ensure the confidentiality of proprietary, client, and personal data.
• Regulatory Compliance: DGS complies with applicable data privacy laws. See our Personal Data Protection Policy and Privacy Policy.

• Regulatory Compliance: DGS adheres to all applicable laws and regulations in the jurisdictions where it operates.
• Fair Competition: Business dealings must be conducted ethically, without engaging in unfair or deceptive practices.

• Quality of Service: We strive to deliver high-quality, innovative, and efficient solutions to our clients.
• Continuous Learning: Employees are encouraged to engage in ongoing professional development and training.

• Transparency: Employees and representatives must disclose any actual or potential conflicts of interest.
• Mandatory Disclosure: Any potential conflicts must be reported and managed appropriately.

• Environmental Commitment: DGS promotes sustainable business practices to minimize its environmental footprint. See our Corporate Social Responsibility Policy.
• Community Engagement: We encourage participation in social initiatives and ethical business practices.

• Anti-Bribery Commitment: DGS strictly prohibits any form of bribery, illicit payments, or corruption. Refer to our Anti-Corruption Policy.
• Gifts and Hospitality: Any form of gift-giving or hospitality must align with ethical standards. See our Gifts and Hospitality Policy.
• Expense and Travel Compliance: All business-related expenses must comply with DGS policies. See our integrated Anti-Corruption and Expense Policy.

• Supplier and Partner Compliance: Third parties working with DGS must comply with ethical standards. See our Third-Party Risk Policy.
• Ongoing Monitoring: We conduct due diligence and integrity screenings of key suppliers and business partners.

• Commitment to Occupational Safety: DGS ensures a safe working environment, complying with workplace health and safety regulations.
• Employee Training: We provide workplace safety training aligned with best practices. See our Health and Safety Policy.

DGS Data Governance Systems LLC is committed to maintaining an ethical, transparent, and responsible work environment. To uphold this commitment, we provide a Confidential Reporting Channel, where employees, partners, suppliers, and other stakeholders can report policy violations, unethical behavior, fraud, harassment, corruption, or any other misconduct that may compromise the integrity of the company.

The whistleblowing channel can be accessed at:

🔗 DGS Ethics & Compliance Reporting

To file a report, follow these steps:

1. Access the portal through the link above.
2. Fill out the form, providing as much detail as possible, including:
   • Date and location of the incident;
   • People involved;
   • Any supporting evidence (documents, screenshots, emails, etc.).

1. Optionally, enter your details (name, phone, email). Anonymity is allowed to ensure whistleblower protection.
2. Submit the report, which will be reviewed by our Compliance team.

• All reports are handled with strict confidentiality and investigated with the utmost seriousness.
• DGS prohibits any form of retaliation against individuals who report concerns in good faith.
• Additional protective measures will be taken if necessary to safeguard the identity of the whistleblower.

1. Report Reception: The Compliance team reviews the submission.
2. Initial Assessment: The credibility and relevance of the report are evaluated.
3. Investigation: If needed, an internal investigation will be conducted to verify the facts.
4. Corrective Actions: If a violation is confirmed, appropriate actions will be taken, including disciplinary measures or operational changes.
5. Feedback (if applicable): If the whistleblower provided contact information, limited updates may be given on the case status.

DGS reaffirms its commitment to ethics, transparency, and corporate responsibility, ensuring that all reports are handled professionally and impartially.

• Regular Reviews: DGS periodically reviews its policies to ensure compliance with evolving legal and regulatory requirements.
• Disciplinary Actions: Violations of this Code of Ethics may result in disciplinary actions, up to and including termination.

This policy is approved by the Senior Management/Board of Directors and is effective from [01-01-2021].

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