Gifts Hospitality Policy

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DGS Data Governance Systems LLC is committed to conducting business with the highest ethical standards and integrity. This policy establishes guidelines for gifts, entertainment, hospitality, and other business courtesies to ensure compliance with anti-corruption laws and prevent conflicts of interest.

This policy applies to:

• All DGS employees, contractors, officers, and business partners globally.
• Any gifts, entertainment, hospitality, donations, sponsorships, or contributions provided to or received from clients, vendors, government officials, or third parties.

✅ Modest gifts of nominal value (e.g., promotional items, company-branded merchandise) are allowed.
✅ Business meals and entertainment are permitted if they are reasonable, occasional, and related to legitimate business purposes.
✅ Gifts or hospitality must comply with applicable laws and industry standards.
✅ Product samples or service trials must be reasonable, aligned with business purposes, and provided transparently, ensuring they do not influence or create an unfair business advantage.

❌ Cash or cash equivalents (e.g., gift cards, vouchers, stocks) are strictly prohibited.
❌ Gifts or hospitality intended to influence business decisions or gain an improper advantage are not allowed.
❌ Any gifts or entertainment that could create the appearance of bribery, corruption, or conflict of interest must be avoided.
❌ Lavish, extravagant, or frequent gifts and entertainment are not permitted.
❌ Contributions, donations, or sponsorships must never be used as a subterfuge for bribery or corruption.

⚠️ Any gifts, meals, or entertainment provided to government officials must be pre-approved by the Compliance Department.
⚠️ Such provisions must be documented and comply with anti-bribery laws (e.g., U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act).

• DGS may engage in charitable donations and sponsorships, but these must be transparent, compliant with laws, and not aimed at influencing business decisions.
• Political contributions are strictly prohibited to avoid conflicts of interest.
• All donations and sponsorships must be approved by senior management and documented.

• Business-related expenses must be reasonable and pre-approved.
• Expense reports must include itemized receipts and justification for business relevance.
• Entertainment, travel, or accommodations paid for by third parties require review to prevent undue influence.

📌 Any gift, hospitality, or sponsorship exceeding $100 must be reported to the Compliance Department and recorded in the company's Gifts and Hospitality Register.
📌 Pre-approval is required for all sponsorships, donations, and political contributions.
📌 Employees must seek written approval before offering or accepting any gifts or hospitality that may be considered excessive or create a potential conflict of interest.

🔹 Violations of this policy may result in disciplinary actions, including contract termination.
🔹 The Compliance Department is responsible for monitoring adherence, conducting periodic audits, and ensuring policy effectiveness.
🔹 All employees and third parties are encouraged to report suspected violations through the official whistleblower channel at DGS Ethics & Compliance Reporting.

This policy will be reviewed periodically to ensure compliance with evolving regulatory requirements and industry best practices. Any updates will be communicated to all employees and relevant stakeholders.