DPL Code of Conduct and Business Ethics Policy

1. Purpose

DPL is committed to conducting business with integrity, professionalism, transparency, and respect for the law. This Code of Conduct and Business Ethics Policy (“Code”) establishes the standards of behavior expected from all employees, directors, officers, contractors, consultants, interns, and third parties acting on behalf of DPL.

The purpose of this Code is to:

• Promote ethical business conduct.
• Ensure compliance with applicable laws and regulations.
• Prevent bribery, corruption, fraud, and other misconduct.
• Protect customer, employee, and company information.
• Foster a respectful and responsible workplace.
• Maintain trust with customers, partners, suppliers, and stakeholders.

All personnel are expected to read, understand, and comply with this Code.

2. Scope

This Code applies to:

• All permanent and temporary employees.
• Interns and trainees.
• Directors and officers.
• Consultants and contractors.
• Third parties acting on behalf of DPL where applicable.

Violations of this Code may result in disciplinary action, including termination of employment or contractual relationship.

3. Our Core Values

DPL conducts business based on the following principles:

• Integrity in all business dealings.
• Respect for people and diversity.
• Accountability for actions and decisions.
• Compliance with laws and regulations.
• Protection of confidential information.
• Fair competition and ethical conduct.
• Continuous improvement and professional excellence.

4. Compliance with Laws

DPL complies with all applicable laws and regulations in the countries where it operates.

Employees must:

• Understand legal obligations relevant to their roles.
• Follow all applicable company policies.
• Seek guidance when unsure about legal or ethical requirements.
• Immediately report suspected violations.

No employee may engage in conduct that violates applicable laws, regulations, or this Code.

5. Anti-Bribery and Anti-Corruption

DPL maintains a zero-tolerance approach toward bribery and corruption.

Employees and representatives of DPL must not:

• Offer, promise, authorize, give, request, or accept bribes.
• Provide anything of value to improperly influence a business decision.
• Use intermediaries, agents, consultants, or partners to engage in prohibited conduct on behalf of DPL.
• Offer kickbacks or improper commissions.

This policy applies to dealings with:

• Government officials.
• Customers.
• Vendors and suppliers.
• Business partners.
• Any public or private entity.

DPL complies with all applicable anti-corruption and anti-bribery laws.

6. Prohibition of Facilitation Payments

DPL prohibits facilitation payments.

Facilitation payments are unofficial payments made to secure or expedite routine governmental actions.

Employees may not make such payments directly or indirectly, regardless of local customs or practices.

Any request for such payment must be immediately reported to management or Human Resources.

7. Gifts, Hospitality, Entertainment and Other Benefits

Business gifts and hospitality must never influence, or appear to influence, business decisions.

Employees may only offer or accept gifts or hospitality when:

• They are reasonable and infrequent.
• They are lawful.
• They are transparent and appropriately documented.
• They do not create a conflict of interest.
• They are not intended to influence business decisions.

Employees must never:

• Offer or accept cash or cash equivalents.
• Offer gifts to obtain improper business advantage.
• Accept excessive hospitality or entertainment.
• Provide gifts to government officials unless expressly permitted by law and approved by management.

Any questionable gift or hospitality must be disclosed to management or Human Resources.

8. Fair Competition and Antitrust Compliance

DPL supports free and fair competition.

Employees must comply with all applicable competition and antitrust laws.

Employees must not:

• Fix prices with competitors.
• Allocate markets or customers.
• Coordinate bids.
• Exchange sensitive competitive information.
• Engage in anti-competitive conduct.

Business decisions must always be made independently and in the best interests of customers and the market.

9. Privacy, Data Protection and Information Security

As a technology services company, DPL recognizes the importance of protecting personal and business information.

Employees must:

• Protect customer, employee, and company data.
• Access information only when authorized.
• Follow applicable privacy and data protection laws.
• Comply with company information security requirements.
• Promptly report data breaches or security incidents.

Confidential information must not be disclosed unless properly authorized.

10. Intellectual Property Protection

DPL respects intellectual property rights.

Employees must:

• Protect DPL intellectual property.
• Respect copyrights, trademarks, patents, trade secrets, and software licenses.
• Use third-party intellectual property only when properly licensed or authorized.
• Follow contractual obligations related to customer intellectual property.

Unauthorized use, copying, distribution, or disclosure of intellectual property is prohibited.

11. Conflicts of Interest

Employees must avoid situations where personal interests conflict with DPL’s interests.

Potential conflicts may include:

• Personal financial interests in suppliers or competitors.
• Outside employment affecting job performance.
• Family relationships influencing business decisions.
• Personal benefits derived from company opportunities.

Actual or potential conflicts must be disclosed promptly to management or Human Resources.

12. Fraud, Theft and Financial Integrity

Employees must maintain accurate and complete business records.

Employees may not:

• Commit fraud.
• Falsify records.
• Misrepresent information.
• Misuse company assets.
• Engage in dishonest conduct.

Financial and operational records must accurately reflect business activities.

13. Child Labor and Human Rights

DPL is committed to protecting human rights and maintaining ethical labor practices.

DPL prohibits:

• Child labor.
• Forced labor.
• Bonded labor.
• Human trafficking.
• Any form of exploitation.

DPL complies with all applicable labor laws and minimum age requirements.

Employees and business partners are expected to uphold these standards.

14. Workplace Respect and Non-Discrimination

DPL is committed to providing a professional, respectful, and inclusive workplace.

DPL prohibits:

• Harassment.
• Bullying.
• Discrimination.
• Retaliation.

Employment decisions are based on merit, qualifications, performance, and business needs.

All employees are expected to treat colleagues, customers, and partners with dignity and respect.

15. Health, Safety and Wellbeing

DPL is committed to providing a safe and healthy working environment.

Employees are responsible for:

• Following safety requirements.
• Reporting hazards and incidents.
• Maintaining a safe workplace.
• Protecting their own wellbeing and that of others.

16. Responsible Use of Company Assets

Company assets must be used responsibly and for legitimate business purposes.

Assets include:

• Equipment.
• Software.
• Networks.
• Intellectual property.
• Financial resources.
• Information systems.

Unauthorized or inappropriate use of company assets is prohibited.

17. Environmental Responsibility

DPL encourages environmentally responsible business practices.

Employees are expected to:

• Minimize waste.
• Use resources efficiently.
• Support sustainability initiatives where practical.
• Comply with environmental laws and regulations.

18. Reporting Concerns and Whistleblower Protection

DPL encourages employees to report concerns regarding:

• Bribery or corruption.
• Fraud.
• Harassment.
• Data privacy violations.
• Security incidents.
• Legal or regulatory violations.
• Violations of this Code.

Reports may be submitted confidentially to:

Employees may also raise concerns directly with their manager or senior leadership.

DPL prohibits retaliation against any individual who, in good faith:

• Reports a concern.
• Participates in an investigation.
• Seeks guidance regarding ethical issues.

Retaliation itself constitutes a violation of this Code.

19. Investigation of Reports

DPL will review all reported concerns promptly and fairly.

Where appropriate:

• Investigations will be conducted confidentially.
• Relevant evidence will be reviewed.
• Corrective action will be taken where necessary.

Employees are expected to cooperate fully with investigations.

20. Leadership Commitment

DPL’s leadership is committed to promoting integrity, ethics, and compliance throughout the organization.

Management will:

• Lead by example.
• Support ethical decision-making.
• Promote compliance with this Code.
• Provide guidance and training.
• Take appropriate action when violations occur.

Ethical conduct is a responsibility shared by everyone at DPL.

21. Training and Awareness

DPL provides periodic training and awareness programs regarding:

• Business ethics.
• Anti-corruption.
• Information security.
• Privacy protection.
• Compliance obligations.

Employees are expected to participate in required training programs.

22. Violations

Violations of this Code may result in:

• Coaching or corrective action.
• Disciplinary measures.
• Termination of employment or contract.
• Legal action where appropriate.

The severity of the action will depend on the nature and seriousness of the violation.

23. Questions

Employees who are uncertain about any aspect of this Code should seek guidance from: