Code of Ethics

DIHSAN (together with its subsidiaries, the “Company”) recognizes that it has inherent responsibilities that go beyond business performance and financial results. The Company is committed to upholding the highest moral, legal and ethical standards in all aspects of its business and requires each officer, director and associate to act with integrity in his or her dealings on behalf of the Company, including with Company associates, customers, suppliers, service providers, other business partners, competitors and other stakeholders.

This Code of Business Conduct and Ethics (this “Code”) has been established by the Company to offer a framework for its officers, directors, and associates to achieve this goal. This Code addresses a broad variety of corporate practices and processes. It does not address every issue that may arise, but it establishes fundamental principles to govern your interactions with the Company. Many of these concepts are further defined in the Associate Handbook and the individual Company rules referred to in this Code.


Those who breach the standards in this Code or any of the key rules outlined below shall face disciplinary action, including termination. If you suspect you are in a situation that may violate or lead to a violation of this Code, please notify the proper services listed in Section 13.

( 1 ) Compliance with Laws, Rules, Regulations and Company Policies

Officers, directors, and associates must respect and observe the applicable laws, rules, and regulations of all jurisdictions in which the Company operates, as well as all Company policies, rules, guidelines, and processes – both in text and spirit. This includes completely and truthfully collaborating with any Company inquiry.

( 2 ) Conflicts of Interest

When a person’s private interest (including any interest of a member of his or her family) conflicts or appears to interfere with the interests of the Company, a “conflict of interest” occurs. Conflicts can arise from a variety of situations, such as actions or interests that make it difficult to perform Company work objectively or effectively (such as an investment in a competitor, customer, or supplier) or the receipt of personal benefits (including loans, guarantees of obligations, gifts, and employment of family members) as a result of one’s position in the Company.


The Company has implemented a detailed Conflict of Interest Policy that outlines how to identify real and prospective conflicts of interest as well as what sorts of behavior are strictly forbidden. Any real or prospective conflict of interest must be reported immediately to the regional head of Human Resources, DIHSAN’s Senior Vice President & Chief Auditor, the Chief Operating & Financial Officer, or DIHSAN’s General Counsel.

( 3 ) Insider Trading

Officers, directors, and associates may obtain important non-public information about the Company or its customers, suppliers, vendors, or rivals while providing services for the Company. This includes information kids unintentionally have heard, seen, or are told in an unsuitable manner. Officers, directors, and associates are strictly prohibited by law and the Company’s Insider Trading Policy from engaging in certain activities while in possession of material non-public information, including purchasing or selling the Company’s or any business partner’s securities, as well as disclosing such information where it may be used to trade by the person receiving it. The Information Disclosure Policy of the Company is a crucial corollary to the Insider Trading Policy. Please visit “Confidentiality” for further information.

( 4 ) Confidentiality

Officers, directors, and associates are required to keep sensitive, proprietary, or otherwise confidential information entrusted to them by the Company or its customers, suppliers, or business partners confidential unless disclosure is expressly authorized by the DIHSAN General Counsel or required by law, regulation, court order, or similar basis. This includes all non-public information, whether important to investors or not, that might be useful to rivals or damaging to the Company, including, if revealed, an individual officer, director, or associate.


The Company’s Confidentiality of Information Policy defines our officers’, directors’, and associates’ duties with regard to sensitive information, many of which remain even after an officer’s, director’s, or associate’s employment or affiliation with the Company ends.


The Company is also required to maintain private information of our officers, directors, colleagues, consumers, customers, and business partners discreet. Officers, directors, and associates are required to treat any personally identifiable information (“PII”) collected, stored, processed, or transmitted in accordance with the Data Classification Policy, Associate Privacy Policy, and all applicable laws, such as the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

( 5 ) Corporate Opportunities

Officers, directors, and associates have a duty to advance the Company’s legitimate interests at all times. They are not permitted to use or leverage opportunities, Company assets (including all inventions and intellectual property developed during his or her employment), physical property, information, or their position for personal gain or the personal gain of friends or family members, or to compete directly or indirectly with the Company.

( 6 ) Competition and Fair Dealing

Officers, directors, and associates must respect and treat the rights of the Company’s customers, suppliers, partners, rivals, and colleagues, as well as anyone else with whom he or she interacts in the course of executing his or her work, fairly. No officer, director, or associate should intentionally take unfair advantage of anybody by manipulating, concealing, abusing privileged information, misrepresenting material facts, or engaging in any other deliberate unfair dealing activity. Officers, directors, and colleagues are also forbidden from directly or indirectly providing, offering, promising, or receiving any business entertainment or gift that produces a real or perceived unfair commercial advantage. Because the Company recognizes that determining what sorts of gifts or entertainment may violate this principle might be challenging, the following broad recommendations have been supplied. (1) do not give or receive cash or cash equivalents (e.g., gift cards); (2) all gifts and business entertainment should be reasonable and consistent with ordinary business practices; and (3) no gift or business entertainment should violate any law, rule, regulation, or Company policy. Additional information on permissible gifts and entertainment may be found in your country’s
or region’s Anti-Bribery Policy.

( 7 ) Anti-Bribery

The Company is dedicated to adhering to the standards outlined in relevant anti-bribery legislation, such as the United States Foreign Corrupt Practices Act, the United Kingdom Bribery Act, and the People’s Republic of China Anti-Unfair Competition Law. In accordance with these regulations, the Company’s Global Anti-Bribery Policy forbids providing, approving, promising, or offering anything of value to any foreign official, whether directly or indirectly, with the goal of getting or maintaining business or receiving an unfair economic advantage. The Company has also created regional and country-specific anti-bribery policies to address the behavior standards in those countries.

( 8 ) Discrimination and Harassment

The Company enthusiastically supports diversity and is steadfast in its commitment to treating all officers, directors, and colleagues with decency and respect in an atmosphere free of harassment and discrimination. You must ensure that you understand your duties under the Company’s Global Anti-Harassment Policy, which strongly forbids harassment and discrimination, including sexual harassment.

( 9 ) Health and Safety

Each officer, director, and associate is responsible for ensuring that all officers, directors, and associates operate in a safe and healthy environment by adhering to safety and health rules and procedures and reporting accidents, injuries, and harmful equipment, practices, or situations. The Company’s Violence in the Workplace Policy prohibits violence and threatening behavior. Officers, directors, and associates must report to work in good health, free of illicit drugs, controlled substances, or alcohol, as specified in the Company’s Substance Abuse Policy. The Company also abides with the 1988 Drug-Free Workplace Act.

( 10 ) Protection and Proper Use of Company Assets

All officials, directors, and colleagues are responsible for safeguarding the Company’s assets and ensuring their optimal use. Theft, negligence, and waste have a direct influence on the profitability of the Company and are strictly banned. Company assets, such as the Company’s computer, phone, and email systems, should not be used for non-Company activity, while accidental personal usage is authorized under specific conditions. Any suspected fraud or theft should be reported promptly for investigation. The Company’s Computer & Internet Acceptable Use Policy, among other things, governs the use of computer equipment and systems.It is prohibited to use, distribute, or fail to protect Company assets or any Confidential or Highly Confidential Information, as defined by the Data Classification Policy. It might also be unlawful, with civil or criminal consequences.

( 11 ) Record-Keeping

Officers, directors, and associates are required to operate with integrity and adhere to the highest ethical standards of business behavior in all papers required to be preserved throughout the course of their employment or contacts with the Company. All such papers, such as time sheets or business expenses, must be reported fairly, correctly, and properly recorded. At all times, records should be preserved or erased in accordance with the Company’s Record Retention Policy.

( 12 ) Waivers of the Code of Business Conduct and Ethics

Any waiver of this Code for executive officers or directors may be granted only by the Company’s Board of Directors or a committee of the Board, and it must be declared in accordance with applicable legislation or stock exchange regulations.

( 13 ) Reporting any Illegal or Unethical Behavior and Enforcement

All officials, directors, and colleagues of the Company are responsible not only for acting ethically but also for reporting any real or prospective misbehavior. If you have knowledge concerning unethical or illegal behavior that violates the law, this Code, or any other Company policy, you must quickly report it to your supervisor, Human Resources, or Legal. Any misconduct involving directors or senior executives must be reported to the General Counsel of DIHSAN.

You can also report possible misbehavior using counsel@dihsan.com. Reports can be made anonymously online or over the phone in fourteen languages, unless where forbidden by legislation, and will be kept as private as practicable. The Company will promptly investigate allegations of unethical conduct and take action as appropriate. The Company prohibits all forms of retaliation against any person who reports possible misconduct in good faith, as well as against any person who cooperates in an investigation. Anyone who believes that they have suffered retaliation is encouraged to contact DIHSAN’s General Counsel.