SUPPLIER CODE OF CONDUCT

Overview

DCSG is committed to unyielding integrity and the highest standards of business. Our commitment is fundamental to the core values and beliefs held by DCSG’s employees and investors and integral to the global communities where we do business. In selecting suppliers and contractors (“Suppliers”), DCSG works hard to choose reputable business partners who are committed to the ethical standards, values and demonstrated business practices compatible with those of DCSG. Suppliers include vendors, manufacturers, contractors, and subcontractors, who provide goods or services (including consultants) to DCSG or are seeking to provide goods or services to DCSG or who are currently parties to agreements for such purposes with DCSG or one of its Suppliers.

Scope

As an organization engaging a global supply base, DCSG understands that there are cultural differences among our Suppliers, however, the Supplier Code of Conduct contains universal principles and it is expected that all DCSG Suppliers meet these standards. The Supplier Code of Conduct applies to any employee, agent, or other representative of a company, corporation or other entity that provides any goods or services on behalf of, at the request of, or in connection with work completed for DCSG.

Purpose

The Supplier Code of Conduct documents the principles, guidelines and expectations for establishing and maintaining a business relationship with DCSG. DCSG is committed to partnerships with Suppliers that share the DCSG dedication to conducting business in a legal, ethical, and socially responsible manner. A continuing business relationship which is mutually rewarding depends upon it.

DCSG reserves the right to verify that a Supplier’s business operations meet these expectations. Failure to act in a manner consistent with these expectations may impede our ability to do business together in the future.

DCSG expects its Suppliers to maintain and enforce policies requiring adherence to business conduct and practices in accordance with applicable law and which comply with our requirements.

Policy

Health, Safety, and Environmental (HSE)

The health and safety of our employees and all personnel associated with our work is our highest priority. Our Suppliers are expected to:

Provide a safe and healthy work environment that supports accident prevention, minimizes exposure to health risks, is in compliance with applicable workers’ health and safety laws, and minimizes harmful impacts to the surrounding community.
Apply safe work practices (including regulatory and contract-specific requirements) to all their activities and install safety in every aspect of their work processes and in the attitude and behavior of all their workers.
Conduct their operations in an environmentally responsible manner and in accordance with applicable laws.

Human Rights and Employment Practices

Our Suppliers are expected to:

Support and respect human rights and the dignity of all people. Avoid complicity in human rights abuses, including engaging in human trafficking, slavery or sexual exploitation.
Treat all their workers with dignity, respect, and fairness.
Conduct all their operations in a socially responsible, non-discriminatory manner whether or not mandated by applicable laws. Respect applicable laws associated with equal opportunity, child labor, forced or compulsory labor, working hours, wages and benefits, freedom of association, data privacy, and harassment-free work environment.
Suppliers will ensure women workers receive equal treatment in all respects of employment. Pregnancy tests will not be a condition of employment and pregnancy testing will be voluntary and the option of the worker.

Financial Controls

Our Suppliers are expected to:

Keep accurate, complete, fair, timely, transparent, and understandable financial and operational books, records, and accounts, and a system of effective internal records.
Create, retain and dispose of business records in accordance with applicable legal and contractual requirements.

Conflicts of Interest, Gifts, Entertainment, and Business Courtesies

Our Suppliers, their employees, and their family members shall not receive improper or unlawful benefits through their relationship with DCSG or allow other activities to conflict with acting in the best interests of DCSG. Our Suppliers are expected to:

Limit promotional items or entertainment involving our employees to common business courtesies, within accepted business practices, and never with the intent to improperly influence a business decision or create a potential conflict of interest or the appearance of impropriety, and disclose any potential conflict prior to entering into any business transaction.
DCSG maintains zero tolerance for bribery and expects our Suppliers to do the same. Bribery is directly or indirectly giving or promising to give anything of value to improperly influence actions of a third party. Bribes may include money, gifts, travel expenses, hospitality, vacations, expenses, below-market loans or products, reciprocal favors, political or charitable contributions, or any direct or indirect benefit or consideration.
Any Supplier that violates this policy risks immediate loss of all existing and future DCSG business.
Suppliers are required to comply with Singapore Law.

Trade Controls

Our Suppliers are expected to:

Know and comply with applicable import-export controls, economic sanctions, and anti-boycott laws applicable to their work and with DCSG.
Never participate in boycotts or other restrictive trade practices prohibited or penalized under Singapore laws.

Company Resources

DCSG resources include property, assets, intellectual property, and confidential information. Our Suppliers are expected to:

Safeguard DCSG’s resources utilized in the course of performing work, to use such resources solely for legitimate business purposes to advance the interest of DCSG.
Honor the intellectual property rights of DCSG and the third parties at all times.
Maintain, handle, and if applicable, process any proprietary and sensitive information internally and on a need-to-know basis only, with the utmost care and in accordance with applicable laws and all contractual requirements.

Competing Fairly

DCSG believes in the freemarket system where merit, quality, price, and other objective factors determine who succeeds and who fails. Our Suppliers are expected to:

Compete honestly and fairly.
Comply with applicable anti trust and competition laws.
Never participate in anti-competitive practices such as price fixing or bid rigging.

Government Work

Our Suppliers who work on projects where government entities or agencies are involved are expected to follow any special rules that apply.

Supply Chain Activities

Respect for human rights, fair labor practices, humane working conditions and the environment are DCSG’s minimum expectations of all Suppliers. Additionally, DCSG expects and requires that all Suppliers apply the same due diligence of enforcing these minimum expectations down to sub-tier suppliers, refusing to conduct business with any parties failing to comply with these bare minimum expectations.

Monitoring and Compliance

Suppliers shall provide to DCSG reasonable access to information and facilities for purposes of assessing and monitoring the Suppliers’ performance in accordance with this Supplier Code of Conduct. Suppliers will immediately notify DCSG of any known material breach of this Supplier Code of Conduct and its proposed corrective action plan.

Event of Violation

If a Supplier is in breach of this policy, DCSG may require the Supplier to implement a corrective action plan to cure the non-compliance within a specified time period. If the Supplier fails to meet the corrective action plan commitment, DCSG may terminate the current and future business relationship, including, but not limited to, cancellation of all existing orders between DCSG and Supplier. DCSG reserves the right to hold the Supplier responsible for reasonable costs of investigating any non-compliance.

Reporting Concerns

Our Suppliers should promptly report any business conduct and ethics concerns involving or affecting DCSG, whether or not the concern involves the Supplier, by contacting the following; your account representative or the Managing Director, DCSG.

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