Code of Conduct

OUR SHARED COMMITMENT

By making this Code of Conduct part of our relationship with our customers, we are acknowledging our critical role in supporting and protecting one of our most valuable assets – the trust that our customers, investors and employees place in DP Seals Ltd.

RESPONSIBLE BEHAVIOUR

Compliance with Laws and Regulations.

BRIBERY & CORRUPTION

DP Seals Ltd will not tolerate any form of bribery or corruption and we comply with all applicable anti-corruption laws and regulations, including but not limited to the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. Making or offering bribes, kickbacks, other payments or items of value, directly or indirectly, to anyone for the purpose of wrongfully obtaining or retaining business related to products or services provided by DP Seals Ltd. is strictly prohibited.
This includes officials, employees, or representatives of any government, political parties, candidates for office, or public or international organisation, as well as any third party where there is reason to believe that it will be passed on to anyone involved in the business decision process for the purpose of influencing the decision. Even where allowed by applicable laws and regulations, any travel-related expenses and business amenities provided must be reasonable, tied to a product demonstration and not provided for the purpose of obtaining or retaining DP Seals Ltd. business.

We also do not allow “facilitation payments” – small sums paid to government officials to expedite or facilitate non-discretionary actions or services such as obtaining a visa or customs clearance.

CONFLICT MINERALS

DP Seals Ltd. maintains due diligence to prevent the use of conflict minerals that are obtained from the Democratic Republic of Congo (DRC) and other war zones or areas of conflict worldwide. DP Seals Ltd. suppliers are expected to develop reasonable policies and processes to ensure all products are responsibly manufactured. Suppliers must fully cooperate with DP Seals Ltd.’s diligence process, including responding in a timely way to DP Seals Ltd.’s inquiries regarding the sourcing and origin of the materials and products DP Seals Ltd. buys.

EQUAL EMPLOYMENT OPPORTUNITY

DP Seals Ltd. provides a workplace free from unlawful harassment and discrimination. This includes physical and verbal behaviour that is abusive, offensive, or threatening and targets characteristics protected by laws applicable to the business. It also includes employment decisions based on legally protected traits. DP Seals Ltd. promotes a diverse and inclusive workforce regardless of applicable law in order to maximise the talents and potentials of their employees and teams.

FAIR COMPETITION

We compete fairly and ethically for all business opportunities. This includes conducting business in accordance with all applicable antitrust and fair competition laws and regulations. Examples of prohibited anti-competitive conduct include, but are not limited to: (1) discussing pricing with competitors; (2) discussing or agreeing to divide or share markets or customers; (3) coordinating with competitors on bids/proposals; and (4) joining with others to boycott suppliers or clients.

In addition, our employees and agents involved in representing DP Seals Ltd. or selling/promoting our products and services will be truthful in their communications and representations and will not make any unauthorised commitments on DP Seals Ltd.’s behalf.

FINANCIAL REPORTING/ACCURATE RECORD KEEPING

We maintain accurate and reliable records that fully represent the event or business transaction that took place. This applies to all DP Seals Ltd. activity.

HUMAN TRAFFICKING/HUMAN RIGHTS VIOLATIONS

Good corporate citizenship and compliance with applicable laws and regulations, requires that DP Seals Ltd. respects human rights in all aspects of their business operations and will adhere to all applicable laws that combat human trafficking, child labour, indentured servitude and forced or unlawful labour practices.

GLOBAL TRADE COMPLIANCE

DP Seals Ltd. will follow export/import laws and regulations concerning controlled products, technical data and comply with all applicable export/import regulations.

ACCOUNTABILITY

Adhere to Best Business Practices.

INFORMATION SECURITY

Information security is no longer a technology focused problem but a basic requirement for business survival.

DP Seals Ltd. is committed to the protection of information, information systems and critical infrastructure while protecting the confidentiality, integrity and availability of information across DP Seals Ltd.
The purpose of securing information is to help protect people, property, products, processes, and information systems by ensuring security throughout DP Seals Ltd., following best practices and industry standards to protect the confidentiality, integrity, and accessibility of DP Seals Ltd. information, including personal information, through appropriate physical and cyber security procedures.
This includes, but is not limited to: installing and maintaining security software on digital devices, keeping antivirus software up-to-date, running regular security scans on digital devices, and avoiding potential sources of cyber infection. DP Seals Ltd. will comply with all applicable data privacy laws and ensure these requirements are met.

CONFIDENTIAL INFORMATION

Business associates may entrust DP Seals Ltd. with sensitive information or which customers considers to be proprietary, confidential, or personal. DP Seals Ltd. will rigorously protect the confidentiality of all such information, use the information only for the intended purpose it was provided for and ensure that the information is not reproduced or released to anyone outside the organisation unless properly authorised to do so.

GIFTS, MEALS AND ENTERTAINMENT

DP Seals will not use the exchange of business courtesies (i.e., meals, hospitality, entertainment, travel costs and gifts) with private, commercial or government customers to gain an unfair advantage or improperly influence business decisions.

DP Seals Ltd. will compete on the merits of their products and services and only offering or accepting a gift or meal when it is modest in value, consistent with local customs or practices and not contrary to any applicable law. DP Seals Ltd. will not offer or pressure any individual to accept a business courtesy that they know would be contrary to their employer’s own rules or policies.

COMPLIANCE & COOPERATION

DP Seals Ltd. will conduct its business dealings with its customers and with others, in accordance with these standards. We will advise our employees and contractors working under contract with DP Seals Ltd. of these standards and their obligation to comply. We will provide information that our customers may request in connection with their periodic revalidation of their company’s business relationship with DP Seals Ltd.

DP Seals Ltd. will maintain documentation reasonably necessary to demonstrate our compliance with this Code of Conduct and provide our customers or independent auditors with access to such documentation upon reasonable request.

REPORTING VIOLATIONS

DP Seals Ltd. takes all reports of illegal or unethical conduct seriously and will conduct a prompt and thorough review or investigation. DP Seals Ltd. does not permit or condone retaliation against any person for reporting a suspected issue in good faith.