Corporate Governance: Code Of Conduct

Domestic and Foreign Business Practices (FCPA)

Conducting Business with Other Parties
Anti-Bribery Policy

Denysys has strict anti-bribery policies regarding the lawful, ethical conduct
of business domestically and internationally. You are responsible for knowing
and adhering to all policies that are relevant to your work with the company.

Compliance with Denysys Policies and Governing Law
Conducting Denysys business domestically, you are required to comply with Denysys’s policies and all local, state and national laws. Conducting business internationally, you must comply with the U.S. Foreign Corrupt Practices Act (FCPA), as well as the laws of all countries in which Denysys does business. You may not use bribes, payments or other inappropriate promises or actions to conduct Denysys business.

Anti-Bribery Policy Under the FCPA
No one acting on Denysys’s behalf may bribe or otherwise attempt to improperly influence a foreign government official or employee for the purpose of obtaining or retaining business or directing business to anyone. The FCPA prohibits payments and gifts, promises or offers to pay, and the authorization or approval of these actions.

Reporting Bribery and FCPA Violations
Employees are required to report any suspected or actual bribery violations and/or violations of the FCPA to the General Counsel. Reporting will not subject the employee to any retaliatory action by Denysys. Violations of the FCPA may subject Denysys to penalties, and employees who violate the FCPA may be subject to disciplinary action by Denysys as well as criminal and civil prosecution.

Discouragement of Payment for Foreign Government Actions
Payments to facilitate routine foreign governmental actions are discouraged and may be made only with prior approval from Denysys’s legal department.

Record Keeping for Payments
All payments made on behalf of Denysys must include proper written documentation and state the purpose of the payment. Each Denysys office, both domestic and international, must maintain accurate records that comply with Denysys’s accounting policies.

For more information, visit our HR Guidelines on the company's employee portal or request a copy from the HR department.

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