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G GLOB BAL A ANTI B BRIBE ERY P POLIC CY

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Page 1: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

G

GLOBBAL A

ANTI BBRIBE

ERY PPOLICCY

Page 2: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

In accordand thirdrequired DPx’s buintegrity adopted “DPx Grany subsi

DPx PerjurisdictiCorrupt PFrance, I

This Procand any hospitalit

A. D

To impleComplianthe entireBribery Cwill deleProceduron the cochangingAudit Coprogram Bribery bribery c

B. G

As an orgFrance, Imust be laws. Th

GLO

dance with Td party agent

to comply wusiness affaand high ethis Global

roup” meansidiary of DP

rsonnel are rions in whicPractice ActItaly, German

cedure, amoother illicit ty.

DESIGNATI

ement this Pnce Officer, e company. Compliance egate responre. The Globompany’s ang bribery riskommittee. Tin its periodCompliance

compliance i

GUIDANCE

ganization oItaly, Germaaware of an

he U.S. Fore

OBAL ANT

The DPx Grots and consuwith the higairs. In ordeethical stand Anti-Bribe

s JLL/Delta PPx.

required to ch DPx opet and the Unny, Australia

ong other thinpayments o

ION OF AN

Procedure, thwho shall h The GlobManagers in

nsibility to bal Anti-Brib

nti-bribery coks faced by tThe Audit Cdic reports t

e Officer wissues.

E

perating in many, Australind ensure itsign Corrupt

THE

TI-BRIBER

oup Code of ultants of anghest level oer to put indards in all ery CompliaPatheon GP

comply witerates, includnited Kingdoa, Austria, a

ngs, prohibiof any kind,

NTI-BRIBE

he DPx Boahave responsbal Anti-Bribn each of thethose indivibery Complompliance prthe company

Committee wto the Boardill report to

many differeia, Austria, a compliancePractices Ac

DPX GROU

RY COMPLI

Business Cony member oof professionnto practice

business afance Procedu, Ltd., its DP

th all applicding, but noom Bribery

and The Neth

ts DPx Persand regulat

ERY COMP

ard of Directsibility for mbery Comple jurisdictioniduals that iance Officerogram and y at least annwill provide d of Directo

the subsidi

ent jurisdictiand The Nete with all apct (“FCPA”)

UP

IANCE PR

onduct, all dof the DPx Gnal and ethic

DPx’s convffairs, the Dure (“ProcePx Holdings

cable laws, ot limited toAct, and the

herlands.

onnel from rtes the givin

PLIANCE M

tors shall apmanaging aniance Officens in which is appropria

er shall reporits continuednually and oupdates on

rs. In additiary Boards

ions, includinherlands, all

pplicable ant) generally p

ROCEDURE

directors, offiGroup (“DPxcal standardviction to p

DPx Board dure”). As s B.V. (“DPx

rules, and ro, the Unitee applicable

receiving or ng and receiv

MANAGER

ppoint a Glonti-bribery coer shall appDPx mainta

ate and conrt to DPx’s Ad effectiveneotherwise as

the anti-brition, respons of Directo

ng the U.S., l members oti-bribery anprohibits DPx

E

ficers, emplox Personnel”

ds in carryinpromote honof Directorsused hereinx) subsidiary

regulations id States Folaws of Can

r providing bving of gifts

S

obal Anti-Brompliance a

point Local ains a facilitynsistent withAudit Commess in the ligrequested b

ibery complsible Local rs on local

the UK, Canof the DPx Gnd anti-corrux Personnel

oyees, ”) are g out nesty, s has

n, the y and

in all oreign nada,

bribes s and

ribery across Anti-y and h this mittee ght of by the iance Anti-anti-

nada, Group uption

from

Page 3: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

making oBribery Afurther toItalian, GDPx Perreceipt oDPx Pers

1

DPx Persvalue, diror may aor any olimitationin his/hersuch pay

2

Because and otherperson ouBribery Cas providupon thethe valuemay impof peopletransacte

DPx Persnature orrecorded exceed $

DPx Persmodest inexplanatiproperly of obtain

or offering tAct likewiseo prohibit b

German, Aussonnel are rf bribes. Thsonnel as par

. Prohi

sonnel are prectly or ind

appear to be other impron, the provisr official capments or ben

. Gifts

the provisior laws, DPx utside of theCompliance ded below. written law

e, purpose, oproperly influe to engage

ed.

sonnel may pr imprinted w

in the corp50.00 in valu

sonnel may n value; appion of DPx recorded in

ning an impro

to make impe prohibits thbribery that stralian, Ausrequired to che Purpose ort of DPx’s c

ibited Paym

prohibited frodirectly, or threlated to th

oper businession of any bpacity. DPxnefits.

and Hospit

on of gifts anPersonnel m

e DPx GroupOfficer or tThe decision

ws of the couoccasion, anduence, or apin business

provide a giwith the comporate booksue, or the lo

provide hospropriate for

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proper or corhe payment o

occurs in pstrian and Ducomply withof this Globcompliance w

ments

om offering,hrough an inhe obtaining,ss advantagbribe or kickx Personnel

ality

nd hospitalitmay only prp with the exthe responsibn as to whetuntry in whid frequency. ppear to imps with the D

ft without apmpany logo; os. Any gift cal permitte

spitality (incthe occasion

ducts and serate books. Ass advantage

rrupt paymeof bribes to private transutch laws likh all applica

bal Anti-Bribwith these a

, promising, ntermediary , retaining ore. This pr

k-back aimedare also pro

ty may be provide, or ofxpress prior ble Local Anther to grantich the gift o No gift or h

properly influDPx Group o

pproval if thotherwise inmust not b

d minimum,

cluding mealn; directly rervices; other

Any hospitale.

ents to foreigforeign publ

sactions. Akewise prohiable laws thbery Procedunti-corruptio

or making ato or for ther directing orohibition ed to influencohibited from

rohibited by ffer to providwritten authnti-Bribery Ct this writtenor hospitalithospitality muence, the dor on what

he gift is: mon accordancebe in cash or, whichever

ls) without aelated to the rwise in accity must not

gn public oflic officials,

Applicable Cibit various

hat prohibit ure is to proon laws and

a bribe or gie benefit of aof business texpressly prce the decisim soliciting

the FCPA, de, gifts or hhorization of Compliance n authorizatity is to be mmay ever be decision of a

terms such

odest in value with local lr similar foris less.

approval if tpromotion,

cordance witt be provided

fficials. Theand also ex

Canadian, Frforms of brithe paymen

ovide guidanregulations.

iving anythinany person tho the DPx G

recludes, wiion of any peor receiving

UK Briberyhospitality tof the Global

Manager, exion will be b

made, considgiven if doin

a person or gbusiness wi

e; promotionlaw; and prorm, and may

the hospitalidemonstratith local lawd for the pur

e UK tends ench, ibery. t and

nce to

ng of hat is

Group ithout erson g any

y Act, o any Anti-xcept based

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nal in operly y not

ity is: ion or

w; and rpose

Page 4: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

Provisionall compComplianlodging iin the perthe travelexpensesin cash.

3

DPx Perswith currwritten a

4

DPx Persfor publicampaignkind withshall basprovidedsuch poli

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Althoughperforma“grease peach jurifacilitatinall formsbusiness,transactio

6

DPx Groservices ta consulton an houPersonnewill oper

n of travel opany policiesnce Officer is to be provrformance ol or lodging

s including pAny provisi

. Chari

sonnel may rent DPx pol

approval that

. Politi

sonnel are prc office, to n, on behalfhout the expse any such d consideringitical contrib

. Facili

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. Reten

oup memberto the DPx Gting fee or curly rate or a

el must take rate. Furth

or lodging tos and procedor the resp

vided, such tof a particula

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itable Dona

make corporlicies, providt the paymen

cal Contrib

rohibited froany politicalf of the DPxpress writtenapproval on

g the amounbutions are su

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o individualsdures or othonsible Loctravel must oar contract. ly or friends all not be paor lodging m

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ments

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aid or reimbumust be prop

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na fide purp

ng to any poltical initiativy funds, comof the Localf the jurisdicnd means of

e DPx Code

made to a foion, sometimolicy of the er the UK Badopted a poy never be uial pertaininse.

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e laws of theust conduct

DPx Grouproved in wribery Complivided for a bshall DPx Peor private oursed to any

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DPx Groupribery Act dolicy prohibiutilized to asng to a dec

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uch represeng sales or mae jurisdictionreasonable

p must be in iting by Gloiance Manag

bona fide busersonnel payfficial and tr

y person direed in the corp

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date or prospum or other

y facilities orry Complianthe politicalal contributiConduct.

c official neas “facilitatip to comply does not permiting facilitassist in obtaicision involv

urposes

provide salsentatives mantatives may arketing reprn in which tdue diligen

accordanceobal Anti-Brger. If travsiness purpo

y for or reimbravel and lodectly or indirporate book

nts in accordanager also

pective candform of polr services once Officer,l support is ion. Further

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mit the makiating paymenining or retaving a parti

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Page 5: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

representsuitabilityutilized imay be mLocal Anregulatiocompens

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Page 6: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

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Page 7: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

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Page 8: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

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Page 9: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

1any famiwhich wo

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Page 10: G LOBAL A NTI BRIBE RY POLICY - EthicsPoint · pany logo; o. Any gift cal permitte pitality (inc the occasion ucts and ser te books. A s advantage rupt payme f bribes to rivate trans

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