May 2026 | Version 1.0
1. INTRODUCTION
This ‘Charitable Donation and Social Contribution Policy’ (hereinafter referred to as the “Policy”) is applicable to DEA TopCo LP and DEA TopCo II LP and their wholly owned and/or controlled direct and indirect subsidiaries (hereinafter referred to as the “Company” or “Digital Edge” or “DE”). This Policy applies to all full-time, part-time employees and contractual employees, as well as third parties performing work for or on behalf of the Company on a dedicated basis, including contingent workers, agents, contractors, and consultants (collectively referred to as “Company Personnel” or “Employee”).
Digital Edge encourages its joint venture companies to adopt this Policy or implement similar policies that meet the standards set out herein. In the event of any inconsistency between applicable laws and this Policy, applicable laws shall prevail. All Employees are responsible for understanding and complying with the provisions of this Policy.
Digital Edge is committed to conducting business ethically and supporting the communities in which we operate. While we believe in contributing positively to society, we must ensure that charitable donations and social contributions are never used to influence, have the potential to influence, or be perceived to influence a business decision or secure an improper advantage.
In accordance with our Code of Conduct and Anti-Bribery & Anti-Corruption (ABC) Policy, we seek to ensure all corporate giving is transparent and legitimate. All proposed charitable donations and social contributions must be reviewed and approved by the Compliance Officer and Company’s Ethics Committee, which shall comprise the Chief Finance Officer, Head of Legal and Compliance and Chief HR Officer of the Company, to ensure compliance with applicable laws.
The Policy may not address every situation that may arise during day-to-day business activities. Where guidance is not explicit, Employees are expected to exercise sound judgment and seek guidance from their manager, their local human resources function (hereinafter referred to as “HR”), or the Compliance Officer at manish.sansi@digitaledgedc.com.
2. SCOPE AND APPLICATION
This Policy is mandatory and applies to all Employees of the Company and also to such Employees who serve as directors on the board of any entity within the scope of the Company. This Policy must be read in conjunction with the Company’s Code of Conduct and Anti-Bribery & Anti-Corruption (ABC) Policy.
3. POLICY STATEMENT AND GUIDELINES
Digital Edge prohibits the use of charitable donations or social contributions as a subterfuge for bribery or in activity which is not legally allowed. To ensure compliance, the following rules apply to all contributions made on behalf of the Company or using Company funds:
- Donations must be made only to legitimately registered, reputable, and bona fide charitable organizations or non-governmental organizations (NGOs).
- No donation or contribution may be made to individuals, political parties, political campaigns, or candidates for political office.
- Donations must not be made if they are tied to, or intended to influence, the outcome of a business transaction, regulatory approval, or government decision.
- Employees must not use personal funds to make donations on behalf of the Company to bypass the requirements of this Policy.
4. SOCIAL CONTRIBUTION PAYMENTS
Do not solicit or offer to make social contribution payments, whether within or outside of a contractual agreement to do so, without first seeking approval in accordance with this Policy.
Certain agreements /arrangements/statute may require the Company to make payments to assist with the development of a particular country. These payments may be charitable donations and training obligations, or social contribution payments. The Company may also wish to make development related payments outside of a contractual obligation. Whether within or outside of a contract, these types of payments must be reviewed for compliance with applicable ABC Laws, and approval of any such payment must be obtained in accordance with this Policy prior to agreeing to make the payment.
Neither the existence of a contractual obligation nor the legality of the payment under any applicable local laws or regulations shields the Company from liability under certain ABC Laws.
5. APPROVAL AND DUE DILIGENCE PROCESS
Prior to making any charitable donation or social contribution on behalf of the Company, Employees must complete the Charitable Donation Request Form (Annexure A) and submit it for review.
Appropriate due diligence will be conducted on the proposed beneficiary organization to confirm its legitimacy and ensure its key personnel or board members are not government officials in a position to influence Digital Edge’s business.
Written approval from the Ethics Committee is strictly required before any funds are disbursed or committed.
6. RECORD KEEPING
All approved charitable donations and social contributions must be accurately documented and transparently recorded in the Company’s books and records. Off-the-book accounts or concealed payments are strictly prohibited. Copies of the approval form, due diligence reports, and receipts from the charitable organization must be retained for seven (7) years in the custody of Compliance Department.
7. INVESTIGATION AND APPELLATE MECHANISM
To investigate any violation of this Policy, the procedure laid out in the Company’s Code of Conduct Policy shall be followed.
An Employee may appeal any determination made under this Policy in accordance with the procedure prescribed in the Code of Conduct Policy. Any decision under this appeal shall be deemed final and non-appealable.
8. CONTACTS AND FURTHER INFORMATION
For further information or any clarification contact:
Head of Legal and Compliance: Joe.b@digitaledgedc.com
Compliance Officer: manish.sansi@digitaledgedc.com
ANNEXURE A:
CHARITABLE DONATION REQUEST FORM
Please complete this form and submit it to the Compliance Officer, for seeking approval of the Ethics Committee prior to committing to any charitable donation or social contribution.
Please provide the answer of the following questions:
1. Is the proposed beneficiary a registered and legally recognized charity/NGO? Yes
No
2. Is the donation intended to influence a business decision, secure a contract, or obtain a permit/license?
Yes (If the answer is Yes, then provide details of business decisions, contracts, permits/licenses that may be influenced by such donation)
No
3. Are any government officials, public officials, or their close family members affiliated with the management or board of this charity?
Yes (If the answer is Yes, then provide details of such government officials, public officials, or their close family members affiliated with the management or board of this charity)
No
4. Is the donation being made to a political party, political candidate, or individual?
Yes (If the answer is Yes, then provide details of such political party, political candidate, or individual) No
5. Total value of the proposed donation:
Donation shall be given to (Organization Name: ) Donation Amount/Description: Business Rationale:
Employee Name: Date: