May 2026 | Version 2.0
I. INTRODUCTION
DEA TopCo LP and DEA TopCo II LP, as well as their direct and indirect wholly owned and/or controlled subsidiaries (collectively, referred as “Company” or “Digital Edge” or “DE”), is committed to carrying on its business affairs in a highly ethical manner. This includes ensuring that Digital Edge and its directors, officers, and employees (collectively referred as “Employee” or “Employees” or “Personnel“) comply with all applicable trade sanctions laws, including those issued by the United States, the European Union, the United Kingdom, and the United Nations Security Council and any other jurisdiction whose sanctions laws apply to the Company’s activities (including Singapore, Hong Kong, Japan and the other jurisdictions in which Digital Edge operates) (collectively, “Sanctions Laws“). Digital Edge has developed this Global Trade Sanctions Policy (hereinafter referred to as “Policy“) to guide Digital Edge’s Personnel in complying with all applicable Sanctions Laws.
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 Personnel are responsible for understanding and complying with the provisions of this Policy.
II. SCOPE AND POLICY APPLICATION
This Policy is based on international best practices and applies to all Digital Edge Personnel. It is the responsibility of every director, officer, and employee of Digital Edge to be familiar with and ensure compliance with this Policy. Further, this Policy additionally reflects the standards by which Digital Edge expects any party to adhere to in all situations where that party is acting on Digital Edge’s behalf. Such parties may include, but are not limited to, business associates, partners, consultants, agents, intermediaries, representatives, suppliers, contractors, and certain third-party service providers (collectively, “Third Parties“).
III. SANCTIONS LAWS
“Sanctions Laws” refer to a series of international laws, rules, and regulations, adopted and established by various governments and governing bodies, including the United Nations, the United States, the United Kingdom, and the Member States of the European Union, which impose economic restrictions on, and on dealings with, certain specified countries, individuals, companies, and organizations (collectively, “Sanctions Targets“). Often, companies and persons are the subject of sanctions due to the foreign affairs, national security, or human rights objectives of the issuing body. Sanctions imposed against Sanctions Targets can vary widely — from prohibitions on transacting with an individual person or entity, to blanket prohibitions affecting economic dealings with all residents of a sanctioned nation.
Violations of Sanctions Laws can carry severe penalties, often exacerbated upon findings of willful non-compliance. Violations may result in imprisonment or fines, with some settlements reaching hundreds of millions of dollars or euros.
Digital Edge is dedicated to compliance with all applicable Sanctions Laws and maintains a strict prohibition on dealings with Sanctions Targets. This Policy is, therefore, intended to support Digital Edge’s efforts to uphold and comply with Sanctions Laws and assist Personnel in ensuring Sanctions Laws compliance. Failure by Personnel to comply with the requirements of this Policy may, therefore, result in appropriate disciplinary action up to and including termination, as warranted by the applicable circumstances. Violation of this Policy may also be a violation of applicable Sanctions Laws, and Digital Edge reserves the right to report such violation to the appropriate authority, which can lead to penalties, fines, and/or imprisonment for the offending party.
IV. VETTING AND COMPLIANCE
In efforts to fully comply with applicable Sanctions Laws, Digital Edge requires thorough due diligence and vetting of all third-party partners, vendors, agents, distributors, customers, and other counterparties (each a “Counterparty“), as well as contractual guarantees with Counterparties to better enforce compliance across Digital Edge’s supply chain and service channels.
Due Diligence
Risk-based due diligence should be conducted on all Counterparties to ensure that each Counterparty is not sanctioned and that Digital Edge’s relationship with that Counterparty will not violate any Sanctions Laws. The due diligence process is designed to ensure that the Counterparty is, itself, not a Sanctions Target; that the Counterparty is not located, organized, or a resident in a country that is a Sanctions Target, and that the Counterparty is not owned, controlled, or acting on behalf of any government, individual, or entity that is a Sanctions Target (including without interalia any entity owned 50% or more, directly or indirectly, individually or in the aggregate, by one or more Sanctions Targets) or located, organized, or resident in a sanctioned nation.
Any Personnel engaging with a new Counterparty should perform initial due diligence into the Counterparty, obtaining, at a minimum:
If the Counterparty is an individual:
- The Counterparty’s full legal name
- The Counterparty’s country of residence and, if different, nationality
- The Counterparty’s address
- If the Counterparty is an agent or representative, the name of the individual or entity that the Counterparty represents (and corresponding information for that person or entity)
If the Counterparty is an entity:
- The Counterparty’s full legal name and any trade names used
- The Counterparty’s countries of incorporation and registration
- The Counterparty’s place(s) of business
- The location and jurisdiction where the Counterparty will be performing services for Digital Edge, if applicable
- Corresponding information for the Counterparty’s parent company, if applicable
- If the Counterparty is an agent or representative, the name of the individual or entity being represented (and corresponding information on that person or entity)
The Personnel performing the initial diligence may be required to obtain more than the above information regarding a Counterparty as may be directed or requested by a Counterparty intake form that Digital Edge may require its Personnel to complete for new Counterparties (the “Intake Form“) or as otherwise directed by the Head of Legal and Compliance.
Screening
Once initial diligence information has been collected, Digital Edge requires that the responsible Personnel submit the Counterparty to an automated screening process using the Company’s GAN Integrity Platform (see the Company’s Third Party Due Diligence Policy for more information). The responsible Personnel should ensure they accurately locate and furnish all requested information in the applicable Intake Form. Responsible Personnel should focus on recognizing “Red Flags” raised by the Counterparty. Red Flags may include:
- The Counterparty’s reluctance to offer information or clear answers on routine commercial issues (including location of services/sales, questions regarding beneficial interests or ownership, or ties to governments or government officials).
- The inclusion of the Counterparty, a member of its leadership, or a beneficial owner or interest-holder, on a searchable Sanctions database, such as:
- The Consolidated List of Persons, Groups, and Entities subject to EU financial sanctions (https://webgate.ec.europa.eu/fsd/fsf)
- The U.S. Office of Foreign Assets Control (OFAC) Sanctions List Search (https://sanctionssearch.ofac.treas.gov/); the UK Sanctions List (https://www.gov.uk/government/publications/the-uk-sanctions-list)
- Any similar list covering Sanctions Targets under applicable law
The results of any screening identifying any Red Flags should be sent to Digital Edge’s Compliance Department for review before the Counterparty is engaged.
Review and Mitigation
In the event the screening process reveals one or more Red Flags applicable to a given Counterparty, the automated screening system shall deliver a report of the due diligence process and screening results to the concerned team member of Legal or Compliance Department from time to time (the “Reviewer“). The Reviewer pursuant to consultation of Head of Legal and Compliance shall be responsible for determining whether, in light of the information known about the Counterparty, engagement of the Counterparty may proceed consistent with this Policy and without violation of any Sanctions Laws. As part of the review process, the Reviewer shall consider whether mitigation practices could assist in the engagement of the Counterparty consistent with this Policy and Sanctions Laws. Mitigation practices may include, but are not limited to: additional diligence into and evaluation of the Counterparty, as well as its directors, officers, and/or beneficial owners or interest-holders; the provision and contacting of Counterparty local references; contractual guarantees and sanctions provisions; and mandatory oversight rights. The Reviewer shall inform the final outcome of the review in writing to the responsible Personnel, and the Counterparty may not be engaged until the Reviewer has confirmed that the engagement may proceed.
V. EXPORT CONTROLS
In addition to Sanctions Laws, many jurisdictions impose additional rules and regulations on international trade and restrict or regulate the export of certain goods, technologies, or materials (“Export Controls“). Generally, Export Controls tend to focus on military goods or items that can be used in a martial capacity. Permissibility of exports does, however, often rely on many factors, including what the export is, where it is going, who the end user is, and what the end use might be. Personnel engaging in activity that they believe may implicate Export Controls should promptly contact the Compliance Department with any questions.
VI. REPORTING
As all Personnel have an obligation to adhere to this Policy, any behavior witnessed on the part of any Personnel or Third Party that you believe may represent a violation of this Policy must be promptly reported. Internal reporting is important to the Company’s ability to comply with Sanctions Laws and is extremely valued by the Company. Digital Edge assesses and takes all reports seriously. The confidentiality of reported violations will be maintained to the extent possible, consistent with the need to conduct an adequate review and subject to applicable law.
Reports should be made pursuant to Digital Edge’s Whistleblower Policy / Ethics Hot Line, available at www.digitaledgedc.com (Ethics Hotline: whistleblower@digitaledgedc.com). No retribution or retaliation will be taken against any person making a report based on a reasonable, good faith belief that a violation of this Policy has occurred.
VII. INVESTIGATION MECHANISM IN CASE OF VIOLATION
To investigate any violation of this Policy, the procedure laid out in the Company’s Code of Conduct Policy shall be followed. Personnel /aggrieved person may appeal any determination made under this Policy in accordance with the procedure prescribed in the Code of Conduct Policy. Any decision under such appeal shall be final and non-appealable.
VII. 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