Issue Date: June 2021 At Digital Edge we aim to adhere to the highest level of ethical conduct in all aspects of our business. This also means ensuring our business partners share an equally strong commitment to ethical business practices. Digital Edge is providing this Business Partner Code of Conduct (the “Code”) to all of our business partners to ensure that the expectations and standards upheld at Digital Edge are understood and adhered to by our business partners. This Code is founded on the principles set forth in our Business Code of Conduct which is applicable to all our employees, officers, and directors and which is available on the Digital Edge website www.digitaledgedc.com. Please take the time to review this Code, become familiar with it and draw guidance from it. As one of our valued business partners, we expect you to comply with this Code insofar as it relates to our business relationship. You are responsible for establishing policies and monitoring practices so that all your employees, independent contractors, consultants, and all others who do business for or on your behalf understand and comply with the provisions of this Code. If a situation arises that, in your opinion, violates this Code, we expect you to report it immediately to Digital Edge’s Ethics Helpline identifying yourself as a business partner. Compliance with Laws and Regulations Business partners are expected to act within the bounds of all applicable laws, rules, and regulations. Corruption, Extortion, Bribery or Embezzlement Business partners must conduct their activities in full compliance with the anti-corruption and anti bribery laws of the country, or countries, in which they are operating and with the United States Foreign Corrupt Practices Act, the UK Bribery Act, and the principles of the OECD Convention on Combating Bribery of Foreign Public Officials. Business partners may not directly or indirectly through a third party, pay, offer, promise to pay, or receive bribes, kickbacks or facilitating payments from any individual, whether that individual is a public official or a private party. A public official is any person who is paid with government funds. This includes individuals who work for a local, state/provincial, or national government, or a public international organization, as well as employees of public (government-owned or operated) schools and state-owned enterprises. Employees at such organizations are considered public officials regardless of title or position. Bribes A bribe is offering or giving anything of value to any person for the purpose of obtaining or retaining business or securing an improper advantage. Anything of value includes cash, cash equivalents, meals, or entertainment, and may also include a promise or other intangible benefit. Kickbacks A kickback is a payment or anything of value given to individuals after a transaction, typically for providing a discount or arranging high volume in a sales agreement. Facilitating Payments Facilitating payments are small payments to a public official to expedite or secure the performance of routine, nondiscretionary government action. These types of payments are typically demanded by low- level officials in exchange for providing a service to which you are entitled even without the payment. Money Laundering Business partners may not engage in or assist others in concealing illicit funds or money laundering activities. The following are sample indicators of money laundering that merit further investigation by business partners:
- Attempts to make large payments in cash.
- Payments by someone who is not a party to the contract.
- Requests to pay more than provided for in the contract.
- Payments made in currencies other than those specified in the contract.
- Payments from an unusual, nonbusiness account
- Business partners should not offer gifts, entertainment, or travel to a Digital Edge employee, nor is acceptance of these permitted beyond a nominal value (retail value $150 or less). Items such as these should never be on a regular or multiple basis.
- Business partners should not offer any gift, entertainment or travel to any Digital Edge employee who plays a role in the decision while a Request for Information, Request for Proposal or contract negotiations process is underway in which the business partner is participating.
- Employee travel and accommodations related to business or entertainment events should be at Digital Edge’s expense. Do not offer to provide travel and accommodations to business or entertainment events.
- Business partners must not offer bribes, kickbacks, payoffs or other unusual or improper payments to Digital Edge employees in order to obtain or keep business.
- Likewise, a Business Partner should never accept cash or a noncash gift, bribes or kickbacks from a Digital Edge employee to influence them to take or not take a course of action or for any other improper purpose.