May 2026 v2.0
Introduction
DEA TopCo LP, as well as its direct and indirect wholly owned and/or controlled subsidiaries (collectively, the “Company” or “Digital Edge” or “DE”), is committed to carrying on its business affairs in a highly ethical manner in all aspects of our business. This also means ensuring that our Business Partners share an equally strong commitment to ethical business practices.
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.
Digital Edge is providing this Business Partner Code of Conduct (“Code”) to all of its vendors, suppliers, service providers, consultants, contractors, intermediaries, agents, or any other third parties engaged by the Company to provide goods or services regardless of the jurisdiction in which they operate (hereinafter referred to as “Business Partner” or “Business Partners”) for or on behalf of Digital Edge.
Digital Edge is sharing this Code with its Business Partners to ensure that the expectations and standards upheld at Digital Edge are understood and adhered to by them. This Code is founded on the principles set forth in the Digital Edge Code of Conduct, which is applicable to all employees, officers, and directors, and which is available on the Digital Edge website (www.digitaledgedc.com).
Please read and understand this Code, become familiar with it, and draw guidance from it. As a valued Business Partner, you are expected to comply with this Code insofar as it relates to your business relationship with Digital Edge. 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 Hotline (whistleblower@digitaledgedc.com) and/or the Compliance Department 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 in every jurisdiction in which they operate.
Corruption, Extortion, Bribery, or Embezzlement
Business Partners must conduct their activities in full compliance with anti-corruption and anti-bribery laws, including 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, solicit, 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 — including cash, cash equivalents, meals, entertainment, or any intangible benefit.
Kickbacks
A kickback is a payment or anything of value given to a person after a transaction, typically in exchange for awarding business, providing a discount, or arranging high-volume sales or contracts.
Facilitating Payments
Facilitating payments are small payments made to a public official to expedite or secure the performance of routine, non-discretionary government action. These are typically demanded by low-level officials in exchange for a service to which you are entitled even without the payment. Such payments are strictly prohibited.
Money Laundering
Business Partners may not engage in or assist others in concealing illicit funds or money laundering activities. The following are indicators of potential money laundering in counterparty transactions 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 the amount provided for in the contract
- Payments made in currencies other than those specified in the contract
- Payments from an unusual or non-business account
Trade Restrictions, Export Controls, and Customs
All transactions must comply with United States export and customs laws and additional applicable export and customs laws of all countries where business is being conducted. Business Partners whose business activities involve the sale or shipment of products, technologies, or services across international borders must ensure compliance with all applicable laws and restrictions.
Gifts, Entertainment, and Travel
Gifts, entertainment, and travel are often an integral part of building and maintaining business relationships. To avoid even the appearance of a conflict of interest, Business Partners must fully respect the spirit and letter of Digital Edge’s Gift & Entertainment Policy and Travel Hosting Policy:
- Business Partners must not offer gifts, entertainment, or travel to any Digital Edge employee beyond a nominal value (retail value greater than USD 150), and such items must never be offered on a regular or repeated basis.
- Business Partners must 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 negotiation process is underway in which the Business Partner is participating.
- Employee travel and accommodation related to business or entertainment events must 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 improper payments to Digital Edge employees to obtain or retain business.
- Likewise, Business Partners should never accept cash or non-cash gifts, 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.
Contact the Digital Edge Ethics Hotline (whistleblower@digitaledgedc.com) or the contacts listed at the end of this Code before engaging in any activity involving gifts, entertainment, or travel to ensure compliance with Digital Edge’s internal policies.
Labor and Human Rights
Business Partners must uphold the human rights of workers and treat them with dignity and respect as understood by the international community.
Non-Discrimination
Digital Edge is dedicated to maintaining a creative, culturally diverse, and supportive work environment, and does not tolerate discrimination of employees or non-employees with whom we have a business, service, or professional relationship. Business Partners shall not discriminate against any worker based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, or marital status in hiring and any employment practices such as applications for employment, promotions, rewards, access to training, job assignments, wages, benefits, discipline, termination, and retirement practices. Business Partners may not require a pregnancy test or discriminate against pregnant workers (subject to requirements of applicable laws and regulations). In addition, Business Partners may not require workers or potential workers to undergo medical tests that could be used in a discriminatory manner, except as required by applicable law or regulation or prudent for workplace safety.
Wages and Benefits
Business Partners must pay their workers at least the minimum wage required by applicable laws and regulations and provide all legally mandated benefits. In addition to their compensation for regular hours of work, Business Partners’ workers must be compensated for overtime hours at the premium rate required by applicable laws and regulations. Business Partners may not use deductions from wages as a disciplinary measure. Workers must be paid in a timely manner, and the basis on which workers are being paid must be clearly conveyed to them in a timely manner. Business Partners must maintain accurate records of employee hours worked and wages paid.
Child Labor
Child labor is strictly prohibited. Business Partners must comply with all applicable child labor laws, including the minimum age for employment in all countries where they do business, or the age for completing compulsory education in such countries, whichever is higher. This Code does not prohibit participation in legitimate workplace apprenticeship programs that are consistent with Article 6 of ILO Minimum Age Convention No. 138 or light work consistent with Article 7 of ILO Minimum Age Convention No. 138.
Diversity
Digital Edge believes competitive strength is achieved through a diverse group of people working together to find the best solutions and is committed to providing procurement opportunities to diverse suppliers in the various communities we serve. Digital Edge expects its Business Partners to exercise diversity in their daily business when it comes to their employees as well as in their decisions to select subcontractors.
Health and Safety
Digital Edge recognizes that integrating sound health and safety management practices into all aspects of business is essential to maintain high morale, produce innovative products and provide high-quality services. Business Partners must be committed to creating safe working conditions and a healthy work environment for all of their workers and must comply with all applicable health, safety, and environmental regulations.
Harsh Treatment and Harassment
Digital Edge does not tolerate unlawful harassment or any mistreatment (including sexual harassment or discrimination) by or of its employees, officers, guests, clients, or partners in the workplace or in a work-related situation, particularly on the basis of sex, race, color, nationality, ethnic or national origin, ancestry, citizenship, religion (or belief, where applicable), age, physical or mental disability, medical condition, sexual orientation, veteran status, marital status, genetic information or characteristics (or those of a family member), or any other category protected under applicable federal, state, or local law. Furthermore, Digital Edge does not tolerate workplace violence of any kind. Business Partners must be committed to a workplace free of harassment and violence. Business Partners may not threaten workers with or subject them to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion, or verbal abuse.
Drug-Free Workplace
Digital Edge’s position on substance abuse is simple: it is incompatible with the health and safety of our employees, contractors, and third parties who do business with Digital Edge, and we do not permit it. Digital Edge prohibits Business Partners from performing work activities for or on behalf of Digital Edge while under the influence of any substance, including drugs or alcohol, which prevents them from conducting their work safely and effectively.
Fair Business, Advertising, and Competition Practices
Business Partners must uphold fair business standards in advertising, sales, and competition.
Competition and Sales Practices
Digital Edge is committed to adhering to applicable antitrust or competition laws. Unfair methods of competition and deceptive practices involving Digital Edge products are prohibited. Laws regulating competition and trade practices vary around the world, but certain activities, such as price fixing or agreeing with a competitor to allocate customers, are almost always illegal. Business Partners must understand and ensure compliance with all competition and trade practices laws or restrictions that apply in connection with their business activities.
Obtaining and Using Business Intelligence
Business Partners who collect information on customers and markets in which they operate must do so only through legitimate means. Business Partners must not seek business intelligence by illegal or unethical means.
Accuracy of Records and Reports
Accurate records are critical to meeting legal, financial, and management obligations. Business Partners must ensure that all records and reports that they provide to Digital Edge, or to any government or regulatory body and that reflect business with Digital Edge, are prepared in reasonable detail to accurately reflect the operations of its business and dispositions of its corporate assets, and are full, fair, accurate, timely, understandable, and compliant with applicable legal and financial standards. Business Partners must never misstate facts, omit critical information, or modify records or reports in any way to mislead others, or assist others in doing so.
Honest and Accurate Dealings
Business Partners must not make any false representations in connection with any Digital Edge transactions, including, but not limited to, oral misrepresentations of fact, the promotion or utilization of false documentation such as non-genuine customer purchase orders, fraudulent or forged contracts, or other false or inaccurate records.
Privacy
Digital Edge is committed to ensuring the privacy of the end-user customers of Digital Edge products and services. Digital Edge’s Privacy Policy covers the collection, use, and disclosure of personal information that may be collected by Digital Edge, a copy of which may be found at https://www.digitaledgedc.com/privacy.
Business Partners are required to comply with all privacy laws and regulations. At a minimum, Business Partners must take appropriate precautions — including administrative, technical, and physical measures — to safeguard customers’ personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction. Failure to protect customers’ private information may damage Digital Edge’s relations with its customers and may result in legal liability for Business Partners.
Confidentiality of Digital Edge Information
Business Partners must strictly abide by all non-disclosure and other confidentiality agreements with Digital Edge. Business Partners must not publicly comment on Digital Edge business matters, programs, policies, or contract terms without prior written authorization from Digital Edge. If a Business Partner mistakenly receives Digital Edge confidential or proprietary information, it must be returned immediately to the designated Digital Edge point of contact.
Protection of Intellectual Property
Business Partners must respect the intellectual property rights of Digital Edge and all third parties and may not knowingly use such intellectual property of any third party unlawfully.
The Environment
At Digital Edge, environmental considerations are an integral part of our business practices. Business Partners must have a similar commitment to reducing the environmental impact of their operations. Business Partners must endeavor to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures in its facilities and by recycling, reusing, or substituting materials. Digital Edge expects every Business Partner to be both innovative and cooperative in implementing an effective assessment methodology. Furthermore, Digital Edge expects its Business Partners to comply with any additional environmental specifications required for products and services designed or manufactured for Digital Edge.
Whistleblower Protection
Business Partners must create programs to ensure the protection of whistleblower confidentiality and to prohibit retaliation against workers who participate in such programs in good faith or refuse an order that is in violation of this Code.
Corrective Action Process
Business Partners must have a process for timely correction of any deficiencies or violations of this Code identified through any internal or external audit, assessment, inspection, investigation, or review.
Reporting
Business Partners must, in good faith, report any violations of this Code (whether such violations are their own, another Business Partner’s, or a Digital Edge employee’s) to Digital Edge promptly, and in any event no later than ten (10) business days after identifying such a violation. All such reports must be made to the Digital Edge Ethics Hotline at whistleblower@digitaledgedc.com.
Contacts and Further Information
For further information or any clarification, please contact:
Head of Legal and Compliance: joe.b@digitaledgedc.com
Compliance Officer: vishal.jain@digitaledgedc.com