Code of Ethics and Conduct

DSS

Integrity in every decision. Trust in every relationship.

Version: 1.0
Effective Date: September 28, 2026
Approved by: DSS Legal

1. Our Commitment

At DSS, we understand that trust is built through responsible decisions, transparent relationships, and the fulfillment of our commitments.

This Code establishes the principles of conduct that guide our business activities, our relationships with stakeholders, and the responsible use of technology.

Our commitment is to act with integrity in all countries where we operate, respecting applicable legislation and the group’s internal policies.

2. Scope

This Code applies to executives, leaders, and employees of the holding company and DSS subsidiaries that formally adopt it, regardless of their position, location, or work arrangement.

Consultants, intermediaries, and third parties acting on behalf of DSS must comply with the principles relevant to their role, in accordance with their contractual agreements.

We promote equivalent principles among suppliers, business partners, and strategic allies.

3. Guiding Principles

Integrity: We act with honesty and consistency, even when no one is watching.

Respect: We recognize the dignity of all individuals and value their differences.

Responsibility: We assume the consequences of our decisions and fulfill our commitments.

Transparency: We communicate truthful information and maintain clear and reliable records.

Confidentiality: We protect the information entrusted to us by clients, employees, and allies.

Responsible Innovation: We use technology considering its impact on people, organizations, and the environment.

4. Compliance with Laws and Policies

We must know and comply with legal provisions and internal policies related to our functions.

Business goals, instructions from a superior, or common market practices do not justify improper actions.

If there is a doubt or a conflict between this Code and a local provision, the designated responsible party must be consulted before acting. No instruction in this Code requires violating the law.

5. Prevention of Bribery and Corruption

At DSS, we prohibit offering, promising, giving, soliciting, or accepting bribes, directly or through third parties.

This prohibition includes money, gifts, employment, favors, donations, or other benefits intended to unduly influence a decision or gain an advantage.

We do not permit facilitation payments to expedite routine procedures.

Donations, sponsorships, commissions, and intermediations must have a legitimate purpose, have the corresponding authorizations, and be documented.

In the event of an immediate threat to physical integrity, the safety of individuals will be prioritized, and the incident will be reported as soon as it is safe to do so.

6. Gifts, Invitations, and Hospitality

Gifts, meals, travel, and invitations must have a legitimate business purpose, be reasonable and transparent, and comply with internal policies and applicable regulations.

They must not be offered or accepted when they could unduly influence, or appear to influence, a decision.

Cash gifts or their equivalents are prohibited.

Attentions to public officials require prior review and authorization in accordance with the applicable procedure.

If there is no clear rule or doubt about the appropriateness of an attention, it must be consulted before offering or accepting it.

7. Conflicts of Interest

A conflict of interest arises when a personal relationship or interest may interfere with a professional decision.

We must timely declare actual, potential, or apparent conflicts, including:

• Financial interest in competing companies, clients, or suppliers.
• Family or personal relationships that could influence hiring or purchasing decisions.
• External activities that interfere with our responsibilities.
• Use of position or internal information to obtain personal benefits.

The involved person must refrain from participating in the decision until it is determined how to manage the conflict.

Declaring a conflict allows it to be evaluated; concealing it prevents proper management.

8. Responsible Business Relationships

We present our capabilities, experience, and solutions truthfully. We do not offer results, certifications, or conditions that we cannot support.

We select suppliers and partners using objective criteria, such as quality, technical capability, service, integrity, and commercial terms.

We respect fair competition. We do not participate in improper agreements to fix prices, divide markets, coordinate bids, or exchange sensitive commercial information with competitors.

In public tenders and contracts, we act with transparency and respect the process rules.

9. Respect and Work Environment

We promote a dignified, safe, and inclusive work environment.

We do not tolerate harassment, sexual harassment, discrimination, threats, violence, or humiliating conduct, whether occurring in person, through digital means, or in work-related activities.

Decisions regarding selection, development, and promotion must be based on professional and objective criteria.

We respect labor rights, reject forced labor and illegal child labor, and expect the same commitment from our business partners.

10. Health, Safety, and Well-being

Every person must comply with safety procedures related to their functions and report dangerous conditions, incidents, and accidents.

No operational or commercial goal justifies endangering the integrity of individuals.

Leaders must promote safe working conditions and address reported situations in a timely manner.

11. Confidentiality and Data Protection

Information concerning clients, employees, suppliers, and the group must only be used for authorized purposes.

We must:

• Access only the information necessary for our functions.
• Share it only with authorized persons.
• Use approved systems and channels.
• Respect classification, retention, and deletion rules.
• Report losses, improper access, or unauthorized disclosures.

The obligation of confidentiality continues after the termination of the employment or contractual relationship, in accordance with applicable law and agreements.

12. Cybersecurity and Resource Usage

We protect DSS equipment, systems, credentials, and other resources, as well as those of its clients.

We do not share passwords, install unauthorized software, or attempt to access systems without permission.

Security tests must have express authorization and a defined scope.

Incidents or suspicions of fraud, impersonation, equipment loss, or information exposure must be reported immediately through established internal channels.

13. Responsible Use of Artificial Intelligence

The use of artificial intelligence must comply with DSS’s security, privacy, and intellectual property policies.

We must not introduce confidential information, personal data, credentials, or client code into tools that have not been authorized for such use.

Anyone using AI-generated content must review its accuracy, relevance, and potential biases before incorporating it into a decision or deliverable.

We do not use these tools to fabricate evidence, impersonate individuals, deceive, or produce discriminatory content.

Professional responsibility for a decision or outcome is not delegated to a technological tool.

14. Intellectual Property

We respect software licenses, copyrights, trademarks, and agreements regarding developments and content.

We do not copy, distribute, or use materials without the corresponding authorization or license.

Client or third-party information and developments must be handled in accordance with contractual commitments.

15. Records and Asset Use

Financial, commercial, and operational records must be complete, accurate, and reflect actual operations.

Falsifying documents, altering receipts, concealing transactions, creating misleading records, or submitting non-existent expenses is prohibited.

We use funds, equipment, and other assets responsibly. They cannot be used for fraudulent purposes or unauthorized personal gain.

16. Communication and Representation of DSS

Only authorized persons may issue official statements or make commitments on behalf of DSS.

Public, commercial, and social media communications must respect confidentiality, intellectual property, and the truthfulness of information.

Personal opinions must not be presented as official positions of the group.

The use of client names, brands, images, or references requires the corresponding authorizations.

17. Environmental and Social Responsibility

We promote the efficient use of resources, waste reduction, and responsible management of equipment and materials.

Claims about environmental or social impact must be verifiable and supported.

We seek respectful relationships with the communities in which we operate and consider the impacts of our activities.

18. Inquiries and Reports

Every person covered by this Code must communicate any reasonable suspicions of non-compliance they become aware of.

Conclusive evidence is not required to report. Information must be presented honestly, describing known facts and avoiding speculation.

Reports can be directed to the immediate supervisor, provided they are not involved, or to the designated ethics channel. It is not mandatory to go to the supervisor first.

Ethics Channel: [approved email or platform]
Reception Manager: [designated position or committee]
Alternative Channel for Conflicts of Interest: [to be completed]

The report should include, when possible, a description of the facts, dates, involved individuals, and available documents.

These channels do not limit the right to approach competent authorities.

19. Confidentiality and Protection Against Retaliation

DSS prohibits retaliation against those who, in good faith, raise concerns, report potential non-compliance, or cooperate in an investigation.

This protection applies even if the reported concern is not confirmed.

Reports will be handled with restricted access to those who need to intervene, respecting legal obligations and the right to defense.

Absolute confidentiality will not be promised when disclosure duties exist.

The deliberate submission of false information may lead to measures in accordance with applicable regulations.

20. Review and Investigation

Reports will be evaluated in a timely, objective, and impartial manner by individuals without conflicts of interest.

Evidence will be protected, and the rights of all parties will be respected.

Destroying documents, interfering with an investigation, or pressuring involved individuals is prohibited.

When a report affects the person who would normally handle it, it must be transferred to an independent body.

The results will lead to appropriate corrective and follow-up actions.

21. Consequences of Non-Compliance

Non-compliance may result in measures proportionate to the severity of the facts, in accordance with legislation, internal procedures, and applicable contracts.

These measures may include training, corrective actions, disciplinary sanctions, termination of employment or contractual relationships, and communication to authorities when appropriate.

Failures in supervision, concealment, and retaliation will also be evaluated.

22. Responsibility of Leaders

Leaders must lead by example, explain behavioral expectations, and make it easy for people to raise concerns without fear.

They must not order, tolerate, or ignore actions contrary to this Code.

Achieving results never justifies violating DSS principles.

23. Administration and Updates

DSS Legal will coordinate the implementation, communication, training, and review of this Code.

Its approval and adoption will correspond to the competent bodies of the holding company and the group’s subsidiaries, according to their structure and applicable regulations.

The Code will be reviewed periodically and when there are relevant changes in operations, risks, or legal obligations.

24. Individual Responsibility

All individuals to whom this Code applies must know it, comply with it, and participate in the corresponding training activities.

Before acting, we must ask ourselves:

• Is it legal and authorized?
• Is it consistent with our principles?
• Does it protect people’s information and rights?
• Could I explain this decision transparently?

If there is a doubt, we must seek guidance before proceeding.

DSS
Code of Ethics and Conduct
Version 1.0
Effective Date: September 28, 2026
Approved by: DSS Legal