Diabos Ethics Policy

Internal Code of Ethics

DIABOS Global Fze, its subsidiaries and representatives, herein referred to as DIABOS, will conduct their business honestly and ethically. The company shall constantly strive to improve the quality of its products, services, and operations, and to be driven by honesty, transparency, fairness, responsibility, and integrity. No illegal or ethical conduct on the part of its officers, directors, employees, or affiliates could be in the interest of the company. DIABOS will not compromise its principles for short-term gains. The ethical performance of the company stems from the conduct of its stakeholders, and hence, they are all expected to maintain high levels of personal integrity.

Officers, directors, employees, and affiliates must never permit their personal interests to conflict, or appear to conflict, with the interests of the company or the ideals it stands for. All such stakeholders should refrain from using the company’s contacts for their personal interests. Officers and employees of DIABOS are not permitted to run or be directly associated with any private businesses outside the company.

No bribes, kickbacks, remuneration, or other consideration shall be offered to any person or company even if it is in the interest of the company or its customers. No officers, directors, employees, and affiliates are permitted to accept kickbacks, rebates, bribes or remuneration either for their personal benefit or on behalf of the company or its customers.

DIABOS representatives, who have access to confidential customer data or vendor data, have to abide by strict non-disclosure rules and provisions incorporated in the Service Level Agreement. The use of such data is permitted only for checking and auditing purposes. All such data must be returned to the customer and no records should be kept with DIABOS once the SLA has expired. Misuse of customer or vendor data by any individual associated with the company, exposes him or her to penalties and civil liabilities under the Indian Penal Code and the Foreign Corrupt Practices Act of 1977 (FCPA).

Officers, directors, employees, and affiliates are not permitted to source unauthorized data from external entities unless it is provided willingly for any use that could be advantageous to DIABOS or its customers.

Officers and employees of the company, who are involved in the process of auditing and passing Disbursement Accounts, have to maintain a clear audit trail for all the actions taken. The same should be available in the DIABOS system at all times. No entry in a Disbursement Account can be modified unless it is authorized in writing or through verbal confirmation and is supported by an email from the vendor or the customer. DIABOS is an auditor and not a service provider.

Officers, directors, and employees are:

• Required to abide by the provisions of the Service Level Agreement signed with a customer. Any deviations warrant a written consent or authorization from the customer;
• not permitted to make any unauthorized changes to the process followed for checking a Disbursement Account that might benefit a vendor;
• expected to refrain from gathering competitor intelligence by illegitimate means. They shall refrain from acting on such knowledge if they happen to acquire the knowledge indirectly.

Unwavering ethics are essential for the reputation and growth of the company. Violation of this code of ethics can attract penalization including, but not limited to, possible termination or action as prescribed by the Indian Penal Code or FCPA policies.

Ethics Policy Statement

As a company that checks and audits disbursement accounts on behalf of its customers, DIABOS and all its stakeholders must adhere to the highest standard of ethics.

Integrity and confidentiality are vital because DIABOS handles confidential customer and vendor data. This is also essential for maintaining and enhancing the company’s brand image and goodwill, and for ensuring long-term success of its business.

The following points are the key elements of the DIABOS ethics policy:

• Ensuring fair and transparent procedures when checking and querying Disbursement Accounts submitted by agents and vendors. DIABOS will not, unilaterally or arbitrarily, amend any accounting entry unless agreed to by the vendor or instructed by the customer. At every step, the vendor will be informed about changes made to their accounts.
• Ensuring and maintaining customer data confidentiality.
• Ensuring that the DIABOS DA process is transparent and auditable in every process and step.
• To be open to and encourage customers audits.

Scope & Summary of the DIABOS Ethics Policy:

• In India, DIABOS operates in a Special Economic Zone (SEZ), and adheres to the local policies and requirements for maintaining the environment and the security within the SEZ campus.
• The internal Ethics Policy ensures compliance with local policies and strives to create a professional and transparent environment.
• The DIABOS system and processes have a maker-checker mechanism, which ensures quality and minimizes errors and fraud.
• DIABOS has developed robust Disbursement Accounts auditing processes to detect fraud. It also has strict anti-bribery and anti-corruption policies for all stakeholders.
• DIABOS has included the ethics and anti-corruption policies and procedures into its regular ISO and ISAE audits to ensure that the best practices and norms are adopted.

DIABOS supports clients who are listed in the Stock Exchanges and have to adhere to strict anti-corruption policies in compliance with FCPA and UK anti-bribery acts. DIABOS has its procedures audited by KPMG for FCPA and UK Anti-Bribery Act.