1 Dimension Data Code of Conduct

2 Dimension Data Business Partner Code of Conduct

3 Dimension Data Asia Pacific Pte Ltd and its group of companies (“Dimension Data”) are
4 committed to the highest ethical standards throughout our business operations. These standards
5 of conduct are important in maintaining the trust and confidence of all our stakeholders including
6 the communities in which we work. This requires the co-operation of every business partner of
7 Dimension Data, including vendors, agents, suppliers and any other party with whom we have a
8 business relationship. We therefore expect our business partners to take reasonable measures to
9 act in compliance with the principles and standards set out in this Code of Conduct (this “Code”)
10 as may be amended from time to time.

11 Towards this end, every business partner of Dimension Data is required to implement policies
12 and processes to ensure that all your directors, officers and employees, consultants, independent
13 contractors and other third parties who provide goods or perform services for and on your behalf
14 understand and comply with the principles, standards and obligations under this Code.

15 1. Legal compliance

16 1.1 You are required to comply with all applicable legal, statutory and regulatory requirements
17 (including any relevant export law and regulations) of the territory or region where your services
18 are performed and/or your products are processed, manufactured or sold.

19 2. Ethics, values and integrity

20 2.1 You must always act in an ethical manner and with integrity and honesty in all your business
21 dealings to avoid being engaged in activity that involves improper conduct or which appears to
22 involve such conduct.

23 2.2 You should treat everyone you deal with, whether they are Dimension Data’s employees or
24 otherwise, with dignity and respect. Dimension Data does not tolerate violence, the threat of
25 violence or any other intimidating or inappropriate behaviour towards our employees, contract
26 workers, interns or third parties who perform services for or on our behalf.

27 3. Financial integrity and accounting

28 3.1 You must not engage in any actions that could result in conveying false or inaccurate
29 financial information to Dimension Data and/or our clients.

30 3.2 You must ensure that all submissions (e.g. orders, sales reporting, rebates, reimbursement
31 requests) made to Dimension Data are full, fair, accurate, timely, and compliant with applicable
32 financial and legal standards.

33

34 4. Bribery and corruption

35 4.1 Dimension Data has a zero tolerance to all forms of bribery and corruption. You must
36 therefore conduct your business in compliance with all applicable local anti-bribery laws in the
37 country/countries in which you operate as well as international anti-bribery including the US

38 Foreign Corrupt Practices Act and the UK Bribery Act.

39 4.2 You should not pay, offer to pay or promise to pay a facilitation payment except in very
40 exceptional circumstances e.g. threat to life, health and/or safety.

41 4.3 You should maintain your own internal policies and procedures to comply with all such
42 applicable laws as well as this Code.

43 5. Unfair business practices

44 5.1 You must comply with all applicable anti-trust and competition laws and regulations.

45 5.2 You must also compete fairly and ensure that all statements, communications and
46 representations relating to Dimension Data’s products and/or services are accurate, complete and
47 truthful.

48 6. Gifts and entertainment

49 6.1 It is essential that you do not request, provide and/or accept any gifts, favours and
50 entertainment to and from any client or any Dimension Data employee that may result in, or
51 create the appearance of, undue influence.
52 6.2 Ensure that any gift or hospitality that you request, offer or provide to any client or to any
53 Dimension Data employee is a reasonable complement to business relationships and complies
54 with all applicable local and international laws and Dimension Data’s Hospitality and Gifts
55 Policy.

56 7. Intellectual property and confidentiality

57 7.1 You must respect the intellectual property of Dimension Data and third parties.

58 7.2 You should not directly or indirectly use and/or disclose (or allow any third party to use) any
59 of Dimension Data’s and our clients’ confidential and proprietary information, whether during or
60 following the cessation of the business relationship with Dimension Data; and protect such
61 information by storing them in secure places and password protecting sensitive files.

62 7.3 You are expected to respect valid patents, trademarks, copyrighted materials and protected
63 intellectual property of third parties and ensure that appropriate licences or approvals are in place
64 prior to usage of such intellectual property.

65 8. Conflicts of interest

66 8.1 You should not enter into a financial or any other relationship with a Dimension Data
67 employee that creates an actual, potential or perceived conflict of interest, such as where the
68 personal interests of the Dimension Data employee are inconsistent with the responsibilities of
69 his/her position with the company.

70 8.2 You must keep all financial, business or non-work related activities lawful and free of
71 conflicts with your responsibilities to Dimension Data.

72 9. Insider trading

73 9.1 You must not buy, sell or suggest that a third party buys or sells shares, stock or other
74 securities of Dimension Data if you are aware of significant or material non-public information
75 (“insider information”) about us. Significant or material information shall include such
76 information or material which a reasonable investor would consider important in deciding
77 whether to buy, sell or hold securities.
 78 9.2 You should not pass on or disclose any insider information to any party unless lawful and
79 necessary for the conduct of Dimension Data’s business.

80 9.3 You are prohibited from passing or disclosing any information if there is any suspicion that
81 such information will be used for an improper trading purpose.

82 10. Respect for employees’ rights

83 10.1 You should promote equal opportunities and fair treatment for your employees, and not
84 discriminate on the basis of race, colour, religion, politics, opinions, gender, sexual orientation,
85 gender identity or expression, national origin, disability or age.

86 10.2 You should respect the personal dignity, privacy and human rights of each of your
87 employees, including respecting their rights to join or form trade unions and to bargain
88 collectively, or to conduct similar activities.

89 10.3 You are also expected to create a harassment-free work environment and not accept or
90 tolerate any form of harassment, sexual harassment or discrimination in violation of Dimension
91 Data’s

92 Anti-Harassment Policy.

93 10.4 You must not use any form of slave, forced, bonded, indentured or involuntary labor, and
94 shall fully comply with the U.K. Modern Slavery Act 2015, to the extent applicable to you.

95 10.5 You should comply with all applicable employment or labour laws and regulations not
96 expressly mentioned herein, including but not limited to those governing the minimum age to
97 work, working hours and compensation in all locations in which you operate.

98 11. Environmental compliance

99 11.1 We encourage you to strive to minimise the environmental impact of your business
100 activities.

101 11.2 You must comply with applicable environmental laws in the countries in which you operate.

102 12. Occupational health and safety of employees

103 12.1 You should provide your employees with a safe working environment and provide a means
104 to detect and prevent risks to their health and safety.

105 12.2 You should comply with applicable legal requirements concerning occupational health and
106 safety of your employees.

107 12.3 You are required to report any potential or actual violation of occupational health and safety
108 laws or regulations to Dimension Data’s management where such incident may affect or impact
109 us.

110 13. Conflict Minerals

111 13.1 Where applicable, you are required to comply with the obligations set out in Dimension
112 Data’s Conflict Minerals Policy, which aims to minimise the risk of the use of Conflict Minerals
113 in products supplied to Dimension Data.

114 14. Personal Data Protection

115 14.1 You must comply with local personal data protection laws and regulatory requirements or
116 their equivalent relating to the collection, processing, transfer and sharing of personal data in all
117 the countries in which you do business where personal data is provided to you by Dimension
118 Data.

119 15. Export Controls and Trade Sanctions

120 15.1 You must comply with applicable local and international laws and regulations relating to
121 export controls and trade sanctions.