Page 29 - Delfi Diagnostics Handbook

The Company encourages employees to use Company email only to communicate with fellow
employees, suppliers, customers, or potential customers regarding Company business. Limited
nonbusiness use of Company Systems may be permitted as long as such use does not:
● substantially increase the Company’s cost;
● interfere with the performance of the individual’s or of co-workers’ job duties and
responsibilities;
● does not represent a waste of Company assets, including undue burdens upon, or risks
to, company Systems or networks.
Employees are responsible for exercising good judgment regarding the reasonableness of
personal use. In the case of any uncertainty, employees should consult their supervisor or
manager. Such personal usage should not cause plan limits to be exceeded. All software in use
on the Company’s Computers is officially licensed software. No software is to be installed or used
that has not been duly paid for and licensed appropriately for the use to which it is being put. No
employee may load any software on the Company’s Computers, by any means of transmission,
unless thoroughly scanned for viruses or other malware prior to installation.

The Company uses a variety of programs and devices to ensure the safety and security of the
Company’s Computers. Any employee found tampering with or disabling any of the Company’s
security devices will be subject to discipline up to and including termination. Any Company
property issued to you must be returned to the Company at the time of your dismissal or
resignation or whenever your manager, or a member of management requests it.

ANTI-CORRUPTION POLICY
As part of DELFI’s commitment to promoting the highest standards of ethical business conduct
and compliance with all applicable laws, rules, and regulations, all DELFI employees worldwide,
including individuals employed by or acting on behalf of DELFI or its subsidiaries, are required to
comply with the Foreign Corrupt Practices Act (“FCPA”), the UK Bribery Act, other anti-bribery
laws, local laws, this Policy, and any procedures developed by management to implement this
Policy.

Conduct Prohibited
DELFI and its officers, employees, agents, and representatives are prohibited from authorizing,
making, offering, promising, requesting, receiving or accepting bribes or accepting kickbacks in
any form:
● Do not authorize, make, offer, promise, request, receive, or accept bribes, kickbacks, or
other improper payments of any sort.
● This prohibition applies to all forms of bribery including commercial bribery as well as
bribery of government officials.
The U.S. and other anti-corruption laws prohibiting bribery are very broad, so that many kinds of
gifts or entertainment provided to government employees might be considered improper. For
that reason, you may not give anything of value to any government official in order to wrongfully
influence the government official, obtain or retain business or receive any advantage. This
prohibition applies regardless of whether the payment or offer of payment is made directly to
the government official or indirectly through a third party.

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