DCL International Inc. is committed to upholding human rights across our supply chains and business operations, and to ensuring that modern slavery and forced labour have no place within them. We believe that respect for human dignity is fundamental, not only as an expression of our core values, but as a cornerstone of the way we conduct business and engage with our partners and stakeholders.

1. INTRODUCTION AND APPLICATION
   
   1. This Supplier Code of Conduct (the “Code”) outlines minimum standards that DCL International Inc. (the “Company”, “we”, “us” or “our”) expect our suppliers to follow in relation to ethical issues to ensure that working conditions at our suppliers and subcontractors are safe, that workers are treated with respect and dignity and that business is done in an ethical way.
   2. This Code applies to our entire supply chain including the distributors, agents, consultants, entrepreneurs, subcontractors, business partners, service providers, and suppliers of the Company and of any affiliated company (each, a “Supplier”).
2. COMPLIANCE WITH LAWS
   
   1. Suppliers must comply with this Code and with all applicable laws, regulations and standards in all of the countries in which they operate, including without limitation, international standards and laws on fraud and money laundering, laws prohibiting bribery of government officials and other corrupt practices, as well as international human rights principles set out in the UN Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and the International Labor Organization.
   2. We also expect our Suppliers to use their best efforts to conduct themselves in accordance with the general principles and standards set out herein as well as through their own supply chain, when appropriate. Suppliers shall make the necessary adjustments to their business practices to ensure compliance with this Code.
   3. In the event that legal or regulatory requirements applicable to a Supplier’s business/operation differ from this Code, Suppliers should adopt the more stringent requirements of the two.
3. FORCED LABOUR
   
   1. Suppliers shall not use any form of forced or compulsory labour as defined in the Forced Labour Convention, 1930, or any labour or service provided or offered to be provided by a person under circumstances that could reasonably be expected to cause the person to believe their safety or the safety of a person known to them would be threatened if they failed to provide or offer to provide the labour or service.
   2. All employment shall be voluntary. Employees must have the right to leave work and freely terminate their employment within legal notice period requirements.
   3. Employees must not be required, as a condition of employment, to make a deposit of, or surrender any government-issued identification, passports, work permits or any other documents necessary for free movement and termination of employment.
4. CHILD LABOUR
   
   1. Suppliers shall not employ children (persons under the age of 18) for labour or services that:
      
      1. are provided or offered to be provided in Canada under circumstances that are contrary to the laws applicable in Canada;
      2. are provided or offered to be provided under circumstances that are mentally, physically, socially or morally dangerous to them;
      3. interfere with their schooling by depriving them of the opportunity to attend school, obliging them to leave school prematurely or requiring them to attempt to combine school attendance with excessively long and heavy work; or
      4. constitute the worst forms of child labour as defined in article 3 of the Worst Forms of Child Labour Convention, 1999, adopted at Geneva on June 17, 1999.
5. EMPLOYMENT STANDARDS
   
   1. We expect our Suppliers to treat all employees and persons with whom they do business with integrity, fairness and respect.
   2. Suppliers shall:
      
      1. protect their own business, and their supply chain, from any instance of forced labour or child labour;
      2. only employ workers that have a legal right to work in the country in which they are to be employed;
      3. verify a worker’s legal eligibility to work, prior to employment, and keep employment records of their workers accessible at all times;
      4. provide fair wages to their employees within the country of operation;
      5. uphold reasonable working hours within the country of operation;
      6. ensure humane treatment of all employees, contractors and subcontractors;
      7. ensure all labour agencies engaged comply with this Code;
      8. provide a safe, healthy, and hygienic work environment;
      9. permit rights to freedom of association and collective bargaining; and
      10. treat all employees with respect and dignity and take active steps to eliminate discrimination.
6. NO DISCRIMINATION
   
   1. Suppliers shall not tolerate discriminatory behaviour on the basis of any personal or social characteristics, including race, colour, gender, nationality, age, disability, union membership, maternity, sexual orientation, marital status, gender identity or expression.
7. RESPONSIBLE SOURCING
   
   1. Suppliers shall comply with all applicable Conflict Minerals rules and regulations and exercise appropriate due diligence while sourcing such minerals. Suppliers shall adopt policies and procedures that are reasonably designed to prevent products or parts that are not responsibly sourced from entering the Company’s supply chain.
8. REPORTING CONCERNS
   
   1. Suppliers or individuals with concerns about potential violations of this Code are encouraged to contact us at: [email protected].
   2. Suppliers must not retaliate against any worker or individual who, in good faith, raises a concern about compliance with this Code.
9. COMPLIANCE AND CORRECTIVE ACTION
   
   1. The Company reserves the right to monitor Supplier compliance with this Code through audits, assessments, and other means deemed appropriate. Suppliers are expected to cooperate fully with the Company in these monitoring efforts and to promptly address any issues identified.
   2. Any violation of this Code may result in corrective action. The appropriate action in a particular case depends on the nature and severity of the violation and the circumstances surrounding the situation.
10. UPDATES TO CODE
    
    1. The Company may update this Code from time to time to reflect changes in law, industry standards, or our own practices. The most current version will govern.
11. QUESTIONS
    
    1. If you have any questions regarding the Code, please contact Hossein Nayebi via the following email address: [email protected].