We are committed to conducting our business in an ethical, transparent way, using our values – i.HOPE and Code of Business Ethics to guide us:

We expect our employees to treat others with respect, fairness and dignity. Our Code of Business Ethics sets clear expectations for how we work at d.light. It applies to all employees and members of the board. We also expect our contractors and their employees to act in a way that is consistent with our code. If those expectations are not met, we take appropriate action. We train our employees on how to apply the code in their daily work.

Right to be heard
We want our employees, contractors and other third parties to feel comfortable speaking up whenever they have a question or concern about our code or if they see something that they feel is unethical or unsafe. That’s why we encourage anyone making a report of suspected unethical or improper practices to either address their concerns via whistleblower (d.light’s independently manned confidential helpline), details of which can be found below OR via d.light’s whistleblowing platform on https://integritycounts.ca/org/dlight

d.light has zero tolerance for retaliation against anyone who seeks advice, raises a concern, reports misconduct or participates in an investigation in good faith. The consequences for misconduct or retaliation range from coaching and performance management through to dismissal, in line with d.light’s disciplinary process guide.

Engaging with suppliers
We hold sessions with suppliers to help them understand our Code of Business Ethics and how we do business. Topics discussed included anti-bribery and corruption, conflict of interest scenarios and grievance processes.

Anti-bribery and corruption
d.light operates in parts of the world where bribery and corruption present a high risk. Our Code of Business Ethics explicitly prohibits engaging in bribery or corruption in any form. Our group-wide anti-bribery and corruption policy and procedures include measures and guidance to assess risks, understand relevant laws and report concerns. We provide training to employees appropriate to the nature or location of their role.

We assess any exposure to bribery and corruption risk when working with suppliers and business partners. Where appropriate, we put in place a risk mitigation plan or we reject them if we conclude that risks are too high. We also conduct anti-bribery compliance audits on selected suppliers when contracts are in place. We take corrective action with suppliers and business partners who fail to meet our expectations, which may include terminating contracts.

Lobbying and political donations
We prohibit the use of d.light funds or company resources to support any political candidate or party. We however recognize the rights of our employees to participate in the political process and these rights are governed by the applicable laws in the countries where we operate.

What issues should we report?
This helpline and the whistleblowing platform can be used to report suspicious behaviors related to below issues including but not limited to:

• Unethical business practices like bribes taken / given
• Non-financial significant favors, gifts beyond the defined guidelines
• Misuse of company funds, assets, property, facilities etc.
• Negligence causing substantial risk to public health and safety
• Manipulation of company data / records
• Financial irregularities, including fraud, or suspected fraud
• Abuse of authority
• Criminal offence
• Theft of confidential / proprietary / customer information
• Violation of the law / regulation organization wide
• Embezzlement of company funds/assets
• Breach of employee Code of Conduct or Rules
• Any other unethical behavior

What happens next?
All reported cases will be directly sent into the management database of the independent 3rd party vendor, for further follow up. If you wish to leave us a way to contact you, in case we require further information as necessary, please feel free to do so. All information left on this platform will be managed by the 3rd party in accordance with the d.light’s whistleblower policy in force at the time.

Toll-free Helplines:

• • USA:  1-866-921-6714

• • China:  400-120-8514 (press ‘0’ to get a live Chinese interpreter)

• • India: 0008001007980

• • Kenya: 0800-221-371

• • Uganda: 0800-113-215

• • Nigeria: 1-227-8919

• • Tanzania: 1-604-922-5953 (collect call + instructions*)

• • Ethiopia: 1-604-922-5953 (collect call + instructions*)

Instructions for collect calls:

Step 1: Call your international operator

Step 2:  Ask the operator to place a collect call to 1-604-922-5953

Step 3:  When the call is accepted by Whistleblower reception, ask for a Whistleblower Agent

Step 4:  Report your incident to the agent.