This Code of Conduct sets forth legal and ethical standards for directors, officers, contractors and employees (“Staff”) of DelAgua Group of companies (“The Company”). This Code is intended to deter wrongdoing and to promote the ethical conduct of all Company business.

Compliance with Laws, Rules and Regulations

The Company requires that all Staff comply with all laws, rules and regulations applicable to the business. You are expected to use sound judgment and common sense to comply with all applicable laws, rules and regulations.

If you become aware of the violation of any law, rule or regulation by the Company, whether by its Staff, or any third-party doing business on behalf of the Company, it is your responsibility to promptly report the matter to your Country Manager or Company Director.

Conflicts of Interest

Staff must act in the best interests of the Company. You must refrain from engaging in any activity or having a personal interest that presents a “conflict of interest.” It is your responsibility to disclose any transaction or relationship that reasonably could be expected to give rise to a conflict of interest.


Staff must maintain the confidentiality of any information entrusted and to them in their capacity with The Company. Unauthorised disclosure of any confidential information is prohibited. Additionally, Staff should take appropriate precautions to ensure that confidential or sensitive business information, whether it is proprietary to the Company or another company, is not communicated within the Company except to Staff who have a need to know such information to perform their responsibilities.

Honest and Ethical Conduct and Fair Dealing

Staff should deal honestly, ethically and fairly with the DelAgua Group’s suppliers, customers, competitors and all Staff. Statements regarding the Company’s products and services must not be untrue, misleading, deceptive or fraudulent. You must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice.

Protection and Proper Use of Corporate Opportunities

Staff must advance The Company’s legitimate interests when the opportunity to do so arises. You must not take for yourself personal opportunities that are discovered through your position with the Company or the use of property or information of the Company.

Accuracy of Books and Records and Public Reports

DelAgua Group expects Staff to honestly and accurately report all business transactions. You are responsible for the accuracy of your records and reports. Accurate information is essential to the Company’s ability to meet legal and regulatory obligations.

Reporting and Compliance Procedures

Every member of Staff has the responsibility to ask questions, seek guidance, report suspected violations and express concerns regarding compliance with this Code or their contract. Any employee, officer or director who knows or believes that any other employee or representative of the Company has engaged or is engaging in Company-related conduct that violates applicable law or this Code should report such information to their supervisor or Collyer Bristow HR Dpt. Such reports should be made without any fear of retaliation. The Company will not discipline, discriminate against or retaliate against any employee who reports such conduct, unless it is found that the report was made with knowledge that it was false, or who cooperates in any investigation or inquiry regarding such conduct

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