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Responsible Business Practices

DIA TISA, INC.

Code of Conduct and Corporate Policies

Effective Date: July 23, 2025

Introduction & Guiding Principles

DIA TISA, INC. is fundamentally committed to conducting its business with unwavering integrity, accountability, and respect for people and the planet. Our purpose extends beyond profitability to include making a positive impact on society, fostering economic opportunity, and championing ethical practices. This document outlines the core policies that govern our operations, our relationships with employees, clients, and suppliers, and our responsibilities as a global corporate citizen. Adherence to these principles is mandatory for all employees and is a precondition for partnership with our suppliers and clients.

Section 1: Human Rights & Workplace Environment

DIA TISA, INC. affirms the principles of universal human rights as detailed in the United Nations Universal Declaration of Human Rights. We are dedicated to providing a safe, inclusive, and respectful work environment for all our employees.

  • Equal Opportunity & Fair Compensation: We provide equal opportunity for all individuals in recruitment, development, and promotion. We are committed to fair pay practices and creating pathways for professional growth.

  • Dignity and Respect: Our workplace must be free from any form of harassment, discrimination, bullying, or intimidation. We strive to cultivate an environment that supports the mental and physical well-being of every team member.

  • Health & Safety: The health, safety, and security of our employees, customers, and communities are paramount. We are committed to exceeding all applicable health and safety regulations to ensure a secure operational environment.

Section 2: Responsible Sourcing & Supply Chain Due Diligence

DIA TISA, INC. is committed to maintaining a transparent and responsible supply chain, particularly concerning minerals sourced from areas identified as conflict-affected or high-risk (CAHRAs). Our due diligence processes are aligned with the framework established by the Organisation for Economic Co-operation and Development (OECD). We require the same level of commitment from our suppliers.

A. Zero Tolerance for Association with Conflict and Abuse:

DIA TISA, INC. will not, under any circumstances, tolerate, contribute to, or facilitate the sourcing of materials that are linked to human rights abuses or conflict. This includes, but is not limited to:

  • Torture, cruel, inhuman, or degrading treatment.

  • Forced labor, compulsory labor, or modern slavery.

  • The worst forms of child labor.

  • Gross human rights violations, including widespread sexual violence.

  • War crimes, crimes against humanity, or genocide.

B. Prohibition of Support for Illegitimate Groups:

We strictly prohibit any business activities that provide direct or indirect support to non-state armed groups or public or private security forces engaged in illegal activities. Such support includes financial transactions, logistical assistance, or procurement from entities that illegally control, tax, or extort money or materials at any point in the supply chain.

C. Engagement with Security Forces:

When operating in areas where security is a concern, any engagement with public or private security forces must be solely for maintaining the rule of law and ensuring the safety of people and assets. We require that any contracted security providers adhere to the Voluntary Principles on Security and Human Rights and that screening processes are in place to prevent the hiring of individuals or units with a history of human rights abuses.

D. Risk Management and Disengagement:

DIA TISA, INC. continuously monitors its supply chain to identify risks. If a reasonable risk of a supplier’s connection to any prohibited activity is identified, we will immediately implement a risk mitigation plan. If mitigation efforts fail to resolve the issue within a six-month period, DIA TISA, INC. will suspend or permanently terminate its business relationship with that supplier.

Section 3: Anti-Corruption, Anti-Bribery, & Financial Integrity

DIA TISA, INC. has a zero-tolerance policy for bribery and all forms of corruption. We comply fully with the U.S. Foreign Corrupt Practices Act (FCPA) and all other applicable anti-corruption laws in the jurisdictions where we operate.

  • Core Prohibition: No employee or agent of DIA TISA, INC. may offer, promise, give, or authorize the provision of money or anything of value to any individual, private entity, or government official to secure an improper business advantage.

  • "Anything of Value" is interpreted broadly to include cash, gifts, travel, entertainment, political or charitable contributions, employment opportunities, or any other tangible or intangible benefit that could be perceived as improperly influencing a business decision.

  • "Government Official" includes employees of any government agency (local, state, or national), public international organizations, state-owned enterprises, political parties, and candidates for office.

  • Financial Transparency: We are committed to the effective elimination of money laundering. All taxes, fees, and royalties owed to governments in connection with our business activities will be paid accurately and transparently, consistent with the principles of the Extractive Industries Transparency Initiative (EITI).

Section 4: Environmental Stewardship

DIA TISA, INC. acknowledges its responsibility to protect the planet's natural resources for future generations. We are committed to managing our activities in an environmentally responsible manner by:

  • Complying with or exceeding all relevant environmental laws and regulations.

  • Implementing practices to reduce waste, prevent pollution, and conserve resources.

  • Continuously seeking opportunities to minimize our carbon footprint and reduce emissions.

Section 5: Whistleblower Protection & Reporting Concerns

DIA TISA, INC. relies on its employees and partners to help uphold these commitments. We encourage the reporting of any activity that may violate these policies or the law.

  • Reporting Channels: Concerns should be reported to Human Resources or a corporate officer. External stakeholders may report concerns via [Designated Reporting Email].

  • Non-Retaliation: DIA TISA, INC. strictly prohibits any form of retaliation against any individual who, in good faith, reports a concern or participates in an investigation.

  • Confidentiality: All reports will be handled with the utmost discretion, and confidentiality will be protected to the fullest extent possible, consistent with the need to conduct a thorough investigation. Intentionally filing a false report will result in disciplinary action.

Governance & Compliance

The Compliance Officer for DIA TISA, INC. is responsible for the implementation and oversight of these policies. For questions regarding these policies, please contact jwinternetlc@gmail.com. These policies will be reviewed annually to ensure their continued relevance and effectiveness.