DPI Laboratory – Code of Conduct

This code is designed to provide all employees of DPI Laboratory with guidelines for appropriate professional conduct. It is intended not as a statement of new beliefs or a codification of new rules of conduct, but as a reaffirmation of enduring values and practices.
 The central theme and principle of this code is that DPI Laboratory’s' reputation for quality testing, assessment, research and consultation services, for business integrity, and for the independence and integrity of our services is the heart and soul of our laboratory. Put another way, it is an essential prerequisite for success in the service and business that our customers believe us to be telling them the truth. If we are not telling them the truth -- or even if they, for any valid reason, believe that we are not - then DPI Laboratory cannot prosper. The Company will suffer, for example, if our customers cannot assume that:

 
     
  • Our testing result and facts are accurate and fairly presented
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  • Our report, analysis, assessment and testing result are valid with no compromise to undue influence
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  • Our analyses represent our best independent judgments rather than our preferences, or those of our sources or information providers
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  • Our opinions represent only our own professional knowledge, or
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  • There are no hidden agendas in any of our testing professional undertakings
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       All companies profess business integrity. But the impact of our work on the work of others, and on their lives and fortunes, places special responsibilities upon all DPI Laboratory employees.
        The clear implication of these beliefs is that the responsibility for safeguarding and growing a Company that lives up to this code lies with each and every one of us. Every DPI Laboratory employee holds a position of trust. Acceptance of a position at any level or in any part of DPI Laboratory includes acceptance of individual responsibility to uphold the Laboratory policies governing legal and ethical business practices. It also includes acceptance of individual responsibility for following all legal requirements and ethical business practices, as well as the responsibility to stress proper ethical behavior among colleagues and subordinates.  
   Moreover, it must be clear to each of us that business integrity is necessary in every business decision- and that it is not the special province of news employees, or members of the legal department, or anyone else. Business integrity requires that we make all of our business decisions, and approach all business questions, objectively and realistically, and in the long-term best interests of all of our shareholders.
   Managers, by virtue of their positions of authority, must be ethical role models for all employees. An important part of a manager's leadership responsibility is to exhibit the highest standards of integrity in all dealings with employees, customers and the world at large. Managers must avoid even implicit or unspoken approval of any actions that may be damaging to the reputation of DPI Laboratory, and must always exercise sound judgment in the performance of their duties.
   An equally important leadership responsibility is to develop employees' commitment to our principles and ability to make sound ethical judgments. Managers must communicate the seriousness of the Company's expectations of ethical conduct, as well as their own personal support for these guidelines. Ethical leadership includes fostering a working environment that encourages employees to voice concerns or otherwise seek assistance or counsel if faced with potentially compromising situations, and also supporting those who raise such concerns.
   Finally, what follows is not intended to be an exclusive or inclusive list of all laws, regulations and other norms applicable to DPI Laboratory and with which compliance is expected. In our rapidly evolving businesses and testing services, a complex environment that often requires quick response under pressure challenges each of us. No written policy can definitively set forth the appropriate action for all business situations. Accordingly, this code emphasizes and clarifies a standard of ethical conduct that must govern all of our business dealings and relationships. In addition, more detailed guidelines for managers are now available for some of the topics covered by this code, and others will be promulgated from time to time; some teams also issue specialized guidelines of their own.
 

Confidential Information

 Any and all information and other material obtained by a DPI Laboratory employee in connection with his or her employment is strictly the property of DPI Laboratory. Such information includes not only our own work and that of our colleagues, but also information relating to future activities, including as-yet-unpublished reports, information, research and advertising, as well as schedules for publishing or issuing the same. Such material must never be disclosed to anyone outside DPI Laboratory, including friends and relatives. In no event should any information obtained in connection with DPI Laboratory employment be disclosed privately to anyone until such information has been made available to the public or being written approved by Director of Product Integrity.
  Similarly, the use of DPI Laboratory’s property of this sort - i.e. forthcoming reports, information or articles - as a basis for any decision is strictly prohibited. No employee with knowledge of any such forthcoming material may, prior to publication, buy or sell products or in any way encourage or assist any other person in buying or selling the products, directly or indirectly, based on that information. These strictures should continue in force until the article or report appears in a DPI Laboratory official publication or release.
  These rules also apply, of course, to confidential information about our own Company. DPI Laboratory employees may not disclose to others any confidential information belonging to the Company, nor may they use such information for their personal benefit or that of others. Each of us who possesses or has access to confidential information has an important responsibility to keep that information confidential and to prevent it from being disclosed to others outside or inside DPI Laboratory, either purposefully or otherwise.
   This obligation applies not only during DPI Laboratory employment, but thereafter as well.In addition, it is important to take care not to discuss such confidential matters with family members or business or social acquaintances or in places where one can be overheard. Within DPI Laboratory, confidential business information should be divulged only to other employees who need to know the information in order to carry out their business responsibilities.
 

Compliance with Law, Rules and Regulations

 All employees must obey the applicable laws, rules and regulations of the People’s Republic of China and relevant laws of product safety and obligation of testing institute of United States. All employees engaged in business outside of the counties abovementioned must obey the applicable laws of countries in which they do business, and respect local culture and values while operating within the strictures of such laws and this code. All applicable trade agreements, including U.S. trade laws, must be honored and observed, including the U.S. Foreign Corrupt Practices Act, which generally makes it illegal to offer or give a bribe to a foreign official or candidate for foreign office, whether directly or through third parties such as consultants or agents.

Disclosure Requirements
It is the Company's policy that all disclosures made by the Company in its filings with the Consumer Product Safety Commission, Custom Office of China and United States and all relevant Accredited and Certified Bodies and to community should be accurate, complete, and understandable to the reader and fairly present the condition and results of all material or product respects. All such filings should be made on a timely basis as required by applicable laws. It is the duty and responsibility of the Director and Manager to carry out this policy.

Environmental Concerns
DPI Laboratory is committed to maintaining a safe work environment by eliminating all significant recognized hazards in the workplace, and to conducting business in an environmentally sound manner based on scientific understanding, customer needs and local requirements. Employees are required to comply with all applicable health, safety and environmental laws and regulations, and all related Company policies.

Compliance with this Code
DPI Laboratory takes this code of conduct very seriously. All employees of DPI Laboratory are responsible for compliance with all aspects of this code. All new employees shall be required to read this code at the outset of their employment, and to attest in writing that they have done so; all DPI Laboratory employees shall be required, at the time this code is first promulgated, to read it and so attest. In the case of all members of senior management, and all news and marketing personnel, such written attestations shall be required once each year. The matters addressed by this code are sufficiently important that any lapse in judgment within the areas covered here may be considered serious enough to warrant discipline up to and including dismissal.
Any employee who has a question about or becomes aware of his or her own possible violation of this code or by any other employee, or who becomes aware that he or another employee is involved in a transaction or relationship that could reasonably give rise to an actual or apparent conflict of interest, should promptly discuss the situation with his or her supervisor or with the Director of Product Integrity immediately. Every effort will be made to maintain the confidentiality of such discussions. The Company will not permit or tolerate any retaliation against any employee who makes a good faith report about a possible violation of the code by another employee. Indeed, the most important wisdom about dealing with these questions is: “preventing it before happen”.