General Business Principles

Updated July 25, 2023

 

DEXMAT’s mission is to drive the next industrial revolution with the goal of making dirty metals obsolete. Our General Business Principles govern how we conduct our affairs.

 

DEXMAT Values:

• Climate-positive and carbon-negative;
• Safety in all domains: societal, physical, and psychological;
• Striving for excellence, and aspiring for impact at scale; and
• Entrepreneurial CNTs: strong, lightweight, energetic, and flexible.

DEXMAT Principle 1: Economic

Long-term profitability is essential to achieving our business goals and to our continued growth. It is a measure both of efficiency and of the value that customers place on DEXMAT products and services. It supplies the necessary corporate resources for the continuing investment that is required to develop and produce Galvorn.

Principle 2: Competition

DEXMAT seeks to compete fairly and ethically and within the framework of applicable competition laws; we will not prevent others from competing freely with us. We seek competitive advantages through superior performance, never through unethical or illegal business practices.

Principle 3: Business Integrity

DEXMAT insists on honesty, integrity and fairness in all aspects of our business and expects the same in our relationships with all those with whom we do business. The direct or indirect offer, payment, soliciting or acceptance of bribes in any form is unacceptable. Facilitation payments are also bribes and must not be made. Employees must avoid conflicts of interest between their personal or private activities and their part in the conduct of company business, which exists when the employee’s personal or private interest interferes - or even appears to interfere - with the interests of DEXMAT. It is also a conflict of interest for an employee to work for a DEXMAT competitor, customer or supplier. Each employee should avoid any direct or indirect business connection with our customers, suppliers or competitors, except as required on behalf of DEXMAT. Employees must also declare to DEXMAT potential conflicts of interest. All business transactions on behalf of DEXMAT must be reflected accurately and fairly in the accounts of the company in accordance with established procedures and are subject to audit and disclosure.

a. Procurement Integrity in Government Contracts

It is contrary to this Code to seek another contractor’s bid or proposal information or U.S. Government source selection information prior to contract award and other than as provided by law. Moreover, DEXMAT Representatives may not engage in discussions with federal agency officials relating to future employment opportunities if those officials are participating or have participated in a procurement action or contract in which DEXMAT is or has been involved. Offers from third parties to provide unauthorized contractor bid and proposal information or source-selection information must be immediately reported to your supervisor, and/or corporate DEXMAT Representative.

b. Export and Import Restrictions

DEXMAT Representatives must comply with all export and import laws and regulations. These controls are highly complex and even unintentional violations can result in severe penalties. Therefore, you are strongly encouraged to seek guidance, if you have any doubt as to the meaning of any relevant law, whenever importing or exporting items on behalf of DEXMAT.

c. Gifts and Gratuities

The purpose of business entertainment and gifts in a commercial setting is to create goodwill and sound working relationships with customers, not to gain an unfair advantage over DEXMAT’s competition. No gift or entertainment should ever be offered, given, provided or accepted by any DEXMAT Representatives (or any family member of such individuals) unless it: (1) is not a cash gift, (2) is consistent with customary business practices, (3) is reasonable in value, (4) cannot be construed as a bribe or payoff and (5) does not violate any federal, state, or local laws, regulations or applicable policies of the other party’s organization. You are required to discuss with your Corporate DEXMAT Representative or Senior Management any gifts or proposed gifts which you are not certain are appropriate.

d. Payment to Government Personnel

It is contrary to this policy to give or promise anything of value to a government official or employee, U.S. or foreign, for the purpose of influencing that person in his or her official duties, to encourage unlawful conduct, or because of any official act performed or to be performed by that person. Importantly, this prohibition extends to foreign government officials and employees. For example, the U.S. Foreign Corrupt Practices Act (FCPA) prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. DEXMAT policy strictly prohibits providing, directly or indirectly, any illegal payments to government officials of any country. These prohibitions on payments or promises for anything of value to, or from, Government officials are broad, and the U.S. government has a large number of laws and regulations regarding business gratuities which may be accepted by foreign and domestic government personnel. Moreover, state and local governments often have similar rules that DEXMAT Representatives must also be aware of and adhere to. In sum, payments or promises for anything of value to Government officials not only violate DEXMAT policy but can also result in substantial civil and/or criminal penalties.

e. Kickbacks

DEXMAT Representatives may not provide anything of value, monetary or non-monetary, for the purpose of improperly seeking favorable treatment in connection with a Government contract. This prohibition includes the giving of any money, fee, commission, credit, gift, gratuity, thing of value, or compensation of any kind to any government contractor, or their employees, for the purpose of improperly obtaining or rewarding favorable treatment in connection with a Government contract.

Principle 4: Political Activities

a. DEXMAT

DEXMAT acts in a socially responsible manner within the laws of the countries in which we operate in pursuit of our legitimate commercial objectives. DEXMAT does not make payments to political parties, organizations or their representatives. DEXMAT does not take part in party politics. However, when dealing with governments, DEXMAT has the right and the responsibility to make our position known on any matters, which affect us, our employees, our customers, our shareholders or local communities in a manner, which is in accordance with our values and the Business Principles.

b. Employees

Where individuals wish to engage in activities in the community, including standing for election to public office, they will be given the opportunity to do so where this is appropriate in the light of local circumstances. Moreover, it is contrary to this policy to contribute funds to any political party or candidate while acting as a representative of DEXMAT. Therefore, you cannot contribute or donate on behalf of DEXMAT, either directly or indirectly, funds, products, services or other resources for any political cause, party or candidate. You may make voluntary personal contributions to any lawful political causes, parties or candidates if it is clear that such contributions are personal and private in nature and are not being made as a DEXMAT representative or otherwise on behalf of DEXMAT.

Principle 5: Health, Safety, Security and the Environment

DEXMAT has a systematic approach to health, safety, security and environmental management in order to achieve continuous performance improvement. We continually look for ways to reduce the environmental impact of our operations, products and services.

Principle 6: Local Communities

DEXMAT aims to be a good neighbor by continuously improving the ways in which we contribute directly or indirectly to the general well-being of the communities within which we work.

We manage the social impacts of our business activities carefully and work with others to enhance the benefits to local communities, and to mitigate any negative impacts from our activities.

In addition, DEXMAT takes a constructive interest in societal matters, directly or indirectly related to our business.

Principle 7: Communication and Engagement

DEXMAT recognizes that regular dialogue and engagement with our stakeholders is essential. We are committed to reporting of our performance by providing full relevant information to legitimately interested parties, subject to any overriding considerations of business confidentiality.

In our interactions with employees, business partners and local communities, we seek to listen and respond to them honestly and responsibly.

Principle 8: Compliance

We comply with all applicable laws and regulations of the countries in which we operate.