Effective Date: February 2026

1. Introduction and Purpose

This Code of Conduct establishes the ethical standards and behavioral expectations for all employees, contractors, suppliers, partners, and stakeholders of Doctor Food Vitality Limited ("DFV", "we", "us", or "our"). Our Code reflects our commitment to integrity, transparency, and excellence in serving the people of Zambia with safe, quality products. All individuals associated with DFV are expected to read, understand, and comply with this Code.

2. Our Core Values

3. Compliance with Laws and Regulations

DFV is committed to full compliance with all applicable Zambian laws and regulations, including but not limited to:

• Food Safety and Quality Standards: Zambia Bureau of Standards (ZABS) regulations, Zambia Compulsory Standards Act, and all food safety requirements
• Labor and Employment: Employment Act, Industrial and Labour Relations Act, Minimum Wages and Conditions of Employment Act, Workers' Compensation Act
• Health and Safety: Occupational Health and Safety Act and all workplace safety regulations
• Environmental Protection: Environmental Management Act and regulations governing waste disposal and water usage
• Business Regulations: Companies Act, Patents and Companies Registration Agency (PACRA) requirements, tax laws administered by the Zambia Revenue Authority (ZRA)
• Anti-Corruption: Anti-Corruption Act and all anti-bribery legislation
• Consumer Protection: Competition and Consumer Protection Act

All employees and partners must familiarize themselves with relevant laws governing their work and seek guidance when uncertain about legal requirements.

4. Workplace Conduct and Professionalism

4.1 Respect and Dignity

We foster a work environment based on mutual respect where:

• All employees are treated with dignity regardless of race, ethnicity, gender, religion, age, disability, or any other characteristic
• Discrimination, harassment, bullying, or intimidation of any kind is strictly prohibited
• Communication is conducted professionally and respectfully
• Different perspectives and backgrounds are valued and respected

4.2 Professional Behavior

All DFV employees and partners are expected to:

• Arrive to work on time and fulfill job responsibilities diligently
• Dress appropriately and maintain professional appearance
• Communicate clearly, honestly, and respectfully with colleagues, customers, and partners
• Avoid conflicts of interest or activities that compromise professional judgment
• Refrain from working under the influence of alcohol or drugs
• Use company resources responsibly and only for authorized purposes

4.3 Zero Tolerance for Harassment

DFV has zero tolerance for sexual harassment, verbal abuse, physical intimidation, or any form of workplace harassment. Any incidents must be reported immediately to management, and all reports will be investigated promptly and confidentially. Retaliation against individuals who report concerns is strictly prohibited.

5. Health, Safety, and Product Quality

5.1 Workplace Health and Safety

The health and safety of our employees is paramount. DFV commits to:

• Providing a safe, clean, and healthy work environment in compliance with Zambian occupational health and safety laws
• Providing necessary safety equipment and training for all employees
• Maintaining machinery and equipment in safe working condition
• Investigating and addressing safety incidents and hazards promptly
• Encouraging employees to report unsafe conditions without fear of retaliation

All employees must follow safety protocols, use protective equipment, and report hazards immediately.

5.2 Product Safety and Quality

DFV's reputation depends on the safety and quality of our products. We maintain zero tolerance for:

• Compromising product safety or quality standards
• Ignoring or concealing quality control failures
• Using contaminated or substandard raw materials
• Tampering with production processes or quality testing results
• Bypassing hygiene and sanitation protocols

Any employee who becomes aware of a product safety concern must report it immediately to management.

5.3 Hygiene and Sanitation

All employees involved in production, packaging, or handling of products must adhere to strict hygiene standards, including proper handwashing, use of protective clothing, and compliance with all sanitation protocols to prevent contamination.

6. Ethical Business Practices

6.1 Anti-Corruption and Bribery

DFV strictly prohibits all forms of corruption, bribery, and unethical payments. Employees must not:

• Offer, give, solicit, or accept bribes, kickbacks, or improper payments
• Make facilitation payments to government officials or private parties
• Provide gifts, entertainment, or favors that could improperly influence business decisions
• Engage in fraud, embezzlement, or financial misconduct

This policy applies to all interactions with government officials, customers, suppliers, and business partners in accordance with Zambia's Anti-Corruption Act.

6.2 Fair Competition

DFV competes fairly and honestly in the marketplace. We do not engage in anti-competitive practices, price-fixing, market manipulation, or any activities that violate competition laws.

6.3 Honest Marketing and Advertising

All marketing materials, product claims, and customer communications must be truthful, accurate, and not misleading. We do not make false or exaggerated claims about our products.

7. Respect for Employees and Labor Rights

7.1 Fair Employment Practices

DFV is committed to fair labor practices in accordance with Zambian employment laws:

• All employees receive written employment contracts outlining terms and conditions
• Wages meet or exceed legal minimum wage requirements and are paid on time
• Working hours comply with legal limits, and overtime is compensated appropriately
• Employees receive statutory leave entitlements including annual leave, sick leave, and maternity leave
• Employment decisions are based on merit, qualifications, and performance

7.2 No Child Labor or Forced Labor

DFV strictly prohibits child labor and forced labor. We do not employ anyone under the legal working age as defined by Zambian law, and all employment is voluntary. We expect the same commitment from our suppliers and partners.

7.3 Freedom of Association

DFV respects employees' rights to freedom of association and collective bargaining in accordance with Zambian labor laws.

8. Confidentiality and Data Protection

Employees must protect confidential company information and customer data:

• Business strategies, financial information, and trade secrets must be kept confidential
• Customer personal information must be protected and used only for legitimate business purposes
• Confidential information must not be shared with unauthorized parties or used for personal benefit
• Company documents and records must be maintained securely and accurately

9. Environmental Responsibility

DFV is committed to environmental stewardship and sustainable practices:

• We comply with all environmental laws and regulations in Zambia
• We minimize waste, conserve water and energy, and promote recycling
• We properly manage and dispose of production waste in accordance with regulations
• We continuously seek ways to reduce our environmental impact

10. Supplier and Partner Standards

DFV expects suppliers, contractors, and business partners to uphold similar ethical standards:

• Compliance with applicable laws and regulations
• Commitment to product quality and safety
• Fair labor practices and respect for workers' rights
• Environmental responsibility
• Ethical business conduct free from corruption

We reserve the right to terminate relationships with partners who fail to meet these standards.

11. Financial Integrity and Record-Keeping

Accurate financial records are essential for legal compliance and business integrity:

• All financial transactions must be accurately recorded and documented
• Company funds must be used only for authorized business purposes
• Expense reports must be truthful and supported by proper documentation
• Tax obligations must be met in accordance with Zambian law
• Financial fraud, embezzlement, or misappropriation will result in immediate termination and legal action

12. Conflict of Interest

Employees must avoid situations where personal interests conflict with DFV's interests:

• Employees must not have financial interests in competing businesses or suppliers without disclosure
• Hiring of family members requires management approval to ensure fairness
• Outside business activities must not interfere with job duties or company interests
• Potential conflicts of interest must be disclosed to management

13. Reporting Violations and Concerns

13.1 Duty to Report

All employees have a responsibility to report suspected violations of this Code, laws, regulations, or company policies. Early reporting helps prevent serious problems and protects the company and its stakeholders.

13.2 How to Report

Concerns can be reported through the following channels:

• Direct supervisor or manager
• Human Resources department
• Senior management
• Confidential hotline: [Phone Number]
• Email: [Ethics Email Address]

13.3 No Retaliation

DFV strictly prohibits retaliation against anyone who reports concerns in good faith. Employees who engage in retaliation will face disciplinary action up to and including termination.

13.4 Investigation and Action

All reported concerns will be investigated promptly, thoroughly, and confidentially. If violations are confirmed, appropriate corrective action will be taken, which may include disciplinary measures, termination, or referral to law enforcement.

14. Consequences of Violations

Violations of this Code of Conduct may result in:

• Verbal or written warnings
• Suspension without pay
• Termination of employment or contract
• Legal action and referral to law enforcement authorities
• Financial penalties or liability for damages caused

The severity of consequences depends on the nature and seriousness of the violation. DFV will take all necessary action to protect the health, safety, and integrity of our operations.

15. Training and Awareness

DFV provides training and resources to ensure all employees understand this Code of Conduct and their responsibilities. New employees receive Code of Conduct training during onboarding, and refresher training is provided periodically. Employees are encouraged to ask questions and seek guidance when uncertain about ethical issues.

16. Continuous Improvement

DFV is committed to continuously improving our ethical standards and business practices. We welcome feedback from employees, customers, and partners on how we can better live up to our values and serve the Zambian community with integrity.

17. Acknowledgment and Commitment

All employees and partners are required to acknowledge that they have read, understood, and agree to comply with this Code of Conduct. By working with DFV, you commit to upholding these standards and contributing to a culture of integrity, respect, and excellence.

18. Contact Information

For questions about this Code of Conduct or to report concerns, please contact:

This Code of Conduct was last updated in February 2026 and applies to all employees, contractors, suppliers, and partners of Doctor Food Vitality Limited.