DEVELOPMENT BANK OF SOUTHERN AFRICA - AMENDMENT TO THE DBSA CODE OF ETHICS

AMENDMENT TO THE DBSA CODE OF ETHICS 

Development Bank of Southern Africa Limited
(Reconstituted and incorporated in terms of section 2 of the Development Bank of Southern Africa Act,
1997) Registration number: 1600157FN
JSE company code: DIDBS
LEI code: 25490071AZ4HOFUNIH94
(the “DBSA” or the “Bank”)


AMENDMENT TO THE DBSA CODE OF ETHICS
Noteholders are hereby advised that DBSA has amended its Code of Ethics as follows:
o   Cosmetic changes, such as re-arranging the flow of document, align to internal branding, wording, etc,
o   Included more elaboration and application of the DBSA Core Values,
o   Aligned with and included the Organisational Culture outcomes,
o   Included an Introduction in express the ethical tone, applicability and weight of the bank’s Code of Ethics,
    line with the current DBSA Policy Development Framework (section 1),
o   Extended stakeholders to express the DBSA’s conduct commitment beyond internal operations (section 3.3),
o   Formalised the requirement for the Code of Ethics to form part of human capital processes and expanded on
    stakeholder impacted by the Banks conduct (4.4),
o   Expounded on the Bank’s values to include practical application and align with the organisational culture
    outcomes (section 5),
o   Incorporated the Bank’s commitment to honour human rights in ethical decision making (6.1.2),
o   Included the insert to address the requirements and expectations of stakeholders and employees to
    responsibly manage and avoid moral hazards in the Bank’s activities (6.1.6 and 6.1.7),
o   In addition to compliance with laws and regulations, included requirement to comply with Bank’s policies
    (section 6.3.3),
o   Alignment to the Employees’ Conflict of Interest Policy (section 6.4.4),
o   Alignment to the gift prohibition of the Gifts, Entertainment and Hospitality policy (section 6.5.5),
o   Expounded on the Bank’s Zero Tolerance to Harassment and Unfair Discrimination incidents that may
    constitute harassment and unfair treatments (sections 6.7.1 and 6.7.2),
o   Included Privacy provisions in alignment with the DBSA Privacy (including personal information processing
    consent) policy (section 6.9.2),
o   Included the principle expectation for Acceptable and Responsible use of Artificial Intelligence, emerging
    technologies and Large Language Modules (section 6.9.4),
o   Elaborated on provisions for employees’ responsibility over the Bank’s tangible and intangible assets (section
    6.10.1 and 6.10.2),
o   Section name changed from “Environmental Management” and to incorporate the Bank’s commitment to
    responsible sustainable impact on the environmental (Sustainability) and human rights (Social and Ethics) in

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    alignment with the Sustainability Framework and the Human Right Policy Framework (sections 6.11.1 to
    6.11.3).
o   Emphasised on the Bank’s Zero Tolerance for malicious whistleblowing reports in alignment with the DBSA
    Whistleblowing policy and anticipated legislation changes (section 6.16.4).


The amended DBSA Code of Ethics can be accessed on the DBSA’s website at: https://www.dbsa.org/about-
us/governance.


10 November 2026
Debt sponsor
The Standard Bank of South Africa Limited




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Date: 10/11/2026 01:58:00
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