DHI Customer Entertainment and Hospitality Policy

Customer Entertainment Request Form

This form must be completed for any customer entertainment event with an anticipated value exceeding $250. Approval must be obtained before committing company funds.

Completion of this form does not override the policy requirements below. Employees must exercise good judgment and seek guidance when uncertain.

Purpose

DHI recognizes that developing strong customer relationships is an important part of conducting business. Appropriate customer entertainment and hospitality can create opportunities to strengthen professional relationships, discuss business matters, better understand customer needs, and demonstrate appreciation for existing partnerships.

This policy establishes guidelines to ensure that all customer entertainment activities are conducted professionally, ethically, transparently, and in a manner that protects the reputation of both DHI and our customers.

Guiding Principle

DHI earns business through safety, service quality, technical expertise, innovation, reliability, and integrity.

Customer entertainment is intended to support professional relationships and facilitate business discussions. It must never be used to improperly influence purchasing decisions, secure favorable treatment, obtain confidential information, or create obligations on behalf of a customer.

If there is uncertainty, employees should seek management guidance before proceeding.

Acceptable Customer Entertainment

Reasonable customer entertainment may include:

• Business lunches, dinners, and breakfasts.
• Sporting events.
• Golf outings and tournaments.
• NASCAR, rodeo, racing, and similar events.
• Hunting and fishing trips where permitted by law and customer policy.
• Industry conferences and trade shows.
• Customer appreciation events.
• Facility tours and demonstrations.
• Charitable fundraising events.
• Hospitality events associated with industry conferences.
• Educational or technical training events.

Entertainment should be reasonable in frequency, cost, and scale relative to the business relationship.

Prohibited Activities

The following are prohibited:

• Cash gifts.
• Gift cards or cash equivalents.
• Personal loans.
• Payments made directly to customer employees.
• Entertainment offered in exchange for business commitments.
• Undisclosed benefits provided to customer personnel.
• Activities that violate applicable laws or regulations.
• Excessive or extravagant entertainment that could reasonably create the appearance of improper influence.
• Any conduct that could damage the reputation of DHI or its customers.
• Entertainment extended to any government or municipal employee without prior written approval from the Chief Executive Officer and legal counsel.

Customer Invitations

When inviting customers to attend events or activities, employees must clearly communicate that attendance is entirely voluntary.

Invitations must be extended respectfully and without pressure, expectation, or implication that attendance is connected to future business opportunities.

Employees should recognize that many customers have internal policies governing gifts, hospitality, travel, and entertainment.

If a customer declines due to company policy or personal preference, that decision must be respected without question or further persuasion.

Where practicable, DHI encourages employees to obtain a brief written confirmation from the customer representative, such as a reply email, stating that attendance has been cleared under their employer's policies prior to finalizing arrangements. This confirmation is not required but provides a reasonable record that DHI acted in good faith.

Customer Policy Compliance

DHI expects customers to comply with their own employer’s policies and procedures regarding gifts, entertainment, travel, hospitality, and related activities.

If a customer representative advises a DHI employee that attendance is permitted under their employer’s policies, that representation may generally be accepted in good faith.

Employees should be aware that certain customers, particularly larger producers, maintain and actively enforce strict gift and hospitality policies. Where DHI has prior knowledge that a customer's employer enforces such restrictions, employees should exercise heightened caution and consider whether extending an invitation is appropriate under the circumstances.

DHI employees are not expected to audit, investigate, interpret, or enforce another organization’s internal policies. Nor are employees required to obtain written approvals, supervisor authorizations, or policy documentation from customer representatives unless specifically requested by the customer’s organization.

DHI respects that customer representatives are professionals responsible for understanding and complying with their own employer’s requirements. Employees should act reasonably, exercise good judgment, and avoid situations that appear improper, but they may generally rely on a customer’s statement that participation is permitted.

If a DHI employee becomes aware that an invitation would clearly violate a customer’s known policy, the invitation should not be extended or should be withdrawn.

DHI Attendance Requirement

Customer entertainment funded or sponsored by DHI must include active participation by DHI personnel.

DHI does not provide entertainment, tickets, travel, lodging, or hospitality solely for the benefit of customers without DHI representation.

The purpose of customer entertainment is relationship building and business interaction, not the provision of gifts or personal benefits.

Travel and Lodging

Travel, accommodations, meals, and related expenses may be provided when there is a legitimate business purpose, including:

• Site visits.
• Technical demonstrations.
• Training activities.
• Industry conferences.
• Customer workshops.
• Strategic planning sessions.

All travel-related hospitality must be reasonable and appropriate to the business purpose.

Approval Requirements

Managers are expected to exercise sound judgment when planning entertainment activities.

Customer entertainment, hospitality packages, sponsorships, travel arrangements, or related activities must be approved before company funds are committed.

Events under $5,000 require MN approval. Events of $5,000 or more require MN review and prior written CEO approval.

Any entertainment or hospitality involving a government or municipal employee requires prior written approval from the Chief Executive Officer and legal counsel regardless of the anticipated cost or dollar amount.

Employees should seek approval whenever there is uncertainty regarding cost, appropriateness, customer policy restrictions, or reputational concerns.

Entertainment Request Form Requirement

For any customer entertainment event with an anticipated value exceeding $250, employees are required to complete an internal entertainment request form identifying the following:

• Requestor.
• Requestor email address.
• Proposed event, date, and location.
• Description of the proposed event.
• Amount requested.
• Customer company and customer representatives attending.
• DHI representatives attending.
• Business justification.
• Requestor signature.

Completing the form prior to an event helps employees think through the parameters of the activity, stay aligned with this policy, and demonstrate a legitimate business purpose if questions arise later.

No employee may expend more than $10,000 in total customer entertainment expenditures in any rolling twelve-month period without prior written approval from the Chief Executive Officer.

Professional Conduct Expectations

Employees attending customer entertainment events represent DHI and are expected to conduct themselves accordingly.

All DHI personnel must:

• Behave professionally at all times.
• Treat customers, vendors, and colleagues with respect.
• Exercise sound judgment throughout the event.
• Remain capable of making responsible business decisions.
• Avoid conduct that could embarrass themselves, the customer, or DHI.

Excessive alcohol consumption, intoxication, disorderly behavior, harassment, offensive language, reckless conduct, illegal activity, or any behavior that could damage professional relationships is strictly prohibited.

Employees are expected to remain professional, respectful, and in control of their actions at all times.

Documentation

Employees should maintain sufficient records to demonstrate the business purpose of significant entertainment expenses.

Documentation should generally identify:

• Date of the event.
• Location.
• Attendees.
• Business purpose.
• Approximate cost.

Management may request supporting documentation when necessary.

Questions and Interpretation

This policy cannot anticipate every circumstance. Employees are expected to use good judgment and seek guidance when situations arise that are not specifically addressed herein.

When in doubt, employees should consult their supervisor, Human Resources, the Chief Financial Officer, or the Chief Executive Officer before proceeding.

Closing Statement

DHI values strong customer relationships and recognizes that business is ultimately conducted between people. Professional hospitality and customer entertainment can be an appropriate part of that relationship.

Every employee is expected to ensure that such activities are conducted with integrity, transparency, professionalism, and respect for both DHI and our customers. Our reputation is one of our most valuable assets and must be protected at all times.

The objective of customer entertainment is to build trust, strengthen relationships, and create opportunities for meaningful business discussions. It is never intended to influence business decisions improperly or compromise the ethical standards of any individual or organization.