1.1 . The Company
In the general context of the activities related to its corporate governance system and the consequent adjustment of its internal organization to the international standard SA8000 as well as the extension of the system of administrative liability of entities in several new offenses (see § 2.1. ), SA Fire Protection Srl is committed to implement a model of organization and management model pursuant to Legislative Decree no. 8 June 2001 . 231 , as amended and supplemented through the adoption of this Code of Ethics (the ” Code”).

SA Fire Protection Ltd, sensitive to the need to ensure fairness and transparency in the conduct of business and corporate activities , to protect its image , the expectations of the members and the work of its employees, deems to comply with its policies proceeding with the application of this Code of Ethics.

This Code sets forth the commitments and ethical responsibilities in the conduct of business and corporate activities undertaken by members and collaborators of the company SA Fire Protection Srl (hereinafter “SA” ), whether they are employees , collaborators or administrators.

1.2 . The mission and activities
SA is responsible for DESIGN, CONSTRUCTION, INSTALLATION AND MAINTENANCE plant and equipment and fire safety in buildings , industries or moving vehicles.

The range of services is carried out in compliance with the existing authorizations, and by virtue of the possession of certificates of permission required by law.

SA ‘s mission is to pursue excellence in the conduct of its business, in order to obtain products with high quality standards to enhance skills and innovation initiatives that represent value for shareholders and full achievement of the objectives in full compliance with the laws and regulations as a fundamental principle in areas where SA operates.

This Code , also an essential element of the control system of preventive type of offenses pursuant to Legislative Decree 231/2001 aims to recommend, promote or prohibit certain behaviors unethical providing for sanctions proportionate to the seriousness of the offenses committed.

1.3 . Relationship with Shareholders and Stakeholders
The multiplicity of national and international partners makes the management of relationships with its stakeholders paramount, including all public or private, Italians or foreigners – individuals, groups or institutions – whose contribution is required for the realization of the mission and objectives of SA or otherwise have an interest in its pursuit . Stakeholders are therefore those who make investments related to the activities of SA in the first place the members, as well as , employees , customers , suppliers and business partners.

1.4 . Ethical Principles
SA , in order to compete effectively and fairly in the market , maintain the relationship of trust with customers, increase the value for shareholders and to develop the skills and professional development of its human resources , has founded its own choices and standards of behavior on the principles of this Code compliance, transparency , proper management and quality production.

1.5. The value of reciprocity
This Code is based on the ideal of co-operation to the mutual benefit of all parties involved , while respecting the role of each. SA requires that each stakeholder acts in accordance with the principles and rules based on a similar idea of ethical conduct.

1.6 Validity and application of the code
Under the system of internal control, the Code is a requirement and reference to both the preventive model of organization, management and control of both the system of sanctions that will be adopted by SA in accordance with the requirements of Art. 6 and 7 of Legislative Decree n . 231 of 2001 and on the basis of the code of conduct drawn up by Confindustria.

The Code applies to SA , and is required by all associates and to follow the leading providers of conduct in line with the general principles of the same .

As a result, every employee of the company SA shall undertake to respect the laws and regulations in all countries in which SA operates , as well as consultants, suppliers, customers and stakeholders in general.

2.1 . Compliance with laws and regulations
SA operates in full compliance with applicable laws and regulations , in accordance with the principles of the Code and its own internal control procedures. The legal and moral integrity is a constant duty of all those who work and collaborate for SA and characterizes the behaviour of the whole organization.

The directors and employees of SA , as well as those who work at different levels with the same , are therefore required , in ‘ scope of their respective competences , to know and observe the laws and regulations , including those governing the competition.

2.2 . Models and rules of behaviour
All work activities by those involved in SA must be performed with professional , moral rigor and proper management, in order to protect the company’s image . The behaviour and relationships of those who work at different levels in the interest of SA , both inside and outside of the Company, shall be based on transparency , fairness and mutual respect. In this context, the directors and executives of SA must represent an example with their work for the human resources of SA , complying,with the performance of its functions , the principles underlying the Code of Ethics, procedures and company rules , taking care of their distribution among employees.

With particular reference to executives , moreover, SA requires that they work actively in order to propose and implement projects , investments and industrial, commercial and managerial usefullness to preserve and enhance the economic, technological and professionalism of the company , in accordance with the normal principles of ethics.

2.3 . Circulation and compliance with the Code of Ethics
SA promotes the knowledge and observance of the Code of Ethics, the internal procedures and their updates among all officers, employees, collaborators , business partners and financial advisors, clients and suppliers, requiring the respect and providing, in case of non-compliance, appropriate disciplinary or contractual action. The aforementioned subjects are therefore required to know the contents of the Code of Ethics , asking and receiving from the appropriate company departments responsible for clarification regarding the interpretation of the contents and to observe and contribute to their implementation, identifying any deficiencies and violations (or even attempted violation) of which they have knowledge. SA also promotes and encourages the cooperation of employees in enforcing, learning and implementing the Code of Ethics and, within their respective competences and functions, internal protocols.

3.1. The determining conditions
Human resources are an essential element for the existence of the company and a critical success factor to compete in the market. Honesty, loyalty, ability, professionalism, integrity, technical expertise , mutual respect of employees and the dedication of the staff are therefore the conditions for achieving the objectives of the Company and represent the characteristics required by SA its officers, employees and collaborators.

3.2 Selection of Personnel
In order to contribute to the development of the corporate objectives, and to ensure that these objectives are pursued by all and achieved effectively and efficiently in accordance with the ethical principles and values to which SA is inspired by the company’s policy it shall select each employee or consultant, working in various capacities, according to the values and characteristics set out above. As part of the selection – conducted in compliance with equal opportunities and without any discrimination of the private lives and opinions of the candidates – SA operates so that the resources acquired correspond to the profiles actually required by the company , avoiding favoritism and concessions of any kind.

3.3 . Development of skills
In the evolution of employment SA strives to create and maintain the conditions necessary to ensure that the skills and knowledge of each employee , follow a policy based on the recognition of merit and equal opportunities, and provide specific programs for professional training and acquisition of more skills. For this reason , the employee is required to cultivate and improve the acquisition of new skills, abilities and knowledge, while executives and managers must take great care to enhance and improve the professionalism of its employees by creating the conditions to develop their skills and realize their potential.

3.5. computer security
With regard to applications, each employee and contractor is required to:

To comply scrupulously with the provisions of the corporate security policies, in order not to compromise the functionality and security of information systems;
Not to send threatening or insulting e-mail messages and inappropriate comments that could offend the person and / or damage the corporate image;
Not to surf websites which are indecent and / or offensive;
To comply with all applicable provisions of the Code of Conduct for the use of goods and services of corporate information.

4.1. Corporate and Individual Interests
The relationship between SA and its employees is a trusting one , under which the primary duty of the employee is to use the assets of the company and their working capacity to the interests of the Company, in accordance with the principles laid down in this Code.

In this perspective, the administrator , managers, employees and collaborators of SA should avoid any situation and refrain from any activity that may cause a personal interest to those of the company or that could interfere with and hamper the ability to take , in an impartial and objective decisions in the interest of the company.

The occurrence of conflicts of interest, as well as being in conflict with the law and with the principles laid down in the Code of Ethics, is detrimental to the image and integrity. Directors , employees and must therefore rule out any possibility of overlapping or crossing , exploiting their functional position in the company, the economic activities connected to a logic of personal and / or family and their roles and positions within the Company.

SA also requires that anyone who becomes aware of a conflict of interest must give timely notice to the Supervisory Board, to be appointed at the end of the preparation of the Organizational Model Special Section.

5.1. Compliance with procedures
The administrator and managers , with particular reference to the executives , employees and all those who have any dealings with SA , each within their respective powers and duties, are required to strictly comply with the procedures laid down organizational business.

5.2 . transparency of accounts
Truthfulness, accuracy, completeness and clarity of information and transparency in the accounting records are necessary conditions that allow proper activity to ensure the shareholders and third parties the opportunity to have a clear picture of the economic situation and financial position of the company.

It is therefore necessary that the documentation of economic movements , report to support accounting records, are complete, clear, truthful, accurate and valid, and are filed for each appropriate verification. The accounting records must reflect in a complete, clear, truthful, accurate and valid way what is described in the aforementioned documents.

In the case of economic and financial elements based on valuations, these records must be made in accordance with the criteria of reasonableness and prudence of proper estimate and conjecture according to best practice standards ( including international), explaining clearly in the documentation the criteria that have led to the determination of the value of the asset.

Anyone who becomes aware of any omissions, falsifications, and irregularities in the accounting records of the Company, or of any breach of the principles established by the Code and the specific procedures you should immediately report to the Supervisory Board.

6.1. Custody and management of resources and assets
SA shall endeavor to ensure the use of resources and assets available to be carried out in accordance with local regulations and in line with the values of the Code to ensure, enhance and reinforce the company’s heritage, to protect the company itself, its shareholders, creditors and the market.

6.2 . Unlawful transactions involving shares or capital
To protect the integrity of corporate assets it is specifically forbidden, except in cases where expressly permitted by law, to return in any form or to release from the obligation to the shareholders; to distribute profits not earned or by law to reserves , or reserves are not distributable by law; buy shares in the company or parent company; to reduce the share capital, mergers or demergers in violation of the rules safeguarding: creditors; fictitiously form or increase the share capital; meet in the event of liquidation, the claims of the shareholder to the detriment of creditors.

In order to prevent the above mentioned SA, within the corporate organization, is committed to the dissemination and knowledge of the rules of law, the Code of Ethics and procedures attached.

7.1. Powers and characteristics
The task of overseeing the functioning and observance of the Code is entrusted to the heads of function.

The Supervisory Board to be appointed, will have to operate with impartiality, continuity and autonomy and for that purpose shall have the right to inspect documents and consult data and suggest any amendments to the Code and internal procedures, on the basis of reports of alleged violations of code provided by the employees and / or associates.

The operating procedures of the Supervisory Board are set out in the Model of Organization and Management adopted by SA.

In addition, the Supervisory Board will have to provide its own regulations.

8.1. Relations with authorities and public institutions and other bodies representing the collective interests
A) Relations with Authorities and Public Administration
The reports concerning the Company’s business with public officials or public service providers and other entities acting on behalf of the public administration, central and peripheral, with the judiciary, with the public supervisory authorities and other independent authorities, as well as partners with private dealers of a public service should be entertained and managed in full and strict compliance with laws and regulations and the principles set out in the Code.

Caution and care must be placed in its dealings with the aforementioned individuals, especially in tasks related to : procurement , contracts, permits, licenses , concessions, requests and / or management and use of funds , however denominated, from public (national or Community ) , management of contracts , relationships with supervisors or other independent authorities, social security institutions , bodies in charge of tax collection, bodies of bankruptcy proceedings, civil, criminal or administrative, etc.

The offering of money or gifts to directors, officers or employees of the Public Administration or their relatives,is not allowed in any case except in the case of gifts or items of modest value.

It is forbidden to offer or accept any item, service, or favor in order to obtain a more favorable treatment in connection with any report spoke with the Public Administration . This prohibition applies even if the SA uses a third party in relations with the Public Administration.

In the course of any relationship with the public administration the following actions are not to be taken ( directly or indirectly):

Proposal of employment and / or business to government employees;
Offering gifts;
Solicitating or obtain confidential information outside of the cases provided by law.
8.2. Relationships with customers and suppliers
A) The Business conduct of a fair and transparent relationship with customers and suppliers
The selection of suppliers and purchases of assets, goods and services must be in accordance with the principles of this Code and internal procedures . Such selection shall be made solely on the basis of objective parameters such as quality, convenience, price , capacity, efficiency. The acceptance by the supplier / customer to the ethical requirements of this Code will be a prerequisite for the maintenance of the relationship.

B) Gifts, donations and benefits
Obtaining benefits (both direct and indirect), gifts, acts of kindness and hospitality, unless they are of a nature and value that do not compromise the company’s image and can not be interpreted as aimed at obtaining favorable treatment that is not determined by market rules are prohibited in business relationships with customers and suppliers.

The employee who receives gifts or favors from customers or suppliers that exceed ordinary courtesy , shall promptly report to his superior who shall immediately inform the relevant bodies and / or the competent department for appropriate action.

9.1. Responsibility towards the community
SA is aware of the influence , even indirectly, that their activities may have on the policies, social and economic development and general welfare of the community, as well as the importance of social communities in which it operates. For this reason, SA intends to conduct its investment activities in compliance with local and national communities , and support initiatives of cultural and social value in order to obtain an improvement of its reputation and social acceptance.

9.2 Environmental protection
The environment is a primary asset that SA is committed to safeguarding ; to this effect it contributes to the dissemination and awareness about sustainable development and manages its business by seeking a balance between economic initiatives and environmental needs, in consideration of the rights of future generations.

SA collaborates with customers and suppliers to improve the environmental and landscape impact of its activities, and to prevent the risks to people and the environment in accordance with local regulations and taking into account the development of scientific research and the most experienced in the field.

To this end, SA verifies that the customers / suppliers operate in compliance with environmental standards before interacting with the company, by a formal acceptance of contract clauses to that purpose.

The violation of the principles of the Code and the procedures set out in the internal protocols undermines the trust relationship between SA and the administrator, employees, consultants, collaborators , customers , suppliers, business partners and financial services.

Such violations shall be sanctioned in a timely manner, through appropriate and proportionate disciplinary measures ( adopted in line with company procedures ), regardless of the criminal relevance of such behaviour and the initiation of criminal proceedings in cases which constitute a criminal offense.