SELEX Communications S.p.A. THE CODE OF ETHICS

INDEX1. AIM AND GENERAL PRINCIPLES................................................................. 41.1 The company and the Group ........................................................................... 41.2 The Code of Ethics............................................................................................ 41.3 The application within the Group ................................................................... 52. GENERAL PRINCIPLES.................................................................................... 62.1 Compliance with laws and regulations ........................................................... 62.2 Models and rules of conduct ............................................................................ 62.3 Dissemination and observance of the Code of Ethics .................................... 72.4 Company management..................................................................................... 73. CONFLICT OF INTEREST................................................................................ 73.1 Company and personal interests ..................................................................... 73.2 Prevention of the conflict of interests.............................................................. 84. PROTECTION OF THE COMPANY’S ASSETS ............................................ 85. MANAGEMENT OF THE HUMAN RESOURCES ........................................ 85.1 Work environment and privacy protection.................................................... 96. PROCEDURES AND PROTOCOLS ................................................................. 97. PROTECTION OF THE COMPANY’S ASSETS .......................................... 118. INTERCOMPANY RELATIONSHIPS ........................................................... 119. EXTERNAL RELATIONSHIPS ...................................................................... 129.1 Relations with Authorities, Public Institutions ............................................ 129.2 Relationships with political and trade union organizations........................ 129.3 Gifts, benefits and promises of favours......................................................... 139.4 Relationships with customers and suppliers................................................. 139.5 Gifts, acts of giving and benefits.................................................................... 159.6 Protection of the environment ....................................................................... 1510. RELATIONSHIPS WITH THE MEDIA AND MANAGEMENT OF THEINFORMATION................................................................................................. 1510.1 Price sensitive information............................................................................. 1610.2 Confidentiality................................................................................................. 1611. CORPORATE INFORMATION ...................................................................... 1612. SURVEILLANCE BODY .................................................................................. 17Page 2 of 20

12.1 Tasks and characteristics ............................................................................... 1712.2 Submissions to the Surveillance Body........................................................... 1813. BREACHES OF THE CODE OF ETHICS – SANCTIONS SYSTEM......... 1813.1 Reporting breaches ......................................................................................... 1813.2 Sanctions system.............................................................................................. 1813.2.1 General principles .......................................................................................... 1813.2.2 Employees and managers............................................................................... 1913.2.3 Executives...................................................................................................... 1913.2.4 Directors and Members of the Board of Statutory Auditors.......................... 1913.2.5 Co-workers, Consultants, Partners, Other Parties in Transactions and otherexternal parties................................................................................................ 20Page 3 of 20

1. AIM AND GENERAL PRINCIPLES1.1 The company and the GroupThis Code (hereinafter referred to as the “Code of Ethics”) expresses the commitmentsand the ethical responsibilities in the conduct of business and corporate affairs undertakenby anyone carrying out transactions of any nature whatsoever with SELEXCommunications – Società per Azioni (hereinafter referred to as “SELEX” or“Company”).The principles and provisions of this Code of Ethics are binding on all the followingRecipients:- members of the Board of Directors, when setting targets, deciding activities,implementing projects, proposing investments and in any decision or action concerningthe Company's business performance;- members of the Board of Statutory Auditors when controlling and reviewing thecorrectness, in both form and substance, of the Company's activities and the operation ofthe internal control system;- the General Director, the Co-General Director, the Central Directors, the Directors andCorporate Executives, with regard to the Company direction activities, in connection withthe management of both internal and external activities;- employees and all the consultants with any type of contract with the company, includingon an occasional and/or merely temporary basis;- all those having commercial and/or financial relationships of any nature with theCompany;- representatives of directly or indirectly controlled Companies.All the Recipients of this Code of Ethics, in any case, intend their conduct to be honest,fair, reliable, diligent and in good faith, either in internal relations or in external relations.SELEX conducts its’ affairs in strict compliance with the law (the laws of Italy and ofthose countries where it operates), with market regulations and with the principles onwhich fair competition is based.No action in seeking to secure an exclusive advantage for the Company justifies theadoption of any conduct in contrast with these principles and any applicable law.1.2 The Code of EthicsSELEX considers it appropriate and necessary to adopt and issue a Code of Ethics whichexpresses the values to which all the Recipients must conform, by acceptingresponsibilities, structures, roles and rules for whose breach they are liable towards thePage 4 of 20

Company and in law, even where it does not entail any third party liability for theCompany. Knowledge and observance of the Code of Ethics by all those who work withor for SELEX is therefore essential in maintaining transparency and upholding theCompany’s reputation. SELEX shall also bring the Code of Ethics to the attention of allthose with whom it has business dealings, who shall be required to know and abide by therules contained herein.Within the system of internal control, the Code of Ethics represents a management toolfor an ethical conduct in business affairs, an effective element of corporate strategy andorganization and an integral part of both the Organizational, Management and ControlModel and of the system of sanctions, in relation to the alleged breaches of the rulesestablished by SELEX pursuant to Articles 6 and 7 of Legislative Decree no. 231 of 2001and based on the code of conduct drawn up by Confindustria for the purposes of Article6, paragraph 3, of the above Legislative Decree.The responsibility for the implementation of the Code of Ethics, its application andupdating is a duty of the directors and employees of Selex, who shall report any noncomplianceor failure to apply, to the special-purpose body called “the Surveillance Bodypursuant to Legislative Decree 231/01”. Such Body may put forward proposals for theintegration or amendment of its provisions, submitting them to the examination of theBoard of Directors of the Company.In this respect, SELEX has set up the Surveillance Body overseeing the operation of, andcompliance with, the Organizational Management and Control Model adopted for theprevention of the above mentioned crimes and offences, and with the present Code ofEthics.1.3 The application within the GroupThis Code of Ethics expresses therefore the guide values to which the activities of thecompanies controlled by SELEX must aspire.In this respect, SELEX is to submit its own Code of Ethics to its controlled companies sothat those companies (following any possible integration of the same Code of Ethics inrelation to specific circumstances), shall formally adopt the Code of Ethics as a device formanaging and as an effective component of the corporate strategy and organization. As aconsequence of this circulation, the principles of this Code of Ethics shall apply to allSELEX controlled companies and shall be binding in driving the behaviours of allSELEX Recipients.Furthermore, all SELEX controlled, affiliates, participating companies and all SELEXsuppliers are required to keep their conduct in line with the principles of this Code ofEthics.Page 5 of 20

2. GENERAL PRINCIPLES2.1 Compliance with laws and regulationsSELEX operates in full observance of the laws and regulations in force in any countrywhere its activity is carried out, in accordance with the principles of the Code of Ethicsand with the procedures established by specific protocols.Moral integrity is a constant obligation on all the Recipients.The Recipients are therefore required to know and observe the laws and regulations inforce in every country where the Company operates, to the extent of their respective areasof competence. This obligation also includes attention towards and observance of theregulations on competition, both in the national and international market.All Recipients’ transactions with Public Institutions and Authorities must be marked bythe highest degree of fairness, transparency and cooperation, in full observance ofapplicable laws and regulations and of their institutional roles.2.2 Models and rules of conductAll the activities undertaken by the Recipients must be performed with professional care,moral rigour and proper management, with a view to safeguarding the image of theCompany.The conduct and relationships of all the Recipients, both internally and outside theCompany, shall demonstrate transparency, correctness and mutual respect.In such context all directors, the General Director, managers and executives must be thefirst to set a good example to all the human resources of SELEX, by complying, in theperformance of their duties, with the principles that comprise the Code of Ethics and withthe Company's procedures and other documents that regulate the corporate affairs, bycirculating them among the employees and urging these latter to submit inquiries aboutsuch Code of Ethics and procedures, or proposals for updating them where necessary.Particularly, SELEX shall request its directors and general managers to use their bestefforts actively to propose and realize any projects, investments and industrial,commercial and managerial actions that may be useful to preserve and increase theeconomic, technological and professional capacity of the Company.SELEX shall also ensure that any supporting information on company events anddecisions is made available, so as to allow the company, the external auditors and thepersonnel overseeing internal controls, as well as the surveillance authorities, to carry outthe most comprehensive and effective control activities.The use of IT and electronic tools must be in compliance with the principles of fairness,protection of secrecy in correspondence and privacy such as to guarantee the integrityand authenticity of the IT and electronic systems and of the processed data, for theprotection of the Company’s and any third party’s interests.SELEX has adopted suitable measures to ensure that electronic and computer data canonly be accessed in accordance with the applicable regulations and the privacy of anyPage 6 of 20

involved persons, and in such a manner as to guarantee that any information shall be keptconfidential and be processed only by expressly authorized persons, and that anyintrusions shall be impeded.2.3 Dissemination and observance of the Code of EthicsSELEX promotes the knowledge and the obedience of the Code of Ethics, of specificprotocols and their updates among all Recipients, requiring their observance andproviding, in case of non-compliance, for adequate disciplinary actions or contractualsanctions.The Recipients are therefore required to understand the Code of Ethics and if necessary toseek explanations on their interpretation from the appropriate Company official and toobserve the Code of Ethics and to contribute to its implementation, by reporting anyweaknesses or breaches (or even attempted breaches) that they may become aware of.SELEX also promotes and encourages cooperation among the Recipients to developcompliance with, knowledge and implementation of the Code of Ethics and of specificprotocols, within the scope of each Recipient's competence and function.For this purpose, the Company provides its employees with specific training/informationprogrammes, elaborated according to the different needs and responsibility of the varioususers.2.4 Company managementSELEX adopts a company management system in compliance with applicable laws, inline with the best international practices.The above-mentioned system of company management is aimed at maximizing the valuefor the stakeholders, controlling enterprise risks and maintaining transparency towardsthe market.3. CONFLICT OF INTEREST3.1 Company and personal interestsThe relationship between SELEX and its directors and employees at any level is basedupon complete trust. Therefore they must always act in order to achieve the Company’sinterests.From this viewpoint, directors, employees and consultants in any capacity of SELEXmust avoid any situation and abstain from any action that could cause a personal interest,either direct or indirect, to interfere with and hamper his/her capacity to take impartialand objective decisions in the interest of the Company. Any conflict of interest would notonly be in conflict with the applicable law but also the principles set forth in the Code ofEthics, and therefore prove detrimental to the Company's image and integrity.Page 7 of 20

The Recipients must therefore rule out any possibility of any economic activitiesconnected to personal and/or family interests that conflict or in any way impinge on theposition and the duties they hold within the Company, making an instrumental use oftheir functional capacity. Any situation of conflict, even potential, must be promptlycommunicated in detail to the Company – in the person of one’s superior and of theSurveillance Body pursuant to Legislative Decree 231/01 –. The individual in potentialconflict shall refrain from being involved or participating in any act that might prejudicethe Company or any third parties, or damage their image.Similarly, consultants, and commercial partners must also undertake specificcommitments intended to avoid any situation of conflict of interests, refraining fromusing, in any way and under any title whatsoever, the activity carried out on behalf of theCompany with a view to achieving any illicit advantage for themselves or for others.3.2 Prevention of the conflict of interestsIn order to prevent situations, even potential, of conflicts of interest, Selex, uponassignment of positions or commencement of an employer-employee relationship,requires its directors, employees, consultants or anyone who cooperates, at any level,with the company to sign a statement that excludes the possibility of a conflict of interestbetween the individual and the Company. This statement also provides that the individualundertakes to inform, promptly and in detail the Surveillance Body pursuant toLegislative Decree 231/01 of any situation of a real or potential conflict of interest he/sheis involved in. SELEX also requires that anyone who becomes aware of a situation ofconflict of interest must promptly report it, through dedicated channels(organismo.vigilanza@Selex-comms.com and/or codice.etico@Selex-comms.com), to theSurveillance Body pursuant to Legislative Decree 231/01. .4. PROTECTION OF THE COMPANY’S ASSETSThe parties are required to observe the Code of Ethics and protect the Company’s assets,using and safeguarding its goods – movables and real estate – with care and diligence,complying with all applicable law and Company regulations.In particular, they:- must refrain from any behaviour that may cause damages to the Company’s assetsor reduce its functionality and efficiency;- must not use those assets illegally and improperly or for private purposes.5. MANAGEMENT OF THE HUMAN RESOURCESSELEX assigns its human resources a central role in reaching its mission. It adoptsprocedures –for selection, training and management methods – which include fullconsideration for the workers’ safety, health, dignity and responsibility, as well as therejection of any form of discrimination and abuse.Page 8 of 20

In the employment relationships, internal and external, there must be no harassment ofany kind, as for instance, the creation of a hostile work environment towards single orgroups of workers, the unjustified interference with the work of others or the creation ofobstacles and impediments to the career prospects of others.5.1 Work environment and privacy protectionSELEX, in compliance with any applicable laws, and in particular the provisions ofLegislative Decree no. 81 of 2008, and any other provisions in this matter, is committedto safeguard the workers’ health, by applying any necessary and appropriate measures,and the best technical and scientific know-how to guarantee the absolute compliance ofthe work place to the highest standards in matters of health and safety.SELEX is also fostering and establishing a culture of safety, protection of workers’ healthin the workplace, developing risk awareness and promoting responsible behaviour by allits employees and/or co-workers.SELEX fully complies with the Personal Data Protection Code and regulations for theprotection of privacy of all the Recipients and, in general, of anyone having contacts withthe Company at any level and adopts appropriate regulations aimed at specificallyprohibiting the improper communication and/or circulation of personal data, without theprior consent of the person concerned. In particular, the dignity of each worker shall alsobe ensured through the respect of privacy in correspondence and interpersonalrelationships between employees, by prohibiting interferences in meetings or dialoguesand any intrusion or form of control or manipulation of personality which may haveharmful effects.SELEX is committed to safeguard the moral integrity of all its employees and/orconsultants , guaranteeing their right to dignified working conditions and the full exerciseof political and union rights. SELEX protects its workers against acts of psychologicalstress, violence or mob rule and opposes any discriminating attitude or behaviour whichmight cause prejudice to the person, their beliefs and inclinations. Harassment ormolestation of any kind in any work relationship is absolutely forbidden , as is to behavein any way that might compromise the peaceful performance of the functions assignedand otherwise cause prejudice to the dignity of the worker.SELEX has adopted suitable measures and initiatives to guarantee the safeguard,integrity, proper use and operation of systems, programmes or IT and electronic data ofthe Company or of any third parties, protecting likewise the intellectual property rightsrelated to the use of programmes and IT and electronic data and the integrity of theinformation provided to the public through the internet web.6. PROCEDURES AND PROTOCOLSThe Code of Ethics has prompted specific protocols aimed at preventing detrimentalevents and, therefore, potentially negative impacts on the Company's situation. ThesePage 9 of 20

protocols are drafted, properly integrated and amended as and if necessary, on the basisof an analysis of the Company's situation, with a view to highlighting any risks for theCompany and for the existing control system and its actual suitability.Anyone taking part, for any reasons, in the operating process, shall adopt the specificprotocols in the terms and manner specifically provided for and described by thecompetent management of SELEX.The correct implementation of these protocols ensures the identification of Companystaff to be put in charge of the processes of decision-making, authorization andperformance of operations: for this purpose - according to the principle of controlrepresented by the separation of tasks - it is necessary that individual operations arecarried out in their various stages by different parties, whose duties are clearly definedand known within the organization in order to prevent unlimited and/or exaggeratedpowers being assigned to individual parties.Directors, with particular reference to the executives, employees and anyone whointeracts with SELEX at any level, within the limits of their individual duties andfunctions, are required to comply strictly with the procedures laid down in the protocols.In particular, Company procedures shall regulate the execution of each operation andtransaction, whose legitimacy, authorization, consistency, congruity, proper recordingand verification, must with due regard to the utilization of financial resources, beassessable (through the following control elements, including but not limited to:validating account balances, joint signatures, supporting accounting documents,understanding the activities of any sales entities such as consultants, distributorssuppliers, etc.).Each operation shall therefore be supported by adequate, clear and full documentation tobe filed with the company records, in order to allow, at all times, a control on themotives, the characteristics of the operation and the exact identification of who, at thedifferent stages, authorized, carried out, recorded and verified the same.Non-compliance with the procedures, protocols and by the Code of Ethics have to bepromptly reported to the Surveillance Body.Truthful, precise, full and clear primary data are the prerequisites of transparentaccounting and are a fundamental value for Selex, and also ensure that shareholders andthird parties may have a clear image of the economic, equity and financial position of theCompany.For that value to be observed, it is first of all necessary for the documentation of basicfacts, in support of the company records, to be complete, clear, truthful, precise and validand that it is filed for any possible checking.The relative book entry shall reflect in a complete, clear, truthful, precise and validmanner that which has been described in the supporting documentation.In the case of economic and financial elements based on valuations, the relevant bookentry shall be made in accordance with the criteria of reasonableness and prudence,explaining clearly in the underlying documentation the criteria which guided thevaluation of the asset.Page 10 of 20

If anyone becomes aware of any possible omission, falsification, irregularity in the booksand records of the Company, or of any breach of the principles set forth in the Code ofEthics and in the specific protocols, he/she should immediately report this to theSurveillance Body.Non-compliance with the procedures, protocols and the Code of Ethics compromise therelationship of trust between SELEX and those who interact with the Company at anylevel and shall be promptly reported to the Surveillance Body pursuant to LegislativeDecree 231/01.7. PROTECTION OF THE COMPANY’S ASSETSSELEX endeavours to work so that the use of available resources, carried out incompliance with applicable law and any relevant corporate by-laws, and in line with thevalues of the Code of Ethics, is directed towards guaranteeing, increasing andstrengthening the Company’s assets, in defence of the Company itself, its shareholders,creditors and the market.To safeguard the entirety of the Company’s assets, it is specifically forbidden, except asexpressly permitted by law, to give back in any form the payments made by theshareholders or to free them from the obligation to make those payments; to distributeprofits not actually earned or appropriated to statutory reserve, or reserves which cannotbe distributed as prescribed by law, to purchase or subscribe shares or quotas of theCompany or of holding companies; to make reductions of share capital, to bring aboutmergers or de-mergers by violating the provisions which protect creditors; to fictitiouslyform or increase share capital; to pay off, in case of winding-up, shareholders' claims tothe detriment of creditors. In order to prevent the occurrence of the aforesaid cases inpoint, SELEX endeavours to disseminate within its organization knowledge about thelaws in force and the provisions of the Code of Ethics and relevant protocols, providingspecific information and training programmes for directors and employees on corporatecrimes.8. INTERCOMPANY RELATIONSHIPSSELEX provides autonomy to its controlled companies, which are required to adhere tothe values expressed in the Code of Ethics and to faithfully cooperate in the pursuit of theCompany’s objectives in compliance with all applicable laws and regulations.SELEX refrains from any behaviour which, being in its sole interest, may jeopardize theintegrity or image of any Group companies. At the same time, SELEX requires itsaffiliates to refrain from behaviours or decisions which, being for their sole benefit, mayjeopardize the integrity or image of any other Group company.Any person delegated by SELEX to act within the Group will participate with integrity,ensuring fair and open communication between the Group companies and SELEX inPage 11 of 20

accordance with any prescribed mandate whilst utilising inter-company synergies toachieve the common goals.The circulation of information within the Group shall be in accordance with theprinciples of truthfulness, loyalty, correctness, completeness, clarity, transparency andprudence and shall occur with observance of the autonomy of each company and of itsspecific area of activity.9. EXTERNAL RELATIONSHIPS9.1 Relations with Authorities, Public InstitutionsRelations with Authorities and Public Institutions – national, local, international andpertaining to the European Union - shall be conducted in full compliance with allapplicable laws and regulations as well as with the principles set forth in the Code ofEthics and internal protocols, in order not to compromise the integrity and reputation ofthe interested parties.Particular care and attention must be used in any transactions regarding: tenders,agreements, authorizations, licenses, concessions, applications for and/or managementand utilization of funding under any denomination whatsoever originating from a publicauthority (whether domestic, European Union or international), management of orders,relations with surveillance authorities and other independent authorities, social securitybodies, bodies in charge of tax collection, bodies established to deal with bankruptcy,civil, criminal or administrative proceedings, access and use of IT and electronic systemsor data as well as electronic documents.In order to guarantee clear and straightforward relations, contacts with internationalcounterparts shall be exclusively between authorized persons and in such a manner as toguarantee fairness and traceability of the contact.9.2 Relationships with political and trade union organizationsSELEX does not fund any political parties, either in Italy or abroad, their representativesand candidates, nor promotes conferences or parties which have the exclusive purpose ofpolitical propaganda. It refrains from making any direct or indirect pressure onpoliticians.SELEX does not make contributions to organizations, with which there may be a conflictof interest (for instance to trade unions, environmental or protection of consumers’interest associations); however, it is possible to cooperate with such organizations, evenfinancially, for specific projects based on the following criteria:- purposes connected to SELEX strategies on organizational and training matters;- clear and documented resources’ destination;- explicit authorization from the functions responsible for the management of suchrelationships in Selex.Page 12 of 20

Eventual sponsorship activities may only be for events pertaining to social,environmental, sport, entertainment and art spheres, provision of quality assurance, havea national interest involving a significant number of citizens, and for which SELEX cancooperate in the planning, in order to guarantee originality and effectiveness.In any case, when choosing an activity to sponsor, SELEX pays particular attention to theavoidance of any possible conflict of interest, personal or of the Company (for instance,family relationship with interested parties, links with organizations which can, for thetasks they perform, promote in some way the activity of SELEX or of its controlledcompanies).9.3 Gifts, benefits and promises of favoursSELEX prohibits all the Recipients from accepting, offering or promising, whetherdirectly or indirectly, money, gifts, goods, services or undue favours in the course of theirrelations with public officers, persons in charge of a public service or private parties(companies or individuals), in order to influence their decisions, obtain preferentialtreatment, undue services or any other gain (prospective or otherwise).In relations with the Italian or a foreign Public Administration, SELEX shall not undulyinfluence the activity, choices or decisions of the other party, for example by offeringundue advantages consisting of sums of money or other benefits, employment orassignment of consultancy arrangements etc., to the public person or his/her family or tonatural or legal persons connected to him/her.Any requests or offers of money or favours of any kind whatsoever (including forinstance gifts or presents unless of a modest and acceptable value) unduly made to or byanybody acting on behalf of SELEX in any transactions with the Public Administration(whether Italian or of a foreign country) or private persons (either Italian or foreign) mustbe immediately reported to the Surveillance Body and to the competent Companymanagement, so that any consequent measures may be considered or taken.In the event of any requests whatsoever from the Judicial Authorities and, in general, ofany contact with the said Authority, SELEX shall offer its full cooperation and refrainfrom any behaviour that may cause hindrance or prejudice, in compliance with applicablelaws and regulations currently in force and in accordance with the principles of fairness,loyalty and transparency.9.4 Relationships with customers and suppliersSELEX conducts its business in compliance with the principles of loyalty, fairness,transparency, efficiency, obedience of the law and the values expressed in the Code ofEthics and openness in the market and requires a similar behaviour from all those havingcommercial and/or financial relationships of any nature, paying particular attention to thechoice of other parties in transactions, suppliers, business partners, consultants, etc…SELEX shall refrain from any relationship whatsoever, even if indirect or throughintermediaries, with natural or legal persons who are known to be, or are reasonablyPage 13 of 20

suspected of, being part of, or as carrying out of, activities in support –of any criminalorganization of any nature whatsoever, including mafia-like organizations or thoseinvolved in the trafficking of human beings and the exploitation of child labour, as wellas persons or groups acting for the purposes of terrorism, and any conduct that may causeserious damage to a Country or an international organization, carried out in order tointimidate the population or force public authorities or an international organization to actor abstain from acting in any way whatsoever or destabilize or destroy basic political,constitutional, economic and social structures of a Country or an internationalorganization.Particular attention must likewise be given to relationships involving receipt or transfer ofsums of money or other benefits: in order to prevent the risk of undertaking, evenunwillingly or without being aware, operations of any nature having as their objectmoney, assets or other benefits that are the proceeds of crime. SELEX shall abstain fromaccepting for whatever reason any cash payments, bearer shares or payments throughunauthorized intermediaries or through any third parties in such a manner as to make itimpossible to identify the payer, or from any relations with persons having theirheadquarters or operating in Countries where the transparency of corporate business isnot guaranteed and, in general, from performing operations that might preclude thetracing of cash flows.SELEX also , in the context of relationships with external parties, refrains from behavingin any way that might compromise the integrity, reliability and security of the IT andelectronic systems and data.The selection of other parties in transactions, business partners, consultants, distributors,suppliers of goods and providers of services shall be made based on objective, transparentand documented evaluation criteria, in accordance with the principles of this Code ofEthics and the procedures required by the specific internal protocols, in writing and inobservance of the hierarchical structure in the Group. In all cases, the choice shall bemade exclusively according to objective parameters such as quality, cost efficiency,price, professional expertise, competence, efficiency and after prior obtainment ofsuitable guarantees as to the correctness of the consultant or supplier of goods or services.Specifically, SELEX shall not establish any relationship whatsoever with persons knownor reasonably suspected to exploit child labour or to employ irregular personnel, orotherwise operating in breach of the law or of any regulations concerning the protectionof workers' rights. Particular attention must be paid when dealing with parties operatingin Countries where the law does not afford sufficient protection to the workers, withregard to child, women and immigrant labour, ascertaining whether sufficient hygienic,health and safety conditions are in place.Commercial transactions require and obligate particular attention be paid to the receiptand payment of money, assets or other benefits. In any case, it is forbidden to makepayments through cash money.Agents, consultants and/or brokers have to report periodically to the Company regardingthe compliance of duties and responsibilities assigned.Page 14 of 20

The Company is entitled to conduct audit activities in order to verify the compliance withcontractual obligations.9.5 Gifts, acts of giving and benefitsDuring the conduct of all business proceedings with consultants, clients, suppliers, otherparties in transactions, business and/or financial partners, no act giving favour or benefits(both direct and indirect), gifts, acts of courtesy or hospitality of any kind shall be made,unless they are of such a kind and value that do not compromise the image of theCompany, and that may not to be interpreted as seeking preferential treatment. In allcases, any gifts, acts of courtesy or form of hospitality shall be reported to and submittedfor the approval of the persons charged to such effect.Any director, member of the Board of Statutory Auditors or employee who receives giftswhich exceed ordinary business practice and made with the purpose of gainingpreferential treatment in any corporate activities, shall promptly report it to the Board ofDirectors, the Board of Statutory Auditors or, if an employee, his/her superior who shallimmediately inform the specific Company bodies and/or competent corporate functionwhich, after appropriate consideration, shall, through the company functions in charge ofexternal relations, inform the person who offered the gift, etc. of the policy of theCompany on this issue.9.6 Protection of the environmentSELEX regards the environment as a primary asset to be protected and to this end it plansits activities in such a way as to achieve a balance between economic initiatives andessential requirements of environmental protection. To such extent, SELEX constrainsthe environmental impact of its activities, taking into account the development ofscientific research in this field.10. RELATIONSHIPS WITH THE MEDIA AND MANAGEMENT OF THEINFORMATIONAll contact with the press, the media and any similar third party, shall be made only bythose persons who have been expressly delegated to this task, in compliance withFinmeccanica guidelines and the procedures or regulations adopted by the Company. Anyrequest for information coming from the press or from the media and received by Selex’personnel shall be communicated to the corporate office responsible for externalcommunications.The external communications shall be made in accordance with the fundamentalprinciples of truthfulness, correctness, transparency and prudence and shall be aimed atpromoting awareness of the Company’s policies, programmes and projects. Therelationship with the media shall ensure observance of the law, and be in accordance withthe Code of Ethics, the related Protocols and the principles as outlined with reference toPage 15 of 20

the relationship with public institutions and which are aimed at safeguarding the image ofthe Company and the Group.10.1 Price sensitive informationIt is strictly prohibited that any form of investment be made, whether direct or throughintermediaries, using knowledge of or originating from confidential information.Particular importance and attention must be given to the external disclosure ofdocuments, news and information pertaining to events occurring within the direct activityof SELEX and of the Group, not in the public domain and which, if made public, wouldbe likely to affect the price of financial instruments.The dissemination of such information should always be done through the channels andthe appropriate authorities, designated by Finmeccanica’s directives.During management of the information, behaviours that might facilitate insider tradingmust never be adopted.10.2 ConfidentialityDue to the sensitive nature and importance of the sectors of activity in which theCompany is active (defence, strategic communications, scientific research, protectedtechnologies, etc.), all those who operate at any level on behalf of SELEX are required tomaintain the utmost confidentiality of any proprietary information, and shall not discloseor unduly request information about documents, know-how, research projects, companybusiness activities, and in general about any information acquired in the performance oftheir duties.In particular, confidential or secret proprietary information means all information subjectto applicable laws or regulations relating, for instance, to national security, militarysectors, inventions, scientific discoveries, protected technologies or new industrialapplications, as well as information declared secret by contract. Confidential informationis also all information acquired in the performance of working activities or through suchactivities, whose circulation and use could jeopardize or harm the Company and/or createunjust enrichment of the employee.Any breaches of their confidentiality obligations by the Recipients would seriously harmthe relationship of trust with the Company and may lead to the application of disciplinaryor contractual sanctions because of the breach of either the confidentiality obligations orthe Code of Ethics.11. CORPORATE INFORMATIONWithin the limits established by applicable laws, SELEX shall provide exhaustive andprompt information, clarifications, data and documents required by the shareholders,Page 16 of 20

clients, suppliers, surveillance authorities, institutions, bodies, entities and otherstakeholders in connection with the performance of the respective functions.Any relevant corporate information must be promptly communicated both to thecompany’s bodies in charge of controlling the management of the company, and to thesurveillance authorities.Clear and complete corporate information ensures, among other things, the fairness ofrelationships: with the shareholders, who must have easy access to information data, incompliance with all applicable law; with third parties that come into contact with theCompany, who must be able to have a clear view of the economic and financial positionof the Company and its assets; with the surveillance authorities, the external auditors andthe bodies overseeing internal controls, who must perform their control activitieseffectively, in order to protect not only the shareholders but also the entire market; withthe other Group companies and also for preparing the consolidated financial statementsand other corporate reports.Pursuant to the measures and through the departments designated by the internalprotocols, SELEX grants access to information and ensures transparency to all partiesrequiring knowledge of corporate events and on the Company’s expected economic andfinancial development. Communications to shareholders and investors, of relevantcorporate events, expected corporate developments or similar situations shall bedisseminated expediently, simultaneously and fairly, by traditional methods and to thepress and Internet in order to ensure that all benefit from the same level of information.Particular care and fairness must be applied in the disclosure of relevant communicationsconcerning the Company’s well being, including the disclosure of information or newswhich may significantly impact on the business or on the credibility or reliability of theCompany, in its relationships with companies and/or banks. In this respect, specificProtocols shall provide for instruments of verification and control so that the statutorycorporate communications, the information to shareholders or to the public on thesituation of the Company and on the expected economic and financial developments (ofthe Company and/or the Group) are always truthful.12. SURVEILLANCE BODY12.1 Tasks and characteristicsThe Surveillance Body, which is granted sufficient autonomous powers of initiative andcontrol, as relevant for the purposes of Legislative Decree 231/01, is entrusted by theCompany’s Board of Directors with the task of overseeing the operation of, andcompliance with, the Organizational, Management and Control Model pursuant toLegislative Decree 231/01 and subsequent amendments as adopted by Selex, and theCode of Ethics which forms an integral part of it.The Surveillance Body operates with impartiality, authority, continuity, professionalismand autonomy and, for these purposes (i) is granted access to any SELEX’ data orinformation; (ii) is entitled to examine any document or data and to consult with anyperson; (iii) recommend any update of the Code of Ethics and of the specific ProtocolsPage 17 of 20

also on the basis of the submissions coming from employees; (iv) may perform controlactivity also on a periodical basis on the operation and compliance with the Model; (v) isattributed adequate resources so that it can quickly and efficiently operate.The Surveillance Body operates with wide discretional powers and with the full supportof SELEX senior management, and cooperates with the latter on an absolutelyindependent basis.12.2 Submissions to the Surveillance BodyIn order to facilitate the flow of information and submissions towards the SurveillanceBody, two dedicated information channels have been established through which anyonebecoming aware of any suspicious, aberrant or illicit behaviour, may freely, directly andon a confidential basis, report it to the Surveillance Body. Such Body is entrusted withthe control of received information, with a view to assessing the application of anydisciplinary actions or the triggering of the procedures for terminating the relevantcontracts once due investigation activity has been performed thereon. In this context, theSurveillance Body has been tasked with monitoring the efficacy of the contractual clausesand the assessment of the suitability of initiatives being undertaken by the referenceFunctions in the business.13. BREACHES OF THE CODE OF ETHICS – SANCTIONS SYSTEM13.1 Reporting breachesWhen a committed, attempted or requested breach of the rules of the Code of Ethics andthe relevant protocols is reported, the Company shall ensure that no-one, in theworkplace, may be subject to any retaliation, illegal conditioning, hardship anddiscriminating treatment of any kind, for having reported a breach of the Code of Ethicsor of the internal protocol procedures to the Surveillance Body (dedicated e-mail boxes:organismo.vigilanza@Selex-comms.com and codice.etico@Selex-comms.com).As a consequence of the said report, the Company shall promptly arrange the necessarychecks and take adequate disciplinary measures.13.2 Sanctions system13.2.1 General principlesBreaches of the principles set forth in the Code of Ethics and in the procedures providedby internal protocols prejudice the trusting relationship between SELEX and theRecipients.Such breaches shall be incisively, promptly and seriously followed up by the Company,through adequate and proportionate disciplinary measures, regardless of whether thePage 18 of 20

elevant conduct is an indictable crime or whether any criminal proceedings have beeninstituted in the cases of indictable crimes.The consequences of a breach of the principles set forth in the Code of Ethics and of thespecific protocols shall be taken into serious consideration by all the Recipients. For thatpurpose, SELEX shall circulate the Code of Ethics and the specific protocols to all thepersons involved and keep everyone informed of the disciplinary measures provided forin case of breach, and on the methods and procedures for inflicting sanctions.To safeguard its image and its company resources, the Company shall not have anydealings whatsoever with parties who do not intend to operate in strict observance of allapplicable laws and regulations, and/or refuse to act in accordance with the values andprinciples set forth in the Code of Ethics and to adhere to the procedures and regulationsset out in the relevant protocols.13.2.2 Employees and managersAny behaviour of employees which is in breach of any rule of conduct of, or that mayreasonably be deduced from, this Code of Ethics shall be defined as a disciplinaryoffence.Any sanctions applicable to the said employees shall fall within the provisions of thecompany’s disciplinary procedures and rules and respect the procedures outlined inArticle 7 of the workers’ statute of rights (or appropriate equivalent National LabourLaw) and any specific applicable regulations.In relation to the above, the Organizational Model and the Code of Ethics, which is anintegral part of it, refer to categories of sanctionable acts under the existing sanctioningmechanisms. These categories describe the sanctions actually provided for committingsuch acts, depending on how serious they are. In particular, the “Criteria for correlatingworkers’ offences and disciplinary measures” contained in the current NationalCollective Labour Agreement (or appropriate equivalent National Labour Law) forprivate engineering industry workers are detailed in the Organizational Model’sappropriate section 6.2.1 adopted by SELEX. .13.2.3 ExecutivesAny breaches, on the part of executives, of the internal procedures set out in this Code ofEthics shall determine the application, against the violator, of the most suitable measuresin accordance with the provisions of the National Collective Labour Agreement (orappropriate equivalent National Labour Law) for industrial executives, as detailed atsection 6.2.2 of SELEX’ Organizational Model.13.2.4 Directors and Members of the Board of Statutory AuditorsAny breaches of the ethical principles set out in this Code of Ethics on the part ofDirectors or members of the Board of Statutory Auditors of SELEX S.p.A. shall -Page 19 of 20

depending on their respective responsibilities – result in the most appropriate andadequate measures consistent with the seriousness of the breach and in accordance withthe powers granted by the law and/or the Articles of Association (as well as statements inthe minutes of meetings and the calling of or request to call a Shareholders Meetings todiscuss appropriate measures towards the individuals responsible for the breach etc.), inaccordance with section 6.3 of Selex’ Organizational Model.13.2.5 Co-workers, Consultants, Partners, Other Parties in Transactions and otherexternal partiesAny behaviour adopted by co-workers, consultants, partners, other parties in transactionsor external parties which is in contrast with the lines of conduct indicated in this Code ofEthics may determine, by application of the appropriate clauses, the termination of thecontractual relationship. In co-operation with the Surveillance Body, the Legal andCorporate Affairs Department of the Company shall look after the drafting, update of andinsertion in engagement letters or business and partnership agreements, of such specificcontractual clauses that provide, in case of non-compliance of the established ethicprinciples, for the termination of the business obligations.Page 20 of 20