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

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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
Page 2 and 3: INDEX1. AIM AND GENERAL PRINCIPLES.
Page 4 and 5: 1. AIM AND GENERAL PRINCIPLES1.1 Th
Page 6 and 7: 2. GENERAL PRINCIPLES2.1 Compliance
Page 8 and 9: The Recipients must therefore rule
Page 10 and 11: protocols are drafted, properly int
Page 12 and 13: accordance with any prescribed mand
Page 14 and 15: suspected of, being part of, or as
Page 16 and 17: the relationship with public instit
Page 20: depending on their respective respo

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

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