Code of Conduct

I

Object, purpose and scope

STAM Strategic & Partners Group work is defensive in nature. We operate at the highest end of the ethical spectrum for private security companies. Our security activities are carried out with professionalism, ethical, lawfulness, accountability and transparency.

STAM Strategic & Partners Group ltd recognizes that an increased demand for security and protection of property and persons must be combined with strict respect for the rule of law and the legal protection of citizens in the field of operation. Within this framework the sector can contribute to the development of a safer society in the countries in which it/we operate(s). However, national regulations are sometimes inadequate or non-existent and do not guarantee the professionalism that the sector needs.

Adherence to this Code of Conduct and Ethics constitutes an assurance of the minimum necessary degree of professionalism and quality for clients, employees, companies, organizations, governing authorities and individuals with whom STAM Strategic & Partners Group comes into contact in its activities.

II

Principles

1 Overarching Principles

a.

STAM Strategic & Partners Group will seek to ensure that it does not engage in activities that exacerbate public insecurity or violate human rights.

b.

Each contract will be assessed on a case by case basis to ensure that these principles can be complied with. Contracts will not go ahead without sufficient information to make this judgment.

2 Compliance with applicable laws and regulations

STAM Strategic & Partners Group is committed to contributing to the creation, promotion, respect and improvement of legislation and regulations applicable to the private security sector and its activities. STAM Strategic & Partners Group adheres to all applicable laws and regulations to the letter and in the spirit in which they were written and takes seriously any alleged breach. STAM Strategic & Partners Group personnel involved in or witness to an incident about which there is a complaint are required to provide a full and frank report in accordance with STAM Strategic & Partners Group Security’s established procedures. STAM Strategic & Partners Group will then investigate the matter to the extent that the environment permits. STAM Strategic & Partners Group will cooperate with any relevant and lawful investigation undertaken by the governing authorities in the field of operation.

a. UK and International Laws and Regulations

STAM Strategic & Partners Group is a limited company registered in the UK. It adheres to all applicable UK laws and regulations (Private Security Industry Act 2001) as well as those

International laws that govern the operations of private security forces as determine by international bodies such as the United Nations, North Atlantic Treaty Organization (NATO), etc.

b. Laws and Regulations in the Area of Operation

STAM Strategic & Partners Group seeks registration with the legal governing authority of the country of operation.

Where we operate in countries where national regulations are nonexistent or underdeveloped or where there is weak rule of law, STAM Strategic & Partners Group undertakes to promote the development of appropriate regulations in such environments. STAM Strategic & Partners Group operates with due and full respect for the regulations and laws of the governing authority.

STAM Strategic & Partners Group will seek to engage in constructive communication and cooperation with the security forces of the governing authority in the field of operation, and with any other official security forces working in the field of operation. STAM Strategic & Partners Group assures the confidentiality of any information received as a result of such relations.

c. International Law

STAM Strategic & Partners Group operates in accordance with applicable international law including international human rights law and international humanitarian law.

STAM Strategic & Partners Group maintains a constructive relationship with appropriate International Humanitarian Organizations, and supports the development of a more systematic approach for adherence to international humanitarian law by companies operating in conflict situations.

3 Rules of Engagement and the use of force

STAM Strategic & Partners Group operates in accordance with the applicable rules of engagement in force and as determined by the governing authority in the area of operation.

Although STAM Strategic & Partners Group’s activities are defensive in nature, personnel often work in violent environments which necessitate the carrying of firearms.

STAM Strategic & Partners Group will only permit the carrying of firearms by its personnel where permitted by the relevant authority in the field of operation.

STAM Strategic & Partners Group personnel are experienced, trained, certified and credentialed in the use of firearms to the highest standards established by the NATO countries’ military and law enforcement agencies. Refresher training and certification will be conducted on a routine basis as required by contractual commitments with the client.

While STAM Strategic & Partners Group recognizes that the use of firearms is considered an extreme measure, where the use of force is required by the exigencies of the situation, it will only be employed as a last resort, when absolutely necessary, in defense of life or property and in accordance with the principle of proportionality. Escalation of force principles will be applied when appropriate, feasible and necessary.

Where STAM Strategic & Partners Group personnel resort to the use of firearms, and regardless of whether this results in injury or death, they will make a full report on the incident in accordance with established reporting and review procedures.

Where injury or death results from the use of force or firearms, STAM Strategic & Partners Group will undertake an internal investigation in accordance with established procedures. STAM Strategic & Partners Group will cooperate with any lawful investigation undertaken by the governing authorities in the area of operation.

Relations with other organizations in the field of operation

STAM Strategic & Partners Group is committed to promoting constructive engagement and cooperating with other organizations operating in the same field of operation.

In particular, it undertakes not to hinder humanitarian efforts and is willing to offer assistance wherever possible.

STAM Strategic & Partners Group maintains a constructive dialogue with appropriate International Humanitarian Organizations on humanitarian issues and strives to support those Humanitarian Organizations to the greatest extent possible.

Relations with the Local Population in the Field of Operation

STAM Strategic & Partners Group personnel will respect the culture, religion and ethnic customs, human dignity and human rights of the communities and countries they work in. They will to the best of their ability and wherever possible, rigorously oppose violation of these rights.

Values, behavior and standards

STAM Strategic & Partners Group recognizes that the quality and value of our services are strongly influenced by the quality and skills of our personnel. Accordingly we are committed to applying a rigorous selection, recruitment and training program.

a. Medical Recruitment

Employees are selected on the basis of objective criteria that allow for a thorough evaluation of candidates’ professional qualities to be made. STAM Strategic & Partners Group recognizes the importance of taking into consideration the candidates’ moral values. During the recruitment, assessment and evaluation phases ensures that recruits have all the basic psychological, intellectual, physical STAM Strategic & Partners Group and moral character aptitudes that make him/her a qualitative and professional private security operative. Their continued fitness to perform their responsibilities is subject to periodic review.

b. Honesty and Integrity

STAM Strategic & Partners Group is committed to ensuring that its employees, officers, directors and board members have a high level of honesty and integrity. Accordingly, and while respecting data protection and privacy legislation, employees are vetted to ensure they do not have associations or interests which may make them unsuitable for employment or which may injure the professional reputation of colleagues or clients. STAM Strategic & Partners Group requires its recruits and personnel to declare previous criminal and disciplinary offences; private business interests and second employments;

outside interests and political associations. Any conflicts of interest must be resolved prior to employment. Current employees, officers,

directors and board members must comply with this policy and not engage in activity that would constitute a conflict of interest.

c. Training

STAM Strategic & Partners Group places tremendous emphasis on vocational training and the maintenance of standards. Newly recruited employees are first assessed and then receive training to provide them with the necessary skills for their work. Recruits must pass this training before they can go on to engage in professional activity on behalf of STAM Strategic & Partners Group.

All employees of STAM Strategic & Partners Group are given ongoing training to ensure the maintenance of high standards and updating of skills. Training programs and operational procedures are reviewed in the light of particular incidents.

All training contains instruction in international humanitarian and human rights law. STAM Strategic & Partners Group maintains a constructive dialogue with appropriate International Humanitarian Organizations to ensure that its activities are compliant with international humanitarian law.

 

Working conditions

Good working conditions are crucial in the development of STAM Strategic & Partners Group and the potential of its employees. Maintenance of appropriate remuneration levels reduces the risks of unfair competition and ensures a high level of efficiency and quality.

a.

Accordingly STAM Strategic & Partners Group is committed to ensure the best working conditions that the field of operation will permit.

b.

In accordance with this Principle, the level of salaries and income ensures that quality work is appropriately remunerated.

c.

There are occupational hazards associated with the nature of the work engaged by STAM Strategic & Partners Group. Applicable medical support is provided to ensure the maximum possible attention in the event of serious incidents and subsequent injuries to personnel.

d.

In line with these procedures STAM Strategic & Partners Group follows best practice by ensuring suitable insurance is always in place to cover issues, assets and business risk.

8 Equal opportunities and non-discrimination

STAM Strategic & Partners Group assumes its responsibility for promoting equal opportunities and combating discrimination.

a.

It seeks to ensure the full integration of each employee in his or her working environment, regardless of his or her ethnic or social origin, color, gender, religion, nationality, sexual orientation or other distinguishing characteristics.

b.

It seeks to ensure that client companies ensure the respect for these values in the working conditions for the personnel made available to them.

9 Relations with clients

By the nature of STAM Strategic & Partners Group’s activities its personnel may obtain information which may relate to the private lives or be potentially harmful to the interests or reputation of others. Great care will be exercised in safeguarding and using such information, which shall be kept confidential unless the performance of the duty or the needs of justice strictly require otherwise.

STAM Strategic & Partners Group will ensure its employees:

a.

are diligent, competent and efficient in discharging their professional responsibilities and commitments;

b.

will not participate in activities which may involve a conflict of interest without appropriate disclosure and approval.

10 Relations with other Private Security Companies

STAM Strategic & Partners Group undertakes to act in an ethical manner and consistent with the rules of fair competition and morality.

11 Transparency

As far as possible, and subject to its obligation to maintain client confidentiality wherever required, STAM Strategic & Partners Group will ensure that its internal organizational procedures are transparent and applied without discrimination to all parties concerned.

III

Monitoring compliance with this code

STAM Strategic & Partners Group’s Ethics Committee will monitor compliance with this Code.

Where a complaint is received it will be investigated in accordance with established independent procedures. Disciplinary action will be taken if appropriate.

Acknowledging the wider interest, STAM personnel who know or who have reasonable grounds to believe that another employee or colleague has failed to conform to this Code shall inform the Ethical Standards Committee.

Will keep this Code and the ethical principles and issues associated with it under constant review.