The Sfpi Group Code of Conduct: Formalizing Our Ethics

Sfpi Group achieves around 700 million euros in turnover and boasts robust structures
that position it at the heart of the challenges facing today’s and tomorrow’s protection
industry. As an industrial, responsible, European entity with a global reach, the group
brings together its companies within 4 autonomous, innovative, and digitized
operational poles: DOM Security, MAC, MMD, NEU-JKF, whose activities focus on
building security and comfort, air treatment, and energy management.

The growth of Sfpi Group is directly attributed to the dedication of its approximately
4200 employees. Therefore, establishing and disseminating our code of conduct has
emerged as a necessity. As a reference document concerning decision-making, it serves
to guide the actions of our talents, leaders, and members of the group’s management
committees.

‘Clarify common rules and principles, to leave ample room for autonomy and
responsibility.’ Henri Morel, CEO of Sfpi Group.

1. The Ethical Charter – major international texts and foundational values

The first of the two parts of the Code of Conduct consists of the Ethical Charter. It sets
and reminds of the major legal, regulatory, and internal frameworks that govern the
actions of the group, its leaders, employees on a daily basis. Beyond being a good
governance practice for publicly traded companies, it provides common references to
guide our decisions. It is publicly accessible for consultation.

What does it contain?

Major international texts concerning human rights.
The Universal Declaration of Human Rights and the United Nations Global Compact,
which the group commits to uphold without compromise. Also included is the text of
the United Nations Sustainable Development Goals, which we adhere to and resolutely
pursue.

Sfpi Group values.

Consistency, transparency, and loyalty form a common foundation shared at all levels of
the group. Each subsidiary manager is granted autonomy and freedom to assess local
issues and determine how to uphold these values within their teams. These three
cardinal values are detailed in the Values Book, accessible online to all our talents and
handed over personally to our new managers.

The four dimensions of industrial responsibility.
Driven by the transformation plan launched in 2020, this Sfpi Group version of CSR
designates behaviour enabling a company and its employees to perform while ensuring
the protection of people, property, and the environment. It encompasses:

● Commercial responsibility, to deepen understanding and customer
culture at all levels in order to enhance customer satisfaction.

● Environmental responsibility, to produce better while consuming less, and
fostering innovation.

● Financial responsibility, to build common standards, tools, and
frameworks that promote collective intelligence.

● Managerial responsibility, to provide managers with the tools to engage
their teams.

It also presents the group various alert and control mechanisms.

2. The action principles of Sfpi Group leaders and members of management
committees

This second part of the Code of Conduct is specifically aimed at the group’s leadership,
whom all members are invited to sign upon joining.

It contains a reminder of the legal and regulatory frameworks that govern our activities,
specifically as a listed group. Also specified are the internal principles and rules
regarding compliance, legal, human, financial, IT, and CSR issues within the group’s life.

● The chapter dedicated to the legal dimension details the functions and missions
of the service, asset preservation, relationships with third parties, and internal
control.

● The pages devoted to Human Resources address the missions and functions of
management, its general rules, and those specific to executives.

● The Finance and Insurance section presents the general rules and banking
relationships under the financial service, purchasing policy, separation of powers
and tasks, organization and monitoring of financial reporting, as well as
insurance and fraud prevention.

● The chapter on IT and digital policies explains the principle of decentralization of
Sfpi Group, the Headquarters IT Service, the General Data Protection Regulation
(GDPR), the digitization of HR processes, and practices related to procedures,
passwords, and backups.

● Finally, the Corporate Social Responsibility (CSR) section explains sustainability
requirements and related procedures.

Thus, the Code of Conduct recalls the legal and regulatory obligations specific to Sfpi
Group. Beyond formal signature, it is incumbent upon each and every one to ensure the
application and dissemination of these best practices on a daily basis to maintain a
healthy working environment at all levels of the group, a condition for the professional
fulfilment of our talents and the long-term prosperity of our activities.