IMPRESSUM

Our Code of Conduct and Pledge to the Vital Interests and Laws of the West HFASA GmbH uses both internal assets, as well as external partners and contractors (such as our external Special Advisors or our attorney partners) within our global strategic network. Thereby our assets pledge to our Code of Conduct (“COC”). It establishes the legal and strategic standards expected while working for or with HFASA GmbH. It fuses Austrian, EU, and U.S. compliance principles with the good-practice benchmarks applied by major Western special service and consulting firms and expressly aligns our activities with the security interests and core values of the Western world. Breach may lead to immediate contract termination and/or legal liability. Hereunder discloses some of the key sections each of our COC Agreements with our external contractors contains, to inform third parties. Each individual COC pledge remains confidential. 1 Purpose & Scope This COC is contractually binding between HFASA GmbH and ______________________ (hereunder “Contractor”). Nothing herein confers on any third party the right to rely on, nor does it grant the Contractor authority to bind HFASA GmbH (see Section 11 below). […] 3 Mandatory Legal Compliance Each Contractor irrevocably pledges to observe and enforce all laws, regulations, and best-practice standards applicable to its mission and affected jurisdictions. This might particularly include: -Anti-Corruption Laws, such as under the U.S. Foreign Corrupt Practices Act or the Austrian Criminal Code -Conflict-of-Interest Laws and Obligations -Human Rights & Rules of Engagement (adherence to the Montreux Document’s good practices for private military and security companies and to any HFASA GmbH Use-of-Force Policy derived from it, as well as other applicable IHL and human-rights instruments) -Data Protection & Confidentiality -Export Controls & Sanctions Regulations By signing this Code of Conduct, the Contractor confirms continuous, demonstrable compliance with the above categories and any other legal obligations, inasmuch as applicable in a particular mission and affected jurisdiction. […] 7 Alignment with Western Alliance Interests The Contractor affirms that all work shall be performed in a manner that does not violate the vital interests of Austria, the EU, the U.S., and NATO. Particular interests and objectives relevant to specific missions are defined in Section 8, below. […] 11 Third-Party Disclaimer Contractors act independent and possess no actual or apparent authority to commit HFASA GmbH. No offer, acceptance, representation, warranty, or endorsement made by a Contractor is binding unless confirmed in writing by an authorized HFASA GmbH officer. Third parties transact at their own risk. 12 Enforcement & Sanctions Breach may lead to immediate termination, indemnification claims, and report to authorities. HFASA GmbH may audit Contractor records to verify compliance. […] […]