Code of Conduct — Hero

The Hero Code of Conduct

This Code of Conduct (this 'Hero Code') of Hero Security (NY) LLC (the 'Company')
applies to all employees, subcontractors and others working for the Company in any
capacity, including that of a paid security guard (each a 'Hero'). By agreeing to be a
Hero, each Hero confirms that it has read this Hero Code, unconditionally adopts and
confirms this Hero Code and agrees to be bound by it when working for the Company,
whether on duty or off:

1. A Hero will become familiar with this Hero Code, as well as all New York State
Laws regarding private security and use of physical force.

2. A Hero will not knowingly or willfully break any law, rule, regulation or
ordinance (collectively, 'Applicable Laws') of the United States, any state of the
United States, including New York State, or any other applicable political
subdivision, including local municipalites and counties (collectively,
'Governments').

3. A Hero will not engage in misconduct.

4. A Hero will not act in a manner that serves to bring discredit upon the Company.

5. A Hero will treat all people equally, regardless of race, color, sex, religion, age,
national origin, disability, sexual orientation, occupation or veteran status.

6. A Hero shall not exhibit inaptitude, inadaptability or reluctance to provide high
quality services to the Company's clients ('Clients').

7. A Hero, should it be a witness to a crime or any matter under investigation by
Government authorities, will be expected to be a cooperative witness. The Hero
should be prepared to testify in court without opinion or bias as to what it
observed. Heroes will always cooperate with law enforcement and regulatory
authorities with whom the Hero may interact, on or off duty.

8. A Hero will not make or cause to be made any false, misleading or improper
entries into official Company records in any form, including digital.

9. A Hero will not engage in conduct that constitutes sexual harassment or may make
any other person reasonably uncomfortable under the circumstances.

10. A Hero will not engage in retaliation against anyone, including a Client, for filing
a complaint for poor service, harassment or any other form of misconduct.

11. A Hero will present a clean and professional appearance while on duty and will be
courteous towards and respectful of Clients and others.

12. A Hero must maintain good personal hygiene.

13. A Hero will not permit the copying of its Company identification card or its New
York State security guard identification and licencing card.

14. A Hero must not carry a firearm or any other weapon of any kind while on duty
for the Company unless expressly permitted in writing, in advance, by the
Company in its sole and absolute discretion.

15. If a Hero does get the Company's approval to carry a firearm or other weapon, it
shall not brandish the weapon in any public place unless it is done in the defense
of a Client, the Hero or other persons and in each case as justified by the
Applicable Law.

16. A Hero will strictly follow the Company's policies, including the prompt
submission of complete and accurate incident reports under all circumstances
where an event occurs during a Client escort.

17. A Hero shall not consume nor be under the influence of alcoholic beverages or
marihuana in any of their respective forms while on duty.

18. A Hero shall not possess, consume, sell or otherwise become involved in matters
regarding illegal drugs or controlled substances within the meaning of Applicable
Law, including without limitation the Controlled Substances Act. A Hero shall
apply this same policy to substances that are not yet scheduled as illegal or
controlled but nonetheless have the potential to cause physical or psychological
impairment.

19. A Hero with a valid prescription for any substance which may impair its ability to
perform services for a Client, the Hero shall promptly notify the Company in
order that the Company can assess the Hero's fitness for duty.

20. A Hero will not associate with groups or persons that advocate the overthrow of
the United States government or that of any of its political subdivisions.

21. A Hero will not associate with any groups or persons that advocate any type of
violence against any Government, individual or other person.

22. A Hero will not frequent any establishment where an offense of any Applicable
Law exists.

23. A Hero will not disclose any Company confidential information or other Company
operational, administrative functions policy and procedures, unless ordered by a
court of competent authority. A Hero may release information to assist
regulatory and law enforcement agencies in fulfilling their lawful missions, where
a delay in release of such information would create substantial risk to life or
property.

24. A Hero will not speak disrespectfully to anyone while on duty.

25. A Hero will not publicly make, express or publish any derogatory statement about
the Company.

26. A Hero will not offer for sale or publication any account of actions taken or
events that occur while the Hero is on duty.

27. A Hero will not permit its on-duty actions to be used for any commercial
advertising or other purpose without the prior, express written consent of the
Company, which may be given or withheld in the Company's sole and absolute
discretion.

28. A Hero shall not engage in any on duty political campaigning for any committee,
candidate or party.

29. A Hero shall not use its relationship with the Company to promote any services or
businesses with whom the Hero has a direct or familial relationship.

30. A Hero shall not engage in gambling while on duty.

31. A Hero shall not tender a gift to anyone who would be regarded to serve in a
supervisory capacity of the Company.

32. A Hero shall not provide services to any individual believed to be committing a
crime and will immediately report such activity to a supervisor and, if
appropriate, law enforcement.

The Hero Code of Conduct This Code of Conduct (this 'Hero Code') of Hero Security (NY) LLC (the 'Company') applies to all employees, subcontractors and others working for the Company in any capacity, including that of a paid security guard (each a 'Hero'). By agreeing to be a Hero, each Hero confirms that it has read this Hero Code, unconditionally adopts and confirms this Hero Code and agrees to be bound by it when working for the Company, whether on duty or off: 1. A Hero will become familiar with this Hero Code, as well as all New York State Laws regarding private security and use of physical force. 2. A Hero will not knowingly or willfully break any law, rule, regulation or ordinance (collectively, 'Applicable Laws') of the United States, any state of the United States, including New York State, or any other applicable political subdivision, including local municipalites and counties (collectively, 'Governments'). 3. A Hero will not engage in misconduct. 4. A Hero will not act in a manner that serves to bring discredit upon the Company. 5. A Hero will treat all people equally, regardless of race, color, sex, religion, age, national origin, disability, sexual orientation, occupation or veteran status. 6. A Hero shall not exhibit inaptitude, inadaptability or reluctance to provide high quality services to the Company's clients ('Clients'). 7. A Hero, should it be a witness to a crime or any matter under investigation by Government authorities, will be expected to be a cooperative witness. The Hero should be prepared to testify in court without opinion or bias as to what it observed. Heroes will always cooperate with law enforcement and regulatory authorities with whom the Hero may interact, on or off duty. 8. A Hero will not make or cause to be made any false, misleading or improper entries into official Company records in any form, including digital. 9. A Hero will not engage in conduct that constitutes sexual harassment or may make any other person reasonably uncomfortable under the circumstances. 10. A Hero will not engage in retaliation against anyone, including a Client, for filing a complaint for poor service, harassment or any other form of misconduct. 11. A Hero will present a clean and professional appearance while on duty and will be courteous towards and respectful of Clients and others. 12. A Hero must maintain good personal hygiene. 13. A Hero will not permit the copying of its Company identification card or its New York State security guard identification and licencing card. 14. A Hero must not carry a firearm or any other weapon of any kind while on duty for the Company unless expressly permitted in writing, in advance, by the Company in its sole and absolute discretion. 15. If a Hero does get the Company's approval to carry a firearm or other weapon, it shall not brandish the weapon in any public place unless it is done in the defense of a Client, the Hero or other persons and in each case as justified by the Applicable Law. 16. A Hero will strictly follow the Company's policies, including the prompt submission of complete and accurate incident reports under all circumstances where an event occurs during a Client escort. 17. A Hero shall not consume nor be under the influence of alcoholic beverages or marihuana in any of their respective forms while on duty. 18. A Hero shall not possess, consume, sell or otherwise become involved in matters regarding illegal drugs or controlled substances within the meaning of Applicable Law, including without limitation the Controlled Substances Act. A Hero shall apply this same policy to substances that are not yet scheduled as illegal or controlled but nonetheless have the potential to cause physical or psychological impairment. 19. A Hero with a valid prescription for any substance which may impair its ability to perform services for a Client, the Hero shall promptly notify the Company in order that the Company can assess the Hero's fitness for duty. 20. A Hero will not associate with groups or persons that advocate the overthrow of the United States government or that of any of its political subdivisions. 21. A Hero will not associate with any groups or persons that advocate any type of violence against any Government, individual or other person. 22. A Hero will not frequent any establishment where an offense of any Applicable Law exists. 23. A Hero will not disclose any Company confidential information or other Company operational, administrative functions policy and procedures, unless ordered by a court of competent authority. A Hero may release information to assist regulatory and law enforcement agencies in fulfilling their lawful missions, where a delay in release of such information would create substantial risk to life or property. 24. A Hero will not speak disrespectfully to anyone while on duty. 25. A Hero will not publicly make, express or publish any derogatory statement about the Company. 26. A Hero will not offer for sale or publication any account of actions taken or events that occur while the Hero is on duty. 27. A Hero will not permit its on-duty actions to be used for any commercial advertising or other purpose without the prior, express written consent of the Company, which may be given or withheld in the Company's sole and absolute discretion. 28. A Hero shall not engage in any on duty political campaigning for any committee, candidate or party. 29. A Hero shall not use its relationship with the Company to promote any services or businesses with whom the Hero has a direct or familial relationship. 30. A Hero shall not engage in gambling while on duty. 31. A Hero shall not tender a gift to anyone who would be regarded to serve in a supervisory capacity of the Company. 32. A Hero shall not provide services to any individual believed to be committing a crime and will immediately report such activity to a supervisor and, if appropriate, law enforcement.