1 | Page Confidential	&	Proprietary 

### VSG Aviation Safety, Safety Ma nagement System

1. Safety	Policy

a. Vision	Services	Group	is	committed	to implementing	and	maintaining	a Safety Management	System (VSG

- SMS) in	accordance	with the	purpose	and	intent	of
the Federal	Aviation	Administra tion	sponsored	Aviation	Safety, Safety Management	System	(AVSSMS).	The	implementation	of	this	SMS	reflects	a commitment	to	safety	not	on ly	because it	is	an	aviation	best	practice	and	the
most	effecti ve	method	of	ensuring	the	endurance	and	safety	of	our	equipment and	personnel ,	but	because	it	is	an	efficient	method	of	optimizing	the	safety	of the	National	Airspace	System.

b. As	part	of	the	VSG

- SMS ,	a	designated	safety	committee,	which	will	be	defined	in this	document, will	regularly review	company	safety	practices	and	identify methods	for	improving	safety	practices	including,	but	not	limited	to,	those recommendations	made	by	the	FAA	and	NTSB.

c. The	key	process	by	which	most	safety	related	incidents could be avoided	or mitigated	is	through	a	comprehensive	risk	management	plan.	This	document outlines	the	safety	risk	management	strategy	employed	by	all	employees	of	the company	and	any	contractors	or	sub

- contractors	in	executing	the	VSG

- SMS.

d. VSG,	its	employees, subsidiaries,	contractors	and	sub

- contractors	shall,	at	all times,	comply	with	all	federal,	state	and	local	statutes	and	regulations	applicable to	company	activities.

e. It	is	the	responsibility	of	all	employees	to	report	violations	of	this	VSG

- SMS	or

a ny	ot her unsafe practices .	Employees	may	report	directly	to	their	supervisor, the	company	safety	representative	or	any	member	of	the	executive management	team	if	they	encounter	a	seemingly	unsafe	situation.	These	reports will	be	treated	completely	in	a	non

- retribution	manner	and	e mployees	are assured	that	the	reporting	of	unsafe	conditions	will	under	no	circumstances	be detrimental	to	their	employment,	career	progression	or	relationship	within	the company.	Whenever	possible,	the	reporting	employee	should	offer	a	suggestion to	bring the	unsafe	situation	into	a	state	of	compliance	or make recommendations	for	better	practices.	Safety	is	everyone’s	responsibility.

f. Acceptable	employee	behavior	is	outlined	in	the	company	policy	document regarding	employee	dress	and	behavior	and	included	i n	the	employee	handbook. VSG	expects	its	employees	to	act	in	a	professional	manner	at	all	times	on	the	job to	include	refraining	from	behavior	that	may	create	an	unsafe	environment	or2 | Page Confidential	&	Proprietary condition.	While	all	risk	cannot	be	removed	from	our	operations,	the

unn ecessary	risk	associated	with	certain	unprofessional	behavior	is	unacceptable
and	will	not	be	tolerated.

g. In	creating	the	VSG

- SMS,	all	safety	objectives	should	reflect	the	following guidance

i. Ensure	the	safety	of	all	human	participants	in	flight	activity	to include operators,	observers and	bystanders.

ii. Ensure	the	protection	of	real	&	personal	property	to	the	greatest	degree possible.

iii. Ensure	the	safety	of	aircraft	and	other	associated	equipment	to	the greatest	degree	reasonable.

iv. The	order	of	precedence	for	thes e	objectives	should	be	preservation	of life,	prevention	of	injury,	protection	of	property	and	then	protection	of VSG	equipment/aircraft.

h. All	managers	shall	ensure	their	subordinates	review	the	safety	objectives	once quarterly	and/or	when	changes	to	safety policies	or	objectives	are	implemented. Executive	management	is	responsible	for	the	support	of	this	VSG

- SMS	and	will provide	managers	with	the	means	to	disseminate	and	review	safety	objectives
with	their	team.

i. The	company	safety	officer	shall	be	appointed by	and	report	to	the	Chief Executive	Officer	for	all	safety	related	duties.	The	safety	officer	is	responsible	for the	execution	and	monitoring	of	the	VSG

- SMS	but	the	executive	management team	is	ultimately	responsible	for	its	success	through	their	commitm ent	and
support. The	safety	officer’s	duties	include:

i. Executing	the	VSG

- SMS

ii. Leading	the	annual	review	of	safety	procedures	and	objectives

iii. Receiving	incident	reports	and	conducting	the	ensuing	investigations

iv. Monitoring	operations	for	VSG

- SMS	compliance

v. Issuing	warnings	and	letters	of	reprimand	which	become	part	of	an employee’s	permanent	record	for	safety	violations

vi. Making	recommendations	for	safety	procedure	improvement3 | Page Confidential	&	Proprietary vii. Reporting	the	overall	condition	of	the	VSG

- SMS	and	company	compliance

j. The	safety	com mittee,	which	includes	at	a	minimum	the	safety	officer,	Chief Operating	Officer	and	Director	of	Training,	shall	review	annually	the	statutory and	regulatory	applications	to	the	VSG

- SMS	to	ensure	its	compliance	with	all federal,	state	and	local	requirements .	The	committee	shall	use	the	resources	at its	disposal	to	include	in

- house	research, company	counsel,	company	flight insurance	representatives	and	any	relevant	government	documents,	notices	or websites	to	ensure	compliance	with	up	to	date regulations.

k. The safety	committee	shall	maintain	and	the	safety	officer	shall	implement, procedures	to	measure	the	effectiveness	of	the	VSG

- SMS.	These	procedures	will include	statistics	around	quarterly	reports	of:

i. Number	of	safety	incidents

ii. Incident	investigation	finding s	(human,	environmental	or	mechanical error)

iii. Number	and	severity	of	safety	violations,	warning	and	reprimands

l. All	incidents	or	accidents	must	be	reported	to	the	safety	officer	following	the incident	reporting	guidelines	found	in	the	employee	handbook.	Form s	for	all ground	&	air	safety	reports	can	be	found	on	the	company	server.	All	incidents shall	be	investigated	by	the	safety	officer.	Depending	on	the	severity	of	the incident,	the	safety	officer	may	choose	involve	the	aircraft	manufacturer, company	mainten ance	or	training	director	for	diagnostic	evaluation	of	the	flight telemetry	and	aircraft/vehicle	condition	to	aid	in	the	investigation.	Results	of	the investigation,	if	they	lead	to	a	new	finding	regarding	best	practices,	may	be incorporated	into	a	technic al	advisory	or	service	advisory	distributed	to,	at	a minimum,	all	company	flight	operations	and	maintenance	personnel,	but	also may	be	distributed	to	the	manufacturer	for	further	dissemination.	The	safety officer,	Chief	Operating	Officer	or	company	counsel may	use	their	discretion	on whether	wider	dissemination	is	necessary.

Safety Risk Management

m. The	Pilot	in	Command	(PIC)	shall	complete	a	Pre

- Flight	Risk	Management Worksheet	prior	to	flight	commencement	at	each	operating	location	for	the	day.4 | Page Confidential	&	Proprietary n. This worksheet	endeavors	to	describe	the	environment	in	which	flight operations	will	take	place,	identify	hazards	present	and	use	this	information	to analyze	the	level	of	risk	for	any	given	flight.

o. The	worksheet	gives	clear	instructions	on	when	supervisors	or	m ore	senior members	of	the	operations	team	must	give	approval	for	flights	based	on	the	risk level.	This	is	meant	to	mitigate	the	risk	of	a	less	experienced	operator	taking unnecessary	risks.

p. Although	a	PIC	is	forbidden	to	fly	if	a	supervisor	or	other	senio r	member	of	the operations	team	directs	them	not	to	fly	because	of	safety	concerns	or	other reasons,	a	PIC	has	the	authority	to	choose	NOT	to	fly

, regardless	of	approval	by supervisors	or	other	senior	members	of	the	operations	team

, if	the	PIC	feels	that

c onditions are	such	that safe	operation	of	the	aircraft is	impossible	and	that flight	would	endanger	the	safety	of	the	crew,	observers,	other	people	or property	or	the	VSG

- owned	equipment

.

q. The	attached Pre

- Flight	Risk	Management	Worksheet uses	figures	based on	the safe	operating	characteristics	of	the	Bramor	fixed

- wing	aircraft	and	the	Octane
multi

- rotor	aircraft.	If	using	a	different	platform,	this	form	should	be	modified according	to	the	operating	handbook	of	that	platform	and	any	applicable supplemental	g uidance	from	VSG.5 | Page Confidential	&	Proprietary Pre

- Flight	Risk	Management	Worksheet

Date: PIC: Location:

C RM	Risks 3 2 1 Crew	Rest	prior	to	duty <6hrs 6

- 8hrs >8hrs

Crewmembers	ill? Yes No

PIC	experience <50hrs 51

- 100hrs >100hrs

Mission	type No	notice Routine Training
CRM	Sub

- Total
Environmental	&	Terrain	Risks 3 2 1 Visibility <1sm 1

- 3sm >3sm

Clouds OVCST SCT CLR
Wind	conditions >7	m/s 4

- 7	m/s <4	m/s

Heat (leave	blank	in	winter/fall) >100F 90

- 99F <90F
Cold (leave	blank	in	summer/spring) <35F 35

- 44F >45F Launch/Land	area <100yd 100

- 150yd >150yd
Obstacles	within	0.5nm (height) >400ft 150

- 399ft <150ft

Population	Density Urban Suburban Rural Topography Mountain Hilly Flat
Environmental	&	Terrain	Sub

Total Risk	Management	Total

If	CRM	sub

- total	is: <8; proceed 8+;	requires	supervisor	approval
If	Environmental	sub

- total	is: <16;	proceed 16+;	requires	supervisor	approval If	Risk	Management	total	is: <24;	proceed 24

- 28;	requires	supervisor >28	requires	Dir,	Flight	Ops

This information	is	accurate	to	the	best	of	my	knowledge.	______________________ PIC	Signature6 | Page Confidential	&	Proprietary 2. Safety	Assurance

a. While	safety	is	everyone’s	responsibility,	the	company	safety	officer	is	the primary	point	of	contact	for	all	safety	related	questions within	the	company.	This officer	is	also	responsible	for	continually	monitoring	the	company’s	activities	and ensuring	compliance	with	safety	policy.	The	company	safety	officer	sits	as	a member	of	the	safety	committee	as	described	in	section	1.b.	and	3.b. o f this
document. The	safety	officer	shall	submit	a	safety	compliance	report	quarterly	to the	safety	committee	and	the	CEO.

b. The	VSG	safety	committee	shall	consist	of	no	less	than	three	(3)	individuals	to include	the	company	safety	officer,	a	Director	or equivalent	from	the	Operations
division

, and	a	member	of	the	senior	executive	team	(C

- level).	The	safety committee	shall	be	responsible	for	reviewing	current	company	safety	policy,	the

VSG

- SMS,	safety	records	and	reports	to	determine if	the	company	is	oper ating under	ideal	safety	practices.	The	committee	will	use	current	practices,	industry standards	and	federal,	state	and	local	statutes/regulations	to	decide	if	changes or	amendments	to	current	practices	need	to	be	implemented.	The	committee
shall	meet	twic e	annually	to	review	the	company	safety	policy	and	may	be	called to	special	session	to	address	immediate	safety	concerns.

c. It	is	the	responsibility	of	all	employees	to	report	violations	of	this	VSG

- SMS	or any	other	situation	that	appears	unsafe.	Employees	m ay	report	directly	to	their supervisor,	the	company	safety	officer	or	any	member	of	the	executive management	team	if	they	encounter	a	seemingly	unsafe	situation.	These	reports will	be	treated	completely	in	a	non

- retribution	manner	and	employees	are
assured that	the	reporting	of	unsafe	conditions	will	under	no	circumstances	be detrimental	to	their	employment,	career	progression	or	relationship	within	the company.	Whenever	possible,	the	reporting	employee	should	offer	a	suggestion to	bring	the	unsafe	situatio n	into	a	state	of	compliance	or	make recommendations	for	better	practices.	Safety	is	everyone’s	responsibility.

d. All	incidents	or	accidents	must	be	reported	immediately	as	outlined	in	the Operator	Handbook.

i. The	first	priority	is	to	assess	injury	to	any	people	and	take	appropriate steps	to	treat	the	injury.	The	next	priority	is	to	assess	damage	to	non

- VSG property.	The	on

- scene	responder	should	then	secure	and	document	the accident	site,	notify	the	company	saf ety	officer	and	the	flight	operations supervisor.7 | Page Confidential	&	Proprietary ii. Accident	investigations	may	be	carried	out	in	the	field,	by	analysis	of flight	telemetry,	interviewing	the	witnesses	or	any	combination	of	the above.	It	is	crucial	for	the	PIC	to	secure	and	evidence	(inclu ding	flight telemetry,	pre

- flight	worksheets	and	any	other	documents)	for	proper investigation	into	the	incident.

iii. The	intent	of	accident	investigations	is	not	to	assess	blame	but	rather	to determine	the	contributing	factors	and	make	changes	to	policies	and procedures,	training	or	operations	to	mitigate	the	risk	of	these	types	of incidents	occurring	in	the	future.

iv. The	safety	officer	shall	be	responsible	for	completing	a	detailed	incident
report for	any	Class	B	or	higher	incident	(refer	to	VSG	Incident
Classi fication	System)	and	shall	decide	if	immediate	action	is	required	to mitigate	future	risks.	If	immediate	attention	is	required,	a	special	meeting of	the	safety	committee	may	be	called.	If	not	required,	the	report	shall	be included	in	the	quarterly	safety	r eport.8 | Page Confidential	&	Proprietary 3. Safety	Promotion

a. VSG ,	its	officers,	management	and	shareholders	all	deem	safety	to	be	a	top priority	for	the	business.	Safety	is	important	to	the	company	and	its	managers not	only	because	of	the	high	value	VSG	places	on	its	personnel’s	safety	and that of	other	people’s	property,	but	also	because	safe	operations	lead	to	lower maintenance	and	repair	costs,	higher	employee	morale	and	more	effective overall	operations ,	as	well	as	the	safe	integration	of	unmanned	aircraft	into	the
U.S.	NAS .	The	commitme nt	to	safety	by	the	senior	executive	management	team is	clear	and	actively	supported	at	all	times	through	clear	and	regular communication	and	training.

b. Company	safety	po li cy	is	communicated quarterly in	a	formal	fashion,	and regularly	in	an	informal	fashio n, by	the	company	safety	officer	as	well	as	during required	annual	safety	training.	The	annual	safety	training	is	a	requirement	for all	employees,	contractors	and	sub

- contractors.	New	employees	receive	training on	the	company’s	safety	policies	and	procedur es	within	30	days	of	hire, regardless	of	position	or	capacity. Amendments to	company	safety	policies	are disseminated	to	all	personnel	immediately	after	publication.

c. The	regular	reports	to	the	senior	executive	management	team	of	safety	statistics
and issues	reaffirms	the	company’s	dedication	to	safe	operations.	The	tracking	of these	statistics	and	their	use	in	shaping	safety	policy	is	essential	to	VSG’s commitment	to	continued	safety	improvement.

d. The	safety	officer	and	other	members	of	the	safety	commi ttee	(as	detailed	in 3.b.)	shall	be	senior	personnel	in	the	company	who	have	demonstrated	the competency	required	to	fulfill	such	an	important	role.	The	safety	officer	shall	be a	senior	UAS	operator	with	a	minimum	of	500	hours total flight	time	and	a	stron g history	of	safe	operations.	This	individual	will	be	required	to	complete	an accident	investigation	training	course	as	well	as	demonstrate	a	thorough understanding	of	VSG

- SMS	and	VSG	safety	policy	and	procedures.

e. The	safety	officer	is	responsible	for	mak ing	budget	recommendations	to	the various	operations	directors	for	safety	related	issues.	The	company	is	committed to	allocating	appropriate	resources	to	safety	programs,	training	and	equipment. This	allocation	of	resources	includes	budgeting	time	off	for “safety	days”	and additional	continuing	training	to	improve	and	reinforce	personnel	safety practices.9 | Page Confidential	&	Proprietary f. The	safe	operation	of	unmanned	systems	is	a	great	concern	to	VSG.	The company	is	committed	to	cooperating	with	the	FAA,	other	governmental	entities and	pr ivate	industry	to	ensure	that	the	safety	best	practices	and	lessons	learned are	shared	and	implemented	whenever	possible	to	foster	a	safer	overall	air environment	and	to	build	and	maintain	the	reputation	of	unmanned	aircraft systems	and	the	aviators	who	op erate	them.

This publication outlines the official VSG

- SMS and is considered the source document for safety policy structure within Vision Services Group. In the event of any conflict between this document and FARs or CFRs, user should follow the FAR/CFR. Any questions or concerns related to this document or its contents should be addressed to the office of the Chief Executive Officer, Vision Services Group, LLC.

– CAO: 06/01/2014