GOVERNANCE AND COMPLIANCE
CONTENTS:
ANTI-SLAVERY AND HUMAN RIGHTS TRAFFICKING POLICY STATEMENT
Risk Consultancy Global offer a variety of security, risk management and consultancy services in the UK and internationally. We are inherently adaptable to multiple environments in an ever evolving and hostile world. We ensure the highest commitment from our staff thus providing experts in our field. This ensures the safety of our staff and clientele at all times morally and ethically in line with human rights laws and freedoms.
We are committed to the following the below objectives when facilitating operations in the UK and internationally.
· Respect the moral and ethical conduct towards life
· Provide an undivided service to each of our client’s and staff to ensure their ultimate safety
· Abide by all legal and regulatory legislation in each host country we operate within
· Promote and hold human rights in high regard
· Promote, Maintain, and enhance our operations and QMS system at all times
Risk Consultancy Global strive to contain and maintain effective protocols to support its overriding objectives within the organisation. This is overseen by the senior management team and maintained throughout departments to encourage continuous improvement.
Scope Statement
Risk Consultancy Global is a high-quality security and risk management organisation that that delivers and exceptionally high service to political and legal entities in the UK and Somalia.
Mission Statement:
To create a safe environment for all associates in a dynamic world.
Core Values:
Loyalty, Respect, Courage, Diligence, Honesty, and integrity.
Risk Consultancy Global strives to continuously provide bespoke and quality service to all its clients and associates. All operations and services are conducted methodically and meticulously planned thus delivering exceptional service. Our loyalty to our clients and stake holders will continually expand as our repour grows with them, due to the professionally delivered service. Our service is bound in international standards, and we abide by local regulatory and legislative laws offering the highest possible standards a company can. The delivery of our service is developed strategically around our client’s intent and operations of conducting their service with lowering the risk to their organisation as much as possible without infringing on their objectives.
Our management system is guided by the international standards of ISO18788, PSC.1 and ISO 9001, with all policies and protocol reviewed and authorised by executive management team, thus reviewed and accounted for in the lower echelons in our organisation. We monitor and review our system regularly thus updating as and when required in the continuous professional development of Risk Consultancy Global Management system. Regular internal and external audits are conducted to ensure we meet our standards and improve if required.
With the application of this, our policy is to,
· Apply exceptional professionalism to our associates and clients
· Ensure we employ adequately qualified staff and continually monitor CPD to ensure staff meet required standards
· Conduct regular reviews, measuring and recording management inputs, outputs and deliverables
· Ensure all parties involved are commercially aware of environments we operate in with our ethical and moral practice at the core of our business
· Promote, learn and increase output service deliverables at all times
Objectives
Risk Consultancy Globalmeet our policy statement following a model of Specific, Measurable, Achievable, Relevant and Time Bound Objectives (SMART), thus aiming to:
· To meet all our client’s requirements safely
· To ensure service provision is not compromised by underachieving quality
· To provide highest possible service to our clientele and associates
· To provide integral moral and ethical practice based upon the UK world view western paradigm
STATEMENT OF CONFORMANCE
Risk Consultancy Global is a private security company predominantly operating from the UK thus expanding into Somalia, a complex and hostile environment.
At Risk Consultancy Global we stive to the development of our client’s success by not impeding on their operational capability with strategic implementation of our risk appetite and business model.
Stake holders: Risk Consultancy Global have provided services to organisations that include, political parties and government agencies such as High Court Enforcement Officers in the UK; additionally, local and international entities in Somalia.
Our organisation consists of seven key elements: Consultancy, Advisory, Logistics, Procurement, Security Risk Management, Enforcement Support and Capability Expansion.
Risk Consultancy Global always conduct operations with uppermost moral and ethical conduct, as stipulated in our code of conduct, enshrined at the heart of our business. We drive to maintain, sustain, and pledge to human rights seeking to improve the environment we work in, thus giving back in a corporate social responsibility framework.
As in the UK we have developed a strategy with working within complex litigation scenarios that evolve into complex situations for our operatives on the ground. We have become accustomed to strategically developing our organisation around demanding and lawful circumstances. This will expand with the development of our service into Mogadishu in which our management system aims to assist moving forward.
Our organisation demonstrates commitment to the UK human rights act and the UN Guiding principles for business operating in complex environments, as well as the international code of conduct (ICOCA) that we are engaging with to move towards membership for private security company providers. We additionally follow all laws and guidelines set out in the Montreux document.
This statement of conformance assists in the application of our PSC.1 and ISO18788 accreditation process, thus asserting the best possible practice on our approach as an organisation holding personalities to account.
We strive to:
· Not discriminate in any nature or form
· Work fairly with all, clients, contractors, and counter parts ensuring all are vetted accordingly.
· Provide the highest possible standards we can as an organisation
· We will not engage in bribery or corruption at any circumstance
· We will provide sufficient remuneration and compensation to, staff, contractors and suppliers
Risk Consultancy Global have an endeavour to always provide the highest possible service, whilst continuously reviewing process and protocols to keep us up to date with evolving laws, legislations, regulations, and accreditations such as ISO9001, PSC,1 and ISO18788 as the company expands.
Risk Consultancy Global is committed to providing security and risk management consultation services for its clients that takes into account all applicable national & international laws, The Montreux Document, and the Voluntary Principles on Security & Human Rights (VPSHR).
It is further the policy of Risk Consultancy Global to commit to and maintain a Security System designed to meet the requirements of ANSI PSC-1 and ISO 18788 through a framework of Plan-Do-Check-Act (PDCA), to meet its primary objectives.
· Meeting the standards of the VPSHR.
· Comply with national legislation in the areas of operations and in the countries of incorporation of Risk Consultancy Global
This Policy and the documented Security Management System ensures that:
· Risk Consultancy Global continuously set measurable targets and objectives surrounding business operations, security matters and shall invoke programmes to realise these goals.
· Risk Consultancy Global has in place a robust Risk Assessment process, which identifies potential security threats and Health & Safety issues. The Risk Assessment further identifies all treatments in order to mitigate potential Security and Health & Safety risks.
· Risk Consultancy Global will continuously monitor and measure the effectiveness of its Security.
· Risk Consultancy Global Management System in order to drive continuous improvement.
· All applicable legislation will be monitored and documented in order to ensure regulatory compliance in all operations.
This policy will be reviewed on a regular basis for continued relevance and compliance, so that Risk Consultancy Global will ensure the safety and security of our clients and personnel within the implemented Security Operations Management System (SOMS).
Introduction
Under certain circumstances, employees are protected from suffering any detriment or termination of employment if they make disclosures about organisations for whom they work.
Qualifying Disclosures
Certain disclosures are prescribed by law as “qualifying disclosures”. A “qualifying disclosure” means a disclosure of information that the employee genuinely and reasonably believes is in the public interest and shows that Diligence Security Solutions has committed a “relevant failure” by:
These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen. Diligence will take any concerns that you may raise relating to the above matters very seriously.
The Employment Rights Act 1996 provides protection for workers who ‘blow the whistle’ where they reasonably believe that some form of illegality, injustice or breach of health and safety has occurred or is likely to occur. The disclosure has to be “in the public interest”. We encourage you to use the procedure to raise any such concerns.
Safeguards:
Protection - this policy is designed to offer protection to the whistle blower who disclose such concerns provided the disclosure is made:
in good faith in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person. It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure. In an extreme case, malicious or wild allegations could give rise to legal action on the part of the persons complained about.
Confidentiality – Risk Consultancy Globalwill treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.
Anonymous Allegations - this policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of Risk Consultancy Global In exercising this discretion, the factors to be taken into account will include:
· The seriousness of the issues raised
· The credibility of the concern
· The likelihood of confirming the allegation from attributable sources
Untrue Allegations - If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.
Procedures for Making a Disclosure
On receipt of a complaint of malpractice, the member of staff who receives and takes note of the complaint, must pass this information as soon as is reasonably possible, to the appropriate designated investigating officer as follows:
Complaints of malpractice will be investigated by the appropriate Director unless the complaint is against the Director or is in any way related to the actions of the Director. In such cases, the complaint should be passed to the Chief Executive for referral.
In the case of a complaint, which is any way connected with but not against the Director, the Chief Executive will nominate a Senior Manager or external party to act as the alternative investigating officer.
Complaints against the Chief Executive should be passed to the Chairman who will nominate an appropriate internal or external investigating officer.
The complainant has the right to bypass the line management structure and take their complaint direct to the Chairman. The Chairman has the right to refer the complaint back to management if he or she feels that the management without any conflict of interest can more appropriately investigate the complaint.
The complainant may use the following platforms to air their complaints;
a). EMAIL: HR@riskconsultancyglobal.com
b). Or alternatively call the following Corporate HQ Contact number: +44 (0) 151 374 0755
If there is evidence of criminal activity, then the investigating officer should inform the police. Risk Consultancy Global will ensure that any internal investigation does not hinder a formal police investigation.
Introduction
1. A grievance is defined as ‘A wrong or a hardship suffered, which is grounds for complaint’. Grievances may arise from within the Company or from an external source; Risk Consultancy Global policy on the handling of grievance covers both these circumstances but the procedures vary. This document reflects this situation.
2. The aim of this document is to present Risk Consultancy Global policy and procedures for the handling of any grievance from within or outside the Company with a view to facilitating their successful resolution in a timely fashion.
3. This policy and procedures apply to all Company staff (clients/consultants/contractors or employees), sub-contractors and any third party who have cause, or feel that they have cause, for complaint against Risk Consultancy Global
Policy
4. The following comprise Risk Consultancy Global grievance policy:
It is to be transparent and fair by nature and in its application.
Informal action will be considered, where appropriate, to resolve problems. Often an informal meeting between the aggrieved party and their manager/Risk Consultancy Global Representative is the most effective way of resolving minor complaints, and encourages direct communication between management and staff.
In the case of formal action the aggrieved party must provide Risk Consultancy Global management with a written submission, which provides details of the complaint (Nature, time, place and those involved).
Risk Consultancy Global management and aggrieved parties are to raise and deal with issues promptly and not unreasonably delay meetings, decisions or confirmation of such decisions.
Risk Consultancy Global management and aggrieved parties are to act consistently.
Employees have the right to be accompanied at any meeting concerning a grievance. In cases where group grievances are addressed, a maximum of two observers will be allowed to attend the grievance process in addition to the representatives.
Aggrieved parties may appeal against the decision made.
No employee will be victimised for invoking this grievance procedure; where victimisation is suspected, a grievance should be submitted in accordance with the Company’s grievance procedure.
Internal Procedures
5. An employee who has a grievance over any work related issue has the right to raise their concerns with Risk Consultancy Global management.
6. Informal Dealing. Issues of a serious nature should always be dealt with formally; however, when mutually agreed, less serious grievances should be dealt with informally. This should take the form of an informal discussion between the aggrieved party and an appropriate manager. If it becomes clear that the matter cannot be resolved satisfactorily, or that the case is more serious than first assessed, the formal process must be adopted. If both parties agree that the grievance has been resolved satisfactorily no further action need be taken but the manager should make an informal note to record the event, its nature and outcome.
7. Formal Process. The formal process may involve up to 4 procedures:
a. Submission. The aggrieved party must provide an appropriate Risk Consultancy Global manager with a written submission which gives details of the grievance; these should include:
· The nature of the grievance
· Where the incident(s) has occurred
· Who has been involved
· When the incident(s) happened or has been happening.
· Any actions that have been taken so far by any of the parties concerned
b. Hearing. Risk Consultancy Global management will arrange for a meeting to take place within 5 days to discuss the grievance. In preparing for such a meeting managers should consider the following: having an impartial record keeper, making themselves aware of the full facts of the case, how similar grievances may have been resolved in the past, whether an interpreter may be needed. The aggrieved party has the right to be accompanied by a colleague, who may be allowed to address the meeting on the employee’s behalf, sum up the employee’s case, respond to any views expressed at the meeting and confer with the employee. Once the hearing has finished the Risk Consultancy Global manager will take time to consider the case.
c. Decision. In making the decision upon the outcome and Risk Consultancy Global position the manager should consult the Director of Human Resources, Head of Legal and Contracts or other senior managers within the Company – and is encouraged to do so. Regardless the decision should be presented in writing within 24hrs of the hearing. Once it has been made the manager is to inform the aggrieved party in writing of the outcome. The latter has the right to appeal if they are dissatisfied.
d. Appeal. The aggrieved party has grounds for dissatisfaction they appeal but this must be submitted within 5 days explaining their grounds for appealing in writing to Risk Consultancy Global management. An appeal meeting should be arranged within 5 days and should be run by the next more senior manager. The hearing will follow the format described in 7b above and the aggrieved party may be accompanied.
8. Records. Records of the following are to be made and kept for 7 years:
· Nature and details of the grievance.
· What was decided and the actions taken.
· The reasons for these actions.
· Whether an appeal was made and its outcome.
· Any other subsequent developments.
External Process
9. The policy set out in paragraph 4 applies to a non-employee who has a grievance to make against the Company. The procedures shown in Figure 1 and described in paragraphs 6 and 7 are very similar but the complaint is likely to be dealt with at corporate level in the first instance. In summary:
Informal Approach. Risk Consultancy Global prefers to resolve grievance issues on an informal basis whenever possible; but only when this course is mutually agreeable.
Formal Approach. The formal approach requires the aggrieved party to submit the details of their complaint in writing (as per 7a) to the Head of Legal and Contracts at Unit 4 Whitworth Court, Cheshire WA7 1WA. Arrangements will be made for a hearing – the composition of attendees will be agreed on a case-by-case basis. Risk Consultancy Global will inform the aggrieved party of its decision in writing within 24 hours of the hearing being completed. The aggrieved party has the right to appeal within 5 days and this process should be started by a submission in writing explaining the grounds for this appeal.
A further hearing will be convened but managed by a different person with the findings being promulgated within 24 hours of its completion
Contacts
For any grievance related purposes please email HR@riskconsultancyglobal.comor should you wish to stay anonymous you are to engage through our website www.riskconsultancyglobal.com . Or the international code of conduct association for PSC companies https://icoca.ch/en/complaints or the secretariat@icoca.ch
Summery
10. Grievances are to be handled with sensitivity, respect but without undue delay. The procedures are relatively straightforward and must be followed precisely; the importance of keeping records is emphasised. Advice should be sought from senior managers (particularly the Director of Human Resources and the Head of Legal and Contracts) from the outset.
General:
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.
Risk Consultancy Global strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Commitments:
Modern Slavery and Human Trafficking
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
Zero-Tolerance Policy:
We have a zero-tolerance approach to modern slavery in our organisation and our supply chains. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Risk Consultancy Global employees must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain. We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.
Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking. Consistent with our risk-based approach we may require: employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct.
Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code. As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
Risk Consultancy Global is committed to fulfilling its responsibilities on human rights in all business units with Somalia and other countries by applying the United Nations Guiding Principles on Business and Human Rights (2011) across all our business units.
The Guiding Principles affirm four international standards that have achieved broad international agreement as a human rights baseline for all businesses:
• The Universal Declaration of Human Rights (1947)
• The International Covenant on Civil and Political Rights (1966)
• The International Convention on Economic, Social and Cultural Rights (1966)
• The International Labour Organisation Declaration on Fundamental Rights at Work (1998)
This Risk Consultancy Global Human Rights Policy demonstrates our commitment to respect human rights and embodies our understanding of their significance for a growing private security company of our scale and diversity. It also sets our expectations for the conduct of all business units in the Risk Consultancy Global group, our contacted personnel and those with whom we do business.
Detailed guidelines for our staff on how to implement the policy across our businesses can be found in our management guidance document: Risk Consultancy Global Human Rights Guidelines. Together our Human Rights Policy and Guidelines make up the policies and principles by which Risk Consultancy Global will hold its contracted personnel accountable for respecting human rights.
A Strategic Approach to Human Rights:
We take a strategic approach to respecting human rights. This recognises the potentially positive and negative impacts of our operations, the nature of our business as a private security company, the UN framework and the different geographies in which we operate.
Assessing Risk and Realisation:
We recognise that Risk Consultancy Global can play a positive and negative role in respecting human rights in each business units’ area or responsibility. Our businesses can contribute positively to the realisation of human rights by the range of services we offer to protect people and enable them to enjoy their rights. We also recognise that we have a duty to ensure that we are not at risk of violating human rights through the services we provide, the customers we work with, the suppliers that we use and through the fair and appropriate treatment of our own employees and others who are in our care.
We will actively assess the impact of our business on human rights. We will encourage our people to develop businesses that consciously and actively enable people to realise their rights and we will take special care to monitor the risks that aspects of our businesses could directly or indirectly contribute to the violation of human rights, or how we could become complicit in violations by our partners suppliers or customers.
Emphasising Risk Consultancy Global Core Rights:
As a private security company, we recognise that there are some human rights that are especially relevant in the sector in which we operate.
In a rights sensitivity analysis of our business, we have identified some core areas of human rights as particularly significant to the nature of our business and its impact on human rights.
These include: rights to Life, Liberty, Security, Due Process, Privacy, Property, Freedom of Movement, Freedom of Expression, and Asylum; as well as international standards around the Use of Force and International Humanitarian Law.
The International Code of Conduct for Private Security Providers and the Voluntary Principles on Security and Human Rights are already important standards for Risk Consultancy Global which have been embedded into the relevant parts of our businesses.
As an employer, labour rights (including freedom of association and the right to engage in collective bargaining) and the right to an adequate standard of living are also central.
While we work to respect all human rights, our work in care and protection, facilities management and security services mean that we need to be especially focused on human rights that are related to security.
Adopting the 2008 UN Framework - "Protect, Respect & Remedy"
We are committed to operate by the guiding principles of the UN framework for business and human rights with its emphasis on the state's duty to protect human rights, the corporate responsibility to respect human rights, and joint state and corporate responsibility to ensure access to effective remedy for people who have experienced business-related human rights abuse.
Integrating Human Rights Due Diligence:
In line with the UN Guiding Principles, we will make human rights due diligence an essential and integrated part of our growing business processes to assess actual and potential human rights risks. Risk Consultancy Global will act upon the findings of this due diligence to ensure that we prevent human rights violations wherever possible and deliver appropriate and effective remedy if we fail to prevent abuses.
Being Consistent in Different Operational Contexts:
We work in a very diverse range of states and operational contexts. In every context, we will make every effort to apply the same high standards of respect for human rights.
In each context, we will develop a distinct understanding of human rights risks and comply with all applicable laws that protect human rights. When a state's own capacity to protect human rights is weak, or when a state and other parties are actively abusing human rights, we will be careful not to exacerbate the situation and wherever possible and whenever this does not put our staff at immediate risk or bring us into dangerous conflict with local legislation, we will comply with international standards.
Management and Responsibility for Human Rights in Risk Consultancy Global:
Immediate responsibility for ensuring the group respects human rights lies with all our management and contracted personnel. They need to be familiar with the Risk Consultancy Global Human Rights Policy and Guidelines. They need to be able to demonstrate how they are actively preventing or responding to human rights risks and abuses, and how they are deliberately managing operations that respect people's human rights and contribute to their realisation.
Ultimate responsibility for Risk Consultancy Global human rights performance lies with the Directors and In Country Management of Risk Consultancy Global who will actively ensure corporate accountability to this Policy and its related Guidelines.
It is the policy of Risk Consultancy Global to treat all employees and job applicants fairly and equally regardless of their sex, sexual orientation, marital status, race,colour, nationality, ethnic origin, religion, age, disability, or union membership status.
Furthermore, Risk Consultancy Global will ensure that no requirement or condition will be imposed without justification which could disadvantage individuals purely on any of the above grounds.
The policy applies to recruitment and selection, term, and conditions of employment, including pay, promotion, training and transfer, and every other aspect of employment.
Risk Consultancy Global will regularly review its procedures and selection criteria to ensure that individuals are selected, promoted, and otherwise treated per their relevant individual abilities and merits.
Risk Consultancy Global is committed to the implementation of this policy and to a program of action to ensure that the policy is, and continues to be, fully effective. The overall responsibility for the policy lies with the Directors.
However, all staff are required to comply with the policy and to act in accordance with its objectives to remove any barriers to equal opportunity. Any act of discrimination by employees or any failure to comply with the terms of the policy will result in disciplinary action being taken.
This policy will be regular monitored to ensure that the objectives are achieved. It will be reviewed and, if necessary, revised in line of legislative or organizational changes.
Craig Poynton MSc
Managing Director I Risk Consultancy Global
Date: Oct 2023
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Risk Consultancy Global Ltd,
Company Number: 14704577 ICO: ZB646760
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