Grievance Policy
The Grievance Policy is an important pillar in the quality management system of United Guards (the “Company”). The policy aims to ensure that employees or external stakeholders, or interested parties with a grievance or claim relating to the company’s actions or lack of actions, or any failure with regards to Company’s policies and codes, including the ICoCA Code, have access to a simple and effective procedure, which can help resolve grievances as quickly and as fairly as possible.
Grievance is a concern, problem, allegation, claim or complaint that an employee or external stakeholder, third / interested party raises with the company. It may be related to any aspect of the relationship between the two, whether employment related, work practice, terms and conditions, health and safety, Human rights or other law / policy or code violations, working relationships or general treatment.
The Company aspires to implement and keep a culture of openness and positive work environment where an individual associated with the company can feel that his/her interests are a priority for the Company and any grievance raised will be dealt with promptly, impartially, confidentially and effectively. Therefore, it is Company’s policy to treat every grievance raised in a serious and swift manner, and to keep the employee or external stakeholder/interested party informed of the status of the grievance and the outcome of the investigation.
Additionally, the Company shall ensure that their personnel who report wrongdoings in good faith are provided protection against any retaliation for making such reports, such as shielding them from unwarranted or otherwise inappropriate disciplinary measures, and that matters raised are examined and acted upon without undue delay.
All details and access for Company grievance mechanism are clearly publish in Company website: www.unitedguards.org. Anyone with a complaint, claim or grievance is highly encouraged to report it directly and in detail to Company Management: reporting@mano-security.com and / or to the Competent Authorities.
The Company will keep records about all allegations, findings or disciplinary measures. Except where prohibited or protected by applicable law, such records will be made available to Competent Authorities upon request. Furthermore, appropriate corrective / preventive actions, including recommendations, shall be taken and followed up to prevent recurrence.
For the sake of law-abiding culture and overall transparency, the Company shall always cooperate with any official investigation, and will not participate in or tolerate from any of its personnel / partners / contractors, the impeding of witnesses, testimony or investigations.
The Company can and will take appropriate disciplinary actions as required, which could include termination of employment in case of a finding of such violations or unlawful behaviour.
This policy is under the responsibility of the compliance manager and should be reviewed annually.
Procedure:
The grievance procedure provides a structured approach to enable employees or external stakeholders and interested parties to raise their concerns with the company’s management. It provides individuals with a course of action should they have a complaint which they are unable to resolve through regular communication. The aim is to ensure prompt, consistent and fair treatment for all persons in order to promote effective working relationships. It is the responsibility of the compliance manager to seek to resolve grievances at the earliest opportunity
All parties involved in this procedure must ensure that they maintain the confidentiality of the process as appropriate within and outside the company. Disclosure of information by any of the parties involved might also occur where this is required under law or where there is a circumstance involving duty of care, which requires disclosure, e.g. where a manager has concerns for the wellbeing of the employee or others.
Employee or external stakeholder/interested party report a grievance in person or in writing through the Team Leader or any of the company’s managers or directors. Whichever way was chosen to raise the grievance; it will be acknowledged in writing (Annex A) within 72 hours.
The compliance manager will then appoint a senior member of the company’s management team who has not been involved in the matter to investigate the issues raised in the complaint.
The investigator will decide how to investigate the complaint, along with likely timescales, to ensure that the complaint is fully, fairly and speedily investigated. The investigator will also endeavour to resolve the issues as quickly as possible and will communicate progress and outcome to the employee or external stakeholder/ interested party and to others impacted by the complaint.
If so requested by the employee or external stakeholder/interested, the identity of the employee or external stakeholder/interested party will not be revealed to people outside the investigation and management teams except where we are legally obliged to do so.
If an investigation found any unlawful or even substandard behaviour by an employee of the company or anyone working on its behalf, the findings shall lead to immediate proper disciplinary measures, which could include termination of employment.
The company shall ensure that anyone who had reported any wrongdoings in good faith is provided with protection against any retaliation for making such report, such as shielding from unwarranted or otherwise inappropriate disciplinary measures, and that matters raised are examined and acted upon without undue delay.
All grievances should be settled as swiftly as possible and no longer than a period 3 months.
The company shall also keep formal records of the complaint and outcome.
Notes:
It is important that the employee or external stakeholder/interested party feels satisfied with any matter relating to his/her employment or any other form of relationship with the company, and should have effective means by which such a grievance can be aired and, where appropriate, resolved.
Nothing in this procedure is intended to prevent informally raising any matter, therefore grievances can also be raised in person. Also, informal discussion can frequently solve problems without the need for a written record. However, if you wish to raise a formal grievance you should normally do so in writing from the outset.
You have the right to be accompanied at any stage of the procedure by a fellow employee or external stakeholder/interested party – not acting in a legal capacity – who may act as a witness or speak on your behalf to explain the situation more clearly.
If you wish to appeal you must inform the Management within five working days for the day of receipt of company’s outcome to your grievance report or the disciplinary hearing. You will then be invited for a meeting (can also be performed online) to which you must take all reasonable steps to attend to. The company will be represented by at least two senior managers to examine your appeal. Following the appeal meeting the company, carry out another investigation (if deemed necessary), determine whether a different outcome is appropriate and provide you with the final outcome in writing within 10 working days from the day of the appeal.
CODE OF BUSINESS ETHICS AND CONDUCT
1.1. UNITED GUARDS SERVICES LIMITED (hereinafter the “Company”) is committed to, and operates in accordance with, the principles of honesty and integrity in the delivery of its services to its clients to provide the appropriate level of protection for life and assets, commensurate with the potential threats that may be encountered, while maintaining compliance with international, national statutory and regulatory requirements, laws and codes, and the industry’s best practices, therefore, the Company has adopted this Code of Business Ethics and Conduct (hereinafter the “Code”).
1.2. The Company requires the relevant party to uphold the highest of standards in all its’ operations and in particular to:
(i) Comply with the laws of each country it operates in;
(ii) Comply with all international laws related to the protection of Human Rights;
(iii) Not accept bribes in any form whether directly or indirectly. This includes payment or receipts of “facilitation payments” which are small payments of gifts made as common practice in some countries to obtain approvals, permits etc;
(iv) Not make political donations anywhere in the world;
(v) Not engage in commercial espionage or covert surveillance of its competitors;
(vi) Record in its published accounts all material assets and liabilities and not maintain secret accounts.
1.3. The Company’s Management monitors compliance of the Code and reports any significant breaches of its provisions to the Chief Executive Officer (CEO) of the Company. All third-party providers offering services to or on behalf of the Company, have the right to make confidential reports direct to the CEO of the Company at reporting@mano-security.com for assessment. The Company shall handle any report discreetly and with high confidentiality.
1.4. Anti-Bribery and Anti-Corruption: The Company takes zero-tolerance approach towards bribery and corruption and is committed to conducting all its business affairs in an honest, professional and fair manner, by establishing effective systems to counter any such acts and requires the Relevant Party to act in the same manner.
1.5. Conflict of Interest: The relevant party is expected to make decisions and take actions that are in the best interests of the Company as a whole, and which are not based on or unduly influenced by personal relationships or benefits. The relevant party must avoid any relationship which could give rise to a conflict of interest and where a conflict of interest comes to the Relevant Party’s attention, he must notify the Company of it immediately for further actions.
1.6. Failure to adhere to this Code could result to a removal of a party from the status of approved supplier/contractor/associate etc.
1.7. The Company reserves the right at its sole discretion, to amend the whole or any part of these Terms and Conditions at any time. If an amendment is material, the Company will make reasonable efforts to provide the relevant party with 30 day’s notice prior to the new Code taking effect.
Human Rights Policy
United Guards Services Ltd (the “Company”) is committed to the recognition, respect and promotion of human rights wherever we conduct our operations and is dedicated to maintaining a working environment where human rights are understood and respected.
The Company adheres to international law on the protection of human rights, as well as the United Nations Guiding Principles on Business and Human Rights and International Code of Conduct Association (ICoCA) Code, even if national or Flag State law does not specify them.
The Company will exercise due diligence to ensure compliance with the Law and the principles contained in the ICoCA Code and we will respect the human rights of all persons we come into contact with, including, the rights to freedom of expression, association, and peaceful assembly and against arbitrary or unlawful interference with privacy or deprivation of property.
The Company will engage with affected stakeholders and their representatives in the development of its human rights approach, identifying and addressing potential impacts our operations have on people involved, including vulnerable groups, remediating any proven adverse impacts on individuals and maintaining grievance mechanisms to record and address human rights allegations and incidents, while protecting the confidentiality of anyone who reports potential violations.
The Company shall not preclude access to judicial or other non-judicial grievance mechanisms and shall always cooperate with all human rights-related investigations.
All Company personnel, partners and contractors shall treat everyone respectfully, protect human dignity and maintain and uphold human rights of all persons, prohibiting harassment and discrimination in all aspects of Company’s activities.
Security guards may use force only when strictly necessary as the last resort and only to the extent required for their self-defence and this of the people they protect during the performance of their duty, always in accordance with United Guards SOP, RUF and Code of Conduct and Ethics.
No security guard or any Company personnel may inflict, instigate or tolerate any act of torture or other cruel, inhuman degrading treatment or punishment.
Security guards should apply as much as possible non-violent means before resorting to the use of force and firearms and should follow the standards and procedures set out for the rules and regulations for the use of force and firearms.
In cases where force is used, such incidents should be properly reported to the appropriate authorities and to the company, as soon as it is safe to do so. United Guards also aspires to conform with the legal duty to rescue any persons, including suspected pirates / assailants, who no longer pose a threat and may be at risk of drowning or worsening of injuries. Medical aid should be provided to injured persons, including to the offenders.
The Company provides effective training for all personnel in international humanitarian law and human rights law / standards and declines any persons determined to have been responsible for human rights violations. Any employee found to have committed such violations after fair hearing will face the consequences which will depend on how the individual has contravened this Policy and the Company’s Codes and in what circumstances and could range from a warning to immediate dismissal.
The adherence to this Policy and the on-going process of human rights due diligence it outlines will be monitored as part of the wider assessment of our policies and codes and shall be conducted on an annual basis.
Health, Safety and Environmental Policy
Health & Safety Policy
At United Guards Services Ltd. (United Guards) we are committed to ensuring the health, safety, and well-being of all individuals associated with our operations and services. We recognize that a safe and healthy work environment is essential for the success of our business, services and the welfare of our employees, contractors, and all parties involved.
Therefore, we are committed and dedicated to maintaining the highest standards of health and safety in all aspects of our operations. The health and safety of our personnel are paramount, and we will spare no effort to ensure their well-being
We will comply with all applicable health and safety laws, regulations, and standards in the jurisdictions where we operate. We will strive to exceed legal requirements wherever possible.
Management, employees at all levels and private contractors share responsibility for health and safety. We will always provide the necessary resources, training, and support to enable everyone to fulfil their health and safety obligations effectively.
We conduct detailed risk assessments to identify hazards in the workplace and in our operations and implement appropriate controls to minimize risks to health and safety.
We arrange and provide the required comprehensive health and safety training and education to all employees and private contractors, to ensure they understand the hazards associated with their work and make sure they work safely.
We are committed to continuously improving our health and safety performance through regular reviews, audits, and feedback mechanisms. We analyse and learn from incidents and near misses in order to prevent future occurrences.
Through our dedication and commitment to health and safety, we aim to maintain a safe and healthy work environment where everyone can thrive. We always strive to achieve our goal of zero accidents, injuries, and occupational illnesses.
Environmental Policy
At United Guards Services Ltd. (United Guards), we are committed to environmental sustainability and responsible corporate citizenship. We recognize our responsibility to minimize our environmental impact, promote social well-being, and uphold high standards of corporate governance. Our Environmental policy outlines our commitment to integrating sustainability and ethical considerations into all aspects of our business operations.
Environmental Commitment:
We are committed to minimizing our environmental footprint by conserving natural resources, reducing paper, waste, and preventing pollution.
We are committed to continuously improving our environmental performance through innovation, efficiency, and the adoption of sustainable practices.
We adhere to all relevant environmental laws, regulations, and industry standards, and we work proactively to exceed compliance requirements wherever possible.
We regularly review our progress toward environmental sustainability, seeking input from stakeholders and leveraging best practices within our industry.
Summarizing, we are committed to conducting our business in a manner that respects the environment, supports social well-being, and upholds the principles of good governance. By integrating environmental considerations into our decision-making processes and business practices, we aim to create and maintain value for our shareholders, employees, contractors, customers, and communities while contributing to a more sustainable and equitable world.
This policy is under the responsibility of the compliance manager and shall be reviewed and adjusted annually.
United Guards employees and contractors shall always:
Take actions to prevent any injuries, to us and others by immediately adjusting to all identified risks.
Ensure that the vessel and all its souls on board are secure from any piracy/terrorist activities and threats or any other action that may jeopardize human life.
Take actions to prevent any damage to property, ours and any third party associated with our operation.
Encourage all personnel to be environmentally conscious and acknowledge their responsibilities to undertake every possible action to prevent pollution, as required by National and International Rules and Regulations and legislation in force as outlined by the International Convention for the Prevention of Pollution from Ships MARPOL 73/78. In addition, to take actions reduce our environmental footprint by publicly and formally stating our obligation to the environment, reducing waste, recycle whenever possible and avoiding printing unnecessary documents.
Comply with Health, Safety and environmental regulations of the client, home state and the various local ports, and confirm that all our local agents and suppliers do so as well.
Take part in all safety drills when conducted on board.
Ensure that proper and continuous training is been contacted through all aspects of the operation as well to eliminate as much as possible any human errors in case of an emergency.
Ensure continuous improvement of the skills of shipboard and shore-side personnel in preparing to handle safety, security and environmental emergencies
Assign personnel (including our customer’s officers and crew members) to shipboard safety, security and pollution prevention activities that is competent, highly motivated and committed to excellence and to provide them with the proper material resources.
Closely monitor all employees medical condition and offer our employees the best medical care possible for any injury that may occur during their employment by offering suitable insurance policies and putting their welfare ahead of any financial factor.
ENVIRONMENTAL PROTECTION
– The principals indicated in the MARPOL 73/78 are to be conveyed and explained during the SOP training that every employee undergoes. In addition, the importance of recycling and the awareness to avoiding printing unnecessary documents must also be clearly conveyed as part of a company policy.
– The Company implements its policy on board by ensuring that all associated sea personnel follow the procedures for a safe ship operation with regards to the prevention of all kinds of pollution and ensuring that contingency plans to combat pollution are in place.
– The Team Leader on each vessel is responsible to fully implement this policy and to monitor, review and report any concerning existing circumstances and conditions for the preservation of life, the vessel and the environment. The TL may exercise his authority regarding environmental protection aspects.
– The Company will constantly review its EPP and make the necessary amendments to conform with relevant new legislation and new developments. Amendments to this policy will be made available to all Company personnel and procedures will be updated as necessary.
– To control and monitor the implementation, maintenance and improvement of its policy, the company shall maintain procedures to include Shipboard Monitoring and Shore based Monitoring