UGS Security Policy – Code of Conduct, Ethics & Human Rights Protection – Health, Safety & Environmental Protection – Grievance Procedures

SECURITY POLICY

 In order to meet its mission, it is the policy of this Company to implement and maintain a security system that is designed to meet the requirements of ISO 28007-1:2015.

This security management policy shall be publicly available on the company’s web site to all stakeholders and interested parties in accordance with our quality management system. furthermore, any new client shall receive the policy with the Due Diligence package upon initial contact.

 Our Mission:

 United Guards Services (United Guards) is driven to make a difference in the stand against piracy by providing superior and trusted support dedicated to eliminating risks from attacks on high value assets at sea.

 In order to achieve that we:

  • Develop and maintain security systems and processes that comply or exceed applicable international, national, statutory and regulatory requirements, laws and codes;
  • Employ only highly trained and competent personnel in all levels of the Company ensuring they are fully aware of the requirements of this policy and our standards.
  • Ensuring that our security guards are highly experienced, competent and characteristically able to adjust and react efficiently and professionally to any changes and threats or potential security breaches;
  • Deploy firearms and equipment that is the most suitable for the task in hand and maintain the highest standards of operational and regulatory state of all equipment.
  • Apply suitable preventative safety and security measures to best eliminate or minimise identified risks and actual incidents;
  • Ensure that this policy is available to all internal and external interested parties in order to establish a two-ways channel of communication for feedbacks and suggestions.
  • Establish, monitor, review and adjust our relevant security objectives continuously;

 

United Guards is committed to the implementation of this policy and to a programme of action to ensure that the policy is, and continues to be, fully effective. To ensure the company maintains its awareness for continuous improvement, the security management system is regularly reviewed and is subject to annual audit.

Scope of Security Management System

 The United Guards Security Management System covers the provision of a private contracted maritime security service. The service includes the provision of armed guard security on board vessels in transit in international waters in the Red Sea, Gulf of Aden, Indian Ocean, and Gulf of Oman on behalf of commercial shipping clients.

Security Management Objectives

United Guards Maritime Security provides a secure working environment by establishing and maintaining security measures to help prevent unlawful acts against ships which endanger the safety and security of persons and property on board Client’s ships and to prevent the ships from being used for terrorist or other undesirable actions.

In order to achieve our mission statement, we have set clear security objectives to guide us throughout our activity:

The Company’s security objectives are to:

  • Constant monitoring and ensuring compliance/implementation of all applicable law and legislations organizations and other relevant sources.
  • Constant monitoring of quality intelligence sources, compiling a thorough and most suitable risk assessment to every task.
  • Constant review of our SOP and daily security procedures in all levels of the company.
  • Develop and maintain constant training programs of company’s employees.
  • Conducting a comprehensive and thorough screening and continuous evaluation process to all personnel.
  • Conducting thorough selection process for our weapons and other security equipment.
  • Ensuring high operational readiness by regular maintenance of our weapons and equipment.
  • Conduct thorough health and safety awareness training and ensure our teams comply with clients’ needs and requirements
  • Publishing our policy online for all to see and encourage a constructive feedback culture with all our stakeholders and interested parties.

Managing Director (MD) maintains overall responsibility for this policy, however its requirements are mandatory and all Company personnel have a responsibility and obligation to it.

BUSINESS CODE OF CONDUCT AND ETHICS – COMPLAINTS AND GRIEVANCE PROCEDURE – WHISTLEBLOWING – LEGAL REQUIREMENTS

United Guards Code of Conduct is a set of professional standards aimed to set clear guidelines of behaviour, appearance, and actions of all United Guards employees.

All employees must conduct themselves in an exemplary and professional manner, reflective of the standards set forth by United Guards.

These standards represent actions, activities, and behaviour expected of United Guards employees in order to best maintain the interests, reputation, and morals of the company, its clients and the world-wide maritime industry.

United Guards employees shall:

  1. Operate in accordance with this code and all its content
  2. Operate in accordance with applicable laws and regulations and in accordance with relevant corporate standards of business conduct.
  3. Operate in a manner that recognizes and supports the rule of law: respects human rights, and protects in the interest of the client.
  4. Operate in accordance with United Guards Code of Ethics and Anti-Bribery and Anti-Corruption Policy
  5. Operate in accordance with United Guards Policy on Human Rights
  6. Provide means for responding to resolving allegations of activity that violates any applicable national or international law or this Code.
  7. Cooperate in good faith with national and international authorities exercising proper jurisdiction in particular with regards to national and international investigations of violations of national and international criminal law, of violations of international humanitarian law, or of human rights abuses.
  8. Comply with the Rules for the Use of Force consistent with applicable law expressed in the United Nations Basic Principles on the Use of Force and Firearms.
  9. Take all reasonable steps to avoid the use of force.
  10. Take all reasonable steps not to use firearms against persons except in self-defence or defence of others against imminent threat of death or serious injury, or to prevent the perpetration of a particularly serious crime involving grave threat to life.
  11. Not engage in any conduct which constitutes neglect of duty, insubordination, carelessness, or any other act which is likely to adversely affect the discipline, good order or reputation of United Guards.
  12. Respond at all times to the lawful orders of a superior officer (team leader) as well as calls for assistance from the Master and vessel’s crew.
  13. Any employee who deliberately, or passively refuses or fails to immediately obey any lawful order or engages in any disrespectful action or language to any superior officer or supervisor, will be guilty of insubordination.
  14. Observe and obey all flag state laws, local ordinances and rules and regulations of United Guards.
  15. Treat superior officers, subordinates, officers and crew, agents and authorities with respect patience and good manners.
  16. Not engage in gossip, public criticisms or ridicule of United Guards.
  17. Not engage in any conduct, whether physical or verbal, which may constitute sexual, racial, religious harassment, or age discrimination.
  18. Not permit their names or photographs to be used to endorse any product or service, which is any way connected with maritime security.
  19. Remain on duty until properly relieved by another Security Guard or competent authority.
  20. Maintain adequate physical and mental condition to allow the proper performance of duties.
  21. Not consume intoxicants while on or off duty.
  22. Inform the company before embarkation if use legally prescribed drugs and non-prescription medications.
  23. Not use of United Guards property without the company’s clear consent.

This Code complements and does not replace the control exercised by Competent Authorities, and does not limit or alter applicable international law or relevant national law. This Code itself creates no legal obligations and legal liabilities on the Signatory, beyond those which already exist under national or international law. Nothing in this Code shall be interpreted as limiting or prejudicing in any way existing or developing rules of international law.

Signatory agree to operate in accordance with the principles contained in this code and to treat all persons humanely and with respect for their dignity and privacy and will report a breach of this code.

Code of Business Ethics and Conduct

Mission Statement

United Guards Services Ltd (United Guards) conducts its business at all times throughout the world with honestly and integrity.  It is part of our mission statement that we have pledged that “we will continue to be an ethical and responsible company.

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.

Values

United Guards Services Ltd operates a culture of honesty, openness, trust and integrity in all its business practices. The company recognises it has responsibility for all the actions of its employees in connection with the activities of the organisation.

United Guards Services Ltd believes that the ethics demonstrated by our employees and indeed any persons providing services on our behalf should give all customers, shareholders, suppliers, colleagues, business partners and regulators confidence that the Company operates in a way that avoids any suggestion of improper of personal motives or actions.

Therefore, all employees and any persons providing services on our behalf are expected to conduct themselves in accordance with this code at all times. This Code is to be read in conjunction with our Bribery and Corruption Policy as part of the company’s approach to ethical and responsible organisation.

The Company believes that all its stakeholders wish to be associated with an ethical organisation upholds high standards in all that it does, in particular:

  • We will comply with the law of each country in which we do business.
  • Will comply with all international laws related to the protection of Human Rights.
  • We will not offer to pay, solicit or 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.
  • We will not make political donations anywhere in the world.
  • We will not engage in commercial espionage or covert surveillance of our competitors.
  • We will record in our published accounts all material assets and liabilities and not maintain secret accounts.

Agents and contracted third parties in countries where United Guards is not directly represented are expected to comply with this Code in all matters in which they are acting on United Guards behalf.

Local Management and all deployed personnel are expected to monitor compliance and report and significant breach to the MD of United Guards Services Ltd.

Grievance Policy

The Grievance Policy is an important pillar in the quality management system of United Guards. The policy aims to ensure that employees or external stakeholders and interested parties with a grievance relating to the company’s actions or lack of actions 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 or complaint that an employee or external stakeholder/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 violations, working relationships or general treatment.

United Guards aspires to implement 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 accordingly. Therefore, it is United Guards 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.

For the sake of law abiding culture and overall transparency, United Guards shall always cooperate with any official investigation, and will not participate in or tolerate from any of its Personnel, the impeding of witnesses, testimony or investigations.

This policy is under the responsibility of the compliance manager and should be reviewed annually.

All employees and third party providers of services on its behalf, have the right to make confidential reports direct to the MD of United Guards Services Ltd at info@unitedguards.org without fear of detrimental action being taken against them.

Additionally, anyone with reason to believe that improper or illegal conduct or act has occurred or is about to occur, coming from UNITED GUARDS SERVICES personnel or procedures, must feel free to report same either by sending us email as above, or regular mail, or fax using the Offices address and Fax no, or following the below link:

http://unitedguards.org/contact

Failure to adhere to this Code may results in disciplinary action or removal from the status of approved supplier/contractor.

This Code will be applied in the same fair and consistent way to all employees and contractors in accordance with all other relevant policy documents.

All information accompanied by any evidence or data deemed necessary should be sent, along with the reporting person’s full contact details and we shall conduct our proper investigation and remedy actions immediately, informing of the results the interested party accordingly.

We declare our commitment to investigate any reports promptly, impartially and thoroughly, with due consideration to full confidentiality.

WHISTLEBLOWING POLICY

The Whistleblowing Policy is an important pillar in the quality management system of United Guards. This policy aims to provide guidance to all Directors, managers, employees and personnel providing services on behalf of the company on a contract basis, if they should need to raise genuine and legitimate concerns that an instance of wrongdoing has occurred or is occurring in the practice or if they have a concern for the mental well being of an individual. This is known as whistleblowing or, more formally, as making a disclosure in the public interest.

United Guards aspires to implement a culture of openness and a work environment where an individual can feel confident about raising a concern without fear of reprisal. We will safeguard an individual who makes a whistleblowing complaint in good faith and with genuine belief of wrongdoing, in accordance with international whistle-blowing standards as set by the United Nations Convention against Corruption (UNCAC), the Council of Europe, the OECD Anti-Bribery Convention, and various civil society organisations (Ashton, 2015).

Therefore, it is United Guards policy to never dismiss, discipline or victimise an employee who ‘blows the whistle’ on criminal behaviour or malpractice, but on the contrary to encourage the reporting of any such suspicions as it will allow a better internal monitoring system and the prevention of unlawful misconduct within the company or its associated parties.

This policy is under the responsibility of the MD and shall be reviewed annually.

Policy Scope and Principles

This policy applies to all managers, employees and personnel providing services on behalf of the company of the company (collectively referred to as ‘staff members’ in this policy), where their actions qualify for protection.

It is not permitted to dismiss, discipline or victimise a staff member who ‘blows the whistle’ on criminal behaviour or malpractice providing the staff member has a reasonably held belief that the information is substantially true and makes the disclosure in good faith.

A qualifying disclosure is a disclosure of information where the staff member reasonably believes one of the following is happening, has taken place or is likely to happen in the future:

  • A criminal offence (such as money laundering, fraud or financial irregularities)
  • Breach of a legal obligation
  • A miscarriage of justice
  • Endangering the health and safety of any individual (in particular any concerns regarding actions that are out of character for an individual)
  • Damage to the environment
  • Deliberate concealment of any of the above

The company’s approach to whistleblowing is under-pinned by the belief that if a staff member is genuinely concerned that wrongdoing has been or is being committed, or if they are concerned about the mental wellbeing of an individual they should not ignore it. Of course it is also the staff member’s responsibility and legal obligation not to disclose any confidential information relating to the company to any third party.

POLICY STATEMENT

1          It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

2          We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of Cyprus, in respect of our conduct both at home and abroad.

3          The purpose of this policy is to:

(a)        Set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and

(b)        Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

4          Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.

5          In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

ENVIRONMENTAL & HEALTH AND SAFETY POLICY

United Guards’ Health, Safety and Environmental Policy is to ensure that all company’s activities associated with the deployment of armed guards on board vessels will comply with the international health and safety and environmental regulations.

By conducting ourselves professionally and systematically following proper training of health and safety risk assessments and the relevant instructions (before and after embarkation), we shall significantly minimize the safety  and health risks of our employees and all our other associated parties, and ensure the avoidance of any harm to the environment.

This policy is under the responsibility of the compliance manager and must be reviewed and adjusted annually.

United Guards employees 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.

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