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

 

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 compliant, claim or grievance is highly encouraged to report it directly and in detail to Company CEO: noam@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. It might be appropriate, for example, for a member of staff to discuss a procedure with his/her partner. 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 United Guards Managers or Directors. Whichever way was chosen to raise the grievance; it will be acknowledged in writing 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.
  • United Guards 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.
  • United Guards will 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 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 CEO within five working days. You will then be invited to a further meeting (can also be performed online), which you must take all reasonable steps to attend. As far as reasonably practicable, the company will be represented by a more senior manager that attended the first meeting (unless the most senior manager attended that meeting). Following the appeal meeting you will be informed of the final decision, normally within ten working days, which will be confirmed in writing.


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.

 

CODE OF BUSINESS ETHICS AND CONDUCT

Mission Statement

United Guards Services Ltd (UGS) 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 recognizes it has responsibility for all the actions of its employees in connection with the activities of the organization.

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 organization.

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

  • We will comply with the law of each country in which we do business.
  • We will comply with all international laws related to the protection of Human Rights.
  • We will comply with the International Code of Conduct Association (ICoCA) Code.
  • 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 Services Ltd is not directly represented are expected to comply with this Code in all matters in which they are acting on United Guards Services Ltd behalf.

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

All employees and third party providers of services on its behalf, have the right to make confidential reports direct to the Director of United Guards Services Ltd at  noam@mano-security.com without fear of detrimental action being taken against them.

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.

Anti-Bribery and Anti-Corruption Policy

United Guards Services Ltd takes zero-tolerance approach to bribery and corruption and is committed to conducting all business in an honest, professional and fair manner and implementing effective systems to counter any such acts.

The Company will uphold laws relevant to countering bribery and corruption in all of the jurisdictions in which it operates. United Guards Services Ltd remains bound by the laws of Cyprus, in respect of conduct at home and abroad.

 
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.

 
WHISTLEBLOWING POLICY

The Whistleblowing Policy is an important pillar in the quality management system of United Guards Services. 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 wellbeing of an individual. This is known as whistleblowing or, more formally, as making a disclosure in the public interest.

United Guards Services 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 the national and Human Rights Laws.

Therefore, it is United Guards Services 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 CEO and should be reviewed annually.

Policy Scope and Principles

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

It is unlawful to dismiss, discipline or victimise a worker who ‘blows the whistle’ on criminal behaviour or malpractice, providing the worker 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, compliance or human rights 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. If a staff member feels they need independent advice, they can contact Cyprus Authorities and ask for confidential advice on whistle-blowing matters, but it is the staff member’s responsibility not to disclose any confidential information relating to the company to this third party.

 

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.

 

ANTI-CORRUPTION AND BRIBERY POLICY

Policy Statement

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.

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, as well as human rights law and ICoCA Code, in respect of our conduct both at home and abroad.

The purpose of this policy is to:

  • Set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and
  • Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

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.
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.

 

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