Compliance – Security Force S.A

Human Rights Commitments

Security Force S.A. SFSA is committed to respecting the human rights of all stakeholders of its business activities. We conduct our business in a manner that respects the rights and dignity of all people, complying with all legal requirements.

We respect internationally recognized human rights, as set out in:

The Universal Declaration of Human Rights (1948)
The International Covenant on Civil and Political Rights (1966)
The International Convention on Economic, Social and Cultural Rights (1966)
The International Labor Organization Declaration on Fundamental Rights at Work (1998)

We recognize our responsibility to respect human rights and avoid complicity in human rights abuses, as stated in the UN Guiding Principles on Business and Human Rights.

We treat everyone who works for SFSA fairly and without discrimination.

We respect the rights of people in communities impacted by our activities. We will seek to identify adverse human rights impacts and take appropriate steps to avoid, minimize and/or mitigate them.

Industry Specific

SECURITY FORCE S.A. believes that the lawful, professional and ethical delivery of security services supports the respect of individual rights, whilst supporting the delivery of public security for the benefit of whole communities. As a private security company, we recognize that there are some human rights that are especially salient in the sector in which we operate.

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 the international humanitarian law.

The International Code of Conduct for Private Security Providers and the Voluntary Principles on Security and Human Rights are absolute standards to which we must abide at SFSA, and these have been embedded into the relevant parts of our business.

• Company Ethics

SECURITY FORCE S.A. is dedicated to uphold uncompromised integrity in all its operations and adhere to the highest ethical standards. We are driven by a vision to make SFSA one of the most trusted security companies by delivering services with high levels of confidentiality and efficiency. SFSA does not accept any act or practice that compromises its values.

SECURITY FORCE S.A. promises to:

Uphold the highest standard of business ethics in all its operations
Deliver the highest standard of service to the clients and maintain client confidentiality
Adhere to the laws and regulations of Haiti
Do business with recognized legal entities and be compliant with relevant national and international law
Adhere to international and local human rights laws and applicable provisions of international humanitarian law
Honor the values, culture and religions of Haiti
Not tolerate discrimination or harassment of people for any reason
Not permit its staff to undertake activities which might compromise the security and stability of Haiti or adversely impact the environment

SFSA treats its appointments, projects and responsibilities with utmost sincerity and promotes an open, transparent and honest environment in all its dealings.

1.1 Business Integrity

Our core values are based on high standards of business integrity. We do not pay bribes, engage in acts of corruption or receive kickbacks either directly or indirectly. SECURITY FORCE S.A. promotes fair practice and upholds its commitment to high standards of integrity.

1.2 Conflicts of Interest

The SECURITY FORCE S.A. staff should avoid transactions in which their personal interests could conflict or might be seen to be in conflict of those of the company. This may include: making use of any client information acquired during the course of their employment with PSS for personal benefit; transferring such information to a third party; or engaging into an act that could be considered as reprehensible.

1.3 Confidentiality

SFSA promises not to reveal the identity of any Crisis Response client or any other client without their approval. Even if a client reveals the company’s involvement, we will neither confirm nor deny our involvement. Any breach, or suspected loss, shall be brought to the notice of the Management.

1.4 Political Activities

SFSA follows a policy of strict political neutrality. Donations to any political parties, organizations, or individuals engaged in politics are not acceptable. SFSA employees are entitled to their own political views and activities, but they may not use company premises or equipment to promote those views nor associate their views with those of the company.

1.5 Business Relationships

SECURITY FORCE S.A. expects its suppliers, sub-contractors, representatives and joint venture partners to adhere to integrity principles that constitute our core values.

1.6 Guidance

The SFSA staff must abide by this code in all circumstances. For any doubt about the application of this code, employees should seek guidance from their line Supervisor. The Management will provide backing to company staff who find themselves in difficult situations, or who fail to win business, as a result of abiding by the code.

SFSA considers the breach of code very seriously. Employees who fail to abide by the code may face disciplinary action including dismissal.

1.7 Gifts, Gratuities and Kickbacks

Any individual working for or on behalf of SFSA is strictly prohibited from accepting or offering kickbacks, cash gifts or gratuities from any supplier, customer, competitor or business partner, directly or indirectly. A kickback can be in the form of cash, fee, commission, gift, or anything of value.

2. Recruitment Process:

At SECURITY FORCE S.A., we discourage discrimination and offer equal employment opportunities. We promote workplace diversity and make employment decisions irrespective of race, color, gender, marital status, ethnicity, religion, age, national origin, sex, sexual orientation, gender identity, veteran status, ancestry, genetic information, disability, or any status protected by the laws of the Republic of Haiti. This applies to all HR aspects including recruiting, hiring, promotions, transfers, terminations, compensation, administering benefits, disciplinary actions, training, performance assessments, and all other employment terms and conditions.

Background checks should be conducted to ensure that employees have not:

Been convicted of a crime that indicates that they lack the character and fitness required to deliver security services;
Had other employment contracts terminated for documented breach of one or more of the principles referred to in the Code of Ethics
Had a history of other conduct that questions their appropriateness to carry a weapon.

Disqualifying crimes may include, but are not limited to, battery, murder, arson, fraud, rape, sexual abuse, organized crime, bribery, corruption, perjury, torture, kidnapping, drug trafficking or trafficking in persons.

3. Grievance Procedures

Following are the ways in which complainants may believe they have been adversely affected by the actions of SFSA and its management or staff:

Death or injury of a family member
Personal injury
Excessive use of force
Violation of human rights, including those relating to gender, ethnicity and labor
Material or financial loss
Breach of contract for a third party
Loss of reputation
Damages caused to environment

3.1 Definition of Third Party

Third parties: Separate contract conditions, policies and processes shall apply for the third party.

3.2 Policy

3.2.1 SFSA will handle complaints from third parties in an effective and appropriate way, and will register such complaints with the appropriate external authorities as and when necessary.

3.2.2 Third parties may file complaints with SFSA Management and staff at any level. Contact details can be found on: www.securityforcesa.com

3.2.3 Complainants should present their complaint in a written form, providing complete information about circumstances and Security Force S.A.’ alleged involvement.

3.2.4 If complainants believe that complaints have not been handled appropriately, and prefer to seek redress through an independent body, they are advised to seek support from a relevant external body.

3.3 Initiation, conduct and reporting of investigations into third party complaints:

3.3.1 A Security Manager, or a Post Supervisor, can initiate an investigation into third party complaints. The concerned body will inform its line manager and submit a report describing the findings.

3.3.2 Where an investigation reveals that a crime or serious disciplinary offence may have been committed, the Post Supervisor will refer the matter immediately to the Operations Department.

3.3.3 The investigation’s findings would be communicated to the complainant in written form, upon conclusion of the investigation.

3.4 All Security Force S.A. Employees must:

Guide complainants about the process and assist them in complaint submission
Ensure that complaints are escalated through the company’s line Management system to an appropriate level
Refer to their line Manager when they are in doubt and ensure that investigations are fully supported

3.5 Responsibilities of Heads of Office and Departments:

Create awareness about the policy internally as well as externally.
Conduct training and implement processes to ensure policy compliance
Ensure that complaints are investigated completely in line with the policy, and that appropriate disciplinary action is implemented when required.
Guide complainants about the outcome of investigations and disciplinary action in written form, and ensure that appropriate reimbursement is made.
Ensure that action is taken to report complaints to the appropriate external authorities.
Ensure that SFSA provides full support to external investigating authorities.

3.6 Legal Counsel:

Where a criminal act may have taken place, the Security Force S.A. Legal Counsel will take the matter to the appropriate authorities and facilitate the investigation.

• Industry Associations

Security Force S.A. is fully dedicated to adhere to the highest professional, legal and ethical standards.

On the national level, PSS is certified to execute security consulting and protective services due to being a member of Association Professionnelle des Agences de Sécurité /APAS and therefore upkeeps a constant communication with local authorities.

On the international level, our company is registered with the International Code of Conduct Association [ICOCA] and always complies with Haitian Law. Also, we have already implemented policies and procedures corresponding with the company management and its operations, which are in line with highest level of ethical standards as well as with the International Human Rights Agenda.

• Complaints

SFSA takes its responsibilities as an internationally operating company very seriously. We remain available for concerns or complaints related to our operations or conduct in any environment. Our goal is to solve challenges to the satisfaction of all affected parties.

For that, please address any issue of concern or a complaint to www.securityforcesa.com and give a detailed factual description of the circumstances that led up to your concern or complaint. In order to verify, investigate and solve a specific matter, we reserve ourselves the right to include our legal department into the process and would appreciate to receive as well the contact details of the individual or organization, which brought the concern or complaint to our attention.

Workplace Discrimination and Harassment Policy

Scope

This policy applies to:

board members
All staff, including: managers and supervisors; permanent staff; job candidates, and contractors.
How SFSA provides services to clients and how it interacts with other members of the public
all aspects of employment, recruitment and selection; conditions and benefits; training and promotion; task allocation; shifts; hours; leave arrangements; workload; equipment and transport
on-site, off-site or after-hours work; work-related social functions; conferences – wherever and whenever staff may be as a result of their SFSA duties
Staff treatment of other staff, of clients, and of other members of the public encountered in the course of their duties with

Aims

SFSA is committed to providing a safe, flexible and respectful environment for staff and clients free from all forms of discrimination, bullying and sexual harassment.

All SFSA staff is required to treat others with dignity, courtesy and respect.

By effectively implementing our Workplace discrimination and harassment policy we will attract and retain talented staff and create a positive environment for staff.

Staff rights and responsibilities

All staff is entitled to:

recruitment and selection decisions based on merit and not affected by irrelevant personal characteristics
work free from discrimination, bullying and sexual harassment
the right to raise issues or to make an enquiry or complaint in a reasonable and respectful manner without being victimized
Reasonable flexibility in working arrangements, especially where needed to accommodate their family responsibilities, disability, religious beliefs or culture.

All staff must:

follow the standards of behavior outlined in this policy
offer support to people who experience discrimination, bullying or sexual harassment, including providing information about how to make a complaint
avoid gossip and respect the confidentiality of complaint resolution procedures
Treat everyone with dignity, courtesy and respect.

3.1 Additional responsibilities of Managers and Supervisors

Managers and Supervisors must also:

Model appropriate standards of behavior.
Take steps to educate and make staff aware of their obligations under this policy and the law.
Intervene quickly and appropriately when they become aware of inappropriate behavior.
Act fairly to resolve issues and enforce workplace behavioral standards, making sure relevant parties are heard.
Help staff resolve complaints informally.
Refer formal complaints about breaches of this policy to the appropriate complaint handling officer for investigation.
Ensure staff that raise an issue or make a complaint are not victimized.
Ensure that recruitment decisions are based on merit and that no discriminatory requests for information are made.
Seriously consider requests for flexible work arrangements.

Unacceptable workplace conduct

Discrimination, bullying and sexual harassment are unacceptable at Security Force S.A. and are unlawful under the following legislation:

Sex Discrimination
Racial Discrimination
Disability Discrimination
Age Discrimination
Discrimination in relation to religious beliefs

Staff (including managers) found to have engaged in such conduct might be counselled, warned or disciplined. Severe or repeated breaches can lead to formal discipline up to and including dismissal.

4.1 Discrimination

Discrimination is treating, or proposing to treat, someone unfavorably because of a personal characteristic protected by the law, such as sex, age, race or disability.

Discrimination can occur:

Directly, when a person or group is treated less favorably than another person or group in a similar situation because of a personal characteristic protected by law (see list below).

For example, a worker is harassed and humiliated because of their race

A worker is refused promotion because they are ‘too old’

Indirectly, when an unreasonable requirement, condition or practice is imposed that has, or is likely to have, the effect of disadvantaging people with a personal characteristic protected by law (see list below).

For example, redundancy is decided based on people who have had a worker’s compensation claim rather than on merit.

Protected personal characteristics under Federal discrimination law include:

a disability, disease or injury, including work-related injury
parental status or status as a career, for example, because they are responsible for caring for children or other family members
race, color, descent, national origin, or ethnic background
age, whether young or old, or because of age in general
sex
industrial activity, including being a member of an industrial organization like a trade union or taking part in industrial activity, or deciding not to join a union
religion
pregnancy and breastfeeding
Sexual orientation, intersex status or gender identity, including gay, lesbian, bisexual, transsexual, transgender, queer and heterosexual.
marital status, whether married, divorced, unmarried or in a de facto relationship or same sex relationship
political opinion
social origin
medical record
an association with someone who has, or is assumed to have, one of these characteristics, such as being the parent of a child with a disability.

It is also against the law to treat someone unfavorably because you assume they have a personal characteristic or may have it at some time in the future.

Actions to be taken in the event of discrimination involving a third party

In the event that discrimination involves a third party, that is, a person who is neither an employee, client, nor supplier of the SFSA Company. That third party who is discriminated against or harassed by one of our employees whom would be the author, the third party would have to file a complaint directly with the Company’s office; it will address a Supervisor, and / or the Manager who will have to start the administrative process for this purpose.

It is important to note that Security Force S.A. encourages any witnesses, even those who are not discriminated against or harassed, to defer any employee who is the author of such actions. This third party may also send an e-mail on the Company’s website: www.securityforcesa.com or come directly to the Company’s offices.
For example: In the case of an employee of the Company who enters into an altercation with a merchant concerning a cumulative debt that he has not been able to honor, the said merchant may come directly to the office of the Company to file a complaint and ask to see a Supervisor or Manager. This report therefore extends to any witness who can denounce and prove this unworthy fact.

4.2 Bullying

If someone is being bullied because of a personal characteristic protected by equal opportunity law, it is a form of discrimination.

Bullying can take many forms, including jokes, teasing, nicknames, emails, pictures, text messages, social isolation or ignoring people, or unfair work practices.

Under Federal law, this behavior does not have to be repeated to be discrimination – it may be a one-off event.

Behaviors that may constitute bullying include:

sarcasm and other forms of demeaning language
threats, abuse or shouting
coercion
isolation
inappropriate blaming
ganging up
constant unconstructive criticism
deliberately withholding information or equipment that a person needs to do their job or access their entitlements
Unreasonable refusal of requests for leave, training or other workplace benefits.

Bullying is unacceptable at Security Force S.A. and may also be against occupational health and safety law.

4.3 Sexual harassment

Sexual harassment is a specific and serious form of harassment. It is unwelcome sexual behavior, which could be expected to make a person feel offended, humiliated or intimidated. Sexual harassment can be physical, spoken or written. It can include:

comments about a person’s private life or the way they look
sexually suggestive behavior, such as leering or staring
brushing up against someone, touching, fondling or hugging
sexually suggestive comments or jokes
displaying offensive screen savers, photos, calendars or objects
repeated unwanted requests to go out
requests for sex
sexually explicit posts on social networking sites
insults or taunts of a sexual nature
intrusive questions or statements about a person’s private life
sending sexually explicit emails or text messages
inappropriate advances on social networking sites
accessing sexually explicit internet sites
behavior that may also be considered to be an offence under criminal law, such as physical assault, indecent exposure, sexual assault, stalking or obscene communications.

Just because someone does not object to inappropriate behavior in the workplace at the time, it does not mean that they are consenting to the behavior.

Sexual harassment is covered in the workplace when it happens at work, at work-related events, between people sharing the same workplace, or between colleagues outside of work.

All staff have the same rights and responsibilities in relation to sexual harassment.

A single incident is enough to constitute sexual harassment – it doesn’t have to be repeated.

All incidents of sexual harassment – no matter how large or small or who is involved – require employers and managers to respond quickly and appropriately.

SFSA recognizes that comments and behavior that do not offend one person can offend another. This policy requires all staff and volunteers to respect other people’s limits.

4.4 Victimization

Victimization is subjecting or threatening to subject someone to a detriment because they have asserted their rights under equal opportunity law, made a complaint, helped someone else make a complaint, or refused to do something because it would be discrimination, sexual harassment or victimization. Victimization is against the law.

It is also victimization to threaten someone (such as a witness) who may be involved in investigating an equal opportunity concern or complaint.

Victimization is a very serious breach of this policy and is likely (depending on the severity and circumstances) to result in formal discipline against the perpetrator.

SFSA has a zero-tolerance approach to victimization.

4.5 Gossip

It is unacceptable for staff at Security Force S.A. to talk with other staff members, clients or suppliers about any complaint of discrimination or harassment.

Breaching the confidentiality of a formal complaint investigation or inappropriately disclosing personal information obtained in a professional role (for example, as a manager) is a serious breach of this policy and may lead to formal discipline.

Merit at SFSA

All recruitment and job selection decisions at SFSA will be based on merit – the skills and abilities of the candidate as measured against the inherent requirements of the position – regardless of personal characteristics.

It is unacceptable and may be against the law to ask job candidates questions, or to in any other way seek information, about their personal characteristics, unless this can be shown to be directly relevant to a genuine requirement of the position.

Resolving issues at Security Force S.A.

SFSA strongly encourages any staff member who believes they have been discriminated against, bullied, sexually harassed or victimized to take appropriate action.

Staffs who do not feel safe or confident to take such action may seek assistance from the Human Resources Services for advice and support or action on their behalf.

Other relevant Security Force S.A. policies

Staff, especially Managers and Supervisors, is encouraged to read this policy in conjunction with other relevant SFSA policies.

More information

If you have a query about this policy or need more information please contact: www.securityforcesa.com

Review details