Human Right Policy

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Human Right Policy

DOCUMENT REVISION CONTROL AND AMENDMENT RECORD

Executive Summary

Mesopotamian Eagles Security (MES) is an Iraqi provider of security services and solutions to corporate, governments and organisations throughout Iraq. MES is committed to operating with integrity and the highest ethical standards. Our reputation is built on trust and the confidence of clients. Strong ethics and good business practice are an integral part of our vision to make and maintain MES as the most respected and successful of Iraqi security companies.

The Services Division is the operating component of MES that provides risk management and specialist manpower solutions to clients (commercial, governmental and international organisations) operating in high risk environments where its personnel may from time to time be granted authority for ‘Use of Force’.

Our Code of Ethics seeks to ensure that the Company will not engage in business with clients that it ought not to do, that its personnel will not be asked to do anything that they may feel is unethical, and that customers can be comfortable that the Company will not accrue reputational issues for them. Few issues demand more attention in this respect, than does Human Rights; especially where the Company operates alongside vulnerable communities, in regions lacking effective rule of law.

MES takes its human rights role seriously and has therefore set out core principles and practices derived from International Codes and instruments in order to provide clients and other stakeholders with clarity as to how we assess and manage our human rights responsibilities.

There are two facets. The external aspect covers MES’s obligation, in the delivery of a contract, to do no harm in keeping with its human rights policy, local law and international codes. The internal aspect encompasses MES’s responsibility to its Personnel, whether core employees or contracted personnel, principally as regards their labour and employment rights.

MES carries through its aims through:

-Responsible Contracting

-Human Rights Risk Assessment

-Training in Human Rights and Human Rights Management

-Acting as a Responsible Employer

Aims

MES will;

-Conduct a human rights impact assessment in territories in which it operates;

-Comply with international and local human rights laws and applicable provisions of international humanitarian law;

-Operate with full respect for the values, culture and religions of Iraq;

-Co-operate with law enforcement agencies in the follow-up to allegation of a breach of the law, or its codes of practice.

Responsible Contracting

MES is sensitive when considering contracts that might be perceived to impinge on civil liberties, where it operates in support of clients in areas which are environmentally fragile or with vulnerable communities, in weak governance absent the rule of law or where operations may on occasion require the bearing of arms by its personnel or by persons acting under its authority.

MES will undertake due diligence as to the human rights implications when contracting:

-MES will determine the human rights record, policies and commitment of potential clients before accepting a contract;

-MES will conduct a Human Rights Impact Assessment (HRIA) as to the potential for harm to individuals, communities, the environment, and to civil liberties in planning the delivery of a contract, or may alternatively conduct a Security and Human Rights Impact Assessment in a conflict zone or high risk environment.

-MES will seek to deliver a contract in full compliance with the human rights policies of its client, the host country and its own undertakings and policies;

Prevention and Non-Compliance

-MES will not accept contracts for the provision of security services where to do so would conflict with applicable international human rights law or international humanitarian law (IHL), or where it would be contrary to international, national or local law, or where it might prejudice the security and stability of the country or impact adversely on the environment where it operates.

-MES will not supply or maintain equipment or systems to governments, where there is a strong possibility that such equipment may be used to breach or suppress human rights.

-MES will initiate disciplinary action if its personnel are suspected of breach of this policy, or of relevant human rights laws, which may result in the dismissal of offenders.

-MES will co-operate with law enforcement agencies in the follow-up to likely breach of the law.

-MES will bring breach of human rights by third parties to the attention of sub-contractors and clients for them to address where they are implicated and the authorities for redress if no other means of addressing the matter is effective.

Human Rights Risk Assessment

Human rights risk assessment is not just the calculation of probabilities but involves other parties who are the rights-holders, i.e. whose human rights might be affected.

As part of its risk assessment strategy, in delivering contracts that might have potential for local impact:

– MES will conduct a risk assessment as to the potential for any of its actions impinging or being perceived to impinge on the human rights of a local community or individuals;

– MES will conduct a risk assessment as to the potential for public controversy or media or legal challenge on human rights grounds;

– MES will develop relationships and maintain a dialog with local community leaders and relevant civil society players, particularly in weak governance societies;

– MES will seek to ensure that senior executives and key members of the operational team fully understand the potential for harm, or perceived harm through allegations of human rights abuse from the inception of any contract.

Training and Management

MES undertakes training in human rights for all its personnel from senior executives to contracted personnel to explain how the Company gives effect to human rights obligations.

Training will:

– Explain the international background and how Human Rights obligations cascade down from
State to company level;

– Set out the background to relevant international corporate initiatives in particular the International Code of Conduct Association for Private Security Service Providers (2010) and where relevant, the Global Compact and the Voluntary Principles;

– Explain the Human Rights Impact Assessment programme. In particular, personnel will be briefed on the provisions under the International Code of Conduct Association for Private Security Service Providers and the provisions that refer to the need,

i. To respect the human rights and culture of the local community;
ii. In keeping with local law, to respect rights as regards freedom of speech and association, protection of property, freedom from arbitrary treatment;
iii. To avoid sexual exploitation or abuse (including prostitution) or sexual harassment or violence;
iv. To avoid people trafficking, child labour or slavery;
v. To avoid racist actions or language.

– Alert Personnel to potential for problems or the perception of problems so that managers can take remedial action swiftly;

– Brief Personnel on the whistle-blowing and grievance provision as it relates to human rights policy;

– Brief personnel that a breach of any of these provisions would constitute a disciplinary offence, and potentially even a criminal offence;

– Keep a record of any claims or any allegations of human rights problems and review them regularly with the Ethics Committee in order to ensure that there is no systemic problem or systematic pattern.

Use of Force

MES Personnel will receive specific training on the MES Guidance on the Use of Force (unless those agreed with and applied by a client should supervene), and use and maintenance on weapons, which are covered in separate policy the Firearms Policy.

Responsible Employer

As a responsible employer, MES values its relationship with its Personnel, whether employees or contracted personnel. MES is committed to reflecting human rights with fair and open employment policies and practices. Specifically, MES will:

– Not allow discrimination on the basis of race, colour, sex, language, religion, or other aspects unless justified by reasons intrinsic to specific work requirements in a particular environment or country;

– Recruit Personnel appropriate to the task in keeping with the laws in the country of recruitment and the country of delivery of a contract, and screen all personnel for any criminal record;

– Screen Personnel when recruiting nationals in countries where there has been a record of human rights abuse by State entities or other organizations to ensure that operatives do not have a record of human rights abuse, racist acts or sexual harassment unless there is an internationally recognized reintegration programme encouraging past parties to conflict to live and work together again;

– Provide training or refresher training appropriate to the task;

– Provide a work environment free from any form of harassment, intimidation or bullying;

– Provide clarity in writing as to job duties, payment and hours of work;

– Make clear in writing what special provision there may be for difficult environments (e.g. as regards medical and travel insurance, work clothing, or leave provision, personal use of office provided mobile phones and laptops etc.);

– Ensure that its employment policies for Personnel are compliant with international standards as reflected in the International Labour Organisation (ILO) Codes and British and third country employment rules and regulations.

Compliance and the Ethics Committee

The Executive Committee of MES is responsible for ensuring compliance with this policy paper, which incorporates the relevant provisions of the ICoCA. They are also responsible for ensuring that the key elements are fully understood by senior executives and reflected in company training courses. The Ethics Committee will act as a source of independent advice to the Executive Committee on business ethics or international matters affecting Company activities in respect of human rights and is responsible for updating and maintaining this Policy.

MES has established a procedure for any case where an individual or group might feel their human rights have been affected by the company’s action which allows for dialogue and possible solutions. The Company’s policy on Whistle-blowing and Grievance Mechanism are covered in a separate policy paper. Employees and contractors serving the Company may register any issue they may have in respect to the Company’s human rights performance as Whistle-blowing, while third parties (external to the Company) wishing to bring issues to MES’s attention as a Third Party Grievance should report the substance of their concern found on the website www.mes106.com under Values click the link or email: [email protected].

Whistle-Blowing

MES makes provision whereby its Personnel can report unethical or illegal activity in the context of human rights without fear of retribution. The Company maintains a confidential line of communication to its Ethics Committee to which Personnel may report their concerns in confidence and receive impartial advice. Allegations of wrong doing, or breach of human rights will be investigated and disciplinary action taken and/or reports submitted to the authorities if necessary. The whistle-blowing confidential e-mail address is: [email protected].

Third parties (external to the Company) wishing to bring issues to MES’s attention as a Third Party Grievance should report the substance of their concern to [email protected].

Standards

MES bases its position on human rights through the following source documents:

Applying to Corporations

• UN Global Compact, 2000
• Voluntary Principles on Security and Human Rights, 2000
• The International Code of Conduct Association for Private Security Service Providers, 2010

Applying to States:
• The Universal Declaration of Human Rights, 1948
• ILO Declaration on Fundamental Principles and Rights at Work (1998)
• The Montreux Document (2008)