A grievance is defined as ‘A wrong or a hardship suffered, which is grounds for complaint’. Grievances may
arise from within the Company or from an external source; Gulf Shield Company for Security Services policy
on the handling of grievance covers both these circumstances but the procedures vary. This document reflects
this situation.



The aim of this document is to present Gulf Shields policy and procedures for the handling of any grievance
from within or outside the Company with a view to facilitating their successful resolution in a timely fashion.



This policy and procedures apply to all Company staff (consultants/contractors or employees), sub-contractors
and any third party who have cause, or feel that they have cause, for complaint against Gulf Shield.


4. Ethics and Standard Operating Procedures

Ethics and personnel adoption of ethical behavior is fundamental to the operation of
this Code of Conduct. SOPs are structured to give defined actions within a set of
This Code of Conduct provides a wider framework in which to implement SOPs,
allowing personnel to incorporate an ethical solution while operating internationally.
This Code requires all personnel to act within applicable law, within guidelines as laid
out by the United Nations Security Council and to strive for full compliance with the
International Code of Conduct.



1. The following comprise Gulf Shields grievance policy:

a. It is to be transparent and fair by nature and in its application.
b. Informal action will be considered, where appropriate, to resolve problems. Often an informal meeting
between the aggrieved party and their manager/Gulf Shield Representative is the most effective way of
resolving minor complaints, and encourages direct communication between management and staff.
c. In the case of formal action the aggrieved party must provide Gulf Shield management with a written
submission, which provides details of the complaint (Nature, time, place and those involved). If, in the case of
a “third party” individual feeling they have a grievance against Gulf shield Security and an in-effective approach
to resolve the grievance cannot be made with informal active, the individual is encouraged to contact our local
representative at and the necessary actions will be made aware to you.
d. Gulf Shield management and aggrieved parties are to raise and deal with issues promptly and not
unreasonably delay meetings, decisions or confirmation of such decisions.
e. Gulf Shield management and aggrieved parties are to act consistently.
f. Employees have the right to be accompanied at any meeting concerning a grievance. In cases where group
grievances are addressed, a maximum of two observers will be allowed to attend the grievance process in
addition to the representatives.
g. Aggrieved parties may appeal against the decision made.
h. No employee will be victimised for invoking this grievance procedure; where victimisation is suspected, a
grievance should be submitted in accordance with the Company’s grievance procedure.

An employee who has a grievance over any work related issue has the right to raise their concerns with Gulf
Shield management.
Informal Dealing

Issues of a serious nature should always be dealt with formally; however, when mutually agreed, less serious
grievances should be dealt with informally. This should take the form of an informal discussion between the
aggrieved party and an appropriate manager. If it becomes clear that the matter cannot be resolved
satisfactorily, or that the case is more serious that first assessed, the formal process must be adopted. If both
parties agree that the grievance has been resolved satisfactorily no further action need be taken but the
manager should make an informal note to record the event, its nature and outcome.


Formal Process

The formal process may involve up to 4 procedures:



The aggrieved party must provide an appropriate Gulf Shield manager with a written submission which gives
details of the grievance; these should include:
(1) The nature of the grievance.
(2) Where the incident(s) has occurred.
(3) Who has been involved?
(4) When the incident(s) happened or has been happening.
(5) Any actions that have been taken so far by any of the parties concerned.



Gulf Shields management will arrange for a meeting to take place within 5 days to discuss the grievance. In
preparing for such a meeting, managers should consider the following: having an impartial record keeper,
making themselves aware of the full facts of the case, how similar grievances may have been resolved in the
past, whether an interpreter may be needed. The aggrieved party has the right to be accompanied by a
colleague, who may be allowed to address the meeting on the employee’s behalf, sum up the employee’s
case, respond to any views expressed at the meeting and confer with the employee. Once the hearing has
finished the Gulf Shield manager will take time to consider the case.



In making the decision upon the outcome and Gulf Shields position, the manager should consult the Head of
Human Resources, Head of Legal and Contracts or other senior managers within the Company – and is
encouraged to do so. Regardless the decision should be presented in writing within 24hrs of the hearing. Once
it has been made, the manager is to inform the aggrieved party in writing of the outcome. The latter has the
right to appeal if they are dissatisfied.


The aggrieved party has grounds for dissatisfaction they appeal but this must be submitted within 5 days
explaining their grounds for appealing in writing to Gulf Shield management. An appeal meeting should be
arranged within 5 days and should be run by the next more senior manager. The hearing will follow the format
described in 4b above and the aggrieved party may be accompanied.



Records of the following are to be made and kept for 7 years:
a. Nature and details of the grievance.
b. What was decided and the actions taken.
c. The reasons for these actions.
d. Whether an appeal was made and its outcome.
e. Any other subsequent developments.



6. The policy set out in paragraph 1 applies to a non-employee who has a grievance to make against the
Company. The procedures described in paragraphs 3 and 4 are very similar but the complaint is likely to be
dealt with at corporate level in the first instance. In summary:
a. Informal Approach. Gulf Shield prefers to resolve grievance issues on an informal basis whenever possible;
but only when this course is mutually agreeable.
b. Formal Approach. The formal approach requires the aggrieved party to submit the details of their complaint
in writing (as per 4a) to the Head of Legal and Contracts at Gulf Shield Principle Office, House 10, Lane 30, Al
Jazeer, Umman District, Al Basra, Iraq. Arrangements will be made for a hearing – the composition of
attendees will be agreed on a case by case basis. Gulf Shield will inform the aggrieved party of its decision in
writing within 24 hours of the hearing being completed. The aggrieved party has the right to appeal within 5
days and this process should be started by a submission in writing explaining the grounds for this appeal. A
further hearing will be convened but managed by a different person with the findings being promulgated
within 24 hours of its completion.



Grievances are to be handled with sensitivity, respect but without undue delay. The procedures are relatively
straightforward and must be followed precisely; the importance of keeping records is emphasised. Advice
should be sought from senior managers (particularly the Head of Human Resources and the Head of Legal and
Contracts) from the outset.

16th July 2015
Mr Saeed brissam
Chief Executive Officer……………………………………………..

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