1. Introduction

The company promotes a commitment to high standards of conduct. All personnel are
expected to share this commitment. This document clearly states the principles upon
which the conduct of personnel will be based.

 

2. Commitments to exemplary conduct

Any Code of Conduct dictates how personnel must work. The aims of this Code are to
set out specific principles in compliance with the International Code of Conduct,
allowing the operation of the company and any associated companies, to bear scrutiny
at an international level. It is expected that adherence to this Code will allow
personnel to operate in a humane way within local, national and international laws
and promote the business ideals of the company.

 

3. Implementation and monitoring

This Code of Conduct will provide a framework for the use of Standard Operating
Procedures (SOPs). Personnel will adopt the principles within this Code with a view
to using this document to inform the implementation of SOPs. Personnel will also be
open to monitoring of the adherence to this Code by Company Senior Management
and the company itself will expect transparency throughout in the case of monitoring
from outside bodies with the appropriate authority.

 

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
criteria.
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.

 

5. Specific Principles ‐ All GULF SHIELD Personnel

5.1 Appearance and general conduct

Personnel will strive to ensure their appearance is professional and practical at all
times when working internationally. Operatives will accept guidance from the
company on appearance and dress in accordance with the laws and climate of
international locations. General conduct is expected to remain at the highest standard
and persons coming into contact with personnel will receive equal humane treatment
with respect for personal dignity and privacy. It is expected that personnel will
familiarize themselves with appropriate local knowledge of customs and courtesy to
promote good relations with local communities.

 

5.2 The use of force, applicable rules and the law

Personnel will take all reasonable steps to avoid the use of force. If force is required,
it should be proportionate to the threat and within the applicable law. Force will only
be used where appropriate to the situation and shall not exceed what is necessary
within the Rules for the Use of Force (RUFs). The use of force and firearms will, at
all times, comply with all national and international laws and will be, where
applicable, parallel to the obligations of regular law enforcement officers in that area.
Firearms must only be used against persons in self-defense or defense of others
against an imminent threat of death or serious injury.

THIS CODE DOES NOT LIMIT THE ACTIONS PERSONNEL CAN TAKE TO DEFEND THEMSELVES.

However, actions of self-defense do not include the use of firearms or force to
degrade or torture persons. When the use of firearms is deemed necessary, adherence
to SOPs relating to such usage is demanded.

 

5.3 Apprehension of persons

Persons may be apprehended when personnel are acting in self-defense, defense of
others following an imminent threat of violence, attack or crime. These persons must
be handed over to an appropriate authority at the earliest opportunity and in the
interim, be treated humanely within applicable law. If a person is required to be held
by personnel for any length of time, they will be treated in compliance with human

rights laws and prohibitions on torture, cruel or degrading treatment or forms of
punishment will be observed at all times

 

5.4 Prohibited actions

All personnel adhering to this Code will accept the prohibition of the following
actions in compliance with international law and the ethics upon which this Code is
founded.
The following prohibitions must be strictly adhered to and include (but are not limited
to):
Personnel will not:
 Engage in torture, punishment, cruel or degrading treatment of persons. Nor will
these actions be enabled or supported by personnel, even in the event of imminent
armed conflict, threats to national or international security, or any other
extraordinary circumstance. The torture or inhumane treatment of persons by
another person will be reported to the company immediately.
 Engage in or benefit from the sexual exploitation of persons. Violent sexual
crime, prostitution, rape and sexual harassment within the company or externally
are strictly prohibited. Incidents of this nature must be reported immediately to the
relevant authorities.
 Engage or benefit from the use of labour provided by force, slaves or children.
Personnel will not allow associated contractors, groups or workers whether paid
or voluntary to engage in these kinds of labour.
 Engage or benefit from human trafficking of adults or children. Personnel will not
support or enable the trafficking of humans for labour, prostitution or any other
cause.
 Discriminate against any persons on grounds of race, colour, sex, religion,
disability or sexual orientation. The company will also adhere to this principle
when recruiting personnel, within the requirements of the position available.
 The above actions are strict prohibitions and contravention of any of these may
result in the termination of employment and further legal repercussions. Personnel
are expected to report immediately any suspicions of incidents involving the
above actions.

 

5.5 Identity and documentation

To maintain security and the safety of civilians, personnel will be individually
identifiable when working internationally. All vehicles used in the course of
contractual duties will be licensed and registered as appropriate and any other
licensable items or materials (including hazardous materials) will be registered within
applicable law.

 

5.6 Corporate Integrity

Personnel will be required to uphold the corporate integrity of their employer. The
Code of Conduct will be observed at all times and the ethics and relevant training and
skills will be utilized effectively in supporting the work of the company. Personnel
will maintain a responsibility to the company and preserve its integrity through
observing the following responsibilities:
 Personnel will not engage in, benefit from, or enable competitors or other
inappropriate persons, to acquire confidential information about the company or
its personnel.
 Personnel will avoid potential conflicts of interest which could impair their
performance for the company. These include (but are not restricted to): business
dealings, investments, family relationships, outside employments, improper
personal benefits, gratuities and inappropriate relationships with clients, suppliers,
or competitors.
 Personnel will not accept or offer gifts, gratuities, kick‐backs or bribes to persons
or organizations seeking to engage in business with the company.
 Personnel will consult with management in the event of an action arising which is
not clearly defined above, but which may be construed as a bribe, gratuity or
solicitation of same.
Personnel will be required to uphold the corporate integrity of their employer. The
Code of Conduct will be observed at all times and the ethics and relevant training and
skills will be utilized effectively in supporting the work of the company. Personnel
will maintain a responsibility to the company and preserve its integrity through
observing the following responsibilities:
 Personnel will not engage in, benefit from, or enable competitors or other
inappropriate persons, to acquire confidential information about the company or
its personnel.
 Personnel will avoid potential conflicts of interest which could impair their
performance for the company. These include (but are not restricted to): business
dealings, investments, family relationships, outside employments, improper
personal benefits, gratuities and inappropriate relationships with clients, suppliers,
or competitors.
 Personnel will not accept or offer gifts, gratuities, kick‐backs or bribes to persons
or organizations seeking to engage in business with the company.
 Personnel will consult with management in the event of an action arising which is
not clearly defined above, but which may be construed as a bribe, gratuity or
solicitation of same.

 

6. Specific Principles – Company Responsibilities

6.1 Qualifications, training and sub‐contracting

 Personnel and sub‐contractors will be selected on the basis of appropriate
qualifications and training.
 To ensure that personnel can consider themselves as providing the highest level of
service, GULF SHIELD will source skills and training where relevant.
 GULF SHIELD will provide and expect personnel to submit to physical and
mental health checks to ensure fitness for duty.
 In line with corporate policies, the suitability of applicants or Personnel to carry
firearms will be subject to stringent inspections including (but not restricted to):
authorized access to prior employment records, Government records and
employment history, consistent with applicable law. Firearms will only be issued under strict guidelines and disqualifying elements may include (but are not limited
to):
 Prior convictions for violent crime.
 Dishonourable discharge.
 A documented violation of International Code of Conduct principles resulting in
the termination of prior employment.
 A history of conduct that, to a reasonable person, may affect their judgment in the
use of a weapon.
The company will also provide ‐ and expect personnel to make effective use of ‐
information and training regarding local, national and international laws,
humanitarian laws and international standards of human rights. Records of training
and attendance will be kept to ensure all personnel are able to work within the
applicable laws.

 

6.2 Policies, personnel contracts and SOPs

The International Code of Conduct, applicable labour laws, criminal laws and human
rights laws provide the basis for company policies, personnel contracts and SOPs. The
company will reserve the right to keep employment records on former and current
personnel for a period of no less than seven years. Such information may be accessed
by competent authorities except where prohibited by law. Travel documents and
identification, including passports will only be held by the company for
administrative purposes and for the shortest amount of time possible. The company
will co‐operate with law enforcement authorities in the event of personnel becoming
the subject of investigation. The company will also use the relevant employment,
labour and national and international laws to implement policies and procedures
regarding Health and Safety, Harassment, Grievances and other relevant training
including weapon and munitions management along with following the Companies
Ethics & Human Rights Policies.

 

6.3 Under the company Code of Conduct

 Personnel will accept a responsibility to work within Health and Safety guidelines
as laid down by the company. Personnel will recognize precautions that are taken
to preserve life in high‐risk or life‐threatening situations and to accept training
which will enable operatives to work as safely as possible.
 Personnel will use the training, weapons, protective equipment and direction
issued by the company with a view to operating within the Code of Conduct and
Health and Safety guidelines as lay out by the company.
 Will adhere to the policies implemented by the company to promote a healthy and
safe working environment, psychological health among personnel and prevent
misconduct and damage to the health and safety of other persons or personnel.
 The company will expect all personnel to report any incidents of harassment or
abuse of co‐workers. Forms of harassment within the company will not be
tolerated.
 Grievances will be considered by the company via the appropriate procedures,
which will be fair, effective and accessible. Appropriate records will be kept and
made available to relevant authorities where, not prohibited by law. Investigations
into conduct or grievances will be made quickly and impartially with
consideration for confidentiality laws and with the co‐operation of outside
agencies where necessary.
 The company will expect all personnel to act in an open and honest manner. To
aid transparency, personnel are expected to report any suspicions of malpractice
or concerns about unethical or potentially illegal behaviour to their immediate
manager or to the Board of Directors. Reports of misconduct will be investigated
and all personnel and associated workers (such as sub‐contractors or consultants)
will co‐operate with any such investigation. Reports can be made anonymously
and substantiated allegations will
 Retaliation is prohibited for grievances or reports of misconduct. Witnesses,
complainants or whistle-blowers will not suffer retaliation. Where reports are
judged to have been made with malicious intent or based on false allegations,
complainants may be subject to disciplinary action. The company will ensure that
financial obligations can be met in the event of anticipated commercial liabilities.

 

6.4 Weapons and their management

 The company will acquire and maintain the relevant authorizations, licenses or
other documentation required for the use and possession of weapons and
ammunitions, as dictated by the applicable laws.
 Weapons and ammunitions will be kept in the appropriate condition and the
company and its personnel (including associated personnel such as
sub‐contractors) will not illegally transfer, alter or use weapons or ammunition.
 The company will establish and provide policies and procedures for the storage,
issue, identification, accounting and disposal of weapons and ammunitions.
Records of the issue of weapons to individuals will also be stringently kept.
 The company will ensure that appropriate training, (weapon‐specific where
required), will be completed before personnel can be issued with a firearm.
 This training will be recurrent, and will include weapon‐specific training where
required and reiteration of the rules for the use of force (RUFs).

 

6.5 Munitions and the material of war

 The company will acquire and maintain the relevant authorizations within
applicable law, for the use, storage, issue and disposal and possession of materials
or war, hazardous materials and munitions.
 The company will establish and enforce policies and procedures for the use,
storage, issue, disposal and record‐keeping relating to munitions and materials of
war.
 The company, its personnel and any associated personnel (including
sub‐contractors) will not use or enable the use of any illegal materials of war
within the applicable laws

 

6.6 Transparency and accountability

The company will expect all personnel to conduct themselves with transparency,
aided by the company’s Code of Conduct.
Personnel will be expected to take responsibility for themselves and each other and,
while acting in accordance with relevant SOPs and the Code of Conduct, to preserve
their health and defend themselves when necessary.
Incident reports form a fundamental part of transparency and will always include:
time and location of the incident, identity, contact details and nationality of persons
involved, injuries or damage sustained, the sequence of events leading up to the
incident and the response by personnel and subsequent measures taken by the
company.
Incidents which may require a report include (but are not limited to):
 The firing of a weapon in any circumstances (except during training).
 Criminal acts.
 Traffic collisions.
 Attacks or threatened attacks.
 Damage to property or equipment.
 Persons injured or killed.
 Incidents involving other security forces.
 Incidents requiring an escalation of force under RUFs.

 

6.7 Compliance with the International Code of Conduct

This Code of Conduct will not replace specific SOPs, RUFs or company policies or
procedures. This document provides a framework within which company‐specific
procedurals can operate.
Best practice ‐ as defined in the International Code of Conduct ‐ is formulated within
this document with a view to ensuring all personnel can operate internationally to the
highest standard of conduct within local, national and international law ‐ including
humanitarian laws.
The adoption of this Code of Conduct invites all personnel within the company to
work within the ethical, moral and humane guidelines as identified by the
international community.
The company reserves the right to make alterations to this document to ensure
compliance with the most recent standards of best practice.

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

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