Ethic Policy

Gulf Shield Security is committed to protecting employees, partners, vendors and the company from illegal or damaging actions by individuals, either knowingly or unknowingly. When Gulf shield addresses issues proactively and uses correct judgment, it will help set us apart from competitors. Gulf Shield will not tolerate any wrongdoing or impropriety at any time. Gulf Shield will take the appropriate measures and act quickly in correcting the issue if the ethical code is broken.

Integrity Policy

Integrity and a high ethical standards are fundamental to Gulf Shield’s beliefs and are to be upheld by all individuals employed by the Company. The Company—and each employee—must remain committed to obeying all laws and always doing what is right.

Our Core Principles are accomplished in dealings with our clients, suppliers, all employees, and all others whom we work with or whom we encounter while representing the Company:

  • Obey the letter and intent of the law;
  • Conduct ourselves in a forthright and honest manner;
  • Fair and considerate in all dealings;
  • Maintain professional behavior and use common courtesy;
  • Respect the rights and dignity of all individuals, as well as the legal rights of all other businesses and organizations;
  • Make only commitments we believe we can keep — and do our best to keep them;
  • Avoid the appearance of any impropriety; and expect and encourage our chosen business partners and suppliers to maintain similarly high standards of ethical conduct.

Whistle-blowing Policy

These guidelines sets out the method by which individuals can report concerns about potentially
dangerous, illegal or unethical practices in the workplace, this is not limited to only company
personnel, but also to any subcontractor or contractor that the company has contact with. It is
not intended to cover standard management procedure and should not be considered as a
method of undermining the normal chain of command that forms the company structure. This
policy is for guidance only and does not form part of the company contracts for employment.

You can submit a grievance through an online form.

Jurisdictive Framework

Whistleblowing is the disclosure of information by an employee or a worker who is directly or
indirectly involved with the company, which related to some danger, fraud, bribery or any other
illegal or unethical conduct in the workplace or with regards to company work. The Iraq Labor
Code, the civil service law of 2008 governs the making of disclosures concerning workplace
activities and is intended to protect and reward employees who “blow the whistle” on bad
practice form being subjected to any detriment of unfairly dismissed as a result of their actions
and reporting.

Who is Responsible for the Implementation of the Policy?

The Gulf Shield CEO has the overall responsibility for the company’s policy on whistleblowing, but
delegated the day-to-day responsibility for the oversight and implementation to the Country
Manager or the Whistleblowing Officer (see paragraph 5.1). Responsibility for change within the
organization resulting form investigations into complaints under the policy lies with the CEO, CM
and MD.
The company managers have a specific responsibility to facilitate the operation of this policy and
to ensure that staff feels able to raise concerns without the fear of reprisals in accordance with the
procedures that are laid out below. To facilitate the process, managers will be given training on
the relevant legal and operational framework and best practice.

All of our company staff are responsible for the success of the policy and should always ensure
that they take the steps to disclose any wrongdoing or any malpractice of which the see of
become made aware. If you have any questions on the content or the application of the policy,
you should request clarification from your line manager, or request a training lesson from the
DWO

Whom does the policy cover and who is affected?

The company policy is applicable to all staff, individuals who are employed by the company across
all levels. It applies to any subcontractor who is contracted directly or indirectly. If you have a
complaint relating to your personal circumstances in the work place then you should use the
company policy on grievance.
Reasons or concerns for the use of the policy is laid out below:

  • A individual has failed or is failing or they are likely to comply with their legal obligations.
  • A miscarriage of justice has occurred or is occurring or is likely to occur.
  • A criminal offence has been committed or is being committed or is likely to be committed.
  • The environment has been or is likely to be affected.
  • The person or persons are likely or have deliberately concealed any of the above.

Within the context of our company’s business there is some concerns that fall within the terms of
the policy which could include as an example a breach in the company code of conduct,
confidentially or unsafe or misguided information. If a case such as the above is found, then the
individual may use the boundaries and the procedures set forth in this policy.
If the reporting individual is unsure on the offence committed, or they are uncertain whether the
concern falls within in the guidelines of the policy, or unsure if a law or company policy has been
broken, then the company encourages the individual to use the scope of the policy and report
their concerns to the DWO in accordance with the procedures laid out in the policy.

How are disclosures made?

The company understands and recognizes that individuals may not feel comfortable with reporting
or discussing matters related to breaches of the policy directly to their line managers, the line
mangers are the first point of contact on these matters, however if the individual is uncomfortable
they can go direct to the DWO. If the disclosure any way involves your direct line manager or the
DWO you can report directly to the CEO.
As a company and inline with the company policy we will also investigate all reports of malpractice
quickly and fairly. The results will be made clear and disrupted as required, however is the results
are not satisfactory then you can request by writing to the CEO directly who will respond as
required.
The policy is designed and implemented as an internal chain of reporting, investigating and
remedying any wrongdoing in the company’s workplace. It is not designed to prevent or
discourage individuals who feel that the reporting should be made to an outside agency or
department of an agency.

How can you make a disclosure?

If you wish to raise a concern with the DWO you can do it in the following ways:
 Via email to bdm@gulfshield.com stating the policy name, within this email you must
state the concern with the details of who the concern is relevant to. You must inform the
DWO if you wish your identity to remain confidential. You will be asked to make your
concern in writing and you will be given the DWO’s Performa to formalize your concern.
The DWO will then investigate the concern and report his findings to the CEO.
 A face to face meeting can be arranged with the DWO where you can verbally raise your
concerns to the DWO, the same procedure as above will then be implemented.
 In writing delivered to the DWO at the company address.

 

The company understands that the disclosures made under the governance of the policy may be confidential and the matters may be sensitive to their nature, individuals may remain or may inform of these concerns anonymous, however the individuals must understand that on many concerns the DWO may require more information to conduct a full investigation of the concern raised. If anonymous concerns are raised and more investigations are required then the DWO may have to halt the proceedings and file the investigation as inconclusive.

Investigations Into Concerns Raised

Gulf Shield is committed to the fulfillment of the full investigation process with regards to the
disclosures made. In most cases that are presented to the Company, the DWO will follow the
below procedure:
 Initial assessment of the disclosure to establish if the information that has been presented
to him are within the boundaries laid out of the policy. He will also look to see if there is
the information or the grounds for a detailed investigation to take place.
 If an in depth or longer investigation is required, the DWO has the right to appoint an
investigator or an investigating team. These may be subject matter experts in the field of
the disclosure. All findings form the SME Team will be reviewed by the CEO, MD and the
CM.
 Once a disclosure has been made there is no requirement for the investigation team or
DWO to inform you on the status until it is completed. Once a full investigation and report
has been complied it will be disrupted as required.
 We as a company recognize that there may be matter that cannot be dealt with internally
and in respect of authorities will be notified and become involved as some junction of the
investigation. This may take place without referral or informing of the individual who made
the disclosure.

Safeguard and Support for the Individual(s) Whistle-blowers

As a company, we will ensure that no person(s) who lodge a complaint or raises a concern using
this policy in good faith will be dismissed or subjected to any detriment as a result of such actions.
This is to include unwarranted disciplinary action and or victimization, if the person(s) feel they are
subjected to any of the afore mentioned they shall raise this back to the line manager or to the
DWO. The individuals choosing to make a disclosure without following the procedure or disclosure
anonymously may not receive the protection that is outlined in the policy.
If the compliant is made in bad faith or in a malicious attempt to discredit an individual(s) or in an
attempt to gain personal gain by the individual (s) complaining, the whistle blower (s) will then fall
subject to the company’s discipline procedure.

Corrective Action and Compliance

As part of the investigation process and the investigation outcome made under the rules of the
policy, recommendations for change will invited form the investigating person (s) to enable the
company to minimize the risk of a recurrence of any malpractice or event that has been uncovered
during the investigation. The CEO will be responsible for reviewing and implementing the
recommendations that are made, and for any future reporting on any changes required will be
directed back to the CEO.

Review of the Policy

This policy reflects of the Laws governing the company as at November 2015. The company, DWO
and the CEO will be responsible for reviewing and updating the policy from a legislative and
operational point of view at least annually, or if the policy is deemed to failed during it
implementation from a complaint.

You can submit a grievance through an online form.

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