Context of the Human Rights Policies of Centurion Security

Centurion Security is committed to operating in a manner that recognizes and supports the Rule of Law, as well as respect for Human Rights and the protection of clients' interests.

The entity is fully committed to fulfilling its responsibilities regarding Human Rights by adhering to the Political Constitution of the Republic of Guatemala and applying the United Nations Guiding Principles on Business and Human Rights (2011) in the entity's operations.

The Guiding Principles have achieved broad international consensus as a baseline for all companies regarding the observance of Human Rights, and they are affirmed in four fundamental instruments:

The Universal Declaration of Human Rights (1948).

The International Covenant on Civil and Political Rights (1966).

The International Covenant on Economic, Social, and Cultural Rights (1966).

The International Labour Organization Declaration on Fundamental Principles and Rights at Work (1998).

That is why Centurion Security acknowledges and considers the Voluntary Principles on Security and Human Rights, adopted in 2000 by the governments of the United Kingdom, the United States, extractive companies, and some non-governmental organizations (ONG).

The entity Centurion Security is also a part of the International Code of Conduct Association (ICOCA), under which the member companies recognize and commit to respecting Human Rights and fulfilling humanitarian responsibilities within their internal policies and business activities, including personnel, clients, suppliers, shareholders, and the local population in the area where services are provided.

This Human Rights Policy of Centurion Security expresses the commitment to respect Human Rights and embodies the understanding and particular importance that such universal standards have for a large-scale security company and its diverse operations in a country where Human Rights are often disrespected. Therefore, the entity establishes expectations of conduct and compliance throughout its organizational structure and departments, employees, and individuals with whom it does business.

The detailed guidelines for staff on how to implement this policy in all personal and labor negotiations are outlined in the internal document "Guidance on Management," which establishes: Human Rights Guidelines of Centurion Security. Together with the internal policy and Human Rights guidelines, they constitute the guiding principles of Centurion Security regarding its employees.

A strategic approach to Human Rights:

The strategic approach of the entity allows us to respect Human Rights and their application in various areas, as the main foundation is respect for human life.

This recognizes the impact of the entity's purpose regarding security, potentially acknowledging the positive operations and compliance with such protocols for operations within its environment. In this context, the ability to maintain conduct aligned with the guiding principles of Human Rights is put to the test.

Human Rights and Security: Sensitive Issues in Guatemala:

In addition to its recognition within the international framework on Human Rights and its voluntary adherence to international instruments relating to corporate responsibility in this area, particularly those concerning private security service providers, Centurion Security understands that it must have an explicit Human Rights policy due to the historical and current sensitivity of these issues in Guatemala.

Indeed, throughout its republican and independent history in the 19th and 20th centuries, the Guatemalan State was characterized by its weak commitment to upholding the fundamental rights of the population, despite these rights being declared in its numerous constitutional texts. This situation worsened during the years of the 36-year internal armed conflict, officially concluded in 1996 with the signing of the peace accords. The same United Nations -UN-, through specialized agencies, documented the nature and magnitude of the massive violations of Human Rights during the war, within which a culture of disrespect for the law, impunity, and denial of fundamental rights took root, reaffirmed by the Political Constitution of the Republic of Guatemala, enacted in 1985 and currently in effect.

Neither the Political Constitution nor the Peace Accords of 1996 could, in themselves, be sufficient to eradicate the culture of violence, impunity, and disrespect for Human Rights. Many of the historical, economic, and social causes that originated or worsened during the armed conflict persisted after 1996, and this was compounded by the difficult process of Guatemala's integration into globalization. As a result, new economic, social, and cultural phenomena emerged that largely explain why the promise of tranquility implicit in the Peace Accords remained unfulfilled.

In the years following the signing of the Peace Accords, the capacity of the State and the corresponding public institutions to guarantee the enforcement of fundamental rights related to security, justice, life, and the integrity of individuals, as well as the preservation of their property and other related constitutional rights, notably deteriorated.

Guatemala has one of the highest homicide rates in the world, and official statistics on attacks against property and assets far exceed those of violent deaths. According to estimates from the National Problems Institute of the University of San Carlos, in 2014 the homicide rate was 35.67 cases per 100,000 inhabitants, while crimes against property reached 734.8 per 100,000 inhabitants.

Deducting from the above, the business environment for Centurion Security is complicated: there is a high historical sensitivity regarding the non-observance of Human Rights (in which there are many pending issues, such as discrimination based on ethnic or linguistic reasons, social conflict due to mining activities, and disputes over water resources, among other examples), while at the same time, an atmosphere of insecurity, violence, and disrespect for the law prevails.

Risk assessment and implementation:

Centurión Security recognizes that it can play a positive role in the promotion of Human Rights within its various areas of work. The company can positively contribute to the respect and observance of Human Rights through the range of services offered to protect individuals and property, creating a security environment that allows them to enjoy their constitutional rights.

At the same time, the entity acknowledges that it has the duty to guarantee the rule of law within the services provided to the clients it works with, as well as the suppliers it hires, ensuring fair and appropriate treatment of employees.

Education and implementation:

How can a security company operating in a country where Human Rights have been systematically violated by the State in the past and are currently often overlooked and disrespected, due to a widespread culture of lawlessness, impunity, and corruption? Therefore, Centurion Security, aware of this historical situation prevailing in Guatemala, aims to educate and promote compliance with the country's legal standards among its employees, with an emphasis on recognizing and respecting the rights and dignity of individuals through feedback exercises and training sessions.

Training and education will help those working for the company to consciously understand and respect the rights to life, physical and moral integrity, freedom, security, due process, privacy, property, inviolability of the home, free movement, freedom of expression, freedom of association, and peaceful assembly, as well as international standards regarding the use of force and International Humanitarian Law.

It is understood that continuous feedback and training are important for working towards the respect of Human Rights. As a security entity, there is a recognition of the need to focus especially on those rights related to the protection of individuals and their property.

The International Code of Conduct for Private Security Service Providers and the Voluntary Principles on Security and Human Rights are fundamental standards for Centurion Security, which have been implemented in business-related areas, following the guiding principles of the United Nations.

The entity commits to operate in accordance with the guiding principles on "Business and Human Rights", adopted in 2011 under the framework of the UN, through which corporate responsibility regarding Human Rights is defined, particularly to ensure access to effective mechanisms for individuals who have suffered violations of their rights due to the activities conducted by businesses.

Specifically, we embrace the principles summarized in the formula of "protect, respect, and remedy", according to which:

• It is the responsibility of the State to protect and guarantee the full enjoyment of human rights.
• Companies are obligated to respect human rights.
• Companies must seek the best ways to repair or restore the rights of individuals when, due to any business activity, such rights have been violated or undermined.

The application of the Guiding Principles in Centurion Security's policy entails the recognition that business activities can, eventually and under certain circumstances, pose risks to the security of individuals or communities, as well as to the enjoyment of human rights. Acknowledging this possibility gives meaning to the triad "protect, respect, and remedy."

Diligent integration of Human Rights:

In line with the aforementioned guiding principles of the United Nations -UN-, Human Rights will be made an essential and integral part of the entity's activities, services, and business. This commitment will begin with rigorous hiring practices, including comprehensive background checks to verify that no Centurion Security employee has been involved in human rights abuses during or after the Guatemalan civil war.

Actions will be taken while respecting intervention protocols and due process, in order to avoid any violations of Human Rights, as well as to provide appropriate and effective responses, including reparations in accordance with the provisions established by law and in prevention.

Centurion Security commits to including, in the diagnostic studies for the provision of security services, assessments related to the history of compliance with or violations of Human Rights by the actors present in the area, municipality, department, or region, as well as regarding social conflict.

These diagnostic studies will include, at a minimum: a) Identification of security risks; b) Assessment of potential violence; c) Records related to Human Rights; d) Evaluation of the state of law compliance; e) Conflict analysis.

Management and responsibility for human rights at Centurion Security:

Immediate responsibility for ensuring respect for Human Rights is assumed, a commitment that falls on all personnel at Centurion Security. Members must be familiar with the entity's Human Rights policies and guidelines. They should be able to demonstrate, through their daily conduct, how they avoid the risks of committing abuses against Human Rights.

The management of Centurion Security will actively ensure corporate accountability in complying with this policy and its related guidelines.

Decalogue of Centurion Security and its personnel to protect and uphold Human Rights.

1. - Centurion Security is a business entity committed at all times to the effective compliance with the Political Constitution of the Republic of Guatemala and its laws.
2. - Centurion Security and those of us who work for this company are committed to respecting and preventing the violation of human rights as an essential part of our work in providing security services.
3. - The workers, employees, and executives of Centurion Security are committed to maintaining respectful relationships with our coworkers, subordinates, and superiors regarding their dignity and Human Rights.
4. - The workers, employees, and executives of Centurion Security declare under oath that we have not committed violations of human rights, and that we have not belonged to or are part of organizations or institutions that, in the past or present, have been accused of committing or have committed violations of Human Rights.
5. - The workers, employees, and executives of Centurion Security understand and accept that if, in fulfilling our responsibilities as part of the company, we engage in conduct that violates the dignity of individuals, in acts of discrimination or violations of Human Rights, such behavior is grounds for dismissal, provided that due process is observed to determine our culpability in such misconduct.
6. - The workers, employees, and executives of Centurion Security are committed to clarifying and addressing, before the competent authorities of the company, any substantiated complaints against us regarding conduct that violates the dignity of individuals, acts of discrimination, or violations of Human Rights.
7. - The management and administration within Centurion Security are fully committed to respecting and ensuring the respect of legally established labor rights.
8. - In providing its security services to individuals, communities, businesses, or institutions, Centurion Security will focus on anticipation and prevention. Its uniformed agents will act proactively and constructively to dialogue and resolve potential conflicts; they will never resort to the use of force or self-defense equipment, nor will they intervene in matters that are the exclusive responsibility of public security institutions.
9. - Centurion Security will not provide its services to any person, organization, company, or institution that is flagrantly involved in or complicit with violations of Human Rights.
10. - Centurion Security commits to maintaining constructive contacts and relationships with communities, civil society organizations, and institutions that defend Human Rights, to exchange information, share best practice experiences, and any other useful knowledge to fulfill its commitment to respect and contribute to the observance of Human Rights.

14th of june 2024

Centurion Security Statement of Conformance

Centurion Security is a private security company (PSC) based in Guatemala, Central America and provides armed and unarmed security services in complex and sometimes hostile environments. Centurion Security works with its clients to provide these services in a way that protects all of their assets. Our clients, all government agencies, local communities where we operate, our partners and suppliers all expect Centurion Security to operate responsibly and in conformance with the law at an international and national level, as well as adhering to the associated international guidelines on human rights.

Centurion Security‘s Code of Conduct and Business Ethics outlines our commitment to best ethical practices including our commitment to respecting human rights and always seeking to provide conflict sensitive services that seek to develop and maintain a social license to operate.

All private security operations in complex environments carry an elevated risk of encountering human rights issues, Centurion Security is based and operates in a country with a terrible history on human rights violations, and to this day there are still accusations against government agencies and private security companies (PSC's) for violating human rights. Centurion Security seeks to mitigate this risk as effectively as possible by ensuring that the principles outlined within the Centurion Security Code of Conduct and Business Ethics and our internal policy on Human Rights are strictly adhered to and that all personnel are aware of these commitments and understand their absolute importance.

Centurion Security respects all people. This includes our personnel, our clients, the local communities within which we operate and local governments and associations. This is demonstrated in a robust commitment to the UN guiding Principles on Business and Human Rights, the Principles of the UN Global Compact, the International Code of Conduct for Private Security Providers (ICoCA) (of which Centurion Security is a certified member), the Montreux Document and all applicable local, national and international laws and guidelines. Seeking to recognise and mitigate risks throughout our operations.

Our statement of conformance is coupled with our compliance and application for certification for PSC1, ISO18788 and ISO 9001 as part of our on-going commitment to best practice.

Peter Snell
Executive Director

General Overview



1. With the ongoing rise in the need for reliable and professional security services the spotlight has been on Private Security Companies (PSCs) to ensure they behave in a professional manner and in line with international and national (host country) laws and therefore should set themselves their own high standard of ethics, conduct and procedures in how they go about their business. These are set out in this document in compliance with the International Code of Conduct and as part of our commitment to gaining certification in PSC-1, ISO 18778 and ISO 9001 as the recognized standards for best practice within the security industry. Centurion Security is committed to the highest standards of social and business practices.


2. Adherence to this code of conduct constitutes an assurance of the operating standards, professionalism and quality for:
   • Clients
   • Employees (including subcontractors)
   • Competitors
   • International organisations
   • Governments and their agencies
   • Individuals
   • Communities
   All of whom Centurion Security comes into contact during the course of its business.


3. This is a "living" document and will be responsive to changes in the law, international environment and public opinion and will be reviewed at minimum, annually.


4. This code covers the following areas:
   • General principles
   • Law and regulation
   • Selection, training and vetting of personnel
   • Behavioural standards, fair business dealing and quality assurance
   • Rules for the use of force
   • Relations with others in the field of operations (local population, governments, PSCs)
   • Working standards
   • Equal opportunities
   • Security sector reform
   • Relations with clients
   • Transparency
   • Oversight and compliance



General Principles



5. Centurion Security will only engage in legitimate security work that adheres to the principles of International Law, including International Humanitarian and Human Rights Law.


6. Centurion Security will always work to mitigate risk to their clients and will only work for clients who are committed to the working within the standards of national (local) and international law. Centurion Security will respect the rights of the local government and will not accept an assignment that seeks to destabilize a country or community.


7. Centurion Security does not condone, nor will it ever become involved in the violation of human rights.


8. A due diligence is carried out on each potential client and any work provided is done so under a legal contract to ensure compliance with the principles and the detail of this Code of Conduct.



Law & Regulation



9. In the absence of international or national regulation of PSCs, Centurion Security is bound by the following:
   • National Law
   • European Law
   • International Law
   • Host Nation Law and regulation
   • The Law of Armed Conflict
   • Contractual obligations and constraints
   • Such special regulation orders and law which may apply to a particular geographical area of operations at any one time (e.g. USFI regulations in Iraq).


10. Centurion Security will adhere to all applicable law and regulation. Centurion Security personnel are required to report in full on any incident in which they are involved, or which they witness which might involve an unlawful act. Centurion Security will investigate fully any such report, or complaints from third parties, to the extent that the operational environment permits.


11. Morally and ethically, Centurion Security supports the development of PSC regulation internationally, and is committed to work under the regulations of the International Code of Conduct Association.



Selection, Training and Vetting



12. All Centurion Security personnel are selected in as thorough a way as possible.


13. Centurion Security will carry out a thorough check of each individual security provider application to include:
    • Study of CV and cross-referencing
    • Confirming with references
    • Checking of military and other professional records including discharge certificates and if ex-military, where applicable, confirmation of any involvement during the Guatemalan civil war and with which unit
    • Background and criminal record checks
    • Government vetting agencies (where appropriate)
    • Interview process and where applicable, any written evaluations


14. Once selected each individual will then be required to pass a 10 day internal training course which they are then externally examined by DIGESSP1 (Direccion General de Sevicios de Seguridad Privada). This will involve:
    • Written exam
    • Psychological assessment


15. Once accepted, security providers will then undergo task specific training. Continuation training will be carried out periodically throughout the year. The purpose of the training is both to ensure professional competence and efficiency and also to develop skill and maturity to avoid overreaction and other traits that may lead to unnecessary incidents. All training includes instruction in local Law, Humanitarian Law and the Law of Armed Conflict, Rules for the Use of Force and Conflict Management.



Behavioral Standards



16. The overall behavioral standard expected of Centurion Security personnel is set down clearly and is monitored in considerable detail.


17. These standards are set with the requirement to always comply with relevant laws and engage in fair business dealings and include:
    • Professional and technical competence
    • Restraint and maturity
    • Honesty and integrity including professional ethics with regard to financial irregularities, inducements, incentives etc.
    • Compassion, respect and dignity
    • Discretion and confidentiality
    • Full understanding of requirements and constraints of their current mission
    • Social and environmental responsibility
    • Cultural sensitivity
    __________________________
    1 DIGESSP is the government department responsible for the oversight of PSCs in Guatemala


18. Ensuring these standards are met is the task of the Centurion Security management structure and chain of command at all levels. A formal disciplinary procedure exists to deal with any deviation from the standards laid down and overall responsibility lies with the Board of Executives.


19. Centurion Security will provide detailed training to ensure personnel understand the standards expected of them, such training will include without limitation specifics with regard to anti-corruption, non-bribery and human rights.



Quality Assurance



20. The quality assurance ethos is fundamental to Centurion Security‘s operations. All personnel are encouraged to conform to the Centurion Security Quality Assurance Programme, to comment on it and participate in the process to continually improve Centurion Security‘s perceived and actual performance as part of Centurion Security‘ Quality Management System (Centurion Security QAMS). The QAMS ensures that reviews of all work in progress are carried out independently from the original source during operations/production.



Corporate Social Responsibility (CSR)



21. Centurion Security has a very active corporate social responsibility program and is involved with numerous local charities and often works in support of a local Rotary Club (Club Rotario, Guatemala Sur). The main benefactor of Centurion Security‘s charitable support is to the foundation "San Jerónimo Emilliani" who provides shelter, health and education to children and teenagers with physical and mental disabilities in order to try give them a healthy and stable life. The foundation survives on donations and for this reason we decided to help by giving them the support that they need. In addition to working with local charities Centurion Security has identified a need for emergency support In the event of natural disasters given that Guatemala is ranked within the top ten most vulnerable countries in the world to climate change and therefore natural disasters. Centurion Security has therefore developed a crisis support plan in the event of any natural disaster which may occur, the plan consists of 3 interrelated teams that mutually support each other;
    1. OPERATIONAL VOLUNTEERS: Operational volunteers consist of volunteers (Centurion Employees) who have received operational training and briefings on dealing with natural disasters in order to save life. The volunteers work in three teams of four people and are able to deploy on short notice to support the authorities in the event of a natural disaster. The teams is fully equipped with rescue and first aid equipment so we are able to assist in search and rescue, or support with providing access control to and from the incident site assisting with the site security.
    2. VOLUNTEERS OF COLLECTION CENTER AND SUPPORT. These volunteers are made up from the management team within the company, as well as colleagues and friends. They are responsible for setting up collection points for the collection of clothes, food, blankets and medicines. They then ensure the distribution of these items to the centres that distribute directly to the people in need.


22. As Guatemala has a terrible history of Human Rights violations, and to this day there are accusations regularly raised against the business development sector and other organisations for violations of Human Rights, Centurion Security takes a strong and dedicated interest in the communities in which we operate, as we ensure any projects are carried out in a socially responsible way. Additionally Centurion Security personnel carry out an assessment of the potential human rights impact of its own projects and activities so as to mitigate such potential impacts, as well as rigorously opposing violation of human rights from whatever source.



Rules for the Use of Force (RUF)



23. As a PSC, Centurion Security‘s services are often armed protective services in quite oftenhigh risk and potentially violent environments that necessitate the carriage of firearms. When Centurion Security personnel are armed, they carry arms for personal protection, or the protection of those in their care.


24. All weapons and ammunition are procured legally and are transported and stored in a secure manner as per the legal requirements of DIGECAM2 (Dirección General de Control de Armas y Municiones), also carriage of all firearms is done so by accredited security agents who carry the correct, in date documentation as required by both DIGECAM and DIGESSP.


25. When weapons are carried, all Centurion Security personnel will comply with the appropriate Rules for the Use of Force ("RUF"). Centurion Security will use minimum force at all times.


26. All personnel will be extensively briefed on RUF, and the principles of minimum force instilled in them. Centurion Security‘s personnel are experienced and trained in the use of firearms. Continuous training takes place with an emphasis on safety, accuracy and restraint.


27. Where Centurion Security personnel resort to the use of firearms, and regardless of whether this results in injury or death, the individual(s) will make a full report on the incident in accordance with the established reporting procedures. An internal investigation by Centurion Security in accordance with established procedures will be carried out.


28. Where injury or death results from the use of force or firearms, Centurion Security will undertake a full internal investigation in accordance with established procedures and will openly cooperate with any lawful investigation undertaken by the governing authorities in the area of operation.

__________________________
2 DIGECAM is the government department that controls the licensing and carriage of fireams


Relations with others in the Area of Operations



29. Centurion Security promotes constructive engagement and cooperation with other organisations operating in the same area of operations.


30. Centurion Security personnel respect the culture, religion and ethnic customs, human dignity and human rights of the communities and countries in which they work. They will to the best of their ability and wherever possible, rigorously oppose violation of these rights.



Working Standards



31. Good working standards are crucial in the development of Centurion Security and the potential of its personnel. By paying our employee‘s as stipulated by local law, including their legally payable benefits Centurion Security is able to reduce the risks of staff turnover and through continuity of service quality ensure a higher level of efficiency.


32. Centurion Security is committed to ensuring the best working conditions that the area of operation will permit.


33. In accordance with this principle, the level of remuneration is designed to ensure that quality work is appropriately remunerated which in turn encourages loyalty and continuity.


34. There are many different occupational hazards associated with the nature of the work engaged in by Centurion Security. Appropriate medical support including psychological assessment is provided to ensure the maximum possible attention in the event of serious incidents and subsequent injuries to personnel.


35. 35. In line with these procedures Centurion Security follows best practise by ensuring suitable insurance as required by local law is always in place to cover medical issues, assets and business risk.



Equal Opportunities



36. Centurion Security recognises its responsibility for promoting equal opportunities and combating discrimination.


37. It seeks to ensure the full integration of all personnel in his or her working environment, regardless of his or her ethnic or social origin, colour, gender, religion, nationality, sexual orientation or other distinguishing characteristics.


38. It seeks to ensure that its clients also recognise respect for these values in the working conditions made available to all personnel.



Client Relations



39. By the nature of Centurion Security‘s activities its personnel may obtain information which may relate to the private lives or be potentially harmful to the interests or reputation of others. Great care will be exercised in safeguarding and using such information, which shall be kept strictly confidential unless the performance of the duty or the needs of justice strictly require otherwise.


40. Centurion Security will ensure its personnel:
    • Are diligent, competent and efficient in discharging their professional responsibilities and commitments
    • Do not participate in activities which may involve a conflict of interest without appropriate disclosure and approval.



Transparency



41. Centurion Security will maintain transparency with its clients, local government agencies (such as DIGESSP and DIGECAM), and any monitoring agency such as ICoCA taking into account client confidentiality.



Oversight and Compliance



42. The oversight and management of all Centurion Security‘s operations is the responsibility of the Centurion Security Board of Executives.


43. Each project has a clearly defined and responsible chain of command. The chain of command is responsible for the day-to-day implementation of the contract.


44. The development of business and general oversight of the company is provided by the Board of Executives withy the direct support of the General Manager. The Board consists of ex British military personnel and a lawyer who provide guidance and advice to the Centurion Security local management on request or as deemed necessary.


45. The Centurion Security Board along with the General Manager has established a Quality Management Review Board for day-to-day monitoring of the Centurion Security Quality Management System. Departmental reports, Statistics, HSE and other audit reports, are used to assess the continuing relevance of Centurion Security‘ quality management system over time and to ensure continuous improvement.

Centurion Security S.A. Quality Policy

The purpose of the Quality Assurance System is to ensure that the all services provided to our Clients consistently meet or exceed their expectations. The company operates a system that regularly evaluates its processes and Client needs, and has set quantifiable objectives with plans in place to ensure that they are reviewed annually for improvement.

It is the policy of Centurion Security S.A. to maintain, on a continual basis, an effectively managed Quality Assurance System, which will assure that the services supplied conform to the procedures or disciplines of the company, and will therefore ensure that the Clients needs and expectations are fully met.

The management of the company is firmly committed to the systems, procedures and controls included in this manual, and the total participation of all personnel is mandatory.

To achieve and maintain the required level of assurance the Executive Director retains responsibility for the Quality System with the routine operation controlled by the Quality Management Representative and to ensure that all legal and regulatory requirements are met such as Health & Safety at work and the requirements established by the Dirección General de Servicios de Seguridad Privada (DIGESSP).

The company Quality Management Representative cannot be over-ruled on matters of Quality, and in case of differences of opinion on Quality related matters, then such matters should be referred to the Executive Director or his representative for resolution. This policy of Quality Assurance is in place to ensure that the overall organizational objectives of the company are met. The objectives of the Quality Assurance System are:

1. To maintain an effective Quality Assurance System complying with International Standard ISO 9001, ISO 18788 and PSC 1.
2. To ensure that the best possible security services are supplied to the companys valued clients.
3. To ensure that the company is able to meet its clients needs and requirements as effectively and efficiently as possible.
4. To achieve and maintain a level of quality which enhances the Company‘s reputation with Clients.
5. To ensure compliance with relevant statutory and safety requirements.
6. To endeavor, at all times, to maximize Client satisfaction with the services provided.

Achievement of this policy involves all staff, who are individually responsible for the quality of their work, resulting in a continually improving working environment for all. This policy is provided and explained to each employee by the General Manager or the HR Manager as applicable.