Code of Conduct Policy
PRIMARY PRINCIPLEThis document sets out LandMark Security’s (LMS) Code of Conduct and states our enduring commitment to the highest ethical standards combined with strict adherence to national and international law. Although this is not a legally binding document it explains the principles and ethical standards that apply to our staff. LMS expects every employee, contractor, agent or any other person or company acting for or on our behalf to comply with this Code and in so doing, act with honesty and integrity whilst exercising good judgment.
GENERALLMS is a Ghana private security company that supports complex offshore, maritime and land-based projects to the highest industry standards. As a specialist security provider for offshore oil and gas exploration and production, we ensure that technical and logistical considerations are complimented by safety and physical security at all times.
ENVIRONMENTS AND CONTEXTWe have carefully considered all internal and external environmental factors. These include: international and national legal and regulatory requirements (e.g. licensing and export/import control); the political, natural and physical environments; the role, perceptions and risk tolerance of our clients and other interested parties; as well as key international developments and trends in home state, flag and coastal states and other areas of operation.
PERFORMANCES AND IMPROVEMENTAs a company we ‘strive for excellence’ and have an enduring commitment to continual improvement. We are passionate about delivering a service and performance that exceeds the expectations of our clients. We seek new opportunities and innovative solutions to overcome challenges efficiently and excel in our field.
STANDARDS AND QUALITY ASSURANCEWe pride ourselves on the quality of our services and the professionalism of our personnel. We maintain this quality through a robust audit and review programme as well as client feedback that covers the aims, activities, outcomes and the cost-effectiveness of every project. We encourage review meetings and provide regular progress reports. LMS’s Management System is currently been independently audited and accredited by MSS Global to ANSI/ASIS PCS.1-2012, ISO 18788:2015 and ISO9001: 2015 Quality Management Standard, Specification for private security operations management systems.
CULTURE, ETHICS AND RESPECTLMS conducts services honestly and honourably, and we expect our clients and suppliers to do the same. Our advice, assistance and the methods imparted through our training and service delivery, take proper account of ethical considerations, together with the protection and enhancement of the moral position of our clients and suppliers. As an international operator, our contractors and employees will consider, in the execution of their duties, local laws, customs and culture. We will ensure that our services and conduct is delivered within legal boundaries and company policy whilst respecting local customs.
CORPORATE SOCIAL INVESTMENTS (CSI)LMS acknowledges our corporate social responsibilities. Our business approach is not only to complete our mission and that of our clients but also to manage our business in a way that has a positive impact on the societies and communities in which we operate. As part of this commitment we implement successful local content programs as part of our operational activities; these programmes draw support from the indigenous workforce and contribute to the local economy.
CONFIDENTIALITYLMS is committed to providing a discreet and professional service. This includes the protection of all confidential information, both in terms of commercially sensitive data and personal information. We understand our responsibilities under the Data Protection Act 1998 and adhere to the Data Protection Principles (www.ico.org.uk). We will not disclose any sensitive or confidential information outside of the company nor will we use this information inappropriately. Employees must not discuss or disclose any confidential information in public where this can be seen or overheard by others. Confidential information must be stored in a safe and secure location.
FINANCIAL ACCURACYAll financial transactions must be conducted correctly and honestly. Employees must obtain adequate approval from personnel with the correct level of financial authorization. Employees must not intentionally do anything, which may be dishonest, misleading or incorrect. All transactions must be recorded accurately and promptly and held for audit purposes.
COUNTERPARTY DUE DILIGENCELMS will identify counterparties for every project and satisfy appropriate levels of due diligence prior to any business relationship. In so doing, we will endeavor to confirm the true nature, trading history and identity of any business entity. As part of this process LMS will actively encourage all parties to comply with this Code and any other appropriate policies and procedures.
CONFLICT OF INTERESTEmployees must not engage in any activity which conflicts or competes with the interests of LMS or in any way damage the company’s reputation or integrity. Employees must not exploit their position or influence, or misuse any LMS asset including confidential information, for their own personal gain or benefit or that of an unauthorized third party. This also precludes any unfair bias or favoritism during the recruitment of personnel or any other business activity. Any potential conflict of interest must be reported to senior management.
LEGAL AND REGULATORY COMPLIANCELMS and its employees comply with all national, international and flag state laws, which include legislation on trade, export controls and financial and political sanctions. We ensure that all of our activities are carried out lawfully and comply with the terms and conditions of our export control licenses and any imposed international restrictions. We operate within strict guidelines, which include Rules on the Use of Force when employing armed guards. We maintain global oversight of our legal responsibilities through government and local engagement and membership of regulatory industry bodies.
INTERNATIONAL CODE OF CONDUCTOur company is founder member, and a signatory of the International Code of Conduct for Private Security Service Providers and has therefore agreed to operate in compliance with the Code’s principles and standards. We strive to ensure our staff; services, policies and procedures reflect these principles and values http://www.icoc-psp.org/.
HUMAN RIGHTSLMS conforms to the rule of law, and acknowledges our corporate responsibility to respect human rights. We believe that all businesses and organizations, including ourselves, should avoid causing any adverse effect on human rights. This is reinforced by our commitment to ICOC and the Voluntary Principles on Security and Human Rights (http://www.voluntaryprinciples.org/). LMS also endorse the principles of The Montreux Document on private military and security companies (http://www.eda.admin.ch/psc) and the United Nations Guiding Principles on Business and Human Rights and their “Respect, Protect, Remedy” framework (http://www.businesshumanrights.org/SpecialRepPortal/Home/Protect-Respect-Remedy-Framework). All LMS personnel are trained to recognize and report any abuses of Human Rights.
EQUALITY AND DISCRIMINATIONLMS aims to treat all our people fairly and with respect, and to comply with applicable employment laws. Issues of gender, race, religion, colour, age, personal disability or sexual orientation must never influence our decisions or actions. All employment decisions will be made on qualifications and competency compared to clearly stated job specifications. LMS will not tolerate any form of harassment or abuse; employees or co-workers should report any harassment or discriminatory behaviour to senior management or a Human Resources representative.
CRIMELMS will not contract with, support or service any government, person, or entity in a manner that would be contrary to International Law or United Nations Security Council sanctions. Further to this we will not, and require that our personnel do not, participate in, encourage, or seek to benefit from any national or international crimes including but not limited to war crimes, crimes against humanity, genocide, torture, enforced disappearance, forced or compulsory labour, hostage-taking, sexual or gender-based violence, human trafficking, the trafficking of weapons or drugs, child labour or extrajudicial, summary or arbitrary executions.
BRIBERY AND CORRUPTIONLandMark adheres to all Bribery laws and other international acts (example – UK Bribery Act 2010) and acknowledges other international legislation including the US Foreign Corrupt Practices Act 1977. We are committed to openness and honesty, and oppose financial crime of any kind. Personnel must not, promise, offer or give to any person or public official, directly or indirectly, anything of value for the public official them self or another person or entity, in order for that person to act or refrain from acting in the exercise of his or her official duties if such inducement is illegal. This includes the prohibition of facilitation or “grease” payments. Further to this LMS does not directly or indirectly make political contributions or donations. Personnel found to have involvement with any such corruption will face disciplinary action and will be reported to the appropriate authorities. LMS has a detailed Anti-Bribery Policy, which all parties should refer to in connection with your specific anti-bribery obligations.
BUSINESS GIFTS AND HOSPITALITYEmployees must not offer or accept any inappropriate or valuable personal gifts, hospitality or services from any person or business entity. The receipt or provision of any appropriate or authorized gift or hospitality must be reported and recorded. Any inappropriate offer or request for gifts or hospitality must be reported to senior management. Again, please refer to our Anti-Bribery Policy for further details.
HEALTH AND SAFETYWe place the highest priority on the health and safety of our employees, contractors and other third parties. We have implemented a variety of measures including our Health and Safety Policy and a safe system of work to ensure a safe working environment. We recognize the inherent dangers and limitations presented by the complex environments in which we operate and ensure that reasonable precautions are taken. All personnel are to be aware of this policy and relevant risk assessments, they must use all the protective equipment supplied and follow LMS procedures and training guidelines. All personnel are actively encouraged to report any health and safety risks or near miss situations. Our policies and processes are compliant with OHSAS 18001:2007 Occupational Health & Safety Management Standard.
DRUGS AND ALCOHOLWe operate a zero tolerance policy towards drugs and alcohol, which means that any person found to be under the influence of illegal drugs or alcohol whilst on duty will have their contract terminated with immediate effect. The LMS Drug and Alcohol Policy clearly states that employees or contractors are not permitted to consume alcohol or illegal drugs immediately prior to or during any operational activity. Furthermore they are not permitted to have any alcohol or non-prescription drugs in their possession whilst embarked on any vessel. We aim to ensure that the use of alcohol or drugs does not in any way compromise the safety and efficiency of our services; LMS conduct scheduled and random drug and alcohol testing to ensure compliance.
REPORTING OBLIGATIONSStaffs are required to report, known or reasonable suspicion of the commission of any of the acts identified in this document or signatory documents to senior management. In turn senior management are required to investigate the issue and report this to the appropriate authority if necessary; this may include one or more of the following: the Client, the Competent Authorities in the country where the act took place, the country of nationality of the victim, or the country of nationality of the perpetrator.
COMPLAINTS AND GRIEVANCESLMS has an established complaints and grievance procedure to address any issues or allegations raised. LMS will:
- Welcome any report or allegation of improper and/or illegal conduct, including such acts or omissions that would violate the principles contained in this Code. Procedures will be fair, transparent and offer effective remedies, including recommendations for the prevention of recurrence.
- Investigate allegations promptly, impartially and with due consideration to confidentiality;
- Keep records about any such allegations, findings or disciplinary measures. Except where
- prohibited or protected by applicable law, such records should be made available to a Competent Authority on request;
- Cooperate with official investigations, and not participate in or tolerate from their personnel, the impeding of witnesses, testimony or investigations;
- Take appropriate disciplinary action, which could include termination of employment in case of a finding of such violations or unlawful behaviour; and ensure that their Personnel who report wrongdoings in good faith are provided protection against any retaliation for making such reports, such as shielding them from unwarranted or otherwise inappropriate disciplinary measures, and that matters raised are examined and acted upon without undue delay.