Human Rights Policy

Version 3 -  01 Oct 2023

1         Introduction

Erinys is unwavering commitment and dedication to upholding human rights throughout all facets of its operations and endeavours. Our commitment is anchored in the principles outlined in the United Nations Guiding Principles on Business and Human Rights. Erinys interprets human rights to encompass the universally acknowledged human rights as delineated in the International Bill of Human Rights, as well as the International Labour Organisation's (ILO) Declaration on Fundamental Principles and Rights at Work. Specifically, these rights encompass:

a. The Universal Declaration of Human Rights (1947)

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

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

d. The International Labour Organisation Declaration on Fundamental Rights at Work (1998)

As a provider of commercial protective security services, Erinys recognizes that the fundamental rights to life and security of person, the right to property ownership, and the right to freedom of movement serve as the cornerstone upon which our services are conceived and delivered.

The purpose of this procedure is to delineate the requisite activities aimed at ensuring the effectiveness of Erinys's document management system.

2         Policy Statement on Combating Human Trafficking

Erinys Iraq Limited firmly acknowledges the significance of the UN Guiding Principles on Business and Human Rights as the cornerstone of our commitment to combat human trafficking. Our management at all levels is bound by the guidance outlined within this framework and is entrusted with the continuous enhancement of its implementation. Erinys is resolutely dedicated to fulfilling these commitments through the integration of industry-specific codes, standards, and best practices pertaining to security and human rights.

As an original signatory to the International Code of Conduct for Private Security Providers (ICOCA) and an active member of the ICOC Association (ICOC-A) and its oversight mechanism, Erinys wholeheartedly recognizes the Montreux Document and its stipulations regarding the responsibilities of private security companies in upholding human rights. The company pledges to adhere fully to all applicable regulations and laws emanating from Contracting States, Territorial States, and Home States, as they pertain to Erinys's services.

Erinys has a longstanding commitment to support the Voluntary Principles on Security and Human Rights, with a particular focus on their relevance to the extractive industry. We have consistently applied these principles in the delivery of our services in support of our clients' operations.

Erinys's commitment to upholding human rights is deeply ingrained within our Integrated Management System, as outlined in the Statement of Conformance (Chapter 2), and through our adherence to stringent Business Ethics (Annex D to Chapter 1).

3         Scope

The scope of this Human Rights Policy encompasses all personnel affiliated with Erinys Iraq Limited. This includes, but is not limited to, full-time and part-time employees, temporary staff, contract workers, consultants, stakeholders, suppliers, subcontractors, and clients. It is imperative that every individual connected with the organization comprehends and diligently adheres to the principles delineated within this policy.

4         Standardized Terminology for Human Rights Commitment

To bolster the organization-wide commitment to the respect of human rights, Erinys will embrace a standardized lexicon aimed at facilitating effective communication and mutual comprehension. In harmonizing the diverse terminologies employed within the framework of standards and codes, Erinys establishes the following common understandings:

·         Human Rights Risks: These denote potential adverse consequences on human rights, arising from the provision of services within a specific context, which have the potential to impact the enjoyment of human rights.

·         Human Rights Impacts: This term refers to the actualization of identified human rights risks. It occurs when activities related to Erinys's services have a tangible and adverse effect on the enjoyment of human rights.

·         Human Rights Due Diligence: This concept embodies the combined application of Erinys's Human Rights Policy and the pertinent codes and standards within our Integrated Management System (IMS).

·         Remedy: Here, "remedy" signifies the process designed to prevent the ongoing or recurrent occurrence of a human rights impact. The objective is to restore the affected individual(s) to a situation comparable to their status prior to the human rights impact.

5         Holistic Approach to Human Rights

Erinys's approach to upholding human rights can be distilled into a comprehensive framework, characterized by the principles of recognition, response, improvement, and communication. This multifaceted approach encompasses the commitments and processes embedded within our framework, the Integrated Management System (IMS), and various applicable standards.

Ø  Recognition

Erinys is committed to an iterative process aimed at comprehensively understanding the contexts in which we deliver our services. This includes considerations such as geographic locations, local cultures and communities, the nature of our services, customer requirements and operations, as well as the practices of our suppliers and subcontractors. This depth of understanding enables Erinys to identify and assess potential human rights risks associated with our service delivery, customer expectations, and the operational methodologies of our suppliers and subcontractors. Periodic assessments of human rights impacts, especially in complex environments, will be conducted to ensure ongoing vigilance.

Ø  Response

In response to identified human rights risks, Erinys is dedicated to implementing mitigation measures that either eliminate, avoid, or reduce these risks to the highest extent feasible. Vigilant monitoring and evaluation of these mitigation measures will ensure their effectiveness, with comprehensive records documenting the outcomes. In essence, Erinys's response to any human rights impact resulting from our business activities is swift and thorough remediation. The following offenses are deemed gross misconduct and may result in immediate dismissal without notice, following a thorough investigation:

Ø  Improvement

Through the diligent application of our human rights due diligence processes and the IMS, Erinys is committed to continually enhancing its organizational capacity to uphold human rights. Responsibility for achieving this improvement permeates every level of management, particularly in terms of the ability to recognize human rights impacts and take corrective actions. At the corporate level, Erinys will establish a Human Rights Committee, tasked with reviewing records of human rights impacts across the organization, assessing the effectiveness of corrective actions, and proactively promoting preventative measures, all with the aim of fostering continuous improvement. This committee will operate as an adjunct to our Management Review process.

Ø  Communication

Communications concerning this policy are to be conducted internally and externally. Erinys has an established Grievance Policy which can be utilized by any employee or external stakeholders/third parties that may have a complaint/grievance concerning the Company or its staff members. This encapsulates the Recognise – Respond – Improve methodology. 

· Internal Communication

Internally, Erinys is dedicated to conveying its unwavering commitment to respecting human rights to all individuals acting on its behalf. This is achieved through the dissemination of documented policies and procedures, informative briefings, notices, and recurring training sessions for personnel. Personnel training includes a focus on their responsibilities to report any perceived human rights risks and impacts resulting from Erinys's activities. Additionally, Erinys has instituted a Whistleblower Policy that enables any employee to report human rights impacts without fear of reprisal.

·  External Communication 

Externally, Erinys will proactively communicate its commitment to upholding human rights to external stakeholders, including clients, subcontractors, and suppliers. We will engage in regular and effective communications with these external partners to gain insights into their perceptions, values, needs, and interests. Such insights will help us determine whether any human rights impacts need to be considered during the 'Recognition' phase of our process. If such impacts are identified, further communications will ensue regarding our 'Response' and 'Improvement' efforts. Comprehensive records of all external communications will be diligently maintained.

6         Duties and Reporting Obligations

Erinys's unwavering commitment to upholding human rights places a collective responsibility on all its personnel. This collective commitment includes the imperative task of recording and reporting any knowledge of human rights impacts. Therefore, all personnel are expected to:

Ø  Seek guidance from their respective line manager in situations where there is uncertainty regarding the application of any aspect of this policy.

Ø  Document and promptly report to their line manager any allegations of human rights impacts that may be, or have the potential to be, associated with Erinys's or a client's activities.

Ø  Document and report to their line manager any instances where they become aware of, or suspect, a human rights impact that could be linked to the activities of Erinys or a client.

Ø  When necessary, report confidentially through the established Whistleblower procedure any knowledge or suspicion of a human rights impact associated with the activities of Erinys or a client.

Furthermore, it is the duty of all employees to promptly notify their line managers of any known or reasonably suspected commission of the following international crimes:

·         War crimes

·         Crimes against humanity

·         Genocide

·         Torture

·         Enforced disappearance

·         Forced or compulsory labour

·         Hostage-taking

·         Sexual or gender-based violence

·         Sexual exploitation and abuse

·         Human trafficking

·         Trafficking of weapons or drugs

·         Child labour

·         Extrajudicial, summary, or arbitrary executions

Managers who receive reports related to any of the above-mentioned international crimes are required to escalate these reports to a member of the Human Rights Committee promptly.

7         Human Rights Oversight Committee

The Human Rights Oversight Committee is entrusted with the responsibility of ensuring that Erinys faithfully adheres to its human rights commitments as outlined in the Human Rights Policy.

Ø  Composition and Meetings

The committee will be composed of key leadership figures, including the Country Director (CD), Commercial Director, Director of Operations, and HR Manager. It convenes regularly in conjunction with the Management Review process, conducting its activities as an integral component of this review.

Ø  Roles and Responsibilities

The committee's roles and responsibilities encompass the following areas:

·         Implementation of the Human Rights Policy: Ensuring the comprehensive implementation of Erinys's Human Rights Policy throughout the organization.

·         Identification of Relevant Contexts and Services: Identifying contexts and services within which the principles of International Humanitarian Law (Laws of War) may be pertinent.

·         Communication with Competent Authorities: Engaging in communication with Competent Authorities in cases where there is known or reasonable suspicion of the commission of international crimes.

·         Definition of Objectives and Targets: Defining the objectives and targets, as integrated into the Integrated Management System (IMS), pertaining to human rights.

·         Specification of Human Rights Aspects in Risk Criteria: Clearly defining the human rights aspects that are to be incorporated into the criteria for assessing and mitigating risks.

·         Oversight of Human Rights Risks: Maintaining a comprehensive overview of the human rights risks identified through Erinys's risk assessment process.

·         Monitoring of Human Rights Impacts: Continuously monitoring all human rights impacts identified via Erinys's human rights due diligence process.

·         Authorization of Remediation: Providing authorization for the remediation of human rights impacts as recommended by managers.

·         Action on Complicity: Deliberating and approving appropriate actions related to human rights impacts in which Erinys may be perceived as complicit due to its associations with external stakeholders.

·         Best Practices Repository: Establishing and maintaining a repository of best practices and lessons learned pertaining to Erinys's fulfilment of its human rights commitments.

·         Periodic Policy Review: Conducting periodic reviews of Erinys's Human Rights Policy and its performance to ensure their continued suitability, adequacy, and effectiveness.

Ø  Communicating with Competent Authorities

When contemplating the notification of Competent Authorities regarding reports of alleged human rights violations, the Human Rights Oversight Committee is acutely mindful of fundamental rights, including the right to life, liberty, and security of person, non-discrimination, and the rights to be free from arbitrary arrest and detention, torture, or cruel, inhuman, or degrading treatment or punishment, as well as the right to a fair trial. Erinys, in its identification and reporting to Competent Authorities, steadfastly refrains from engaging in any activities that could be construed as complicity in such severe human rights violations.

8         Review and Continuous Improvement

In line with our dedication to excellence and continuous improvement, our Human Rights Policy will undergo regular reviews. These evaluations will be conducted by a designated department responsible for policy management. The primary goal is to assess the policy's effectiveness in promoting and safeguarding human rights within our organization and in our interactions with stakeholders.

9         Conclusion

Erinys Iraq Limited remains steadfast in its dedication to the principles articulated in this Human Rights Policy, with the aim of cultivating a workplace characterized by professionalism, fairness, and unwavering respect for human rights. Our commitment to fostering an environment that champions justice and equity is not static but continually adapts to meet the evolving needs of both our organization and its employees.

By wholeheartedly embracing this policy, we ensure that our employees flourish within an environment that prioritizes their dignity and rights, while simultaneously driving the overall success of our organization.  

We extend our gratitude to all for their dedication in maintaining a work environment that is not only respectful and professional but also one where every individual can thrive and contribute to our collective success.