PJT.

CODE UNIT
SHELL NIGERIA EXPLORATION &
CLIENT PRODUCTION COMPANY LIMITED
0 001
(SNEPCo)

TENDER REF:
THE PROVISION OF WELL ENGINEERING SUPPORT
PROJECT CONTRACT NO.
SERVICES FOR SNEPCo NO CW745443
Page Revisions
PJT/UNIT PROJECTS DEVELOPMENT
0

DOC. TITLE APPENDIX A: CONTRACTOR WORKER WELFARE QUESTIONNAIRE

APPENDIX A: CONTRACTOR WORKER WELFARE QUESTIONNAIRE

0 01.09.202 ISSUE FOR: Christopher Engr. Obot Edet SHELL NIGERIA EXPLORATION
3 Wealth
Technical &
PRODUCTION COMPANY
Rev Date Description Prepared by Approved Client
 S/N HEADING DESCRIPTION RESPONSE
1 Child Labour and Young
Workers (REQUIRED
SECTION)
1.1 Does your company have a policy, procedure or process that prohibits Yes .
the employment of employees who are under the international
minimum age for work (15 years), or the national minimum age for Kindly see attached:
work if it is higher? Please specify which supporting document(s) and Appendix A _Section 1.1_Evidence of Child Labour Policy
corresponding section(s) provides evidence
underpinning your answer.
1.2 How does your company communicate, manage and monitor the
implementation of this policy or process on under-age employees, Communication:
including the corrective actions to be taken if an under-age employee
is identified? Please describe. Policy Distribution: The child labour policy is distributed to
all employees, contractors, and relevant stakeholders via
mails.

Training and Awareness: We Conduct training sessions or

workshops to educate employees and management about
the child labour policy. Ensure that they understand the
policy's importance and their roles in its implementation.

Clear Reporting Channels: Establish clear channels for

reporting potential violations or concerns related to
underage employees. Employees should feel comfortable
reporting such issues without fear of retaliation.

Management:

Age Verification: Implement a robust system for verifying

the age of all employees, especially those who may appear
to be underage.

Supervision and Oversight: Assign responsibility for

oversight of the child labour policy to a designated
compliance officer or team. This team should monitor and
evaluate the policy's implementation.

Regular Audits: Conduct regular audits of your workforce

to ensure compliance with the child labour policy. These
audit include the review of age documentation, working
hours, and conditions.

Monitoring:

Documentation and Record Keeping: Maintain accurate

and up-to-date records of employees' ages and relevant
documentation, such as birth certificates or government-
issued IDs.

Working Hours Tracking: Implement systems to track

working hours of young workers to ensure they are not
exceeding legal limits.

Complaints and Reports: Keep records of any complaints,

reports, or concerns related to underage employment and
the actions taken in response to them.

Corrective Actions:

Investigation: If an underage employee is identified or if

there is reasonable suspicion of underage employment,
conduct a thorough investigation to confirm the violation.
 Immediate Removal: If an underage employee is identified,
remove them from the job immediately to protect their
rights and well-being.

Legal Compliance: Comply with all local and national laws

regarding reporting violations of child labour to the
appropriate authorities.

Corrective Measures: Implement corrective measures to

prevent future violations. This include revising recruitment
and onboarding processes, improving age verification
procedures, and conducting additional training.

Transparency: Communicate the actions taken to address

the violation to all relevant parties, including employees,
contractors, and stakeholders. Transparency is crucial in
maintaining trust.

Prevention: Develop and implement preventative

measures to ensure that similar violations do not occur in
the future.
1.3 Does your company have a policy, procedure or process specifying the No
conditions under which young workers (aged 15 to 18) can be
employed, and the types of work that they can be asked to
undertake? Please specify which supporting document(s) and
corresponding section(s) provides evidence underpinning your
answer.
1.4 How does your company communicate, manage and monitor the N/A
implementation of this policy or process? Please describe.

2 Modern Slavery, Forced

Labour and Human Trafficking
 (REQUIRED SECTION)
2.1 Does your company have a policy, procedure or process that prohibits Yes .
modern slavery (slavery, servitude, forced labour and human Kindly see attached:
trafficking) in your operations and in those of employment agencies or Appendix A _Section 2.1_CDPNL Modern Slavery policy
sub-contractors you use? Please specify which supporting
document(s) and corresponding section(s) provides
evidence underpinning your answer.
2.2 How does your company communicate, manage and monitor the 1. Communication:
implementation of this policy or process? Please describe.
A. Policy Distribution: C.D Princeton Nig Ltd communicate
its anti-modern slavery policy to all employees, suppliers,
contractors, and stakeholders.

B. Training and Awareness: Conduct training sessions or

workshops to educate employees and management about
the anti-modern slavery policy, its importance, and the
signs of modern slavery. Ensure that they understand their
roles in preventing and reporting such practices.

C. Reporting Channels: Establish clear and confidential

reporting channels for employees and external
stakeholders to report suspicions or incidents of modern
slavery. Encourage a culture of reporting and ensure
protection for whistleblowers.

2. Management:

A. Risk Assessment: Conduct a risk assessment to identify

areas within the company's operations and supply chain
that may be vulnerable to modern slavery. This includes
assessing suppliers and subcontractors.

B. Due Diligence: Implement a due diligence process for

assessing suppliers and business partners for compliance
with anti-modern slavery standards. This process should
include evaluating their policies and practices related to
human trafficking and forced labour.

C. Supplier Engagement: Engage with suppliers and

contractors to communicate the company's expectations
regarding anti-modern slavery measures and request
transparency and documentation regarding their own
practices.

D. Supplier Audits: Conduct regular audits or assessments

of high-risk suppliers to ensure compliance with anti-
modern slavery standards. Audits should be carried out by
qualified professionals or third-party auditors.

3. Monitoring:

A. Data Collection: Collect relevant data and information

related to the company's anti-modern slavery efforts, such
as supplier audits, reports of suspicious activity, and
training records.

B. Key Performance Indicators (KPIs): Establish KPIs to

measure the effectiveness of the anti-modern slavery
program. These may include the number of reported
incidents, audit results, and supplier compliance rates.

C. Continuous Monitoring: Continuously monitor the

company's operations and supply chain for any signs of
modern slavery. This can involve ongoing assessments and
supplier communication.
4. Corrective Actions:

A. Investigation: If an incident or suspicion of modern

slavery is reported, conduct a thorough investigation to
verify the claim and determine its extent.

B. Remediation: Take appropriate corrective actions based

on the investigation's findings. This may include ceasing
business with non-compliant suppliers, supporting affected
individuals, and improving internal processes.

C. Reporting: Comply with legal requirements for reporting

incidents of modern slavery to relevant authorities.
Transparency in reporting is crucial.

D. Prevention: Implement measures to prevent the

recurrence of modern slavery incidents, such as
strengthening supplier contracts, revising procurement
practices, and enhancing employee training.

5. Review and Improvement:

A. Regular Review: Periodically review and update the anti-

modern slavery policy and procedures to ensure their
effectiveness and alignment with changing laws and
regulations.

B. Stakeholder Engagement: Engage with stakeholders,

including NGOs and industry associations, to stay informed
about best practices and emerging trends in combating
modern slavery.

C. External Verification: Consider seeking external

 verification or certification from relevant organizations to
validate the company's commitment to anti-modern
slavery efforts.
Ethical Recruitment
(REQUIRED SECTION)
2.3 Does your company pay the service fees charged by the employment Yes .
agencies or sub-contractors that you use for recruitment and hiring Kindly see attached:
and all other recruitment related expenses necessary to recruit, hire, Appendix A _Section 2.3_Evidence of Recruiters license
deploy, and manage workers ? Please specify which supporting
document(s) and corresponding section(s) provides evidence
underpinning your answer.
2.4 Does your company have a policy, procedure or process to ensure the Yes .
employment agencies, or sub- contractors, you use to recruit and hire Kindly see attached:
workers operate ethically and legally? Please specify which supporting Appendix A _Section 2.4_Sub Contractor Integration
document(s) and corresponding section(s) provides evidence Procedure
underpinning your answer.
Employment (REQUIRED
SECTION)
2.5 Does your company provide all workers with a written contract, in a Yes .
language the employee understands, setting out terms of Kindly see attached:
employment, and including daily wage rates and hours of work? Appendix A _Section 2.5_Evidence of staff employment
Please specify which supporting document(s) and corresponding letter
section(s) provides evidence underpinning your answer.
2.6 Does your company provide workers with a contract which specifies Yes .
an agreed period of notice and then permits workers to activate this Kindly see attached:
notice period at their discretion, with no penalty? Please specify Appendix A _Section 2.6_Evidence of Blending Plant
which supporting document(s) and corresponding section(s) provides contract to BRT
evidence underpinning your answer.
2.7 Does your company prohibit unlawful wage deductions or payments YES.
by workers and prohibits the withholding of both money or
identification documents belonging to workers, by your company, or Kindly see attached:
employment agencies acting on your behalf, before or after the start Appendix A_Section 2.7_Evidence of Unlawful wage
of employment? Please specify which supporting document(s) and deduction and withholding of workers possession policy
 corresponding section(s) provides evidence underpinning your
answer.
2.8 Do you have a policy, procedure or process which requires that regular YES.
checks are conducted on facilities, including the following: living Kindly see attached:
space, temperature, lighting, sanitary facilities, privacy, ventilation. Appendix A _Section 2.8_Evidence Of Regular Facility
Please specify which supporting document(s) and corresponding Checks For Living Conditions Policy And Procedure
section(s) provides evidence underpinning your answer.

3 Non- Discrimination
(REQUIRED SECTION)
3.1 Do you have a policy, procedure or process that prohibits YES .
discrimination in hiring, wages, equal pay, protections and conditions
of employment, promotion, benefits and grievance management, Kindly see attached:
termination / dismissal? Please specify which supporting document(s) Appendix A _Section 3.1_Evidence of Employee
and corresponding section(s) provides evidence underpinning your Recruitment and Selection Procedure
answer.
3.2 How does your company communicate, manage and monitor the 1. Policy Development and Documentation:
implementation of this policy or process? Please describe. - Develop a clear and comprehensive Non-Discrimination
and EEO policy that outlines the organization's
commitment to fair and equitable treatment for all
employees and job applicants.
- Document the policy in an official policy manual or
employee handbook.

2. Communication:
- Communicate the Non-Discrimination and EEO policy to
all employees, job applicants, and relevant stakeholders.
- Ensure that the policy is accessible to everyone through
channels such as the company's website, intranet, and
printed materials.
- Conduct training sessions and workshops to educate
employees and management about the policy, its
importance, and how to implement it effectively.
3. Recruitment and Hiring:
- Develop standardized procedures for recruitment and
hiring that align with the Non-Discrimination and EEO
policy.
- Monitor job postings and application processes to
ensure they comply with EEO principles.
- Implement blind recruitment processes, if applicable, to
remove bias from initial resume reviews.

4. Training and Education:

- Provide training and education programs to promote
awareness of diversity, inclusion, and EEO principles among
employees and management.
- Include anti-discrimination and EEO training in
onboarding processes.

5. Implementation:
- Actively implement the Non-Discrimination and EEO
policy in all HR practices, including recruitment, selection,
promotion, compensation, and discipline.
- Ensure that hiring decisions are made based on
qualifications and merit, and not influenced by
discriminatory factors.

6. Monitoring and Auditing:

- Establish regular monitoring and auditing processes to
assess compliance with the policy.
- Conduct internal audits of HR practices, employee
demographics, and complaints related to discrimination or
harassment.
- Review pay equity to identify and address wage gaps
based on gender, race, or other protected characteristics.
7. Reporting and Resolution:
- Implement a system for employees to report
discrimination or EEO concerns confidentially.
- Investigate and address complaints promptly and
impartially, following established procedures.
- Keep records of all complaints, investigations, and
actions taken.

8. Feedback and Improvement:

- Seek feedback from employees and applicants on their
experiences with the organization's EEO practices.
- Use feedback to make continuous improvements to
policies and procedures.
- Engage in diversity and inclusion initiatives to foster a
more inclusive workplace culture.

9. Legal Compliance:
- Ensure that the organization's Non-Discrimination and
EEO policies and practices comply with local, state, and
federal laws and regulations.
- Stay up-to-date with changes in relevant laws and adapt
policies accordingly.

10. Leadership Commitment:

- Encourage leadership to champion diversity and
inclusion efforts and set a positive example.
- Hold leaders and managers accountable for
implementing and upholding EEO principles.

11. Public Accountability:

- Communicate the organization's commitment to Non-
Discrimination and EEO in external communications, such
 as on the company website and in annual reports.
3.4 Does your company have a policy, procedure or process which YES.
prohibits violence, sexual harassment and sexual violence in the
workplace? Please specify which supporting document(s) and Kindly see attached:
corresponding section(s) provides evidence underpinning your Appendix A _Section 3.4_Evidene of Business Ethics and
answer. Compliance Program
3.5 How does your company communicate, manage and monitor the 1. Policy Development and Documentation:
implementation of this policy or process? Please describe. - Develop a clear and comprehensive policy that explicitly
prohibits violence, sexual harassment, and sexual violence
in the workplace.
- Document the policy in an official policy manual or
employee handbook.
2. Communication:
- Communicate the policy against violence, sexual
harassment, and sexual violence to all employees,
contractors, and relevant stakeholders.
- Conduct mandatory training sessions and workshops for
all employees and supervisors to ensure awareness of the
policy and its consequences.

3. Reporting Mechanisms:
- Establish multiple channels for reporting incidents,
including a confidential and anonymous reporting system.
- Provide clear instructions on how to report incidents
and assure employees that they will not face retaliation for
reporting.

4. Investigation and Resolution:

- Develop a well-defined procedure for investigating
complaints of violence, sexual harassment, and sexual
violence.
- Ensure investigations are conducted impartially and in a
timely manner.
 - Take appropriate disciplinary actions against
perpetrators when allegations are substantiated.

5. Support for Victims:

- Offer support services for victims, including counseling
and legal assistance if necessary.
- Maintain confidentiality to the extent possible,
respecting the wishes of the victim.

6. Preventative Measures:
- Implement preventative measures such as awareness
campaigns, bystander intervention training, and conflict
resolution programs.
- Foster a workplace culture that encourages respectful
and inclusive behavior.

7. Legal Compliance:
- Ensure that the organization's policy and procedures
align with local, state, and federal laws and regulations
regarding workplace violence and harassment.
- Stay up-to-date with changes in legislation and adapt
policies accordingly.

8. Leadership Commitment:
- Encourage leadership to lead by example in promoting a
violence-free and harassment-free workplace.
- Hold leaders and managers accountable for enforcing
and upholding the policy.

9. Monitoring and Auditing:

- Regularly monitor and audit the workplace environment
to assess compliance with the policy.
- Review records of reported incidents and resolutions to
 identify trends and areas for improvement.

10. Training and Education:

- Provide ongoing training and education on preventing
violence, sexual harassment, and sexual violence in the
workplace.
- Train managers and HR personnel on how to handle
complaints and conduct investigations.

11. Public Accountability:

- Communicate the organization's commitment to
preventing violence, sexual harassment, and sexual
violence in the workplace in external communications, such
as on the company website and in annual reports.

12. Feedback and Improvement:

- Seek feedback from employees on their experiences
with the organization's policies and procedures.
- Use feedback to make continuous improvements to
policies and procedures.

13. Consequences for Violation:

- Clearly communicate the consequences for violating the
policy, which may include disciplinary actions up to and
including termination.

Creating a safe and respectful workplace is an ongoing

effort that requires the commitment of all employees and
leadership.

4 Freedom of Association
(REQUIRED SECTION)
4.1 Do you have a policy, procedure or process that permits freedom of YES .
 association and collective bargaining? Please specify which supporting
document(s) and corresponding section(s) provides evidence Kindly see attached:
underpinning your answer. Appendix A _Section 4.1_Evidence of Freedom Of
Association And Collective Bargaining Policy
This includes provision for the development of "parallel means" of
representation for labour rights, in countries where the law restricts
labour rights, or discriminates against workers on the grounds of trade
union membership or activities?
4.2 How does your company communicate, manage and monitor the Communication:
implementation of this policy or process? Please describe.
1. Policy Distribution: The organization should distribute
the Freedom of Association and Collective Bargaining Policy
to all employees, including management, and relevant
stakeholders. This can be done through various means,
such as email, the company's intranet, employee
handbooks, and posting the policy in common areas.

2. Training: Conduct training sessions to educate

employees and management about the policy's content,
purpose, and importance. Ensure that employees are
aware of their rights and responsibilities under the policy.

3. Translation: If your organization has a diverse workforce

with employees who speak different languages, consider
translating the policy into the languages spoken by your
employees to ensure everyone understands it.

Management:

4. HR Department: The Human Resources (HR) department

typically plays a central role in managing the
implementation of the policy. HR should be well-versed in
the policy's details and responsible for ensuring
compliance.

5. Employee Representatives: Engage with recognized

employee representatives, which may include union
representatives, to establish lines of communication and
cooperation for collective bargaining purposes. Ensure that
both management and employee representatives
understand the collective bargaining process and the
expectations outlined in the policy.

6. Conflict Resolution: Develop a clear procedure for

resolving disputes or conflicts related to the policy,
especially in cases where disagreements arise during
collective bargaining negotiations. Ensure that this
procedure is well-communicated to all parties involved.

Monitoring and Implementation:

7. Regular Audits: Conduct regular internal audits and

reviews to ensure that the policy is being followed, both in
terms of respecting freedom of association and during
collective bargaining activities.

8. Documentation: Maintain records of collective

bargaining sessions, agreements, and any related
communications. Proper documentation helps ensure
transparency and compliance.

9. Feedback Mechanisms: Create mechanisms for

employees and employee representatives to provide
feedback on the implementation of the policy. This
feedback can help identify any issues or areas for
improvement.
Continuous Improvement:

10. Policy Review: Regularly review and update the

Freedom of Association and Collective Bargaining Policy to
align with changes in labour laws, organizational needs, or
industry standards.

11. Training Updates: Keep employees and management

informed of any updates or changes to the policy through
ongoing training and communication.

Legal Compliance:

12. Legal Consultation: Consult with legal counsel to

ensure that the policy and its implementation align with
local, state, and federal labour laws and regulations.

Leadership Commitment:

13. Leadership Support: Encourage leadership to support

and champion the policy, demonstrating a commitment to
freedom of association and collective bargaining principles.

Public Accountability:

14. External Communication: Communicate the

organization's commitment to freedom of association and
collective bargaining externally, as appropriate. This may
include mentioning it in sustainability reports or on the
company's website.
5 Working Conditions:
Compensation (REQUIRED
SECTION)
5.1 Does your company have a policy, procedure or process requiring the Yes
direct, timely and accurate payment of wages, pension and tax
remittances for all workers? Please specify which supporting Kindly See Attached:
document(s) and corresponding section(s) provides evidence Appendix A _Section 5.1.1_Evidence Of Direct, Timely, And
underpinning your answer. Accurate Payment Of Wages, Pensions, And Tax
Remittances Policy
This should be supported with a payslip in a language and format they Appendix A _Section 5.1.2_Evidence Of Tax Receipts
understand, which explains how their wages are calculated and any Appendix A _Section 5.1.3_Evidence Of Pension
deductions? Contribution
Appendix A _Section 5.1.4_Evidence Of Pay Slip
5.2 How does your company communicate, manage and monitor the 1. Communication:
implementation of this policy or process? Please describe.
Policy Distribution: The policy should be clearly written
and distributed to all relevant parties within the
organization, including HR personnel, finance departments,
and employees. It may be included in the employee
handbook or made available through the company's
intranet.

Training: Conduct training sessions or workshops for

employees involved in payroll, pension contributions, and
tax remittances. Ensure they understand the policy's
requirements and how to implement them effectively.

Documentation: Provide written guidelines or manuals

that detail the procedures and processes to follow when
making payments, managing pension contributions, and
remitting taxes.

2. Management:
Designated Authority: Appoint a specific individual or
department responsible for overseeing the implementation
of the policy. This entity should have the authority to
enforce the policy and address any issues or non-
compliance.

Resource Allocation: Ensure that the necessary resources,

including personnel, payroll systems, and financial
software, are available to support accurate and timely
payments.

Internal Controls: Establish internal controls and checks

and balances to prevent errors and fraud in payroll
processing and tax remittances.

3. Implementation:

Payroll Process: Define the step-by-step process for payroll

management, including timesheet submission, payroll
calculation, and payment distribution.

Pension Contributions: Outline the procedures for

managing and making pension contributions, including
employer and employee contributions.

Tax Remittances: Detail the steps for withholding and

remitting taxes to the appropriate tax authorities, including
deadlines and reporting requirements.

4. Monitoring and Compliance:

Regular Audits: Conduct regular internal audits to verify

compliance with the policy. Audits may focus on payroll
accuracy, pension contribution records, and tax
withholding and remittance records.

Documentation Review: Ensure that records related to

wage payments, pension contributions, and tax
remittances are accurate and up-to-date.

Feedback Mechanisms: Establish a system for employees

to report any concerns or disputes related to payments,
pensions, or taxes. Encourage open communication and
address issues promptly.

5. Reporting and Transparency:

Regular Reports: Provide regular reports to senior

management and stakeholders regarding payroll, pension
contributions, and tax remittances. These reports should
include key performance indicators (KPIs) and any
compliance issues identified.

Transparency: Maintain transparency in all financial

matters related to employee compensation, pensions, and
taxes, and ensure that employees understand their
compensation details.

6. Corrective Actions:

Issue Resolution: Develop a process for addressing and

resolving any discrepancies, errors, or disputes related to
payments, pensions, or taxes.

Continuous Improvement: Use the data gathered from

 monitoring and audits to identify areas for improvement
and implement corrective actions.

7. Compliance with Regulations:

Legal and Regulatory Compliance: Keep abreast of changes

in tax laws and regulations and ensure that the
organization's practices align with these changes.

External Audits: Be prepared for external audits by tax

authorities or regulatory bodies, and ensure that all
documentation and processes are in compliance.

6 Working Conditions: Hours

(REQUIRED SECTION)
6.1 Does your company have a policy, procedure or process which ensures Yes.
that working hours and rest periods for all categories of workers are
compliant with national laws? Please specify which supporting Kindly see attached:
document(s) and corresponding section(s) provides evidence Appendix A _Section 6.1.1_Evidence of Working Hours And
underpinning your answer. Rest Periods Compliance Policy
Appendix A _Section 6.1.2_Evidence of work leave
This includes legally mandated breaks & rest periods on a daily and
weekly basis, the provision of paid leave, sick leave, emergency leave
and parental leave.
6.2 How does your company communicate, manage and monitor the 1. Communication:
implementation of this policy or process? Please describe.
Policy Distribution: Share the policy with all employees,
contractors, and relevant stakeholders through multiple
channels. This may include email, company intranet,
physical copies, and employee orientations.

Training: Conduct training sessions or workshops to

educate employees on the policy's key points, their rights,
and responsibilities. Ensure that they understand the
importance of compliance with working hours and rest
period regulations.

Clear Communication Channels: Establish clear and

accessible channels through which employees can seek
clarification, report violations, or ask questions related to
the policy. This may include setting up a dedicated email
address or hotline for inquiries.

2. Management:

Designated Responsibility: Appoint a dedicated individual

or department responsible for managing and enforcing the
policy. This entity should have the authority to address
compliance issues and make necessary adjustments.

Policy Integration: Integrate the policy into your

organization's broader HR policies and procedures. Ensure
that HR professionals and managers are well-versed in the
policy's contents.

Customization: Tailor the policy to the specific needs and

work environments of different categories of workers, if
applicable (e.g., office employees vs. shift workers).

3. Implementation:

Monitoring Systems: Implement systems to track and

record employee working hours accurately. This may
involve time-tracking software, biometric systems, or
manual timesheets, depending on your organization's
needs.

Rest Period Scheduling: Develop schedules that allow

employees to take their required rest periods without
hindrance. Ensure that these schedules are communicated
and adhered to.

4. Monitoring and Compliance

Regular Audits: Conduct regular internal audits or reviews

to monitor compliance with working hours and rest period
regulations. Use these audits to identify any potential
violations or patterns of non-compliance.

Feedback Mechanisms: Encourage employees to report

any concerns or violations related to working hours and
rest periods. Establish a confidential reporting system to
protect employees who report violations.

Corrective Actions: Develop a process for addressing and

rectifying non-compliance issues promptly. Corrective
actions may include adjusting schedules, providing
compensation for overtime, or addressing any systematic
issues contributing to non-compliance.

5. Reporting and Transparency:

Regular Reports: Provide regular reports on compliance

with working hours and rest period regulations to senior
management and relevant stakeholders. Highlight any
corrective actions taken.

Transparency: Maintain transparency in all matters related

 to working hours and rest periods. Share the results of
audits and actions taken to address violations with
employees.

6. Legal Compliance:

Legal Updates: Stay informed about changes in national

labour laws and regulations related to working hours and
rest periods. Ensure that your policy remains aligned with
current legal requirements.

Legal Consultation: Seek legal counsel or consult with

labour law experts to ensure that your policy remains in
compliance with the latest legal standards.

7. Continuous Improvement:

Feedback Loop: Continuously gather feedback from

employees and relevant stakeholders to identify areas for
improvement in policy implementation. Use this feedback
to make necessary adjustments.

Review and Revision: Regularly review the policy and

procedures to assess their effectiveness and relevance.
Make amendments and improvements as needed to
ensure compliance and employee well-being.

7 Grievance Mechanism &

Disciplinary Procedures
(REQUIRED SECTION)
7.1 Does your company have a policy, procedure or process providing YES.
disciplinary and grievance mechanisms for workers? Please specify Kindly see attached:
which supporting document(s) and corresponding section(s) provides Appendix A _Section 7.1_Evidence of Conflict Resolution
 evidence underpinning your answer. Procedure
7.2 How does your company communicate, manage and monitor the Kindly see attached:
implementation of this policy or process? Please describe. Appendix A _Section 7.2_Evidence ofConflict Resolution
Procedure_Page 4-11
7.3 Has your company established a body to manage grievance and Kindly see attached:
disciplinary issues and to ensure they are applied consistently to all Appendix A _Section 7.3_Evidence ofConflict Resolution
workers without discrimination Procedure_Page 4-11

Supplier Standards
(REQUIRED SECTION)
8.1 Does your company have a policy, procedure or process for selection Yes .
and follow up of suppliers on the basis of human rights? Please specify
which supporting document(s) and corresponding section(s) provides Kindly see attached:
evidence underpinning your answer. Appendix A _Section 8.1_Evidence of Procurement
Standard Operating Procedure
8.2 How does your company manage and monitor the implementation of 1. Establishing the SOP: The first step is to create a
this policy or process? Please describe. comprehensive procurement SOP. This document should
outline all the procedures and guidelines that need to be
followed during the procurement process. It should cover
everything from procurement planning and vendor
selection to contract management and performance
evaluation.

2. Training and Communication: Once the SOP is in place,

it's essential to ensure that all relevant personnel are
trained on its contents. This may involve conducting
workshops, providing online training modules, or
organizing informational sessions to ensure that everyone
involved in the procurement process understands their
roles and responsibilities.

3. Documentation and Record-keeping: Proper record-

keeping is crucial in procurement. This includes
documenting every step of the procurement process, from
the initial request for goods or services to the final contract
and payment. Digital procurement systems are often used
to streamline this process and ensure accuracy and
transparency.

4. Compliance Monitoring: Organizations typically have a

compliance officer or team responsible for monitoring
adherence to the procurement SOP. This may involve
regular audits of procurement transactions, reviewing
documentation for accuracy and completeness, and
ensuring that all actions are in line with organizational
policies and relevant regulations.

5. Key Performance Indicators (KPIs): Establish KPIs to

measure the effectiveness and efficiency of the
procurement process. Common KPIs include cost savings,
procurement cycle time, vendor performance, and contract
compliance. Regularly track and analyze these metrics to
identify areas for improvement.

6. Continuous Improvement: Based on the data and

feedback gathered from compliance monitoring and KPIs,
organizations should continuously refine their procurement
SOP. This may involve updating procedures, addressing
bottlenecks, and implementing best practices to optimize
the procurement process further.

7. Stakeholder Feedback: Solicit feedback from all

stakeholders involved in the procurement process,
including procurement officers, end-users, and vendors.
This feedback can help identify issues and areas for
improvement in the SOP and the overall procurement
 process.

8. Technology and Automation: Many organizations use

procurement software and automation tools to streamline
and monitor the procurement process more effectively.
These tools can help with vendor management, contract
tracking, and real-time reporting.

9. Reporting and Transparency: Maintain transparency in

the procurement process by providing regular reports to
senior management and relevant stakeholders. These
reports should highlight performance against KPIs,
compliance status, and any notable developments or
challenges.

10. Legal and Regulatory Compliance: Ensure that the

procurement SOP is updated regularly to reflect changes in
laws and regulations governing procurement. Compliance
with legal requirements is essential to avoid legal issues.

9 Security arrangements
(ELECTIVE SECTION)
9.1 Does your company have a policy, procedure or process providing Yes.
guidelines for use of force for security providers? Please specify which
supporting document(s) and corresponding section(s) provides Kindly see attached:
evidence underpinning your answer. Appendix A _Section 9.1_Evidence of Guidelines For
Security Providers

9.2 How does your company communicate, manage and monitor the 1. Communication:
implementation of this policy or process? Please describe. Policy Distribution: The first step is to communicate the
policy to all relevant stakeholders, including security
providers. This may involve distributing a copy of the policy
document electronically or in print.
Training and Orientation: Conduct training sessions or
orientation programs to ensure that security providers fully
understand the policy's contents and implications. This may
include discussing key points, answering questions, and
providing scenarios for practical understanding.
Acknowledgment: Require security providers to
acknowledge receipt and understanding of the policy
through a signed acknowledgment form. This
acknowledgment form can be kept on record for future
reference.

2. Management:

Designated Authority: Appoint a designated authority or

department responsible for overseeing the implementation
of the policy. This entity should have the authority to
enforce the policy and address any violations.

Policy Integration: Ensure that the policy is integrated into

the day-to-day operations of the security department. This
may involve updating standard operating procedures
(SOPs), protocols, and training materials to align with the
policy.

Roles and Responsibilities: Clearly define the roles and

responsibilities of individuals and teams involved in
implementing the policy. This includes identifying who is
responsible for monitoring compliance and reporting.

Regular Review: Establish a schedule for periodic policy

reviews and updates to ensure that the guidelines remain
current and effective. Regulatory changes, industry
standards, and evolving security threats may necessitate
revisions.

3. Monitoring and Compliance:

Incident Reporting: Implement a system for security

providers to report any incidents related to the policy,
including any use of force situations. Encourage prompt
and accurate reporting.

Audits and Inspections: Conduct regular audits or

inspections to assess compliance with the policy. These
audits may be internal or conducted by external experts,
depending on the organization's needs and industry
standards.

Key Performance Indicators (KPIs): Establish KPIs and

metrics to measure the effectiveness of the policy. These
may include incident rates, compliance rates, and feedback
from stakeholders.

Corrective Actions: When non-compliance or policy

violations are identified, establish a process for corrective
actions, which may include retraining, disciplinary
measures, or process improvements.

4. Communication and Feedback Loop:

Continuous Communication: Maintain open lines of

communication with security providers and other
stakeholders. Encourage them to provide feedback on the
policy's implementation, share concerns, and suggest
improvements.
 Policy Updates: Communicate any updates or revisions to
the policy promptly to ensure that security providers are
aware of the changes and can adapt their practices
accordingly.

Regular Reporting: Provide regular reports on policy

implementation and compliance to senior management
and relevant stakeholders. This transparency helps in
assessing the policy's effectiveness.

10 Community (ELECTIVE
SECTION)
10.1 Does your company have a policy, procedure or process for avoiding Yes .
and managing any adverse impacts on communities? Please specify
which supporting document(s) and corresponding section(s) provides Kindly see attached:
evidence underpinning your answer. Appendix A _Section 10.1_Evidence of Community relations
Plan
10.2 How does your company manage and monitor the implementation of 1. Communication:
this policy or process? Please describe. Stakeholder Engagement: Identify and engage with key
stakeholders, including community members, local
organizations, government agencies, and other relevant
parties. Open and ongoing communication is essential.

Public Awareness: Develop a communication strategy to

inform the community about the Community Relations
Plan.

Internal Communication: Ensure that all relevant

departments and employees within the organization are
aware of the plan's goals, objectives, and their respective
roles in its implementation.
2. Management:

Designated Responsibility: Appoint a dedicated team or

individual responsible for overseeing the implementation
of the Community Relations Plan. This team should have a
clear understanding of the plan's goals and objectives.

Resource Allocation: Allocate the necessary resources,

including budget, staff, and tools, to support the plan's
implementation effectively.

Action Plans: Develop detailed action plans that outline

specific activities, timelines, and responsible parties for
each aspect of the plan. These action plans should align
with the plan's overall goals.

Integration: Integrate the Community Relations Plan into

the organization's broader strategic planning and decision-
making processes.

3. Monitoring and Evaluation:

Key Performance Indicators (KPIs): Define measurable KPIs

and metrics that will be used to assess the plan's progress
and success. These could include community engagement
levels, public perception, or specific project milestones.

Data Collection: Collect relevant data and feedback from

the community, stakeholders, and internal sources to
assess the plan's impact and effectiveness.

Regular Review: Schedule regular reviews and evaluations

of the plan's implementation. These reviews can identify
areas for improvement and ensure that the plan remains
aligned with community needs and expectations.

Adjustment: Be prepared to adjust the plan as needed

based on feedback, changing circumstances, or emerging
community concerns.

4. Reporting and Transparency:

Regular Reporting: Provide regular reports on the progress

of the Community Relations Plan to senior management,
the board of directors, and relevant stakeholders. These
reports should include key findings, successes, challenges,
and action plans for improvement.

Community Feedback: Actively seek feedback from the

community and other stakeholders and demonstrate a
commitment to addressing their concerns and suggestions.

Transparency: Maintain transparency in all

communications related to the plan's implementation,
including both successes and challenges.

5. Continuous Improvement:

Learning and Adaptation: Use the data and feedback

collected during the monitoring and evaluation process to
make informed decisions and improvements to the plan.

Adaptive Management: Embrace a flexible and adaptive

management approach, allowing for adjustments to the
plan in response to changing community dynamics and
needs.
 Community Involvement: Involve the community in the
planning and decision-making processes to ensure their
voices are heard and their needs are addressed effectively.

11 Living Conditions (REQUIRED

SECTION)
11.1 Does your company have a policy, procedure or process which ensures Yes .
that accommodation is provided such that workers have: quality of
sleep and food, and access to leisure activities and facilities to Kindly see attached:
communicate with family and friends, compliant with international Appendix A _Section 11.1_Evidence Of Employee Well-
recommended practices (eg IFC and EBRD guidance note Workers’ Being And Accommodation
accommodation: processes and standards)? Please specify which
supporting document(s) and corresponding section(s) provides
evidence underpinning your answer.

12 Supporting Documentation
12.1 Please upload any relevant supporting documents required to
demonstrate compliance with the requirements of the above
questionnaire.