Code of Conduct & Ethics

Introduction

With this Code of Conduct, (hereafter “the Code”), Primary Response presents a unified approach and framework of conduct and ethics. The purpose of the Code is to affirm Primary Response’s commitment to human rights and to establish a standard for providing services, conducting business and interacting with stakeholders, in order to have a positive influence in the society and the communities in which it operates.

Primary Response promotes the Code of Conduct and Ethics to all employees as a set of core standards. The primary stakeholders for the Code are Primary Response’s personnel, customers, suppliers and other business partners, authorities on all levels, society and the communities in which they operate.

Section 1 – Human Rights

1.1 Primary Response acknowledges that security is a fundamental need, shared by individuals, communities, businesses, and governments alike. While acknowledging that difficult security issues are faced by private security companies, Primary Response recognizes that security and respect for Human Rights can and should be consistent.

1.2 Primary Response shall support and respect, when conducting business, the dignity of all human beings and will endeavour to observe all applicable international humanitarian and human rights laws.

Section 2 – Laws and Regulations Governing Private Security

2.1 Primary Response shall carry out its private security operations in compliance with applicable laws and regulations governing the private security industry.

2.3 Primary Response shall comply with existing laws and regulations, and shall establish its own procedures regarding screening, vetting, and training of its personnel according to those laws and regulations. Member personnel will be trained in accordance with applicable legislation and/or licensing standards.

2.4 Operations will be carried out in line with compulsory obligations regarding uniforms, communication tools, use of batons and hadncauffs or any other operational working method.

2.5 Primary Response shall only provide services to customers which can be legally provided and are conducted within the limits of legally allowed operational methods. Primary Response will also subscribe to compulsory insurances in accordance with applicable regulation and will endeavour to obtain and maintain reasonable coverage for third party liability.

2.6. Within the communities in which it operates and within society as a whole, Primary Response will promote the rationale of regulations for the security industry and raise awareness regarding the positive impact of regulatory frameworks.

Section 3 – Business Ethics

3.1 Primary Response commits to proper business conduct in how it treats its personnel, customers and business partners and how it interacts with its competitors. Primary Response shall demonstrate respect for laws and regulations.

3.2 Primary Response shall refrain from unlawful discrimination based on any applicable protected personal characteristics

3.3 Primary Response shall prohibit its personnel from taking or offering bribes and will require that its personnel avoid any conflict of interest that might affect business decisions.

3.4 Primary Response will allow its personnel, without fear of reprisal, to raise serious concerns about business practices or those which otherwise violate the Code.

3.5 Primary Response shall treat customers’ confidential and proprietary information and intellectual property in a confidential manner and shall protect it from inappropriate disclosure and misuse.

3.6 Primary Response shall ensure that its customers will receive relevant contract information in a transparent, accurate and timely manner.

3.7 Primary Response shall ensure that customers’ complaints will be treated and followed-up in an appropriate manner.

3.8 Primary Response shall treat its suppliers and other business partners in accordance with principles of good faith and fair dealing.

3.9 Primary Response shall encourage its suppliers and other business partners to comply with and promote standards of human rights and business ethics.

3.10 Primary Response shall make efforts to provide a positive influence in the communities in which it operates.

Section 4 – Working Conditions

4.1 With regard to working conditions and occupational health and safety, Primary Response shall comply with statutory requirements and strive to ensure that the workplace and its operations do not endanger the health and safety of any personnel.

4.2 Primary Response shall act in accordance with principles of equality of treatment, showing respect, dignity and empathy towards personnel. Primary Response shall prohibit any kind of unlawful discrimination based on applicable protected personal characteristics.

4.3 All screening and selection processes shall be conducted by Primary Response properly and in compliance with applicable regulations.

4.4 Primary Response shall conduct employment commencement and termination according to applicable regulations.

4.5 Upon commencement of employment, Primary Response shall give new personnel all necessary instructions and training in order to carry out their duties effectively and efficiently.

4.6 Primary Response shall ensure that it pays wages corresponding at least to the minimum wage prescribed by law. Wages shall be paid at an agreed time and in a form that is practical for both the personnel and the employer and complies with applicable law. Personnel shall be informed regularly and in a detailed, comprehensible manner of the composition of their remuneration.

4.7 If the working conditions change in the course of employment, Primary Response shall notify personnel in due time and advise them of any need for additional qualifications, in accordance with applicable legislation.

4.8 Primary Response shall establish procedures to deal with any grievances raised during the course of employment in a timely manner.

4.9 Primary Response shall take an active approach to understanding the needs of and building relationships with its personnel.

Section 5 – Environment

5.1 Primary Response commits to taking the environmental impact of its business into account. It shall actively strive to reduce the overall effect of its business activities on the environment and ensure that they will contribute to the benefit of its stakeholders without compromising the needs of future generations.

5.2 Primary Response shall ensure that its business activities comply with applicable laws and regulations regarding the protection of the environment.

5.3 Primary Response shall obtain and maintain all required environmental permits and registrations and follow their operational and reporting requirements.

5.4 Primary Response shall continuously seek ways to reduce the consumption of resources, emissions and waste.

Section 6 – Evaluation

6.1 The Code will be the subject of periodic evaluation by a working group, for examination, assessment and update, as determined by Primary Response. Adopted in Toronto, 1996.

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