CODE OF BUSINESS ETHICS

Duguf Enterprise Security Services has adopted this code of business ethics to:

The code sets forth general legal and ethical principles. Managers, supervisors and employees must use good judgment and common sense in applying them, and in deciding when to seek guidance from others as to the appropriate course of conduct.

Duguf will conduct its business honestly and ethically wherever we operate in the world. We will constantly improve the quality of our services and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound judgment. No illegal or unethical conduct on the part of our managers, supervisor or employees will be tolerated as it is goes against the company’s best interest and the clients it serves. Duguf will not compromise its principles for short-term advantages.

Duguf pledges strong commitment to respect and implement all the articles in the International Code of Conduct for Private Security Service Provider throughout its business operations.

Each manager, supervisor and employee must demonstrate honest and ethical conduct in fulfilling his/her duties, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

Each manager, supervisor and employee should endeavor to deal fairly with the company’s clients, suppliers, competitors and employees. No one should take unlawful and unfair advantage of the company’s clients, suppliers, competitors and employees through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice.

A “conflict of interest” occurs when an individual’s private interest interferes or appears to interfere with the interests of the company. A conflict of interest can arise when a manager, supervisor or employee takes actions or has interests that may make it difficult to perform his or her company work objectively and effectively. Conflicts of interest must be avoided.

Managers, supervisor and employees are prohibited from:

Managers, supervisors and employees must maintain the confidentiality of confidential information entrusted to them by the company, its clients and suppliers, except when disclosure is authorized by the company or legally mandated.

Confidential information includes all non-public information that might be of use to the company’s competitors, or that could be harmful to the company, its clients or suppliers, if disclosed.

Managers, supervisors and employees must, in all practicable ways, protect the company’s assets and ensure their efficient use. All company assets must be used for legitimate business purposes.

It is the company’s policy to comply with all applicable laws and governmental rules and regulations. It is the personal responsibility of each manager, supervisor and employee to adhere to the standards and restrictions imposed by those laws, rules and regulations.

The company’s commitment to its values includes ensuring that any person with a good-faith concern about potentially unethical conduct can report it in the way in which they feel most comfortable. This includes reports of conduct that would violate this code, or applicable laws. Concerns may be reported by anyone, and they may be reported to a supervisor (for employees), the Human Resources or the grievance committee.

All managers, supervisors and employees of the company are expected to be familiar with the code and to adhere to those principles and procedures set forth in the code that apply to them.

The senior management shall determine, or designate appropriate persons to determine, appropriate actions to be taken in the event of violations of this code. Such actions shall be reasonably designed to deter wrongdoing and to promote accountability for adherence to this code and may include written notices to the individual involved that the senior management has determined that there has been a violation, demotion by the senior management, or re-assignment of the individual involved, suspension with or without pay or benefits, and/or termination of the individual’s employment.

The senior management or its designee shall determine what action is appropriate and in a particular case may take into account all relevant information, including the nature and severity of the violation, whether the violation was a single occurrence or repeated occurrences, whether the violation appears to have been intentional or inadvertent, whether the individual in question had been advised prior to the violation as to the proper course of action and whether or not the individual in question has committed other violations in the past.

Duguf Enterprise Security Services believes it is essential that its employees and business partners comply with global anti-corruption laws, as well as the anti-bribery laws of the Federal Government of Somali.

Duguf prohibits any of its personnel from corruptly seeking to obtain or retain business by offering, paying or offering to pay money or provide other things of value to individuals or entities for the purposes of:

Duguf recognizes and respects the value and integrity of each and every human life.  It affirmthat it has a responsibility to respect the human rights of, and fulfills humanitarian responsibilities towards, all those affected by its business activities, including Personnel, clients, suppliers, shareholders, and the population of the area in which services are provided.

Duguf and its personnel also recognize the importance of respecting the various cultures encountered in its work, as well as the individuals they come into contact with as a result of those activities.

Duguf will respect human rights, including but not limited to, non-derogatory, human rights, such as:

We are aware of some of the human rights challenges in our industry, some of the applicable human rights risks in our line of work might include:

The risk of using deadly force and taking lives; torture and inhuman treatment; sexual exploitation; human trafficking; forced labor; Discrimination. We work actively to minimize any such risks and challenges throughout our business operations.

Our main purpose as a private security company is to enable the right to life in high-riskenvironments that are inherently unstable and dangerous, doing so in such a way that does not violate other human right. Deadly force should only be used in self-defense or the defense of our clients, when it reasonably appears necessary to prevent the commission of a serious offense involving violent threatening death or serious bodily harm.

Duguf will not, and will require that their Personnel not, engage in torture or other cruel, inhuman or degrading treatment or punishment.

Duguf will, and will require that their Personnel, report any acts of torture or other cruel, inhuman or degrading treatment or punishment, known to them, or of which they have reasonable suspicion. Such reports will be made to the Client and one or more of the following: the competent authorities in the country where the acts took place, the country of nationality of the victim, or the country of nationality of the perpetrator.

Duguf will not benefit from, nor allow their Personnel to engage in or benefit from, sexual exploitation (including, for these purposes, prostitution) and abuse or gender-based violence or crimes, either within the company or externally, including rape, sexual harassment, or any other form of sexual abuse or violence.  Duguf will, and will require their Personnel to, remain vigilant for all instances of sexual or gender-based violence and, where discovered, report such instances to competent authorities.

Duguf will not, and will require their Personnel not to, engage in trafficking in persons. Signatory Companies will, and will require their Personnel to, remain vigilant for all instances of trafficking in persons and, where discovered, report such instances to Competent Authorities. For the purposes of this Code, human trafficking is the recruitment, harboring, transportation, provision, or obtaining of a person for (1) a commercial sex act induced by force, fraud, or coercion, or in which the person induced to perform such an act has not attained 18 years of age; or (2) labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, debt bondage, or slavery.

Duguf will not use slavery, forced or compulsory labor, or be complicit in any other entity’s use of such labor.

Duguf will respect the rights of children (anyone under the age of 18) to be protected from the worst forms of child labor, including:

Duguf will, and will require their Personnel to, report any instances of the activities referenced above that they know of, or have reasonable suspicion of, to Competent Authorities.

Duguf will not, and will require that their Personnel do not, discriminate on grounds of race, color, sex, religion, social origin, social status, indigenous status, disability, or sexual orientation when hiring Personnel and will select Personnel on the basis of the inherent requirements of the contract.

DESS does not tolerate sexual related misconduct and/or abuse, or other misconduct detrimental to dignity, respect, and good order, against ANY individual, Other Country National or Local National alike.

All DESS employees will receive full PSEA training as a mandatory condition of employment. Employee will also undergo refresher PSEA training at least every 12 months.

Who harasses?

Harassment

Sexual harassment is one of the most common types of harassment. Sexual harassment occurs when a person makes an unwelcome sexual advance, an unwelcome request for sexual favors or engages in unwelcome conduct of a sexual nature in circumstances which causes another person to feel offended, humiliated, or intimidated by that conduct.

Sexual harassment can include a wide variety of behavior of a sexual nature. Unwelcome physical contact, “dirty” jokes, persistent requests for dates, comments about a person’s sexual behavior and the display of sexually explicit material pin-ups, calendars, etc., are examples of conduct that may constitute sexual harassment.

If you believe that you have been subjected to harassment of any kind, you should notify your Health & Safety Representative who will ensure the situation is confidentially investigated and any necessary action is taken. The normal disciplinary procedures will apply if harassment is found to occur.

It is everyone’s responsibility to maintain a workplace that is free of harassment of any kind.

Sexual Assault

Sexual assault is defined as intentional sexual contact, characterized by use of force, physical threat or abuse of authority or when the victim does not or cannot consent; sexual assault can occur without regard to gender, spousal relationship, or age of victim and includes the following:

NOTE: Cultural differences are no excuses to engage in inappropriate behavior leading to sexual assault.

Forms of harassment

What is consent?

Helpful Tips About Consent

Impact of Sexual Assault on the Victim

Victim Actions

Bystander Intervention

First Responders Actions