The Company expects that Employees avoid at all times any situation, which may involve a conflict of interest between the employee and the company. Employees are expressly prohibited from offering, accepting, or soliciting a bribe, a gift in the form of money, or in-kind including entertainment and paid employment in other companies in return to influence a business decision. Executive Management written consent should be sought, in exceptional circumstances, or even for legitimate reasons, in the case of a gift, or entertainment, the value of which should be nominal.

Our Ant bribery and Corruption Policy

Amalgamated Security Services Limited shall commit to conducting its business lawfully, ethically and with integrity which is embodied in our code of Business Ethics and Code of Conduct policy [ADM-P002].

In essence, the company, its subsidiaries, affiliates, directors, officers, and employees shall not engage in any activity, practice or conduct which would constitute an offence under sections 3,4, or 5 of the Prevention of Corruption Act [Chap.11:11, Act 11 of 1987, Laws of Trinidad and Tobago].

For the purpose of this policy, corruption is defined as the misuse of public power for private profit, or the misuse of entrusted power for private gain. Bribery shall be defined as the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage.

Additionally, the company shall ascertain that its affiliates, shareholders, officers, directors, and employees shall conduct all of its activities in accordance with all applicable laws, regulations and codes relating to anti-bribery and anti-corruption.

Compliance with this policy is the responsibility of every Amalgamated Security Services Limited stakeholder. Therefore, Amalgamated Security Services Limited agrees to participate in anti-bribery corruption training provided by TRACE, or by a comparable organization, and to make training available for all principals and for all key employees in sales, marketing and procurement via the Company’s Employee Orientation Session/s.

Amalgamated Security Services Limited is committed to preventing and mitigating exploitation, bribery, and corruption. We will not accept modern slavery, forced labor, and human trafficking anywhere within our operations or supply chain.

We consider modern slavery as a crime and morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It takes various forms, such as slavery servitude, forced and compulsory labor, and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure include due diligence of the supplier’s reputation, respect for the law, compliance with health, safety, and environmental standards and references.

The following are Amalgamated Security Services Limited’s core elements of our actions to prevent modern slavery and human trafficking:

Policies

We have stringent policies and processes already in place to ensure fair and equal employment rights and pay, working time protections, and protection against any form of discrimination, including but not limited to harassment, which both protects our staff and set out the principles by which our staff must deal with any third parties.

ASSL operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Whistleblowing Policy – we encourage all employees, customers, and suppliers to report any suspicion without fear of retaliation. We provide a confidential helpline to protect the identity of the whistleblowers.
• Code of conduct – our code of conduct encourages employees to do the right thing by clearly stating the highest standards of employee conduct and ethical behavior when operating abroad and managing our supply chain.
• Health & Safety Policy – we encourage all employees, customers, and suppliers to ensure they follow best practices to protect the health, safety, security, and well-being of everyone who is encompassed within the scope of ASSL’s business.
• Human Rights Policy – this reflects a zero-tolerance approach to all forms of child exploitation, abuse, and forced labor including those that constitute human rights abuses.
• Anti-bribery & Anti-Corruption Policy – our rules and principles regarding bribery and corruption apply to all our partners, employees, contractors, and consultants and are strictly enforced.

Supplier Due Diligence

ASSL conducts due diligence on new subcontractors and suppliers during onboarding. We require subcontractors and suppliers to complete a due diligence checklist to ensure they conform to ASSL’s policies and procedures, and we check them against international watch lists.

 This includes:

• Assessing risks in the provision of particular services.

We require subcontractors and suppliers to attest that:

• They do not use any form of forced, compulsory, or slave labor
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment.