GOVERNANCE AND COMPLIANCE

COMPANY POLICY

Belstone Dart International conducts operations in environments that are inherently unstable and dangerous. We are committed to conducting those operations to the highest level of professionalism whilst maintaining the safety and security of our clients, and ensuring respect for human rights, laws and fundamental freedoms.

When conducting operations, we are firmly committed to the following objectives:

  1. Respect of human life and dignity as its first priority

  2. Avoid, prevent and reduce the likelihood and consequence of disruptive and undesirable events

  3. Comply with applicable legal requirements

  4. Respect human rights

  5. Promote continual improvement in the conduct of our operations

Belstone Dart International implements effective processes to support the conduct of security operations. Its management are responsible for establishing objectives and driving towards continuous improvement in all areas.

STATEMENT OF CONFORMANCE

Belstone Dart International (BDI) is a company primarily based in Somalia, and provides a variety of services in a complex environment.


At BDI we are an organization completely committed to the success of our clients. Our delivery model consists of four key elements; Consulting, Intelligence Risk Management, Capability Development, Logistics & Procurement.


Our stakeholders which include clients, government agencies, communities where we operate, expect BDI to operate responsibly and in conformance with national, international laws and human rights.


BDI’s Code of Conduct and application of all aspects of our operations are conducted in an ethical manner. A key principle of this commitment is our pledge to respect human rights and to provide understanding services that seek to improve and sustain a community license to operate. 


Complex environments pose elevated risks of facing issues from or relating to human rights abuses. BDI seeks to mitigate this risk as effectively as possible by ensuring that the principles outlined within our Code of Conduct and Business Ethics and our internal policy on Human Rights are strictly adhered to and that all personnel are aware of these commitments and understand their absolute importance.

BDI respects all people. This is demonstrated in a robust commitment to the UN guiding Principles on Business and Human Rights, the International Code of Conduct for Private Security Providers (ICoCA), the Montreux Document and all applicable laws and guidelines.

Our statement of conformance is coupled with our compliance with and application for certification for PSC1 and ISO18788 as part of our on-going commitment to best practice. Aspects of this accountable approach include:


  • Safeguard against any form of discrimination based on gender, culture, faith, race or disability.

  • Staff, partners and suppliers and where suitable, clients are strictly and fairly vetted during our selection process.

  • Our working environment is as safe and healthy as possible.

  • Always focus on providing the highest quality of services across our portfolio.

  • Internal training is at the very centre of developing and maintaining a quality approach to our clients.

  • Reject any form of bribe or corruption, irrespective of the form.

  • Appropriate compensation for our personnel, suppliers and contractors. 


BDI is committed to providing a quality of service and has a clear process for examining disruptive events, through this review the design, implementation, and observing of improvements is carried out. Lessons learnt are embedded in the company, including external evaluation from auditors to ISO9001, ANSI: PSC-1 and ISO 18788.

SECURITY POLICY

Belstone Dart International (BDI) is committed to providing services for its clients that takes into account all applicable national & international laws, The Montreux Document, and the Voluntary Principles on Security & Human Rights (VPSHR).


It is further the policy of BDI to commit to and maintain a Security System designed to meet the requirements of ANSI PSC-1 and ISO 18788 through a framework of Plan-Do-Check-Act (PDCA), to meet its primary objectives:


  • Meeting the standards of the VPSHR

  • Comply with national legislation in the areas of operations and in the countries of incorporation of BDI.


This Policy and the documented Security Management System ensures that:


  • BDI continuously set measureable targets and objectives surrounding business operations, security matters and shall invoke programmes to realise these goals

  • BDI has in place a robust Risk Assessment process, which identifies potential security threats and Health & Safety issues.The Risk Assessment further identifies all treatments in order to mitigate potential Security and Health & Safety risks.

  • BDI will continuously monitor and measure the effectiveness of its Security

  • BDI Management System in order to drive continuous improvement.

  • All applicable legislation will be monitored and documented in order to ensure regulatory compliance in all operations.

This policy will be reviewed on a regular basis for continued relevance and compliance, so that BDI will ensure the safety and security of our clients and personnel within the implemented Security Operations Management System (SOMS).

WHISTLE BLOWING

  1. General:

Belstone Dart International is committed to the highest standards of openness, probity and accountability.

An important aspect of accountability and transparency is a mechanism to enable staff, other members of BDI (e.g. contractors) and other stakeholders (such as third parties) to voice concerns in a responsible and effective manner. Where an individual discovers information which they believe shows serious malpractice or wrongdoing within the organisation then this information should be disclosed internally without fear of reprisal, and there should be arrangements to enable this to be done independently of line management.

Employees must be protected against being dismissed or penalised by their employers as a result of publicly disclosing certain serious concerns. BDI has endorsed the provisions set out below to ensure that no members of staff, or other whistle blower should feel at a disadvantage in raising legitimate concerns.


It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by BDI nor should it be used to reconsider any matters which have already been addressed under harassment, complaint, disciplinary or other procedures.


2.      Scope of Policy:


This policy is designed to enable employees, contractors and other stakeholders (e.g. third parties) of BDI to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary. These concerns could include:


  • Financial malpractice or impropriety or fraud

  • Failure to comply with a legal obligation or Statutes

  • Dangers to Health & Safety or the environment

  • Criminal activity

  • Improper conduct or unethical behaviour

  • Attempts to conceal any of these


3.      Safeguards:


Protection - this policy is designed to offer protection to the whistle blower  who disclose such concerns provided the disclosure is made:


  • in good faith

  • in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person. It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure. In an extreme case, malicious or wild allegations could give rise to legal action on the part of the persons complained about.


Confidentiality - Belstone Dart International will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

Anonymous Allegations - this policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of BDI. In exercising this discretion, the factors to be taken into account will include:


  • The seriousness of the issues raised

  • The credibility of the concern

  • The likelihood of confirming the allegation from attributable sources


Untrue Allegations - If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.


4.      Procedures for Making a Disclosure


On receipt of a complaint of malpractice, the member of staff who receives and takes note of the complaint, must pass this information as soon as is reasonably possible, to the appropriate designated investigating officer as follows:


  • Complaints of malpractice will be investigated by the appropriate Director unless the complaint is against the Director or is in any way related to the actions of the Director. In such cases, the complaint should be passed to the Chief Executive for referral.

  • In the case of a complaint, which is any way connected with but not against the Director, the Chief Executive will nominate a Senior Manager or external party to act as the alternative investigating officer.

  • Complaints against the Chief Executive should be passed to the Chairman who will nominate an appropriate internal or external investigating officer.

  • The complainant has the right to bypass the line management structure and take their complaint direct to the Chairman. The Chairman has the right to refer the complaint back to management if he or she feels that the management without any conflict of interest can more appropriately investigate the complaint.


  • The complainant may use the following platforms to air their complaints;


a).   EMAIL:        info@belstonedart.com                       

                    b).   Or alternatively call the following Corporate HQ Contact number:                        


+44 (0) 7502487427


If there is evidence of criminal activity, then the investigating officer should inform the police. BDI will ensure that any internal investigation does not hinder a formal police investigation.

PRIVACY

This privacy policy notice is served by Belstone Dart International registered at Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX and under the website www.belstonedart.com.  The purpose of this policy is to explain to you how we control, process, handle and protect your personal information through the business and while you browse or use this website. If you do not agree to the following policy you may wish to cease viewing / using this website, and or refrain from submitting your personal data to us.

Policy key definitions:

  • "I", "our", "us", or "we" refer to the business, [Business name & other trading names].

  • "you", "the user" refer to the person(s) using this website.

  • GDPR means General Data Protection Act.

  • PECR means Privacy & Electronic Communications Regulation.

  • ICO means Information Commissioner's Office.

  • Cookies mean small files stored on a user’s computer or device.


Key principles of GDPR:


Our privacy policy embodies the following key principles; (a) Lawfulness, fairness and transparency, (b) Purpose limitation, (c) Data minimisation, (d) Accuracy, (e) Storage limitation, (f) Integrity and confidence, (g) Accountability.

Processing of your personal data:

Under the General Data Protection Regulation (GDPR) we control and / or process any personal information about you electronically using the following lawful bases.

We are exempt from registration in the ICO Data Protection Register as BDI only collates personal data for core business purposes of staff administration, advertising, our marketing, client accounts and record keeping.

  • Lawful basis: Consent
    Our purpose for processing is that data is purely retained to maintain staff and clients’ details. Which is necessary because it allows the relevant administrative staff to maintain accurate and timely employee records and to process client’s contractual requirements. E.g. invoicing. Our data retention period will continue to process information under this basis until you withdraw consent or it is determined your consent no longer exists. We do not share your information with third parties.

  • Lawful basis: Contracts
    Where our purpose for processing is maintaining clients’ details
    Which is necessary because it is required to ensure we fulfil our legal and contractual obligations.
    Data retention period: We will continue to retain your information under this basis until you withdraw consent, is required for financial obligations or is determined your consent no longer exists.

  • Sharing your information: We do share your personal information with third parties and they include; Her Majesty’s Revenue & Customs (HMRC).


If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.

QUALITY STATEMENT

Scope Statement:  Belstone Dart International is a high-quality risk management and security consultancy provider, delivering professional services to diplomatic missions and blue-chip organisations.


Mission: To be a company of choice committed to our customers and employees in the provision of effective and efficient solutions at exceptional value.


Core Values: Professionalism and excellence, Integrity and ethics, commitment to our people.


BDI is dedicated to providing a high-quality security and risk management services to all of its clients. Its services will be carried out in a professional manner to ensure they are delivered in accordance with the needs and expectations of all stakeholders and applicable laws and guidelines.
Our management system has been developed to ensure that our quality framework and associated procedures are carried out with integrity to ensure the highest level of value. We aim to provide clients with the best possible service based on reliability, safety and efficiency.
Our quality system has been designed, developed and implemented across our services to deliver this strategic intent. The system ensures that both the contractual requirements agreed with our clients, and the controls laid down satisfy all our needs and expectations.
The company’s management system is laid down in the controlled documentation of our manual; it covers all aspects of our company’s business. All policies and procedures have been approved by senior management, and is understood by all our personnel, thus ensuring it is implemented at all levels. The whole system is regularly monitored through internal audits and management reviews to safeguard its relevance.


To deliver this, it is our policy is to:
 Consistently apply our professional services to all clients;
 Provide sufficient qualified personnel, and to continually review and where necessary develop the skills and qualifications they may need to provide a high-quality service;
 Conduct regular management reviews and record and measure the learning outcomes.
 Be sensitive to the environment and promote this concept to interested parties;
 Value and promote the concept of continual improvement.

Quality Objectives
In order to fulfil our policy statement and strategic direction, we have produced the following objectives to monitor our quality of services. Our objectives are all designed on the “SMART” model;
 To achieve High standards in service of our clients
 To achieve best ethical practice