1. Purpose of the procedure

ANTICIP is committed to delivering high quality security services according to high standards of ethics, practice, honesty, accountability and openness. We have a mechanism in place that allows our staff, customers and third parties alike to report grievance situations in the workplace, or to report allegations of malpractice, unethical behaviour, or improper and illegal conduct, such as a violation of ANTICIPs code of practice or the International Code of Conduct for Private Security Providers.

The purpose of this procedure is to ensure that, as far as possible, grievances are dealt with and resolved as a matter of urgency and in confidential manner that is respectful to both the complainant and the respondent.

Grievances are concerns, problems or complaints raised by an employee, customer or third party and must be made in writing to the employees line manager or contracts manager (in the case of a customer) or Company President (in the case of a third party), or submitted through this website.

However, before using this grievance procedure it is expected that an employee or customer/third party will try to resolve their complaint informally if at all possible with their line-manager or the company in the case of a customer/third party. The formal stage of the procedure should only be used when the informal stage has failed to resolve the issue or is not making progress at reasonable speed.

Where this is not possible to directly resolve the grievance or issue, staff and third parties may consider using an independent party to help resolve the problem. This may not need to come from outside the organisation but could be an internal mediator, so long as they are not involved in the grievance issue. In some cases, an external mediator might be more appropriate. In appropriate cases ANTICIP will offer facilities for mediation and provide for translation and clarity if needed.

If we receive a complaint falls within the jurisdiction of an official investigation or is deemed as a legal matter, ANTICIP has a duty to, and shall, cooperate fully with the all law enforcement agencies, legal entities, human rights agencies and/or any other official investigation. Whether this involves a member of staff/client/third party, the complainant will be informed that ANTICIP is conducting an official investigation and the complainant will be contacted by our legal department in order to pursue and investigate the complaint.

2. Employee Principles

ANTICIP welcomes employees raising concerns or problems about improper conduct, malpractice and unethical behaviour and that all grievances will be dealt with in a confidential manner. Employees will not be penalised or disciplined for genuine grievances or concerns raised against ANTICIP and its staff.

The appropriate protection will be given to any employee(s) during the whole grievance process. Any form of bullying, harassment, intimidation or unfair discipline will not be tolerated and disciplinary action will be taken in accordance with ANTICIP’s discipline policy.

Reference to the Human Resources department (HR) is recommended in all internal proceedings, whether informal or formal, should, as far as practicable, remain confidential and a formal record of a hearing will be available to the employee. The hearing will be recorded and a copy given to the employee. The timescales set out may be extended with the agreement of the parties involved. Any grievance must be made in writing as soon as possible and in any case, within one month of the act that is being complained of.

Where more than one employee has lodged a complaint relating to the same, or substantially of the same issue, the complaints may be dealt with together in the interests of fair and consistent decision-making. In some circumstances, it may be more appropriate for the complaint to be resolved through the collective agreement of the parties involved and ANTICIP.

Where an internal grievance concerns an apparently trivial issue the line manager will discuss this informally with the member of staff to determine whether there is a real need to pursue the matter through the grievance procedure. If the member of staff and line manager are unable to agree, the line manager will decide, with the advice of HR whether the matter is trivial. If the grievance is determined to be trivial, the employee will be informed that the matter will not be dealt with through the grievance procedure. The employee will be entitled to resubmit the grievance together with any further evidence or explanation that throws new light on it, and demonstrates that a substantive complaint is in fact being made.

If the employee’s grievance restates a complaint that ANTICIP is already dealing with, or that it has dealt with in the past, the employee will be asked to explain how the new grievance differs from the previous one, and either what new incident has occurred or what new evidence has come to light. Where it is clear that there is nothing new being raised, ANTICIP can reject the grievance without a hearing.

Deliberately false or malicious grievances will be treated as matters of misconduct and will be investigated in line with the disciplinary policy and procedure.

Grievances raised while an employee is subject to disciplinary proceedings will be heard when the disciplinary process has been completed. If the grievance has any bearing on the disciplinary proceedings, it can be raised in the course of those proceedings.

3. Employee Procedure (Informal Stage)

3.1 If an employee has a complaint that involves another employee or other employees, they should first of all try to resolve the matter by direct approach to the employee or employees involved.

3.2 If the matter remains unresolved, the employee may request a meeting with their own line manager who will try to resolve the issue. The meeting should be held within 10 working days of the submission of the request.

3.3 If, after any action to resolve the grievance taken by the line manager, the employee is still dissatisfied, they may proceed to the formal stage of the procedure.

3.4 If the complaint is against the line manager or there is another reason why the employee does not wish to raise it with their manager they should seek advice from HR on how to deal with the complaint.

4. Employee Procedure (Formal Stage)

4.1 If the complaint has not been resolved at the informal stage and the employee wishes to proceed to the formal stage, the employee may do so and the complaint will be heard by a panel. The employee must set out in writing the nature of their complaint and the reasons why they are dissatisfied with the outcome of the informal stage. The employee should explain how they think it should be settled.

This must be submitted to the ANTICIP HR Manager. Grievances raised against members of the Project Management Team should be submitted to the CSO and grievances raised against the CSO should be submitted to the Company President. In all cases a copy of the grievance should be sent to HR.

4.2 Should the complaint relate to a process or decision, the HR Manager will appoint an appropriate investigating officer who will be asked to provide a full written report together with any relevant documents. The investigation should be conducted as quickly as possible while allowing for all relevant information and evidence to be gathered. A timescale for this will be agreed between the employee and HR.

4.3 Should the complaint be against a named individual or individuals, the HR department will give them a copy of the complaint at the earliest opportunity. The individual will present their response at the hearing and it would not normally be necessary to conduct an investigation. The individual(s) will be advised of the conduct and discipline policy at this stage.

4.4 The panel will consist of an ANTICIP senior manager (Executive Manager) and another Project level manager with a member of HR to advise. Grievances submitted by members of the Project Management Team will be heard by the CSO and a member of Executive Management. Where possible, there should be a gender balance on panels. ANTICIP will make every attempt to ensure that the hearing will be held within 10 working days of receipt of the investigating officer’s report, or within 10 working days of the complaint being received if it is against an individual.

The employee will be given five working days’ notice that the hearing is to be held. The employee may request an alternative date to allow up to an additional five working days if their representative is unavailable. If following a reasonable attempt to rearrange the hearing, the employee is still unable to attend, they may send a representative, or the hearing may be held in their absence

4.5 The complainant should ensure that they attend the meeting at the specified time. If they are unable to attend because of circumstances beyond their control, they should inform their line manager and/or the chair of the panel if the grievance is against their line manager, as soon as possible. If they fail to attend without explanation, or it appears that they have not made sufficient attempts to attend, the hearing may take place in their absence

4.6 Any relevant written information or evidence must be made available to all parties at the earliest opportunity and, in any case, two working days before the hearing.

4.7 All parties involved will be allowed to attend and make representations at the meeting. Witnesses may be called.

4.8 Refusal of either party to attend shall not invalidate the proceedings.

4.9 The panel, in seeking to resolve the complaint, may adjourn the meeting or defer a decision if more information is required.

4.10 The decision of the panel, reasons for that decision and any redress will be communicated to the employee who has made the complaint. Where the complaint is against an individual, both parties will be given a copy of the decision. This will be handed to the employee whenever possible or given to a pre-authorised/approved nominated person.

4.11 Failure to meet the requirements of redress set out by the panel will result in the invocation of the disciplinary policy and procedure, unless an appeal has been lodged

5. Right of appeal

5.1 Should the complainant wish to appeal against the decision of the panel they must do so, in writing, to the HR Manager within five working days of being informed of the decision.

5.2 A request for an appeal must specify the grounds of the appeal preferably under one or more of the following headings:

• the nature of any redress
• the finding of the hearing on a point of fact which is pertinent to the decision of the hearing
• a failure to adhere to the published procedure.

5.3 A member of the original panel will attend to present their findings and reasons for their decision. The employee and the management representative presenting the case should use the guidance attached at Annex 1 and Annex 2 as best practice for the presentation of their respective case statements. Witnesses may be called.

5.4 The appeal will be heard by the CSO or nominated deputy and another manager with a member of HR to advise. An appeal to a grievance raised by a member of the Executive Management be heard by the Company President and selected other senior managers.

5.5 The complainant should ensure that they attend the meeting at the specified time. If they are unable to attend because of circumstances beyond their control, they should inform their line manager as soon as possible. If they fail to attend without explanation, or if it appears that they have not made sufficient attempts to attend, the hearing may take place in their absence. 5.6 The appeal is not a rehearing of the original grievance, but rather a consideration of the specific areas with which the employee is dissatisfied in relation to the original grievance. The chair of the panel may therefore confine discussion to those specific areas, rather than reconsider the whole matter afresh. 5.7 The panel will hear all or part of the previous hearing depending upon the nature of the appeal. The panel has the scope to:

• Uphold all or part of the previous decision
• Not uphold the previous decision.

5.8 If the panel decides either to uphold only part of the previous decision or not to uphold the previous decision, it may at its discretion substitute an appropriate remedy of its own choosing.

5.9 Within three working days of the appeal the panel will record the decision and hand it to the employee wherever possible.

5.10 Any recommendations made by the panel will be notified to the appropriate individuals, and will be time bound. Failure to meet the requirements of the panel will result in the invocation of the Disciplinary policy and procedure.

5.11 The decision of the appeals panel is final.

6. Customers & Third Parties

6.1 If a grievance or issue relating to service delivery is raised by a customer, this can be reported directly to their ANTICIP contract manager or person responsible for providing the service, or directly on the website using the link provided in section 1 of this procedure. All matters will be treated in strict confidence.

6.2 If a grievance or whistleblowing issue needs to be raised by a third party, then this can be reported either in writing to the ANTICIP President to the address on the website or submit the details using the link provided in section 1 of this procedure. All matters will be treated in strict confidence.

6.3 If the issue cannot be resolved directly by those nominated above, a full investigation will take place which may require the customer or third party to provide further evidence in writing to their respective counterparts. In such cases, ANTICIP President chair the investigation with the HR Manager, CSO and corporate staff, and legal department if required.

6.4 It is anticipated that any investigation should take no longer that 10 working days to complete and the complainant/whistleblower will be informed accordingly. If however, ANTICIP requires more time to conduct the investigation then this will be promulgated accordingly.

6.5 On completion of the investigation, ANTICIP will disclose its findings and take the necessary course of action such as corrective action procedures, preventative measures or report the incident to the law enforcement agencies if any criminal act has been suspected or committed. Any breach in the ICoCA code of practice will be reported immediately to ICoCA including full details of the report.