Human Rights Policy

1. Introduction.  Hawki is a leading, specialist, international business risk consultancy with capabilities on land, sea and air providing services to governments, humanitarian, corporate and non-governmental organisations (“NGO’s”) operating in an increasingly dangerous and volatile world. Hawki’s range of services include: 
   1. Asset Protection.
   2. Personnel Protection.
   3. Training.
2. These services are delivered wherever the client requires.  Hawki’s primary footprint is in Europe, the UK, Middle East and Africa.
3. Hawki’s Mission.  Hawki’s mission is to help clients conduct their legitimate business around the world, whatever the security risks they face.
4. Employee Standards.
   1. Hawki’s management and employees fully appreciate the value of continuous loyalty both to the Company, their fellow employees and especially their clients for whom they are performing a service.
   2. Hawki’s management and employees are fully briefed upon the importance of possessing confidential information and not abusing that knowledge for personal gain.
   3. Hawki’s management and employees are fully cognisant of the consequences of contravening any law or relevant regulation prescribed in any of the jurisdictions in which the Company operates.
   4. The ethics of all of Hawki’s clients, contractors and partners (whether these are private sector or governmental) is of great importance to the Company. Where an issue is identified between the Company and those with whom, or for whom, Hawki works, it is referred to Hawki’s management for a decision on the future of that arrangement.
   5. Hawki’s management and employees understand the crucial importance of managing their clients’ needs and expectations by analysing, clarifying and matching those needs to the available resources – whilst continually fulfilling and exceeding client expectations.
5. Hawki’s Code of Conduct.
   1. Hawki strongly supports the statement of support to the ICoC and holds that its employees are never to be complicit in human rights abuses.
   2. Hawki does not accept commissions from manufacturers or suppliers of arms equipment.
   3. Hawki does not sponsor manufacturers or suppliers of arms equipment.
   4. Hawki’s employees are not allowed to give or receive any commissions unless authorised by management. Hawki’s employees must declare all gifts over the value of £50 to their Project Manager who, if in doubt, should consult Management.
   5. Hawki will not allow a conflict of interest to arise against any of its core clients where it is discovered that those clients are either engaged in themselves or supporting activities in countries where human rights are known to be being severely breached.
   6. Hawki will not pay bribes or provide inducements for services or information.
   7. Hawki will neither conduct nor sub-contract activities to support or participate in questionable police, military or paramilitary operations in those countries where human rights are known to be being severely breached.
   8. Hawki conducts due diligence on all its sub-contractors for probity and quality. References will be sought before employing sub-contractors.
6. Continuous Audit.  Hawki continually reviews and amends these principles and standards to reflect any changes in the climate and environment in which the Company and its clients operate.
7. Compliance.  Hawki’s employees are required to comply with all laws and regulations of the countries in which they operate and will only work for clients who are prepared to comply with all laws and regulations of the countries in which they have a presence.
8. Quality Control.  Hawki has a fully developed Quality Management System (QMS) Manual and associated compliance procedures.  Hawki’s trained internal auditors regularly conduct internal audits of the QMS and particularly the associated procedures appropriate to contract-deliverables.  The ISO accreditations currently held are:
   1. ISO 9001:2015.
   2. ISO 14001:2015.
   3. ISO 45001:2018.
9. Hawki’s Approach to Human Rights.
   1. General.
      1. Hawki supports human rights and believes that business, as an integral part of society, can make an important contribution to furthering these rights through sustainable economic development.  Hawki’s commitment to human rights is based on its core values of honesty, integrity and respect for people.
      2. Hawki wishes to offer its support to international declarations and standards that were developed to foster human rights, including the UN’s Universal Declaration of Human Rights and the International Labour Declaration of Principles and Rights at Work. 
      3. Hawki recognises its obligation to support employee rights and believes wholeheartedly in the highest level of duty of care towards its employees in the light of increased risks of attacks and kidnapping in some countries.
      4. Hawki has made a specific commitment not to exploit children in any way, either directly or indirectly through joint ventures with contractors or suppliers.
      5. Hawki is committed to its proven policy of maintaining a close-liaison with local communities about human rights in the countries in which we do business.
   2. Contributing to International Initiatives.  Hawki wishes to actively contribute actively to international initiatives aimed at protecting and promoting human rights. These include:
10. The HRCA.  Hawki’s Human Rights Compliance Assessment Tool (HRCA) is designed to assess the compliance of the company in regard to human rights on the basis of some 1,000 indicators that were developed from more than 80 major human rights treaties and conventions including the Universal Declaration of Human Rights.  These indicators are updated regularly to reflect changes in international human rights law.  The HCRA, based upon an integral, six step, human rights analysis system involves the following:
    1. Step one: Country risk analysis.  Every right in the Universal Declaration of Human Rights (and other international standards, such as ILO and World Bank) should be measured against the risks in that country, in both formal laws and practice. 
    2. Step two: Human rights focal areas.  Five to ten areas are identified where the company should refrain from human rights abuses and remain vigilant for abuses by its contractors.  Possible solutions, such as adapting procedures incorporating human rights considerations into legal documentation, are also identified.
    3. Step three: Human rights compliance assessment.  Performance is measured against the Human Rights Compliance Tool using selected indicators.  The company receives a scorecard on its performance.
    4. Step four: Strength, weakness, opportunities and threats (SWOT) analysis and Action Plan.  Follow-up action is identified and prioritised to address key issues.
    5. Step five: Stakeholder dialogue.  Key stakeholders are invited to review findings and discuss the action plan.
    6. Step six: Reporting.  In the interests of transparency Hawki will be expected to report externally on the results of its human rights performance.
11. Torture.  Every human being has a right not to be tortured or treated in an inhuman way.
    1. Jurisdictions.  There is an absolute ban on torture and other cruel, inhuman or degrading treatment and outrages upon personal dignity under international humanitarian law (IHL) and international human rights law (IHRL).
       1. UK.  In the UK, human rights are protected by the Human Rights Act 1998.  The Act gives effect to the human rights set out in the European Convention on Human Rights.
       2. Worldwide.  The prohibition of torture and other forms of ill- treatment derives from the Geneva Conventions of 1949, their Additional Protocols of 1977, the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment of 1984, and other international instruments.  Both IHL and IHRL converge and complement each other in establishing a comprehensive legal framework for the prevention and punishment of acts of torture and other forms of ill-treatment.
    2. Article 3.
       1. Article 3 covers the specific aspect of right not to be tortured or treated in an inhuman or degrading way is one of the rights protected by the Human Rights Act.
       2. Article 3 states that a person must not be tortured or treated in an inhuman or degrading way.  Article 3 protects individuals if they have suffered ill-treatment which is very severe.  Whether something is severe enough to be a breach of Article 3 depends on the circumstances of the case - for example:
    3. Inhuman Treatment.  Inhuman treatment is ill-treatment which causes a person severe mental or physical suffering.  The ill-treatment doesn't have to be deliberate or inflicted on purpose.
    4. Degrading Treatment.  Degrading treatment is treatment which is grossly humiliating or undignified.  Very severe forms of discrimination or harassment could be degrading treatment.
    5. Duty To Take Positive Steps.  Article 3 also imposes a positive obligation on public authorities to protect individuals from serious ill-treatment by other individuals.  Examples on when Article 3 could be used are:
       1. Serious physical or mental abuse.
       2. Inhuman detention conditions – for example, in police cells, mental health hospitals or in prison.
       3. Use of excessive force on patients or detainees.
       4. Serious neglect in a care home or hospital.
       5. Malnutrition and dehydration.
       6. The deportation of someone to a country where there is a real risk of torture, inhuman or degrading treatment.