Reference Number	SUL-HRM-MN-02-2024
Document Title	Grievance Policy and Procedure
Version Number	03
Document Status	Active
Effective Date	25/07/2024
Published document	Download here

Introduction

Saracen (U) Ltd is committed to ensure that all Staff co-exists harmoniously amongst themselves and with the clients whom we serve. We have developed this Grievance Policy and Procedure through a consultative process that was guided by the legal provisions including;

• The Constitution of the Republic of Uganda (1995) Chapter 4- Protection of Fundamental Rights and Freedoms
• The Human Rights Act 2006
• The Prevention and Prohibition of Torture Act (2012)
• Employment Act (Amendment 2016),
• Occupational Health and Safety Act and Provisions within regulations for Workers safety

The process of developing this policy engaged legal minds including the Chief Compliance and Legal Officer, the Chief Operations Officer, External consultants of labour management, conflict resolution and organisational management.

Saracen Uganda Limited handles a multitude of persons more than 6000 employees with differing character, skill sets, and experience, all dealing with very sensitive issues relating to security provision. We appreciate the fact that differences are bound to occur during the course of work and these should be resolved amicably and without unreasonable delay.

We have considered the following as some of the issues that may cause grievances:

• Work relations within and among staff
• Structural or Organization change
• Terms and Condition of employment Bullying or Harassment
• Health and Safety
• Changes to working practices
• Work environment and relations with clients
• Discrimination or ill treatment by supervisors or clients

Saracen (U) Ltd encourages free communication between Employees to ensure that questions and problems arising during employment can be aired and, where possible, resolved informally. The policy provides for protection of aggrieved persons to anonymously report any actions or mistreatment.

Policy Objectives

• To ensure that rights and privileges of employees are protected
• To ensure that grievances are addressed as they occur to maintain harmony at work
• To provide aggrieved employees machinery through which their grievances are addressed while providing protection and confidentiality to the aggrieved
• Ensure that disciplinary action is taken against the perpetrators as per company provisions in the Human Resource Manual

Policy Application

This policy applies to all Saracen Uganda Limited employees and subcontractors, consultants, service providers and persons discharging their duties within the premises manned by Saracen Uganda Limited and that may affect employees of the company.

Definition of a Grievance

A grievance or complaint for purposes of this policy and procedure is defined as an allegation of improper or illegal conduct, which has occurred or is about to occur, associated with acts by an individual or group of individuals.

‘Improper or illegal conduct’ includes acts or omissions that would violate the principles contained in the Laws of Uganda to which we subscribe and the general and overall provisions of The Code (International Code of Conduct). Complaints may allege potential or actual violations, or raise concerns that involve forms of improper or illegal conduct.

Categories and Types of Grievances

Saracen has categorised grievances to include the following categorisation for ease of management during handling.

Individual grievances: Related to personal issues which may be limited to the individual aggrieved and ideally of a personal nature. The examples here may include harassment, segregation, discrimination against the individual.

Group grievances: These may be conditions that may be affecting more than one member of staff but specific to an issue that may be resolved through intervention of the Grievance Committee.

Types of Grievances or their specific examples include the following and are assessed as such:

• Discrimination: unfair treatment based on age, sex, race, religion, or other protected characteristics.
• Harassment: unwelcome behaviour, comments, or actions that create a hostile work environment.
• Unfair treatment: unequal application of company policies, rules, or procedures.
• Communication breakdown: poor or lack of communication leading to misunderstandings or errors.
• Workload and work-life balance: excessive workload, unrealistic expectations, or inadequate support.
• Promotion and career development: unfair promotion practices, lack of opportunities, or inadequate training.
• Pay and benefits: unfair compensation, inadequate benefits, or incorrect pay calculations.
• Health and safety: unsafe working conditions, inadequate equipment, or poor ergonomics.
• Bullying: repeated behaviour intended to intimidate, degrade, or humiliate.
• Unprofessional behaviour: unprofessional conduct by colleagues or supervisors, such as gossiping or favouritism.
• Lack of resources: inadequate tools, equipment, or support to perform job duties effectively.
• Unfair discipline: unjustified or disproportionate disciplinary actions.
• Conflicts with coworkers or supervisors: interpersonal conflicts or disagreements.
• Changes in job duties or responsibilities: unilateral changes without consultation or agreement.
• Lack of recognition or appreciation: inadequate acknowledgment of contributions or achievements.

Procedure for Grievance Management

Stages of Grievance Handling Process

The Grievance handling process of Saracen takes guidance from the ICOCA Manual for Developing and operating fair and accessible company grievance mechanisms that offer effective remedies.

Our Management team undertakes to provide means for ensuring that the following guiding principles are not breached;

• Registration of Complaints through a protective system that allows anonymity if preferred.
• Assessment of complaints and determining whether they should be considered as grievances for the CGM management and investigation of complaints.
• The company puts in place remedies for the grievances through our disciplinary committee if necessary as detailed in our Human Resources Manual.
• If the grievances are of nature that requires dialogue with the aggrieved parties and aggressor, management through the Chief of Staff arranges the dialogue and the issues are resolved.
• Records are kept with the Grievance handling /Disciplinary Committee files and on personnel files for the individuals involved.

Reporting Information on Grievances

Work related grievances of simple nature that may be managed by the supervisor at site or immediate line manager may be reported by aggrieved staff.

There may be instances where the circumstances prefer reporting of the grievance in anonymity. At this stage, Saracen Uganda Limited has provided a hotline number 0800220580 in which case, the issue is recorded in real-time by control room operator and channelled to the Chief Executive Officer.

We have also developed a system that provides for anonymity through the suggestion boxes at each of our stations and field offices. Keys to the suggestion boxes are kept by the Chief of Staff, who will within routine trips on a monthly basis extract the written issues and handle them in confidence on a case-by-case basis.

Evaluation of Grievances and Complaints

Management of Saracen Uganda Limited has structures in place for evaluation of Grievances in order to guide whether they qualify to be heard or may simply be based on hearsay or personal vendetta against individuals or a system.

The Process of evaluation of Grievances is overseen by the following;

• Chief Executive Officer (CEO) as Chairperson- The CEO may designate an alternate to oversee this process.
• Chief Operations Officer (COO).
• Chief of Staff (COS)/Head of the Human Resource Department.
• Chief Security Operations Officer (CSOO) or designated authority in cases of security operations.
• Chief Legal and Compliance Officer (CLCO)- to give legal opinions on the decisions being made by the team.
• QHSE Manager and/or Compliance Manager may be co-opted in case of QHSE Matters.
• Employee and Industrial Relations Officer and/or Public Relations Officer (PRO) may be co-opted in relevant cases.

Informal Grievance management

In cases where the grievance may be handled informally and resolved by simply speaking to aggrieved parties, the grievance may not need to be formally written but shall be recorded for purposes of future reference.

Formal Grievance Management

• If an employee is unable to resolve the grievance informally, or if the matter is so serious to be dealt with informally, the employee should set out details of his or her complaint or grievance in writing and submit to his or her immediate supervisor and copy to the Head of Department (unless the employee is complaining about the supervisor then he or she should forward the complaint straight to the Head of Dept.) who will call the two parties and try to resolve the matter.
• A fair hearing will be called by the Disciplinary/Grievance Handling Committee and a ruling should be given within five (5) working days with a copy to the COS.
• If the grievance is not resolved, the matter may be referred to the next management level (Department Head).
• At this stage, the Manager appealed to, will convene a meeting to
• review the grievance and the complaint’s Manager’s response.
• The complainant may choose to be accompanied by a colleague. The Manager will hear the case and confirm his or her decision in writing within five (5) working days.
• If the matter is still not resolved, the complainant may appeal to the CEO unless he or she has already handled the complaint in which case, the appeal should go to the COS. A copy of the appeal should be sent to the CEO for independent opinion.
• The CEO will investigate the grievance to give an independent opinion.
• The COS will resolve the matter but may refer grievance to the Grievance handling and/or disciplinary committee for hearing and final ruling at its discretion.
• If the grievance is deemed to be collective e.g. Branch or Departmental staff, the matter will be channelled through the staff representative or Branch Manager and the grievance process outlined above will be followed.

Protection against Retaliation

Saracen Board and management appreciates the fact that in many cases, the aggrieved parties may need to be protected from their aggressors and/or colleagues with whom misunderstandings have occurred. In view of this , we have developed a Whistle Blowers Policy which caters for the provision of anonymity for staff and clients and members of the public that may be aggrieved.

Disciplinary Measures

Disciplinary measures shall be applied in cases where grievances are evaluated and assessed and concerned parties heard fairly leading to a decision to take disciplinary action. The Disciplinary actions and penalties are prescribed in the Human Resources Manual.

Referrals to External Authorities

Saracen Uganda Limited operates within the legal provisions and regulatory framework for the private security organisations in Uganda. These regulations provide that when a criminal office or any offence that is against the law and code of practice for Private Security Organisations is committed, it shall be reported to the Uganda Police Force. Saracen therefore refers cases that are criminal in nature to the nearest Police.

Saracen Uganda Limited has an internal investigations department licensed by Uganda Police and conducts investigations into grievances and reports the same to the police for collaboration of facts.

In case of grievances of social nature, we refer these to the Ministry of Gender, Labour and Social Development which has structures that operate at every subcounty and district within which we operate.

Record Keeping and Accessibility

All matters arising out of the Grievance handling process shall be minuted and records securely kept with copies of the outcomes on the personnel files of the aggrieved persons and the aggressor (s) for a period not exceeding 5 years.

We have ensured to provide means of access to the grievance policy and procedures by availing them on the cloud which is accessed by all staff employed by Saracen. We also train them on all policies at the point of recruitment and ensure that they sign a personal undertaking to commit to their understanding of the procedures.

Public Complaints System and Toll free line

We have set aside a publicly accessible hotline for reporting of any incidents of abuse of human rights, misuse of arms and excessive use of force by any of our staff.

This is a toll free line is open 24 hours for reporting of incidents directly to our control room and customer care department. The toll free line is 0800220580.

Approval

This revision of the Saracen Uganda Limited Grievance Policy and Procedure has been authorized and approved by Management on the 25th day of July 2024.