HEALTH, SAFETY, ENVIRONMENT
It is the mission of the organization to continually improve our processes, systems, and technology to provide higher product quality, lower costs, and reduced lead time to maximize our customers’ success which we realize is an important Tool for our Sustenance and Growth.
HEALTH, SAFETY, ENVIRONMENT AND QUALITY (HSEQ)
At ROCK Drilling Services FZC, we are committed to provide products & solutions in a safe and responsible manner. Health Safety &Environmental policies are viewed and respected in our entire business activities. Our objective is to achieve efficiency through continuous improvement.
The focus of the management is to ensure that our employees understand the business and take personal ownership in what they do, realizing the impact of our products and services to our customer’s success. Therefore, in order to support the mission of the organization, we will hire qualified employees and provide sufficient training to ensure that they become valuable resources with an outstanding level of knowledge and skills that will set us apart from our competition.
Anti-Bribery Policy
Travel Security Policy
HR and Labour Standards
Code of Conduct
Security Policy
Violence Policy
Anti-Bribery Policy
It is the policy of ROCK DRILLING FZC and its subsidiaries to conduct business honestly and ethically.
We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally,
fairly, and with integrity in all our business dealings and relationships, wherever we operate.
ROCK DRILLING FZC will abide by the anti-corruption laws in every country in which we operate. We
therefore take our legal responsibilities seriously.
What is bribery?
A bribe is an inducement or reward offered, promised, or provided in order to gain any commercial,
contractual, regulatory, or personal advantage. Bribery is intended to influence an individual in the
performance of his duty and incline him to act in a way that a reasonable person would consider dishonest
under the circumstances. For example:
- Offering a bribe You offer a potential customer ticket to a major sporting event, but only if he/she agrees to do business with ROCK DRILLING FZC. This is an offense as you are making the offer to gain a commercial and contractual advantage or to obtain business. It may also be an offense if the potential customer accepts your offer.
- Receiving a bribe A vendor gives your cousin a job but makes it clear that in return he expects you to use your influence within ROCK DRILLING FZC to ensure we continue to do business with them. It is an offense for a vendor to make the offer, and it would be an offense for you to accept the offer as you would be doing so to gain a personal advantage.
- Bribing a foreign official You offer to make an additional payment to a foreign official to alter an administrative process (e.g., access to work visas, when they are limited in number). Because this offer is made to gain a business advantage, the offense of bribing a foreign official is committed as soon as the offer is made.
Gifts and Hospitality
Our policy does not prohibit normal and appropriate hospitality to or from third parties, if the following
requirements are met:
- not made with the intent to influence a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favors or benefits.
- complies with local law.
- does not include cash or a cash equivalent (e.g., gift card, voucher).
- appropriate in the circumstances (e.g., a nominally priced Christmas gift); and
- given openly, not secretly.
Facilitation Payments
Facilitation payments are small, unofficial payments made to government officials for routine government
actions.
If you are asked to make a payment on behalf of ROCK DRILLING FZC, you should always be mindful of what
the payment is for and whether the amount requested is proportionate to the good or service provided. You
should always ask for a receipt detailing the reason for the payment.
Protection Money
In some parts of the world, local gangs offer protection services, which are a form of extortion involving threats of violence. ROCK DRILLING FZC does not pay for protection, and you must report any such requests immediately. If, however, you believe your safety or that of your family or fellow
employees is at risk, act first to ensure safety and then report the request.
Political Donations
ROCK DRILLING FZC does not make political donations of any kind in any jurisdiction. If you wish to make
political contributions, you are free to do so but they must be made in your name with no attribution to
ROCK DRILLING FZC.
Charitable Donations
ROCK DRILLING FZC may, on occasion, make a charitable donation, but it must not be offered to gain a
business advantage and must have senior management’s documented prior approval.
Are there actions you can take?
Record keeping and reporting. It is important that you keep records of all financial transactions including
those that could potentially be interpreted as bribery; this ensures that there is an appropriate paper
trail to refer to in the event of prosecution. Likewise, report any actions to your manager and the
Directors.
Responsibilities for enforcement. Managers are responsible for ensuring their employees are fully
informed of policy requirements and for adopting and enforcing appropriate controls to ensure compliance
with this policy statement.
Travel Security Policy
Purpose
To provide a road transport/air travel system that will enable Rock Drilling FZC to ensure proper
safeguards are in place for all journeys associated with its operations. This document describes the
criteria to be used for all journey planning and provides information to assist in that planning.
Additionally, the methods to be used for monitoring journeys, and the responsible person for each
journey, are outlined here.
Travel for work locations are based on client requirements like contract/call out/work order etc.
In land travel
- Travel within India are planned normally through Indian railways and ticket booking is done by office personnel.
- It is ensured that personnel travelling carry travel tickets and proof of identity.
- Personnel travelling are advised to contact the office on reaching the work location either over phone/e-mail and for normal reporting about job.
- On reaching back, personnel submit relevant documents to the office.
International travel
- For travelling to international locations, country specific visa/safety/vaccinations etc requirements are understood by HR.
- In case of any vaccination’s requirements, it is arranged well in advance.
- Visa is processed well in advance and travel plan is decided.
- On receipt of visa, insurance & travel is arranged as per client requirements.
- The Crew is advised on OHSE requirements and to follow client/country specific safety norms.
- Crew travelling is advised to intimate office on their reaching to destination.
- Crew either call/sends e-mail on status of reaching. If no intimation is received from the crew for any reason, office personnel contact the travelling crew for confirmation of their safe reaching.
Charitable Donations
- Rock Drilling FZC makes every effort to provide resourcesto travelersto ensure their security and health while on travel. Traveler itineraries arranged through our preferred travel agencies.
- Rock Drilling FZC intendsto ensure that all travelers can be contacted in the event of a travel security event (e.g., natural, or man-made turmoil).
- Rock Drilling FZC will only use airlines with a good safety record.
- Rock Drilling FZC will sustain the overall well-being of our business operationsin the event that a catastrophic incident adversely impactssenior managers. To that end, the following combination of travelersshould avoid traveling in the same travel vehicle, which includes cars, buses, commercial aircraft: Any two of Directors
- Rock Drilling FZC intendsfor its travelersto comply with all laws of countries being visited.
HR and Labour Standards
Introduction
Rock Drilling FZC is committed to protecting the human rights of everyone who works for the
company and all those who have dealings with it. As a responsible company, we support the
United Nations Universal Declaration of Human Rights that sets “common standards of
achievement for all people and all nations.”
We recognize that our responsibility for human rights and labour conditions encompasses:
- Operating sites: In developed countries, performance on most of the issues covered in this policy will be required by law. Therefore, this policy is primarily provided to guide operations in those emerging markets where concerns are regularly expressed about human rights.
- Supply chain: I t is our aspiration that the working conditions throughout our supply chain meet internationally accepted standards of human rights and working conditions
Responsibility
We believe that everyone in our organization is responsible for having due regard for human
rights. In particular:
- The Board has overall responsibility for ensuring that human rights considerations are integral in the way in which existing operations and new opportunities are developed and managed.
- Managers and supervisors provide visible leadership that promotes human rights as an equal priority to other business issues. They also have a responsibility for identifying abuses that occur.
- All employees are responsible for ensuring that their own actions do not impair the human rights of others. They are also encouraged to bring forward, in confidence, any concerns that they may have about human rights abuses.
Effecting action
We recognize that from time to time we will encounter challenges on human rights that are
bigger than Rock Drilling FZC is able to tackle alone. Many human rights abuses are systemic in
their host communities. We are therefore committed to working with other organizations that
can help us implement this policy effectively over time.
Policy principles
Rock Drilling FZC requires that all its operating units seek to abide by the following:
Child labour
We will not employ workers under the legal minimum age for admission to work stipulated
by the laws of the countries where we work and will operate in accordance with ILO
conventions No 138 on the minimum age for admission to employment and No182 on the
banning of the worst forms of exploitation of child labour.
Forced labour
In accordance with ILOConventions 29 on Forced Labour and 105 on the Abolition of
Forced Labour, we will not make any use of forced labour, including prison or debtbondage labour. We will not require the lodging of deposits or identity papers, either by
our operating companies or agencies providing employees.
Health and safety
We will provide a safe and healthy work environment and take all reasonable steps to
prevent death or injury to anyone on our sites. Regular training to all our crew on health and
safety issues will be provided. All workers will have access to bathroom facilities and
potable water.
Most aspects of health and safety are covered by the existing Rock Drilling FZC OHSE system.
Freedom of association and the right to collective bargaining
We respect the principles of freedom of association and collective bargaining as defined in
ILO convention No 87 on the freedom of trade unions and the protection of trade union
law and No 98 on the right of organization and collective bargaining.
Discrimination
In accordance with ILOConvention 111 on Discrimination, we will not discriminate against
any person based on race, caste, origin, religion, disability, gender, sexual orientation,
union or political affiliation or age. We will not tolerate sexual or racial harassment or
bullying.
Discipline
We will not employ, or allow to be employed, any form of corporal punishment, physical
coercion, or verbal abuse. Any disciplinary matter will be dealt with through proper
procedures.
Working hours
Working hours in our businesses, including rest days and holidays, are informed by various
applicable statutory bodies and prevailing national laws.
Compensation
Wages paid for standard working hours must meet local legally mandated minimum wage
levels. However, they must also be sufficient to meet the basic needs of workers and their
families.
Living conditions
In sites where dormitory accommodation is provided to our crew, we will ensure
that this accommodation is of an acceptable standard of size and cleanliness; that it is
appropriate to local customs and norms and that adequate facilities are provided.
Implementation
Responsibility
Responsibility for the compliance of Rock Drilling FZC with this policy lies ultimately with the
Board.
Responsibility for the implementation of the policy lies with the Directors who are required to
develop procedures. They will work with Operations personnel who are responsible for the
day-to-day implementation of the policy.
Code of Conduct
Introduction
This Code of Conduct (“Code”) has been adopted by the Directors to maintain the standards of business
conduct for Rock Drilling FZC (“the Company”). The Code is applicable to all the directors of the Company
and all the employees of the Company collectively refereed as ‘Officers.’
The Board appoints the Accounts Manager as compliance officer for the purpose of this code.
The Board of Directors reserves the right to amend, alter or enlarge this Code at any time in line with
relevant legal/other requirements.
The Officers should conduct their activities in line with the following policies laid down by the Code and
adhere and seek compliance thereto:
Principles and Conduct
Honest and Ethical conduct
The Officers shall deal on behalf of the company with professionalism, honesty, and integrity.
Compliance with law
The Officers shall, in their business conduct, ensure compliance with all applicable laws, rules and
regulations, in all the territories in which the Company operates and adhere to the reporting system
thereunder.
Loyalty in employment
In consideration of employment with the Company, Officers have to devote their full attention to the
business interests of the Company. Officers are prohibited from engaging in any activity that interferes with
their performance or responsibility to the Company or is otherwise in conflict with or prejudicial to the
Company.
Conflict of interest
The Officers shall not engage in any business, relationship, or activity, which may detrimentally conflict with
the interest of the company.
Gifts and Donations
The Officers shall neither receive nor offer or make, directly or indirectly, any illegal payments,
remuneration, gifts, donations, or comparable benefits that are intended to, or perceived to obtain business
or uncompetitive favours for the conduct of its business. However, Officers may accept and offer nominal
gifts which are customarily given and are of commemorative nature for special events. In case of doubt,
please speak to the Accounts Manager.
Government Agencies
The Officers shall not offer or give any company funds or property as donation to any government agencies or their representatives, directly or through intermediaries, in order to obtain any favourable performance of official duties.
Equal opportunities within the Company
The Officers shall ensure that equal opportunities are provided to all employees of the Company and all
qualified applicants for employment, without regard to their race, caste, religion, colour, ancestry, marital
status, sex, age, and nationality; and that no discrimination or exploitation is done in this regard.
Health, safety, and environment
The Officers shall strive to provide a safe and healthy working environment, both within the organization and as part of the society and comply, in the conduct of its business affairs, with all regulations regarding the preservation of the environment of the territory the Company operates in.
Use of the Rock Drilling FZC logo
The Officers shall manage the use of the “Rock Drilling FZC” logo in the manner authorized and in the best interest of the Company.
Protection of Assets
The assets of the Company should be employed for the purpose of conducting the business for which they are duly authorized, and they should not be misused.
Confidentiality
The Officers shall maintain confidentiality of information entrusted to them by the Company or any other
information about the Company that comes to them except when disclosure is duly authorized or required
by any law or regulation.
Reporting concerns
The Officers shall promptly report to the management any actual or possible violation of this Code, or any
event he or she becomes aware of that could affect the business or reputation of his/her or the company.
Violation of the Code
The Company will take appropriate action against any Officer whose actions are found to violate the Code or
any other policy of the Company. Disciplinary action may include immediate termination of employment at
the Company’s sole discretion, along with legal action, where necessary. In case the Company has suffered
any losses, it may pursue recovery of such losses against the individuals or entities responsible.
Disclaimer
The Code of Conduct is a statement of certain fundamental principles, ethics, values, policies, and procedure
that govern the Officers of the Company in the conduct of the Company’s business. It is not intended to and
does not create any rights in any way in clients, suppliers, shareholders and any other person or entity.
Security Policy
Our Mission
Security is a vital element of Rock Drilling FZC and key to the success of the company is the protection of the
company’s employees, sub-contractors, assets, information, integrity, and reputation from potential threats.
Rock Drilling FZC’s corporate Security Policy establishes the implementation of and compliance with its
security standards.
Our Approach
Rock Drilling FZC’s core values, code of conduct and business ethics guide our operational and service delivery approach. They include professionalism, respect for employees, sub-contractors, stakeholders, and a commitment to continual improvement. This enables Rock Drilling FZC to provide the most reliable service
without unnecessarily exposing clients or us to security risk. Key is the need to create secure environments and robust processes that can be trusted by clients, stakeholders, and national and international regulatory bodies.
Our Security Principles
Rock Drilling FZC’s security management policy is built upon the following broad security principles:
- The commitment to prevent, avoid and reduce the likelihood and consequences of disruptive or undesirable events.
- To ensure through pre-emptive planning, incidents are rapidly and effectively mitigated, with response plans developed and tested to deal with assessed risks.
- The commitment that security measures and procedures are regularly inspected, validated, and verified to maintain high levels of security standards throughout Rock Drilling FZC’s operations.
- To comply with current applicable legislative, regulatory, and statutory requirements.
- To ensure security policies and procedures are implemented according to the Universal Declaration of Human Rights, international and national laws and the Voluntary Principles on Security and Human Rights.
- To ensure that the professionalism, knowledge, and integrity of those involved in security matters is tightly controlled through establishment and implementation of training, recruitment, and contractual procedures.
- The commitment that all security-related incidents will be reported, recorded and where necessary, corrective action is taken to improve the overall security standard.
Risk Assessment
Central to the security policy is Rock Drilling FZC’s security threat and risk management approach, which
requires the undertaking of threat and risk assessments at key points of the business’s processes appropriate
to the nature and scale of Rock Drilling FZC’s operation. These provide the frame upon which the direction and
conduct of Rock Drilling FZC’s security policy is based and which ensures the protection of both Rock Drilling
FZC’s and our client’s reputations. Care is also taken to protect information belonging to Rock Drilling FZC from
unauthorized disclosure. This applies to all communication including electronic records, paper, and memory
sticks. Similarly, security mechanisms are implemented in all Rock Drilling FZC computer systems to ensure
confidentiality and availability of information. Stringent access controls and audit trails will always be
employed to protect against external and internal threats to Rock Drilling FZC’s systems.
Responsibilities
Secure operations are dependent upon employee and sub-contractor participation, commitment, and accountability in order to create a secure environment that can be trusted by clients and stakeholders. Rock Drilling FZC expects this policy to be adhered to at all times and any willful or deliberate breach will result in disciplinary action. Training and advice will be provided at induction and regularly thereafter to ensure that the security risks and procedures are understood by all. Rock Drilling FZC will ensure a copy of this document
is readily available to all employees and brought to the attention of all its clients and suppliers. Any policy
changes will be reported and communicated by the Director.
Violence Policy
Policy Statement and Coverage
This policy covers all employees and persons under control of Rock Drilling FZC.
Rock Drilling FZC employs and provides services to a cross section of people from diverse social, political, and
cultural backgrounds in providing products and services to our clients. We aspire to recognise and benefit from
the differences in experience and perspectives that our employees bring to the business.
Just as Rock Drilling FZC values diversity in managing investment risk, diversity in the workplace adds value to
our business decisions through different perspectives and experiences. The term diversity in the workplace
recognises that individuals within the workforce differ from each other. As a result, they have a wide range of
different needs, skills, and experiences. Differences between employees are both observable (such as race,
gender, and age) and not immediately apparent (such as marital status, family/parental status, sexual
orientation, political affiliation, religious affiliation, education level, socio-economic status and physical or
intellectual impairments).
Rock Drilling FZC encourages diversity in the workplace because diversity creates:
- Effective adjustment to demographic and cultural changes.
- Effective team membership and increased productivity.
- New approaches and ideas.
- Wider pool for recruitment selection.
- Multi-dimensional corporate image.
- Utilisation of employees’ overseas experience and qualifications.
- Increased access to a diverse market; and
- Increased business opportunities
We aim to give every job applicant and employee a fair go. We recruit and promote on the basis of merit; that is,
the person who is best for the job will get the job.
As an employer, Rock Drilling FZC recognises the rights of individuals and groups to be free from discrimination
and harassment on applicable grounds such as:
Race
Sex
Physical/mental
Colour
Age
Marital status
What is Equal Employment Opportunity (Eeo)?
EEO means that employees are treated fairly and equitably. It means that employees are judged on their ability
to do the job based on merit – skills, qualifications, and experience, rather than assumptions about them
because of different characteristics such as their sex, race marital status, disability, etc. It also means promoting a working environment that is free from sexism, racism, sexual harassment, and other forms of discrimination. This applies to customers, fellow employees, and independent contractors.
EEO legislation deals with three main areas of practical concern:
- Discrimination
- Harassment
- Affirmative action
Discrimination
Discrimination, which includes both direct and indirect discrimination, is essentially any practice that makes
distinctions between individuals or groups so as to disadvantage some or advantage others. Direct
discrimination refers to individual actions or behaviour usually resulting from prejudice or stereotypical thinking.
Indirect discrimination involves instances where certain groups are unreasonably excluded or otherwise
disadvantaged by apparently neutral policies, practices, procedures, or decisions that are unfair or unequal in
their effect.
Rock Drilling FZC will ensure that direct or indirect discrimination on the grounds listed in section 1 of this policy does not occur in its work environment or dealings with the public.
Employees found engaging in discriminatory conduct will be subject to disciplinary action, including termination.
Harassment
Rock Drilling FZC is committed to providing all employees with a harassment-free work environment.
Harassment is a form of discrimination. It consists of unwelcome, embarrassing, unsolicited, offensive, abusive,
belittling or threatening behaviour directed at an individual or group because of some real or perceived
attribute such as a person’s ethnicity, sexuality, or disability in circumstances which a reasonable person, would
have anticipated that the person harassed would be offended, humiliated or intimidated.
Harassment can be any one or more of the following:
- Practical jokes
- Swearing
- Bullying
- A demand or inappropriate request for sexual/romantic favours
- Crude jokes, derogatory comments, offensive messages, or phone calls
- Graffiti with racial overtones
- Name calling, physical threats and offensive gestures.
- Campaigns of hate and silence
- Leering, patting, pinching, touching.
- Displays of offensive posters, pictures, or graffiti
If such behaviour makes an employee feel offended, humiliated, or intimidated, then harassment and/or
discrimination is occurring in the workplace and immediate action is required.
Harassment can occur on the basis of any of the grounds of discrimination.
Any form of harassment in the workplace will not be tolerated. There will be disciplinary consequences for
employees who engage in harassment in the workplace. This may include termination.
Bullying
Work bullying is aggressive behaviour that intimidates, humiliates, and/or undermines a person or group.
Bullying can be defined as the repeated less-favourable treatment of a person by another or others in the
workplace, which is considered unreasonable and inappropriate workplace practice. Examples of bullying at
work may include sabotaging someone’s work or their ability to do their job by not providing them with vital
information, appropriate training and/or resources. Bullying often results from one person or a group needing to
dominate or show superiority over another person.
Any form of bullying in the workplace will not be tolerated. There will be disciplinary consequences for
employees who engage in harassment in the workplace. This may include termination.
Workplace Violence
Violence and aggression include verbal and emotional abuse or threats, and physical attack to an individual or to
property by another individual or group. The impact of violence on a victim depends on the severity of the
violence, his or her own experiences, skills, or personality.
Violent acts include:
- Verbal abuse, in person or over the telephone
- Written abuse
- Harassment
- Threats
- Ganging up, bullying and intimidation
- Physical or sexual assault
- Armed robbery
- Malicious damage to the property of staff, customers, or the business
Workplace violence may not always be a critical or extreme situation from the outset. It sometimes follows a
pattern of escalating behaviour – from agitation, expressed anger or frustration and intimidating body language,
to verbal/written abuse and threats, physical threats, or assault. Violence can be internal to the organisation or
from external sources.
Workplace violence will not be condoned by Rock Drilling FZC and serious disciplinary consequences, including
summary dismissal will apply for offences.
The complaints procedure should be followed in the event of a complaint of workplace violence, however in a
severe instance of violence you are required to immediately remove yourself from the situation and report the
instance to a company manager. The same potential outcomes described in the procedure will apply.
Policy Statement
Rock Drilling FZC is committed to ensuring that the working environment is free from harassment, discrimination, bullying and workplace violence.
Rock Drilling FZC considers all types of harassment, discrimination, bullying and workplace violence to be
unacceptable form of behaviours that will not be tolerated under any circumstances. We believe all employees should be.
treated with respect, fairly and in a reasonable way.
Rock Drilling FZC is therefore committed to ensuring that:
- Harassment, discrimination, bullying and workplace violence complaints are treated seriously.
- Complaints are attended to promptly and confidentially.
- Complaints are investigated impartially.
- Action is taken to ensure that misconduct does not continue; and
- Complainants and witnesses are not victimised in any way.
Equal Opportunity for Women in the Workplace
Affirmative action means the removal of obstacles in employment so that all employees receive the same
opportunities. It is based on the principle of merit, that is, the best person must be employed for the job.
Affirmative action aims to take a positive approach, by attempting to prevent discrimination from occurring in
the first place as well as removing previous causes of discrimination.
In relation to the Equal Opportunity for Women in the Workplace, it is Rock Drilling FZC’s responsibility to
ensure that its employment policies and practices do not discriminate against women and that employment
decisions are based on the principle of merit.
Rock Drilling FZC is committed to ensuring that the organisation’s employment practices, recruitment, selection
and promotion procedures are based on the individual merit of applicants and the inherent requirements of the
job.
Responsibilities of Management and Employees
The management has a responsibility to:
- Ensure that acceptable standards of conduct are observed at all times.
- Promote and model appropriate behaviour.
- Promote the EEO, Bullying and Workplace Violence Policy.
- Treat complaints seriously and ensure that immediate action is taken to investigate and resolve them; and
- Maintain confidentiality principles related to all complaints.
All employees have a responsibility to:
- Comply with the Rock Drilling FZC Discrimination, Harassment and Workplace Violence Policy.
- To refrain from engaging in harassing or discriminating conduct; and
- Maintain complete confidentiality if they provide information to or are involved in an investigation of a complaint.
Complaints Procedure
Rock Drilling FZC’s policy outlines the types of behaviour that are and are not acceptable within the workplace. Our complaints procedure is:
- Impartial Both sides have a chance to tell their side of the story. No assumptions will be made, and no action will be taken until all relevant information has been collected and considered.
- Free of repercussions No action will be taken against anyone for making a valid, truthful complaint or helping someone in making a valid, truthful complaint. Disciplinary action, including possible termination, may ensue against employees who make deliberately false and/or malicious complaints.
- No victimisation The employer will take all necessary steps to ensure that no victimisation occurs against anyone who makes a complaint. Should an employee (the first employee) victimise another employee for making a complaint, the first employee shall be disciplined including as to potential termination of employment.
- Timely All complaints will be dealt with as quickly as possible.
- Completely confidential You can feel secure that if you do make a complaint under this policy, it will remain as confidential as possible. The only people who will have access to information about the complaint will be the person making the complaint, the investigators, and where necessary, the person about whom you have complained. In some situations, some details of a complaint will also have to be told to potential witnesses. Only the people directly involved in making or investigating a complaint will have access to information about the complaint. Employees involved in any way with an investigatory process, including complainants, alleged offenders or witnesses who breach confidentiality requirements explained to them at any time prior to, during or after the investigation process will face disciplinary consequences for their actions; including potential termination of employment.
