Communication on Progress

  • 2015/04/24
Time period
  • April 2014  –  April 2015
  • Stand alone document – Basic COP Template
Differentiation Level
  • This COP qualifies for the Global Compact Active level
  • Includes a CEO statement of continued support for the UN Global Compact and its ten principles
  • Description of actions or relevant policies related to Human Rights
  • Description of actions or relevant policies related to Labour
  • Description of actions or relevant policies related to Environment
  • Description of actions or relevant policies related to Anti-Corruption
  • Includes a measurement of outcomes
  • Statement of continued support by the Chief Executive Officer
  • Statement of the company's chief executive (CEO or equivalent) expressing continued support for the Global Compact and renewing the company's ongoing commitment to the initiative and its principles.

  • 24th April 2015

    To our stakeholders:

    I am pleased to confirm that Pilgrims Group Limited (PGL) reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

    In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

    Sincerely yours,

    William Freear

Human Rights
  • Assessment, policy and goals
  • Description of the relevance of human rights for the company (i.e. human rights risk-assessment). Description of policies, public commitments and company goals on Human Rights.

  • PGL is full committed to the Universal Declaration of Human Rights and the Voluntary Principles on Security and Human Rights (VPSHR) and a member of the International Code of Conduct Association (ICoCA).

    In this reporting period PGL rolled out its policy on the VPSHR for its operations in Iraq and Afghanistan and in 2015 propose to roll out the policy for its operations in Algeria and Nigeria.

    Human rights issues and abuse of Human Rights forms an integral part of our company risk assessments for all our areas of operations.

    PGL Human Rights Policy (VPSHR) - see below:

    Voluntary Principles on Security and Human Rights

    Pilgrims Group complies with international human rights standards and abides by international humanitarian law. The company fully supports the UN Voluntary Principles on Security and Human Rights. Pilgrims is not a signatory or participant, because the principal signatories are governments, originally the USA and the UK, with support from key NGOs and international observers, such as the International Committee of the Red Cross (ICRC), who participated in the formulation of the principles which were also formally supported by the world’s leading companies, including BP, BHP, ExxonMobil, Shell, Statoil and a few others. Pilgrims recognises the constructive role our staff can play in advancing the goals in these UN Voluntary Principles; and also uses as a reference those principles incorporated in the later Montreux Document, produced by the ICRC, which has similar goals and guidelines; and the company supports the principles and work of the ‘Geneva Centre for the Democratic Control of Armed Forces ( )’, which was established by the Swiss government and is supported by 52 other member states, and which, in seeking to illustrate patterns of behaviour in corporate obligations, has produced a draft Code of Conduct for private military and security companies which Pilgrims entirely subscribes to.
    In summary, Pilgrims is committed to adhere to all laws, rules and regulations which apply in the countries where our staff work and strives to exceed both international and industry best practices. Our documented policies and employee handbook for sites govern and direct our staff behaviours in all our workplaces, inside the UK and abroad. Specifically, Pilgrims is compliant and audited annually to meet BS7499:2007 ‘Static site guarding and mobile patrol service Code of Practice’, the company is an approved contractor in the UK’s Security Industry Authority Approved Contractor Scheme, and ensures that its foreign operations match the same standards.
    Professional proficiency
    All our personnel are fully vetted and screened, and the majority of the security operatives we select are ex Special Forces, so are highly trained professionals with extensive experience in hostile environments.
    Use of force
    All our personnel are required to abide by our Rules of Engagement, which state that in all situations the minimum force necessary should be used and that firearms must only be used as a last resort. All incidents are required to be reported immediately and an inquiry carried out where necessary. In Iraq, Pilgrims Group operates in accordance with the instructions in MNF-I Fragmentation Order 08-641 (Rules for the Use of Force and Graduated Force Response procedures for armed DOD contractors, civilians and Private Security Companies) and we constantly monitor and liaise with relevant authorities to ensure we are aware of any changes or amendments in laws applicable to Rules of Engagement.

    The local community
    Pilgrims Group has been built upon the UK Special Forces ethos of winning the “hearts and minds” of the local population in the areas we operate in. We aim to integrate as many qualified local personnel into our security teams as we can, offering robust training programmes and high quality management, and ensuring that they receive good rates of pay and are treated well. Our expatriate personnel have an understanding and respect of local customs and at all times must show respect to local communities.
    Reporting procedures
    Pilgrims Group encourages personnel to report any abuses of human rights, and we have in place a Confidential Reporting Policy to provide all employees with ready access to a safe and effective means of reporting any matters regarding the Company and/or its employees, no matter how serious, in the full knowledge that the report will be dealt with in the strictest confidence and they will be protected against any detriment. Should any allegations relating to human rights be made, a full investigation will be carried out and allegations forwarded to the relevant law enforcement authorities where applicable.

  • Implementation
  • Description of concrete actions to implement Human Rights policies, address Human Rights risks and respond to Human Rights violations.

  • PGL operate a no blame culture and encourage all staff and contractors to report any breach of policy through our whistle blowing procedure.

    PGL recognise the rights of individuals to freely report their grievances without fear of repercussions. Our grievance policy is given below:


    As an employer, we know that problems and tensions can arise between people at work and that, if such issues are not dealt with and resolved quickly, they may well get worse rather than better. Accordingly, we have established our Grievance Procedure, the use of which is open to all members of staff at any time during their employment with us. The purpose of the procedure is first to allow an employee freely to express a complaint or matter of concern and then, where appropriate, to try and resolve the issues raised by means of a discussion and negotiation or, if necessary, counselling or training. The procedure is not intended to prevent an issue being resolved informally without a written record, but if an employee should wish to have a grievance formally investigated and recorded, he/she may so request. Therefore, whilst the following explanation of the various levels of the Grievance Procedure should be seen as the route to be followed in most cases, it is not essential that all levels are used on every occasion.
    This procedure exists to give employees a means of raising a grievance they may have with the minimum possible delay. There are 3 levels to the procedure.
    Level 1
    An individual employee wishing to raise an issue with which he is directly concerned should discuss the matter in the first instance with their Line Manager.
    Level 2
    If the matter cannot be satisfactorily resolved at this point, the employee shall raise the matter with the next level of management, or if that level is a Director, then the matter should be raised to an alternative director.
    Level 3
    Should the matter still not be resolved, the employee shall refer the matter to the Managing Director, who shall be the final arbiter in this procedure.
    Employees must set down their grievance in writing at all levels. All employees are entitled to be accompanied at any grievance hearing by a work colleague of their choice.

    PGL Corporate HR Manager is responsible for company HR policy and its implementation. HR management is a line management responsibility and lead by our Country Directors and Managers in our overseas areas of operation.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates performance.

  • In this reporting period PGL rolled out its policy on the VPSHR for its operations in Iraq and Afghanistan and in 2015 propose to roll out the policy for its operations in Algeria and Nigeria.

    All Human Rights violations are investigated by senior management and an action plan developed and tracked to closure; including review at monthly and quarterly executive management meetings as appropriate.

    PGL has not been the subject of any investigations related to Human Rights during this reporting period.

  • Assessment, policy and goals
  • Description of the relevance of labour rights for the company (i.e. labour rights-related risks and opportunities). Description of written policies, public commitments and company goals on labour rights.

  • PGL HR Manual clearly sets our employees rights and responsibilities and their compensation and benefits.

    The HR Manual and supporting employee handbooks are provided to all new employees on induction, including a briefing by HR staff and acknowledgement of the employee's understanding of the policies and procedures.

    PGL recognises the potential impact of labour related risks in all our areas of operations and such risks are assessed and mitigated in our routine risk assessments.

    PGL HR Manual covers the following areas:

    Table of Contents
    1. Purpose 7
    2. Recruitment Process Flowchart 8
    2.1 Placing and Logging a Vacancy 9
    2.1.1 Vacancy Notice Request 9
    2.1.2 Head Office Vacancy Notice Request 9
    2.1.3 Recruitment Advertising Log 9
    2.2 Advertising 9
    2.2.1 Free advertising:- 9
    2.2.2. Agencies:- 10
    2.2.3 Newspapers & Websites:- 10
    2.3 Staff Referral Bonus Scheme 10
    2.4 Application Forms 11
    2.4.1 Site Applications Analysis:- 11
    2.5 Site Applications 11
    2.5.1 Incoming Website Applications 11
    2.5.2 Incoming Email Applications 11
    2.5.3 Incoming Fax or Postal Applications 11
    2.5.4 Saving Applications for Operations Managers 11
    2.6 Head Office Applications:- 12
    2.7 Site - Stage 1 Initial/Telephone Interviews 12
    2.7.1. Site - Stage 2 Face to Face Interviews 12
    2.7.2 Invite to Interview 12
    2.8 Head Office Face to Face Interviews 13
    2.8.1 Invite to Interview 13
    2.9 Retention of Interview Notes and Documentation 13
    2.10 Verbal Offer of Employment 14
    3. Screening BS:7858 15
    3.1 5 Year Telephone Screening Check 15
    3.1.1 Summary of the PASS team 15
    3.1.2 Overview 15
    3.1.3 Saving Documentation 16
    3.2 Checking 5 years employment/unemployment history 16
    3.2.1 Employment Gaps Note 16
    3.2.2 Educational Establishment Notes 16
    3.2.3 Self Employment Notes 17
    3.2.4 Unverifiable Gaps – When can a Statutory Declaration be used? 17
    3.2.5 TUPE 17
    3.2.6 Verbal/Written Confirmation 17
    3.3 Character References (CRs) 17
    3.4 Required Original Documentation 18
    3.5 SIA Licence 18
    3.6 Right to Work 18
    3.7 Carrying out the credit check 19
    3.7.1 CCJS & Bankruptcy 20
    3.7.2 Telephone Screening Timescales 21
    3.7.3 Screening Team pass to Sign Off Team 21
    3.7.4 Input onto TimeGate 21
    3.8 Failed Screening 21
    3.9 Additional Screening /The Security Watchdog 22
    3.9.1 Site’s who require additional screening for all new Permanent employees 22
    3.9.2 Authorisation and Documents from Candidates 22
    3.9.2 Once you have received all the relevant documentation, you will need to: 23
    4. New Employee 23
    4.1 Offer Letters and Contracts 23
    4.1.1 Security Officer Starter Pack 23
    4.1.2 Casual Worker Starter Pack 24
    4.1.3 Head Office Starter Pack 24
    4.2 Setting up a P File 25
    4.2.1 P-Files must contain the following information as a minimum: 25
    4.3 New Employee Information Checklist: 25
    4.3.1 Analysis and ID Number 25
    4.3.2 SIA Licence Tracker 25
    4.3.3 Probationary Tracker 26
    4.3.4 Joiners-Leavers Spreadsheet 26
    4.3.5 Job Evaluation – Head Office Employees Only 26
    4.3.6 Bank Details & P45/P46 passed to Accounts Manager 26
    4.3.6 Visa Spreadsheet 26
    4.3.7 Outstanding Documents and Screening Status 27
    4.3.8 TimeGate Updating 27
    4.4 The ID Card 27
    4.5 Payroll Information 28
    5. Head Office Permanent Employee Immediate Benefits 28
    5.1 Health Cover/Life Insurance 28
    5.1.1 Employees 28
    5.1.2 Senior Management Team 28
    6. 5 Year Written Screening Check 29
    6.1 Overview 29
    6.1.1 Saving Documentation 30
    6.2 Template Letters 30
    6.2.1 Previous Employers 30
    6.2.2 Educational Establishments 30
    6.2.3 Self-employment 30
    6.2.4 Character References 30
    6.3 Completion of 12 Week Screening 31
    6.3.1 Permanent Staff 31
    6.4 Failure to complete 12 Week screening 31
    6.4.1 Failure to completed 12 week screening for TUPE Employee 31
    7. During Employment 31
    7.1 Head Office Company Induction 31
    7.1.1 Head Office Training Record 31
    7.2 Probationary Process 32
    7.2.1 Head Office Employees 32
    7.2.2 Permanent Site Employees 32
    7.2.4 TUPE Transfer Employees 32
    7.3 Annual Leave 33
    7.3.1 Site Employees 33
    7.3.2 Head Office Employees 33
    7.4 Sickness Absence 33
    7.4.1 Self Certification (Section 9.3 in the Employee Handbook) 33
    7.4.2 Doctors Fit Notes (Section 9.4 in the Employee Handbook) 34
    7.4.3 Return to Work Interviews (Section 9.2 in the Employee Handbook) 34
    7.4.4 Receiving Self Certificates and Return to Work Interview Forms from Site Employees 34
    7.4.5 Receiving Doctors Fit Notes from Site Employees 34
    7.5 General Letters / References 34
    7.5.1. General Letters 34
    7.5.2 References (Employment and Personal) 34
    7.6 Right to Work – Anniversary Points for employees working under a Visa 35
    7.6.1. Visa Spreadsheet 35
    7.6.2 Immigration and Visa Folder Contents 35
    7.6.3 Visa Information Folder 35
    7.6.4 Initial Right to work checks 35
    7.6.5 Biometric Residence Permit Card 36
    7.6.6 Unlimited leave and right to abode 36
    7.6.7 Student Visas 36
    7.6.8 Limited leave to remain 36
    7.6.9 Documents required to be seen for employees/casuals workers with a current valid Visa at the anniversary point 37
    7.6.10 Documents required to be seen for employees/casuals applying for a new visa at the anniversary point 37
    7.6.11 Validity of Original Documentation 38
    7.6.12 Photocopying Passports 38
    7.7 Monthly reporting/analysis 38
    7.8 Annual Reporting/Information Updates 39
    7.9 Employee Benefits 39
    7.9.1 Head Office Employee Benefits 39
    7.9.2 Pension - Permanent Head Office Employees 39
    7.9.3 Pension - Permanent Site Employees 39
    7.9.4 TUPE Employees 39
    7.10 Change of Employee Details 39
    7.10.1 Change of Bank Details 40
    7.10.2 Change of Address 40
    7.11 Medical Appointments 40
    8 Disciplinary Issues 40
    8.1 Disciplinary Procedure 40
    9. Grievance Issues 40
    9.1 Grievance Procedure 40
    10. Company Doctor 41
    11. Leaver Processing 41
    11.1 Exit Interview 41
    11.2 Calculating Final Payment and Deductions 41
    11.3 Reference Requests Made By Future Employer 42
    11.4 Re-Employment 42
    11.5 Payroll Information 42
    12. TUPE Transfers 42
    12.1 Incoming Contract 42
    12.2 New Employees / During Employment 43
    12.3 Outgoing Contract 43
    13. Company Handbook and Policy Documents 43
    13.1 Sight Testing and Provision of Glasses for VDU Use 43
    14. Company HR, Employment and Business Support 44
    14.1 A Brief Overview of XpertHR 44
    14.2 Obtaining advice from XpertHR Helpline 44
    15. General 45
    16. SIA Information 45
    17. Retention 46

  • Implementation
  • Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.

  • PGL Grievance Procedure - see below:


    As an employer, we know that problems and tensions can arise between people at work and that, if such issues are not dealt with and resolved quickly, they may well get worse rather than better. Accordingly, we have established our Grievance Procedure, the use of which is open to all members of staff at any time during their employment with us. The purpose of the procedure is first to allow an employee freely to express a complaint or matter of concern and then, where appropriate, to try and resolve the issues raised by means of a discussion and negotiation or, if necessary, counselling or training. The procedure is not intended to prevent an issue being resolved informally without a written record, but if an employee should wish to have a grievance formally investigated and recorded, he/she may so request. Therefore, whilst the following explanation of the various levels of the Grievance Procedure should be seen as the route to be followed in most cases, it is not essential that all levels are used on every occasion.
    This procedure exists to give employees a means of raising a grievance they may have with the minimum possible delay. There are 3 levels to the procedure.
    Level 1
    An individual employee wishing to raise an issue with which he is directly concerned should discuss the matter in the first instance with their Line Manager.
    Level 2
    If the matter cannot be satisfactorily resolved at this point, the employee shall raise the matter with the next level of management, or if that level is a Director, then the matter should be raised to an alternative director.
    Level 3
    Should the matter still not be resolved, the employee shall refer the matter to the Managing Director, who shall be the final arbiter in this procedure.
    Employees must set down their grievance in writing at all levels. All employees are entitled to be accompanied at any grievance hearing by a work colleague of their choice.

    PGL is a signatory member of the VPSHR and a member of the ICoCA.

    Management of Human Rights issues is a line management responsibility, included in this is the management responsibility to ensure all their staff are aware of and comply with the company's Human Rights policy.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates performance.

  • PGL is an equal rights employer and does not differentiate in any way between applicants.

    All applicants are selected based upon their suitability and competence to fulfil the post in question.

    PGL are not under any investigation for Human Rights or Labour related issues and have not been under investigation for such behaviours during the reporting period.

    PGL has been ISO 9001 certified for 10 years and is proud of its record of having zero non-compliance reports during this period.

  • Assessment, policy and goals
  • Description of the relevance of environmental protection for the company (i.e. environmental risks and opportunities). Description of policies, public commitments and company goals on environmental protection.

  • PGL is a strong advocate of sound environmental practices and all our operations apply best practice environmental management principles, including recycling at all our facilities.

    All our risk assessments consider environmental risks as key areas to be mitigated.

    PGL Environmental Policy - see below:


    Record of Amendments

    Amendment No Date Signature


    Chapter Title Page
    1 Environmental Policy Statement 4
    2 Key Environmental Legislation 5
    3 Environment Policy 7
    4 Environmental Audit 10
    5 Waste Management & The Duty of Care 12
    6 Water Pollution 16
    7 Integrated Pollution Control (IPC) & Air Pollution Control 18
    8 Ozone 19
    10 Contaminated Land 20
    11 Environmental Incident Reporting 22
    12 Oil Storage and Handling
    13 Emergency Procedures 28
    14 Environmental Contact Details 29


    Pilgrims and individuals are responsible for preventing pollution and compliance with Environmental regulations and to be seen to be a responsible neighbour that cares for our surroundings and the Environment as a whole.

    We are committed to ensuring that a framework exists to control our working practices so that they have the least damaging effect on our Environment.

    Pollution Prevention is the key if we are to be successful, this can be achieved by:

    • Minimising waste production, which will in turn REDUCE the amount of waste we generate and save costs as well as protection of the Environment,
    • REUSE, RECYCLE & RECLAIM waste products if at all possible,
    • RESPONSIBLE WASTE Management ensures that we comply with relevant legislation.
    • DISPOSAL in accordance with Duty of Care requirements ensures that all waste is disposed of in the proper manner.
    • MINIMISE CO2 emissions through responsible management of equipment.

    The impact which Pilgrims may have on the environment can therefore be greatly reduced and can only contribute to our success if we adopt the above principles into everything we do within the company.

    William Freear

    The following is a list of some relevant current environmental legislation applicable within the United Kingdom. The full text of these regulations can be obtained from Pilgrims House.

    Although this legislation applies to the UK it should be regarded as industry best practice and implemented throughout Pilgrims.

    Waste Management

    • Control of Pollution (Amendment) Act, 1989
    Regulates the Registration system for carriers of waste.

    • Environmental Protection Act, 1990
    Controls and regulates on complete life cycle of waste from production to final disposal. Acts as enabling Act for other Env Regs.

    • Environmental Protection (Duty of Care) Regulations, 1991 and Statutory Code of Practice on Duty of Care.
    Introduced Waste Duty of Care, which says that you must take all reasonable steps to keep waste safe. If you give this waste to someone else you must be sure that they are authorised to take it and are authorised to transport, recycle or dispose of it safely. (Not applicable to waste from your home but does include household waste from commercial or industrial premises.)

    • Waste Management Licensing Regulations, 1994 (amended 1995 and 1996)
    Defined Directive Waste and introduced a new licensing system for waste treatment and waste disposal operators.

    • Special Waste Regulations, 1996 (amended 1997)
    Introduced a new definition of Special Waste and also a requirement to have a waste consignment note system for movements of Special Waste and new restrictions on mixing different types of waste.


    • Water Resources Act, 1991
    Imposes a general prohibition on discharges to controlled waters. Re-specified system of discharge consents subject to conditions relating to quality and character of discharge. Introduced a general water pollution offence where it is an offence to cause or knowingly permit polluting matter to enter controlled waters.

    • Water Industry Act 1991
    Consolidated legislation relating to the supply of water and sewerage services. Controls on the 10 Water and 15 Water & Sewerage Companies in the UK (‘The Water Industry’)


    • Environmental Protection Act, 1990
    Introduced a dual system of pollution control whereby the most polluting processes require prior authorization under integrated pollution control (IPC) and others fall under local authority air pollution control (LAAPC). Introduced the legal requirement to use Best Available Techniques not Entailing Excessive Cost (BATNEEC) and the Best Practicable Environmental Option (BPEO). Will be phased out in favour of IPPC & BAT

    • Environmental Act, 1995
    Established the Environment Agency and introduced measures to enhance the protection of the Environment in particular the prevention and remediation of water pollution.

    • Pollution Prevention and Control Regulations 2000
    Introduces Integrated Pollution Prevention and Control (IPPC) which will be phased in over 7 years and will replace IPC (see above). Permit from the EA or the LA if intending to operate a prescribed process. (Aircraft painting). Introduced the concept of Best Available Technique (BAT) which replaces BATNEEC & BEPO.

    • Environmental Protection (Applications, Appeals and Registers) Regulations, 1991 (amended 1996)
    Lays down the information requirements for IPC and LAAPC applications, establishes the need for statutory consultation and requires the Environment Agency (EA) to impose specific conditions on process authorisations. Specifies the conditions under which an appeal may be made and imposes a duty on the EA and local authorities to establish public registers.

    • Environmental Protection (Prescribed Processes and Substances) Regulations, 1991 (amended 1994 and 1995)
    Defines which processes or substances are to be controlled by the IPC legislation and which fall under APC. (Being replace by IPPC Regs 2000)


    Environmental Protection Act 1990

    Environment Act 1995

    Contaminated Land Regulations 2000


    It is the responsibility of Management to ensure that all staff reporting to them have read and understood the Pilgrims Environmental Policy. They must also ensure that all contractors and suppliers are aware of this policy.


    Environmental Impact

    Pilgrims identifies the environmental impacts of its activities and assesses their significance through a system of site environmental audits.

    Environmental audits are conducted by Pilgrims management.

    Statutory requirements

    Pilgrims management are responsible for understanding and reviewing Environmental Statutory requirements including codes of practice, agreements with public authorities and non-regulatory guidelines that are applicable to Pilgrims activities..

    A list of relevant environmental legislation and regulations is contained in this manual. Guidance on these may be obtained from Pilgrims House.



    All Employees

    All staff are responsible for safeguarding, as far as they are able, both their working environment and the greater environment surrounding Pilgrims operations. This includes:

    • Complying with environmental standards and procedures as set out in this Policy
    • Notifying management and supervisors of potential Environmental Hazards using the procedures set out in the Environment Policy
    • Avoiding needless wastage of energy and materials.

    Line Management

    All line managers, in relation to activities under their individual control, are responsible for identifying and ensuring compliance with environmental regulations affecting our environment. Line managers must:

    • establish individual responsibilities, objectives and accountabilities for subordinate staff in environmental matters,
    • develop and maintain procedures to protect the working and external environment,
    • monitor implementation of procedures and working practices and take swift and appropriate steps to put environmental non-conformances right,
    • provide communication channels for employees and contractors to be consulted on environmental matters
    • investigate and report all environmental incidents and near misses and take necessary follow up actions,
    • review regularly the use of materials and energy in order to reduce waste, optimise recycling and select materials compatible with environmental objectives,
    • Maintain accurate and comprehensive records of waste disposals and other discharges to the environment.

    General Manager

    Authority for environmental matters is devolved through the GM who is responsible for:

    • periodic assessments, audits and reviews of facilities and operations to ensure compliance with environmental statutes and this policy,
    • provision of support and advice on environmental matters throughout Pilgrims,
    • promoting workable procedures, codes of practice and working co-operatively in emergencies,
    • encouraging initiatives for implementation of the Pilgrims Environmental policy,
    • active co-operation with government, local authorities and other external bodies, to provide an informed and constructive background to regulatory processes,
    • keeping staff, relevant authorities and, as appropriate, the public informed of our efforts to protect and improve the environment,
    • Interpreting and ensuring implementation of this policy, and updating it as required.

    Training, awareness and competence

    Line managers are responsible for identifying the environmental training needs of the staff under their supervision and ensuring that all personnel whose work may create a significant impact on the environment have received suitable and sufficient training.
    Line managers must ensure that all employees under their supervision are aware of:
    • the importance of compliance with the environmental policy and procedures
    • The significant environmental impacts, actual or potential, of their work activities, the potential consequences of departure from specified operating procedures and the impact this could have on the environment.

    The key documents for raising staff awareness on these issues are:
    • Pilgrims Environmental Policy
    • Pilgrims Health & Safety Policy

    Environmental Management Documentation

    The following documents form the core for Environmental Management within Pilgrims:
    • Pilgrims Environmental Policy
    • records of permits, consents and authorisations
    • local emergency plans
    • Environmental accident and incident records
    • Staff training records
    • environmental audit and review documentation


    a. POLICY

    Pilgrims will undertake an annual Environmental Audit reviews of all its major facilities as part of its commitment to continual improvement in environmental performance.


    In general the Audit process aims to:
    • identify and assess relevant environmental issues
    • check compliance with Pilgrims Environmental Policy as well as statutory requirements (both current and forthcoming) and industry best practice
    • assess the appropriateness of management arrangements for dealing with identified environmental issues
    • identify training and awareness requirements
    • identify opportunities for improvement in practice and saving of materials, energy and water
    • make prioritised recommendations for action to achieve compliance and other improvements within designated timescales


    Each Audit involves a site visit, guided tours, interviews with key personnel and the acquisition of background information such as legislation, codes of practise and site plans.

    Environmental Technical issues covered may include:

    • use, handling and storage of hazardous substances
    • effluent discharge
    • atmospheric emissions and control
    • waste management and disposal
    • energy use
    • housekeeping, visual impact and litter

    Management issues covered may include:
    • policy and management structure
    • identification and evaluation of significant environmental issues
    • development and implementation of environmental programmes
    • training and awareness
    • communications
    • monitoring and auditing,
    • information, reporting and document control


    a. RESPONSIBILITIES FOR Environmental Management System DOCUMENTS

    H,S & E Department

    • Review and updating Environmental audit documentation.
    • Review and updating of the Pilgrims Environment Manual.

    Line Managers

    • Local operational procedures with regards to environmental impacts, e.g. Spill control measures
    • Records of permits, consents and authorisations if applicable.
    • Local monitoring records (discharges, waste disposal) if applicable.
    • Local inspection, calibration and maintenance records.
    • Local accident and incident records.
    • Local training records.


    Line Managers are responsible for ensuring that all documents which form part of the Environmental Management System and which are identified with activities under their control conform to the following:.
    1) Documents must be stored in a recognised and known location
    2) They must be legible
    3) They must be dated, including dates of revision
    4) They must be maintained in an orderly manner, with revisions incorporated promptly
    5) They must be retained for a minimum of two years
    6) The current versions of relevant documents must be available at all locations.

    • Pilgrims Environmental Policy.
    • Waste Transfer Notes and Special Waste Transfer notes.
    • Trans Frontier Shipment (TFS) transfer notes
    • Discharge Consents.
    • Authorisations to undertake a prescribed process.

    5 WASTE MANAGEMENT and the Duty of Care

    a. POLICY
    In addition to complying with the relevant national and international legislation on waste management, it is Pilgrims policy to promote waste minimisation, reuse and recycling. Line managers should regularly review the use of materials and energy in order to reduce waste. Final disposal (landfill, for example) should be considered as the least preferred option.

    The Waste Hierarchy
    1. preferred option is to REDUCE waste production
    2. next best solution REUSE, RECYCLE & RECLAIM waste products if at all possible
    3. last resort RESPONSIBLE DISPOSAL in accordance with Duty of Care requirements.

    Waste: Any substance or object which Pilgrims discards or is required to discard. In practical terms this means anything which has fallen out of the normal cycle of commercial activity. Waste from Pilgrims is usually defined as industrial or commercial waste. Materials for recycling are also defined as waste.
    examples: General office waste, food waste, scrap metal, pallets.

    Special Waste: Certain types of waste, which are potentially environmentally hazardous and difficult or dangerous to dispose of. Waste is considered special if it is:
    • one of the 250 substances listed in the EC Hazardous Waste List and has one of 14 listed properties which qualify a chemical as dangerous;
    • a prescription only medicine;
    • a liquid with a flashpoint of 21°C or below;
    • any highly flammable, irritant, harmful, toxic, corrosive or carcinogenic substance.
    examples: Waste from electroplating, chemical processes and aircraft painting such as paints, thinners, paint strippers, oils, various acids, alkalis and bulk effluent slurries. This includes empty tins or other containers used for the original products.

    Clinical Waste: Waste which consists wholly or partly of human or animal tissue, blood, body fluids or excretions or swabs, dressings, syringes, needles or other sharp instruments, which unless rendered safe maybe hazardous to a person who comes in contact with it; or any other waste arising from medical, nursing, dental, veterinary, pharmaceutical or similar practice.
    examples Medical and dental waste, needles and other sharps, waste from aircraft toilet maintenance and toilet service unit maintenance and any associated contaminated cleaning materials and clothing.

    c. Managing Waste – The DUTY OF CARE

    The Environment Protection (Duty of Care) Regulations 1991 and the Statutory Code of Practice imposes a ‘duty of care’ on anyone who produces, stores, carries, disposes, imports, treats or brokers waste, to take reasonable steps to prevent the illegal disposal, treatment or storage of waste and to ensure:
    • against the escape of any waste,
    • that waste is only transferred for disposal to an authorised person
    • that an adequate description and documentation of the waste is given to anyone to whom the waste is transferred.

    It is a criminal offence to breach the duty of care, irrespective of whether damage is caused. It is the failure to take reasonable steps that is the offence, which carries the punishment of an unlimited fine.

    It is Pilgrims responsibility to ensure that waste is only transferred to an authorised person, or to a person for authorised transport purposes, with an accompanying description which enables subsequent holders of the waste to fulfil their Duty of Care.

    Authorised person is a person who will be one of the following
    • Waste collection authority
    • Someone who is the holder of, or who has an exemption for, a waste management licence
    • Someone who is registered, or who has an exemption for registration, as a carrier of controlled waste

    It is the responsibility of Pilgrims the ‘WASTE PRODUCER’ to ensure that any waste we generate is handled by an authorised person and it is important that we:-
    • Check that the waste collector is authorised to carry waste and is registered, copies of registration certificates can be obtained from the Environment Agency
    • Check that the Waste carrier is registered to carry the type of waste produced.
    • Check that we know where the waste is going and that it will not escape en route. This will involve ensuring that skips are covered, adequately securing drums and taking any other measures to prevent spillage in transit.


    This is household, commercial or industrial waste. It can be from a house, school, hospital, shop, office, factory or any other trade or business. It may be liquid, solid, scrap metal or even a scrap car. It does not have to be hazardous or toxic to be controlled waste.


    Certain wastes are considered to pose a potential risk to the environment and require special handling and treatment. A waste is classified as special if it has hazardous properties such as flammability, toxicity or is corrosive for example and as such has a more stringent system of control to ensure that it is handled and disposed of properly.

    Special waste movements are controlled and recorded using official Special Waste documentation, which must be supplied to the relevant enforcing authority before the waste is moved. In the UK, the top copy of a set of consignment notes are sent to the Environment Agency, the remainder travel with the waste and record subsequent transfers of the waste, i.e. carrier to final disposal.


    Transported hazardous are subject to legislation covering the classification, packaging, labelling and transportation of dangerous goods. They also require a waste transfer note which is completed by the waste removal firm and given to Pilgrims as a record of waste transfer and disposal.


    Line managers are responsible for ensuring that:
    • Procedures are established for the disposal of all waste and recycling materials including specific procedures for special, and clinical, wastes,
    • Staff and service partners have been provided with adequate information, equipment, training and supervision before handling Pilgrims waste,
    • The possibility of reuse, recycling or pre-treatment is investigated where waste cannot be avoided.
    • It is expressly forbidden to allow solid or liquid waste materials to be discharged into foul or surface water drains, unless approval has been obtained from the relevant authorities,
    • All waste and recycling materials leaving Pilgrims are transferred to a licensed waste carrier.
    • All waste is treated and disposed of at appropriate treatment and disposal facilities.
    • All documentation on waste movements must be retained (in UK: Waste Transfer Notes for 2 years and Consignments Notes ( for Special Waste) for 3 years),
    • A written description of the waste is provided to handling/disposal contractors.

    IOM Waste disposal.

    Special waste must only be disposed of through the IOM Government Trans Frontier Shipment (TFS) process

    All staff have a part to play in ensuring Pilgrims waste is handled and disposed of in accordance with government and local regulations and the company requirements. This includes:
    • Taking all reasonable steps to avoid or minimise the use of packaging and the generation of waste,
    • Avoiding the mixing of different types of waste. In particular, special and clinical waste must be kept separate from other wastes.
    • Keep waste in appropriate, well-maintained containers that are securely stored.
    • Label waste correctly.

    a. POLICY

    In addition to complying with the relevant national and international legislation on water pollution control and with the conditions of any discharge consents applicable to its activities, it is Pilgrims policy to minimise the discharge of solid, liquid and gaseous emissions that could be harmful to the environment.


    Discharge consent: A permit granted by the Environment Agency to allow surface water or treated process effluent to be discharged to controlled waters.

    Trade effluent agreement: A permit granted by the local sewerage undertaker to allow producers to discharge trade effluent to public sewer. The permit will set limits on the temperature, volume and chemical constituents of the discharge.

    IPC Authorisation: An operating licence granted by the EA for certain prescribed processes or for use of prescribed substances. The terms of the authorisation may specify conditions regarding discharges to public sewer, in addition to those specified by the sewerage undertaker. (To be replaced by IPPC)

    Controlled waters: Surface water (ponds, lakes, rivers and estuaries), groundwater and territorial waters up to three miles offshore.

    Trade effluent: Any liquid waste matter produced within the course of trade or industry.

    Special category effluent: Trade effluent, which contains prescribed substances requiring authorisation.


    As a line manager you should ensure that you comply with the following requirements
    • Ensure any discharge of waste contain details of any effluents produced within your area of responsibility together with details of their correct disposal routes.
    • Local procedures contain details of any discharge consents, authorisations or trade effluent agreements applicable to effluents produced within your area of responsibility.
    • Information is made available to all employees and contractors working within your area of responsibility whereby they must be informed of the correct disposal routes for all waste effluents.
    • Procedures are developed for responding to emergency spillages or accidental discharges to sewer along with any local Airport Authority Instructions.

    a. POLICY

    In addition to complying with the relevant national and international legislation on pollution control and the terms and conditions of any authorisations and consents for discharges, it is BA CitiExpress policy to seek to minimise the discharge of solid, liquid and gaseous emissions to the environment.

    Prescribed substance: any substance listed in the Environmental Protection (Prescribed Processes and Substances) Regulations 1991 (as amended) whose release into the environment is to be controlled.
    Prescribed process: any industrial process listed in the Environmental Protection (Prescribed Processes and Substances) Regulations 1991 (as amended).
    BATNEEC: Operators of prescribed processes are required to use the Best Available Techniques not Entailing Excessive Cost to minimise the release of substances to the environment. Guidance on the BATNEEC for any process can be found in IPR series or PG series guidance notes.
    BPEO: The Best Practicable Environmental Option is that which “provides the most benefit, or least damage, to the environment as a whole, at acceptable cost, in the long as well as the short term”. The Environment Agency is required through consultation to establish what is the BPEO for any process falling within the scope of IPC.


    Line managers must ensure local procedures direct employees to:
    • comply with the conditions of authorisations and consents applicable to their areas of activity
    • comply with any enforcement or prohibition notice or any inspector’s requirement
    • maintain accurate and comprehensive records of any discharges to the environment
    • report breaches of compliance limits to line management in order that the relevant regulatory authorities can be notified


    Any applications for which require a process authorisation whether under IPC / LAAPC / IPPC must be handled through the H,S & E Department.
    8 OZONE

    a. POLICY

    In addition to complying with the relevant national and international regulations on the use of ozone depleting substances, Pilgrims aims to take all reasonable precautions to reduce and prevent, where possible, the emissions of ozone depleting and greenhouse gases into the atmosphere. The use of alternatives, substitution, improved working methods and recycling shall be utilised where it is deemed cost effective.

    b. PHASE OUT

    Production of the following ozone depleting substances has been phased out under the Montreal protocol:
    • Chlorofluorocarbons (CFCs)
    • Halons
    • Carbon Tetrachloride
    • 1,1,1-Trichloroethane
    • Hydrobromofluorocarbons.

    The EC has set a phase out date of 2015 (with interim reductions) for Hydrochlorofluorocarbons (HCFCs). The Montreal Protocol has a phase out date for use of Methyl Bromide by 2005. This has yet to be reflected in EU legislation.


    Line managers should identify any ozone depleting substances or equipment containing such substances used within their area of responsibility. Substitution should be considered.
    • New refrigeration equipment should not contain CFCs or HCFCs.
    • Existing equipment containing CFCs should be fitted with leak detection equipment and purge control devices.
    • Equipment containing CFCs or HCFCs will remain in service until such time as it requires replacement.

    a. POLICY

    Persons acting on behalf of Pilgrims should ensure that environmental issues are identified and adequately addressed when acquiring or disposing of land or facilities.

    Under existing requirements it is the responsibility of the owner or occupier of land or premises to bear the cost of any clean up works required to return contaminated land back to use.

    Disposal of assets must be conducted so as to minimise damage to the environment and prevent any liability for future claims on environmental grounds.


    Before any land is acquired for use it should be assessed to ascertain any levels of contamination this must be undertaken with the assistance of the H,S & E Department and will involve a gathering of information and an Environmental Assessment produced to include:
    • Site History
    • Site investigation
    • Subsequent Environmental Hazard Assessment
    • Remediation techniques if necessary

    Guidance notes published by the Department of Environment Food and Rural Affairs (DEFRA) detail the scope and content of environmental statements and consultation procedures.


    Gathering of information to ascertain perceived levels of contamination is essential and may be gained from the following sources.
    • Previous Owners or Occupiers
    • Staff you have been in long term employment
    • Land Register from the Land Registry
    • Hydro-geological maps from the Environment Agency (EA) (England & Wales) or Scottish Environmental Protection Agency (SEPA) available at
    • Planning conditions from Local Authority Councils
    • Lease conditions from landlords consent
    • Soil or water surveys
    • Contaminated Land Register at the EA


    As the cost of remediation of any contaminated land is extremely expensive it is essential that the extent of any contamination is ascertained before property is purchased:
    • Identify the previous use of the land.
    • Identify hydro-geological conditions (potential for pollution) if applicable.
    • Establish nature and location of previous potentially polluting processes.
    • Establish processes requiring authorisation or consent from a regulatory body.
    • Establish the extent of any soil or water monitoring.
    • Identify any areas of soil or water that may have been contaminated in the past.
    • Identify planning conditions or conditions of leases previously applicable.
    • Prepare an environmental statement for all projects where there is potential for significant environmental impact.
    • Assess the project against the concept of ‘suitable for use’.


    Planning Guidance PPG23 Planning Policy Guidance: Planning and Pollution Control (1994) highlights the need to be aware of the previous use of land in considering development plans. Where contamination is suspected, developers should investigate the land to determine what remedial measures are necessary to ensure its safety and suitability for the proposed purpose - ‘suitable for use’.
    Guidance based on the ‘suitable for use’ principle on the redevelopment and after-use of contaminated land is provided by DEFRA’ Interdepartmental Committee on the Redevelopment of Contaminated Land (ICRCL).


    The Environment Protection Act 1990 (Part IIA), contains the legislative framework for identifying and dealing with contaminated land in England (similar requirements apply in other countries). And further updated by the Contaminated Land Regulations 2000.
    In England, Local authorities have a duty to identify contaminated land within their area, and if the land is identified as contaminated, determine whether the land is a ‘special site’, i.e. severely contaminated. Land is identified as ‘contaminated’ under the new regime if:
    • significant harm is being caused or
    • there is a significant possibility of significant harm being caused
    • pollution of controlled waters is occurring or
    • there is a significant possibility of controlled waters being contaminated.

    Those sites identified as ‘special sites’ will be the responsibility of the Environment Agency, while all other sites will be the responsibility of the local authority. Once ‘contaminated land’ or ‘special sites’ have been identified, the owners, occupiers and other appropriate parties are notified that this is the case. A consultation period of three months then takes place, which usually ends with the issuing of a remediation notice which may impose

    • Obligations on the recipient to assess the land, undertake works on the land to clean up the contamination and monitor the land after it has been remediated.
    • The responsibility for remediating the land will lie with the person who caused or allowed the polluting substances to be present in the first place. If this person cannot be found, the notice may be served on the current owner or occupier of the land. Where more than one person is deemed to have caused the polluting substances to be present, liability may be apportioned.

    g. COMPANY REQUIREMENTS to prevent Land Contamination

    Line managers are responsible for ensuring that:
    • Arrangements are in place to prevent spillages and leaks from process activities an operations from entering the ground.
    • Report all spillages according to the procedure detailed in this manual.
    • Where contamination of the ground is suspected, this should be notified to the H,S & E Department who will evaluate the need for site investigations.
    • Where soil is known to be contaminated, the need for remediation will be established by reference to Property and H,S & E Department using the principle of ‘suitable for use’.
    • Records of site investigation soil sampling and water analysis will be retained for an indefinite period.


    It is essential that where an Environmental Incident has occurred it must be reported and investigated thoroughly, this will enable management in conjunction with the H,S&E Department prevent it happening again.

    Pilgrims Accident and Environmental Incident Report Form.

    All Environmental incidents must be reported using the Pilgrims Accident and Environmental Incident Report Form (Attached) within 7 days of the incident.
    You must complete as much information about the event as possible at the time and forwarded to the H,S &E dept.
    A copy must be kept for your departmental records and the original sent the H,S& E Department

    Serious Environmental Incident

    In the event of a serious Environmental Incident such as
    • spillage of over 5 litres of Oil
    • The rupture of any Oil tank or Drum.
    • The collapse of a bund surrounding an Oil storage area.
    • Evidence of leakage from a Bund or Oil storage area.
    • The leak of any amount of oil, hydraulic fluid, paint or solvents into a drain, sewer or water course.
    • The unexpected combustion of any toxic material.
    • The rupture or overspill of any Septic Tank or Cesspit
    • The collapse of any drain or sewer
    • The contamination of any water source by any material likely to cause an Environmental Hazard.

    Immediately telephone the following personnel;
    General Manager - 07932 750057
    Contract Development Manager – 07789 153930
    Operations Manager – 07951 588302

    use additional sheet if required AGE Tel No

    TIME LOCATION (eg. IOM,BRS, MAN) SUB LOCATION 1 (eg Building / Airside/ Ramp/ Pier) SUB LOCATION 2 (floor/room/stand/road etc)

    STRUCK AGAINST MINOR An injury requiring first aid with an immediate return to work
    STRUCK BY SERIOUS An injury where full recovery and return to normal duties can be expected in time
    TRAPPED MAJOR Injury involving permanent disability and preventing return to normal duties
    UNSAFE LOAD FATAL Self Explanatory
    OTHER (Specify in Text) Clean up
    SIGNED (Originator) NAME (Print) TITLE Tel No DATE
    WHAT INVESTIGATION HAS TAKEN PLACE AND BY WHOM? (e.g. interviews, site visit, photographs)
    WHAT CAUSED THE INCIDENT ? (state primary cause(s) and any contributory factors identified - e.g. training , procedures, equipment design, congestion)
    I confirm that:- 1. the above action has been / will be taken to prevent recurrence of this type of accident.
    2. all statutory and company documentation has been completed.
    3. this report has been passed to person responsible for recording in BASIS SIGNED (INVESTIGATING MANAGER)

    Tel No

    Any additional information should be enclosed on a separate sheet

    NOTE:- You are required to send this copy to the HS&E Department and to keep a photocopy for local records and audit purposes

    12 OIL STORAGE AND HANDLING (Including Waste Oil)


    Pilgrims is committed to the prevention of environmental damage from Oil pollution and we are committed to the prevention of Pollution during the storage and handling of Oil.

    Oil is toxic to plants and animals and a small amount of Oil can devastate river life by forming a thin film on the water surface which stops oxygen getting to plants and animals. Oil, which is spilt on the ground, can pollute underground water supplies making them unfit for drinking purposes.

    Oil Storage & Bunding Requirements.

    Where Oil is stored the following standards must be adhered to.
    • Tanks, Drums or other containers must be strong enough to hold the Oil without leaking or bursting.
    • Oil containers must be positioned away from vehicle traffic to avoid damage from collision
    • A Bund or drip tray must be provided to contain any oil leaks from the container or any of the ancillary pipework and equipment.
    • The Bund must be large enough to contain 110% of the maximum contents of the container.
    • Where more than one container is stored, the bund must be capable of storing 110% of the largest container or 25% of the total storage capacity, whichever is the greater.
    • The bund base and walls must be impermeable to water and oil and checked regularly for leaks.
    • Any valve, filter, sight gauge, vent pipe or other ancillary equipment must be kept within the bund when not in use.
    • It is forbidden to fit a drainage valve to any bund for the purpose of draining rainwater.
    • Any above ground pipework must be properly supported along its length.

    Oil Storage Tanks.

    Before the installation of any new Oil storage facility is implemented the HS&E Dept must be consulted.

    Standards for construction of Oil storage tanks are contained within the Environment Agency: Pollution Prevention Guidelines (PPG2) Above Ground Oil Storage Tanks.

    Safe Storage and Disposal of used Oils and lubricants.

    Pilgrims has a ‘Duty of Care’ to dispose of waste and in particular Waste Oil as it is one of the most polluting substances and is therefore treated as ‘Special Waste’. It must be disposed of through a licensed special waste contractor in accordance with the Special Waste section of this Policy. It is a criminal offence not to do this.

    Storage of used Oils and lubricants.
    The same requirements for safe and secure storage are needed for Used Oils as for new Oil (See Above).

    Emergency procedures must be formulated at all bases where Pilgrims operate this will include any processes which could have an impact on the environment. Adherence to local Airport Authority Instructions and the contents of the Pilgrims Environmental Policy must be followed to minimise any Environmental impact and assist with the clean up and recovery.

    Any emergency response plan to deal with spillage should include the following information as appropriate

    • How spillages are dealt with
    • What spill kit is held by Pilgrims at the Airport in Question?
    • Where this spill kit is located?
    • Who is responsible for dealing with the spillage? - There must be a designated individual within Pilgrims who will deal with the situation and act as the focal point.
    • What training is given on dealing with spillages and how is this training delivered?
    • How is any materials used in spillage operations disposed of?
    • What records are kept?
    • What follow up action is taken? - i.e. investigation into cause of spillage / maintenance regime / staff training / discipline.

    14 Contact Details

    Comments are welcomed and encouraged from anyone having constructive suggestions on improvements to Pilgrims organisation and arrangements for Health, Safety and the Environment.

    These should be addressed to:

    David Freear
    General Manager
    Pilgrims Group Ltd
    Pilgrims House
    PO Box 769
    Surrey GU21 5EU
    Des Ewers
    Contract Development Manager
    Pilgrims Group Ltd
    Pilgrims House
    PO Box 769
    Surrey GU21 5EU

    Tel: 01483 228771 Tel: 01483 228762
    Mobile: 07932 750057 Mobile: 07789 153930
    Email: Email:

  • Implementation
  • Description of concrete actions to implement environmental policies, address environmental risks and respond to environmental incidents.

  • All PGL offices take an active part in local recycling projects.

    Whenever possible PGL incorporates environmental practices into our risk mitigation plans; i.e. Crime Prevention Through Environmental Design (CPTED) and use of integrated smart technology with low energy footprints thereby encouraging suppliers to raise their own environmental awareness.

    Effective environmental management is a line management responsibility within PGL with the Facilities Manager holding responsibility for the development of environmental policies and procedures.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates environmental performance.

  • PGL actively manages all environmental issues (see Environmental policy on waste management, spill management and incident management).

    PGL are not subject to nor have been the subject of any investigations or fines related to environmental issues during this reporting period.

    PGL environmental policy implementation is regularly reviewed and forms part of our annual ISO 9001 audit procedure.

  • Assessment, policy and goals
  • Description of the relevance of anti-corruption for the company (i.e. anti-corruption risk-assessment). Description of policies, public commitments and company goals on anti-corruption.

  • PGL has a zero tolerance to un-ethical behaviour and any breach of our ethical or anti bribery policy will be investigated by senior management and may result in disciplinary action including dismissal.

    PGL Anti Bribery Policy - see below:

    The Company is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The Company will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf. Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.
    Scope of this policy
    This policy applies to all employees and officers of the Company, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, the Company ("associated persons”) within the UK and overseas. Every employee and associated person acting for, or on behalf of, the Company is responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of the Company.

    PGL operates in many areas of the world where corruption is endemic. We are in the process of rolling out our anti bribery policy to all staff, partners and contractors across our global operations to re-enforce our commitment to compliance with the UK Bribery Act 2010 and the USA Foreign and Corrupt Practices Act. All staff will be required to sign as compliant with our anti bribery policy.

    PGL provides clear guidance to staff and managers on the management of corruption and fully supports all staff in their avoidance of corrupt practices.

  • Implementation
  • Description of concrete actions to implement anti-corruption policies, address anti-corruption risks and respond to incidents.

  • PGL whistle blower and no blame culture encourages staff to report any potential or actual case involving un-ethical behaviour internally and externally.

    Our current roll out of our anti bribery policy is aimed at raising awareness and compliance in the many hostile business environments where we operate.

    While the day to day management of ethical behaviour is a line management responsibility the CEO holds executive responsibility for compliance.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates anti-corruption performance.

  • All incidents (actual and potential) of unethical behaviour are subject to investigation by senior management.

    The executive management team reviews all cases of unethical behaviour at its quarterly meetings. There have been no such cases during this reporting period.