I am pleased to confirm that Sustainable Criminal Justice Solutions CIC reaffirms its support for the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti Corruption. In this, our first, annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and it's principles into our business strategy, organisational culture and operational processes. We also commit to sharing this information with our key governmental and educational partners through our statutory Advisory Board and other primary stakeholders through our standard channels of communication. Gary Linton (Managing Director, Sustainable Criminal Justice Solutions CIC)

Sustainable Criminal Justice Solutions (SCJS) CIC supports the promotion and application of the Universal declaration of Human Rights across its entire range of business activity.

SCJS ensures that high standards of ethical behaviour and professional conduct are integral to all their projects delivered across the world. All SCJS staff and sub-contractors are required to uphold high levels of integrity, honesty, objectivity and impartiality, in-line with SCJS’ expectations, contractual agreements, and in accordance to the Civil Service Code.

SCJS primary business objective is to assist foreign administrations in strengthening the Rule of Law through the development and advancement of law enforcement agencies. We necessarily operate in countries and regions affected by conflict and security issues, many of whom have a questionable history on Human Rights violations. We therefore apply a due diligence process to all requests for assistance where we are to provide services either as a stand alone service provider or when forming part of an international consortium to ensure that our operations are aligned to the principles of HMG Overseas Security and Justice Assistance (OSJA) guidance i.e. that our actions 'do no harm' in relation to the Human Rights of citizens in those countries.

The upholding, preservation and promotion of fundamental Human Rights is an intrinsic element in the creation, delivery and evaluation of our Criminal Justice development programmes. We promote and practice a zero tolerance approach to Human Rights abuse or behaviour that indicates a disregard for the Human Rights of others.

SCJS embraces the Equality Act 2010 and accords to the framework of protection provided by the legislation relating to discrimination, harassment and victimisation. We are a member of the Equality Register managed through the Association of Equality Scheme Providers (AESP). Our approach to equality is applied to all aspects of SCJS practice, from staff recruitment, pay, benefits and development, to our policies and procedures and indeed throughout our capacity building missions.

In-line with the UK National Action Plan on Women (2018-2022) and the United Nations Building Stability Overseas Strategy (BSOS), SCJS supports the UK’s Women, Peace and Security commitments in overseas development projects to reduce the impact of conflict on women and girls, to promote their inclusion in conflict resolution and to achieve gender equality.

SCJS understands that promoting gender equality in fragile and conflict-affected states is a matter of human rights, whereby women and girls are more likely to be subject to gender-based violence, are less likely to have access to basic services (such as health, education and justice) and have increased responsibilities (such as domestic labour). The International Development (Gender Equality) Act (2014) ensures that humanitarian and development assistance programmes delivered outside the United Kingdom must by law take account of any gender-related differences and contribute to reducing gender inequality.

Advancing gender equality and empowering women is an integral element of SCJS project and training design, implementation and Monitoring and Evaluation stages.
All SCJS projects are designed and implemented in a gender-sensitive way. The following principles are promoted throughout all SCJS projects in order to secure an equal opportunity approach: Gender parity (equal representation and participation of men and women), equality (equal access and opportunities) and equity (ratio of participation). SCJS promotes gender equality in its resource and personnel strategy, with women fully represented on the SCJS Advisory Board, Management Team, and as Subject Matter Experts and Trainers.

Our goals for the coming year in relation to human rights are:

1) To explicitly affirm our support for upholding, preserving and promoting Human Rights to all of our stakeholders.
2) To record, report and act upon any potential or witnessed violations of Human Rights identified as party of our development programmes.

In March 2017 SCJS conducted an Organisational Training Needs Assessment for the National Accountability Bureau (NAB), the apex Anti-Corruption Organisation in Pakistan. As part of this TNA, SCJS conducted a number of focus groups, including with female Financial Investigators. In addition to the generic issues that their male counterparts had, female investigators also stated that they faced additional issues because of their gender. As a consequence, it was agreed with the NAB Leadership that a female only workshop (the first of its kind in NAB) would be arranged and facilitated by a Female Financial Investigator from SCJS. This workshop was conducted on March 2018, as part of the pilot courses that were run in 2017/18. The programme was as follows:

• History of women in UK law enforcement, the challenges they faced and overcame and the situation today
• The delegates were then encouraged to identify the issues that they faced
• Then after being introduced to the Circles of Control, Influence and Concern Model, to look at what issues they could resolve themselves (empowerment), what issues they could influence others to resolve on their behalf (empowerment) and what issues were currently beyond their control (ignore).

The workshop was very well received by the female investigators. However, many of the women stated that what would be most beneficial would be workshops with their male colleagues to raise their awareness of the additional issues that women faced. Subsequently, SCJS met with the NAB Deputy Chairman to discuss this feedback and consequently a second and more significant project was agreed, one that included a more detailed female development programme.

In the coming year SCJS will actively seek to affirm our firm commitment to the preservation and promotion of Human Rights through the delivery of the following actions;

1) To include an explicit reference to our commitment to the upholding, preservation and promotion of Human Rights in all new contracts with domestic and foreign administrations.
2) To review our organisational policies to ensure that wherever possible the Human Rights of individuals are promoted and upheld in all aspects of our operations.
3) To incorporate a Human Rights data collection section within our post deployment assessment reports for the collection, assessment and action of any identified issues relating to the positive promotion of or the potential abuse of Human Rights within or by the client organisation during programme implementation.
4) To conduct an awareness raising session for all project officers within SCJS to promote our commitment on respecting Human Rights.
5) To allocate the role of Human Rights compliance assessment to the SCJS Office Manager.

In the past year SCJS has further expanded its delivery of Human Trafficking investigation skills training in Nigeria and in Jamaica. The development of the Nigerian Agency for the Prevention in Trafficking in People (NAPTIP) and the Jamaican Immigration Services by SCJS is targeting stronger enforcement and victim identification in two of the world's key source and destination countries for Human Trafficking.

Going forward we recognise the need to be more transparent with regard to our internal organisational processes and to ensure that we are monitoring our own compliance in the area of Human Rights.

As stated in Action 5 the Office Manager role will be allocated the responsibility of Human Rights compliance and will report directly to the Senior Management team at the monthly SMT meeting on any Human Rights issues identified within the previous period and on the progress of actions 1-4 above.

SCJS is an equal opportunities employer that operates in compliance of the International Labour Organisation's (ILO) 8 fundamental conventions.

All employees of SCJS are supplied with a copy of the SCJS Staff Handbook detailing the conditions of employment, entitlements, expectations and working standards. All employees of SCJS are remunerated above the current minimum wage rate.

Employees are free to join official staff associations or Unions and are afforded all rights applicable to them under current UK employment legislation.

SCJS runs an internship programme with Solent University (Southampton) to promote awareness and career progression in the community.

All temporary, contracted staff used on overseas deployments are provided with clear terms of reference and an agreement detailing remuneration, expenses, insurance, security arrangements and other benefits relevant to the specific deployment. When operating in conflict or high-risk environments, SCJS always sets realistic budgets to reflect delivery requirements and cater for security, in line with their Duty of Care policies and procedure, to ensure the safety of staff and contractors.

SCJS complies with the principles of the Modern Slavery Act 2015, notably the Transparency in Supply Chain provision. SCJS acknowledges that businesses have a vital role to play in countering Modern Day Slavery. SCJS is well versed in the recruitment of local staff overseas and has established such arrangements in more than 15 countries across the world. This practice is a mandatory requirement of the Twinning and CBRN CoE projects that SCJS undertakes on behalf of the European Commission. Local staff are recruited in a fair and ethical manner, using objective assessments of their experience, skill and capability. Each staff member is issued a contract and is paid a day rate relative to the local market.

Specific goals for the coming year in relation to Labour Rights are:

1) To develop and implement a clear recruitment policy in line with the ILO Core Conventions. SCJS has grown organically since its inception in 2011 and now employs 22 full time staff. It is anticipated that the organisation will continue to grow and expand and will benefit from the development of a standard recruitment policy and processes.

SCJS has a clear management structure with departmental managers responsible for the resolution of labour related grievances in the first instance. All managers have implemented a monthly 1-2-1 staff engagement process where workloads, welfare, working conditions and performance issues can be discussed freely with all staff members. Any issues that cannot be dealt with by line managers are escalated to the Senior Management Team for resolution.

SCJS has developed a robust risk assessment process for all overseas deployments of staff. The process involves pre deployment risk assessment conducted using a range of current situational analysis tools for the destination country / countries. Security arrangements are secured through either British High Commissions / Embassies in country or where necessary private security providers.

Regular Hazardous Environment Awareness Training and Trauma Treatment / First Aid is provided free of charge to SCJS staff deployed overseas.

All staff travelling overseas are provided with appropriate health, safety and security equipment including live time location monitoring equipment whilst on deployment. A fully comprehensive organisational insurance policy is provided for all members of staff deployed overseas regardless of the length of the deployment. Where necessary additional insurance is provided for particularly hazardous environments.

SCJS conforms to the minimum age convention of the International Labour Organisation and the Ethical Trading Initiative Base Code to support the elimination of forced/child labour.

SCJS annually reviews its pay and conditions packages for all employees ensuring that it does not discriminate in any way and provides comparable pay for comparable work.

SCJS has an established suite of Human Resource Policies reviewed annually by the Office Manager who has the delegated Senior Management responsibility for compliance.

As a private organisation SCJS has grown 'organically' since its inception in 2011. We embrace diversity with a range of age and experience, ethnic and cultural backgrounds and gender across our core team of 22 staff. Due to the nature of how demands on SCJS have grown in recent years recruitment has tended to be ad hoc and unable to be planned in a structured way due to many unknown factors. As SCJS continues to develop and grow we are now able to introduce standard recruitment processes and apply planning to meet the forecast demands on the organisation. For transparency the monitoring of diversity factors such as age, gender will be undertaken by the Senior Management Team as part of the monthly management meetings. Reporting on workforce diversity will be included in Annual Reports from 2019 onwards.

SCJS is currently leading a 3-year project in Southeast Asia on behalf of the CBRN CoE on ‘Sound management of chemicals and their associated wastes’. The sound management of chemicals and waste is a specific target under the United Nations Agenda for Sustainable Development and its Sustainable Development Goals (SDGs). SCJS is delivering this project in response to rapid industrialisation in Southeast Asia and associated illegal dumping and mismanagement of chemicals, which is having an acute impact on the environment and the safety of residents. In addition to enhancing capability in the areas of judicial reinforcement, prevention, mobile detection and preparedness and response, the project will strive to secure the implementation of international conventions in the region to prevent hazardous chemicals entering the environment.

SCJS is keen to reduce the environmental impact of its operations. The primary function currently conducted by SCJS that has an adverse impact on the environment is the overseas deployment of experts using commercial air travel. In all regional projects that SCJS manages, it is a priority for the organisation to undertake missions in a group of countries per regional visit, to negate the need for repeated international flights in and out of the region. In addition, and subject to budget provisions, SCJS will always book the most direct flights for experts deployed overseas. These measures support the overall organisational aim for the reduction of SCJS’ environmental footprint.

In addition to the global environmental projects that SCJS is currently engaged in with the European Commission we ensure our own internal operations are as efficient as possible with minimum environmental impact.

SCJS has introduced a recycling system within its UK office for all waste generated by the office. This includes personal / food waste generated by office personnel as well as office consumables such as waste paper, cardboard and print cartridges. This process is overseen by the SCJS Office Manager who regularly updates staff on recycling issues.

The default setting of printers in the office is for double sided printing and all staff are advised to only print hard copy black and white documents when it is absolutely necessary.

A suggestion scheme was recently set up for staff to contribute to ideas for reducing waste within the office which resulted in a large amount of redundant IT hardware being recycled through a local recycling service provider.

In the past year SCJS has set up a dedicated flight centre that is used to manage the travel requirements of its experts deployed overseas. The flight centre, whilst being a separate company in its own right, works exclusively for SCJS and therefore implements our policy on direct flights and the grouping of travel requirements wherever possible.

Updates to the Senior Management Team on environmental issues pertaining to SCJS operations are discussed at the SMT monthly meetings as a standing agenda item. Any remedial actions required are taken forward by the Office Manager.

SCJS operates in an honest and ethical manner and requires all staff and sub-contractors to uphold these standards.

SCJS is compliant with UK laws, including the Bribery Act 2010, and upholds the relevant laws of the jurisdictions in which they operate.

SCJS has formal anti-bribery, whistleblowing and code of ethics policies, encompassing compliance with principles that protect against conflict of interest, bribery, corruption, as well as the disclosure of clients’ confidential information.

SCJS's expectation for compliance by all staff and subcontractors is clearly defined in the code of conduct and is integral to the induction process for new staff.

SCJS recognises that when deploying staff to Fragile and Conflicted States, heightened levels of vulnerability (notably women and children) can create opportunity for inappropriate and harmful behaviour.

SCJS operates with a transparent financial approach and is well versed in high levels of scrutiny. For example, SCJS is subject to European Commission independent audits (expenditure verifications) every four months for its Twinning Projects and every six months for projects delivered for the Chemical, Biological, Radiological and Nuclear (CBRN) Centre of Excellence (CoE). SCJS is currently managing numerous projects that fall into this auditing schedule. In each case, the auditors have commented favourably and have complimented SCJS’ financial management.

Via their ADS membership, a core team of SCJS staff has been vetted to Security Clearance (SC) level. Other staff and contractors are vetted as required under specific contracts. This provides contractors with a high degree of trust and assurance regarding the suitability of SCJS staff, whilst ultimately upholding the reputation of SCJS and the UK government.

Our due diligence when working with partner organisations include legal standing reviews (company registration documents), rigorous background checks (including county court judgements, director disqualifications and credit ratings) and a zero-tolerance approach to fraud, bribery, financial misuse and misconduct.

SCJS has delivered many projects aimed at tackling organised and institutional corruption. In November 2018 SCJS commenced a three year programme, working in partnership with the United Nations Office on Drugs and Crime (UNODC) to deliver institutional strengthening & improved coordination between Law Enforcement Agencies with Financial Crime & Money Laundering remit in Pakistan. Although Pakistan has the majority of required financial structures and systems in place, it is primarily a cash economy. This significantly reduces the quantity and reliability of financial data available, has a substantial impact on the level of tax revenues and increases the potential for Financial Crime, including Money Laundering and Corruption. Over the next three years our work on this programme will:

1. Support HMG’s interest in pioneering a cross-mission, holistic, long-term and sustainable programmatic approach for Serious and Organised Crime
2. Support the British High Commission’s Anti-Corruption Strategy
3. Support Pakistan to act to Pursue and Prevent money laundering threats to the UK and Pakistan

Internally, all financial matters are dealt with by a dedicated and highly skilled finance team who are subject to regular and thorough audits under the terms of specific project frameworks. Any issues identified suggesting suspicious financial activity / transactions are dealt with by the Finance Manager and, if necessary, escalated to the Senior Management Team.

The detection and prevention of internal fraud and corruption are central to the SCJS ‘Standards of Conduct- Anti-Bribery and Corruption’ organisational policies and procedures and the staff induction process. It is company procedure to conduct all business in an honest and ethical manner.

Bribery and corruption are prohibited in SCJS business and in business dealings.

SCJS is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever they operate. SCJS will uphold all laws relevant to anti-bribery and anti-corruption in all of their business areas. However, the anti-bribery laws of the UK, including the Bribery Act 2010, take priority in respect of SCJS conduct.

In operating this zero-tolerance approach and in-line with their risk management procedures, should SCJS identify any illegal activity within their delivery chains, they will cease working with any contractor/organisation involved and will invoke reporting procedures as per The Supplier Code of Conduct.

The SCJS finance team have directly assisted HMG departments (Home Office, Ministry of Justice) to comply with the audit processes required by the European Commission for EU funded projects including the provision of financial training to their project teams.