Dear Mr. Secretary-General,

I am pleased to confirm that Farsight Services Limited (Seefar) supports the Ten Principles of the United Nations Global Compact on human rights, labour, environment and anti-corruption. With this letter of commitment, we express our intent to implement those principles. We are committed to making the UN Global Compact and its principles part of the strategy, culture and day-to-day operations of our company, and to engaging in collaborative projects which advance the broader development goals of the United Nations, particularly the Sustainable Development Goals. Seefar will make a clear statement of this commitment to our stakeholders and the general public.
We recognize that a key requirement for participation in the UN Global Compact is the annual submission of a Communication on Progress (COP) that describes our company’s efforts to implement the Ten Principles. We support public accountability and transparency, and therefore commit to report on progress within one year of joining the UN Global Compact, and annually thereafter according to the UN Global Compact COP policy. This includes:
A statement signed by the chief executive expressing continued support for the UN Global Compact and renewing our ongoing commitment to the initiative and its principles. This is separate from our initial letter of commitment to join the UN Global Compact.
A description of practical actions (i.e., disclosure of any relevant policies, procedures, activities) that the company has taken (or plans to undertake) to implement the UN Global Compact principles in each of the four issue areas (human rights, labour, environment, anti-corruption).
A measurement of outcomes (i.e., the degree to which targets/performance indicators were met, or other qualitative or quantitative measurements of results).

Sincerely yours,

Jacob Townsend
CEO

Respect for human rights is fundamental to the sustainability of Seefar and the communities with which we work. When it comes to our staff, consultants and all who are involved in our projects, Seefar is committed to ensuring that people are treated with dignity and respect.
“Security and justice, displaced people, fighting modern slavery”
These are a few of the pivotal themes that Seefar is publicly committed to. We seek to resolve these global dilemmas along our journey to protect the rights and opportunities of vulnerable people in the low-skilled labour workforce.
For example, in Afghanistan, Seefar remains committed to our goal of preventing/ eradicating human trafficking and modern slavery as we focus on education and awareness programs for low-skilled labour migrants. We continue to seek more positive outcomes in promoting opportunities for them to obtain ethical, better-paid work. From the perspective of market actors, we run projects that empower Afghan migrants to make good decisions and benefit more from their employment. We are determined to develop ethical competitors to existing labour recruitment arrangements and identify opportunities for governments to improve life for Afghan migrant workers.
In Afghanistan, our work in preventing modern slavery and human trafficking includes:
• Advising on practices to recruit Afghan labour migrants that are ethical and profitable;
• Conducting large-scale surveys to identify abuses and opportunities for progress;
• Delivering counselling and strategic communications to give Afghans the information and skills they need to reduce the risks of exploitation.

All of these ventures are supported by our Human Rights Policy. The Seefar Human Rights Policy stipulates that everything we do internally and externally aligns with our mission to achieve social impact. We have very strong guiding values, behaviours and systems of professional development that we live and breathe daily. We put these in practice by ensuring that all our policies and procedures are fully aligned with international human rights and we address any potential issues directly through giving and sharing constructive feedback.

This policy is supported by several other policies and procedures;

• Gender Policy - The overall goal of this policy is to promote gender equity, equality, and social justice in the Seefar workspace and beyond.
It aims to:
- improve the quality of life of men and women, at all levels of society through the promotion of gender equity and equality
- promote active and visible gender mainstreaming in all sectors.

• Disability Policy - The aim of this policy is to promote the goals of an inclusive, barrier-free and rights-based Enterprise for persons with disabling impairment, as a set of policy directions. It is also to protect and where relevant promote the rights and dignity of disabled people.

• Safeguarding SOP - Seefar believes that all individuals, including children, have a right to live in an environment that is free from abuse, neglect, and exploitation. This policy is committed to working in a way that protects and keeps all children, young people and vulnerable adults safe. The purpose of Seefar’s safeguarding policy is to:
- Protect children, young people and vulnerable adults who receive Seefar services. This includes the children of adults who benefit from our services.
- Provide Seefar staff with the overarching principles that guide our approach to safeguarding and child protection and ensure that the protection and safety of all individuals, including children, is paramount in every area of our work. This includes that it is safe for those affected to come forward and to report incidents and concerns with the assurance that Seefar will handle these sensitively and properly.

• Personnel Grievances SOP - The aim of this SOP is to settle grievances or complaints fairly, and it is intended to be implemented simply and quickly. All reasonable efforts will be made to resolve the issue at the earliest possible stage. Accurate records shall be kept throughout the process, including at the informal stage.

• Global Security SOP - Seefar has a legal and moral duty of care to ensure, as far as is practicable, the safety and security of its staff and consultants working in and visiting its countries of operation. The security policy’s objective is to enable Seefar staff and consultants to carry out their work globally, while minimising risks to people and the Enterprise.

• Formal Grievances and Reporting SOP - The grievance procedure is a procedure designed to address serious issues such as;
- physical violence;
- bullying, serious intimidation and harassment;
- sexual misconduct;
- maltreatment;
- abuse;
- victimization;
- discrimination on any ground;
- deliberately accessing internet sites containing pornographic, offensive or obscene material;
- serious incapability at work brought on by alcohol or illegal drugs;
- a serious breach of health and safety rules;
- theft or fraud
- gross negligence (serious lack of care to duties or other people);
- a breach of any important protocols that might put others at risk.

• Incident Reporting SOP - The objective of the incident reporting SOP is to define what constitutes a safety or security incident or near miss and therefore highlight to Seefar staff what must be reported. The SOP outlines the timelines and mechanisms for reporting incidents verbally and in writing. It outlines how follow up is to be conducted and makes provision for annual reporting and analysis.

Seefar values the diversity of the people with whom we work and the contributions they make. We have a long-standing commitment to equal opportunity and intolerance of discrimination and harassment. We are dedicated to maintaining our achieved goal of workplace fairness, which in 2019 has remained free from discrimination or harassment on the basis of race, sex, colour, national or social origin, religion, age, disability, sexual orientation, political opinion or any other status protected by applicable national/ international law.

Seefar is driven by the highest quality of service and standards of business conduct to enhance our growth. Our sense of purpose and humility, combined with our openness to learning and commitment to working on tough issues, makes us value our staff and those with whom we work.
Respect for human rights is fundamental to the sustainability of Seefar and the communities in which we operate. In our organisation and across our system, we are committed to ensuring that people are treated with dignity and respect.

Seefar is dedicated to respecting the human rights of our staff, consultants and the communities we work with. Seefar continues to be committed in identifying, preventing/ mitigating adverse human rights impacts resulting from or caused by our business activities before or if they occur through human rights due diligence and mitigation processes. Seefar’s Human Rights Policy is guided by international human rights principles encompassed in the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights.

Seefar conducts in depth analysis and due diligence before initiating any projects with subcontractors or forming new partnerships.
Should any grievance/ allegation of a human rights issue be raised, Seefar is obliged to conduct a thorough investigation of such allegations so as to determine what exactly has occurred and apply the appropriate response.

Seefar maintains a zero-tolerance policy on any form of human rights abuses. We continue to make all efforts to ensure that we mitigate, if not eliminate any forms of such violations. To monitor and assess this process, Seefar has implemented an ‘auditing framework’. This enables us to conduct an in depth review of each project every 3 months with direct input from the Project Manager and Local Project Coordinator with support/ monitoring from the Operations department along with the Safety, Security and Resilience Advisor.

In 2019, we have reviewed and improved our policies and procedures which support the reporting and investigation of any alleged human rights abuses. In Q3, Seefar contracted a Safety, Security and Resilience Advisor who reviews our policies on a regular basis along with reviewing each project on an individual basis.

For our Ethical Recruitment Agency (TERA) in India (explained in further detail under LABOUR), we have installed a multilayered monitoring system to ensure our beneficiaries that all steps have been taken to mitigate any risk of human rights abuses.

Those steps are as follows;
• Weekly check-ins from our Worker Welfare Officer to ensure worker safety.
• Random check-ins from an independent Employment Compliance Monitor at all stages of recruitment and work abroad.
• Monitoring of industry best practice and legal regulations in India and the UAE
• Paying workers through a Wage Protection System

Eliminating forced labour, exploitation of labourers and the freedom of association is part of Seefar’s vision to ensure that less fortunate people can live in a world where the opportunity to advance themselves and build a better future is provided. Since the founding of Seefar in 2014, we have conducted labour migration and strategic communications projects in Indonesia, West Africa and Afghanistan (to name but a few). Seefar has worked with more than 100,000 migrants in the past five years. Modern slavery is a global issue deeply connected to labour migration. Migrants and those pursuing work abroad are often at risk of financial, emotional and physical exploitation.

All of Seefar’s staff and projects are supported by policies and procedures that protect and support our staff, contractors and the people we work with.
• Human Rights Policy - The Seefar Human Rights Policy stipulates that everything we do internally and externally aligns with our mission to achieve social impact. We have very strong guiding values, behaviours and systems of professional development that we live and breathe daily. We put these in practice by ensuring that all our processes and SOPs are fully aligned with international human rights and we address any potential issues directly through giving and sharing constructive feedback.
• Gender Policy - The overall goal of this policy is to promote gender equity, equality, and social justice in the Seefar workspace and beyond.
It aims to:
- improve the quality of life of men and women, at all levels of society through the promotion of gender equity and equality
- promote active and visible gender mainstreaming in all sectors.

• Disability Policy - The aim of this policy is to promote the goals of an inclusive, barrier-free and rights-based Enterprise for persons with disabling impairment, as a set of policy directions. It is also to protect and where relevant promote the rights and dignity of disabled people.

• Safeguarding SOP - Seefar believes that all individuals, including children, have a right to live in an environment that is free from abuse, neglect, and exploitation. This policy is committed to working in a way that protects and keeps all children, young people and vulnerable adults safe. The purpose of Seefar’s safeguarding policy is to:
- Protect children, young people and vulnerable adults who receive Seefar services. This includes the children of adults who benefit from our services.
- Provide Seefar staff with the overarching principles that guide our approach to safeguarding and child protection and ensure that the protection and safety of all individuals, including children, is paramount in every area of our work. This includes that it is safe for those affected to come forward and to report incidents and concerns with the assurance that Seefar will handle these sensitively and properly.

• Personnel Grievances SOP - The aim of this SOP is to settle grievances or complaints fairly, and it is intended to be implemented simply and quickly. All reasonable efforts will be made to resolve the issue at the earliest possible stage. Accurate records shall be kept throughout the process, including at the informal stage.

• Global Security SOP - Seefar has a legal and moral duty of care to ensure, as far as is practicable, the safety and security of its staff and consultants working in and visiting its countries of operation. The security policy’s objective is to enable Seefar staff and consultants to carry out their work globally, while minimising risks to people and the Enterprise.

• Formal Grievances and Reporting SOP - The grievance procedure is a procedure designed to address serious issues such as;
- physical violence;
- bullying, serious intimidation and harassment;
- sexual misconduct;
- maltreatment;
- abuse;
- victimization;
- discrimination on any ground;
- deliberately accessing internet sites containing pornographic, offensive or obscene material;
- serious incapability at work brought on by alcohol or illegal drugs;
- a serious breach of health and safety rules;
- theft or fraud
- gross negligence (serious lack of care to duties or other people);
- a breach of any important protocols that might put others at risk.

Seefar values the diversity of the people with whom we work and the contributions they make. We have a long-standing commitment to equal opportunity and intolerance of discrimination and harassment. We are dedicated to maintaining our achieved goal of workplace fairness, which in 2019 has remained free from discrimination or harassment on the basis of race, sex, colour, national or social origin, religion, age, disability, sexual orientation, political opinion or any other status protected by applicable national/ international law.

In 2019, Seefar conducted further research into forced labour in Asia. This was our second study in this area in three years. Some of the findings in this report included;
• Debt-led recruitment rose significantly between 2016 and 2019
• Many workers agree to contracts they do not understand
• Almost half of the total sample experienced coercive recruitment
• Physical and sexual violence was reported at low levels but neglect was higher

Currently, in Uttar Pradesh in northern India, Seefar has strategized a pioneering specialist recruitment subsidiary initiative called ‘The Ethical Recruitment Agency’ (TERA). The aim of TERA is to allow low- and semi-skilled people seeking work abroad by enabling them to benefit more from their employment while eliminating exploitation.
Though the TERA project is still in its initial stages, the goals are defined:
• Eliminate forced labour from the grassroots recruitment level
• Guarantee our workers the highest ethical standards of recruitment, placement, working and return

TERA India benefits from having negotiated agreements to give domestic workers, cleaners (and soon construction workers) from Uttar Pradesh, opportunities to work in safe and decent jobs in the United Arab Emirates. This means that every beneficiary will be placed with employers who have agreed to TERA’s non-negotiable worker welfare protocols, which are protected in the agreed contracts and monitoring mechanisms.

Measurement and Outcomes for Seefar staff:

• As Seefar staff are predominantly telecommuters, we encourage the use our internal mentoring program. This enables us to assist staff in using their time optimally, avoid build up of stress and anxiety, further develop our ethos of teamwork and assist in meeting work demands and deadlines. This has assisted Seefar in continuing to monitor productivity while also ensuring that national/ international labour laws are respected.
• Seefar also provides a supervisory system to our staff. This system has proved very effective throughout 2019 as it allows individuals the opportunity to seek advice in areas such as communication issues, potential bullying and harassment issues.
• With these systems in place, there were no reports in 2019 of violations of national/ international labour laws.
• Seefar continues to engage directly with its staff for feedback on our labour monitoring systems. We believe in encouraging our staff to offer comments and feedback either through their supervisors or by utilising our feedback forum which is a part of our database system.

Monitoring and outcomes for TERA India (commencement date TBC in Q1 2020);

• The TERA India Manager / Ethical Recruitment Officer (ERO), who manages TERA India’s operations and is responsible for implementing all recruitment activities.
• Training, Logistics and Marketing Officer (TLMO), who is responsible for delivering pre-departure training, providing worker recruitment logistical support, and conducting marketing
• The Worker Welfare Officer (WWO) is responsible for worker welfare data collection, project monitoring, and serving as a 24/7 contact for workers to support while they are abroad. This role operates and is supervised independently from the ERO and TLMO as one of our ethical controls.

Seefar business activities do not have any significant negative impact on climate and the environment due to a number of factors;

• Seefar staff work remotely
• We provide services rather than product creation
• Up to 80% of Seefar’s 150 staff work in their own communities
• Seefar hires local teams in communities for all of our projects

However, we are aware that in this time of climate change there has been a significant shift in global attitudes towards environmental responsibility and Seefar recognises its obligation to work towards a more positive impact.

As all of Seefar staff work remotely (telecommuters) we identified a number of areas where we are already having a positive impact on the environment;

• Less Gasoline consumption
• Reduction in carbon emissions/ air pollution
• Minimal necessity for paper printing
• All of our research is uploaded via software
• Less energy consumption
• As a remote organisation, all of our work is shared online
• Limitation on use of bottled water at annual summits

Seefar realises that these are small measures and that there is a wider scope to which we must adapt to by educating our staff, contractors and those participating in our global projects.

In Q4 of this year, a meeting was convened at management level to begin assessing our carbon footprint and initiate the application of a company environmental policy by Q1 of next year. This policy, and all environmental issues will be discussed at our next summit by the end of Q1 2020. Largely, we will address our carbon footprint (both primary and secondary) and hold a discussion forum with all Seefar staff on how we must continue to mitigate this global dilemma by having a more positive impact on our working/ home environments.

Some of the key areas to be discussed will be;
• Building and strengthening a culture of awareness
• Reducing our airmiles
• Incorporating our environmental policy into Seefar projects
• Educating business partners to adhere to the UNGC Environmental Principles
• Reevaluating our waste consumption and management
• Exploring how we can integrate climate change and migration for future work
• Look to reducing paper usage and waste for field events
• Encourage the use of trains rather than flights when attending European seminar/ meetings

Currently Seefar have no measurement of outcomes in place for the UNGC Principles on Environment. This shortfall has been recognized and we wish to ensure the UNGC, our global partners and donors that this will be rectified over the coming 12 months. Firstly, we intend to have our Environment policy drafted, reviewed and in place in the second half of Q1 2020. Once the policy is in place and Seefar’s staff aware of its content, the issues of climate change will be addressed at the next summit at the end of Q1 2020. Seefar is considering an incentive method to enhance motivation within our field teams by introducing an award for field teams who adopt and implement environmentally friendly practices into their respective projects. We also intend to research methods to appoint key staff as ‘Climate Change Evaluators’. The overall objective being to promote the culture with the organisation and ensure a monitoring and evaluation system is installed in 2020.
Seefar welcomes this challenge and looks forward to being able to report a more positive actioned impact and outcome to the UNGC, our partners and donors in our UNGC COP 2020 Report.

Seefar is an international social enterprise and our staff, contractors and the people we work with are obliged and committed to complying with the respective laws of all countries where we conduct our work and business respectively. This also applies to abiding by any and all anti-corruption laws internationally. Seefar conducts a stringent interview process when hiring new staff. This is partly due to the fact that we take care in hiring/ contracting individuals who we determine can meet the criteria in upholding our own set of ethical values and principles.
Seefar staff are fully aware not to accept any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery and though this culture may exist in a number of the countries we operate in, it is not something to be condoned.

In addition to the requirements defined by national and international law, Seefar has established a robust compliance framework which includes several integral policies and procedures to mitigate any/ all risks of bribery and corruption in support of our Anti-Briber and Anti- Corruption Policy;

• Anti- Bribery and Anti - Corruption Policy - This policy exists to set out the responsibilities of Seefar management and staff, consultants and those who are contracted to Seefar projects, to enforce our zero-tolerance position on bribery and corruption. The policy also provides guidance for Seefar staff. It assists our staff in recognising and dealing with bribery and corruption issues, as well as understanding their responsibilities in reporting any such violations.

• Human Rights Policy - The Seefar Human Rights Policy stipulates that everything we do internally and externally aligns with our mission to achieve social impact. We have very strong guiding values, behaviours and systems of professional development that we live and breathe daily. We put these in practice by ensuring that all our processes and SOPs are fully aligned with international human rights and we address any potential issues directly through giving and sharing constructive feedback.
• Gender Policy - The overall goal of this policy is to promote gender equity, equality, and social justice in the Seefar workspace and beyond.
It aims to:
- improve the quality of life of men and women, at all levels of society through the promotion of gender equity and equality
- promote active and visible gender mainstreaming in all sectors.

• Safeguarding SOP - Seefar believes that all individuals, including children, have a right to live in an environment that is free from abuse, neglect, and exploitation. This policy is committed to working in a way that protects and keeps all children, young people and vulnerable adults safe. The purpose of Seefar’s safeguarding policy is to:
- Protect children, young people and vulnerable adults who receive Seefar services. This includes the children of adults who benefit from our services.
- Provide Seefar staff with the overarching principles that guide our approach to safeguarding and child protection and ensure that the protection and safety of all individuals, including children, is paramount in every area of our work. This includes that it is safe for those affected to come forward and to report incidents and concerns with the assurance that Seefar will handle these sensitively and properly.

• Personnel Grievances SOP - The aim of this SOP is to settle grievances or complaints fairly, and it is intended to be implemented simply and quickly. All reasonable efforts will be made to resolve the issue at the earliest possible stage. Accurate records shall be kept throughout the process, including at the informal stage.

• Global Security SOP - Seefar has a legal and moral duty of care to ensure, as far as is practicable, the safety and security of its staff and consultants working in and visiting its countries of operation. The security policy’s objective is to enable Seefar staff and consultants to carry out their work globally, while minimising risks to people and the Enterprise.

• Formal Grievances and Reporting SOP - The grievance procedure is a procedure designed to address serious issues such as;
- physical violence;
- bullying, serious intimidation and harassment;
- sexual misconduct;
- maltreatment;
- abuse;
- victimization;
- discrimination on any ground;
- deliberately accessing internet sites containing pornographic, offensive or obscene material;
- serious incapability at work brought on by alcohol or illegal drugs;
- a serious breach of health and safety rules;
- theft or fraud
- gross negligence (serious lack of care to duties or other people);
- a breach of any important protocols that might put others at risk.

• Incident Reporting SOP - The objective of the incident reporting SOP is to define what constitutes a safety or security incident or near miss and therefore highlight to Seefar staff what must be reported. The SOP outlines the timelines and mechanisms for reporting incidents verbally and in writing. It outlines how follow up is to be conducted and makes provision for annual reporting and analysis.

Seefar is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that prevent and respond to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever we operate.

A goal achieved by Seefar in Q3 of 2019 was the recruitment of a Safety, Security and Resilience Advisor (SSRA). The SSRA coordinates meetings with all Seefar Project Managers and Project Coordinators appointed to each project. A rigorous risk assessment is conducted by the SSRA to assess if there are any breaches in safety and security procedures and determine if the mitigative measures in place are relevant and adhered to. The SSRA assessment also includes any potential infringements/ unreported violations of Seefar's Anti- Bribery and Anti- Corruption SOP.
Each risk assessment is customized to the region/ country where the project is being conducted and accounts for the laws of that region/ country.

All Seefar staff (including field staff) receive awareness training in anti-bribery and anti-corruption and are encouraged to report any such incidents should they occur. Also, as mentioned in the previous section, each respective project receives a rigorous risk assessment by Seefar’s Safety, Security and Resilience Advisor to mitigate any such incidents. Each risk assessment is customized to the region/ country where the project is being conducted and accounts for the laws of that region/ country. Should any form of bribery or corruption be reported or identified, an incident will be reported to management and an investigation team will be launched.

Seefar condones the process of whistle-blowing (covered under our Grievance Procedures). Where staff or consultants or any community we work with wish to report a serious concern about the conduct of one or more individuals connected to the organisation/ project, they are trained and made aware to follow the procedures under 'whistle-blowing' (should he/ she so choose).

Seefar is committed to protecting whistle-blowers from reprisals or negative consequences.

Seefar operations department and the Safety, Security Resilience Advisor monitor any anti-bribery and anti-corruption related incidents should they occur. Such incidents are collated and analysed by project teams and the operations department. Recommendations arising from analysis will feed into an annual review of Seefar Anti-Bribery & Anti-Corruption Policy.
Seefar keeps detailed and accurate financial records, and has appropriate internal controls in place to act as evidence for all payments made. To our best ability, we will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

Seefar uses an ‘auditing framework’ which enables us to conduct an in depth review of each project every 3 months with direct input from the Project Manager and Local Project Coordinator with support/ monitoring from the Operations department along with the Safety, Security and Resilience Advisor. As part of this framework, attention is given to reviewing the progress of each project and if those projects/ field staff are continued to be protected from any forms of bribery or corruption. Due to the nature of our business, our culture promotes, and policies demand that any instance of possible unethical behaviour is reported. Any such cases are then compiled through our database and dealt with by management on a case by case basis.