Statement of continued support
27 April, 2021

To our stakeholders:

I am pleased to confirm that Policy and Management Consulting Group - PMCG 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,

Alex Aleksishvili
CEO and Chairman

Policy and Management Consulting Group (PMCG) is a team of highly experienced professionals; a network of institutional development and project management, research-based economic and social policy experts, and engineers. We highly appreciate the valuable work and unique knowledge of our staff members, experts and consultants that supports us to deliver high-quality outcomes and to bring real value to all project stakeholders.

PMCG is committed to create an inclusive working environment at all levels, give equal opportunity to all employees and job applicants. The company promotes positive and supportive culture and eliminates discrimination among the workforce.

PMCG values diversity, every individual and through its policy aims to protect those who may face inequality or harassment due to any kind of discrimination.

Equality is fully incorporated in all PMCG’s work as a universal human right. We have clearly defined scope, in our equality and diversity policy that reinforces our commitment to provide equality and fairness to all in our employment. We are not biased on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, ethnic origin, nationality, religion or belief, sex and sexual orientation. We are opposed to all forms of unlawful and unfair discrimination.

All employees, no matter whether they are part-time, full-time, or temporary, are treated fairly and with respect. They are given support and encouragement to develop their full potential.

Candidates are selected based on their own merits and abilities for employment, promotion, training, or anything of this nature.

PMCG has developed and is continuously implementing the policy on equality and diversity. We use this policy within the company, also in the framework of the projects we implement with our partners, like international development institutions and consulting organizations. According to the policy we commit:

 To promote equality in the workplace, create an environment in which individual differences and contributions of all team members are recognized and valued.
 To encourage employees, treat everyone with dignity and respect, and not tolerate any form of bullying, or harassment.
 To conduct all recruitment aspects in a fair and transparent manner and subject to open competition whether internal or external.
 To make training, development, promotion, and payment opportunities available to all staff equally.
 To inform all employees and newcomers during on-boarding that an equality and diversity policy is in operation and that they are obligated to comply with its requirements and promote fairness in the workplace.
 To encourage anyone who feels they have been subject to discrimination to raise their concerns so PMCG can apply proper actions.

We share our commitments to all our employees as part of onboarding procedure, as well as train them regularly. In order to ensure that our commitments are met, we have created whistleblowing mailing channel and instructed and encouraged our employees to use this opportunity in case of need.

Fortunately, we did not have incidents linked with human rights violations. But we do have regular person to person meetings with employees to encourage them to raise a voice and to instruct about the mechanisms of dealing with such cases.

Company has a designated Integrity Manager. This position does not fall under the supervision of any PMCG staff member and is fully independent. Staff members planning to raise concerns can contact the Integrity Manager.

The Integrity Manager examines the report, conducts interviews, and if consented to by the Whistle-blower, discusses the issue at a meeting of the Board of Directors. In other cases, he or she will supply the Whistle-blower with advice or refer him or her to legal counsel.

All information acquired by the Integrity Manager (unless otherwise requested by the Whistle-blower) is handled in the strictest confidence.

As an alternative, staff members and PMCG experts may raise their concerns with the General Director or Executive Director.

Any actions of retaliation against the Whistle-blower (if proven true) is addressed accordingly. The provision of various types of compensation for damages caused by retaliation or connected actions are taken into consideration.

PMCG values diversity and employs and partners with individuals and organizations from a wide range of cultures and races. The company is committed to an open and Discrimination free workplace.

Representatives will not engage in discriminatory behaviors on the basis of race, color, gender, language, religion, political or other opinion, national, ethnic or social origin, property, birth, pregnancy, marital status, disability, sexual orientation, age or any other protected status.

Further, the Company is dedicated to promoting gender equity and inclusive workplaces where persons with disabilities and other disadvantaged or vulnerable groups are reasonably accommodated. Representatives must not engage in any discriminatory behaviors including, but not limited to, the following:

 Refusing to hire someone on the basis of their status;
 Terminating Employees on the basis of their status;
 Refusing to promote Employees on the basis of their status;
 Refusing to make adjustments to a workstation of Employees with a disability;
 Treating Employees unfavorably due to their status; and
 Refusing to excuse Employees for pregnancy appointments, disability-related appointments, gender reassignment surgery or other such medical reasons related to their status.

Sexual Harassment or Workplace Harassment is unacceptable behavior and is not tolerated.

PMCG is committed to upholding the values and purpose of the UN Convention on the Rights of the Child, which requires that Children will be protected from performing any work that is likely to be hazardous, interfere with a Child’s education, or are harmful to a Child’s physical, mental, spiritual, moral or social health. Regardless of the jurisdiction in which the Company is registered or doing business, these activities are prohibited.

The Company has a zero tolerance of Child abuse and it expects the same commitment to Child protection from Representatives. Specifically, Representatives will:

 Treat Children with respect regardless of race, color, gender, language, religion, political or other opinion, national, ethnic or social origin, property, birth or any other protected status;
 Whenever possible, ensure that another adult is present when working in the proximity of Children;
 Use any computers, mobile phones or video and digital cameras appropriately, and never to exploit or harass Children or to access Child pornography through any medium;
 Refrain from physical punishment or physical discipline of Children;
 Refrain from hiring Children for domestic or other labor; and
 Comply with all applicable laws, rules and regulations concerning Child protection, including laws in relation to Child labor.
Representatives will not:
 Use language or behavior towards Children that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate;
 Engage Children in any form of sexual activity or acts where under the law(s) applicable to the Child, the Child is below the age of consent or the act(s) are an offence under relevant laws;
 Invite unaccompanied Children into the Representative’s home or place of residence without parental or legal guardian consent;
 Sleep close to unsupervised Children; and
 Supply controlled drugs to Children for use, trafficking or importing.

When photographing or filming a Child for work-related purposes, Representatives will:

 Assess and endeavor to comply with local traditions or restrictions for reproducing personal images before photographing or filming a Child;
 Explain how the photograph or film will be used and obtain consent from the child’s parent or legal guardian before photographing or filming a Child;
 Ensure photographs and films however recorded and stored present Children in a dignified and respectful manner and not in a vulnerable or submissive manner;
 Ensure that Children are adequately clothed and not in poses that could be seen as sexually suggestive;
 Ensure images are honest representations of the context and the facts; and
 Ensure that physical and electronic labels of photographs and films do not reveal identifying information about a Child.

As Mentioned above, we have Whistle-blower policy and mechanism in place to ensure that Code of Ethics and other important policies are effectively implemented.
Information regarding the Whistle-blowing policy is provided through the following means:

 All new staff members and experts are provided with information on the Whistle-blowing policy, the reporting form and relevant contact information. Pertinent information is attached to their contracts.
 Induction training covers, in detail, topics related to the reporting of fraudulent practices.
 Information is periodically (once every three months) reiterated at the regular (monthly) Staff Meetings. Management reinforces its commitment to the ethical integrity of the Company and its work, and thus the importance and value of confidential Whistle-blowing.
 Contact information for raising concerns related to corrupt activities can be found on PMCG’s website - http://pmcg-i.com/contact-us.

PMCG is comprised of young professionals. Majority of staff members fall in the range of between 25-45 years, and average age of the company is 33 years.

Gender balance at PMCG is satisfactory in general and at management level. In terms of staff male and female team members are distributed as 42 and 56 percent respectively. Management team comprises of 56% female and 44% male members. However, our objective is to focus on Executive Board (Board of Directors) that outstands for its imbalance, with 17% female and 83% male members. We are actively working on developing tools and mechanisms that will help us overcome this challenge. We would like to stay objective while recruiting the candidates, however such proportions in executive level are not acceptable for us.

Along with whistleblowing mechanism, we also have incident reporting guidelines at PMCG that is designed for reporting any violation of Code of Ethics and PMCG’s policies and procedures. We are committed to enforce all measures to avoid such occurrences in the delivery of projects, business operations and supply chains. However, if such episodes take place, PMCG is to ensure that all cases are reported in a timely manner, in order to investigate and take appropriate actions.

We have not been audited in this regard, however the prior source of funding for our projects come from such international development institutions as: European Commission, USAID, EBRD, The World Bank and their partner organizations, and they are always checking if relevant policies and procedures are in place.

Environmental issues are part of PMCG’s Code of Ethics that emphasizes how important is the topic for us and is widely implemented within the company, as well as within the various projects we are part of. We engage in in environmentally sustainable development, promote conservation and sustainable use of natural resources, conservation of biodiversity and heritage sites and disaster risk reduction planning, ensuring compliance with environmental protection legislation in the countries where PMCG is registered and the countries where the company works.

It is the responsibility of each representative and/or team member to fully comply with this policy. In order to ensure its implementation, the policy includes duty to fulfill and failure to comply may be subject to disciplinary action including contract termination, contract non-renewal or other appropriate action.

It is part of our onboarding training to share our environmental policy with the newcomers. We explain them new procedures and the importance of taking care of environment.

We have paper recycling boxes placed throughout the offices that makes easier for our employees to collect used paper. PMCG collaborates with several recycling organizations, including social enterprises and printing houses.

We raise awareness of the issue with our partners and consultants by providing them with our policies.

We have position within the company that is responsible for collecting gathered paper and collaboration with various recycling institutions.
PMCG’s offices are equipped with energy efficient appliances and lighting that ensures responsible use of resources.

In 2020 we have developed environment risk management plan to move forward in the field and be more sustainable. The plan gives the management opportunity to identify environmental risks, the triggers, strategy, actions to be taken and those who are responsible for specific tasks.

The tool also serves well the management of PMCG to permanently monitor the progress made and effectively identify and eliminate risks during quarterly discussions of the plan.

Anti-Corruption policy is part of our Code of Ethics. PMCG is committed to honesty, transparency and fairness and has zero tolerance for Bribery, including making Facilitation Payments or Graft. PMCG rejects corruption in all of its forms and complies with the spirit and letter of all applicable anticorruption laws and regulations.

We don’t have specific goals related to anti-corruption, as we do not have some specific issues in this direction. Everyone working for PMCG, inhouse or for short term within the framework of the projects is obliged to sign the code of ethics, and therefore commit to our principles.

As part of our policy and code of ethics, PMCG’s representatives are required to:

 Reject Corruption in all of its forms, including Bribery, making Facilitation Payments, Graft or any Prohibited Act;
 Understand and appreciate that Bribery and Graft are unlawful and therefore strictly prohibited, regardless of jurisdiction or circumstance;
 Adopt and enforce all policies that prevent Corruption in the conduct of business;
 Ensure that no Public Official benefits financially or in any other unlawful way from the relationship with the Company (or any Client);
 Operate with an adequate system of internal accounting controls and maintain accurate records that document relevant transactions; and
 Immediately inform their line manager if information is discovered indicating that a Prohibited Act has been committed, has been requested or otherwise suggested by any person, including a Public Official or private individual, in connection with, in relationship with, or working for the Company.

Company Representatives must not:

 Directly or indirectly, commit or attempt to commit, any Prohibited Act, including Bribery, Graft or making a Facilitation Payment;
 Directly or indirectly receive a Bribe;
 Use their authority for personal gain; or
 Offer, provide or receive unlawful gifts, benefits, hospitality, advantages, courtesies or entertainment from a Public Official where a reasonable person could interpret the offer, provision or receipt as a Prohibited Act made in connection with the Representative’s duties, status or authority.

Fortunately, we never had cases of corruption. But in order to ensure that nothing is missed, we regularly, once a year hire external audit. The audit company checks PMCG’s every projects’ financial details. In addition, our sources of funding, such as USAID, European Commission and others audit their projects. So, we have various external, trustworthy sources for auditing PMCG’s activities, together with our inhouse staff responsible for efficiently and transparently managing the finances of PMCG.