Thursday 16 September 2021

To our stakeholders:

I am pleased to confirm that Silver Fleet Limited 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 sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,
Brian Barahukwa
Director

Silver Fleet aims to provide top-tier service in the passenger transport sector at the most competitive rates on the market. Today a number of corporate business outfits and private individuals make use of our services to travel across the country.

Our operations and growth in the business are based on three core values that guide our activities;
1. Safety
2. Respect
3. Exemplary behavior

This Policy Statement describes how we put these values into practice every day. It explains our commitments and expectations towards our stakeholders and provides guidance for our employees and contractors.

In addition to the core values mentioned above, there are two more business principles that are critical to the success of our company. They include;
Compliance with the highest integrity standards, in particular by preventing corruption, fraud, and anti-competitive practices.
Respect for internationally recognized Human Rights standards

Objectives of the Policy
1. Set out the values guiding the company employees’ conduct.
2. State Silver Fleet’s business principles and commitments to our different stakeholders.
3. Define our expectations towards employees in their day-to-day decision-making and in their relationships with other stakeholders

OUR BUSINESS PRINCIPLES

Silver fleet seeks to ensure the highest Health, Safety, Security, and Environmental standards within its operations. 

Silver fleet has a rigorous Compliance Program based on a “zero tolerance” principle designed to prevent and detect violations of applicable anti-trust, anti-fraud, anti-bribery, and anti-corruption laws. 

Silver Fleet is committed to respecting internationally recognized Human Rights standards within our operations.


EMPLOYER’S EXPECTATIONS

The company has been able to succeed in its operations due to the safety policies that the company directors and senior managers have put in place with the aim of providing her employees with a Safe and Healthy Working Environment which includes motor vehicles. The Directors manage and assess any risks to employees, and ensure as far as is reasonably practical, that employees do not endanger themselves or the public through work-related driving activities. 

Safety at Silver Fleet is an integral element that, given the nature of our business, requires the company to adopt and adhere to safety precautions in order for its operations to run smoothly without any incidents. These measures include;

1. Providing a thorough induction of the company's road safety policies and procedures for new Fleet Assistants (drivers) and regular refresher sessions for existing fleet assistants to keep them up to date with best practice industry procedures.
2. Maintain all company-owned and operated vehicles in a safe, clean, and road-worthy condition to ensure the maximum safety of the Fleet Assistants, our clients, and other road users.
3. Carry out a full service on all vehicles according to manufacturers’ recommendations
4. Undergo regular risk assessment and ensure that Fleet Assistants are not put under unrealistic time delivery or travel pressures.
5. Check that employees do not drive under conditions that are unsafe and/or likely to create an unsafe environment, physical distress, fatigue, or endangerment.
6. Ensure that Silver Fleet and its employees comply with all of the obligations imposed on them by law.
7. Treat all Fleet Assistants who are subject to an incident report with respect, fairness, and without fear of punitive action.
8. Address Fleet Assistant safety concerns seriously and appropriately.
9. Provide appropriate driver safety training in response to an incident report or need.
10. Monitor performance to ensure informed decisions are made about the effectiveness of the company’s work-related road safety policy.

11. We believe our development depends on trust and respect between the company and employees and amongst employees themselves. All our staff must bring our values to life through team spirit.
12. Employees have an annual appraisal during which objectives are set, performance and the respect of this policy are assessed and career development, facilitated by appropriate training, is discussed.

13. We pay particular attention to employees’ working conditions, especially the respect for each individual, the absence of discrimination, freedom of association, and collective bargaining. No form of harassment is tolerated.

14. We respect the private lives and more specifically the personal data of all employees and other stakeholders.

15. We recruit personnel solely on the basis of our requirements and the specific capabilities of individual applicants.

16. Diversity is a decisive factor for our competitiveness, attractiveness, and ability to innovate and adapt. We develop our employees’ professional skills and careers without any discrimination, whether based on tribe, gender, age, disability, sexual orientation, gender identity, or affiliation with a political, religious, or minority group.

17. We include our employees in our development by initiating and facilitating the distribution of relevant information, by consultation, and by engaging in ongoing dialogue through the fleet assistants’ committee. 


EMPLOYEES' OBLIGATION TOWARDS THIS CODE OF CONDUCT

Employees must be conscious of their personal responsibility during daily work activities, giving due consideration to the prevention of accidents, harm to health, environmental damage, or adverse impacts on local communities. Employees are expected to understand internal standards as well as the impact of our operations and improve risk management.

Employees’ vigilance and personal involvement regarding Human Rights in daily activities are essential.

Silver Fleet operates a zero-tolerance approach towards these topics and adheres to the highest standards of integrity. Employees must build sound relationships with all stakeholders and identify, prevent, and report situations that might cross the line.

Employees may not disclose confidential information, whether verbally, in writing, or electronically. They must also observe the rules governing the intellectual and industrial property. This obligation remains even after an employee leaves the company.
IT and communication resources are intended for professional use. Reasonable personal use may be tolerated in line with applicable legislation and internal rules.

This Policy explains our commitments and expectations towards our stakeholders who are key to our long-term success.

Customers

Silver Fleet provides customers with quality services and strives at all times to offer good performance at competitive prices for their particular requirements. We are attentive to our customers’ needs. We continuously monitor, assess and improve our services through customer visits where we engage our customers in a number of issues to ensure we satisfy their needs putting into consideration their value for money.

Suppliers and contractors

Silver Fleet’s policy regarding suppliers and contractors is based on our effort to respect each party’s interests with transparent and fairly negotiated contract terms. It is built on three pillars:
1. Dialogue
2. Professionalism
3. Respect of commitments

We expect our suppliers:
1. To adhere to principles equivalent to those in our policy and to submit to an audit when required.
2. To make sure that their own suppliers and subcontractors respect equivalent principles to ours.
3. To pay particular attention to their Human Rights standards and procedures, including their employees’ working conditions.

Silver Fleet Limited (“the Company”) requires safe and effective working relationships at all levels of the operations. Whilst respecting different cultures, traditions and employment practices, we share common goals, in particular the elimination of workplace injuries, and are committed to good corporate values and ethical behaviour.

The Company employs on the basis of job requirements and does not discriminate on grounds of age, ethnic or social origin, gender, sexual orientation, politics or religion. We may make exceptions to favour local employment where our local content policy provides. Nevertheless, the Company does not for any reason whatsoever employ forced, bonded or child labour.

Being trained to work, and then working, in safe, healthy and environmentally responsible ways comes first and foremost. Beyond that, the Company believes in enabling employees to develop to the extent of their abilities.
We improve our skills and competencies by regular performance reviews, recognising potential, undertaking education, training and coaching as appropriate, and offering professional development opportunities within the organisation.

The Company expects managers to be models of the highest standards of behavior. We treat each other and those we deal with externally with dignity, fairness and respect. We guard against harassment in the workplace and neither abuse nor misuse our positions or facilities for personal purposes.
We respect our obligations to our colleagues and employer. We work together within and across businesses, cultures and countries to raise performance.

The Company’s Code of Conduct establishes sound conditions of work and disciplinary procedures. The Company implements equitable and transparent remuneration and incentive systems.

We recognize everyone’s right to choose whether or not they wish to be represented collectively and live up to our code of conduct and evaluate the performance of the policy based on feedback collected from the confidential feedback system in use on the company premises.

Silver Fleet Limited intends to be acknowledged as a (Quality, Health, Safety & Environment) QHSE industry leader in the passenger transport services sector. We aim not only to satisfy but also exceed customers’ expectations by providing a first-class quality service, with HSE at the heart of all our operations.

We conduct our businesses with respect and care for the environment and without compromising the health and safety of people.

We strive to maintain a high quality of service delivery to make our customers successful and add value to our business. We provide an environment for open and transparent communication of QHSE matters.

We recognise that the skills and involvement of our employees are essential for understanding and fulfilling the needs of our company and customers.

In order to follow our principles, the Company will measure performance against the ability to;
Provide a safe and healthy working environment for all personnel, including Employees, Clients, Sub-Contractors, and Visitors, with a commitment to preventing injury and avoiding ill health.
Train and develop the competence of our people to the standard required for delivery of first-class quality products and services to clients while demonstrating our commitment to Quality, Health, Safety, and the Environment.
Regularly assess the environmental impact of our key processes, products, or services.
Develop and continually promote a Health and Safety awareness culture throughout the organization.
Ensure that all employees are aware of our QHSE requirements and take reasonable care of themselves, others, and the environment.
Identify and fulfill our obligation to all relevant legislative requirements to which we subscribe.
Ensure confidentiality of information.
Actively promote the involvement of staff in all QHSE related matters.
Provide sufficient resources to ensure QHSE objectives can be achieved.

The purpose of our Anti-Bribery and Corruption policy is to set out the responsibilities in observing and upholding Silver Fleet’s (“the Company) position on bribery and corruption and to provide information and guidance to Silver Fleet team members on how to recognise and deal with bribery and corruption issues.

This Policy is particularly important for Silver Fleet as we work in the passenger transport industry, which is very sensitive with regard to confidentiality and safety. Bribery and corruption undermine the rule of law and the principle of fair competition causes significant damage to the societies in which we operate and to the proper functioning of the market. The Company is committed to playing its part in supporting an ethical marketplace.

We are keen to ensure that all our operations are handled with the highest level of honesty, ethical conduct and integrity. I call upon all team members to follow this policy and strive to ensure the prevention, detection and reporting of bribery and corruption through the available confidential reporting channels.

Silver Fleet Limited, together with its affiliates, is committed to instilling a strong anti-corruption culture and to upholding all laws relevant to countering bribery and corruption. This includes, but is not limited to, the Government of Uganda Anti-Corruption Act of 2009, the UK Bribery Act 2010 (“Bribery Act”) and the US Foreign and Corrupt Practices Act (“FCPA”) which are generally considered to be the strictest legal regimes against bribery. The Company’s management are committed to taking a zero-tolerance approach to bribery and corruption, so you should seek support if you feel that you are being pressured to breach the Policy to achieve other Company objectives.

The Company expressly prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement. This applies to bribes to or from any person or company, regardless of their geographical location and irrespective of whether they are a public official, public body or private person or private company, by any individual employee or third party. Bribery by an employee or third party in order to gain any commercial, contractual or regulatory advantage for the Company potentially exposes the Company itself to criminal prosecution, as well as the individuals involved.

There is a higher risk that benefits offered to public officials could be interpreted as a bribe. As a general rule extra care and due diligence should be taken in all interactions with public officials, which can include employees of state-owned enterprises. 


All employees and third parties are responsible for the success of this Policy and should ensure that they use the guidance provided to identify and report any potential bribery risks or control failure to their line management.

The Company will monitor the effectiveness and review the implementation of this policy regularly to ensure its suitability, adequacy and effectiveness. This monitoring process includes a managerial review of gifts and hospitality records, third-party due diligence checks, management testing of required approvals and significant transactions. This ongoing process also informs periodic reports to our audit committee.

The Company welcomes comments and suggestions with regard to improving this Policy and its effectiveness and encourages comments via line management. Any improvements identified will be made as soon as possible.