Feronia recognises that its activities may generate risks to local communities, and will work with our stakeholders to identify and manage these issues. Given the Company’s long history of operations in DRC, limited government capacity in promoting health, safety and security, and the post-conflict nature of the country, particular sensitivity is required in its interactions with local communities and other stakeholders around plantation and asset security.
This Policy identifies Feronia’s responsibility to avoid or minimize security related risks and impacts that may arise from its activities, with particular attention to vulnerable groups. Overarching objectives of the Policy are:
- To anticipate and avoid adverse impacts arising from the use of security personnel on the health and safety of the Affected Community.
- To ensure that the safeguarding of Company personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities.
- To protect Company personnel and assets and to ensure that the rule of law is recognised and respected.
This Policy is based on Performance Standard 4 (Community Health and Safety) and adjusted to reflect the circumstances of Company operations in DRC. It provides principles and commitments that the Company will refine and implement via its standard operating procedures. Broader community development commitments and activities are described in the Company’s Community Development Plan.
This Policy describes the Company’s commitment to:
- Identify and assess security related risks as they may affect the Company in its concession and in the wider community as well as potential impacts of the Company’s use of security on Affected Communities.
- Mitigate potential risks and impacts through alignment of community engagement activities and the security function.
- Appoint security personnel (or commission third party services) who have appropriate skills and aptitudes.
- Actively manage the behaviour of all security personnel to ensure appropriate professional standards.
- Use the Stakeholder Engagement and Community Grievance Mechanisms as key mechanisms for assessing the effectiveness of security personnel performance in the light of the three objectives above.
- Review and report on all security related incidents in a manner commensurate with the incident.
1 Identifying and Assessing Security Risks
1.1 Evaluate security related risks to the Company and potential impacts on Affected Stakeholders within and outside plantation concessions.
1.2 Establish preventive and control measures consistent with good international industry practice (GIIP).
1.3 Develop mitigation measures commensurate with the nature and magnitude of risks.
1.4 Favour the avoidance of risks and impacts over minimization.
1.5 Evaluate whether risks change over time and will adjust the focus of this Policy as appropriate.
2 Mitigating Potential Risks Through Engagement and Management of Security Personnel
2.1 Appoint security personnel (or commission third party services) who have appropriate skills and aptitudes.
2.2 Be guided by the principles of proportionality and good international practice in relation to hiring, rules of conduct, training, equipping, and monitoring of such workers, and by applicable law.
2.3 Make reasonable inquiries to ensure that those providing security are not implicated in past abuses.
2.4 Ensure that those providing security are aware of this Policy and its requirements and that security personnel are aware of disciplinary action (including dismissal) that will be used to ensure professional standards are met.
2.5 Ensure that force is only used for preventive and defensive purposes in proportion to the nature and extent of the threat.
3 Actively Manage the Performance of all Security Personnel:
3.1 Ensure that all security personnel, whether directly employed by Feronia or via third party sources under Feronia’s control, operate to the same standards.
3.2 Train security personnel under Feronia’s control so that they are able to discharge their duties in a safe manner, respecting the needs and wishes of local communities and protecting the rights and assets of the Company and acting within relevant laws and regulations.
3.3 Include human rights awareness and sensitivity in training programs (with specific reference to the UN Guiding Principles on Business and Human Rights).
3.4 Ensure that if armed security personnel are ever deployed by Feronia, that they have enhanced training in the use of force (and where applicable, firearms), and that their behaviour reflects the requirements of the Voluntary Principles on Security and Human Rights.
3.5 Implement a “Zero Tolerance” policy on the use of drugs and alcohol in the workplace.
3.6 Not sanction the use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat.
4 Use the Stakeholder Engagement Plan and Grievance Mechanism to Gauge the Impact and Efficacy of this Policy
4.1 Provide a grievance mechanism for Affected Communities to express concerns about the security arrangements and the performance of security personnel in a way that does not create risks for individuals.
4.2 Proactively review grievances and wider community sentiment in order to understand impacts and concerns before they become serious or significant.
4.3 At least annually, review performance of this Policy at the ESG Management Committee.
5 Reviewing and Reporting Incidents
Feronia will investigate all allegations of unlawful or abusive acts of security personnel, take action (or urge appropriate parties to take action) to prevent recurrence, and report unlawful and abusive acts to public authorities.
Oversight of the Policy
This Policy is owned by the ESG Management Committee which has ultimate oversight of, and responsibility for delivery of Policy objectives.
Implementation will be defined and achieved via the Company’s standard operating procedures and the Policy requirements will be implemented in a timely and efficient manner recognising that there is a pre-existing security operation and that existing staff will be trained, assessed and managed so as to effect a timely implementation and achievement of Policy objectives.
The Community Relations & Development Manager will have specific responsibilities to ensure that community concerns in respect of security personnel are assessed and represented quickly and clearly to the ESG Management Committee.