The Grievance Policy is an important pillar in the quality management system of Black Pearl (the “Company”). The policy aims to ensure that employees or external stakeholders, or interested parties with a grievance or claim relating to the company’s actions or lack of actions, or any failure with regards to Company’s policies and codes, including the ICoCA Code, have access to a simple and effective procedure, which can help resolve grievances as quickly and as fairly as possible.

Grievance is a concern, problem, allegation, claim or complaint that an employee or external stakeholder, third / interested party raises with the company. It may be related to any aspect of the relationship between the two, whether employment related, work practice, terms and conditions, health and safety, Human rights or other law / policy or code violations, working relationships or general treatment.

The Company aspires to implement and keep a culture of openness and positive work environment where an individual associated with the company can feel that his/her interests are a priority for the Company and any grievance raised will be dealt with promptly, impartially, confidentially and effectively. Therefore, it is Company’s policy to treat every grievance raised in a serious and swift manner, and to keep the employee or external stakeholder/interested party informed of the status of the grievance and the outcome of the investigation.

Additionally, the Company shall ensure that their personnel who report wrongdoings in good faith are provided protection against any retaliation for making such reports, such as shielding them from unwarranted or otherwise inappropriate disciplinary measures, and that matters raised are examined and acted upon without undue delay.

All details and access for Company grievance mechanism are clearly publish in Company website: www.ms-bp.com. Anyone with a complaint, claim or grievance is highly encouraged to report it directly and in detail to Company CEO: ceo@blackpearlmaritimesecurity.com and / or to the Competent Authorities.

The Company will keep records about all allegations, findings or disciplinary measures. Except where prohibited or protected by applicable law, such records will be made available to Competent Authorities upon request. Furthermore, appropriate corrective / preventive actions, including recommendations, shall be taken and followed up to prevent recurrence.

For the sake of law-abiding culture and overall transparency, the Company shall always cooperate with any official investigation, and will not participate in or tolerate from any of its personnel / partners / contractors, the impeding of witnesses, testimony or investigations.

The Company can and will take appropriate disciplinary actions as required, which could include termination of employment in case of a finding of such violations or unlawful behaviour.

This policy is under the responsibility of the compliance manager and should be reviewed annually.

  • The grievance procedure provides a structured approach to enable employees or external stakeholders and interested parties to raise their concerns with the company’s management. It provides individuals with a course of action should they have a complaint which they are unable to resolve through regular communication. The aim is to ensure prompt, consistent and fair treatment for all persons in order to promote effective working relationships. It is the responsibility of the Compliance manager to seek to resolve grievances at the earliest opportunity
  • All parties involved in this procedure must ensure that they maintain the confidentiality of the process as appropriate within and outside the company. It might be appropriate, for example, for a member of staff to discuss a procedure with his/her partner. Disclosure of information by any of the parties involved might also occur where this is required under law or where there is a circumstance involving duty of care, which requires disclosure, e.g. where a manager has concerns for the wellbeing of the employee or others.
  • Employee or external stakeholder/interested party report a grievance in person or in writing through the Team Leader or any of Black Pearl Managers or Directors. Whichever way was chosen to raise the grievance; it will be acknowledged in writing within 72 hours.
  • The compliance manager will then appoint a senior member of the company’s management team who has not been involved in the matter to investigate the issues raised in the complaint.
  • The investigator will decide how to investigate the complaint, along with likely timescales, to ensure that the complaint is fully, fairly and speedily investigated. The investigator will also endeavour to resolve the issues as quickly as possible and will communicate progress and outcome to the employee or external stakeholder/interested party and to others impacted by the complaint.
  • If so requested by the employee or external stakeholder/interested, the identity of the employee or external stakeholder/interested party will not be revealed to people outside the investigation and management teams except where we are legally obliged to do so.
  • If an investigation found any unlawful or even substandard behaviour by an employee of the company or anyone working on its behalf, the findings shall lead to immediate proper disciplinary measures, which could include termination of employment.
  • Black pearl shall ensure that anyone who had reported any wrongdoings in good faith is provided with protection against any retaliation for making such report, such as shielding from unwarranted or otherwise inappropriate disciplinary measures, and that matters raised are examined and acted upon without undue delay.
  • All grievances should be settled as swiftly as possible and no longer than a period 3 months.
  • Black Pearl will keep formal records of the complaint and outcome.



  • It is important that the employee or external stakeholder/interested party feels satisfied with any matter relating to his/her employment or any other form of relationship with the company, and should have effective means by which such a grievance can be aired and, where appropriate, resolved.
  • Nothing in this procedure is intended to prevent informally raising any matter, therefore grievances can also be raised in person. Also informal discussion can frequently solve problems without the need for a written record. However, if you wish to raise a formal grievance you should normally do so in writing from the outset.
  • You have the right to be accompanied at any stage of the procedure by a fellow employee or external stakeholder/interested party who may act as a witness or speak on your behalf to explain the situation more clearly.
  • If you wish to appeal you must inform the CEO within five working days. You will then be invited to a further meeting (can also be performed online), which you must take all reasonable steps to attend. As far as reasonably practicable, the company will be represented by a more senior manager that attended the first meeting (unless the most senior manager attended that meeting). Following the appeal meeting you will be informed of the final decision, normally within ten working days, which will be confirmed in writing.