Human Rights Policy

Black Pearl Maritime Security Management Ltd (the “Company”) is committed to the recognition, respect and promotion of human rights wherever we conduct our operations and is dedicated to maintaining a working environment where human rights are understood and respected.

The Company adheres to international law on the protection of human rights, as well as the United Nations Guiding Principles on Business and Human Rights and International Code of Conduct Association (ICoCA) Code, even if national or Flag State law does not specify them.

The Company will exercise due diligence to ensure compliance with the Law and the principles contained in the ICoCA Code and we will respect the human rights of all persons we come into contact with, including, the rights to freedom of expression, association, and peaceful assembly and against arbitrary or unlawful interference with privacy or deprivation of property.

The Company will engage with affected stakeholders and their representatives in the development of its human rights approach, identifying and addressing potential impacts our operations have on people involved, including vulnerable groups, remediating any proven adverse impacts on individuals and maintaining grievance mechanisms to record and address human rights allegations and incidents, while protecting the confidentiality of anyone who reports potential violations.

The Company shall not preclude access to judicial or other non-judicial grievance mechanisms and shall always cooperate with all human rights-related investigations.

All Company personnel, partners and contractors shall treat everyone respectfully, protect human dignity and maintain and uphold human rights of all persons, prohibiting harassment and discrimination in all aspects of Company’s activities.

Security guards may use force only when strictly necessary as the last resort and only to the extent required for their self-defence and this of the people they protect during the performance of their duty, always in accordance with Black Pearl SOP, RUF and Code of Conduct and Ethics.

No security guard or any Company personnel may inflict, instigate or tolerate any act of torture or other cruel, inhuman degrading treatment or punishment.

Security guards should apply as much as possible non-violent means before resorting to the use of force and firearms and should follow the standards and procedures set out for the rules and regulations for the use of force and firearms.

In cases where force is used, such incidents should be properly reported to the appropriate authorities and to the company, as soon as it is safe to do so. Black Pearl also aspires to conform with the legal duty to rescue any persons, including suspected pirates / assailants, who no longer pose a threat and may be at risk of drowning or worsening of injuries. Medical aid should be provided to injured persons, including to the offenders.

The Company provides effective training for all personnel in international humanitarian law and human rights law / standards and declines any persons determined to have been responsible for human rights violations. Any employee found to have committed such violations after fair hearing will face the consequences which will depend on how the individual has contravened this Policy and the Company’s Codes and in what circumstances and could range from a warning to immediate dismissal.

The adherence to this Policy and the on-going process of human rights due diligence it outlines will be monitored as part of the wider assessment of our policies and codes and shall be conducted on an annual basis.