This policy applies to AL SUR Security Services its affiliates and subsidiaries (“AL SUR Group”). All companies within the AL SUR must implement this Grievance Procedure. 

A Complaint includes any complaint or grievance made by an individual or company which arises as a result of the alleged acts or omissions of AL SUR Group or any personnel (including contractors or employees engaged by it at the time the alleged acts or omissions took place) or any of its subcontractors.

A communication of a Complaint may be received in a number of ways:

(i) Via email to the address: Info@alsursecurity.net

(ii) Via hotline number: 07700790027

(iii) Via the submission of a completed form as included on the AL SUR website: Alsursecurity.net

If a member of staff receives a verbal Complaint, he/she should direct the originator of such Complaint (“Complainant”) to make his/her Complaint via one of the above methods so that it can be captured.

Upon receipt of the Complaint, the Legal Department shall:

(i) Determine how the Complaint should be categorised (see below);

(ii) Assign a reference number to the Complaint in the database for the recording of Complaints (“Complaints Database”); and

(iii) Send an email to the complainant, acknowledging receipt of the Complaint and providing the complainant with the reference number (as above) for the Complaint.

3. Categorisation of Complaint

Complaints (which are not External Complaints (see below)) are divided into the following categories:

A. Client Service Contract

B. Whistleblowing

C. Personnel

D. Other Comment

A. Client Service Contract

Following the recommendation of the Legal Department, the Complaints Officer shall pass the Complaint to the relevant AL SUR project director/manager and client relationship manager. The Complaints Officer will inform the Complainant by email that the Complaint is being handled in this way. The Complaint shall then be closed in Complaints Database.

B. Whistleblowing

Whistleblowing is the disclosure of information by an employee or worker which relates to some danger, fraud or other illegal or unethical conduct in the workplace. If a Complaint relates to an AL SUR employee or worker’s personal circumstances in the workplace then he/she should use this Grievance Procedure and not the Whistleblowing Policy. If the Complaint falls within the remit of the Whistleblowing Policy, the Complaints Officer shall refer the Complaint to AL SUR’ designated whistleblowing officer (DWO). After the Complaint has been resolved under the Whistleblowing Policy, the Complaints Officer shall close the Complaint in the Complaints Database.

C. Personnel

If the Complaint is made by a current employee and does not fall within the remit of the Whistleblowing Policy, the Complaints Officer shall refer the Complaint to Human Resources, and shall inform the Complainant as to how the Complaint is being handled. The Complaints Officer shall then close the Complaint in the Complaints Database.

If the Complaint is made by a contractor and does not fall within the remit of the Whistleblowing Policy, the Complaints Officer shall refer the Complaint to AL SUR Security Services and shall inform the Complainant as to how the Complaint is being handled. The Complaints Officer shall then close the Complaint in the Complaints Database.

D. Other comment

If the Complaint is determined by the Complaints Officer (following the recommendation of the Legal Department) (i) not to fall within A, B or C above and (ii) is not otherwise actionable as an External Complaint (see below), the Complaints Officer shall refer the Complaint to the relevant recipient and the Complainant should be advised as to what action is being taken (if any). The Complaints Officer shall then close the Complaint in the Complaints Database.

4. External Complaint

If the Complaints Officer determines that a Complaint does not fall within A, B, C or D above, he/she shall classify the Complaint as an External Complaint.

The Complaints Officer shall determine how such External Complaint shall be dealt with as follows:

1. If the Complaints Officer determines that the Complaint is a criminal matter requiring the notification to the appropriate external authorities, the Complaint shall be passed to the AL SUR Board for approval and confirmation of the determination of the Complaints Officer. If approved, the Complaints Officer shall pass the Complaint to the appropriate external authorities with whom AL SUR shall provide all reasonable assistance. If the external authorities decide not to proceed with the Complaint or discontinue their investigations for any reason (including resolution), AL SUR shall then deal with the Complaint internally.

2. If the Complaints Officer determines that the Complaint is (i) not a criminal matter requiring the notification to the appropriate external authorities and (ii) without foundation, merit or substance, then the Complaint shall be passed to the Legal Department for second review and confirmation.

3. If the Legal Department agrees with the determination of the Complaints Officer, an email will be sent to the complainant advising him/her of this and then the Complaint shall be closed in Complaints Database.

4. If the Legal Department disagrees with the determination of the Complaints Officer, then it should recommend whether the Complaint concerns the allegation or fact of death, serious crime, government, external audit or investigation and/or has any press involvement.

5. If the Complaint does concern the allegation or fact of death, serious crime, government, external audit or investigation and/or has any press involvement, then the Complaints Officer shall pass the Complaint to the Quality Management Review Board (“QMRB”) (copying the AL SUR board of directors (“AL SUR Board”) who will then (i) appoint an Investigating Officer to investigate the Complaint and (ii) advise the complainant as to the Grievance Procedure. 

6. If the Complaint does not concern the allegation or fact of death, serious crime, government, external audit or investigation and/or has any press involvement, then the Complaints Officer shall review and quantify the severity of the Complaint and determine how the Complaint should be treated. 

7. Following the determination made in Paragraph 5 above, if a Complaint is classified as being (i) not of a serious nature and (ii) concerns events which took place at least three (3) years before the filing of the Complaint, the Complaints Officer shall (i) inform the Complainant that the Grievance Procedure is complete and (ii) close the Complaint in the Complaints Database.

8. Following the determination made in Paragraph 5 above, if a Complaint is classified as being (i) not of a serious nature and (ii) concerns events which took place no more than three (3) years before the filing of the Complaint, the Complaints Officer shall transfer the handling of the Complaint to the Legal Department (copying the QMRB). The Legal Department will then (i) appoint an member of AL SUR’ personnel who is not connected with the Complaint in any way, to investigate the Complaint (“Investigating Officer “) and (ii) advise the Complainant as to the Grievance Procedure.

9. Following the determination made in Paragraph 6 above, if a Complaint is classified as being of a serious nature then the Complaints Officer shall pass the Complaint to the QMRB (copying the AL SUR Board) who will then (i) appoint an Investigating Officer to investigate the Complaint and (ii) advise the complainant as to the Grievance Procedure.

10.  The Investigating Officer appointed under Paragraphs 5, 8 and 9 above shall examine the substance of the Complaint thoroughly and shall interview persons that he/she deems to be relevant to the investigation. The Investigating Officer shall only be required to use reasonable efforts to pursue his/her enquiries in order to come to an objective and reasonable view of the Complaint. The findings and conclusions reached by the Investigating Officer shall be reviewed by representatives of the QMRB.

11.  Following the conclusion of the investigation, the Complaints Officer shall inform the Complainant (i) whether any action will be taken and (ii) that he/she has the right to appeal the determination reached. Unless the Complaints Officer deems any explanation of the decision to be necessary, there is no requirement for any explanation as to the reasons for the decision to be given to the Complainant.

5. Appeal

The Complainant is entitled to appeal the decision reached (” Appeal”). If the Complainant informs the Complaints Officer (or any other person at AL SUR who will then refer the Complainant to the Complaints Officer) that he/she wishes to appeal, the Complaints Officer will inform the QMRB who will then appoint someone to review the basis of the appeal and advise the Complainant that the appeal is being considered. Following the conclusion of the investigation of the basis of appeal, the Complaints Officer shall inform the Complainant whether or not the appeal has been upheld. Unless the Complaints Officer deems any explanation of the decision to be necessary, there is no requirement for any explanation as to the reasons for the decision to be given to the Complainant.

6. Completion of Grievance Procedure

In the event that the Complainant decides not to pursue an appeal or following the completion of the Appeal, the Complaints Officer shall convene a meeting to be chaired by a representative of the Legal Department or the QMRB (depending upon which of them appointed the Investigating Officer for that particular investigation). The purpose of such meeting shall be to:

(i) confirm whether the Grievance Procedure was properly followed in respect of this particular Complaint; 

(ii) recommend whether as a result of the dealing with this Complaint, the Grievance Procedure should be reviewed; and

(iii) recommend whether any other AL SUR Group policies and procedures should be reviewed in the light of any substantive findings or evidence gathered as a result of the investigation of the Complaint.

Following the meeting, the Complaints Officer shall provide the Legal Department and the QMRB with a copy of the minutes and close the Complaint