Human Rights Policy

Ownership and status

1. Purpose and rationale

This Policy sets out Britannia Elite’s commitment to respect, protect and uphold human rights across every part of its work, and the framework through which that commitment is put into practice, monitored and enforced. It applies to the organisation’s governance, its training and accreditation activities, its employment and recruitment practices, its commercial relationships, and the conduct it expects of those it trains.

Britannia Elite operates in the security, training and justice-sector environment. That sector carries a heightened risk of adverse human rights impact — through the use of force, the exercise of authority over others, access to personal data, and deployment into sensitive operating environments. With that exposure comes a corresponding responsibility. This Policy exists so that responsibility is met deliberately and verifiably, not left to assumption.

The Policy is also a working instrument. It is written to satisfy the human rights expectations of clients, financiers, awarding bodies and regulators, and to support due-diligence and procurement processes in the extractive, infrastructure and institutional markets in which the organisation and its partners operate.

2. Scope and application

This Policy is group-wide and binding. It applies to:

• Britannia Elite Ltd and all current and future group entities, subsidiaries, joint ventures and associated delivery bodies;
• all directors, officers, employees, instructors, assessors, consultants and contractors, whether permanent, temporary or sub-contracted;
• all learners, trainees and programme participants;
• all partner organisations, awarding bodies, agents, suppliers and service providers acting in connection with Britannia Elite; and
• all training sites, operational environments, events and digital platforms operated under, or on behalf of, the Britannia Elite brand.

Compliance is mandatory. Where this Policy sets a higher standard than local custom or practice, the higher standard applies. Where any provision conflicts with applicable law, the organisation will comply with the law and seek ways to honour the principles of this Policy to the greatest extent the law allows.

3. Definitions

4. Legal and normative framework

Britannia Elite aligns this Policy with the principal international, United Kingdom and Ugandan instruments governing human rights and the responsible provision of security. The organisation states its alignment with these standards as a commitment; where a standard provides for formal certification or membership, the organisation will pursue it as its management system matures and does not claim any certification it has not been granted.

4.1 International human rights law

• The Universal Declaration of Human Rights (1948);
• The International Covenant on Civil and Political Rights (1966) and the International Covenant on Economic, Social and Cultural Rights (1966) — together with the UDHR, the International Bill of Human Rights;
• The UN Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (1984);
• The Convention on the Elimination of All Forms of Discrimination against Women (1979) and the Convention on the Rights of the Child (1989); and
• The fundamental Conventions of the International Labour Organization, covering freedom of association and collective bargaining, the elimination of forced and compulsory labour, the abolition of child labour, the elimination of discrimination in employment, and a safe and healthy working environment.

4.2 Business and human rights

The UN Guiding Principles on Business and Human Rights (2011) provide the authoritative global framework and the backbone of this Policy. Built on three pillars — the State duty to protect, the corporate responsibility to respect, and access to remedy — they require organisations to know and show that they respect human rights through ongoing human rights due diligence. Britannia Elite adopts this framework in full (see Section 8).

4.3 Security and conduct standards

• The Voluntary Principles on Security and Human Rights (2000) — the leading framework for managing security in the extractive and energy sector, addressing risk assessment and the conduct of public and private security, with force used only when strictly necessary and proportionate to the threat.
• The International Code of Conduct for Private Security Service Providers (ICoC, 2010; amended 2021), and its Geneva-based oversight body, the ICoC Association (ICoCA, established 2013). Britannia Elite supports the principles of the Code and will pursue Association membership and certification through the recognised standards as it matures.
• ISO 18788:2015 — Management system for private security operations. Britannia Elite designs its management system to be consistent with this standard, which requires accountability to law and respect for human rights, and is a recognised pathway to ICoCA certification.
• The Montreux Document (2008) — on the international-law obligations and good practices for States relating to private military and security companies.
• The UN Code of Conduct for Law Enforcement Officials (1979) and the UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (1990) — the international benchmarks for lawful, necessary and proportionate use of force, which inform all use-of-force training content (see Section 9).

4.4 Client and project-finance standards

IFC Performance Standard 4 — Community Health, Safety, and Security (2012). Where Britannia Elite trains or supports personnel deployed on financed projects, it does so in a way that helps clients meet PS4, which requires that security arrangements are managed consistently with human rights, that personnel are appropriately trained and bound by a code of conduct, and that allegations of misconduct are investigated. The organisation will provide documentation to support clients’ environmental and social due diligence.

4.5 United Kingdom law

• The Human Rights Act 1998, which gives effect in UK law to the European Convention on Human Rights;
• The Modern Slavery Act 2015;
• The Equality Act 2010;
• The Bribery Act 2010; and
• The Data Protection Act 2018 and the UK General Data Protection Regulation.

4.6 Ugandan law

• The Constitution of the Republic of Uganda 1995, Chapter Four (Protection and Promotion of Fundamental and Other Human Rights and Freedoms) — including equality and freedom from discrimination (Article 21), the right to life (Article 22), personal liberty (Article 23), respect for human dignity and protection from inhuman treatment (Article 24), protection from slavery, servitude and forced labour (Article 25), and the right to privacy (Article 27);
• Article 44, which makes freedom from torture and cruel, inhuman or degrading treatment, freedom from slavery or servitude, the right to a fair hearing, and the right to an order of habeas corpus non-derogable in any circumstances;
• The Uganda Human Rights Commission, the independent constitutional body established under Article 51;
• The Prevention and Prohibition of Torture Act 2012 and its Regulations 2017, which domesticate the Convention against Torture and extend liability to persons acting in a private capacity;
• The Human Rights (Enforcement) Act 2019;
• The Employment Act 2006 and the Occupational Safety and Health Act 2006; and
• The Data Protection and Privacy Act 2019.

5. Policy statement and commitment

Britannia Elite affirms that human rights are universal, inalienable and non-negotiable. The Board commits the organisation to respect human rights wherever it operates, to avoid causing or contributing to adverse human rights impacts, and to use its influence to prevent or mitigate impacts directly linked to its operations, programmes or relationships. In particular, Britannia Elite commits to:

• respect and protect the rights, dignity and welfare of every person who interacts with the organisation;
• conduct ongoing human rights due diligence and act on what it finds;
• hold all use-of-force and security training to the standard of legality, necessity, proportionality and accountability;
• operate fair, safe and lawful employment, recruitment and training practices;
• deal only with partners and clients who can demonstrate rights-respecting practices;
• provide accessible, fair and effective channels for raising concerns, and enable access to remedy where harm occurs; and
• be transparent about its commitments, its performance and its shortcomings, and to improve continually.

6. Core human rights principles

7. Governance and accountability

Accountability for human rights sits at Board level and runs through every line of management. Responsibility cannot be delegated away by any individual who exercises authority on the organisation’s behalf.

8. Human rights due diligence

Britannia Elite is committed to ongoing human rights due diligence, consistent with the UN Guiding Principles, and continues to embed it across its activities. It is proportionate to the organisation’s size and risk profile and is reviewed at least annually. The process has four continuous stages.

8.4 Communicate and account

The organisation accounts for how it addresses its impacts — to affected people, clients, financiers and oversight bodies — through reporting that is proportionate and does not itself create risk to any individual.

8.5 Client, partner and contract screening

Before entering or renewing a relationship, Britannia Elite screens clients, partners, agents and suppliers for human rights risk. Relationships may be declined, made conditional, suspended or terminated where there is credible evidence of involvement in human rights abuses or an unwillingness to remediate. Human rights expectations are written into contracts and partnership agreements.

9. Use of force and firearms

Because Britannia Elite trains security personnel, the use of force is its most significant area of potential human rights impact. The following standards are non-negotiable and govern all relevant training, regardless of client, market or contract.

9.1 Governing principles

• Legality — force is used only for a lawful purpose and within the law of the jurisdiction concerned;
• Necessity — force is used only when strictly necessary, and only to the minimum degree required;
• Proportionality — the force used is proportionate to the lawful objective and the seriousness of the threat;
• Precaution — non-violent means are attempted first wherever feasible, and force is de-escalated as soon as possible; and
• Accountability — any use of force can be explained, is recorded, and is subject to review.

These principles reflect the UN Code of Conduct for Law Enforcement Officials and the UN Basic Principles on the Use of Force and Firearms. Firearms training, where delivered, confers no legal authority of any kind; lawful authority derives solely from the licensing and legal framework of the jurisdiction in which a person is employed.

9.3 Prohibited training outcomes

Britannia Elite will not design, deliver or knowingly support training that is intended or reasonably likely to enable:

• torture or cruel, inhuman or degrading treatment;
• extrajudicial, arbitrary or summary action against any person;
• the suppression of lawful assembly, expression or association;
• indiscriminate or disproportionate force; or
• any other act that would constitute a serious human rights violation.

10. Operational commitments

10.1 Training delivery

Training content reflects human rights principles and lawful practice. Instructors model ethical, respectful and professional behaviour. Training environments are free from harassment, intimidation, discrimination and abuse, and reasonable adjustments are made for disability and need.

10.2 Recruitment, employment and labour rights

Recruitment, selection and progression are fair, transparent and merit-based. The organisation prohibits forced, bonded and child labour, respects freedom of association, pays lawfully and on time, provides safe working conditions, and does not retain workers’ identity documents or charge recruitment fees to workers.

10.3 Conduct and behaviour

All staff and learners uphold professional conduct consistent with this Policy. Abusive, discriminatory or degrading behaviour is prohibited and subject to disciplinary action.

10.4 Partnerships and supply chain

Britannia Elite collaborates only with organisations that can demonstrate lawful, ethical and rights-respecting practice. Partnerships may be suspended or ended where credible evidence of human rights violations emerges and is not remediated.

10.5 Vetting and screening of personnel

Personnel are vetted proportionately to their role and risk, including identity, right-to-work and relevant background checks, so that authority and weapons-related training are not extended to those who present an unmanaged risk to others.

10.6 Data protection, privacy and surveillance

Personal data is processed lawfully, fairly and securely under the applicable UK and Ugandan data protection law, collected only for defined purposes, and accessed only by those who need it. The organisation does not train or facilitate unlawful surveillance.

11. Salient human rights risks and mitigations

Britannia Elite identifies and records its salient human rights risks. The principal risks and their primary controls are summarised below, and are reviewed at least annually.

12. Vulnerable groups, gender equality and PSEAH

Britannia Elite gives particular attention to people at heightened risk of harm, including women, children, persons with disabilities, and people in detention or displacement. The organisation promotes equal and safe participation for women across its programmes, including dedicated female training pathways delivered in a secure and structured environment.

The organisation maintains a zero-tolerance position on sexual exploitation, abuse and harassment. All staff, instructors and learners are bound by clear standards of conduct; reports are handled confidentially and survivor-centred; and substantiated cases result in disciplinary action and, where appropriate, referral to authorities.

13. Prohibited practices

The following are strictly prohibited in all circumstances:

• Physical, emotional or psychological abuse
• Torture or cruel, inhuman or degrading treatment
• Harassment, bullying, intimidation or coercion
• Discrimination of any kind
• Sexual exploitation, abuse or harassment
• Forced, bonded or child labour, and unsafe work
• Retaliation against anyone raising a concern in good faith
• Misuse of authority, power or position

14. Grievance mechanism and access to remedy

Anyone — including staff, learners, partners, community members and members of the public — may raise a human rights concern. Concerns may be raised in confidence and, where the reporter wishes, anonymously.

Consistent with the UN Guiding Principles, the grievance mechanism is designed to be:

• Legitimate — trusted and fairly administered;
• Accessible — known to and usable by all who may need it, with assistance for those facing barriers;
• Predictable — with clear stages, timeframes and outcomes;
• Equitable — giving complainants fair access to information and support;
• Transparent — keeping parties informed, consistent with confidentiality;
• Rights-compatible — delivering outcomes that accord with human rights; and
• A source of learning — feeding lessons back into prevention.

Where Britannia Elite has caused or contributed to harm, it will provide for or cooperate in legitimate remedy.

15. Reporting, investigation and response

When a concern is raised:

1. it is acknowledged and formally recorded;
2. a designated senior officer or panel reviews it and decides the appropriate response;
3. evidence is gathered impartially, securely and proportionately;
4. interim protective measures are taken where needed to keep people safe;
5. appropriate action follows — corrective or disciplinary measures, training, policy change, suspension or termination of a relationship, remedy, and referral to law-enforcement or regulatory authorities; and
6. outcomes are documented and communicated to the parties so far as confidentiality allows.

Investigations are conducted with fairness, confidentiality and respect for all parties, including the presumption of innocence and the right to be heard.

16. Training and awareness

All staff and instructors are required to complete training on human rights principles and legal obligations; ethical conduct and professional standards; safeguarding and the protection of vulnerable people; equality, diversity and non-discrimination; PSEAH; and reporting and escalation. Use-of-force instructors are additionally trained to apply the human-rights filter. Learners receive clear guidance on their rights, responsibilities and expected conduct.

17. Monitoring, review and continuous improvement

This Policy is reviewed by senior leadership at least annually, and sooner following any material incident, legal change or new contractual requirement. Performance is monitored through defined indicators — including grievances received and resolved, training completion, incidents and their outcomes, and due-diligence actions — and the Board receives a regular report. Findings drive improvement to the Policy, controls and training.

18–20. Related policies, breach and approval

18. Related policies

This Policy is read together with, and supported by, the organisation’s Code of Conduct, Modern Slavery Statement, Equality, Diversity & Inclusion Policy, Safeguarding Policy, Use of Force Policy, Data Protection & Privacy Policy, Whistleblowing Policy, and Vetting & Screening Procedure. Where any of these provides more detail on a matter covered here, both apply.

19. Breach and consequences

A breach of this Policy is treated seriously. Depending on its nature and severity, a breach may result in disciplinary action up to dismissal, removal from a programme, termination of a contract or partnership, withdrawal of certification, and referral to law-enforcement or regulatory authorities. Conduct that violates human rights may also constitute a criminal offence under UK or Ugandan law.

20. Approval and review

This Policy is approved by the Board of Directors of Britannia Elite Ltd and issued under the authority of the Chief Executive Officer. It takes effect on approval and remains in force until superseded.

Normative framework reference

Human rights due-diligence checklist

Before each programme and client engagement, Britannia Elite works through a human rights due-diligence checklist. Each item is evidenced and dated:

• Operating context and salient risks identified and recorded
• Client, partner, agent and supplier screened for risk
• Human rights clauses in the contract or agreement
• Personnel vetted proportionately to role and risk
• Use-of-force and weapons content passed the filter
• Instructors briefed and authorised to halt non-compliant sessions
• Grievance channel communicated to learners and partners
• Safeguarding / PSEAH measures in place for the cohort and site
• Data protection requirements met for enrolment and records
• Indicators set and a review point scheduled
• Decision recorded: proceed / with conditions / decline

How to raise a concern

Anyone with a human rights concern about Britannia Elite — whether a member of staff, a learner, a partner, a community member or a member of the public — is encouraged to raise it. You can do so by email to info@britannia-elite.co.uk, which is monitored by the Chief Executive Officer, or in person to any manager, instructor or the human rights lead. Concerns about the most senior staff may be taken to the Board.

When raising a concern it helps to include, where you can, what happened, where and when, who was involved, whether anyone else was affected or witnessed it, and the outcome you are seeking — but a concern will still be received and acted on even if you cannot provide all of this. You may ask to remain anonymous.

Every concern is taken seriously. It will be acknowledged, recorded and investigated promptly, impartially and in confidence, and no one will face retaliation for raising a concern in good faith.