Complaints Incident Management

Incident Management Guidelines

Complaints made by governments, local authorities, other companies, communities, groups, or individuals may result in reputational and liability risks to the company. They may also generate resentment and ill will from local communities and workforces that could result in peripheral threats to business activities, such as widespread labor disputes or, in severe cases, to threats posed directly to personnel and assets. Complaints may be related to employment conditions and terms, labor disputes, business arrangements and contracts, the leasing of vehicles or facilities, damage resulting from accidents, contaminant spills, contract awards, or construction tasks. Complaints may also result from disputes over right of passage or land ownership claims.

In the event of a complaint incident occurring, the following points should be addressed:

Action Points

1. Stand up the nominated incident manager using the SAD CHALETS system. Mobilize the Crisis Response Team only if the incident is significant, with immediate and high‐impact risk implications.
2. Establish whether there is documented evidence to substantiate a complaint.
3. Establish immediate risks associated with a complaint:
   • Physical
   • Operational
   • Liability
   • Reputational
   • Relationship
4. Take written statements from the person or group making the complaint.
5. Take written statements from those accused of a wrongdoing.
6. Seek legal assistance if appropriate.
7. Notify law enforcement agencies if a civil issue.
8. Make no admission of guilt or responsibility until all facts are known and authorized persons determine the course of action.
9. Ensure that all information is accurately documented.
10. Take disciplinary or compensation actions within permitted parameters of authority.
11. Provide an IMP Risk Assessment Report as soon as possible.

Site Occupation or Sit‐Ins Incident Management

Incident Management Guidelines

Site occupation or sit‐ins may occur for a variety of reasons. Domestic terrorists or special‐interest groups may seek to stage a public protest, labor disputes may result in employees disrupting work, and local communities or nomadic tribes may seek to publicly illustrate concerns or disagreements with the company by occupying areas, offices, or work spaces. Site occupation or sit‐ins may be peacefully conducted, or may be violent in nature. Durations of occupancy may be short, or may be for long periods of time, especially if personnel cannot be evicted safely.

In the event of a site occupation incident occurring, the following points should be addressed:

Action Points

1. Stand up the Incident Management and Crisis Response Teams using the SAD CHALETS system.
2. Secure the facility to prevent access by additional unauthorized personnel.
3. Secure areas that are being occupied by unauthorized persons to prevent other areas being invaded. Secure offices, laptops, and sensitive information.
4. Clear the areas of employees, notify personnel of the situation, and avoid mixing staff and authorized persons where possible.
5. Alert the local police and request assistance in order to evict persons.
6. Determine other threats presented by the individuals or groups:
   • To steal information.
   • To sabotage materials, facilities, or equipment.
   • To illicit media attention.
   • To instigate a physical or verbal response from employees or managers.
   • To gain access to sensitive areas, or stage a sit‐in within offices or work sites.
   • To barricade or impede access to areas.
   • To intimidate, threaten, or harm employees.
   • To plant harmful or hazardous materials.
   • To conduct prank activities (disruptive in nature).
7. Passively attempt to escort persons from the area or building. Do not engage in aggressive measures unless essential. Such activities should be undertaken by security staff only.
8. Avoid inflammatory remarks or heated discussions.
9. Ask persons to leave a premises or work site politely; inform them of any laws or regulations they are breaking.
10. Do not discuss company activities, policies, or plans.
11. Record the group's or individual's activities using cameras or closed‐circuit TVs as part of investigation and legal response requirements.
12. Record their activities and note any risks posed to personnel, facilities, or materials.
13. Forward an IMP Risk Assessment Report when possible.

Espionage Incident Management

Incident Management Guidelines

Espionage can be conducted by individuals, groups, or governments in order to gain commercially sensitive information. Espionage can take many forms, either covert or overt, and can have significant impacts on a company, especially during a tendering phase of a business pursuit. Espionage can be conducted within the parameters of the law, or may be illegal. It can be geared to commercial activities, as well as operational functions.

In the event of an espionage incident occurring, the following points should be addressed:

 Action Points

1. Stand up the Incident Management and Crisis Response Teams using the SAD CHALETS system.
2. Determine what has occurred:
   • When did it happen?
   • Where did it happen?
   • Who was involved?
   • What information or materials were stolen or divulged?
   • What implications does this have to the company?
3. Secure facilities or sensitive materials to prevent further losses.
4. Take a statement from the individual reporting the event.
5. Determine whether any laws have been broken.
6. Determine who might be or is responsible:
   • Group or organization.
   • Individuals involved.
7. Determine whether persons are at physical risk following the event; stop any activity that might be compromised if persons are at risk.
8. Alert police or federal agencies if urgent in nature.
9. Provide an IMP Risk Assessment Report as soon as possible.