January 7, 2017

Vighter’s PSC.1 Program

General Information Regarding Vighter’s PSC.1 Program

ANSI/ASIS PSC.1-2012 is a management standard for quality of private security company operations. Developed by more than 200 experts from 24 countries, this series helps private security service providers or private security companies (PSCs) ensure quality of service, manage risks, and protect human rights in areas of the world where rule of law has been undermined due to acts of war or natural disaster, including the maritime environment.

The standard seeks to operationalize the International Code of Conduct (ICoC) within a formal structure familiar to businesses. That structure, with national and international supervision, provides auditable procedures for the development of the standard, certification to it, and monitoring of ongoing compliance.

PSC.1 establishes a mechanism for private security service providers and their clients to provide demonstrable commitment, conformance, and accountability to the principles outlined in the International Code of Conduct for Private Security Service Providers and the Montreux Document.

Code of Business Conduct

Click the link to view Vighter’s VMG Code of Business Conduct 20170309

Statement of Conformance

Vighter provides medical services in conflict zones and geographically austere environments. The arenas within which we work are often torn by insurrection or military strife and complicated by terrorist activity. All of these factors regularly contribute to weakened governance, the erosion of the Rule of Law, and an inability of the local authorities to enforce laws and standard operating procedures across all sectors of society. This results in a high risk of human rights violations, substandard business operations, and unethical practices. It is, therefore, critical that companies in our industry conduct operations in a safe and responsible manner that promotes the ethical treatment of people and best-in-class operations and that we uphold the highest of standards. It is also imperative that we operate in accordance with internationally accepted standards for Private Security Companies and we abide by international and local laws and respect humanitarian law and human rights.

 

In the 10+ years of operating as a reputable and dependable expeditionary service provider, Vighter has developed very mature and well-established Standard Operating Procedures (SOPs) that define how we conduct our operations. These SOP’s form the framework of our adherence to the internationally recognized standard of ANSI/ASIS PSC.1-2012 and the principles contained in its normative references, the Montreux Document, Implementing the United Nations “Protect, Respect and Remedy” Framework 2011, and ICoC. Vighter is highly committed to our adherence to these standards and guiding principles, and we demand compliance from our all of our personnel. To enable our personnel to meet or exceed these standards, we conduct formal training and on-the-job training and provide documentation (including Employee Handbooks, Management Handbooks, and SOPs providing guidelines for all aspects of our operations) that requires written acceptance of and a commitment to uphold the required standards.

 

Vighter’s commitment to uphold the highest ethical and operational standards includes:

  • Effective mitigation and management of both internal and external risks through the diligent application of an established and standardized Risk Management Policy and Procedure.
  • Selection of appropriately qualified personnel through effective application of our demanding recruiting, vetting, and screening processes in compliance with applicable laws and host country regulations and contractual obligations.
  • Selection of appropriate subcontractors and/or vendors through careful screening and vetting in conformance with the standards of ANSI/ASIS PSC.1-2012 to provide a positive contribution to the communities in the regions within which we operate.
  • Selection of business opportunities and targets using a Risk Management approach that ensures regulatory compliance and respect for human rights and the environment.
  • Ensuring the health and safety of staff, clients, and communities, through the effective mitigation of environmental and physical risks and the provision of appropriate training and equipment required to execute tasks.
  • Effective implementation, monitoring, and auditing of the Vighter’s QAMS to ensure quality of service across all of our business processes and deliverables.
  • Distribution of the Vighter HR handbook and QAMS to all personnel and ensuring all Vighter personnel understand and commit to operating within the prescribed guidelines and framework.
  • Providing fair compensation to employees, subcontractors, and/or vendors in accordance with applicable laws and regulations.
  • Ensuring that all staff are trained and equipped to successfully execute their duties in compliance with the US Foreign Corrupt Practices Act (FCPA), in order to combat corrupt practices and bribery at all levels.
  • Compliance with US and Host Country import/export regulations, including the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) as related to the procurement and import/export of all equipment and technology required for the delivery of our services.
  • Through our Quality Assurance Management Systems and Quality Control Systems, Vighter strives to continually improve and mature our service offerings and operations worldwide. We are fully committed to monitoring and policing any events that are found to be non-compliant or have the potential to risk our ability to comply with any of the internal or external standards that we have committed to upholding. In the event that we do discover or learn of a negative event, we commit to investigating the incident and taking the necessary steps to remedy the issue, document and learn from the event, implement, as far as possible, steps to ensure the negative event does not occur again, and where applicable, take the necessary disciplinary steps to ensure conformance with all internal rules and external regulations and laws.

 

Vighter is 100% committed to ensuring that our worldwide operations are conducted in a responsible, ethical, and ever-improving manner and to instilling a corporate culture where human rights and ethical operation considerations are at the forefront of every decision made and every action taken by every member of the Vighter Team.

///Original Signed\\\

Jeremy Calvert

COO

 

Continuous Improvement & Feedback

Vighter is committed to continuous improvement and seeks input from employees and non-employee stakeholders to meet this goal. The senior management team takes the submission of grievances, suggestions for improvement, and complaints very seriously. Vighter accepts submissions regarding potential or actual non-conformances with ANSI/ASIS PSC.1, Vighter’s Code of Business Conduct and other policies, and international laws, local laws and human rights, as well as suggestions for improving our services. Each submission will be reviewed in a timely and fair fashion and action, if required, will be taken to address the submission and improve Vighter’s delivery of services.

To report an ANSI/ASIS PSC.1-related concern in response to the conduct of a Vighter employee, please choose from the following options:

  1. Vighter Medical Group management: (507) 474-8995
  2. Email: [email protected]

Upon receiving a complaint, Vighter will maintain confidentiality, as far as possible, and prevent retaliation against the individual submitting the complaint. Vighter will conduct an internal investigation and, if warranted, will communicate with appropriate authorities. Vighter will cooperate fully with external investigations by those authorities. Additionally, Vighter will identify root causes of any legitimate grievances and address them through corrective and preventative actions as necessary.

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