Statement of Policy
Continuity Global Solutions (Continuity) is committed to maintaining a collegial work environment in which all individuals are treated with respect and dignity. Grievances will be treated seriously and with sensitivity, having due regards to procedural fairness and confidentiality. No employee shall be subjected to discrimination or adverse treatment for participating in a grievance procedure.
Continuity will respect all persons alleging improper conduct providing processes for fair and transparent resolution. Continuity will ensure that personnel who report wrongdoings in good faith are provided protection against any retaliation for making such reports, such as shielding them from unwarranted or otherwise inappropriate disciplinary measures, and that matters raised are examined and acted upon without undue delay.
Continuity’s Grievance Policy meets all aspects of the International Code of Conduct Grievance Procedures (https://www.icoca.ch)
Definition of Grievance
A “basic grievance” is defined as a claim that the Continuity has violated a published policy in the manner in which an employee was treated. Basic grievances do not involve claims of: Possible discrimination on the basis of race, color, sex (including sexual harassment or sexual orientation), religion, creed, age, handicap, national origin, or status as a veteran. Employees wishing to pursue claims of such discrimination must contact the Continuity Program Manager at the Continuity HQ.
Disputes over salary grades or salary/rate of pay, or disputes over a supervisor’s judgment regarding job performance or professional competence should be brought to the employee’s human resources administrator. Although problems of this nature are not covered by the Basic Grievance Policy, an employee with these concerns is encouraged to discuss them with his/her supervisor or the Human Resources Department at Continuity GS HQ, or the appropriate contact within the Continuity HQ at the Program Management level.
The Office of Human Resources will determine whether or not a dispute is within the scope of this policy.
Individuals Covered Under the Policy
This policy covers all employees. Continuity will acknowledge grievances by employees or by non-employees who conduct business with Continuity. Any employee who feels they have been subjected to mistreatment should communicate the matter immediately and directly to either the Office of Human Resources, the Program Manager, or Senior Management. Continuity will investigate any incident of alleged mistreatment by a person who is not an employee of Continuity to the extent practical and will take any action it deems appropriate after evaluating all circumstances. Continuity encourages reporting of all incidents of harassment, regardless of whom the offender may be, in accordance with the method set out below.
Reporting a Complaint Informal Procedure
Continuity encourages individuals who believe they are being mistreated to clearly and promptly notify the offender that his or her behavior is unwelcome. If for any reason an individual does not wish to approach the offender directly, or if such discussion does not successfully end the harassment, the individual should notify the either the Office of Human Resources, the Program Manager, or Senior Management of Continuity, who may talk to the alleged harasser or arrange for mediation between the individual and the alleged harasser with a third person acceptable to both.
In the event that the reporting individual does not wish to pursue the informal procedure, or in the event that the informal procedure does not produce a result satisfactory to the reporting individual, the following steps should be followed to report the grievance to initiate a formal procedure:
Time for Reporting a Complaint
Prompt reporting of complaints is strongly encouraged as it allows for rapid response and resolution of objectionable behavior or conditions for the reporting individual and any other employees. Failure to report an incident may result in the offender not being aware his or her conduct is offensive and thereby repeating the activity.
Protection Against Retaliation
Continuity will not retaliate against an individual who makes a report of mistreatment, nor permit any employee to do so. Retaliation is a very serious violation of this policy and should be reported immediately. Any individual found to have retaliated against an individual for reporting harassment, or against anyone participating in the investigation of a complaint, may be subject to appropriate disciplinary action, up to and including termination of employment.
Any allegation of harassment brought to the attention of either the Office of Human Resources, the Program Manager, or Senior Management will be promptly investigated. Confidentiality will be maintained throughout the investigation process to the extent practical and appropriate under the circumstances.
Sanctions for Mistreatment
Individuals found to have engaged in misconduct constituting mistreatment shall be subject to appropriate disciplinary action, up to and including termination of employment. Appropriate sanctions will be determined by the Chief Executive Officer of Continuity. In addressing incidents of harassment, Continuity’s response at a minimum will include reprimanding the offender and preparing a written record of the investigation and outcome.
If an investigation results in a finding that the reporting individual falsely and maliciously accused another of harassment, the reporting individual shall be subject to appropriate disciplinary action, up to and including termination of employment.
Maintaining a Written Record of the Complaint
Continuity shall maintain a complete written record of each complaint and how it was investigated and resolved. Written records shall be maintained in a confidential manner to the extent practical and appropriate and shall be maintained in the possession of the Chief Executive Officer of Continuity.
The following comprise Continuity’s Grievance Policy (all information will be held confidential):
- It is to be transparent and fair by nature and in its application.
- Investigate allegations promptly, impartially and with due consideration to confidentiality.
- In the case of formal action the aggrieved party should provide Continuity management with a written submission, which provides details of the complaint (Nature, time, place and those involved).
- Continuity desires to deal with incidents promptly and will take steps to follow up, make decisions, and confirm actions in the most expedient manner possible.
- Keep records about any such allegations, findings or disciplinary measures. Except where prohibited or protected by applicable law, such records should be made available to a Competent Authority on request.
- Employees have the right to be accompanied at any meeting concerning a grievance. In cases where group grievances are addressed, a maximum of two observers will be allowed to attend the grievance process in addition to the representatives.
- Aggrieved parties may appeal against the decision made.
- Cooperate with official investigations, and not participate in or tolerate from their Personnel, the impeding of witnesses, testimony or investigations.
- Continuity will take appropriate disciplinary action, which could include termination of employment in case of a finding of such violations or unlawful behavior.
- Ensure that personnel who report wrongdoings in good faith are provided protection against any retaliation for making such reports, such as shielding them from unwarranted or otherwise inappropriate disciplinary measures, and that matters raised are examined and acted upon without undue delay.
INTERNAL GRIEVANCE PROCEDURES
An employee who has a grievance over any work-related issue has the right to raise their concerns with Continuity management. Informal Dealing. Issues of a serious nature should always be dealt with formally; however, when mutually agreed, less serious grievances should be dealt with informally. This should take the form of an informal discussion between the aggrieved party and an appropriate manager. If it becomes clear that the matter cannot be resolved satisfactorily, or that the case is more serious that first assessed, the formal process must be adopted. If both parties agree that the grievance has been resolved satisfactorily no further action need be taken but the manager should make an informal note to record the event, its nature and outcome. Formal Process. The formal process may involve up to 4 procedures:
- Grievance Submission. The aggrieved party must provide an appropriate Continuity manager (i.e.: direct supervisor, senior Supervisor, site HR, PM, RPM, SPM, DO, HQ HR or an executive) with a written submission, which gives details of the grievance; these should include:
- The nature of the grievance
- Where the incident(s) has occurred
- Who has been involved
- When the incident(s) happened or has been happening.
- Any actions that have been taken so far by any of the parties concerned
- Grievance Hearing. Continuity’s management will arrange for a meeting to take place as quickly as possible to discuss the grievance. In preparing for such a meeting managers should consider the following: having an impartial record keeper, making themselves aware of the full facts of the case, how similar grievances may have been resolved in the past, whether an interpreter may be needed. The aggrieved party has the right to be accompanied by a colleague, who may be allowed to address the meeting on the employee’s behalf, sum up the employee’s case, respond to any views expressed at the meeting and confer with the employee. Once the hearing has finished the Continuity manager will take time to consider the case.
- Management Decision Process. In making the decision upon the outcome and Continuity’s position the manager should consult the Director of Human Resources, Head of Legal and Contracts or other senior managers within the Company – and is encouraged to do so. Regardless the decision should be presented in writing within 24hrs of the hearing. Once it has been made the manager is to inform the aggrieved party in writing of the outcome. The latter has the right to appeal if they are dissatisfied.
- Grievance Appeal. If the aggrieved party is dissatisfied with the outcome of the decision, they can appeal but this must be submitted within 5 days explaining their grounds for appealing in writing to Continuity management. An appeal meeting should be arranged within 5 days and will be run by the next more senior manager. The hearing will follow the format described in 7b above and the aggrieved party may be accompanied.
Grievance Record Keeping. Records of the following are to be made and kept for seven (7) years:
- Nature and details of the grievance
- What was decided and the actions taken.
- The reasons for these actions.
- Whether an appeal was made and its outcome.
- Any other subsequent developments.
EXTERNAL GRIEVANCE PROCESS
The policy set out in paragraph 4 applies to a non-employee who has a grievance to make against the Company. The procedures shown in Figure 1 and described in paragraphs 6 and 7 are very similar but the complaint is likely to be dealt with at corporate level in the first instance. In summary:
- Informal Approach. Continuity prefers to resolve grievance issues on an informal basis whenever possible; but only when this course is mutually agreeable.
- Formal Approach. The formal approach requires the aggrieved party to submit the details of their complaint in writing (as per 7a) to the Continuity Director of Human Resource or COO at 7389 Lee Highway, Suite 207 Falls Church, VA 22042 or email firstname.lastname@example.org.
- Office 703-527-8088. Arrangements will be made for a hearing – the composition of attendees will be agreed on a case-by-case basis. Continuity will inform the aggrieved party of its decision in writing within 24 hours of the hearing being completed. The aggrieved party has the right to appeal within 5 days and this process should be started by a submission in writing explaining the grounds for this appeal. A further hearing will be convened but managed by a different person with the findings being promulgated within 24 hours of its completion.
Grievances are to be handled with sensitivity and respect, but without undue delay. The procedures are relatively straightforward; the importance of keeping records is emphasized. Advice should be sought from senior managers (particularly the Director of Human Resources and the Head of Legal and Contracts) from the outset. The over-arching intent is for the fair treatment of all persons within and external to Continuity.
As an alternative for those wishing to resolve disputes between themselves without resorting to the formal complaint procedures, Continuity will, if all parties agree, make available a trained outside mediator to help those parties find an amicable, informal solution. If mediation does not solve the problem, the affected parties may still use the procedures in this policy.
Continuity has developed this policy in an effort to ensure that all of its employees and associate personnel can work in an environment free from mistreatment. Continuity is committed to eliminating any mistreatment in the workplace.