Ship Recycling Policy
We at, Kabir Group Ship Recycling Facilities, are committed to the safe and environmentally sound recycling of ships and to:
- Comply with applicable national and international legislations, regulations and other requirements.
- Committed to enhance customer satisfaction by continual improvement of implemented management system
- Provide safe and healthy working conditions for the prevention of work related injury and/or ill health.
- The protection including prevention of pollution of the environment by proper waste management through life cycle analysis.
- We are committed to ensure the consultation and participation of our workers to all relevant activities with OHSAS.
- Reduce and minimize ecological footprint of our internal operations with a focus on low carbon growth path and use renewable energy.
- Adopt the 3R (reduce, reuse and recycle) philosophy for all types of wastes toward prevention of pollution and dispose of "inevitable" wastes in line with regulatory requirements or industry best practices and committed to protect our environment.
- Introduction of a robust safety system for all our operations with a special attention to our contractors / subcontractors
- Comply with relevant Interested Parties requirements.
- Continually improve the implemented the Integrated Management System (IMS) as well as enhance relevant interested parties satisfaction by regular review of this policy.
Human Rights Policy
Respect for human rights is the fundamental value of Kabir Group Ship Recycling Facilities. We strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights in our relationships with our employees, suppliers and relevant interested parties and to:
- We acknowledge that we are part of the communities in which we operate and engage with communities on human rights matters that are important to them such as land rights, access to water and health.
- We are committed to equal opportunity and are intolerant of discrimination and harassment.
- We work to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, color, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, political opinion or any other status protected by applicable law.
- The basis for recruitment, hiring, placement, development, training, compensation and advancement at the Company is qualifications, performance, skills and experience.
- We do not tolerate disrespectful or inappropriate behaviour, unfair treatment or retaliation of any kind.
- We respect our employees’ right to join, form or not to join a labour union without fear of reprisal, intimidation or harassment.
- We follow our recycling policy as our commitment to ensure safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal requirements.
- We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats.
- Security safeguards for employees are provided, as needed, and are maintained with respect for employee privacy and dignity.
- We prohibit the use of all forms of forced labour, bonded labour and modern forms of slavery.
- We prohibit the hiring of individuals that are under 18 years of age.
- We compensate employees competitively relative to the industry and local labour market and we work to ensure full compliance with applicable wage, work hours, overtime and benefits laws.
- We strive to create workplaces in which open and honest communications among all employees are valued and respected.
We also ensure that employees are aware of the Human Rights Policy. This policy is communicated and explained to all employees of this facility by various formal and informal means like tool box meeting, internal training etc. The Human Rights Policy is displayed at various work places within the facility. This policy is also made available to the public and relevant interested parties through various digital platforms.
Drug Policy
Drug and Alcohol Free Workplace Policy.
Kabir Steel Limited is committed to maintaining the workplace free from the effects of drugs or alcohol to protect the health and safety of our employees, workers and visitors by ensuring:
- This policy applies to all employees including contractor workers and visitors
- All employees will be treated consistently and fairly in line with this policy and all matters concerning alcohol and drugs shall be treated as confidential.
- All employees must report to work in a condition to perform their very best
- KSL has zero tolerance over the use of drug and alcohol of any type within the facility premises
- Employees must not consume alcohol or any unlawful drugs in the workplace during work time or during a period prior to work where they may still be under the influence of alcohol and drugs effects which may carry over to the working hours. This includes business functions where the employee is representing the facility
- All employees are prohibited from the use, distribution, unlawful manufacture, dispensation, possession, sale and transfer
- Inappropriate behavior shown in relation to the use of drugs and alcohol will be dealt in accordance with the organization disciplinary rules and regulations
- Employees who are taking prescription drugs should ensure that they are aware of any side effects and advise their manager or a member of the management team immediately of any side effects of prescription drugs, which may affect work performance or the health and safety of themselves or others.
- The facility will raise awareness of alcohol or drug issues in the workplace and will provide signposting to employees of the support that is available. This awareness raising will include providing information leaflets, information on staff notice boards and /or be included on the web page as well.
The policy on drug and alcohol will be strictly enforced.
Disciplinary action in accordance with the facility disciplinary procedures will be undertaken where breaches of the policy occur. In the case of contractor workers services will be terminated immediately upon a breach of the policy.
Possession of or dealing in illegal drugs on facility premises will, without exception, be reported to the Police.
This policy will be communicated to all employees at induction and the policy will be made available on various location within the facility.
Other Policies
Policy Against Anti-Corruption and Ethical Behavior in the Workplace
At Kabir Ship Recycling Facilities, we are steadfast in our commitment to maintaining the highest standards of ethical conduct and integrity in all aspects of our operations. We firmly reject any form of corruption, bribery or unethical behaviour and are dedicated to fostering a workplace culture that upholds honesty, transparency and fairness.
We have a zero-tolerance policy for corruption, bribery and any form of unethical behaviour. Our employees, partners and associates are strictly prohibited from engaging in such activities.
We comply with all applicable laws and regulations related to anti-corruption and ethical business practices. We actively seek to exceed the legal requirements by implementing stringent internal controls.
We avoid situations where personal interests conflict with the best interests of the company. Employees are required to disclose any potential conflicts and act in a manner that prioritizes the company's well-being.
We compete fairly in the market and do not engage in unfair trade practices, collusion or any other activities that distort competition.
We provide channels for employees to report any suspected instances of corruption, bribery or unethical behaviour confidentially and without fear of retaliation. Reports will be thoroughly investigated and appropriate action will be taken.
We conduct thorough due diligence on our business partners, suppliers and clients to ensure they adhere to similar ethical standards and share our commitment to anti-corruption practices.
We protect whistle-blowers who report genuine concerns in good faith. Retaliation against whistle-blowers is strictly prohibited and appropriate measures will be taken to ensure their safety and well-being.
By adhering to these principles, we reinforce our dedication to maintaining the trust and respect of our stakeholders, creating a workplace environment that values integrity and contributing to a more ethical business landscape.
This policy will be communicated to all employees at induction and the policy will be made available on various location within the facility.
Policy Against Child and Forced labor
At Kabir Ship Recycling Facilities, we are firmly committed to the eradication of child labour and forced labour in all forms within our operations and supply chain. We uphold the principles of human rights, dignity and ethical business practices and we recognize our responsibility to ensure that our activities do not contribute to or support these harmful practices.
We strictly prohibit the use of child labour (under the age of 18 years) and forced labour in any aspect of our operations, including ship recycling, material distribution and all associated activities.
We conduct rigorous age verification processes to ensure that all employees, workers and individuals involved in our operations are of legal working age as defined by Bangladesh laws and regulations.
We extend our commitment to child and forced labour elimination to our supply chain partners. We work diligently to identify, assess and mitigate any risks of child or forced labour in the suppliers and contractors we engage with.
We believe that every individual deserves fair treatment, respect and the opportunity to work in safe and humane conditions. Our commitment to eradicating child and forced labour reflects our unwavering dedication to upholding these fundamental principles.
This policy will be communicated to all employees at induction and the policy will be made available on various location within the facility.
Policy Against Discrimination and Harassment in the Workplace
At Kabir Ship Recycling Facilities, we are committed to maintaining a workplace that fosters respect, inclusivity and equal opportunities for all employees. We firmly believe that diversity enhances our organizational strength and contributes to our collective success. Discrimination and harassment in any form is strictly prohibited within our workplace and we are dedicated to upholding this principle throughout all aspects of our operations.
We do not tolerate any form of discrimination or harassment based on race, colour, religion, gender, gender identity or expression, sexual orientation, national origin, age, disability, marital status, veteran status or any other characteristic protected by applicable laws. Our commitment to a discrimination-free workplace extends to all aspects of employment, including but not limited to hiring, promotions, transfers, training opportunities, compensation and benefits.
Managers, supervisors, and all employees are expected to adhere to this policy, promoting an environment that is free from bias, prejudice, and harassment. Any complaints or concerns related to discrimination will be promptly investigated and appropriate corrective actions will be taken as necessary. Retaliation against individuals who report discrimination or participate in investigations is strictly prohibited.
By embracing diversity and fostering an inclusive work culture, we aim to create a supportive environment where every employee can thrive, contribute their unique perspectives and collaborate effectively. Our commitment to non-discrimination is an integral part of our core values and integral to achieving our shared goals.
This policy will be communicated to all employees at induction and the policy will be made available on various location within the facility.
Policy for Contractors and Vendors
At Kabir Ship Recycling Facilities, we recognize the importance of building strong, ethical partnerships with our vendors and contractors. We are committed to establishing relationships that are founded on transparency, fairness, and mutual respect. This policy outlines our expectations and standards for all vendors and contractors who engage in business with us.
Vendors and contractors are expected to uphold the highest standards of ethical behaviour in all their interactions with our employees and our stakeholders.
Vendors and contractors must adhere to all applicable laws, regulations, and industry standards relevant to their products, services, and operations.
Vendors and contractors are responsible for delivering products and services that meet our quality standards and adhere to all safety requirements.
Vendors and contractors must engage in fair competition and avoid any form of collusion, bid rigging, or anti-competitive behaviour.
Vendors and contractors are prohibited from engaging in any form of corruption, bribery, or unethical practices. Gifts, entertainment and favours should not influence business decisions.
Vendors and contractors must protect any confidential information or data they have access to during the course of their engagement with us.
We encourage vendors and contractors to operate in an environmentally responsible manner, promoting sustainability and minimizing the impact on the environment.
Vendors and contractors must respect human rights, treat their employees fairly, and ensure safe and ethical working conditions.
Vendors and contractors must promptly report any concerns related to non-compliance with this policy. They are also expected to cooperate with any audits or assessments.
We regularly evaluate the performance of our vendors and contractors based on their adherence to this policy, quality of work, and alignment with our values.
By adhering to these standards, vendors and contractors contribute to our shared commitment to ethical business practices, sustainability and the creation of positive business relationships that benefit all parties involved.
This policy will be communicated to all employees at induction and the policy will be made available on various location within the facility.
Policy for Complaints & Suggestions
1. Purpose:
This policy outlines the procedure for submitting and handling complaints and suggestions from our stakeholders including workers, employees, suppliers, customers and any other interested parties. We value the feedbacks as it helps us improve our systems, products, services and processes.
2. Scope:
This policy applies to all individuals and entities associated with Kabir Ship Recycling Facilities including but not limited to customers, workers, employees and suppliers.
3. Definitions:
- Complaint: An expression of dissatisfaction or concern related to our process, products, services or any aspect of our operations.
- Suggestion: A proposal for improving our products, services or processes.
4. Complaints and Suggestions Submission:
- Customers, workers, employees and suppliers are encouraged to share their complaints or suggestions by utilizing the designated IMS/F/80 form. Completed forms can be deposited in the dedicated boxes conveniently located throughout our facility (Labor building, Gate-02, Contactor offices and Admin building)
- Employees are encouraged to use internal channels, such as their immediate supervisor or HR, to submit complaints and suggestions.
- The process to put complaints or suggestions are discussed in the tool box meeting with the workers.
5. Handling Procedure:
- All complaints and suggestions will be recorded and acknowledged in weekly basis.
- The Admin and relevant department will investigate the matter thoroughly.
- A response or resolution will be provided without any delay
- If further information or clarification is needed from the complainant, they will be contacted for the required details.
- In case of complex issues, facility management will contact with top management without any delay.
6. Confidentiality:
- All complaints and suggestions will be handled with utmost confidentiality. Only individuals involved in the investigation and resolution process will have access to the information.
7. Feedback and Continuous Improvement:
- We value feedback and view complaints and suggestions as opportunities for improvement.
- Data and trends from complaints and suggestions will be analyzed regularly to identify areas for enhancement.
- A systematic approach to address recurring issues and implement necessary corrective actions will be adopted.
8. Reporting:
- Periodic reports on complaints and suggestions, including the number received, resolved, and pending, will be generated and shared with top management and discussed in the MRM as necessary.
9. Review:
- This policy will be reviewed and updated as necessary to ensure its effectiveness and relevance.
This policy will be communicated to all workers, employees and other relevant interested parties at induction and the policy will be made available on various location within the facility.
Policy for Whistle-Blower
1. Purpose:
The purpose of this Whistleblower Policy is to provide a framework for employees, workers, stakeholders and third parties to report genuine concerns, illegal activities, unethical behavior or misconduct within Kabir Ship Recycling Facilities. This policy ensures the protection of whistleblowers and promotes transparency and integrity within the organization.
2. Scope:
This policy applies to all employees, workers, contractors, vendors, customers and any individuals or entities associated with Kabir Ship Recycling Facilities.
3. Definitions:
- Whistleblower: An individual who, in good faith, reports or discloses any illegal, unethical or improper activities within the organization.
4. Reporting Mechanism:
4.1 Reporting Channels:
- Kabir Ship Recycling Facilities encourage whistleblowers to report concerns through multiple channels, including but not limited to:
- Direct supervisors, foreman, managers or Facility Coordinator
- Human Resources department
- Anonymously through a hot line (KSL: +8801819329362, KSBL: +8801819329364)
- Email communication to the address (info@kabirshiprecycling.com)
4.2 Anonymous Reporting:
- Whistleblowers have the option to submit reports anonymously. The organization is committed to protecting the confidentiality and identity of anonymous whistleblowers to the extent allowed by law.
5. Reporting Procedure:
5.1 Good Faith Reporting:
- All reports must be made in good faith and based on reasonable belief.
5.2 Timely Reporting:
- Whistleblowers are encouraged to report concerns as soon as possible after becoming aware of the issue.
5.3 Detailed Information:
- Reports should include specific details, such as dates, locations, individuals involved and any supporting documentation.
5.4 Protection from Retaliation:
- Kabir Ship Recycling Facilities prohibits retaliation against whistleblowers who report in good faith. Any form of retaliation is a violation of this policy and will be subject to disciplinary action.
6. Investigation and Follow-Up:
- All reports will be promptly and thoroughly investigated. The investigation will be carried out impartially and with due regard for the rights of all parties involved.
7. Confidentiality:
- The confidentiality of the whistleblower's identity and the information provided will be maintained to the extent allowed by law and during the investigation process.
8. Non-Retaliation:
- Kabir Ship Recycling Facilities is committed to ensuring that whistleblowers are protected from any form of retaliation as a result of their report.
9. Reporting to Authorities:
- If necessary, Kabir Ship Recycling Facilities will report any illegal activities to the appropriate authorities in compliance with the law.
10. Review and Revision:
- This Whistleblower Policy will be reviewed periodically to ensure its effectiveness and relevance. Any necessary revisions will be made.
This policy will be communicated to all workers, employees and other relevant interested parties at induction and the policy will be made available on various location within the facility.
Policy for Labour Accommodation & Dining Facilities
1. Purpose:
Kabir Ship Recycling Facilities is committed to the well-being and safety of our employees. This Labor Accommodation & Dining Facilities Policy demonstrates our dedication to providing quality facilities that meet the needs and expectations of our valued workforce.
2. Scope:
This policy applies to all employees & workers who are living in labor building and use dining facilities.
3. Accommodation Standards:
3.1 Number of occupants per room
- The maximum number of the occupants in each room are defined and this will be followed accordingly.
3.2 Safety and Hygiene:
- Accommodation facilities must comply with all relevant safety and hygiene standards and regulations.
- Regular inspections will be conducted to ensure safety and hygiene are maintained.
3.3 Privacy and Comfort:
- Employees will have access to clean and comfortable living quarters, ensuring privacy and personal space.
3.4 Adequate Amenities:
- Accommodation facilities will provide necessary amenities, including beds, storage and sanitation facilities.
3.5 Maintenance:
- Accommodation facilities will be well-maintained, with timely repairs and upkeep.
4. Dining Facilities Standards:
4.1 Food Safety:
- Dining facilities must meet all food safety and hygiene standards and regulations.
- Regular inspections will be conducted to ensure food safety is maintained.
4.2 Varied and Nutritious Meals:
- A variety of nutritious meals will be provided to meet the dietary needs of our employees.
4.3 Cleanliness:
- Dining areas and kitchen facilities will be kept clean and sanitized at all times.
4.4 Hydration:
- Adequate clean drinking water will be available at all times.
5. Health, Safety & Recreation:
5.1 Occupational Health:
- Regular health check-ups will be conducted to monitor the well-being of our employees working in dining facilities.
5.2 Fire Safety:
- Accommodation and dining facilities will have adequate fire safety measures in place.
5.3 Emergency Procedures:
- Employees will be informed about emergency procedures and the location of emergency exits.
5.4 Social and Recreational Facilities:
- Kabir Ship Recycling Facilities will provide access to social and recreational facilities for the well-being and morale of our employees.
6. Compliance with Regulations:
- Kabir Ship Recycling Facilities will comply with all national and local regulations related to labor accommodation and dining facilities.
7. Grievance Procedure:
- Employees are encouraged to report any concerns or issues related to labor accommodation and dining facilities through our complaints and suggestions procedure.
8. Review and Revision:
- This policy will be reviewed periodically to ensure its effectiveness and relevance. Any necessary revisions will be made.
This policy will be communicated to all workers, employees and other relevant interested parties at induction and the policy will be made available on various location within the facility.
Policy for Security of the Facility
1. Introduction:
Kabir Ship Recycling Facilities is dedicated to ensuring the safety and security of our ship recycling yards. This policy outlines our commitment to maintaining a secure environment, complying with relevant regulations and protecting the well-being of our employees, workers and the surrounding community.
2. Access Control:
2.1. Entry Authorization:
- Only authorized personnel, employees, workers and contractors are allowed to enter the facility.
- Employees and workers will use the digital attendance system and others will follow the entry permit system in main gate.
2.2. Visitor Control:
- Visitors will be required to sign in and receive temporary identification before entering the premises.
- Visitors must be escorted by authorized personnel at all times.
3. Perimeter Security:
3.1. Fencing and Barriers:
- The facility will be enclosed with sturdy fencing, barriers and boundary to prevent unauthorized access.
3.2. Surveillance:
- Surveillance cameras and monitoring systems will be in place to monitor the perimeter.
4. Personnel Screening:
- All employees, contractors, and other individuals working or visiting within the facility will undergo checking system by security guards as necessary.
5. Security Measures:
5.1. Emergency Response:
- Protocols for responding to emergencies, including intrusions and security breaches, will be established.
5.2. Fire Safety:
- Adequate fire safety measures will be in place, including fire extinguishers, alarms, and evacuation procedures.
5.3. Security Personnel:
- Trained security personnel will be on duty to monitor the premises and respond to security incidents.
6. Continuous Improvement:
- We will continuously evaluate and improve our security measures to address evolving security challenges.
7. Reporting and Communication:
- All employees are encouraged to report any security concerns to the appropriate authority and communication channels for security issues will be clearly defined.
8. Review and Revision:
- This security policy will be reviewed periodically to ensure its effectiveness and relevance. Any necessary revisions will be made.
This policy will be communicated to all workers, employees and other relevant interested parties at induction and the policy will be made available on various location within the facility.
Policy for Information Security & Intellectual Property
1. Introduction:
Kabir Ship Recycling Facilities recognizes the importance of safeguarding its information and intellectual property assets. This policy outlines our commitment to preserving the confidentiality, integrity and availability of information while respecting intellectual property rights.
2. Information Security:
2.1. Data Classification:
- Information assets will be classified according to their sensitivity and criticality to determine appropriate security measures.
2.2. Access Control:
- Access to information will be restricted on a need-to-know basis and user access will be managed through appropriate authentication and authorization mechanisms.
2.3. Data Encryption:
- Sensitive data in transit and at rest will be encrypted to protect against unauthorized access.
2.4. Awareness and Training:
- All employees will receive information security training to understand and follow security protocols.
3. Data Protection:
3.1. Backup and Recovery:
- Regular data backups will be performed and disaster recovery plans will be established to ensure data availability.
3.2. Incident Response:
- Protocols for reporting and responding to information security incidents will be in place to mitigate potential breaches.
4. Intellectual Property:
4.1. Ownership and Protection:
- Kabir Ship Recycling Facilities asserts ownership and protection of all intellectual property created by its employees and contractors during the course of their work.
4.2. Non-Disclosure Agreements:
- Confidentiality and non-disclosure agreements will be executed when sharing intellectual property with third parties.
4.3. Respect for Third-Party Rights:
- Kabir Ship Recycling Facilities will respect the intellectual property rights of third parties and will not infringe upon them.
5. Compliance with Regulations:
- Kabir Ship Recycling Facilities will adhere to all national and international regulations related to information security and intellectual property.
6. Continuous Improvement:
- We will continuously evaluate and enhance our information security measures to address evolving threats and safeguard intellectual property.
7. Reporting and Communication:
- All employees are encouraged to report any breaches of information security or violations of intellectual property rights. Clear communication channels for reporting will be defined.
8. Review and Revision:
- This Information Security & Intellectual Property Policy will be reviewed periodically to ensure its effectiveness and relevance. Any necessary revisions will be made.
This policy will be communicated to all workers, employees and other relevant interested parties at induction and the policy will be made available on various location within the facility.
Policy for Freedom of Association and Collective Bargaining
1. Introduction:
Kabir Ship Recycling Facilities is committed to upholding the principles of freedom of association and the right to engage in collective bargaining. We recognize the importance of respecting these fundamental labor rights as essential elements of a just and equitable workplace. This policy outlines our commitment to promoting and protecting these rights within our organization.
2. Freedom of Association:
2.1. Right to Form Associations:
- All employees have the right to freely form, join or participate in associations of their choice, including labor unions, without fear of discrimination, retaliation or interference.
2.2. Non-Interference:
- Kabir Ship Recycling Facilities will not interfere with the lawful activities of these associations or seek to control or influence them.
2.3. Access and Communication:
- Associations will have access to employees and workplaces to engage in their legitimate activities and communication channels will be provided.
3. Collective Bargaining:
3.1. Recognition:
- Kabir Ship Recycling Facilities recognizes the right of employees to engage in collective bargaining and will engage in good faith negotiations with duly chosen representatives.
3.2. Negotiation:
- Negotiations will cover terms and conditions of employment, including wages, hours and working conditions, in a respectful and constructive manner.
3.3. Dispute Resolution:
- Kabir Ship Recycling Facilities is committed to resolving disputes arising from collective bargaining through peaceful means and in accordance with the law.
4. Compliance with Regulations:
- Kabir Ship Recycling Facilities will adhere to all national and international regulations related to freedom of association and collective bargaining.
5. Non-Retaliation:
- Kabir Ship Recycling Facilities prohibits retaliation or discrimination against employees who exercise their rights to freedom of association and collective bargaining.
6. Communication:
- This policy will be communicated to all employees and relevant parties during onboarding and made available in relevant languages.
7. Review and Revision:
- This Freedom of Association and Collective Bargaining Policy will be reviewed periodically to ensure its effectiveness and relevance. Any necessary revisions will be made.
This policy will be communicated to all workers, employees and other relevant interested parties at induction and the policy will be made available on various location within the facility.