Compliance


Oversight

Centerra’s Board of Directors and Senior Leadership are committed to a corporate compliance program that involves continuous monitoring for adherence to all laws and regulations.

Centerra assesses internal risk and maintains an Internal Audit program, independent of management, and reports to the Chairman of the Audit Committee of the Board of Directors. The Internal Audit Manager reports quarterly to the Audit Committee during scheduled Board of Directors’ meetings.

All newly hired employees are provided Centerra’s Standards of Business Conduct and certify to uphold these standards. Manager level employees and above provide annual certifications to uphold the standards.

Federal

With more than 80% of Centerra’s business performed with United States Government agencies, Centerra is committed to providing the best value to the Government and taxpayers. Centerra operates within the guidelines of the Federal Acquisition Regulations and applicable agency supplements.

State

Centerra maintains business licenses, performance bonds and taxing authority compliance as required by each State and Local jurisdiction where Centerra performs work.

International

Centerra complies with all United States laws pertaining to international work and operates in accordance with International law and licensing regulations in foreign countries where work is performed.

Centerra Grievance Process
The Centerra grievance process is an internal resolution system in which Centerra’s personnel (which includes employees and contractors of Centerra) and third parties can address claims alleging failure by the Company, or its personnel, to comply with, and respect: (a) the principles of the International Code of Conduct for Private Security Companies; (b) all applicable laws and regulations; and (c) the Company’s Code of Conduct. This includes raising concerns regarding fraud, waste or abuse, harassment or violations of the Company ethics policy, and other concerns, without fear of retaliation or discrimination for reports made in good faith. The process requires that no individual shall be subjected to discrimination or adverse treatment for participating in a grievance procedure.

Pursuant to the grievance process, Centerra requires cooperation with investigations of alleged wrong doings, and requires its personnel not to participate in or tolerate the impeding of witnesses, testimony or investigations.

A dedicated phone line programmed to go directly to voicemail (800) 275-8307, and e-mail address (openline@centerragroup.com) will be monitored by an appointed administrative staff person. All telephone messages (after transcription), e-mail messages, and letters regarding possible violations will be numbered and entered into the Open Line Log, and the corresponding Open Line form will then be forwarded to the appropriate member(s) of management for a thorough review and investigation. If the caller would like a response, he or she may leave his or her name and contact information. Otherwise, the caller may leave an anonymous message. After the investigation is complete, the results are recorded and reported back to senior management. When each case is fully resolved, the Open Line Log will reflect the case as closed.

The grievance policy requires that the resolution of a complaint to be unbiased, fair and just. Centerra’s personnel are required to cooperate with official investigations, and ensure witnesses are free and able to provide their testimony without fear of retaliation.

Immediate Corrective Actions
Corrective action and immediate performance adjustment/improvement are essential. Errors are corrected as early as possible and, in many cases, in real-time via on-the-spot corrections. If a guard is sleeping on duty, he/she is awakened, counseled on their violation and an incident report is written. A relief person takes his/her place for the remainder of the shift and there is a loss of wages for that period. The inspectors exercise good judgment, prudence, and discretion in these situations. They intend, for example, to preserve the confidence and credibility of the inspected employee and the post while at the same time remediating/correcting the behavior.

Graduated Warnings and Removal for Systemic Deficiencies and Gross Misconduct
The Centerra corrective actions and deficiency reporting scale to the deficiency and the incident. This means that levels of corrective actions are employed in accordance with the severity of the deficiency or offense and reporting procedures are based on the corrective actions and the deficiency.