Appendices

www.fcx.com

  Freeport-McMoRan Copper & Gold
APPENDIX TABLE OF CONTENTS
Appendix A
Environmental Policy		 Appendix B
Social, Employment & Human Rights Policy		 Appendix C
Human Rights Policy & Implementation		 Appendix D
Voluntary Principles on Security & Human Rights
Appendix A: Environmental Policy

General

Freeport-McMoRan Copper & Gold Inc. (FCX) believes that, as a responsible corporate citizen, it is the duty of the company and its operating affiliates to minimize the impact of their operations on the environment and, where feasible, to protect and enhance the quality of the environment in areas where they operate. FCX is also committed to providing a safe working environment for its employees and a healthy social/economic environment for the local people in its operational areas.

FCX is committed not only to compliance with federal, state, and local environmental statutes and regulations, but also to continuous improvement of its environmental performance at every operational site. Environmental audits will continue to be conducted to assess environmental compliance, management systems and practices. Goals and benchmarks will be established in each operating unit as a yardstick to measure environmental performance. FCX will also work with governmental agencies, the local population and responsible non-governmental organizations to enhance its environmental performance.

Environmental Principles

To achieve these Policy objectives, FCX and its operating affiliates will:
 
  • Comply in all material respects with all applicable environmental laws and regulations and, in jurisdictions where these are absent or inadequate, apply cost-effective management practices to advance environmental protection and to minimize environmental risks.
  • Make environmental management a high corporate priority and the integration of environmental policies,  programs, and practices an essential element of management.
  • Provide adequate resources, staff, and requisite training so that employees at all levels are able to fulfill their environmental responsibilities; and communicate with all employees, contractors and vendors on the importance of environmental protection.
  • Review and take account of the environmental effects of each activity, whether exploration, mining or processing; and plan and conduct the design, development, operation, and closure of any facility, including pollution control systems, in a manner that optimizes the economic use of resources while reducing adverse environmental effects.
  • Promote responsible stewardship and recycling efforts of its products.
  • Conduct regular environmental reviews, assessments and audits and act on the results.
  • Acknowledge that certain areas may have particular ecological or cultural values as well as development  potential and, in such instances, consider these values along with the economic, social, and other benefits resulting from development.
  • Support research to expand scientific knowledge and develop improved technologies to protect the environment, promote the international transfer of technologies that mitigate adverse environmental effects, and use technologies and practices which take due account and respect of local cultures, customs and values as well as the economic and environmental needs.
  • Recognize local communities as stakeholders and engage with them in a process of consultation and communication regarding environmental management issues and impacts.
  • Accept the responsibility of supporting resource conservation and sustainable development in all operational areas.
Environmental Auditing

Environmental auditing is a key component of this Environmental Policy. This process is a systematic, objective evaluation of facility operations and practices which is designed to:

1. Verify compliance with environmental regulations, internal policies, and accepted practices.

2. Evaluate the effectiveness of environmental management systems in place.

3. Identify and assess any reasonably foreseeable risks associated with hazardous conditions attributable to  environmental and related factors and provide an avenue for effective prevention and resolution.

As prescribed in the FCX Environmental Auditing Protocol, major operational facilities are to continue to be internally audited on an annual basis. Smaller facilities, with senior management concurrence, can be audited on a biannual basis. Periodic, external audits may also be deemed appropriate for certain facilities by FCX Senior Management. The formal auditing protocol covers all aspects of environmental management, programs, controls and treatment facilities.

 Oversight and Communication

The FCX Board of Directors Public Policy Committee and the Board will periodically review and update this Environmental Policy. Based on the results obtained from the periodic evaluations and audits, FCX Senior Management will review and revise, as needed, environmental objectives, environmental programs and the environmental management system of each operating unit.

FCX will work to foster throughout the Company and its operating affiliates a sense of responsibility regarding the  environment. FCX also recognizes its responsibility to communicate to the public on its environmental status and progress through annual reports, publication of external audit results, notifications of all environmental certifications, and other public statements and announcements.
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Appendix B: Social, Employment & Human Rights Policy
General

Freeport-McMoRan Copper & Gold Inc. (FCX) believes that, as a responsible corporate citizen, it is the duty of the company and its operating affiliates to foster positive social and employment relationships in every area where they  operate, and FCX is committed to continuous improvement of those relationships. FCX is dedicated to ensuring that its operations are conducted in a manner that respects the Universal Declaration of Human Rights and other applicable international standards of human rights, the laws and regulations of the host country, and the culture of the people who are indigenous to the areas in which the company operates. FCX will work to be a partner in the social and economic development of the people in and around areas of operations.
 
Social Relationships and Development

To achieve these Policy objectives, FCX and its operating affiliates will:
  • Build relationships with people in the host country and especially with people indigenous to areas of operations or exploration;
  • Work continuously to understand the culture and social patterns of the people in the host country and especially the people indigenous to areas of operations or exploration. To accomplish this, the company and its affiliates will undertake social, cultural and medical studies;
  • Consult with local populations about important operational issues that will impact their communities;
  • Work with the host country government, the local people and responsible non-governmental organizations to create and periodically update social integration and/or sustainable development plans for all operational sites. These plans shall address the issue of economic and social viability of each operating area after cessation of operations;
  • Provide for periodic outside, independent audits of the social and human rights performance of the company.
Employment

FCX and its operating affiliates will:
  • Obey the laws and regulations of the host country with respect to employment practices;
  • Adhere to applicable international standards of health and safety;
  • Employ as many citizens of the host country as practicable and will, wherever practicable, employ people who are
    indigenous to the operational or exploration site;
  • Provide training to citizens of the host country and especially to those indigenous to an operational or exploration area to prepare them for employment in the operation;
  • Promote employees on the basis of their willingness and ability to perform the job without discriminating on the basis of race, creed, gender or national origin. However, special efforts will be made to train and hire people indigenous to each operational or exploration area.
Human Rights

FCX, its affiliates and employees are dedicated to the promotion of the rule of law and protection of human rights at all operational sites. The company and its affiliates will adhere to the principles of the Universal Declaration of Human Rights and other applicable international standards of human rights and all laws of the host country wherever the company operates. The company and its affiliates will:
  • Educate employees about human rights;
  • Notify all employees that the company requires them to treat employees and non-employees in and around areas of company operation with dignity and respect;
  • Take appropriate action against any employee who violates the human rights of others;
  • Report any credible accusation of a human rights violations to the appropriate government authorities and
    other agencies;
  • Provide the company’s full cooperation with any responsible human rights investigation and to support appropriate punishment for any proven violations;
  • Protect all employees who report suspected human rights violations;
  • Work proactively to create a constructive climate for promotion of human rights in all areas where it operates  by implementing programs and policies aimed at building positive relationships, and by setting a good example;
  • Do all in its power to make certain its property and/or equipment is not used by any party in the violation of
    human rights.
Human Rights Reporting

Each operational site will have a Human Rights Compliance Officer and there will be a corporate Human Rights Compliance Officer. The Human Rights Compliance Officers will be responsible to receive all reports of possible human rights violations, to evaluate those reports and to forward them to appropriate government authorities and, where applicable, to non-governmental organizations. Each year staff employees, all security employees and all  community development employees will be required to fill out and submit to the corporate Human Rights Compliance Officer a Human Rights Assurance Letter stating that they understand the company’s Social and Human Rights Policy and that they have neither taken part in any activities that would violate human rights nor have they witnessed any such activities. The corporate Human Rights Compliance Officer will make a report to the Public Policy Committee of the FCX Board of Directors each year about human rights and compliance with the company’s Social, Employment and Human Rights Policy.
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Appendix C: Human Rights Policy & Implementation
I. Policy

The Board of Directors of Freeport-McMoRan Copper & Gold Inc. (FCX) adopted a Social and Human Rights Policy at its meeting on February 2, 1999. As part of that policy, the management of FCX and its affiliates are required to  support the human rights of all those who live and work around the sites of FCX or any FCX affiliate operations and to inform and educate all employees about human rights. Also, FCX and its affiliates are committed to establish a mechanism by which employees and others can report suspected human rights violations to Company management. The full text of the human rights portion of the FCX Social and Human Rights Policy follows.

General

Freeport-McMoRan Copper & Gold Inc. (FCX) believes that, as a responsible corporate citizen, it is the duty of the Company and its operating affiliates to foster positive social relationships in every area in which they operate, and FCX is committed to continuous improvement of those relationships. FCX is dedicated to ensuring that its operations are conducted in a manner that respects the Universal Declaration of Human Rights and other applicable  international standards of human rights, the laws and regulations of the host country, and the culture of the people who are indigenous to the areas in which the Company operates. FCX will work to be a patient partner in the social and economic development of the people in and around all areas of operations.

Human Rights

FCX, its affiliates and its employees are dedicated to the promotion and protection of human rights. The company and its affiliates will adhere to the principles of the Universal Declaration of Human Rights and other applicable standards of human rights and all laws of the host country wherever the company operates. The company and its affiliates will:
  • educate employees about human rights;
  • notify all employees that the company requires them to treat employees and non-employees in and around areas of company operation with dignity and respect;
  • take appropriate action against any employee who violates the human rights of others;
  • report any credible accusation of a human rights violations to the appropriate government authorities and other agencies;
  • provide the company’s full cooperation with any responsible human rights investigation, and to support
    appropriate punishment for any proven violations;
  • protect all employees who report suspected human rights violations;
  • work proactively to create a constructive climate for promotion of human rights in all areas where it operates
    by implementing programs and policies aimed at building positive relationships and by setting a good example; and
  • do all in its power to make certain its property and/or equipment is not used by any party in violation of human rights.
II. Policy Implementation
Human Rights Compliance Officer

The FCX Human Rights Compliance Officer will be located at the FCX corporate headquarters in New Orleans, Louisiana. The Compliance Officer will be assisted by on-site officers at all operational locations. The Compliance Officer and his/her assistants will receive by telephone, electronic mail, or fax all reports about possible human rights violations. The Compliance Officer and the on-site assistants will investigate all reports of possible violations, and the Compliance Officer will report to the Public Policy Committee of the Board of Directors at least annually on compliance with the Social and Human Rights Policy. Alison Hartman is the company-wide corporate Human Rights Compliance Officer.
.
Human Rights Declaration for Employees

Once each year all staff employees, all employees of the Security Department and all community development employees will be asked to sign the following declaration about human rights as part of the annual Assurance
Letter process:

“I hereby declare that I have neither participated in nor witnessed any action which deprived the human rights of any person in or around any operations area of FCX or any FCX affiliate. I further agree during the coming year to report to the Company’s Human Rights Compliance Officer any action I see taken either by employees or others in or around the operations area of FCX or any FCX affiliate that could be construed as a violation of human rights.”
Human Rights-Definitions and Procedures

The Universal Declaration of Human Rights provides the standard definition of human rights. Although the Universal Declaration is intended to set a standard of human rights for governments, it also can give general guidance to companies and others that wish to establish a standard for decision making which respects both employees and the communities in which they work. Of the thirty articles in the Universal Declaration, several are of special importance for PT Freeport Indonesia’s Social and Human Rights Policy:

Article 3: Everyone has the right to life, liberty, and security of person.

Article 5: No one shall be subjected to torture or to cruel, inhuman, or degrading treatment or punishment.

Article 9: No one shall be subjected to arbitrary arrest, detention, or exile.

Article 12: No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor attacks upon his honor and reputation. Everyone has the right to the protection of the law against such interference or attacks.

Employees are expected to respect these human rights principles, and if an employee sees any of these principles being disregarded it is the employee’s obligation to report such disregard to the Human Rights Compliance Officer.
 
Employee and Contractor Guidance

There are several scenarios involving potential human rights problems of which employees should be aware. The most difficult involves property that may be construed as belonging to Freeport. This includes buildings, containers, aircraft, trucks, busses, light vehicles and other company equipment. Under certain conditions, Indonesian law permits the police and military to request the use of and/or commandeer such equipment in cases where they believe an emergency situation exists. Even when those conditions do not exist, there have been times when government officials have requested the use of company and contractor equipment and in some cases, equipment has been commandeered. If a request comes from Indonesian authorities to use Freeport equipment and there is time for management consideration of the request, you should ask the requesting party to contact the General Manager. If equipment in your control is commandeered and there is no opportunity to refer the matter to company management, you should surrender the vehicle to the officer, but you should not operate the equipment and you should immediately notify senior management that the equipment has been commandeered. You should fully identify the  equipment commandeered, where and when the equipment was taken, by whom (if known) and for what purpose
(if known).

If you see a Freeport employee, contractor or anyone else behaving in such a way that you suspect that he is violating someone’s human rights, you should note the person’s name (if known) and department (if a Freeport employee or  contractor), the time and place in which the incident took place, the nature of the possible violation and any other information that would be helpful to the company and the authorities in investigating the incident. This should be reported immediately to the Human Rights Compliance Officer at the employee’s work location. Generally, you should not try to intervene in the incident.
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Appendix D: Voluntary Principles on Security & Human Rights
The Governments of the United States and the United Kingdom, companies in the extractive and energy sectors ("Companies"), and non-governmental organizations, all with an interest in human rights and corporate social responsibility, have engaged in a dialogue on security and human rights.

The participants recognize the importance of the promotion and protection of human rights throughout the world and the constructive role business and civil society (including non-governmental organizations, labor/trade unions and local communities) can play in advancing these goals. Through this dialogue, the participants have developed the following set of voluntary principles to guide Companies in maintaining the safety and security of their operations within an operating framework that ensures respect for human rights and fundamental freedoms. Mindful of these goals, the participants agree to the importance of continuing this dialogue and keeping under review these principles to ensure their continuing relevance and efficacy.

Acknowledging that security is a fundamental need, shared by individuals, communities, businesses and governments alike, and acknowledging the difficult security issues faced by Companies operating globally, we recognize that security and respect for human rights can and should be consistent;

Understanding that governments have the primary responsibility to promote and protect human rights and that all parties to a conflict are obliged to observe applicable international humanitarian law, we recognize that we share the common goal of promoting respect for human rights, particularly those set forth in the Universal Declaration of Human Rights, and international humanitarian law;

Emphasizing the importance of safeguarding the integrity of company personnel and property, Companies recognize a commitment to act in a manner consistent with the laws of the countries within which they are present, to be mindful of the highest applicable international standards, and to promote the observance of applicable international law enforcement principles (e.g., the U.N. Code of Conduct for Law Enforcement Officials and the U.N. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials), particularly with regard to the use of force;

Taking note of the effect that Companies’ activities may have on local communities, we recognize the value of engaging with civil society and host and home governments to contribute to the welfare of the local community while mitigating any potential for conflict where possible;

Understanding that useful, credible information is a vital component of security and human rights, we recognize the importance of sharing and understanding our respective experiences regarding, inter alia, best security practices and procedures, country human rights situations, and public and private security, subject to confidentiality constraints;

Acknowledging that home governments and multilateral institutions may, on occasion, assist host governments with security sector reform, developing institutional capacities and strengthening the rule of law, we recognize the important role Companies and civil society can play in supporting these efforts;

We hereby express our support for the following voluntary principles regarding security and human rights in the  extractive sector, which fall into three categories, risk assessment, relations with public security and relations with  private security:

RISK ASSESSMENT

The ability to assess accurately risks present in a Company’s operating environment is critical to the security of personnel, local communities and assets; the success of the Company’s short and long-term operations; and to the promotion and protection of human rights. In some circumstances, this is relatively simple; in others, it is important to obtain extensive background information from different sources; monitoring and adapting to changing, complex political, economic, law enforcement, military and social situations; and maintaining productive relations with local communities and government officials.

The quality of complicated risk assessments is largely dependent on the assembling of regularly updated, credible information from a broad range of perspectives - local and national governments, security firms, other companies, home governments, multilateral institutions and civil society knowledgeable about local conditions. This information may be most effective when shared to the fullest extent possible (bearing in mind confidentiality considerations) between Companies, concerned civil society, and governments.

Bearing in mind these general principles, we recognize that accurate, effective risk assessments should consider the
following factors:
  • Identification of security risks. Security risks can result from political, economic, civil or social factors. Moreover, certain personnel and assets may be at greater risk than others. Identification of security risks allows a Company to take measures to minimize risk and to assess whether Company actions may heighten risk.
  • Potential for violence. Depending on the environment, violence can be widespread or limited to particular regions, and it can develop with little or no warning. Civil society, home and host government representatives and other sources should be consulted to identify risks presented by the potential for violence. Risk assessments should examine patterns of violence in areas of Company operations for educational, predictive and preventative purposes.
  • Human rights records. Risk assessments should consider the available human rights records of public security forces, paramilitaries, local and national law enforcement, as well as the reputation of private security. Awareness of past abuses and allegations can help Companies to avoid recurrences as well as to promote accountability. Also, identification of the capability of the above entities to respond to situations of violence in a lawful manner (i.e., consistent with applicable international standards) allows Companies to develop appropriate measures in operating environments.
  • Rule of law. Risk assessments should consider the local prosecuting authority and judiciary’s capacity to hold accountable those responsible for human rights abuses and for those responsible for violations of international humanitarian law in a manner that respects the rights of the accused.
  • Conflict analysis. Identification of and understanding the root causes and nature of local conflicts, as well as the level of adherence to human rights and international humanitarian law standards by key actors, can be instructive for the development of strategies for managing relations between the Company, local communities, Company employees and their unions, and host governments. Risk assessments should also consider the potential for future conflicts.
  • Equipment transfers. Where Companies provide equipment (including lethal and non-lethal equipment) to public or private security, they should consider the risk of such transfers, any relevant export licensing requirements, and the feasibility of measures to mitigate foreseeable negative consequences, including adequate controls to prevent misappropriation or diversion of equipment which may lead to human rights abuses. In making risk assessments, companies should consider any relevant past incidents involving previous equipment transfers.
INTERACTIONS BETWEEN COMPANIES AND PUBLIC SECURITY

Although governments have the primary role of maintaining law and order, security and respect for human rights, Companies have an interest in ensuring that actions taken by governments, particularly the actions of public security providers, are consistent with the protection and promotion of human rights. In cases where there is a need to  supplement security provided by host governments, Companies may be required or expected to contribute to,  or otherwise reimburse, the costs of protecting Company facilities and personnel borne by public security. While
public security is expected to act in a manner consistent with local and national laws as well as with human rights standards and international humanitarian law, within this context abuses may nevertheless occur.

In an effort to reduce the risk of such abuses and to promote respect for human rights generally, we have identified the following voluntary principles to guide relationships between Companies and public security regarding security provided to Companies:
Security Arrangements
  • Companies should consult regularly with host governments and local communities about the impact of their security arrangements on those communities.
  • Companies should communicate their policies regarding ethical conduct and human rights to public security providers, and express their desire that security be provided in a manner consistent with those policies by personnel with adequate and effective training.
  • Companies should encourage host governments to permit making security arrangements transparent and
    accessible to the public, subject to any overriding safety and security concerns.
Deployment and Conduct
  • The primary role of public security should be to maintain the rule of law, including safeguarding human rights and deterring acts that threaten Company personnel and facilities. The type and number of public security forces deployed should be competent, appropriate and proportional to the threat.
  • Equipment imports and exports should comply with all applicable law and regulations. Companies that provide equipment to public security should take all appropriate and lawful measures to mitigate any foreseeable negative
    consequences, including human rights abuses and violations of international humanitarian law.
  • Companies should use their influence to promote the following principles with public security: (a) individuals credibly implicated in human rights abuses should not provide security services for Companies; (b) force should be used only when strictly necessary and to an extent proportional to the threat; and (c) the rights of individuals should not be violated while exercising the right to exercise freedom of association and peaceful assembly, the right to engage in collective bargaining, or other related rights of Company employees as recognized by the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.
  • In cases where physical force is used by public security, such incidents should be reported to the appropriate
    authorities and to the Company. Where force is used, medical aid should be provided to injured persons,
    including to offenders.
Consultation and Advice
  • Companies should hold structured meetings with public security on a regular basis to discuss security, human rights and related work-place safety issues. Companies should also consult regularly with other Companies, host and home governments, and civil society to discuss security and human rights. Where Companies operating in the same region have common concerns, they should consider collectively raising those concerns with the host and home governments.
     
  • In their consultations with host governments, Companies should take all appropriate measures to promote observance of applicable international law enforcement principles, particularly those reflected in the U.N. Code of Conduct for Law Enforcement Officials and the U.N. Basic Principles
    on the Use of Force and Firearms.
  • Companies should support efforts by governments, civil society and multilateral institutions to provide human rights training and education for public security as well as their efforts to strengthen state institutions to ensure accountability and respect for human rights.
Responses to Human Rights Abuses
  • Companies should record and report any credible allegations of human rights abuses by public security in their areas of operation to appropriate host government authorities. Where appropriate, Companies should urge investigation and that action be taken to prevent any recurrence.
  • Companies should actively monitor the status of investigations and press for their proper resolution.
  • Companies should, to the extent reasonable, monitor the use of equipment provided by the Company and to investigate properly situations in which such equipment is used in an inappropriate manner.
  • Every effort should be made to ensure that information used as the basis for allegations of human rights abuses is credible and based on reliable evidence. The security and safety of sources should be protected. Additional or more accurate information that may alter previous allegations should be made available as appropriate to concerned parties.
INTERACTIONS BETWEEN COMPANIES AND PRIVATE SECURITY

Where host governments are unable or unwilling to provide adequate security to protect a Company’s personnel or assets, it may be necessary to engage private security providers as a complement to public security. In this context, private security may have to coordinate with state forces, (law enforcement, in particular) to carry weapons and to consider the defensive local use of force. Given the risks associated with such activities, we recognize the following voluntary principles to guide private security conduct:
  • Private security should observe the policies of the contracting Company regarding ethical conduct and human rights; the law and professional standards of the country in which they operate; emerging best practices developed by industry, civil society, and governments; and promote the observance of international humanitarian law.
  • Private security should maintain high levels of technical and professional proficiency, particularly with regard to the local use of force and firearms.
  • Private security should act in a lawful manner. They should exercise restraint and caution in a manner consistent with applicable international guidelines regarding the local use of force, including the U.N. Principles on the Use of Force and Firearms by Law Enforcement Officials and the U.N. Code of Conduct for Law Enforcement Officials, as well as with emerging best practices developed by Companies, civil society, and governments.
  • Private security should have policies regarding appropriate conduct and the local use of force (e.g., rules of engagement). Practice under these policies should be capable of being monitored by Companies or, where appropriate, by independent third parties. Such monitoring should encompass detailed investigations into allegations of abusive or unlawful acts; the availability of disciplinary measures sufficient to prevent and deter; and procedures for reporting allegations to relevant local law enforcement authorities when appropriate.
  • All allegations of human rights abuses by private security should be recorded. Credible allegations should be properly investigated. In those cases where allegations against private security providers are forwarded to the relevant law enforcement authorities, Companies should actively monitor the status of investigations and press for their proper resolution.
  • Consistent with their function, private security should provide only preventative and defensive services and should not engage in activities exclusively the responsibility of state military or law enforcement authorities. Companies should designate services, technology and equipment capable of offensive and defensive purposes as being for defensive use only.
  • Private security should (a) not employ individuals credibly implicated in human rights abuses to provide security services; (b) use force only when strictly necessary and to an extent proportional to the threat; and (c) not violate the rights of individuals while exercising the right to exercise freedom of association and peaceful assembly, to engage in collective bargaining, or other related rights of Company employees as recognized by the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.
  • In cases where physical force is used, private security should properly investigate and report the incident to the Company. Private security should refer the matter to local authorities and/or take disciplinary action where appropriate. Where force is used, medical aid should be provided to injured persons, including to offenders.
  • Private security should maintain the confidentiality of information obtained as a result of its position as security provider, except where to do so would jeopardize the principles contained herein.
To minimize the risk that private security exceed their authority as providers of security, and to promote respect for human rights generally, we have developed the following additional voluntary principles and guidelines:
 
  • Where appropriate, Companies should include the principles outlined above as contractual provisions in agreements with private security providers and ensure that private security personnel are adequately trained to respect the rights of employees and the local community. To the extent practicable, agreements between Companies and private security should require investigation of unlawful or abusive behavior and appropriate disciplinary action. Agreements should also permit termination of the relationship by Companies where there is credible evidence of unlawful or abusive behavior by private security personnel.
  • Companies should consult and monitor private security providers to ensure they fulfil their obligation to provide security in a manner consistent with the principles outlined above. Where appropriate, Companies should seek to employ private security providers that are representative of the local population.
  • Companies should review the background of private security they intend to employ, particularly with regard to the use of excessive force. Such reviews should include an assessment of previous services provided to the host government and whether these services raise concern about the private security firm's dual role as a private security provider and government contractor.
  • Companies should consult with other Companies, home country officials, host country officials, and civil society regarding experiences with private security. Where appropriate and lawful, Companies should facilitate the exchange of information about unlawful activity and abuses committed by private security providers.
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