Governance

Corporate Commitment

Meridian believes that integrity is the corner stone of any professional relationship and that honest and open communication fosters success. We are committed to conducting our business with a broad perspective, taking in to account our customers, our employees, and the communities in which we operate. As we continue to grow as a company, we remain committed to maintaining the highest of ethical standards and becoming an ideal corporate citizen.We do so by implementing our core values:• Courage in doing what is right;• Delivering customer satisfaction;• Demonstrating leadership in our industry as a company and as individuals;• Acting with integrity in all we do.

Code of Ethical Conduct

It is the policy of Meridian to conduct its business at all times throughout the world with honesty and integrity. It is part of our mission statement that we have pledged that, “we will continue to be an ethical and responsible company.” Meridian recognizes it has a responsibility for all the actions of its employees in connection with the activities of the organization. In view of this, Meridian believes that the ethics demonstrated by our employees and indeed any persons providing services on our behalf should give all customers, shareholders, suppliers, colleagues, business partners and regulators confidence that the company operates in a way that avoids any suggestion of improper or personal motives or actions.

Therefore, all employees and any persons providing services on our behalf are expected to conduct themselves in accordance with this Code at all times. Meridian believes in the companies approach to ethical commercial business practices alongside our other polices concerning ethical conduct. In a wider delivery of our services by all employees and other 3rd parties on its behalf, we require our high standards to be maintained at all times. Meridian believes that all its stakeholders wish to be associated with an ethical organization which publicizes and upholds high standards in all that it does, in particular:

  • We will comply with the law in each country in which we conduct business including laws relating to unfair competition/anti-trust.
  • We will not offer to pay, solicit or accept bribes in any form whether directly or indirectly. This includes payment or receipt of “facilitation payments” which are small payments or gifts made as common practice in some countries to obtain approvals, permits, etc more speedily – they are still bribes. Meridian promotes measures to eliminate these types of payment. All personnel (including 3rd party providers delivering services for us or on our behalf) should ensure they comply with all local laws and regulations. If you are requested to make a payment which you believe may be a facilitation payment you should consult your team leader or Designated Operations Manager (as appropriate). All payments made by deployed personnel should be recorded and a receipt requested if possible.
  • We will only give or receive gifts and entertainment that are not material or customary. Local management in each country will establish guidelines reflecting local custom as to the maximum permitted value and the circumstances in which such gifts and entertainment are acceptable.
  • We will record in our published accounts all material assets and liabilities and not maintain secret accounts.
  • We will not make political donations anywhere in the world.
  • We will not engage in commercial espionage or covert surveillance of our competitors.
  • We will not seek or continue to work where there is a potential or actual conflict of interest unless this is fully disclosed to the effected party(s) and their written consent first obtained.

Agents and contracted third parties in countries where Meridian is not directly represented are expected to comply with this Code in all matters in which they are acting on Meridian’s behalf. Local management and all deployed personnel are expected to monitor compliance and to report any significant breach to the Operations Manager. In case of uncertainty in interpretation, employees and our contractors including deployed personnel should seek clarification from their line managers and operations managers respectively.

Meridian expects its employees to conduct themselves in a businesslike manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on ship or in any environment while representing Meridian. Meridian expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of the company. Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage. Regardless of the circumstances, if employees sense that a course of action they have pursued, are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to the Operations Manager.

Accurate and reliable records of many kinds are necessary to meet the Meridian’s legal and financial obligations and to manage the affairs of the company. Meridian’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and record-keeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements. In all matters relevant to customers, suppliers, government authorities, the public and others in the organization, all employees must make every effort to achieve complete, accurate, and timely communications – responding promptly and courteously to all proper requests for information and to all complaints.

Employees uncertain about the application or interpretation of this document or any legal requirements should refer the matter to their supervisor.

Human Rights Policy

Purpose

Respect for human rights is fundamental to the sustainability of Meridian Global and the communities in which we operate. In our Company and across our system, we are committed to ensuring that people are treated with dignity and respect.

Meridian Global’s Human Rights Policy is guided by international human rights principles encompassed in the Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights.

Scope

This Human Rights Policy applies to Meridian Global, its employees, subcontractors, entities that it owns, the entities in which it holds a majority interest, and the facilities that it manages.
Meridian is committed to working with and encouraging our clients to uphold the principles in this Policy and to adopt similar policies within their businesses if such a policy is not present.

Statement

Respect for Human Rights

The Meridian respects human rights. It is committed to identify, prevent, and mitigate adverse human rights impacts resulting from or caused by our business activities before or if they occur through human rights due diligence and mitigation processes.

Community and Stakeholder Engagement

Meridian recognizes its impact on the communities in which it operates. We are committed to engaging with stakeholders in those communities to ensure that we are listening to, learning from and considering their views as we conduct our business. Where appropriate, we are committed to engaging in dialogue with stakeholders on human rights issues related to our business. We believe that local issues are most appropriately addressed at the local level. We are also committed to creating economic opportunity and fostering goodwill in the communities in which we operate through locally relevant initiatives.

Valuing Diversity

Meridian Global values the diversity of the people with whom we work and the contributions they make. We have a long-standing commitment to equal opportunity and intolerance of discrimination and harassment. We are dedicated to maintaining workplaces that are free from discrimination or harassment on the basis of race, sex, color, national or social origin, religion, age, disability, sexual orientation, political opinion or any other status protected by applicable law. The basis for recruitment, hiring, placement, training, compensation and advancement at Meridian is based off qualifications, performance, skills and experience.

Regardless of personal characteristics or status, Meridian does not tolerate disrespectful or inappropriate behavior, unfair treatment or retaliation of any kind. Harassment is unacceptable in the workplace and in any work-related circumstance outside the workplace. These principles apply not only to Meridian employees but also to the business partners with whom we work.

Safe and Healthy Workplace

Meridian provides a safe and healthy workplace and complies with applicable safety and health laws, regulations and internal requirements. We are dedicated to maintaining a productive workplace by minimizing the risk of accidents, injury and exposure to health risks. We are committed to engaging with our employees to continually improve health and safety in our workplaces, including the identification of hazards and remediation of health and safety issues.

Workplace Security

Meridian is 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 will be maintained with respect for employee privacy and dignity. This includes whistleblowers, as Meridian has a policy to ensure the protection of any employee or subcontractor that is designated a whistleblower.

Forced Labor and Human Trafficking

Meridian Global prohibits the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, slave labor and any form of human trafficking.

Child Labor

Meridian prohibits the hiring of individuals that are under 18 years of age for positions in which hazardous work is required.

Work Hours, Wages and Benefits

Meridian compensates employees competitively relative to the industry and local
labor market. We operate in full compliance with applicable wage, work hours, overtime and benefit laws.

Guidance and Reporting for Employees

Meridian creates workplaces in which open and honest communications among all employees are valued and respected. We are committed to following all applicable labor and employment laws wherever we operate.

If an employee or subcontractor believe there is a conflict between the language of the policy and the laws, customs and practices of the place where services are performed, or there are questions about this policy, or if someone would like to report a potential violation of this policy, they should raise those questions and concerns through existing processes utilizing the proper chain of command which make every effort to maintain confidentiality. Employees and subcontractors may ask questions or report potential violations to local Management, Human Resources, Legal Department or Strategic Security. Employees and subcontractors can also report suspected violations see the Ethics/Whistleblower section below. No reprisal or retaliatory action will be taken against any employee or subcontractor for raising concerns under this policy. Meridian is committed to investigating, addressing and responding to the concerns of employees and to taking appropriate corrective action in response to any violation.

Whistle Blower Policy

Anyone who, in good faith, reports a suspected or actual violation of law, regulation, company policy or procedure, or ethical or professional standards, will be protected from retaliation as a result of such reporting regardless of whether or not, after investigation, a violation is found to have occurred.

No member of Meridian Global Consulting shall discharge, demote, suspend, threaten, harass or discriminate against the whistleblower for reporting what the whistleblower sincerely believes to be a serious actual or suspected violation or unethical act.

This whistleblower protection extends to individuals who provide information in relation to an investigation of a report by a whistleblower.

Any act of retaliation shall be treated by Meridian Global Consulting as a serious violation of policy, which will result in disciplinary action.

If a whistleblower believes he/she is being retaliated against after reporting a violation, he/she should contact the President of Meridian Global Consulting at (251) 345-6776.

If the president of Meridian does not adequately resolve the issue, then the member is encouraged to call and report the issue to United States Department of Labor (www.whistleblowers.gov, 1-800-321-6742)

Employee / Third Party Grievance Procedure

Procedures

Employees / third parties must be treated fairly and receive prompt responses to problems and concerns. For this reason, Meridian Global Consulting provides a grievance procedure to promote quick and responsible resolution of issues raised by staff. This procedure may be used freely without fear of retaliation, and the Manager of Human Resources (HR) will be available to assist throughout the process. The process outlined below should be used if an individual disagrees with a supervisor's action, including any disciplinary action.

Step One:

Discuss Complaint with Immediate Supervisor.

Meridian Global Consulting encourages informal resolution of complaints. Employees / third parties should first discuss the complaint with their immediate supervisor within three (3) business days of the situation whenever possible. If the complaint is not resolved as a result of this discussion, or such a discussion is not appropriate under the circumstances, proceed to Step Two. If the action in dispute involves suspension or termination of employment, Steps One and Two should be bypassed.

Note: If the immediate supervisor is an officer of the company, Step Two should be bypassed and the complaint submitted directly to the President, who will then schedule a meeting for the employee / third party.

Step Two:

Prepare and Submit a Complaint Procedure Form to HR for Review by the company Operations Manager.

Suppose the employee / third party feels the complaint was not resolved in discussions with their immediate supervisor. In that case, they may prepare and submit a formal written complaint which will be reviewed by the person to whom the employee's / third party's immediate supervisor reports ("second-level supervisor"). To do so, the employee / third party should prepare a Complaint Procedure Form and submit it to HR within seven (7) business days of the Step One discussion with the immediate supervisor (or within seven (7) days of the event being grieved if Step One is bypassed). HR will then review the complaint, send a copy to the second-level supervisor and the immediate supervisor (if appropriate), and schedule a meeting for the employee / third party, the second-level supervisor, to discuss the complaint. The meeting will ordinarily be held within five (5) business days of the HR's receipt of the Complaint Procedure Form. The second-level supervisor will issue a written decision, generally within five (5) business days of the meeting. If the complaint is not resolved to the employee's / third party's satisfaction, they may proceed to Step Three.

Step Three:

Submit Complaint Procedure Form to HR for Review by the company President.

Suppose the employee / third party is not satisfied with the Step Two decision. In that case, they may proceed with the complaint within five (5) business days of receipt of the Step Two decision by submitting it to HR for review by the company President. A meeting between the employee / third party, the Operations Manager, and the President will generally be held within five (5) business days. The company President will issue a written decision, generally within five (5) business days of the meeting.

General Information

The time limits above are subject to modification on a case-by-case basis due to operational requirements, travel away from the home office, in-depth investigations, etc. The company President shall have the final authority to resolve any disputes regarding implementing this Complaint Procedure, including the determination of the appropriate decision-makers.

Client Complaint Procedure

Meridian.us welcomes the information and feedback from clients, which will enable Meridian to improve the quality of service provided. Meridian recognizes the value in complaints and will accept the complaint openly. The complaint is seen as an opportunity to review and evaluate the service we deliver.

Steps:

  • Complaints will be made in person, over the phone, by email or in writing determined by the client (anonymous complaints will not be accepted).
  • The staff member who receives the complaint will immediately notify the Department Manager.
  • The complaint will be logged, as well as the action taken.
  • All complaints will be treated seriously but will be dealt with at the lowest operational level, ensuring to resolve the issue promptly.
  • The staff member will advise the client of the complaint process, providing a written copy of the procedure and a flow chart.
  • The client will then submit a written notification addressed to the Department Manager or Client Manager.
  • We will attempt to resolve the issue within 14 days.
  • If the issue is not resolved to the client’s satisfaction, the client can raise the issue with the Client Manager.
  • The Client Manager will further investigate and prepare a response to the complaint and a report for the President of Meridian within 28 days of receipt.