Human Right and Anti slavery Policy For Midland Cosmos ltd

We draft human right and anti slavery policy for Midland Cosmos ltd in Nigeria

This draft Human Rights and Anti-Slavery Policy is tailored for Midland Cosmos Ltd including its engineering and energy services and oil and gas division operating in Nigeria) to align with the 1999 Nigerian Constitution (Section 34), the Trafficking in Persons (Prohibition) Enforcement and Administration Act 2015, and international best practices for 2026.

Midland Cosmos Ltd: Human Rights & Anti-Slavery Policy (2026)

1. Policy Statement

Midland Cosmos Ltd is committed to ethical conduct and integrity, with a zero-tolerance stance on modern slavery and human rights abuses in its operations and supply chains. The company aims for transparency in tackling modern slavery.

2. Scope

This policy covers all individuals working for or on behalf of Midland Cosmos Ltd, including employees, directors, contractors, and business partners.

3. Human Rights Commitments

Midland Cosmos Ltd is committed to upholding human rights as outlined in the Nigerian Constitution. This includes treating individuals with dignity and respect, prohibiting discrimination and harassment, maintaining safe workplaces, and ensuring fair compensation, including the national minimum wage and statutory benefits.

4. Anti-Slavery & Human Trafficking

Midland Cosmos Ltd strictly forbids forced labor, child labor (below legal age or in hazardous roles for those under 18), and human trafficking within its operations and supply chains.

5. Due Diligence Processes

To mitigate risks, the company will conduct risk-based supplier audits, include anti-slavery clauses in contracts, and verify the right to work for employees and agency staff.

6. Training & Communication

New staff receive training on this policy during induction, and regular updates are provided to help employees identify and report exploitation.

7. Reporting & Whistleblowing

Employees are required to report concerns about modern slavery promptly. Midland Cosmos Ltd protects those who report concerns in good faith and provides channels for reporting, such as through a manager, HR, or a confidential "Speak Up" channel.

8. Breaches of Policy

Breaches of this policy by employees may lead to disciplinary action, including dismissal. The company may also terminate relationships with partners who violate the policy.

Approved by: Board of Directors, Midland Cosmos Ltd

Date: January 2026

To ensure the policy is operational and enforceable for Midland Cosmos Ltd throughout 2026, the following sections should be added to the draft to cover implementation, compliance, and specific Nigerian regulatory alignment.

9. Specific Compliance with Nigerian Law

Midland Cosmos Ltd shall operate in strict accordance with:

The Labour Act (Cap L1 LFN 2004): Ensuring all employment contracts are documented and wages are paid in legal tender.

NAPTIP Guidelines: Full cooperation with the National Agency for the Prohibition of Trafficking in Persons (NAPTIP) regarding any suspected cases of trafficking or forced labor.

Employee Compensation Act 2010: Maintaining active contributions to the Nigeria Social Insurance Trust Fund (NSITF) to protect worker rights in the event of workplace injury.

10. Supply Chain Management

Midland Cosmos Ltd expects its suppliers to adhere to the same high standards. As part of our 2026 procurement strategy, we will:

Require tier-one suppliers to sign a Supplier Code of Conduct.

Reserve the right to conduct unannounced site visits to verify working conditions.

Prioritize partnerships with vendors who demonstrate transparent recruitment practices and do not charge "recruitment fees" to workers.

11. Monitoring and Review

The Board of Directors will review this policy annually to ensure its effectiveness. Key Performance Indicators (KPIs) for 2026 include:

Training Coverage: 100% completion rate for mandatory anti-slavery modules by all staff.

Audit Frequency: Bi-annual audits of high-risk project sites (e.g., remote engineering or construction locations).

Incident Response: Resolution of all reported human rights grievances within 30 days.

12. Awareness and Training Resources

Employees are encouraged to stay informed about global standards via the International Labour Organization (ILO).

Acknowledgement

All employees are required to sign an acknowledgement form upon receipt of this policy.

Employee Name: __________________________

Signature: _______________________________

Date: __________________________________

Implementation Steps for Midland Cosmos Ltd:

Digital Distribution: Upload the policy to your internal portal or distribute via email.

Contractual Updates: Update your standard "Terms and Conditions of Purchase" to include a clause referencing this policy.

Local Context: If the company operates in high-risk zones, consider translating a summary of this policy into local languages (e.g., Hausa, Igbo, or Yoruba) for on-site laborers.

To further strengthen the Midland Cosmos Ltd Human Rights and Anti-Slavery Policy for 2026, the following advanced operational sections are included. These sections address the specific risks of the engineering and energy sectors, such as site security, field-based labor, and community relations.

In alignment with the Voluntary Principles on Security and Human Rights, Midland Cosmos Ltd recognizes that maintaining safety at engineering sites must not compromise human rights.

Private Security Providers: All third-party security firms contracted by the company must undergo vetting to ensure they have no history of human rights abuses.

Rules of Engagement: Security personnel are strictly prohibited from using excessive force and must respect the rights of local community members and protesters.

Reporting Misconduct: Any instance of security-related human rights violations must be reported immediately through the designated whistleblowing channel.

14. Operational Grievance Mechanism (OGM)

Accessibility: Grievances can be submitted via digital portals, physical drop-boxes at project sites, or through community liaison officers.

Remediation: If the company is found to have caused or contributed to a human rights harm, we are committed to providing or cooperating in a fair remedy, such as compensation, public apologies, or process changes.

Non-Retaliation: The company guarantees that no person will face repercussions for reporting a concern in good faith.

15. Site-Specific Human Rights Due Diligence (HRDD)

For high-impact engineering projects, Midland Cosmos Ltd will:

Pre-Site Assessments: Conduct impact assessments to identify potential risks to local residents (e.g., land rights or environmental health) before project commencement.

Labor Standards on Site: Ensure all sub-contracted laborers have access to clean water, sanitation, and protective equipment (PPE) as mandated by the Factories Act (Cap F1 LFN 2004).

Child Labor Prevention: Strictly prohibit the presence of minors on project sites, except for approved vocational training programs that comply with Nigerian educational laws.

16. External Accountability and Reporting

To maintain transparency throughout 2026, the company will:

NAPTIP Cooperation: Report any credible evidence of human trafficking or forced labor to the National Agency for the Prohibition of Trafficking in Persons (NAPTIP).

Annual Reporting: Publish an annual "Modern Slavery Statement" detailing the steps taken to assess and manage risks in our supply chain.

Stakeholder Engagement: Participate in industry-wide forums to share best practices and stay updated on the National Action Plan on Human Trafficking in Nigeria (2022–2026).

Actionable Steps for 2026:

Contractual Review: Use the NAPTIP Business Guidelines to audit all sub-contractor agreements by Q2 2026.

Training: Schedule specialized "Human Rights in the Field" workshops for all site managers and community relations teams.

Audit: Perform a "Deep Dive" audit on any recruitment agencies used for temporary site labor to ensure no recruitment fees were charged to workers.

13. Security and Human Rights

Midland Cosmos Ltd provides a formalised process for stakeholders—including employees, contractors, and host communities—to raise concerns regarding human rights.

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To conclude the Midland Cosmos Ltd Human Rights and Anti-Slavery Policy (2026), the following sections provide final operational safeguards, enforcement mechanisms, and a roadmap for continuous improvement throughout 2026.

17. Stakeholder Engagement & Community Rights

Midland Cosmos Ltd recognizes its impact on host communities in Nigeria. In 2026, we commit to:

Meaningful Consultation: Actively seeking input from community leaders and marginalized groups before commencing new engineering or energy projects to respect land rights and local livelihoods.

Inclusive Employment: Prioritizing local hiring and providing "green job" apprenticeship programs for under-represented groups, including women and people with disabilities, to support Nigeria's transition to renewable energy.

Environmental Stewardship: Mitigating operational impacts that could infringe on a community’s right to a clean and healthy environment.

18. Technology and Data Privacy

In the deployment of engineering technologies and AI-driven monitoring for 2026, Midland Cosmos Ltd will:

AI Ethical Standards: Ensure any AI tools used for recruitment or supply chain auditing are audited for bias to prevent discrimination against workers based on race, gender, or disability.

Worker Privacy: Respect the data privacy of all employees and contractors, ensuring that site surveillance and digital tracking are proportionate and transparent.

19. Remediation and Corrective Action

Should any violation of this policy be identified, Midland Cosmos Ltd is committed to:

Victim-Centered Support: Prioritizing the safety and welfare of any identified victims of modern slavery or exploitation, working with NAPTIP to ensure they receive appropriate legal and psychological support.

Supplier Correction: Working with suppliers to address root causes of non-compliance. Termination of contracts remains a final resort if the supplier refuses to implement corrective measures.

20. Annual Reporting & Transparency (2026 Framework)

To comply with the National Action Plan on Business and Human Rights (2024–2028), the company will:

Annual Statement: Publish a 2026 Modern Slavery Statement on the company website by September 30th, detailing risk assessments, due diligence steps, and the effectiveness of current actions.

Key Performance Indicators (KPIs): Report on metrics such as the percentage of suppliers screened and the number of employees who have completed the 2026 Anti-Slavery induction.

21. Policy Approval and Governance

This policy has been reviewed and approved by the Board of Directors of Midland Cosmos Ltd. It is subject to annual review to ensure alignment with evolving Nigerian laws and international standards.

Director Signature: __________________________

Name: ______________________________________

Title: _____________________________________

Date of Last Review: January 2026

Final Checklist for Implementation:

Registry Upload: Upload the finalized policy to the Nigerian National Human Rights Commission (NHRC) business portal if required by 2026 sector-specific regulations.

Field Handbooks: Distribute simplified "Know Your Rights" handbooks to all site-based workers in English and relevant local languages.

Supplier Induction: Integrate this policy into the 2026 Supplier Onboarding Package for all new engineering contractors.