Business Continuity Policy

Gartner Callaway has a holistic business continuity management policy that identifies potential impacts that threaten our organization and provides a framework for building resilience with the capability for an effective response that safeguards the interest of our stakeholders, reputation and value creating activities.

These impacts or ‘crisis’ include:

• Building or site incidents: for example, flood, fire, terrorist attack on buildings affecting access to or from buildings and sites.

• Infrastructure incidents: for example, loss of computer / telephony systems, loss of power.

• Staff / Operational incidents: for example, loss of key staff/stakeholder, loss of critical documents.

• Widespread environmental factors: for example, flu pandemic, fuel shortages.

Gartner Callaway business continuity plan consists of one plan to cover different operations, based at our headquarters and separates plans will be incorporated for operations based on other sites. The primary objective of the Business Continuity Plan is to show how Gartner Callaway would respond to identify risks and continue to manage its operations under adverse circumstances.


1. Chain of Command

Overall responsibility for business continuity in the organization is handled by a director and in his/her absence another director handles that responsibility.

2. Crisis Management Group

If a major disaster occurs Gartner Callaway Crisis Management Group will be mobilized. The membership of this group will be all senior managers of the company and all communication with the media must be via the Head of Public Relations with direct consent from stakeholders.


3. Documentation and location


Business Continuity Plan                                      

Appendix A: Crisis Management Group            –        Staff Notice Board

Appendix B: Key Stakeholders Contacts           –        Reception

Appendix C: Staff Contact Details                       –        Human Resources Department

Appendix D: Organizational Chart                      –        Staff Handbook

4. Review of Business Continuity Plan

The Management Team takes a comprehensive review of risk at least once every quarter. These revised plans must be submitted to the Management Committee for incorporation within the organization’s Business Continuity Plan.

5. Training

All staff is made aware of their roles and responsibilities as part of their induction, supervision, and performance review. Their responsibilities include awareness of key policies and procedures, including the Business Continuity Plan. Staff must take personal responsibility to ensure they are familiar with the content of the Plan so they know who to contact in case of an incident and how they can contribute to the plan’s implementation.

6. Coordinated Responses

The Plan should not be implemented in isolation, but where possible, should be used in conjunction with the Business Continuity and Emergency Plans of the host local authority and emergency services in which it operates.

7. Risk Assessment and Response

The following table is an example that identifies some of the main risks, their likely level of impact on operations and the planned responses to address these risks.

Risk Area                 Details                                          Risk Level             Action / Response

Fire                              Caused by carelessness,               Low                        Each employee has a responsibility in respect of 

                                      accident, terrorism, etc.                                               health and safety risks. 

                                                                                                                                  In accordance with the Fire Precautions (Places of Work) Regulations, there are                                                                                                                                                        Emergency Planning Procedures in place                                                                                                                                                                                           


Loss of data              Caused by technical fault,              Medium               All electronic files are backed up every night and 

                                     human error or sabotage                                              weekly copies kept out of the office Key paper documents should be scanned

And so forth

8. Recording Incidents

Details of major incidents and action taken will be recorded. These notes may be referred to if there is any further investigation and it will also inform future business continuity planning.

9. Key Contacts

A directory of key contacts such as Stakeholders, Landlord, Utility Companies, Service Users, Suppliers, Insurers and others are made available to all staff making emergency response times quicker and more efficient.

10. Crisis Management Group

Step One

If you have a concern, the first point of contact should be your line manager. This can be done orally or in writing.

Step Two

If you feel unable to raise the matter with your line manager, for whatever reason, please raise the matter with any of the company’s Directors.

Step Three

If step one and two have been followed and you still have concerns, or if you feel the matter is serious and cannot be discussed with any of the above, you should contact: the Chairman of the Board of Trustee

Signed By:

Yomi Williams

Group CEO 

Code of Business Ethics

The importance of personal integrity at work can never be overstated. As ambassadors of Gartner Callaway in Nigeria and beyond, each of our employees must maintain a high level of honesty and integrity in all transactions and actions that could in any way reflect on our company.

Our company’s good reputation was established and is reinforced everyday by the actions of our staff. This reputation is based largely on the collective and individual actions of our employees: their work performance will often be perceived as either the actions of Gartner Callaway or as reflecting positively or negatively on the company.

Compliance with the law

Employees must strictly adhere to all laws and regulations of the Federal Republic of Nigeria, in the first instance, and secondarily to the regulations and instructions of Gartner Callaway and its management.

Abuse of office

Employees shall not abuse their office or take any action that may be interpreted as an attempt to benefit from their positions.

Abuse of office includes but is not limited to the following:

• Any attempt by employees to use their positions within the company for personal gains.

 The use of Company funds or assets for unauthorized, improper or personal use.

 Exertion of influence over contractors to the benefit of employees.

 The offering, payment, soliciting or acceptance of bribes in any form.

 The use of office time to conduct the employee’s personal business

 Any attempt by employee(s) to cover up any impropriety by others in connection with the company’s business.

Conflict of interest

Professional excellence can only be maintained by a culture of honesty, integrity and fairness. Employees must, therefore avoid a conflict between their role in the conduct of the company’s business and their private activities. Where such conflict exists, employees must fully disclose all facts to the company through their manager.

Accepting gifts or free services

The acceptance of gifts or gratuitous services from contractors which have business dealings with Gartner Callaway and which could place an employee in a position where his independent business judgment may be prejudiced is forbidden.  Minor corporate gifts may be accepted. All offers of gifts or gratuitous services (whether accepted or rejected) must be reported. In no case should the employee or his family solicits gifts or gratuitous services from companies currently doing, having done, or planning to do business with Gartner Callaway. Inducements (bribes and dash) are at all times unacceptable and should be reported immediately to the employee’s manager. Acceptance, directly or indirectly, of payments, services or loans from a supplier, contractor, sub contractor or other third parties is forbidden.

Offering gifts

Business gift giving spreads goodwill. The British Chartered Institute of Personnel and Development (CIPD) characterizes it as the “consolidation of a business relationship with the main beneficiary being the organization”. It is important that the company manages this function effectively because it could be open to abuse.

Signed By:

Yomi Williams

Group CEO 

Community Relations

Gartner Callaway values the importance of strong relationships with the communities in which we operate. Nurturing of community relationships is a core element of our business’s social responsibility. Through active community participation, we develop a long-term commitment and create positive energy built on mutual understanding, respect and trust balancing our business needs with the needs of the communities within which the company and its people work. Our communities include stakeholders such as landholders, neighbors, councils, local and state government authorities, goods and services providers, environmental and cultural groups, customers and others.

In supporting the community, we will:

• Demonstrate Gartner Callaway’s Community Relations Policy to all employees and other stakeholders as appropriate;

• Recognize that each community is unique;

• Listen to community needs and expectations and seek regular feedback;

• Become an active member of the community through involvement in social, recreational, well being, charitable and cultural initiatives;

• Seek to continually improve our standards of community relations involvement;


• Review and revise our Community Relations Policy to maintain their relevance.

• Reserve 50% of skilled labor and casual labor for the execution of any project exclusively for indigenes of the host community

• The company shall recognize the leadership or the traditional ruling institution of the host community

• The company shall not be involved in the local policies of the host community

By acting on this policy, we make a meaningful contribution and create positive energy within the communities in which we operate.

Signed By:

Yomi Williams

Group CEO

Environmental Policy

This environmental policy is important to Gartner Callaway and states the Company’s commitments and principles to sound environmental performance through the provision of a framework for action and the setting of environmental objectives and targets. Maintaining the quality of our Environment is a high priority to Gartner Callaway in Nigeria. We are committed to safeguarding the environment and the prevention of pollution through the implementation of an effective Environmental Management System (EMS) during projects.

It is our policy to:

• Execute our activities in compliance with applicable local and international environmental laws and regulations.

• Enhance proper waste management through measures that encourage minimization, recycle and reuse of processed waste.

• Set objectives/targets and performance standards in order to promote continual improvements in environmental management system/performance and the prevention of pollution.

• Systematically evaluate the environmental impact of our activities on the physical/socio-economic aspects of our operational environment and the implementation of corresponding mitigating measures.

• Encourage individual responsibility for sound environmental management and the provision of adequate means and organization as well as environmental training programmes for our employees and contractors.

• Co-operate with federal, state and local governments and other relevant stakeholders in sharing/analyzing emerging environmental issues/experiences, finding solutions to environmental problems and developing costeffective, scientifically based environmental standards.

• Maintain corporate/departmental environmental monitoring programs, periodic auditing, inspections and internal reviews to assess environmental performance in compliance with our policy and governmental requirements.

• Develop, maintain and update Emergency Contingency Plans for the protection of our operating environment and the provision of associated resources to mitigate against any accidents.

• Endeavour to manage natural resources in a responsible way, to preserve bio-diversity for future generations and promote sustainable development of our communities.

With the continuous and permanent commitment of everyone, we will achieve these objectives.

Signed By:

Yomi Williams

Group CEO

Health and Safety Policy

The Responsibilities of the Company

The Company will make every practical effort to comply with the obligations laid down under the Health and Safety at Work Act 1974. In particular by:

a) Providing a safe workplace with safe access to and from the premises and a healthy working environment;

b) Providing safe and healthy systems of work by taking all practical steps to ensure that all plant, machinery and equipment is designed, constructed and operated in a safe manner, including the provision of appropriate protective equipment and clothing.

c) Providing safe arrangements for the use, handling, storage and transport of articles and substances;

d) By giving instruction, training, supervision and information to enable all employees to carry out their duties in safety and to actively contribute to the safety within the organization;

e) Providing first aid facilities and training;

f) Consulting staff about arrangements for implementing, promoting and developing health and safety at work. 

The Company will use their best endeavours to:

a) Ensure that this policy is actively complied with and to create a climate in which there is an awareness of the importance of health and safety:

b) Define areas of responsibility for safety where appropriate;

c) Maintain a set of codes of practice and procedures relating to health and safety;

d) Provide the necessary resources with which to pursue this policy;

e) Ensure that any person other than employees and volunteers is protected by this policy;

f) Ensure that employees and other persons affected by this policy are aware of it.

The company will encourage employees to examine this policy and take action or seek advice appropriate to their situation. The company will be willing at any reasonable time to discuss any aspects of the policy with all or any employees. This policy will from time to time be reviewed and amended as necessary. Employees will be kept informed of any amendments.

Employee Responsibilities

All employees have an important part to play in the operation of the Health and Safety Policy. 

Every employee has a responsibility for ensuring that they:

a) Undertake the work they are required to do taking reasonable care for the health and safety of themselves, their colleagues, visitors, customers, contractors and members of the public;

b) Use protective clothing and equipment when and where necessary;

c) Not interfere with or misuse anything provided in the interests of health and safety;

d) Report any incident to the management, which may have led to injury or damage;

e) Give all assistance as required in the investigation of accidents;

f) Become familiar with and conform to this policy and relevant safety instructions at all times;

g) Co-operate with the management in any efforts to comply with the Health and Safety at Work Act 1974.

Signed By:

Yomi Williams

Group CEO

Quality Policy

The responsibility of Gartner Callaway management team is to offer services that meet customer’s quality standard requirements.

In Cognizance:

• That human life during operations may not be put at risk

• That the environment is mankind’s greatest asset

• That the requirements and expectations of the customer must be met,

• That the services offered on the market must be competitive to competitors’ services

• That this is only possible if the service is not only based on efficiency but also on quality

• That more and more charterers/shippers request a certified Quality and Safety Management System.

Gartner Callaway has implemented a Quality and Safety Management System that is documented and has organized measures laid down in a descriptive manual. Green Cottage reserve the right to modify certain procedures put down in it’s manual in order to meet customers and industry instructions or requirements.

Reliability, Sustainability and Safety are characteristics of quality. That means:

• Protection of human life from risks in operations

• Environmental Protection in compliance with IMO, SOLAS, MARPOL and the corresponding appendices

• Maintenance of company asset condition and employees’ qualification

• Co-operation of all employees to obtain a permanent improvement of quality

The consideration of regulations such as:

• ISO Classifications

• FAO Standards

• Classification rules

• Climate change guidelines

• Sustainability codes

The management expects from all employees good co-operation to keep quality standards and service. Employees are expected to follow, to support and to improve the procedures described in the Quality and Safety Management Manual.

Signed By:

Yomi Williams

Group CEO

Security Management Policy

The mission of Gartner Callaway in Nigeria is to do the business of Production, Processing and Trading of Commodities and Sustainability Consulting Services.

However, in achieving this mission, the following two conditions must be fulfilled:

1. Ensuring the security of personnel;

2. Ensuring the safety of the company’s facilities and assets.

The potential risks in our environment are high; therefore our companies, together with our contractors and employees, are committed to providing a secure working environment by protecting ourselves, our assets, and our operations against risk of injury, loss or damage from criminals, hostile or malicious acts.


In line with Gartner Callaway policies and directives:


• We ensure that security policies, procedures and criteria are fully designed and updated; and the means fully available to ensure security and protection for all in our business activities and at all times within our companies’ facilities.

• It is a duty for everybody to take advantage of these means, and to conduct him or herself in a manner that would not compromise their security, the company and other people’s security.

• Security, like safety, is everybody’s business. These rules guide the implementation of this policy.



1. Respect of Laws and Regulations

 In all operations, our companies’ laws in compliance with National and International Laws and Regulations, Gartner Callaway Policies and Directives.


2. Responsibilities

Every employee is responsible for managing the risks pertaining to his specific activity and to the activities of his team members at every level of company operation. 


Line Managers ensure that all persons are aware of the need for constant vigilance, care and compliance with security procedures, and the necessity to report any incident or suspicion to the appropriate entity, authority or person.

Security Management defines and implements Security Policy and Objectives for the Company and communicates to personnel at all levels within the organization. 


The Managing Director/Chief Executive allocates sufficient resources to implement this poly.

3. Risk and Threat Evaluation Review 

Before the implementation of procedure, a risk and threat assessment is carried out to justify appropriate levels of security for which procedures are to be applied. The risks in each site is reviewed regularly, immediately if a situation evolves and once a year for the company.

4. Incident Analysis 

Every incident and, or breach of security is reported, investigated, analyzed and necessary measures including legal and/or disciplinary action taken to prevent reoccurrence.

5. Emergency Preparedness 

The Potentially most serious situations are identified and systematically analyzed to prepare adequate emergency response procedures, appropriate personnel and material to face crisis.

6. Confidentiality 

Company propriety information, including Security Document, is protected and handled in line with security procedures and company “Communications Policy.


7. Competence of Personnel

Security personnel is properly trained and their effectiveness and knowledge regularly assessed. Security awareness and co-operation by our personnel, contractors and employees are continuously renewed.

8. Audits and Inspections 

The implement of our Security Policy will be periodically checked and performance assessed during audits and internal reviews.

Signed By:

Yomi Williams

Group CEO

Substance Abuse Policy

Substance Abuse

Substances in question include Alcohol and Illicit drugs such as Cocaine, Cannabis, and Opiates. In addition, inappropriate use of prescription medications such as Diazepam, Barbiturates, Amphetamines or other substances may result in impairment to health and behavior, judgment or job performance.

It is our policy;

To prevent

• Any of the workforces becoming a risk to themselves or others by the abuse of Alcohol and Substances. The Abuse can be defined as incorrect, improper or harmful use of any substance in such a way as to intentionally modify mood, behavior or performance. It includes the use of medications, which induce dependence, habituation or addiction.

• Impairment of the abilities to perform assigned tasks in a safe and productive manner.

• Dependence by increasing the need to use substances and inability to stop despite attempts to cut down or becoming physically and psychologically reliant on use of the substance.


• Impairment by use, possession, distribution, consumption or sale of alcohol at company premises or on company business is not permitted without prior management approval and control. In case of Road Traffic Accident, systematic detection of alcohol level will be performed and no level of detected alcohol in the blood will be tolerated. Breathalyzer does alcohol testing through electronic equipment in case of abnormal behavior.

Other substances of abuse

• The employee is responsible for making himself/herself fit for work. Employees are informed that they may be tested at random. The use, possession, distribution, consumption or sale of illegal drugs at company premises or on company business is strictly prohibited. This prohibition also applies to the abuse of legal drugs or other substances. Company tests program include testing by urine analysis for: Cocaine, Cannabis, Opiates, Diazepam, Barbiturates, and Amphetamines.

The violation of rules governing conduct in the workplace in respect of substance abuse could result in the application of disciplinary measures.

Signed By:

Yomi Williams

Group CEO