Human Rights Policy


To achieve ISD’s vision and objectives, this Policy uses the following definitions:

Human Rights

Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination.

Universal and Inalienable

The principle of universality of human rights is the cornerstone of international human rights law. This means that we are all equally entitled to our human rights. This principle, as first emphasized in the UDHR, is repeated in many international human rights conventions, declarations, and resolutions.

Human rights are inalienable. They should not be taken away, except in specific situations and according to due process. For example, the right to liberty may be restricted if a person is found guilty of a crime by a court of law.


Complicity is associated with the concept of aiding and abetting an illegal act or omission.

In the non-legal context, complicity derives from broad societal expectations of behavior. In this context, an organization may be considered complicit when it assists in the commission of wrongful acts of others that are inconsistent with, or disrespectful of, international norms of behavior that the organization, through exercising due diligence, knew or should have known would lead to substantial negative impacts on society, the economy or the environment. An organization may also be considered complicit where it stays silent about or benefits from such wrongful acts.

While their boundaries are imprecise and evolving, three forms of complicity can be described.

Direct complicity This occurs when an organization knowingly assists in a violation of human rights.

Beneficial complicity This involves an organization or subsidiaries benefiting directly from human rights abuses committed by someone else. Examples include an organization benefiting economically from suppliers' abuse of fundamental rights at work.

Silent complicity This can involve the failure by an organization to raise with the appropriate authorities the question of systematic or continuous human rights violations, such as not speaking out against systematic discrimination in employment law against particular groups.


The purpose of this Policy is:

  1. to establish guidelines and principles for ISD’s engagement regarding the respect for human rights in its projects, operations and activities, in every community ISD is present.
  2. to establish ISD’s commitment towards the respect of Human Rights as those are defined and expressed by:
  • the International Bill of Human Rights,
  • the International Labor Organization’s (ILO) Declaration of Fundamental Principles and Rights at Work,
  • the International Covenant on Civil and Political Rights,
  • the International Covenant on Economic, Social, and Cultural Rights,
  • the Universal Declaration of Human Rights,
  • the United Nations Global Compact Principles,
  • the United Nations Guiding Principles on Business and Human Rights,
  • the Global Network Initiative Principles.


Application Scope

This policy applies to every employee and director of ISD, its subsidiaries and affiliates worldwide, as well as third parties acting on behalf of ISD. It is the responsibility of ISD’s employees and directors, to promote a culture where rights are understood and respected.

The policy also applies to all our suppliers including direct and indirect suppliers and invites all our business partners to uphold the principles herein and adopt similar policy within their own businesses.

For other entities in which ISD has an ownership interest, its reproduction is recommended in compliance with the related Policies & Procedures of ISD’s Management System.


ISD’s Human Rights Policy is effectively expressed as well as implemented through the following principles and procedural activities:

  1. Due Diligence

ISD maintains a structured human rights due diligence approach that aims to:

  • Identify and prevent human rights risks to people in our business as well as those affected by it,
  • Integrate findings into our internal controls, systems and processes,
  • Track the effectiveness of our actions and influence,
  • Communicate with our internal and external stakeholders.
  • Human rights due diligence will be carried out annually and immediately when incidents of Human rights violation are identified within ISD’s operational spectrum.


  1. Human Rights Risk Situations

ISD recognizes that there are certain circumstances and environments that lead to undeniable challenges and dilemmas relating to human rights and may result in human rights abuse. These include:

  • conflict or extreme political instability, failure of the democratic or judicial system, absence of political or civil rights,
  • poverty, drought, extreme health challenges or natural disasters,
  • activities that can affect or involve children, and more
  • ISD commits to investigate and respond to such challenges by first conducting the necessary Human rights due diligence and/or Risk assessments.


  1. Avoidance of Complicity

Part of ISD’s Human rights due diligence procedure is to ensure that the Company isn’t incalculably participating in, facilitating or benefiting from human rights violations.

Moreover, ISD commits to:

  • not provide products or services to an entity that uses them to carry out human rights abuses,
  • not enter into a formal or informal partnership or contractual relationship with a partner that commits human rights abuses in the context of the partnership or in the execution of the contracted work,
  • inform itself about the social and environmental conditions in which purchased goods and services are produced,
  • consider making public statements, or taking other action indicating that it does not condone human rights abuse, such as acts of discrimination, occurring in employment in the country concerned, and
  • avoid relationships with entities engaged in anti-social activities.


  1. Resolving Grievances
  • ISD warmly invites any individual or party directly or indirectly affected by the Company’s operations to express their grievance (if any) regarding Human rights issues.
  • Τhe issue will be openly discussed internally and externally.
  • In case aggrieved parties face barriers to access, such as language, illiteracy, lack of awareness or finance, distance, disability or fear of reprisal, ISD shall provide aid (where possible) in order to reduce those barriers.
  • ISD will provide access to sources of information, advice and expertise for conducting a righteous investigation of the issue.
  • Depending on the nature of the issue and the necessary procedures to resolve, a clear time frame for each stage and clarity as to the types of process and outcome as well as means of monitoring the implementation, shall be provided.
  • Internationally recognized human rights standards will be taken is serious consideration so that the outcomes and remedies of the process are corresponding.
  • Appropriate level of confidentiality depending on the nature of the issue shall be implemented.
  • ISD will discuss these issues in a friendly, open manner.


  1. Discrimination and Vulnerable Groups

We do not tolerate discrimination against individuals based on race, color, gender, age, language, property, nationality or national origin, religion, ethnic or social origin, caste, economic grounds, disability, pregnancy, trade union affiliation, political affiliation or political or other opinion.

We take action to:

  • implement fair employment practices and maintain a workplace in which all individuals are treated with dignity and respect.
  • periodically examine our own operations as well as the operations of other parties within ISD’s sphere of influence to determine whether direct or indirect discrimination is present.
  • provide training on our human rights expectations to all new employees and all relevant existing employees.


ISD has established and implements a Gender Equality Policy that addresses related Human rights issues specifically and accordingly.


  1. Civil and Political Rights

ISD respects and promotes:

  • freedom of opinion and expression,
  • opinions, even when the person expresses criticism of the organization internally or externally,
  • freedom of expression and right to associate of our employees and contractors, including their right to establish and to join organizations of their own choosing to bargain collectively and advance their occupational interests without our previous authorization or unreasonable interference
  • freedom to seek, receive and impart information and ideas through any means, regardless of national borders,
  • life of individuals,
  • access to due process and the right to a fair hearing before any internal disciplinary measure is taken.


Any disciplinary measure should be proportionate and not involve physical punishment or inhuman or degrading treatment.


  1. Economic, Social and Cultural Rights
  • ISD assesses the possible impacts of its decisions, activities, products and services, as well as new projects, in terms of Social and Cultural rights such as:
    • education,
    • work in just and favorable conditions,
    • freedom of association,
    • adequate standard of health,
    • standards of living adequate in terms of physical and mental health and well-being of individuals and their families,
    • food, clothing, housing, medical care,
    • necessary social protection, such as security in the event of unemployment, sickness, disability, death of spouse, old age or other lack of livelihood in circumstances beyond his or her control,
    • the practice of a religion and culture,

including the rights of the local population.

ISD shall neither directly nor indirectly limit or deny access to essential Civil and Political rights.


  1. Fundamental Principles and Rights at Work
  • ISD respects and complies with all the fundamental rights at work identified by the International Labour Organization (ILO) as well as the ones defined by the National and International legislation. Specifically:
  • We recognize and respect the freedom of association and collective bargaining, meaning that: Representative organizations formed or joined by workers should be recognized for purposes of collective bargaining. Terms and conditions of employment may be fixed by voluntary collective negotiation where workers so choose.
  • Workers' representatives should be given appropriate facilities that will enable them to do their work effectively and allow them to perform their role without interference. Collective agreements should include provisions for the settlement of disputes. Workers' representatives should be provided with information required for meaningful negotiations.
  • We do not engage in or benefit from any use of forced or compulsory labor.
    No work or service shall be demanded from any person under the threat of any penalty or when the work is not conducted voluntarily.
  • We confirm that our employment policies are free from discrimination based on race, color, gender, religion, national extraction, social origin, political opinion, age, disability, marital or family status, personal relationships, and health status. ISD’s Hiring policies and practices, earnings, employment conditions, access to training and promotion, and termination of employment are based only on the requirements of the job.
  • We do not tolerate the use of child labor, prison labor, or any form of forced labor, slavery or servitude.



Employees and contractors violating this Policy may be subject to disciplinary action at the discretion of ISD’s Management.