Insights

Since 2004, Page Group has managed and operated security contracts for diplomatic missions in high risk countries including Haiti, Afghanistan, Sri Lanka, Kingdom of Saudi Arabia, Palestinian Territories and Sri Lanka. The contracts involve the provision of close protection teams to the Head of Delegation/Ambassador and Senior Staff as well protecting their premises.

Below is an overview of the daily duties of one of our international security managers protecting EU Missions and other Embassies in Israel and the West Bank.

“Every day starts around 6 o’clock, checking the recent announcements of the Israeli government, Israeli Defense Force, Lebanese Government and Army, Palestinian Authorities and regional media outlets for updates on the current situation to anticipate any possible scenario that could develop during the day. I prepare a quick report for our clients, to inform them of any potential events, for example, a potential attack from Iran or something similar. Once the guards start arriving at their posts, I check in with them to ensure they are ready for the working day, regarding their respective missions and the current national situation. They inform me if there are any requests regarding equipment maintenance or supply acquisition.

Around 9 or 10 in the morning, I arrive at the office, and proceed to do my administrative work. This includes but not limit to checking our “punch in and out” system, request for new equipment including guns or ammunition if it is needed, preparing extensive report for the clients if they require them, paperwork regarding the different government offices and prepare a recce report for possible locations that our clients may visit in the future.

Usually by 3pm I will visit the different projects under my supervision to check how our team is performing to ensure that we are maintaining our high standards and state of alert. Sometimes, the clients, represented by their Security officers (aka Regional Security Officer/Advisor or Security Manager, etc) and their Head of Administration, request a meeting to discuss future events that requires our assistance.

There were many expats who were terrified of the situation, so our duty was also to calm them down. I remember how I personally handled the evacuation of a mother and her daughter where the mother was in panic, not knowing what to do once the Ambassador of her mission told her to evacuate, asking every five minutes if they were going to die. We are aware that our clients are not used to this extreme situation, and I think that it is one of our prime duties to keep them calm and demonstrate how they will be ok.”

In July this year the Corporate Sustainability Due Diligence Directive ‘CSDDD or CS3D’ came into force. This is a European Union Directive which sets a corporate due diligence duty for larger companies concerning environmental and human rights transgressions.

CSDDD – Who it affects

The directive is applicable to EU and also to non- EU businesses depending on size (see below). The date set by which companies need to comply is staggered (up until the end of July 2029) depending on the size and turnover of the company. Importantly for all companies covered by this Directive is that it encompasses not only the business itself, but also its subsidiaries and the whole of its supply chain, globally.

The EU Commission outlines the following guidelines for those companies that need to comply:

Small and Medium-sized Enterprises (SMEs)

Micro companies and SMEs are not covered by the proposed rules. However, the Directive provides supporting and protective measures for SMEs, which could be indirectly affected as business partners in value chains.

Requirements for Compliance – Due Diligence

Each company affected by the Directive will have an obligation to undertake due diligence and make this part of the corporate strategy. The due diligence needs to take into consideration human rights, climate change, and the environmental impact of their actions and decisions – the findings of the due diligence will be made public.

For more information about the Corporate Sustainability Due Diligence Directive see the European Union website –
Corporate sustainability due diligence – European Commission

For more information about how Page Group can assist with due diligence please do not hesitate to contact us.

The United Nations Office on Drugs and Crime recently issued a paper on Organised Fraud. The paper looks closely at how fraud has changed and adapted with technological changes, how organised crime uses it and the damage it does to people, economies and prosperity worldwide.

The paper created a broad definition of fraud to cover the variety of laws in different countries. It describes it as “fraud that deliberately uses deception by any method or medium with the intent to make a wrongful financial or other material gain and which causes detriment to another”.

It describes an “organized criminal group” as defined in article 2 (a) of the Organized Crime Convention as

The report noted that modern technology has industrialised fraud methodologies that have long been in existence and also automating many laborious processes. In addition the availability of encryption tools played an important role in enabling cybercrimes, anonymizing the fraudsters, all using legally available technology.

In order to combat organised crime, the report recommended a multi -pronged approach:

• Legislation – adoption of clear and robust legal framework (it varies country to country)
• Law enforcement should adopt the following strategies:
 Assessing and Targeting organised Fraud
 Criminal investigation – report notes that in many regions the police are not equipped to address the growth in cyber fraud.
 Disruption – a more proactive approach by law enforcement to disrupt organised crime
 International Co-operation
 Diverse Workforce (in law enforcement) – to improve the poor experience of women and persons from diverse backgrounds in co-operating with the police.
 Intelligence Led Policing – improve the data collection, sharing and analysis to identify patterns, connect separate offences and locate/identify potential suspects.

Prevention

The report noted that: “effective crime prevention is contingent not only on developing more secure systems, but also on equipping the public and business community with the knowledge, awareness and capabilities to defend against fraud. Fraud is highly diverse and continuously evolving, and the effectiveness of education and awareness-raising campaigns lies in public messaging that is succinct and clear enough to influence public behaviours and vigilance”

In addition it recommends the following:

• Better Collection of Data
• Centralized Fraud Reporting
• Integrating Data Sets – the sharing of information between countries is essential to prevent, identify and investigate suspects.
• Public-Private Sector Partnerships – better co-operation between law enforcement and private sector such as the financial institutions and technology companies to help prevent and investigate fraud.

The full report can be found here:

UN Report on Organised Fraud

What is its Source?

90% of the world’s data was generated in the last 2 years and that data growth is expected to increase by 150% in 2025.[1] The increase in digitalised information has led to a rise in publicly accessible information. This in turn has led to a dilemma – how to verify that the information being generated/uncovered is real/truthful.

The accessibility of the technology has meant that anybody who can use a smart phone can put data out into the public realm through a plethora of social media sites, blog sites, YouTube and social chat. Information generated in this way also gets picked up by other websites, including the many online sites providing corporate details, health information, news reports, celebrity stories and political information to name but a few.  This impacts everyone, whether they are an individual searching online, or those responsible for maintaining databases providing public information, or those working in the information/intelligence gathering sector.

Data analysis in the Investigations/Intelligence Industry

There can be no discussion about data analysis without discussing the role of AI technology. There are many current debates about whether the upsurge in data and the increasing developments in AI technology will make data analysts obsolete. And whilst AI algorithms can search through large datasets much more quickly than a human brain – for instance, AI is more efficient/faster at extracting patterns in data, at image recognition and processing unstructured data etc – the results of AI searches will still need human analysts to help provide context and help verify the source of the information.   The increasing importance of data and information means that there is an increasing need for analysts to make sense of data. Analysts’ roles will still be pivotal in data-driven companies.

These sources on the ground can also give an informed opinion regarding the quality/veracity of smaller online publications as well as the various main stream press (including political bias etc).  They can also analyse and question any the information obtained by undertaking human intelligence enquiries, talking to people who have knowledge of the subject(s) being investigated and asking questions.

[1] https://www.luzmo.com/blog/ai-data-analysis

Investigating/tracing stolen art work and luxury items is complex. It requires knowledge of the particular market i.e., fine art, luxury goods, antiquities etc.  Knowing the market can guide you in understanding how items are moved around as well as the potential places/countries where they might be held. Knowledge of the market also allows a greater understanding as to how the works are sold on, including type of currency used and payment method (including cryptocurrency).

Fine art market

Focussing on the fine art market (paintings and sculpture) as an example, if an artwork is stolen, there is little intrinsic value, unless it is attributed to an artist and has good provenance. Before any investigation begins, it is important to check that the artwork in question has official, legitimate, provenance. This document is used to verify that the art in question is not a forgery and that the person who is claiming that the art work has been stolen, is the legitimate owner of the art.

There are some rudimentary searches that can be initially made when an art work has been stolen and these include:

• Using a photograph of the art work to search online for any corresponding images of the work.
• Online searches using as many details as available type of art (painting, sculpture), medium, classification (surrealist, modernist, postmodern, cubist etc) as well as the title, artist’s name, or country of provenance.

One of the largest databases of ‘lost art’ is the Art Loss Register. This register includes more than 700,000 items reported as missing. The database offers a due diligence service to clients in the art market who wish to ensure that they are working with items to which no claim will arise. The register can be used to check the provenance of items before people buy or handle art. Police, insurers, the trade and the public may record items that have been stolen and to record disputes or items within collections.[1]

Interpol also hold a database of stolen art. On its website it states that it combines descriptions and pictures of more than 52,000 items.[2] The database is open to any authorized user, to check in real-time if an item is among the registered objects. It can therefore be used to check if any art being offered for sale is listed as stolen.

There are also several experts that can be called upon to provide information concerning the work:

• There are experts in provenance research who can help prove chain of ownership and legitimacy.
• The insurance company used to insure the art work (any, legitimate valuable work will be insured). The insurance company will know where the art is listed as currently being held as well as noting that the art has been stored correctly in a temperature-controlled environment – again this is to ensure that the art work in question is legitimately owned and registered.
• Law enforcement. They will know the names of any suspect dealers who have been convicted in the past of art theft or of moving stolen art work.
• Shipping companies. If a work is being shipped anywhere it will require documentation which can put you on the trail of its movements.
• Art market dealers. Dealers can be an invaluable source as they have knowledge as to which art work has become available for sale through various trade online sources.

Finally, it is also important to remember that not all valuable art works are by artists who have long since died. Many contemporary artists are making works that sell for tens of millions. These artists and their agents, dealers and galleries will be able to comment on the legitimacy of a work (including early, possibly less known works) as well as giving possible clues to who would be interested in the work, where it sells and how the work is usually acquired and paid for.

[1] https://www.artloss.com/

[2] https://www.interpol.int/en/Crimes/Cultural-heritage-crime/Stolen-Works-of-Art-Database

For over ten years Page Group has been supporting security departments of the multinational corporations in the management of the travel integrity and security programs for their Executives and business travellers.

Page Group has been deploying tactics and procedures based on its security management experience of the intelligence-driven, low-profile, and avoidance based approach. Page Group deploys experienced, low profile close protection trained operatives (international and/or local) with local knowledge who are sensitive to commercial environments. They may accompany the Executives overseas enabling the client to work in the knowledge that all aspects of their personal safety are being managed. The operatives may go in advance of an Executive to meet at airports and ensure all arrangements are made in the destination country. Other roles include conducting counter surveillance, physical security (checking hotels, residences, offices and venues of interest) and instigating crisis management and evacuation when the situation requires. Page Group maintains working relationships with the experienced and qualified local security providers in the countries and locations of interest. The services have been recently provided in Iraq, Libya and the United Kingdom.

The European Diplomatic Mission to the West Bank and Gaza entrusted Page Group with the security of persons and premises, as well as the surveillance of these premises.

The different assignments include the protection of the Office, the Residence and the houses of members of the Mission by armed international and unarmed local guard force; access control for persons and vehicles to those offices and houses; managing and handling security equipment and radio communication; security driving with designated staff in an armoured vehicle; providing a motorised patrol for a general supervision of the Mission premises, the residence, the houses and apartments of all designated Diplomatic officials; the armed Close Protection of the Head of Mission and other officials on their missions to the West Bank and Gaza Strip, and on the assignments in Israel.

The European Diplomatic Mission to Afghanistan entrusted to Page Group the security of the Diplomatic compound in Kabul, the Head of Mission and its Diplomatic staff. The project included the organisation of the management structure of both the physical security guard force, Close Protection team and mobile Quick Reaction Force. The guard force consisted of the international Management Team and the Operations Room staff, armed third-country national guards and unarmed local national guards. The Close Protection teams and mobile Quick Reaction Force were manned by the armed international staff. In total over 250 personnel were deployed. All third-country national staff were former Indian Army Gurkhas or former members of the Singapore Police Gurkha Detachment.

Page Group was instructed by a high net worth client to investigate an employee whom they suspected of abusing his senior position to use company funds and credit cards to fund a gambling addiction.  As well as investigating the Subject’s background and current lifestyle (to check if it was in keeping with his salary), we conducted analysis of company credit card statements and withdrawals of cash to identify patterns of spending and where he went.  Based on this intelligence, we conducted a period of surveillance to obtain evidence of visiting casinos and his spending habits. Based on this the Client was able to dismiss the employee.

A law firm instructed Page Group to prepare an asset tracing report on a shipping company who had chartered a vessel from their client.  The subject company had not paid the final instalment of the charter and the law firm wanted to check to see if it had any assets prior to taking any legal action.  The client provided limited information other than the company name and an address in Athens.  Research identified the company was incorporated in Singapore, owned by two Marshall Island companies.  The Athens address and phone numbers were linked to two other companies. These two other companies had similar websites to the Subject Company.  All three had been registered on the same day.  It appeared the Subject Company had been set up as Special Purpose Vehicle, solely for the charter of this vessel, and had no assets of its own.

For the last 5 years Page Group has been providing ongoing support to a law firm who have been pursuing a significant debt on behalf of a multi-national client.  The law firm who had already secured judgement used Page Group to track the Subject in the UK, conduct surveillance to see who he was meeting, identify assets overseas particularly in Asia, provide support when serving papers and conduct research into the Subject’s family, to whom the Client believed the Subject had transferred his assets.

Page Group regularly conducts due diligence on behalf of a pharmaceutical client. The due diligence covers all companies that form the client’s global supply chain.  The focus is on ensuring that all the companies and management working with the client are operating in compliance with the strict regulatory requirements of the industry.

Recognising the challenge for the client is in the breadth of jurisdictions involved (all of which vary culturally, politically, and economically) Page Group uses its vast network of in-country sources to help collate the relevant information. Working/living in-country, the sources can provide additional information allowing an informed analysis which considers these differences. The enquiries have uncovered several potential issues for the client. For instance, owners/senior managers with political connections to the current government in a country in political turmoil, the lack of a proper licence to operate or accusations of collusion or corruption during the tendering for state contracts

Page Group was engaged to conduct due diligence on a company involved in a tender issued by the Client. The objective was to establish if this company bidding for the tender had the capability to offer facilities for Liquid Petroleum Gas (LPG) extraction, following the receipt of confidential information that it was tendering on behalf of another (related) company, hidden from the process.

Using in-country sources, Page Group investigated any potential links between the alleged proxy company and the hidden company. This included a comprehensive review of both companies and affiliates’ ownership structures. These investigations identified one indirect link between the companies – a family member of the tendering company, had previously worked for the alleged hidden company. Further investigations revealed that contrary to the confidential information the client had been given, the tendering company was in fact acting independently.

DOING BUSINESS WITH INDIA – THE GROWTH OF OPPORTUNITY

In June 2023 India became the most populous country in the world, overtaking China.  Economically, it is the fifth largest economy in the world according to their GDP data and will only continue to grow and become stronger.  This growth, according to Forbes India, is fuelled by information technology, services, agriculture, and manufacturing.   Other sectors that are performing well include the pharmaceutical industry (which had a major role in manufacturing the COVID-19 Vaccines); semi-conductor manufacturing (Tata Group), logistics/supply chain, education and Healthcare infrastructure.   In addition, it has an expanding Middle Class and a young and technologically educated and adept workforce.

The UK, based on recent press speculation, is close to signing a Free Trade Agreement.  According to UK Governments publishing service, total trade in goods and services (exports plus imports) between the UK and India was £36.3 billion in the four quarters to the end of Q1 2023, an increase of 34.2% or £9.2 billion in current prices from the four quarters to the end of Q1 2022.

The ICC Cricket World Cup started on 5^th October.  It will be held in 10 cities across the country, with the largest stadium holding 132,000 people.  It will be a riot of colour, passion and noise and hopefully produce some great games as well as attracting world attention.

The positive opportunities for trading with and investing in India are increasing all the time.  As a company Page Group have operated in India for a number of years providing due diligence services on new business partners, suppliers or distributors.  We have a good network of contacts who can retrieve vital information on the background and reputation of companies/individuals as well as conduct site visits to factories/operating hubs to ensure compliance with all ESG (environmental, social and corporate governance) issues.   If you need assistance with any business matters in India Page Group can help you. Please do not hesitate to contact us.

HOW SOCIAL MEDIA IS USED TO FIND VICTIMS

Fraud via social media takes many forms, depending on the type of social account (LinkedIn, Instagram, Facebook, X etc). It not only affects individuals but businesses too where criminals may fraudulently imitate a genuine company. In other cases, business hackers use social media to steal personal data or gain control of your social media accounts which leads to confusion for clients and those using the genuine company’s services. There are also the widely publicised fake cryptocurrency and investment opportunities, which are one of the biggest scams using social media platforms. The implications of social media fraud are potentially enormous causing financial loss and damage to a company’s reputation.

HOW PREPARED IS YOUR COMPANY?

Botnet, data breach, exploitation, malware, phishing, ransomware, spyware, spoofing, Trojan horse, zero-day vulnerability, virus and worm.  These are just some of the often confusing terms one might see in news headlines and articles when describing the latest cyber-attack on a company or government institution.   Implementing good cyber security is essential to protect a company’s assets and IP and to reassure clients and customers that any details they provide will be secure.

SANCTIONS AND DUE DILIGENCE

BBC DOCUMENTARY: “TRUE COST OF OUR TEA: SEXUAL ABUSE ON KENYAN TEA FARMS REVEALED”

It was shocking to watch the recent BBC undercover investigation into the sexual harassment of women workers on tea plantations in Kenya. The perpetrators are allegedly the line managers/managers of the plantations. These women, desperate for work, were only given a job if they complied with the requests of the management and it made for difficult viewing.

What is equally shocking is that at the time of filming, the companies Unilever and James Finlay & Co owned the plantations and supply the UK’s most popular brands, including PG Tips, Lipton and Sainsbury’s Red Label.  During the period the undercover filming took place, Unilever sold the plantation to Liptons (2021).

It was noted that Unilever joined the Ethical Tea Partnership (ETP) in 2017, an organisation that aims to improve supply chain standards and had a system in place for reporting any abuse in its workplaces.  In reply to the allegations uncovered in the documentary, Unilever said “We are very disappointed that the measures put in place to make it easier to report, detect and investigate abuse failed to detect and address the issues highlighted by the BBC and we welcome the fact that Lipton Teas and Infusions will commission a full and independent investigation into these serious allegations.”

Due diligence on supply chains can cover a range of potential issues not just sexual harassment but also: child labour, environmental practices, failure to comply with safety regulations, licensing, being properly registered and any legislation against the company or its owners, etc.  It is important to conduct due diligence to know whom you are working with, as any issues could lead to reputational damage with implications for your business.

Due diligence should be conducted in-country, on the ground and by local investigators who know the local laws and customs and can give an opinion on whether there are potential issues in countries whose laws/practices may differ from those in the UK. Furthermore, where possible conducting unannounced visits to the site in question or carrying out a covert visit is a good idea to see how the company is run daily. This can be done in addition to making discreet enquiries into a company’s reputation company.  And of course, due diligence needs to be regularly updated to review any changes (in management, ownership, structure, etc).

For assistance with any of the above matters above and to discuss where Page Group can help, please do not hesitate to contact us.