BARRIER SERVICES LTD. Fencing Contractors

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1 BARRIER SERVICES LTD. DOCUMENTS: Health & Safety at Work We will take all reasonable measures to ensure that any employee, self-employed person and contractor under our control whose health and safety may be affected by our work activities are made aware of the contents of this Policy, the possible effects upon their personal health & safety, upon their colleagues health & safety and the possible consequences in the event of any breach of this Policy. We recognise our obligations under Section 2(1) of The Health and Safety at Work etc. Act 1974 and the various duties and obligations under The Management of Health and Safety at Work Regulations 1999 and associated legislation and will take all reasonable measures to prevent, so far as is reasonably practicable, any breach of duty placed upon the Company by legislation and/or this Policy. Our employees will at all times exercise diligence in ensuring that this policy is adhered to. Responsibilities of individuals are determined by their grade of employment as detailed elsewhere within this Policy. We will undertake, as far as is reasonably practicable, the following:- d). e). f). g). h). i). The provision and maintenance of plant and systems of work that are safe and without risks to health. Arrangements for ensuring safety and absence of risks to health in connection with the supply, use, handling, storage and transporting of articles and substances. The maintenance of places of work which are safe and without risks to health, safe access to and egress from such places and arrangements for their welfare at work. The provision of such information, instruction, training and supervision as is necessary to ensure the health and safety at work of employees. Adequate arrangements to ensure that employees or their representatives are given every facility for consulting with management in promoting and developing measures to ensure the health and safety at work of all employees. Systems and procedures which will ensure that all operations and activities are executed at all times in such a manner that persons not in our employment who may be affected by such operations are not exposed to risks to their health and safety. Continually improve health and safety performance to ensure that best practises are implemented. Identify objectives that are both consistent with this policy and which can be monitored and measured to ensure their continued suitability and provide a framework for continual improvement. However Health and Safety will never be compromised for any other objective. Review this policy after changes in legislation or Company structure, in the light of additional knowledge or information becoming available, and in any event annually.

2 DOCUMENTS: Company Structure BARRIER SERVICES LTD. Barbara Gibson Managing Director Dan Raffles Commercial Director (SHEQ, HR & IT) R Philip Gibson Director (Transport & Estate) Neil Amesbury Operations Director (Training & Plant) R South Wales Safety Consultancy Tony Heneghan Senior Quantity Surveyor Gordon Davies Transport Manager Jason Huntley Senior Contracts Manager Sonia Whitfield Office Manager Green Triangle Consultancy TBC Estimator Lorry Drivers & Fitters Paul Whitcut Senior Contracts Manager Darren Gibson Accounts Administrator NQA Jamie Wicks Contracts Manager Keila Mayo Office Administrator Peninsula Business Services Damien Conway Contracts Manager Ann Reynolds Office Administrator Site Supervisors & Installation Teams R = Nominated to report RIDDOR occurrences BSL/QM Issue 3 Section: 3 Revision: F Page: 24 of 67

3 DOCUMENTS: Quality BARRIER SERVICES LTD. It is the policy of Barrier Services Limited to ensure that throughout all aspects and all levels of the company s business, quality is of the highest standard. The Company adopts the principles stated in BS EN ISO 9001:2015 and operates a quality management system (QMS) within its guidelines and those of the Sector Schemes for Quality Management in Highway Works - Scheme 2A (The Design and/or Supply, Installation and Repair of Fences), Scheme 2B (The Supply, Installation & Repair of Vehicle Restraint Systems and Scheme 2C (The Supply, Installation & Repair of Environmental Barriers). Barrier Services Limited is committed to: d). e). f). g). h). Adhere to all applicable policies and legislative guidance, and strive to meet or exceed industry standards, best practice and the expectations of interested parties in all areas. Maintain a PDCA cycle (Plan, Do, Check, Act) Process Approach to assessing and managing risks to achieve compliance to both customer and regulatory requirements. Embrace continual review procedures in order to ensure the suitability of the system on an ongoing basis and to monitor and continually improve its effectiveness in achieving the overall goal of the highest possible standards. Top management ensuring that working practices meet the requirements of the standard and that sufficient resources are available and maintained for the successful and meaningful implementation of this policy. The provision of such information, instruction, training and supervision as is necessary to ensure the health and safety at work of employees. Continually improve performance and risk management to ensure that best practises are implemented. Identify objectives that are both consistent with this policy and which can be monitored and measured to ensure their continued suitability and provide a framework for continual improvement. Review this policy after changes in Company structure, in the light of additional knowledge or information becoming available and in any event annually.

4 BARRIER SERVICES LTD. DOCUMENTS: Environmental We will take all reasonable measures to ensure that any employee, self-employed person and contractor under our control whose work activities have an impact on the environment are made aware of the contents of this Policy. We recognise our legal obligations and duties and will take all reasonable measures to prevent, so far as is reasonably practicable, any breach of duty placed upon the Company by legislation and/or this Policy. Our employees will at all times exercise diligence in ensuring that this policy is adhered to. Responsibilities of individuals are determined by their grade of employment as detailed elsewhere within this Policy. The Company commits to the following specific steps to minimise its effects on the Environment:- d). e). f). g). h). Ensure that all staff are trained in Environmental Management issues in so far as they impact upon our operations and are made aware of this Policy Document. We will aim to reduce carbon dioxide emissions. We will aim to reduce, so far as is reasonably practicable, dust, noise and fume emissions so that they do not cause a nuisance to the community surrounding the place of work Recycling will be used as much as possible and where practicable waste production reduced. Office staff will be encouraged to use paper and other products sensibly and increase the use of electronic communication and record keeping. Commitment to continuous improvement in our environmental performance and the prevention and reduction of pollution. Identify objectives that are both consistent with this policy and which can be monitored and measured to ensure their continued suitability and provide a framework for continual improvement. Review this policy after changes in legislation or Company structure, in the light of additional knowledge or information becoming available, and in any event annually

5 DOCUMENTS: Business BARRIER SERVICES LTD. Statement of Commitment Barrier Services Limited are an independently owned company who operate an externally audited Quality Management System (QMS) to BS EN 9001:2008 and to the National Highways Sector Scheme and abide by the code of conduct issued by the Association of Fencing Contracts Association (AFCA). The aim of Barrier Services Limited is to establish mutually beneficial working relationships with all of its customers and suppliers, in order to explore business opportunities and to deliver contracted works in accordance with agreed programmes, without conflict while delivering the highest level of service and support from initial tender enquiry to contract completion. Confidentiality We are committed to maintaining the highest degree of integrity and confidentiality in all dealings with potential, current and past clients and extend such same standards to our supply-chain. Ethical Business Conduct We always conduct our own services honestly and honourably, and expect our clients, suppliers and employees to do the same. Our approach and advice provided always endeavours to take account of ethical considerations. We value our customers and the trust that they place in us and will safeguard the information provided to us by our customers in accordance with relevant laws and contractual commitments. Our honesty and integrity regarding the products and services we provide will not intentionally be misrepresented. Duty of Care Our actions and advice will always conform to relevant law, and we believe that all businesses and organisations, including this Company, should avoid causing any adverse effect on the human rights of people in the organisations we deal with, the local and wider environments, and the well being of society at large. Professional Conduct We conduct all of our activities professionally and with integrity and take great care to be completely objective in our judgement and recommendations in order that issues are never influenced by anything other than the best and proper interests of our clients. Bribery and Corruption We are dedicated to ensuring full compliance with all anti-bribery and corruption laws and regulations, including the Bribery Act Our policy is that no employee shall pay bribes or offer improper inducements to anyone for any purpose, nor will we accept bribes or improper inducements. We will not tolerate bribery or corruption in any form and have a zero tolerance approach to any breach of this policy. All directors and employees are required to comply with the policy.

6 DOCUMENTS: Business BARRIER SERVICES LTD. Disaster Recovery / Business Continuity We maintain duplicates of all contractual documentation and maintain daily server backups to ensure that if documentation is lost or damaged, system normality can be resumed efficiently and effectively. In the event of a serious business incident the Company will nominate a member of senior management as lead contact to liase and coordinate with employees, clients, suppliers and stakeholders to endeavour to service all current contract commitments to a level that achieves customer satisfaction. Sustainable and Ethical Procurement The Company endeavours to incorporate sustainable development and consideration of customer requirements by ensuring awareness of alternative products and services. Wherever reasonably practicable the Company will procure materials and services from Companies with ethical policies and make procurement decisions based on a balance between economic, social and environmental factors. All timber products are purchased from sustainable sources and carry the stamp of approval from Forest Stewardship Council (FSC).

7 BARRIER SERVICES LTD. DOCUMENTS: Drugs and Alcohol This statement sets out the policy of Barrier Services Ltd in respect of any employee, self-employed person or contractor under our control (employees) whose proper performance of their duties is, or may be, impaired or otherwise affected as a result of the consumption of alcohol and/or illegal substances. Provided that employees adhere to the provisions contained within this policy, they will normally be considered to have demonstrated compliance with the conditions of their employment with regard to the use of drugs and alcohol. All employees are to be made aware of the contents of this Policy. Policy:- The Company will take all reasonable measures to prevent, so far as is reasonably practicable, any breach of duty placed on any person by this Policy and to encourage a safer and healthier working environment. This may include providing awareness of the acceptable standards and screening when contractually required and/or when such screening is warranted by just cause or circumstance. Employees will be expected at all times to exercise diligence in monitoring their colleagues, and to report any evidence of alcohol and/or drug abuse to their line manager. Should any employee suffer any problems or difficulties in respect of the misuse of drugs and/or alcohol, or should they have reason to believe that a colleague may be experiencing such difficulties, they may approach a Manager, who will at all times treat information provided as confidential and take such measures as are deemed necessary to ensure that the matter will be resolved in a fair and consistent manner with the minimum of distress to the person concerned and others who may be affected. It is a condition of employment by the Company that no employee shall:- d). Report, or endeavour to report, for duty whilst under the influence of alcohol or drugs. Report, or endeavour to report, for duty whilst in an unfit state due to previous consumption of alcohol or drugs. Be in the possession of alcohol or non-prescribed drugs during working hours. Consume alcohol or non-prescribed drugs during working hours. The Company will not accept any deviation from the above conditions and failure to maintain the standards set out by this Policy may be considered as gross misconduct and will lead to the enforcement of appropriate action in accordance with the relevant disciplinary procedure where warranted by circumstance. In addition, employees must ensure that a manager is made aware of any prescribed medication being taken which may in any way affect their performance at work and the nature of any such medication that they are required to carry with them during working hours.

8 BARRIER SERVICES LTD. DOCUMENTS: Work Safe (Refusal to Work) We will take all reasonable measures to ensure that any employee, self-employed person and contractor under our control whose health and safety may be affected by our work activities are made aware of the contents of this Policy, the possible effects upon their personal health & safety, upon their colleagues health & safety and the possible consequences in the event of any breach of this Policy. We recognise our obligations under Section 2(1) of The Health and Safety at Work etc. Act 1974 and the various duties and obligations under The Management of Health and Safety at Work Regulations 1999 and associated legislation and will take all reasonable measures to prevent, so far as is reasonably practicable, any breach of duty placed upon the Company by legislation and/or this Policy. Under the Health & Safety At Work Act 1974, every employee has the absolute right to refuse to carry out work which is unsafe. It is the employees right, and duty to report any concerns that they have on carrying out a task that they feel will be unsafe. The Company commits to the following: Any situation arising which leads to an individual refusing to work for Health and Safety reasons must be reported to immediate management as soon as possible, and no work should be recommenced until the issue(s) causing concern have been addressed. Should immediate line management be unable to action the concerns, the matter must be cascaded to senior management as soon as is practicable. Bona fide cases of refusal to work on grounds of health and safety will be free from disciplinary action or discrimination. Review this policy after changes in legislation or Company structure, in the light of additional knowledge or information becoming available, and in any event annually.

9 BARRIER SERVICES LTD. DOCUMENTS: Health & Well Being We will take all reasonable measures to ensure that any employee, self-employed person and contractor under our control whose health and safety may be affected by our work activities are made aware of the contents of this Policy, the possible effects upon their personal health & safety, upon their colleagues health & safety and the possible consequences in the event of any breach of this Policy. It is recognised that people are a valuable commodity and resource whose health and well being is essential and invaluable to effective work performances. Its intention is to promote and assist the Company in fulfilling its legal and moral obligations by ensuring good health within the workforce and ensuring that work-related occupational health injuries are kept to a minimum and/or eradicated. The Company s commitment to this Policy statement will be achieved by: d). e). f). g). h). Embracing and utilising medical screening facilities promoted by our Clients who have such procedures in place through their own Occupational Health & Wellbeing Policies. Ensuring that prospective employees undergo medical examinations with their own GP to ensure and determine that they are fit to perform the duties required of them. The gathering of medical information including but not limited to prescribed drugs and medication to determine measures and/or controls that may have to be considered for their continued wellbeing. With the assistance of our Consultants and/or Clients it is intended to promote Behavioural Safety amongst our workforce. The provision, with just cause, to provide alcohol and drugs testing on site and in offices in line with the Company s Drug and Alcohol. Encouraging our workforce to take responsibility for their own wellbeing including for aspects of their health which is within their own control. Managers will be encouraged to take an interest in the wellbeing of employees working under their control. Review this policy after changes in legislation or Company structure, in the light of additional knowledge or information becoming available, and in any event annually

10 BARRIER SERVICES LTD. DOCUMENTS: Equal Opportunities We aim to be an inclusive organisation where everyone is treated with respect and dignity, and where there is equal opportunity for all. We respect and value the diversity of our employees, clients, stakeholders and members of the public. We understand and respect that there is a diverse work force community and that everyone has the right to be treated with dignity and equality. We recognise our legal obligations including those under The Equality Act 2010 and the Part-time Workers legislation. The aim of this policy is to encourage harmony and respect amongst individuals so as to promote good working practices with a view to maximising the performance. Equal Opportunities are taken very seriously. Wilful failure to apply the policies or evidence of discrimination, harassment, bullying or victimisation will result in disciplinary action, which may include dismissal. Harassment, and particularly sexual, racial or disability harassment, will be regarded as gross misconduct for disciplinary purposes and as such employees found guilty of the aforesaid will be dismissed. We will undertake, as far as is reasonably practicable, the following:- d). e). Ensure where individuals are considered for employment or promotion they are assessed solely on the basis of their merits and abilities. All employees will be treated with dignity and respect. We will endeavour to provide a working environment free from unlawful discrimination, harassment or victimisation on the grounds of sex, age, marital status, disability, sexual orientation, gender reassignment, race, colour, religion, ethnic or national origin. If an existing employee becomes disabled we recognise our legislative obligations and will take all reasonable measures to prevent, so far as is reasonably practicable, any breach of duty placed upon the Company by legislation and/or this Policy. Review this policy after changes in legislation or Company structure, in the light of additional knowledge or information becoming available, and in any event annually.

11 BARRIER SERVICES LTD. DOCUMENTS: Slavery and Human Trafficking Statement We have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our corporate activities and throughout our supply chains, even though this is beyond our disclosure obligations under the Modern Slavery Act We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. This statement sets out Barrier Services actions to understand all potential modern slavery risks related to business and to ensure steps are maintained to prevent slavery and human trafficking. Our Business Barrier Services is a fencing contractor with approximately 50 employees based out of one office in the UK. Our Supply Chain The relationship with all our suppliers has been established over a number of years and is built upon mutually beneficial factors, where we have close and personal links and contact with the directors, typically reflecting the fact that we partner with Small and medium sized operations in the main. As and when we have new contractors or suppliers come on-board we prequalify any new Company through assessment and then continual assess and review their performance. To date we haven t been made aware of any human trafficking/slavery activities within the supply chain but if any were highlighted to us then we would act immediately in accordance with our legal obligations. Our Policy on Slavery and Human Trafficking We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in out supply chains. Due diligence processes for slavery and human trafficking: As part of our initiative to identify and mitigate risk we have in place systems to: Identify and assess new suppliers and regularly review our existing supply chains. Mitigate the risk of slavery and human trafficking occurring in our supply chains. Monitor potential risk areas in our supply chains. Protect whistle blowers. Training We have zero tolerance to slavery and human trafficking. To maintain awareness of the risks of modern slavery and human trafficking in our business this statement is available on all notice boards and on will be posted on the Company s website. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

12 DOCUMENTS: Data Handling Statement BARRIER SERVICES LTD. Introduction Barrier Services Ltd needs to collect and use certain types of information about employees of Barrier Services Ltd in order to carry on our work. This personal information must be collected and dealt with appropriately whether is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the Data Protection Act Disclosure Barrier Services Ltd may share data with agencies such as the local authority, funding bodies and other voluntary agencies. The employee will be made aware in most circumstances how and with whom their information will be shared. There are circumstances where the law allows Barrier Services Ltd to disclose data (including sensitive data) without the data subject s consent. These are: Carrying out a legal duty Protecting vital interests of an employee The employee has already made the information public Conducting any legal proceedings, obtaining legal advice or defending any legal rights Monitoring for equal opportunities purposes i.e. race, disability or religion Providing a confidential service where the employees consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill employees to provide consent signatures. Barrier Services Ltd regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal. To this end, Barrier Services Ltd will adhere to the Principles of Data Protection, as detailed in the Data Protection Act Specifically, the Principles require that personal information: Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes Shall be adequate, relevant and not excessive in relation to those purpose(s) Shall be accurate and, where necessary, kept up to date Shall not be kept for longer than is necessary Shall be processed in accordance with the rights of data subjects under the Act Shall be kept secure taking appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of employees in relation to the processing of personal information. Barrier Services Ltd will, through appropriate management and strict application of criteria and controls:

13 DOCUMENTS: Data Handling Statement BARRIER SERVICES LTD. Observe fully conditions regarding the fair collection and use of information Meet its legal obligations to specify the purposes for which information is used Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements Ensure the quality of information used Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include: o The right to be informed that processing is being undertaken, o The right of access to one s personal information o o The right to prevent processing in certain circumstances and The right to correct, rectify, block or erase information which is regarded as wrong information) Take appropriate technical and organisational security measures to safeguard personal information Ensure that personal information is not transferred abroad without suitable safeguards Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information Set out clear procedures for responding to requests for information Data Collection Barrier Services Ltd will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form. When collecting data, Barrier Services Ltd will ensure that the employee: Clearly understands why the information is needed Understands what it will be used for and what the consequences are should the employee decide not to give consent to processing As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress Has received sufficient information on why their data is needed and how it will be used Data Storage Information and records relating to service users will be stored securely and will only be accessible to authorised staff. Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately. It is Barrier Services Ltd responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

14 DOCUMENTS: Data Handling Statement BARRIER SERVICES LTD. Data Access and Accuracy All employees have the right to access the information Barrier Services Ltd holds about them. Barrier Services Ltd will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes. In addition, Barrier Services Ltd will ensure that: Everyone processing personal information understands that they are contractually responsible for following good data protection practice It deals promptly and courteously with any enquiries about handling personal information All employees are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.