NI Cleaning Employee Handbook Version 1

An employee should make a request in writing to any of above Data Protection Officers, stating the exact data required. Employees are only entitled to access data about themselves and will not be provided with data relating to other employees or third parties. It may be possible to block out data relating to a third party or conceal his or her identity, and if this is possible the organisation may do so. Data that is classified as the opinion of another person will be provided unless it was given on the understanding that it will be treated confidentially. Employees who express opinions about other employees in the course of their employment should bear in mind that their opinion may be disclosed in an access request, e.g., performance appraisals. An employee who is dissatisfied with the outcome of an access request has the option of using the organisation’s grievance procedure. Mobile Phone Policy Mobile Phones are an important communications tool. As such they should be used in an efficient, lawful, safe and ethical manner. ABM staff will be held accountable for appropriate use of their company mobile phone and must abide by this Mobile Phone Policy. Subject to the written permission of management, the use of personal mobile phones is not permitted by employees during working hours. Mobile phones are not to be in an employee’s possession during their working shift, nor should personal calls be made/taken during a working shift. Mobile phones should be stored in the lockers provided or in a designated area advised by the Stores Manager. Group messages referring to employment within the Company are not to be created and are not permitted by the company unless prior approval is granted in writing by the Human Resource Department. 101

Weekly rosters should not be shared on Group messages which an employee has created on their personal mobile phone. Employees who refuse to adhere to the above will be subject to disciplinary action, up to and including dismissal. Employees are not permitted to use the Company’s or Customer’s telephones to make or receive personal calls in their working environment unless permission from the manager/ supervisor has been received. Employees must not use their personal phone during work hours unless in the event of an emergency. Provision of Mobile Phones ABM will provide a mobile phone/device for specific posts, where the use of a device is of significant benefit in assisting the user in discharging their duties. Usage • All users must abide by the terms in this Mobile Phone Policy. • ABM Mobile Phones are not to be used for individual “business” or private matters related to personal income generating activities. • From time to time a personal call may be made, while the user is on company business, this privilege should not be abused. As with the use of other company telephone lines, personal (i.e. non-business) calls should where necessary be of short duration. • All ABM phone accounts are monitored, and users shall be responsible for their use and provide an explanation of call charges if requested. • You must ensure that you have recorded an appropriate and relevant greeting on your mobile phone voice mail, with your name used in the greeting. • The use of messages which contains an emoji (e.g. Smiley Face symbol) is prohibited as not appropriate for business use 102

and furthermore converts a message from texts to MMS (Multi Media Messages) which adds over 200% to the transmission costs of a normal text message. Accountability • Mobile Phones access is provided for officially approved purposes only i.e. company business and limited personal use. • ABM Staff must comply with all policies, legislation and regulations applicable to the use of Mobile Phones. • Mobile Phones usage should be able to withstand public scrutiny and/ or disclosure. • ABM Staff should not use the Mobile Phones in a way that could defame, harass, abuse or offend individuals or organisations. • ABM reserves the right to audit any or all ABM funded Mobile Phone usage. Staff may be called upon to explain their use of ABM funded Mobile Phones. • Care must be taken of mobile phones to avoid damage or breakage, you will be provided with phone cover to protect your phone. Where a phone is damaged due to misuse the cost of repair/replacement will be at the cost of the User. • On leaving the company the company mobile phone must be returned by the user in good working order, failure to do will result in the full recovery of the replacement costs of the phone. Security of mobile phones • Staff issued with a mobile phone purchased by ABM must ensure the security of the phone (and any allied equipment) at all times. The following items should be noted: 103

• Should a mobile phone be lost or stolen, the user must report the matter to the line manager within 24 hours for notification to service providers and replacement. Alternatively, users can contact phone administrator within the office to report the theft in order to block the number and handset. • Users are required to keep mobile phones clean, and in serviceable condition to the best of their ability and report all irregularities immediately to your line manager. • There are a number of built in protection mechanisms that the user should apply in the day to day operation of the mobile phone: • Activate the keypad lock • A PIN code must be used to lock the phone so that if the phone is subsequently stolen or lost a PIN code must be used to unlock the phone. However, the PIN number should be given to the user’s line manager. • Secure the phone at home as if it is a personal possession. • Mobile phones must not be left in unattended vehicles. • While in the office, store the phone and associated equipment with due care. If lending the phone to other members of staff, make a record of when and whom. • Mobile phones must be kept charged at all times. • Where mobile phones are shared by staff the handing over of the phone between staff must be recorded so that in the event of loss or damage to the phone the responsible person can be easily identified. • Do not overcharge your mobile phone or leave your mobile phone whilst charging on or near paper of other flammable materials as an overcharged mobile phone can be a fire hazard. Procedure for Upgrade Upgrades can only be initiated through existing authorised users. Requests submitted to the Finance Director will generally be 104

upgraded in accordance with the provisions contract; currently upgrades are issued every two + years. All unused or replaced mobile phones must be surrendered to the Accounts Office. Courtesy • As a matter of professional courtesy, we advise mobile phone users to either turn off their phone or divert it to voicemail or another number, or set the phone into “silent mode” during meetings, training courses, seminars etc. In exceptional circumstances, where it becomes necessary to take a business call, it is courteous to inform colleagues that an urgent call is expected. • When conducting business away from ABM premises users should endeavour to comply with any local restrictions on the use mobile phones. • When in ABM offices remember the office is a working environment so please take into consideration your colleagues when on the phone. Travelling Abroad (Roaming) • The users or lines manager must contact the company phone administrator so that he/she can put the user on the correct plan before leaving the republic of Ireland. • The user must ensure that while travelling abroad they are on the correct tariff and mobile network. Where phones are taken abroad without permission for non-company business (EG Holidays) the company has the right to recover the Roaming costs from the employee. 105

Use of Mobile Phone whilst driving • It is illegal to use mobile phones whilst driving. When driving mobile phones must only be used in hands-free mode, if no hands-free kit is provided you must leave the phone unanswered until the car is stopped and parked in a safe place. • Where an employee is caught by Law Enforcement Agency’s using a mobile phone whilst driving, he/she is responsible for the payment of the fine imposed and will be subject to disciplinary action. Social Media & Internet • The company mobile phone must not be used to contact competition lines but if a competition line is inadvertently contacted then once you become aware of this you must immediately unsubscribe by to the competition line with a text “STOP”. All costs incurred on the competition lines will be charged to the user. • Mobile Phones with a camera must not be used inappropriately. In this respect Company Mobile Phone users must not take photographs or video recordings of the public, clients or employees without their consent. • Always adhere to the ABM Policy on Social Media when using your mobile phone in the workplace. • The internet may not be accessed for personal use during normal hours of employment. Occasional use for personal reasons is allowed outside working hours, however the restrictions set out in Browsing/downloading material (below) must be adhered to. Browsing/downloading/transmitting material 106

• Only material from a bona fide business, commercial or governmental websites should be browsed/downloaded. • Due to the uncensored nature of the material on the internet, there are a large number of websites which contain offensive, obscene and illegal material. Company mobile phones are not to be used to view, create, download, host or transmit such material as this could cause offence to others on the grounds of race, sexual orientation, gender, age, political beliefs or disability. • No other material should be browsed/downloaded. This specifically includes games, screensavers and music/video. • Inappropriate text messages or e mails or any other form of electronic communication are not to be transmitted on the company mobile phone. Failure to adhere to this Policy could result in disciplinary action, up to and including dismissal and all illegal activities will be reported to the relevant authorities. During normal working weeks your voice mail greeting should be recorded as follows; “You have reached the voice mail of [insert your full name] I am sorry that I cannot answer your call at present, but if you leave your name, telephone number and brief message after the tone I will call you back as soon as possible. Thank you.” If it is appropriate for you to change your message during annual leave, then you should use the following greeting: “This is [insert your full name] I am on annual leave until [insert date returning to work]. If you wish to leave your name, telephone number, and message I will call you back on my return, however if your call is urgent you can call [insert relevant number and contact name if appropriate] for immediate attention. Thank you.” 107

Policy for use of E-Mail & Internet While E-mail and the Internet bring many benefits to ABM in terms of its communications internally and externally, there are also risks to the organisation, particularly where employees use it outside of their ABM roles. For this reason it is necessary to have a code of practice which regulates usage and sets down specific rules for the use of e- mail and the Internet. Every employee has a responsibility to maintain the company’s image, to use these electronic resources in a productive manner and to avoid placing the company at risk of legal liability based on their use. ABM’ computing resources and those of their clients are to be used for business purposes only. They should not be used for private purposes, personal gain or entertainment. Procedures for e-mail use • It is your responsibility to safeguard your password, it must not to be given to any unauthorised personnel. • E-mails should be regarded as potentially public information, which carry a heightened risk of legal liability for the sender, the recipient and the organisations for which they work. Particular care should be taken when sending confidential or commercially sensitive information. • Great care should also be taken when attaching documents as the ease with which people can download files from the Internet or ‘cut and paste’ materials from electronic sources increases the risks of infringement of the rights of others particularly intellectual property and other proprietary rights. Also attaching documents may give rise to the release of 108

information not intended, hence the importance of vetting attachments. • Extra caution needs to be taken with e-mail messages in respect of any disparaging remarks that may be contained therein. An e-mail should be regarded as a written formal letter the recipients of which may be much wider than the sender intended hence any defamatory or careless remarks can have very serious consequences as can any indirect innuendo. Avoid the use of indecent, obscene, sexist, racist or other inappropriate remarks whether in written form, in cartoon form or otherwise. • If you receive any offensive, unpleasant, harassing or intimidating messages via e-mail you are requested to inform your Manager or the Human Resources Department immediately. • If you receive or suspect you have received a virus, you should contact Lantech immediately. Do not forward the email. ABM reserves the right to review, audit, intercept, access and disclose all messages created, received or sent over the electronic mail system for any purpose. Notwithstanding the company’s right to retrieve and read any e-mail messages, such messages should be treated as confidential by other employees and accessed only by the intended recipient. Employees are not authorised to retrieve or read any e-mail messages that are not sent to them. Any exception to this policy must receive prior approval from your Manager. When an employee is out office, he/she is required to leave the following automatic email reply: “Thank you for your email. I am currently on annual leave returning XXX. Should your query be urgent please contact XXX. Alternatively, I will respond to your email on my return.” 109

Internet Procedures • ABM Service’s Internet connections are intended for activities that support company business. Web surfing unrelated to these activities is strictly forbidden. Staff members who have abused this will be subject to disciplinary action. • General Internet access will only be provided to authorised personnel. Authorised personnel will have responsibility for Internet access on their password and hence will have responsibility for illicit use of that facility with or without their consent. Screensaver passwords are recommended to protect unauthorised access. • Internet usage will be monitored on a systematic basis by the company. • To prevent computer viruses from being transmitted through the system there will be no unauthorised downloading of any software. All software downloads must only be done with permission from Lantech, • The accessing, downloading or sending of any indecent, obscene, pornographic, sexist, racist, illegal or defamatory or other inappropriate materials as well as the circulation of such materials is a dismissible offence. This rule will be strictly enforced and is viewed as very serious with potential criminal liabilities arising there from. Non-adherence to these terms and conditions regarding e-mail and Internet use constitutes a violation of company policy and could result in the loss of computer privileges and disciplinary action, up to and including dismissal. Under no circumstances should any employee use a customer’s hardware or software without first receiving authorisation from the Operations Manager. Social Media Policy 110

This policy on social media must be read in conjunction with other employee policies. Particular attention is drawn to the dignity at work, equality, bullying and harassment, internet, e-mail usage, employee privacy policy statement and business confidentiality policies, all of which are applicable to social media usage. This policy on social media applies to all employees. Social media is the collective term referring to social and professional networking sites (for example; Facebook, LinkedIn, MySpace, TikTok), microblogs (such as Twitter), blogs, wikis, boards and other similar online fora and the policy extends to all such sites and incorporates any future developments of such media. Breaches of this policy will be investigated, and the organisation retains the right to take disciplinary action, up to and including dismissal. You are prohibited from participating in social networking websites while at work or using the organisation’s equipment and are not permitted to register with such sites; • Access any personal account you may have on such sites • Access other people’s accounts on such sites • Post comments on any social media sites regarding our organisation and that of our clients • Use the organisation’s name, logos, images or comment on the organisation’s customers, clients or business. ABM recognises that employees use social media tools as part of their daily lives. Employees should always be mindful of what they are posting, who can see it, and how it can be linked back to the organisation, colleagues and clients. All employees should be aware that the organisation regularly monitors the internet and social media in reference to its work and to keep 111

abreast of general internet commentary, brand presence and industry/customer perceptions. The organisation does not specifically monitor social media sites for employee content on an ongoing basis; however, employees should not expect privacy in this regard. The organisation reserves the right to utilise for disciplinary purposes any information that could have a negative effect on the organisation / customers or its employees, which management comes across in regular internet monitoring, or is brought to the organisation’s attention by employees, customers, members of the public, etc. All employees are prohibited from using or publishing information on any social media sites during their personal time, where such use has the potential to negatively affect the organisation/client sites or its staff. Examples of such behaviour include, but are not limited to: • Publishing material that is defamatory, abusive or offensive in relation to any employee, manager, office holder, shareholder, customer or client of the organisation • Publishing any confidential or business-sensitive information about the organisation • Publishing material that might reasonably be expected to have the effect of damaging the reputation or professional standing of the organisation • Posting comments about our clients and or our client sites which is defamatory, abusive or offensive in nature Procedures regarding usage All employees must adhere to the following when engaging in social media. • Be aware of your association with ABM when using online social networks. You must always identify yourself and your role if you mention or comment on the organisation. Where you 112

identify yourself as an employee, ensure your profile and related content is consistent with how you would present yourself with colleagues and clients. You must write in the first person and state clearly that the views expressed are your own and not those of the organisation. Wherever practical, you must use a disclaimer saying that while you work for the organisation, anything you publish is your personal opinion, and not necessarily the opinions of the organisation. • You are personally responsible for what you post or publish on social media sites. Where it is found that any information breaches any policy, such as breaching confidentiality or bringing the organisation into disrepute, you may face disciplinary action, up to and including dismissal. • Be aware of general data protection regulations – you must not post colleagues’ details or pictures without their permission. Photographs of company events should not be posted online. Employees must not provide or use their company password in response to any internet request for a password. • Material in which the organisation has a proprietary interest – such as software, products, documentation or other internal information – must not be transmitted, sold or otherwise divulged, unless the organisation has already released the information into the public domain. Any departure from this policy requires the prior written authorisation of your senior manager. • Be respectful at all times, in both the content and tone of what you say. Show respect to your audience, colleagues, our customers and suppliers. Do not post or publish any comments or content relating to the organisation or its employees, which would be seen as unacceptable in the workplace or in conflict with the organisation’s website. Make sure it is clear that the views and opinions you express are your own. • Recommendations, references or comments relating to professional attributes, are not permitted to be made about employees, former employees, customers or suppliers on 113

social media and networking sites. Such recommendations can give the impression that the recommendation is a reference on behalf of ABM, even when a disclaimer is placed on such a comment. Any request for such a recommendation should be dealt with by stating that this is not permitted in line with organisation policy and that a formal reference can be sought through HR, in line with the normal reference policy. • Once in the public domain, content cannot be retracted. Therefore, always take time to review your content in an objective manner before uploading. If in doubt, ask someone to review it for you. Think through the consequences of what you say and what could happen if one of your colleagues had to defend your comments to a customer. • If you make a mistake, be the first to point it out and correct it quickly. You may factually point out misrepresentations, but do not create an argument. • It is very important that employees immediately report any inappropriate activity or behaviour regarding ABM, its employees or third parties. Inform your supervisor or another member of management or your HR representative. All allegations made in good faith will be fully and confidentially investigated. You are required to cooperate with all investigations of alleged policy violations. • This policy extends to future developments in internet capability and social media usage. In addition to the above rules, there are a number of key guiding principles that employees should note when using social media tools: • Always remember on-line content is never completely private; • Regularly review your privacy settings on social media platforms to ensure they provide you with sufficient personal protection and limit access by others; 114

• Consider all online information with caution as there is no quality control process on the internet and a considerable amount of information may be inaccurate or misleading; • At all times respect copyright and intellectual property rights of information you encounter on the internet. This may require obtaining appropriate permission to make use of information. You must always give proper credit to the source of the information used. Specific managerial responsibilities By virtue of your position, managers have particular obligations with respect to general content posted on social media. Managers should consider whether or not personal thoughts they publish may be misunderstood as expressing ABM’s opinions or positions even where disclaimers are used. Managers should err on the side of caution and should assume that their teams will read what is written. A public online forum is not the place to communicate organisation policies, strategies or opinions to employees. Managers should not make ‘friend’ requests or other similar requests of their team members, as this may place undue pressure on an employee. Enforcement Non-compliance with the general principles and conditions of this social media policy and the related internet, e-mail and confidentiality policies may lead to disciplinary action, up to and including dismissal. This policy is not exhaustive. In situations that are not expressly governed by this policy, you must ensure that your use of social media and the internet is at all times appropriate and consistent with your responsibilities towards the organisation. In case of any doubt, you should consult with your manager. 115

Monitoring of internet usage by ABM applies to personal use as well as normal business use. Media Policy This media policy establishes guidelines for ABM or communications by the company. It covers the release of information about the Company to the general public, media, customers, authorities, investors, financial community and other stakeholders. Compliance with this policy is important for both business reasons and to meet the Company’s legal and regulatory obligations. This policy on dealing with the media has been created to protect employees and the ABM Group. Media and Press includes, but is not limited to: • Newspapers (local & national) • Magazines and Publications • TV and Radio Stations • Online News services • Journalists and Bloggers ABM has designated the Human Resource Director to be the principal media contact and company spokesperson. In the absence of the Human Resource Director, the Sales Director will be the media contact and company spokesperson. The Human Resource Director has expertise in media relations and will handle each media inquiry. Media enquires can be regarding both positive and negatives stories in relation to ABM. Regardless of the nature of the query they must still be directed to the Human Resource Director. They will convey the official ABM position on issues of significance or situations that are particularly sensitive in nature. The main responsibilities for the HR Director when dealing with the media are: 116

• Act as the first point of contact for media enquiries • Research and feedback responses in consultations with appropriate members of staff • Produce press releases as and when required • Encourage employees to communication potential or actual media coverage when appropriate • Brief employees who are allowed to speak to the media For further information on this policy please contact the HR department. Statements to the Media You shall not be permitted to discuss with the press or other media, issues concerning the Company and its activities unless you are appointed as an authorised spokesperson for the Company or you have been given specific permission to comment on any such matter. 117

Whistleblowing Policy We are committed to the highest standards of openness, integrity and accountability and an important aspect of these standards are to ensure transparency as a mechanism to enable our team members and other persons on our team to be able to voice and highlight concerns in a responsible and effective manner. It is a condition of employment, that an employee will not disclose confidential information about the company. Nevertheless, where an employee / individual discovers information which they reasonably believe shows either malpractice or wrongdoing within the Company, then this information should be disclosed without fear of reprisal. It should be emphasised that this policy is intended to assist individuals who believe they have relevant information relating to malpractice or impropriety. This policy is not designed to question financial or business decisions taken by the organisation nor should it be used to reconsider any matters, which have already been addressed under through our grievance or disciplinary procedures. With our whistleblowing procedures outlined in this policy, we would encourage our employees to use this process rather than disclose the information outside the company. Internal Reporting Channel: ABM Compliance Hotline The internal channel has been designed in a GDPR Compliant manner which ensures the confidentiality of the reporting person and any other person(s) named in the report. The ABM Compliance Hotline is a web and phone-based complaints reporting system available to team members of the company, as well as a secure database the company uses to process and store data relating to team member complaints. When a complaint is submitted 118

via Compliance Hotline reporting system, the details of the complaint will be processed and stored in the system. This also includes some personal data. When a complaint is submitted outside the ABM Compliance Hotline reporting system, in accordance with this policy, the manager dealing with the complaint will usually enter details of the complaint into the system. Again, this includes some personal data. Storing the details of each complaint centrally is important because it can help the company deal with grievances effectively. It also means that the company can monitor the frequency of certain types of complaint and the effectiveness of its processes. Before entering any personal data into the ABM Compliance Hotline system. If the team member consents, they should confirm this in writing and the relevant data should then be entered into the system. If the team member does not consent, then the data should not be entered into the ABM Compliance Hotline system. However, copies of certain documents and information relating to the concern may still be attached to the team member’s personnel file in accordance with this policy. Report a Compliance or Ethics Complaint To report incidents of possible fraud, theft, or misconduct, as well as discriminatory, harassing, or retaliatory conduct, in the workplace, please use one of the following options. 1. Call the ABM Compliance Hotline 1800-903-224 Ireland and 0800-069-8801 UK. The Hotline is staffed 24 hours a day, 7 days a week. Specialists are available to take calls in over 100 languages. 2. Report Online: abmhotlineeurope.ethicspoint.com. Reports are taken by an unbiased vendor and are forwarded in a secure and confidential manner to an appropriate Human Resources professional for prompt investigation. 119

3. Report to your local Human Resources representative or director. What is Whistleblowing? Whistleblowing is the disclosure of information which relates to suspected wrongdoing, potential dangers or Health and Safety concerns which could jeopardise the company and / or its employees within the workplace. These could include but not limited to the following: • A criminal offence. • Fraud. • Failure to comply with a legal obligation or regulatory requirement. • Any miscarriage of justice. • Danger to health and safety. • Environmental damage. • Bribery. • Deliberate attempts to conceal any information about the above. Should a team member have any genuine concerns related to suspected wrongdoing or potential danger(s) affecting any Company activities (a whistleblowing concern) they should report it as soon as possible under this policy. Team members who raise legitimate concerns about specified matters are protected by law. Should a team member be unsure that their concern is a whistleblowing matter, they should raise the concern with their Line Manager/HR Department at [email protected]. Once an alleged whistleblowing concern has been raised, an appropriate manager will investigate the concerns promptly and in accordance with this policy. Please note we do not require the individual to carry out an investigation themselves. Employees are also not expected to provide any proof of their alleged concern; however, they must have a reasonable belief that there are grounds for same. 120

It should be noted that appropriate disciplinary action may be taken against any employee who is found to have raised a concern or raised a disclosure with malicious intent. It is important to note that in situations where an employee makes a disclosure not in compliance with the Act, the protections under the Act will not be available to the employee. Whistleblowing Procedure Raising a Concern In the first instance any concerns should be raised with the team member's Line Manager. Should the concern be in relation to your Line Manager, please contact your Director. Depending on the nature of the concern, the line manager may refer the matter to another manager for investigation. If for any reason the team member does not wish to approach their line manager, the team member should approach a different manager, a senior manager, a Director of the Company, or their HR representative. Alternatively, the team member can also use the ABM Compliance Hotline web and phone-based reporting system (contact details in here). Team members are encouraged to summarise their whistleblowing concern in writing and provide as much factual detail as possible. Investigation The team member and any other individual(s) allegedly involved will be required to provide written statements of their concern(s). The manager will aim to keep the team member informed of the progress of any investigation and its likely timescale. Any investigation will be carried out in accordance with the procedures set out above. The investigating manager will compile an investigation report and forward to a senior manager who will review and take any necessary action. This may include reporting the concern to an external regulatory body such as An Garda Síochana / Police or addressing the concern 121

in accordance with the company’s Disciplinary Procedures which carries sanctions up to and including dismissal. Media & Publicity As per our Media Policy, any statements to reporters from newspapers, radio, television, etc. will only be provided by the Managing Director or their nominated representative. Team members are not permitted to publish or promote their whistleblowing concerns online, for example on social media or on blogs. The reason for same is that these actions may interfere with the Company conducting a fair investigation into the whistleblowing concerns and may affect the rights of the accused team member. If a team member acts maliciously or dishonestly in publishing their concerns, it may be deemed an act of misconduct which may be dealt with in accordance with our Disciplinary Policy. Timescales Due to the varied nature of a whistleblowing concern, which may involve internal investigators and/or the Garda Síochana / Police, it is not possible to outline precise timescales for completion of such investigations. The investigating manager will, as soon as reasonably possible, send a written acknowledgement of the concern to the complainant. The investigating manager will ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations. Anti-Bribery Policy It is our policy to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. 122

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non- employee who breaches this policy may have their contract terminated with immediate effect. Who must comply with this policy? This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. What is bribery? Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit. Bribery includes offering, promising, giving, accepting or seeking a bribe. All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager. Specifically, you must not: • Give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received; • Accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; or • Give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure. 123

• You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption. Gifts and hospitality This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services. A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process). Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers) or be given in secret. Gifts must be given in our name, not your name. Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners. Record-keeping You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept \"off-book\" to facilitate or conceal improper payments. 124

How to raise a concern If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible. Quality Policy It is the policy of ABM, to satisfy the needs of its customers by providing quality services. To maintain these quality requirements, we will operate a quality system under the requirements of ISO 9001:2015. ABM Quality Statement is implemented through the operation of a Quality Management System. The requirements of this system are mandatory for all company personnel and no unauthorised alterations or deviations are permitted. Improved effectiveness of the Quality System is our key objective. We are committed to the achievement of high quality and to the concept of continual improvement. Our employees shall receive the necessary education and training to enable them to understand, implement and maintain the company quality statement. Each employee, in whatever capacity, has the responsibility to perform his/her duties to the highest standards in accordance with the systems and procedures in the Quality Manual and its reference documents. Health & Safety Policy The policy of ABM in respect of safety and health is to conduct its affairs so as to ensure, so far as is reasonably practicable, the safety, health and welfare of employees and others who may be affected by its works and activities. 125

To this end the ABM is determined to take every step necessary to discharge the duties laid down by the Safety Health and Welfare at Work Act 2005, and other all-relevant legislation and under common law. The main objective of ABM is to achieve legal compliance and compliance with other relevant standards, as a minimum level or criterion. ABM has developed a Health and Safety Management System in accordance with the requirements of ISO 45001:2018. This system is used to manage and to continually improve our health and safety effort. Our core health and safety objective is to provide a safe and healthy place of work that is accident free. It shall be the duty of all employees to take reasonable care for the safety, health and welfare of themselves and other persons who may be affected by their acts or omissions and will co-operate with Supervisors and Management to achieve a safe and healthy workplace. ABM is committed to the provision of such information and training as may be necessary to enable all employees to carry out their duties competently and without risk to the health and safety of themselves or others and will be in a form and language that all employees are likely to understand. This policy cannot be achieved solely by management. ABM is committed to a process of full consultation in this matter and the views of management, supervisors, and all staff will be taken into account. The Safety Statement will be made available to all employees and to other interested parties upon request. The Safety Statement and Health and Safety Management System will be reviewed annually and revised as necessary to meet changing circumstances. The Safety Statement and Health and Safety Management System will be brought to the attention of employees annually. 126

Health and Safety Instructions The Safety, Health and Welfare at Work Act 2005 requires that the employer shall ensure, so far as is reasonably practicable, the safety, health and welfare at work of his or her employees. Employers are obliged by law to provide: • Safe place of work • Safe plant and equipment • Safe systems of work • Information and training • Provision of suitable Personal Protective Equipment (PPE) • Adequate emergency plans • Safe articles and substances • Adequate welfare facilities • Competent Persons The 2005 act also places a number of responsibilities on the employee, these include: • Take reasonable care of one self and colleagues. • Co-operate with employer on health and safety matters • Report defects • Use PPE and any other safety devices provided • Do not recklessly interfere with or misuse machinery and/or PPE Many situations exist in buildings, which are serviced by ABM, which could be dangerous to you if the Safety Instructions are not obeyed. Everything possible will be done to ensure that the workplace is free from risk. To safeguard employees and minimize the risk of accidents, any possible hazard should be reported to your Supervisor/Manager or the HR manager. All company safety instructions must be strictly observed. Breach of safety rules will result in disciplinary action. 127

Health and Safety at Work The company places great importance on employee’s health and safety. Please contact your immediate site manager/account manager if you have any queries regarding Health and Safety. Your manager will pass on your concerns to the Health and Safety Committee. The full safety statement is available on request from your Line manager. Safe Lifting - adopt safe lifting practices at all times: Before lifting an object, it is important to assess the task, the load and the area. If the load is too heavy, get help or use a mechanical aid. Never carry more than you can manage. • Stand with legs slightly apart. • Keep your back straight, bend from knees and use legs to take strain. • Ensure you have a firm grip of the load. • Keep arms in line with your trunk and hold the load as close to your centre of gravity as possible. • Avoid turning your body when lifting; turn your feet in the direction of movement instead. • Allow your body time to recover after physical effort. Fire Safety Make sure you understand the correct procedures on your work site, in case of fire. You must ask your Supervisor/Manager for instructions if you are in doubt. 128

Basic Rules Instructions to be followed in the case of emergencies are generally displayed in all buildings. Read these instructions carefully and memorize them and get to know where fire arms and extinguishers are situated. Your Supervisor/Manager will assist you to obtain this information. In case of fire, operate the nearest fire alarm, or if there is no fire alarm, telephone 999 or 112 from a safe location and ask for emergency services. Give them the address for your work site and a brief explanation of what has happened. If you have been trained to operate fire extinguishers and you can do so without risk to yourself or others, use the extinguisher on the fire. Do not use a water (red label) extinguisher on an electrical fire Fire Evacuation Procedure • One of your duties is to know where all emergency exits and fire equipment is located. • In the event of fire contact security or the switchboard (in larger sites, as appropriate) or the emergency services - stating your location. • Upon hearing the fire alarm, calmly evacuate the building immediately. • Before leaving the building, if safe to do so, ensure that your equipment will not obstruct access or egress to the premises for others or firefighting personnel. • Do not use the lifts. • Evacuate through the nearest emergency exit. • When outside proceed to the Assembly Point. • Do not attempt to move cars or bicycles from the parking area. • At the assembly point, report to the Fire Warden responsible for completing the roll call. 129

• Employees hosting visitors or contractors should ensure that these people have left the building. • Once safely outside, re-entry is strictly forbidden until the instruction is given that it is safe to return to the building. • Remain at the assembly point until instruction is given. • Re-entry to the building must only be through the front door. Electrical Equipment Follow your supervisor’s training instructions and the guidelines for standard work practice on your contract, every time you use one of the company’s machines. Basic Procedures • Always check equipment and cables before commencing work for defects: if there are any apparent defects visible, DO NOT operate the machine • Never attempt to repair a machine which has refused to function or breaks down in use. Report it to your Supervisor/Manager immediately. • Do not allow cables to knot or kink when in use, position the cable as close to skirting boards/edges of the work area as possible. • Do not over-reach the scope of the power cable. • Never touch a switch, power point or electrical appliance with wet hands. • Keep equipment clean to permit easy spotting of damage or faults. • Always unplug a machine which is unattended. • If you need to wet scrub with a machine, request rubber boots and check that the extension cables are fitted with watertight connectors and the sealing rings are fitted properly. 130

General • Always conform to site regulations, i.e. if you are working in a stores area, where there are forklift trucks, the regulators may call for protective footwear and safety helmets. Your supervisor/manager will advise you of these instructions. • Instructions will be given in the handling and use of corrosive cleaning materials, which you may be required to use. • Never leave your cleaning equipment where it could be a danger to others. • Report any incidence or occurrence, which you think may constitute an accident risk to your Supervisor/Manager. • The Company does not expect you to work under dangerous circumstances at any time. If you are in doubt ask your Supervisor/Manager. Accidents / Incidents at Work If you see an accident occur do whatever you may think sensible to prevent further injury to the casualty. If a machine is involved, go to the wall socket and if safe to do so, pull out the plug. Get help immediately. If you think an accident is serious, call emergency services at 112 or 999. If you work on a site where there is security staff on duty, use the site telephone facility to summon their assistance. Accidents are the result of people’s carelessness or negligence. If you go about your job with the contents of the work instructions detailed in this booklet in mind, you will reduce the risk of an accident to both yourself and others. All accidents must be reported to your Supervisor/Manager immediately. A fully completed Accident Report Form must be 131

submitted to the Accident Investigator no later than 24 hours after the incident. Time Management System If you are required to clock in/out, you must ensure that you clock in on arrival at and clock out on departure from the premises. If you have permission to leave the premises during normal working hours, you should ensure that you get clock out. In the event of failing to clock in/out, you must report to your Line Manager and advise them of the exact time of arrival or departure, together with the reason for failing to clock in/out. It will be the Company's responsibility to make the appropriate entry on the clock card. You must never complete entries on clock cards for yourself without express authority from your line Manager and obtaining an authorisation signature at the time. If you falsify your clock card, complete entries on your own clock card without express authority, clock in/out for another employee or allow another employee to clock out for you, you will be subject to disciplinary up to and including dismissal. Environment Policy ABM are an outsourcing company providing business solutions to its clients and as such, recognise that good management includes environmental matters and will ensure environmental protection and the prevention of pollution as part of our business decisions. We will Endeavor to work towards the following objectives: • To ensure that environmental impacts are minimised and controlled; • To ensure compliance with all applicable environmental legislation, regulation and industry codes of practice and other 132

requirements to which the Company subscribes which relate to our environmental aspects; • We will provide for the publication of the environmental policy internally by posting the document on the Company notice boards. This policy will be available externally to all interested parties, (on request). • We will provide for the setting and achievement of environmental objectives and targets for the company; and for the publication of those objectives and targets by posting the document in the company; • We will maintain continuous efforts to achieve continual improvement in environmental performance of our policies, programmes and operations taking into account technical developments, scientific understanding, customer and community expectations. Our starting point is to comply fully with the requirements of ISO14001: 2015. • We will develop services that have minimal environmental impact and are safe in their intended use. Our considerations will include spillage prevention, waste management, natural resource consumption, and the introduction of energy efficiency practices. • We will conduct and support assessment of the environmental impacts of new services before starting a new activity or project. • We will work with suppliers and contractors to minimise the impact of their operations on the environment. • We will foster openness and dialogue with employees and all interested parties, anticipating and responding to their concerns about potential hazards and impacts of operations, products, wastes and services. We will measure environmental performance by conducting regular environmental audits and assessments of compliance with this policy statement, legal and Company requirements. 133

Smoke-Free Workplace Policy Under the terms of Section 47 of the Public Health (Tobacco) Acts, it is the policy of ABM to ensure that all of its workplaces are smoke-free and that all employees have a right to work in a smoke-free environment. Smoking is prohibited throughout the entire workplace, including vehicles, with no exceptions. This policy applies to all employees, consultants, contractors, customers and visitors. Policy Infringements Infringements of this policy will be dealt with through the disciplinary procedure. Employees, consultants, contractors, customers and visitors who contravene legislation prohibiting smoking in the workplace are also liable to a criminal prosecution with an associated fine. Procedure If a person smokes in the workplace: 1. Draw the person’s attention to the “No Smoking” signs and advise them that they are committing an offence by smoking on the premises. 2. Advise the person that it is also an offence for the occupier, manager and any other person for the time being in charge of the premises to permit anyone to smoke in contravention of the law. 3. Advise the person that the business has a smoke-free policy to ensure a safe working environment for staff and customers. 4. Report any non-conformance with this policy to management. 134

Anti-slavery and Human Trafficking ABM Group has a zero-tolerance approach to Slavery and Human Trafficking and is committed to preventing acts of slavery and human trafficking from occurring within both its business and supply chain. Our position on human rights within ABM is evident through our Mission Statement “We do business ethically by keeping our promises to our customers, our staff and our suppliers”. We respect the rights of all our employees and those within our supply chain. The ABM Modern Slavery and Human Trafficking Policy is in place for all stakeholders in the company including: Employees, Customers, Suppliers and any Sub-Contractors acting on our behalf. ABM encourages all employees, clients and suppliers to report any activity they feel is unlawful conduct or have concerns about the risk of Modern Slavery. Please see our Whistleblowing Policy for further details regarding the process for reporting suspect activity. ABM are dedicated to the prevention of Modern Slavery and Human Trafficking within our business and throughout our supply chain. We shall: • ABM will ensure the recruitment policy is compliant with the Modern Slavery & Human Trafficking legislation. The Human Resource Department will be responsible for screening & vetting of new hirers. They will also be responsible for monitoring and auditing right to work visas. • Employees will receive a copy of the Employee Handbook which will include our Modern Slavery and Human Trafficking Statement. • Internal training courses and employee tool box talks will be provided to all employees in order to raise awareness of Modern Slavery and Human Trafficking. These training courses and employee toolbox talks will aim to fully 135

educate and prepare managers, supervisors and human resources officers to identify the signs of Modern Slavery and Human Trafficking and how to handle an incident should one occur. ABM will review this policy as an annual basis, it may be revoked, replaced or changed at any time to adhere with legislative amendments. Areas of Risk The key areas that could be affected by Slavery and Human Trafficking are; employees hired by the company, employees working on our sites through subcontractors and employees hired by our suppliers. Employee Wellbeing Policy Introduction: ABM has developed an employee wellbeing policy to manage its obligations to maintain the mental health and wellbeing of all staff. It covers the organisation's commitment to employee health, the responsibilities of managers and others for maintaining psychological health, health promotion initiatives, communicating and training on health issues, the range of support available for the maintenance of mental health, and organisational commitment to handling individual issues. Objectives: The aim of this policy is to describe the organisation's commitment to the mental health and wellbeing of employees in its broadest, holistic sense, setting out how ABM fulfils its legal obligations, the responsibilities of different functions and specialists and the range of services available to help employees maintain health and wellbeing. ABM recognises that wellbeing and performance are linked. Improving 136

employees' ability to handle pressure and to balance work and home life will ultimately lead to improved individual and organisational performance. Organisational Commitment: ABM has legal obligations under health and safety legislation to manage risks to the health and safety of employees. This means operating the business in a way that minimises harm to employees' mental health, by ensuring that the demands of jobs are not unacceptable and having policies and procedures in place to support individuals experiencing ill health at work. ABM will put in place measures to prevent and manage risks to employee wellbeing, together with appropriate training and individual support. It will also seek to foster a mentally healthy culture by incorporating these principles into line manager training and running regular initiatives to raise awareness of mental health issues at work. Responsibilities: Organisation ABM has a legal duty of care to employees to ensure health at work, as set out in the Safety, Health and Welfare at Work Act 2005. ABM will ensure that its policies and practices reflect this duty and review the operation of these documents at regular intervals. Line Managers Line managers will put in place measures to minimise the risks to employee wellbeing, particularly from negative pressure at work. Managers must familiarise themselves with the Health and Safety training & standards and use these to mitigate psychological risks in their teams. For example, managers should ensure that employees understand their role within the team and receive the necessary 137

information and support from managers and team members to do their job. Managers must also familiarise themselves with the organisation's policies on diversity and tackling inappropriate behaviour in order to support staff, for example on bullying and harassment issues. In particular, line managers must ensure that they take steps to reduce the risks to employee health and wellbeing by: • Ensuring that the right people are recruited to the right jobs and that a good match is obtained between individuals recruited and job descriptions/specifications. • Keeping employees in the team up to date with developments at work and how these might affect their job and workload. • Ensuring that employees know who to approach with problems concerning their role and how to pursue issues with senior management. • Making sure jobs are designed fairly and that work is allocated appropriately between teams. • Ensuring that work stations are regularly assessed to ensure that they are appropriate and fit for purpose. Human Resources The Human Resources (HR) Department will develop organisation- wide policies and procedures to protect the wellbeing of employees, assist line managers in supporting individuals, and liaise as appropriate with the Company Doctor, if required, and other medical professionals, with the object of helping employees to maintain good psychological health. Occupational Health Specialist Occupational health professionals will provide a comprehensive service designed to help employees stay in work, or to return to work, after experiencing health problems. This will include preparing medical 138

assessments of individuals' fitness for work following referrals from line managers and approval from the HR Department, liaising with GPs and working with individuals to help them to retain employment. Employees Employees must take responsibility for managing their own health and wellbeing, by adopting good health behaviours (for example in relation to diet, alcohol consumption and smoking) and informing ABM if they believe work or the work environment poses a risk to their health. Any health-related information disclosed by an employee during discussions with managers, the HR Department or the Company Doctor is treated in confidence. Health Promotion Initiatives: ABM will develop and run a range of health promotion initiatives designed to raise awareness of health and lifestyle issues affecting mental health and wellbeing. The HR Department will have primary responsibility for leading these programmes, but line managers and employees will be expected to participate. Employees will also be encouraged to establish clubs and groups designed to foster wellbeing, for example lunchtime walking. Training and Communications: Line managers and employees will regularly discuss individual training needs to ensure that employees have the necessary skills to adapt to ever-changing job demands. An examination of training needs will be particularly important prior to, and during, periods of organisational change. Managers and employees are encouraged to participate in communication/feedback exercises. All employees are expected to be aware of the importance of effective communication and to use the 139

media most appropriate to the message, for example team meetings, one-to-one meetings, electronic communications and organisation- wide methods. ABM will ensure that structures exist to give employees regular feedback on their performance, and for them to raise concerns. ABM will consider special communication media during periods of organisational change. If employees believe that their work, or some aspect of it, is putting their wellbeing at risk they should, in the first instance, speak to their line manager or the HR Department. The discussion should cover workload and other aspects of job demands, and raise issues such as identified training needs. A referral to the Company doctor may be made if this is considered appropriate after an employee's initial discussion with their manager or the HR Department. Discussions between employees and the company doctor are confidential, although they are likely to provide a report on the employee's fitness to work, and any recommended adaptations to the working environment, to the HR Department. Other measures available to support employees in maintaining health and wellbeing include; • An Employee Assistance programme. • A Mental Health first-aid programme. • Procedures for reporting and handling inappropriate behaviour (for example bullying and harassment). • Special leave arrangements. • Opportunities for flexible working. • Support for workers with disabilities. • ABM’s Grievance Policy. 140

Employee Assistance Programme A free and confidential, 24-hour helpline (1800 936 071) from Health Assured to support you through any of life’s issues or problems. The service offers; • Up to 6 sessions of face to face, telephone or online counselling • Full case management protocols for all structured counselling cases • Unlimited access to 24/7/365 confidential telephone helpline • Coverage for dependants and retirees (up to three months) The topics they provide support on are; • Financial • Home life • Work life • Health & lifestyle More information can be obtained from your manager and the HR Department. The Employee Assistance programme also has a Mobile phone App called My Healthy Advantage. Simply download the App and enter our company code MHA112890. The My Healthy Advantage App offers access to holistic health and wellbeing support at the tap of a finger anywhere and anytime,. Some of the features you can access are: • Support videos and webinars • Mood tracker • Four-week programmes • Home life support and advice • Work life assistance 141

• Physical and emotional health • Mini health checks • Life Support • Medical information The app is available for you to download now free of charge, and you can register using the code ‘MHA112890’. Please download and enjoy the benefits. Flexible Working Policy This flexible working policy gives eligible employees an opportunity to request a change to their working pattern. We will deal with flexible working requests in a reasonable manner and within a reasonable time. In any event the time between making a request and notifying you of a final decision (including the outcome of any appeal) will be less than three months unless we have agreed a longer period with you. This policy does not form part of your contract of employment and we may amend it at any time. Eligibility To be eligible to make a flexible working request, you must: (a) Be an employee; (b) Have worked for us continuously for at least 26 weeks at the date your request is made; and (c) Not have made a flexible working request during the last 12 months (even if you withdrew that request). 142

What Is A Flexible Working Request? A flexible working request under this policy means a request to do any or all of the following: (a) To reduce or vary your working hours; (b) To reduce or vary the days you work; (c) To work from a different location (for example, from home). Making A Flexible Working Request Your flexible working request should be submitted in writing and dated. It should: (a) State that it is a flexible working request; (b) Explain the change being requested and propose a start date; (c) Identify the impact the change would have on the business and how that might be dealt with; and (d) State whether you have made any previous flexible working requests. We will arrange a meeting at a convenient time and place to discuss your request. You may be accompanied at the meeting by a colleague of your choice. They will be entitled to speak and confer privately with you but cannot answer questions on your behalf. We may decide to grant your request in full without a meeting, in which case we will write to you with our decision. Decision We will inform you in writing of our decision as soon as possible after the meeting. If your request is accepted, we will write to you with details of the new working arrangements and the date on which they will 143

commence. You will be asked to sign and return a copy of the letter. If we cannot immediately accept your request, we may require you to undertake a trial period before reaching a final decision on your request. Unless otherwise agreed, any changes to your terms of employment will be permanent. We may reject your request for one or more of the following business reasons: (a) The burden of additional costs. (b) Detrimental effect on ability to meet customer demand. (c) Inability to reorganise work among existing staff. (d) Inability to recruit additional staff. (e) Detrimental impact on quality. (f) Detrimental impact on performance. (g) Insufficiency of work during the periods that you propose to work; or (h) Planned changes. If we are unable to agree to your request, we will write to tell you which of those reasons applies in your case. We will also set out the appeal procedure. Appeal You may appeal in writing within 14 days of receiving our written decision. This includes a decision following a trial period. Your appeal must be dated and must set out the grounds on which you are appealing. We will hold a meeting with you to discuss your appeal. You may bring a colleague to the meeting. We will tell you in writing of our final decision as soon as possible after the appeal meeting, including reasons. There is no further right of appeal. 144

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