ROI Security Employee Handbook Version 1 new

Consideration will be given to reasonable adjustments or alternative employment which could facilitate your return to work. However, employees should be aware that long term absence could lead to the termination of their employment if they are certified medically unfit to return to work. AWOL Process Absent without official leave (AWOL) is when an employee fails to turn up for work without notifying/making contact with their employer to advise of their absence. ABM adhere to a fair process when managing an employee who is deemed absent without leave. Should the employee fail to make contact with the company within the first 3 days of absence, the employee will be contacted in writing advising them: 1. That they are in breach of the company’s Absence Policy and 2. Requesting them to make contact with the company within 3 – 5 days to advise on the reasons for their unauthorised absence. Should the employee fail to make contact with the company after the first attempt, the employee will be contacted for a second time in writing advising them; 3. They are being provided with a final opportunity to make contact with the company. 4. That they are in breach of the company’s Absence Policy and 5. To make contact with the company within 3 – 5 days to advise on the reasons for their unauthorised absence or the company will be left with no alternative only to believe that the employee wishes to terminate their contract of employment with the company. Should the employee fail to make contact with the company after the second attempt made in writing, the HR Department will be notified by 51

the employees’ manager. The HR department will then issue the employee a termination notification in writing, and they will be processed as a leaver from the date of the final AWOL correspondence attempt. The employee will also be provided with an opportunity to appeal any termination within a given timeframe. Absence Review Meetings Procedure The Company will apply this procedure whenever we consider it necessary, including, for example, if you: • Have been absent due to illness on 3 or more occasions within a rolling 6 month period; • Have discussed matters at a return to work interview that require investigation; and/or • Absence for a period of 4 weeks or more Unless it is impractical to do so, the Company will give you 2 working days’ notice of the date, time and place of an absence review meeting. Concerns about your absence and the basis for those concerns will be put to you in writing and a reasonable opportunity for you to consider this information will be provided before the meeting. The meeting will be conducted by your line manager. You may bring a colleague or trade union representative with you to the meeting as support. You must take all reasonable steps to attend the meeting, failure to do so without good reason may be treated as misconduct. If you or your representative are unable to attend at the time specified, you should immediately inform your line manager who will seek to agree an alternative time. To ignore or fail to acknowledge the meeting request, will not be tolerated by the Company. 52

A meeting may be adjourned if your line manager is awaiting receipt of information, needs to gather further information or consider the matters discussed at the meeting. You will be given a reasonable opportunity to consider any new information obtained before the meeting is reconvened. Confirmation of any decision made at a meeting, the reasons for it, and of the right of appeal will be given to you in writing within five working days of a sickness absence meeting (unless this time scale is not practicable, in which case it will be provided as soon as is practicable). If, at any time, your Manager considers that you have taken or are taking sickness absence when you are not unwell, they may refer matters to be dealt with under the Company’s Disciplinary and Dismissal Procedure. Right to be accompanied at meetings You may bring a representative to any meeting or appeal meeting under this procedure. Your representative may be either a trade union representative or a work colleague. Their identity must be confirmed to the person conducting the meeting, in good time before it takes place. Some companions may not be allowed: for example, anyone who may have a conflict of interest, or whose presence may prejudice a meeting. Companions should not work at another site, exceptions will be made when no-one reasonably suitable is available at the site at which you work. The Company may at its discretion, permit a representative who is not an employee or union representative where this will help overcome particular difficulties caused by a disability, or difficulty understanding English. Please seek permission from your manager to allow attendance at the meeting. 53

Employees are allowed reasonable time off from duties without loss of pay to act as a representative. However, they are not obliged to act as a representative and may decline a request if they so wish. A representative may make representations, ask questions, and sum up your position, however, will not be allowed to answer questions on your behalf. You may confer privately with your representative at any time during a meeting. Stage 1: First Absence Review Meeting The purposes of a first absence review meeting may include: • Discussing the reasons for absence; • Where you are on long-term sickness absence, determining how long the absence is likely to last; • Where you have been absent on a number of occasions, determining the likelihood of further absences; • Considering whether medical advice is required; • Considering what, if any, measures might improve your health and/or attendance; • Agreeing a way forward, action that will be taken and a time- scale for review and/or a further meeting under the sickness absence procedure. Stage 2: Further Absence Review Meeting(s) Depending on the matters discussed at Stage 1 of the absence review meeting, further meetings may be necessary. The purposes of further meeting(s) may include: • Discussing the reasons for and impact of your ongoing absence(s); 54

• Where you are on long-term sickness absence, discussing how long your absence is likely to last; • Where you have been absent on a number of occasions, discussing the likelihood of further absences; • If it has not been obtained, considering whether medical advice is required. If it has been obtained, considering the advice that has been given and whether further advice is required; • Considering your ability to return to/remain in your job in view both of your capabilities and the business needs and any adjustments that can reasonably be made to your job to enable you to do so; • Considering possible redeployment opportunities and whether any adjustments can reasonably be made to assist in redeploying you; • Where you are able to return from long-term sick leave, whether to your job or a redeployed job, agreeing a return to work programme; • Agreeing a way forward, actions that will be taken and a time- scale for review and/or a further meeting(s). This may, depending on steps we have already taken, include warning you that you are at risk of disciplinary action, up to and including dismissal. Stage 3: Final Absence Review Meeting Where you have been warned you are at risk of dismissal or action short thereof, the Company may invite you to a meeting under the third stage of the absence review procedure. The purposes of the meeting will be: • Review the meetings that have taken place and matters discussed with you; 55

• Where you remain on long-term sickness absence, to consider whether there have been any changes since the last meeting under stage two of the procedure, either with regards to your possible return to work, opportunities for return or redeployment; • Consider any further matters that you wish to raise; • Consider whether there is a reasonable likelihood of you returning to work or achieving the desired level of attendance in a reasonable time; • Consider the possible termination of your employment. No decision will be made that could affect your employment without careful consideration of all the circumstances. Where the Company wishes to send you to the company doctor, and you refuse to attend without reasonable grounds, the Company will take a decision regarding your continuing employment without the benefit of medical opinion. Termination will normally be with full notice or payment in lieu of notice. Use of Company Property during any absence Should you be in receipt of a fuel card or mobile phone, these are provided for legitimate business purposes only; where possible and depending on the length of the absence these can be retained and will be reviewed during the absence. If a company vehicle or mobile phone is allocated to a site, it may be necessary to return these for business continuity purposes. 56

Appeals You may appeal against the outcome of any stage of this procedure and you may bring a representative, be that a work colleague or union representative, to an appeal meeting. An appeal should be made in writing, to the person named in the letter, stating the full grounds of appeal, within 5 working days of the date on which the decision was sent to you. Unless it is not practicable, you will be given written notice of an appeal meeting within one week of the meeting. In cases of dismissal the appeal will be held as soon as possible. Any new matters raised in an appeal may delay an appeal meeting if further investigation is required. You will be provided with written details of any new information which comes to light before an appeal meeting. You will also be given a reasonable opportunity to consider this information before the meeting. Where practicable, an appeal meeting will be conducted by a Manager or senior person to the individual who conducted the absence review meeting. Depending on the grounds of appeal, an appeal meeting may be a complete rehearing of the matter or a review of the original decision. Following an appeal, the original decision may be confirmed, revoked or replaced with a different decision. The final decision will be confirmed in writing within 5 working days of the appeal meeting. Depending on the complexity of the case an extension may be required to ensure a thorough review of the appeal is conducted. Where an extension is required this will be notified to the appellant. 57

Once the appeal process concludes there will be no further right of appeal. The date that any dismissal takes effect will not be delayed pending the outcome of an appeal. However, if the appeal is successful, the decision to dismiss will be revoked with no loss of service continuity or pay. Disciplinary Policy Shortcomings relating to conduct, attendance and performance will be brought to an employee’s attention as and when they arise. Continuous poor standards of conduct, attendance and performance will be dealt with through the disciplinary procedure. The procedure has been designed to provide a formal process to assist and encourage employees to achieve and maintain required standards of conduct, attendance and job performance. Records of warnings will be kept on employee’s files. Company Commitment The company commits to ensuring the rules of natural justice are applied in all disciplinary matters. • At every stage in the procedure the employee will be advised of the nature of the complaint against him/her and will be given the opportunity to respond and state his/her case before any decision is made. • The employee concerned is given the opportunity to respond fully to any such allegations or complaints. • No employee will be dismissed for a first breach of discipline except in cases of gross misconduct, in such cases the penalty may be dismissal without notice or payment in lieu of notice. 58

• An employee will have the right to be accompanied or represented by a work colleague or union representative during any aspect of the investigation and disciplinary process. • Whilst the disciplinary procedure is usually progressive in nature the Company reserves the right to bypass any stage of the procedure where a decision is made that the nature of the misconduct warrants such action. • The employee concerned has the right to a fair and impartial determination of the issues concerned, taking into account any representations made by, or on behalf of, the employee and any other relevant or appropriate evidence, factors, circumstances. • The employee has the right to appeal any aspect of the disciplinary procedure. Informal Discussion Record In the first instance shortcomings relating to performance, absence and conduct will be brought to an employee’s attention by their line manager, or his/her nominee. Measures for improvement will be advised to the employee by the manager. Employees will be given a minimum of 24 hours’ notice prior to an informal discussion record taking place. Where the employee does not improve identified shortcomings a line manager will progress to the informal process. This process will result in the line manager carrying out a discussion record, this will result in a template being completed that will be signed off by the manager and employee. Written discussion records must be retained on file for a period of 6 months. 59

In circumstances of repeated shortcomings / misconduct (maximum of two informal discussions in a period of 6 months) will result in the initiation of the formal disciplinary process. Formal Process Where the employee does not improve shortcomings addressed during the informal discussion a line manager will progress to the formal process. Employees will be given a minimum of 48 hours’ notice of a scheduled disciplinary hearing. The employee reserves the right to be accompanied and/or represented at the hearing by either a work colleague or registered union representative. The purpose of a disciplinary hearing is to discuss performance and/or attendance shortcomings formally. The hearing provides an opportunity to the manager to complete a fact gathering exercise. The employee will be provided with all documentation which will be relied upon during the hearing and provided with an opportunity to respond to same. The disciplinary hearing will be adjourned to allow the manager time to consider all information presented at the hearing and for a decision to be made. The meeting will be reconvened, and the employee informed of the disciplinary outcome. Whilst the disciplinary procedure is usually progressive in nature the Company reserves the right to bypass any stage of the procedure where a decision is made that the nature of the misconduct warrants such action. 60

Investigation concerning Gross Misconduct Disciplinary investigations must be conducted by an independent investigator for the purposes of fact finding in all circumstances of alleged gross misconduct, which may result in dismissal or action short thereof. The disciplinary investigation process is as follows: 1. The employee will be informed of the complaint / allegation against them in writing with all supporting documentation that will be referred to throughout the process. 2. The employee will be invited to a formal investigation meeting and will be entitled to accompanied by either a work colleague or union representative at the meeting. 3. A written record will be made of the meeting by a company note taker. 4. All witnesses will be invited to formal meetings relating to disciplinary investigations. A written record will be made of witness meetings by a company note taker. 5. A disciplinary investigation outcome report will be prepared by the investigator. A copy of the report, to include all documentation used to reach the outcome, will be provided to the employee in question and to the appropriate manager. 6. In circumstances where an investigation upholds the complaint / allegation the employee may be invited in writing to a disciplinary hearing. The hearing will be facilitated by an independent manager who has had no prior involvement in the case. Suspension An employee may be suspended with or without pay pending a formal investigation and conclusion of any subsequent disciplinary process. 61

The fact of any suspension will be confirmed in writing and any payment will be based on basic pay only. Suspension with pay may occur where an employee is suspended pending an investigation of misconduct which appears to have been committed by you. Examples of Gross Misconduct The following acts are examples of Gross Misconduct offences and as such will render you liable to Summary Dismissal (i.e. Dismissal without notice and without previous warnings). This list is not exhaustive. • Fighting, physical assault or dangerous horseplay. • Deliberate refusal or wilful failure to carry out a reasonable and lawful direct instruction given by management during working hours. • Serious insubordination. • Serious cases of bullying, offensive, aggressive, threatening or intimidating behaviour or excessive bad language. • Theft or misappropriation of property belonging to the Company, clients, other employees or the general public. • Wilful damage or negligence involving damage to property belonging to the Company, clients, other employees or the general public. • Performing, arranging or carrying out any work or activity which could be considered to be in competition with, or which adversely affects in any way, the Company's interests. • Fraud or any other illegal offence committed against the Company. • Drinking alcohol during working hours, being under the influence of alcohol/drugs and/or drug abuse. 62

• Providing false or misleading information within your role and responsibilities • Being in possession of or dealing illegal drugs whilst at work. • Breach of safety rules and/or any action which seriously endangers the health or safety of an employee or any other person whilst at work. • Deliberately making a false entry in the written records of the Company. • Knowingly giving false information or deliberately omitting relevant information on a job application form or curriculum vitae. • Unlawful discrimination including harassment. • Receipt of bribes to affect the placing of business with a supplier of goods or services. • Inaccurate or fraudulent recording of financial transactions. • Unauthorised access to or disclosure of any confidential information from whatever source including any personal data under Data Protection legislation. • Falsification of working hours. • Criminal offence causing harm to the reputation of the Company or relations with the Company's employees. • Unauthorised access to or disclosure of any part of the Company's computer data. • Acts of gross negligence or misconduct involving careless or reckless driving, including the use of hand-held mobile phones whilst driving. • Loss of driving licence on conviction when driving is all or an essential part of the job requirements. • Indecent or lewd behaviour of a serious nature. • Smoking in designated non-smoking areas. • Serious misuse of the Company's e-mail\\internet or other computing resources. • The act of copying computer software without authorisation. • The use of unauthorised software on Company PCs. 63

• The unauthorised disabling of antivirus software. • Use of pirate software on Company PCs. Disciplinary Stages Stage 1 - Verbal Warning Given to advise the employee of the specific aspect of work performance or conduct which is below standard together with the improvement required and stating that this is the first step in the formal disciplinary procedure. A verbal warning will be live on the employees file for a period of 6 months. Failure to make the required improvement may result in progression to Stage 2 of the procedure. Stage 2 – Written Warning Issued for a more serious offence or where there is insufficient improvement resulting from the verbal warning. Details of the specific aspect of the employee’s work or conduct, which is below standard, and the improvement required. A written warning will be live on the employees file for a period of 9 months. Failure to make the required improvement may result in progression to Stage 3 of the procedure. Stage 3 – Final Written Warning Issued where circumstances warrant it or where there is still a failure to improve and conduct or performance is still unsatisfactory. Gives details of the particular aspect of the employee’s work or conduct 64

which is below standard and the improvement required. A final written warning will be live on the employees file for a period of 12 months. Failure to make the required improvement may result in progression to Stage 4 of the procedure. Stage 4 – Dismissal A further failure to improve after a final written warning will lead to dismissal. A member of Senior management will arrange a meeting with the employee and inform him/her of the situation and the reasons for the dismissal. A decision to dismiss will be taken, only after thorough investigation of all relevant facts. Summary Dismissal Certain offences such as gross misconduct or any serious or wilful breach of contract will be regarded as so serious as to justify summary dismissal (without notice or payment in lieu of notice) Appeal If an employee is dissatisfied with the outcome of the disciplinary procedure or any aspect of the proceeding an appeal may be made in writing within 5 working days to the appointed Manager as stated in the disciplinary outcome correspondence. The appointed Manager will be a more senior manager and will not have had any prior involvement in the disciplinary procedure. The employee will be given the opportunity to state his/her case and may be accompanied to the meeting. 65

Grievance Procedure At times employees may wish to raise a grievance relating to their employment. In this respect, ABM’s policy is to encourage free communication between employees and managers to ensure that questions and problems arising during the course of employment can be aired and, where possible resolved quickly and to the satisfaction of all concerned. A grievance must always be raised in the first instance with your immediate manager. If a satisfactory solution is not reached, you may raise this with the HR Department. The objectives of this policy are: • To treat the employee fairly, consistently and provide a positive working environment. • To ensure the employee has the opportunity to discuss any issues they may have about their employment. • To develop an open, friendly and harmonious atmosphere and to assist good working relationships. • To assist and maintain open communications, prevent misunderstandings and resolve grievances. • To facilitate speedy and effective resolutions. • To ensure fair procedures and natural justice. • To promote confidence and a satisfactory outcome. Informal Grievance Procedure ABM wants to give all employees every opportunity to express their potential dissatisfaction and have this dealt with by the Company in a fair and consistent manner, without them feeling that their position is jeopardised in any way. Most issues or misunderstandings that arise can be dealt with informally, through discussion with their Manager. 66

Every effort should be made to resolve the difficulty in this way. However, if it is not possible to resolve the grievance near to its point of origin, there is a more formal process in place, where it can be taken by way of appeal to a higher level within the Company. Mediation Where an informal grievance process has not worked for an employee, mediation may be offered to the employee as a possible path to resolution. Mediation is simply an informal problem-solving conversation facilitated by a third person who is impartial and independent to the grievance. It is a voluntary, consensus-based method of dispute resolution that uses facilitated communication, problem-solving, collaborative negotiation, exploration of options, compromise and impasse resolution. Mediation is about hearing the story or grievance, developing options and reaching agreement. It is a confidential process which is owned by the parties involved in the grievance where details of the process are not disclosed to the organisation but remain within the mediation process. Formal Grievance Process Where an employee has a grievance arising from employment, he or she should initially raise the matter in writing with their manager. The manager will invite the employee to attend a formal hearing to discuss the grievance. After due consideration, the manager will give a decision in writing and offer the right of appeal. If the matter is not resolved, or if the grievance relates to the employee's manager, the employee may raise the matter with the HR Department, who will obtain the manager’s record of the grievance, 67

record any additional information and hear the grievance. A decision will be given in writing. If the matter is still not resolved, and the employee still remains dissatisfied, he or she may raise the grievance in writing with the Director. A decision will be given in writing, if possible, within 7 days of the appeal hearing. This decision will be final. Appeals against disciplinary action and dismissal are not heard under the grievance procedure as these can be dealt with through the company's separate disciplinary appeals procedure. The grievance procedure may, however, be used if either the disciplinary action taken potentially constitutes unlawful discrimination or the employee believes that the real grounds for the disciplinary action are different from the grounds on which the employer claimed to be taking the action. If a disciplinary appeal is pending, however, the complaint can be dealt with at the disciplinary appeal. Appeals Process Each employee has the right within the grievance process to appeal, each time to a more senior person within the business. Where appeals are being heard, all supporting documentation from previous meetings must be submitted with the written appeal. Appeal documents and letters should be presented to the Human Resources Department for allocation to a more senior manager than who previously heard the grievance. At all times the decision of the final hearing manager of the appeal will be deemed to be final. 68

Further Procedures Applicable • The decision of the Director is considered final. • If at any stage of the process, the employee feels that the issue cannot be discussed with their manager they may ask the HR Department for advice. • In all meetings, natural justice will be observed, and every effort made to resolve the grievance. • All grievances must be made in writing and clearly outline the reasons/grounds for appeal. • The person hearing the grievance at each stage will clarify the same, meet with anyone who has been involved in the situation described by the employee and investigate it thoroughly. • A decision will be reached only once all the facts have been taken in to account and considered. It will be based only on the facts. • The right to representation applies to all meetings. • There must be no unreasonable delay of the procedures. • Locations and times of meetings must be reasonable for both parties. • Both parties must be allowed to voice their side at the meetings. • Appeals require a more senior manager (than heard at the initial meeting). Abuse of Policy Any abuse in the application of this policy will be dealt with in accordance with the Company’s Disciplinary Policy and Procedure and may result in disciplinary action being taken, up to and including dismissal if proven to have occurred. 69

Dignity at Work Policy It is the policy of the Company to create and maintain a good working environment which is free from harassment/sexual harassment and bullying is a condition of work to which every employee is entitled. Harassment/sexual harassment and bullying affect the dignity of people at work and will not be tolerated under any circumstances by the Company. Harassment is any unwanted verbal or physical attention involving duress, bullying and any unreasonable pressure. Workplace Bullying is repeated inappropriate behaviour, direct or indirect, whether verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment, which could reasonably be regarded as undermining the individual’s right to dignity at work. Examples include: • Manipulation of the victim’s reputation by rumour, gossip and ridicule; • Preventing the victim from speaking by making loud voiced criticisms or obscenities; • Social exclusion or isolation; • Manipulating the nature of the work or the ability of the victim to perform the work, i.e., by overloading, withholding information or setting meaningless tasks; • Physical abuse or threats of abuse; Sexual harassment is any unwanted verbal or physical advances, sexually derogatory statements or sexually discriminatory remarks made by someone in the workplace which are offensive or 70

objectionable to the recipient or which cause the recipient discomfort, humiliation or which interferes with their job performance. Examples include: • Unwelcome sexual advances • Unwelcome pressure for social contact • Unwelcome sexual comments and jokes • Unwelcome physical conduct such as pinching • Unnecessary touches, fondling, kissing, sexual assault or rape • Display of distasteful or pornographic material Complaints Procedure There is both an informal and formal procedure to deal with the issue of bullying/harassment at work. Any investigation should be completed as quickly as possible. Informal Procedure It is often preferable for all concerned that complaints of bullying or harassment are dealt with informally whenever possible. This is likely to produce solutions which are speedy, effective and minimise embarrassment and the risk of breaching confidentiality. Thus, in the first instance a person who believes that he/she is the subject of bullying/harassment should ask the person responsible to stop the offensive behaviour. If a person finds it difficult to approach the alleged perpetrator directly then they should seek help and advice on a confidential basis from a supervisor/manager. 71

Having consulted with this person, the complainant may request their assistance in raising the issue with the alleged perpetrator(s). In this situation the approach of the contact person should be by way of a confidential, non-confrontational discussion with a view to resolving the issue in an informal low-key manner. A complainant may decide, for whatever reason, to bypass the informal procedure. Choosing not to use the informal procedure will not reflect negatively on a complainant in the formal procedure. Mediation Mediation is the preferred method under the Dignity at Work Policy for resolving complaints of bullying and harassment. The objective of mediation is to resolve the matter speedily and confidentially without recourse to a formal investigation and with the minimum of conflict and stress for the individuals involved. Mediation requires the voluntary participation and co-operation of both parties in order to work effectively. Both parties will be requested to consider the use of mediation and every effort will be made to secure their agreement. An assigned mediator will meet with both parties, usually separately to begin with, to discuss the alleged offending behaviour. The mediator will then bring both parties together to reach a common understanding and agreement on acceptable future behaviour. A mediated agreement seeks to reach an accommodation between the parties and thereby restore harmonious working relations. A mediated solution will not result in the issues being dealt with under the disciplinary policy. If the mediation process does not produce a satisfactory outcome, the complainant may seek to have the matter resolved through formal investigation. If the matter remains unresolved at this stage, a formal investigation will be carried out. Note: Mediation may be attempted at 72

any/all points in the procedure to try to resolve the matter. Mediation may be attempted again during the formal investigation or following the outcome of the investigation. Formal Procedure Any employee who feels he/she has been or is being subjected to persistent harassment/sexual harassment/bullying should report the matter using the grievance procedure and report the matter to their Line manager or to the Human Resources Department. Complaints will be promptly investigated in the strictest confidence with sensitivity and with due respect for the rights of both the complainant and the alleged harasser. All involved are guaranteed a fair and impartial hearing. The complainant must be prepared to put details of the complaint in writing, if requested to do so. The complainant will be kept informed of progress during the investigation. The facts of the allegation will be checked as discreetly as possible. Staff will be protected against intimidation, victimisation or discrimination resulting from their alleging sexual harassment/harassment/bullying or assisting with the investigation. Strict confidentiality and proper discretion will be maintained at all times. If a complaint is substantiated, the case will be regarded as grounds for disciplinary action, up to and including dismissal. Respectful Workplace At ABM, we all have the right to work in an environment that is free from harassment and is respectful, with professional working relationships being commonplace. 73

Inappropriate and disruptive behaviours compromise the integrity of the employment relationship and undermines an employee’s self- respect and productivity. Inappropriate and disruptive behaviours is behaviour that interferes with the functioning and flow of the workplace. It hinders or prevents employees from carrying out their professional responsibilities, examples include; yelling, use of profanity, refusing reasonable requests, etc. Inappropriate and disruptive behaviours in the workplace can create an uncomfortable, hostile or intimidating work environment, leaving individuals and the company open to accusations of harassment and discrimination. All employees have the responsibility to be mindful of their tone of voice and avoid the use of foul and / or disrespectful language at all times in their dealings with others. Based on the principles of reasonableness, respect and professionalism, all employees are expected to conduct themselves professionally, whilst considering the behaviours of others. Every employee is responsible for contributing to an environment that encourages all employees to reach their full potential, therefore increasing business effectiveness and providing everyone with a positive, engaging and supporting work environment. Maintaining a respectful, professional and harassment free workplace is everyone’s responsibility. Termination of Employment Resignation If you intend to leave the Company, unless you have a contract that states otherwise, you are required to give a minimum of 1 weeks’ notice, as per the terms of the Minimum Notice and Terms of Employment Acts, 1973-2001 which must be confirmed in writing. 74

The Company reserves the right to make the appropriate payments in lieu of notice and may require the employee not to work the notice period. On termination of your employment with the Company, you will immediately return all property of the Company or relating to the business of Company that is in the possession or under your control. This includes, where requested, uniforms (in good condition and washed), ID badges, training materials, books, documents, papers, and equipment. You may not retain copies of any documents. If the Company gives you notice of the termination of your employment, you agree to return all Company property as soon as reasonably practical. Mobile phones and laptops are company owned assets and may not be retained by the employee when leaving the business. All mobile phones, laptops and accessories must be returned to your manager by your last day of employment with the Company. It is important to note that Intellectual Property Rights apply. Retirement Policy The normal age of retirement set with ABM is 66 years. An employee will be given 6 months written notice before they reach their retirement date from Head Office and a copy of the written notice will be given to the employee’s Account / Site Manager. The retirement date will not be before the exact date of the employees 66th birthday. The employee has the right to submit a written request to continue working beyond the retirement date. The request to continue to work beyond retirement age can be submitted to your Account / Site Manager at least 3 months before your retirement date is due. 75

On submission of a valid request to continue working beyond the retirement a meeting will then be scheduled to discuss the request, the employee if they wish can be accompanied by a representative of their choice. At this meeting consideration will be considered regarding the employee’s request. Response 1: If the request to continue working is refused, ABM are under no obligation to specify the reason for refusal but you do however have the right to appeal the decision to your Operations Director. Response 2: If your request to continue working is granted you will be placed on a fixed term contract period of 1 year. You will be given 6 months notification of the retirement procedure again prior to the end of the fixed term contract. ABM will monitor the age profile of its staff and the policy will be reviewed when the statutory default retirement age will be reviewed by the Government. Child Protection Policy Children trust and depend on adults to protect and safeguard them from harm. In support of the Children First Act (2017), it is the responsibility of ABM employees who come into contact with children or young persons on a daily basis to prevent and minimise the potential for harm and to report any suspicions of abuse to a young person whether it is outside or within a project or activity. ABM is committed to practice which protects children and young people from harm. All managers and staff of ABM accept and recognise their responsibilities in this area. 76

This policy applies to all permanent and temporary ABM employees. In addition, this policy applies to any person involved with work for, or on behalf of, ABM in any setting including volunteers, students, agency works and contractors. ABM are not expected to ultimately determine if an incident or allegation constitutes ‘child abuse’, that is the role of other agencies, including the Police or Garda, Statutory agencies and the Court Services. ABM employees are expected to provide these agencies with information necessary to assist in this determination and the protection of children. Employee Privacy Policy Statement The ABM Group is a data controller for each employee’s personal data and referred to as the “organisation” throughout this policy, as relevant. The organisation collects and processes personal data relating to its employees to manage the employment relationship. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. This Privacy Policy statement applies to the organisation’s current and former workers and contractors and relates to the types of information which could be used to identify them. The organisation collects and processes a range of information about you. This includes: • Your name, address and contact details, including email address and telephone number, date of birth and gender; • The terms and conditions of your employment; 77

• Details of your qualifications, skills, experience and employment history, including start and end dates with previous employers and with the organisation; • Information about your remuneration, including entitlement to benefits; • Details of your bank account and PPS/NI number; • Information about your marital status, next of kin, dependants and emergency contacts; • Information about your nationality and entitlement to work in Ireland/UK; • Information about your criminal record; • Details of your schedule (days of work and working hours) and attendance at work; • Details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave; • Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence; • Assessments of your performance, including appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence; • Information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments; • Details of trade union membership; • Equal opportunities monitoring information; and • Driving licence, GPS vehicle tracker and functionality information. The organisation collects this information in a variety of ways, for example, data is collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during 78

employment; from correspondence with you; or through interviews, meetings and/or other assessments. In some cases, the organisation collects personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks permitted by law. The organisation may also receive personal data about you from your previous employer or its client due to service provision change or employment transfer legislation. Data is stored in a range of different places, including in your personnel file, in the organisation's HR management systems and in other IT systems (including the organisation's email system). Why does the organisation process personal data? The organisation needs to process data to enter into an employment contract with you and to meet its obligations under your employment contract. For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer benefit, pension and insurance entitlements. In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee's entitlement to work in Ireland/UK, to deduct tax, to comply with health and safety laws, to enable employees to take periods of leave to which they are entitled, and to consult with employee representatives if redundancies are proposed or a business transfer is to take place. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question. We may use such personal data relating to criminal convictions when the law allows us to do so (such as: where necessary to carry out our obligations; in relation to legal 79

claims; to protect your or someone else’s interests; or in the course of our legitimate business activities with the appropriate safeguards). We will collect such information during the recruitment process or during your employment. In other cases, the organisation has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows the organisation to carry out any of the following activities in its legitimate interests: • Maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights; • Operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace; • Operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes; • Operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled; • Obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled; • Operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the organisation complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled; 80

• Ensure effective general HR and business administration; • Conduct employee engagement surveys; • Provide references on request for current or former employees; • Respond to and defend against legal claims; • Maintain and promote equality in the workplace. Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes). Information about trade union membership is processed to allow the organisation to operate check-off for union subscriptions. Who has access to data? Your information will be shared internally, including with members of the HR and recruitment team (including payroll), your line manager, managers in the business area in which you work and external IT staff if access to the data is necessary for performance of their roles. Your data may also be shared with employee representatives in the context of collective consultation on a redundancy or business sale. This would be limited to the information needed for the purposes of consultation, such as your name, role and length of service. The organisation will only share your data with third parties for the purpose of administering your employment for example; pre- employment references, annual penalty points statements, employment background checks from third-party providers and obtain necessary criminal records checks from the relevant services. The organisation may also share your data with third parties in the context of a sale of some or all of its business or as required due to service 81

provision change or employment transfer legislation. In those circumstances the data will be subject to confidentiality arrangements. The organisation also shares your data with third parties that process data on its behalf, in connection with payroll, the provision of benefits and the provision of occupational health services. The organisation will not transfer your data to countries outside the European Economic Area. How does the organisation protect data? The organisation takes the security of your data seriously. The organisation has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Where the organisation engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data. For how long does the organisation keep data? The organisation will hold your personal data for the duration of your employment. The periods for which your data is held after the end of employment are set out in a Retention Document. Your rights As a data subject, you have a number of rights. You can: • Access and obtain a copy of your data on request; • Require the organisation to change incorrect or incomplete data; 82

• Require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; • Object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and • Ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data. What if you do not provide personal data? You have some obligations under your employment contract to provide the organisation with essential data so that we can accurately administer your employment. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide the organisation with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights. Certain information, such as contact details, your right to work in Ireland/UK and payment details, have to be provided to enable the organisation to enter a contract of employment with you. If you do not provide other information, this will hinder the organisation's ability to administer the rights and obligations arising as a result of the employment relationship efficiently. 83

Automated decision-making Employment decisions are not based solely on automated decision- making. Medical data The organisation may carry out pre-employment medicals as part of the recruitment process. This data will be retained by the organisation. Occasionally, it may be necessary to refer employees to the organisation’s doctor for a medical opinion and all employees are required by their contract of employment to attend in this case. The organisation may receive certain medical information, which will be stored in a secure manner with the utmost regard for the confidentiality of the document. The organisation does not retain medical reports on job applicants who do not become employees for longer than is necessary. Employees are entitled to request access to their medical reports. Should an employee wish to do so, please contact the HR Department, which will consult with the doctor who examined you and request the data. The final decision lies with the doctor. Employees are required to submit sick certificates in accordance with the sick pay policy. These will be stored by the organisation, having the utmost regard for their confidentiality. E-mail monitoring The organisation provides e-mail facilities and access to the internet. In order to protect against the dangers associated with e-mail and internet use, screening software is in place to monitor e-mail and web usage. Mailboxes are only opened: 84

• Upon specific authorisation by a manager in cases where the screening software or a complaint indicates that a particular mailbox may contain material that is dangerous or offensive; • Where there is a legitimate work reason or in the legitimate interest of the organisation. Please refer to the e-mail and internet usage policies for further details. Closed circuit monitoring (where relevant) The organisation permits use of closed-circuit television cameras located at different areas in different client sites. Such a system will typically be intended for the security of staff and visitors to the site, to capture images of intruders or of individuals damaging property or removing goods without authorisation. Access to the recorded material will be strictly limited to authorised personnel. We have closed circuit television cameras in our Head Office and Regional offices. Closed circuit surveillance is used to manage performance. Access requests Employees are entitled to request data held about them on computer or in relevant filing sets. The organisation will provide this data within 40 days. There is no charge for requesting this data. 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. 85

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. 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 86

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 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. 87

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: • • 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 88

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 upgraded in accordance with the provisions contract; currently 89

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. 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 90

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 • 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, 91

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.” 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 92

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 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 93

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.” 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. 94

• 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 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. 95

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 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. 96

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 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 97

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 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 98

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; • 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. 99

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. Monitoring of internet usage by ABM applies to personal use as well as normal business use. 100