Gerry Cuffe Financial Services Limited Employee Handbook Ver 3 Jan 2022

APPENDICES APPENDIX 1: DIGNITY AT WORK CHATER This Charter, to which GCFS is committed and on display in our workplace, is reproduced below and incorporated into this document as part of our bullying and harassment prevention policy. \"GCFS is committed to working together to maintain a workplace environment that encourages and supports the right to dignity at work. All who work here are expected to respect each individual's right to dignity in their working life. All will be treated equally and respected for their individuality and diversity. Bullying and harassment in any form are not accepted by us and will not be tolerated. Our policies and procedures will underpin the principles and objectives of this Charter. Whether directly employed or contracted by us, all individuals have a duty and a responsibility to uphold this Dignity at Work Charter. Managers, Supervisors and Employee Representatives where applicable in the workplace have a specific responsibility to promote its provisions.” 150 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

APPENDIX 2: EXAMPLES OF BULLYING/INAPPROPRIATE BEHAVIOUR/HARASSMENT Many forms of behaviour can constitute Bullying/Inappropriate Behaviour/Harassment; examples include but are not limited to the following: Physical: • Unwanted physical contact. • Assault. • Interference with personal property or work area; and/or • Shoving jostling. Verbal: • Insults and name-calling. • Shouting and aggressive behaviour. • Using a person as a constant butt of jokes. • Derogatory or offensive nicknames. • Sneering or public humiliation. • Slandering or maligning a colleague or contractor by manipulating their reputation by gossip, rumour, and ridicule. • Persistent unwarranted criticism. • Inappropriately finding fault with a person’s work and using this as an excuse to humiliate them instead of trying to improve performance. • Limiting or preventing communication; and/or • Use of obscene language. Non-Verbal: • Social exclusion, isolation, or non-co-operation at work. • Unreasonable scrutiny or surveillance. • Deliberate withholding of recognition for work done well. • Deliberately blocking another colleague’s development. • Showing hostility through sustained unfriendly contact or exclusion. • Unfair delegation of duties. • Reducing a job to routine tasks well below the person’s skills and capabilities without prior discussion or explanation. • Offensive gestures; and/or • Staring or aggressive facial expressions. 151 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

APPENDIX 3: EXAMPLES OF BEHAVIOURS, WHICH COULD CONSTITUTE SEXUAL HARASSMENT Many forms of behaviour can constitute sexual harassment; examples include but are not limited to the following: Physical conduct of a sexual nature: • Unwanted physical contact. • Unnecessary touching, patting, pinching, or brushing against any category as outlined under SCOPE; and/or • Sexual assault. Verbal conduct of a sexual nature: • Unwelcome sexual advances, propositions, or pressure for sexual activity. • Continued suggestions for social activity outside the workplace after it has been made clear that such offers are unwelcome; and/or • Unwanted or offensive flirtations, suggestive remarks, innuendos, or lewd comments. Non-verbal conduct of a sexual nature: • The display of pornographic or sexually suggestive pictures, objects, written materials, emails, text messages, or faxes; and/or • Leering, whistling, or making sexually suggestive gestures. 152 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

APPENDIX 4: GUIDANCE TO ANY COMPLAINANT WHO WISHES TO PROCEED WITH AN INFORMAL RESOLUTION PROCESS. 1) Tell someone else that you are going to challenge the alleged offender: o Your manager. o Director of GCFS. o A colleague or friend. 2) Pre-arrange and agree, with the respondent, a mutually suitable time and place to meet. o Consider discussing with the respondent that you would like to be accompanied to the meeting. 3) Precisely describe the behaviour to which you are objecting and the effects that behaviour has on you. 4) Do not label the person, just the behaviour. 5) Identify the way you would like the behaviour to be different. 6) State clearly what you will do next if the behaviour continues. 7) Do not make empty statements; mean what you are saying. 8) At the end of the meeting, restate what has been discussed and agreed. 9) Write up this meeting in detail and add it to your diary of incidents. 10) If necessary, take the matter further (if there is no change in the behaviour identified). 153 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 19: MEDIATION POLICY 19.1 INTRODUCTION GCFS endorses workplace Mediation as a voluntary process to be used in appropriate circumstances to resolve individual work-related disputes quickly, amicably, and informally. Whilst resolving disputes in a harmonious and consensual way is always preferable, participation in mediation is a matter of individual choice. It does not interfere with an individual's rights under any other GCFS policy. It is hoped that employees would give serious consideration, in conjunction with their advisor(s), managers, or recognised staff representative, to the use of mediation in appropriate circumstances. Employees who are considering the use of Mediation are also encouraged to discuss its potential use with the Mediation Co-ordinator (see below). 19.2 PURPOSE The purpose of a workplace mediation framework is to provide a mechanism to resolve workplace disputes informally and as close to the source as possible, without recourse to formal processes. These may be more time consuming and adversarial and therefore difficult for the staff members concerned. Mediation is designed to be a positive process, as it focuses on the future rather than trying to apportion blame for the past. Managers have a responsibility to try to resolve issues if employees on their team are in conflict with each other, but if they cannot do so, a mediator may be able to help. Where mediation is deemed to be an appropriate course of action, the decision to proceed with it will rest with the parties to the dispute. 19.3 SCOPE This Policy applies to all GCFS employees. 19.4 POLICY STATEMENT This Policy will be set out under the following sections: Mediation Supporting the scheme Parties to MediationProcess Confidentiality Whathappens if Mediation does notresolve a dispute? 19.5 MEDIATION Mediation involves an impartial third party bringing two or more parties together with the aim of reaching a mutually acceptable agreement. Mediation is a confidential and informal way to resolve disputes between people who work together with the assistance of trained Mediators. The process is voluntary, is not legally binding and is without prejudice to employee's rights under other GCFS policies or otherwise. However, where any employee participates in Mediation, it is expected that they approach the process with an open mind and a desire to find a solution. Thus, mediation distinguishes itself from other forms of conflict resolution in many ways. Mediation is: • Informal – it does not form part of the Grievance Procedure or Disciplinary Procedures. 154 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• Mediation is Flexible. • Voluntary – the parties are assisted in working out their own solution rather than having something imposing a solution on them. • Faster than other dispute resolution procedures. Mediation is impartial and confidential. It encourages individuals to take charge of their own decisions and to accept responsibility for the consequences of their own decisions. Mediation aims to resolve conflicts at an early stage and to reduce any tension and anxiety. Types of issues suitable for workplace mediation could include those around work or management styles, working arrangements and environmental conditions, for instance: • Interpersonal conflict/personality clashes. • Perceived discrimination, harassment, and bullying (please also refer to GCFS’s Dignity at Work: Appropriate Workplace Behaviour Policy). • Unreasonable work demands. • Inappropriate behaviour or treatment. • Differences of working style or approach. • Communication breakdown. • Inappropriate use of power, status, or position. GCFS reserves the right to address an issue through its formal processes in certain cases rather than through Mediation. 19.6 SUPPORTING THE PROCESS GCFS will support the framework by ensuring that Mediators have the necessary time to undertake mediation, subject to the balance with other work requirements. In addition, GCFS will raise awareness of the Mediation scheme through appropriate channels to ensure that staff are aware of its potential uses. GCFS will appoint a Director of GCFS to perform the role of 'Mediation Coordinator' (see under Roles and Responsibilities section below), who will act as administrator and owner of the Mediation Policy. 19.7 PARTIES TO THE MEDIATION PROCESS 19.7.1 Mediators Mediators will be independent/neutral of the situation to ensure impartiality. In general, mediators will work alone, but this does not rule out Mediators working in pairs in some situations. Depending on the circumstances, GCFS may choose to assign additional mediator(s). 19.7.2 Representation While experience generally suggests that mediation works best when involvement is restricted to those directly involved in the dispute, it is recognised that the direct participation of a representative may assist the process in certain circumstances. 19.7.3 Mediation Coordinator The Mediation Co-ordinator is responsible for appointing a mediator in appropriate situations. The mediation co-ordinator decides (if necessary, in consultation with the relevant manager) if mediation is appropriate in the circumstances of a request. However, there are situations where it may not be 155 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

applicable to use mediation. It will be a matter for the Mediation Co-Ordinator to decide on a case- by-case basis. The decision of the Mediation Co-ordinator will be final in this regard. In deciding whether or not mediation is appropriate in a particular situation, the Mediation Co- Ordinator will have regard for the fact that Mediation should not be: • Used as a first resort – employees should, where possible, attempt to resolve matters between themselves directly or speak with a manager before seeking a solution via mediation. • Used by a manager to avoid managerial responsibilities. • Used where behaviour or performance is at issue and the matter is more appropriately dealt with through other GCFS policies/procedures. • Used where either party wants a formal investigation. The Mediation Coordinator will not be privy to details of discussions during mediation, nor will they receive a copy of mediation agreements. However, the Mediation Co-ordinator may be appropriately consulted by a mediator to ensure any proposed solution(s) aligns with GCFS practice and Policy. The Mediation Coordinator will, in any event, be informed by the mediator in a particular case of whether or not the outcome was successful. The Mediation Coordinator will maintain a record of mediation requests received. In addition, the coordinator will record details of the mediator appointed, if any, and whether mediation was successful. When the mediation process has concluded in a particular case, the Mediation Coordinator will inform relevant management about whether the process was successful or unsuccessful. 19.8 CONFIDENTIALITY Unless otherwise agreed by the parties, the contents of any discussions during mediation are to be kept confidential to the parties involved and the mediator. The exception to this would be if a party raised issues of harm to self or others, cases of serious misconduct, or a disclosure required by law. A record of the mediation process is not to be kept on personal files. Any notes taken by the mediator will be discarded once the mediation process has been concluded. Agreement reached at mediation will be confirmed in writing by the mediator. A written agreement made due to mediation will be kept only by the parties involved and not shared with others unless agreed by the parties. Unless otherwise agreed by the parties to the mediation, copies of a mediation agreement will not be retained by the mediator, the Mediation Coordinator, or any other party. Where it is agreed to share the mediation agreement with others, then this will be detailed explicitly by the mediator in the agreement. Similarly, unless otherwise agreed, management does not receive details of mediation discussions other than that the process was successful or unsuccessful. 19.8.1 What happens if Mediation does not resolve a dispute? If the mediation does not resolve the dispute, then the following will occur: • Relevant managers will be informed that the mediation process was unsuccessful. • In consultation with the relevant manager, the Mediation Coordinator is available to discuss options for dispute resolution with the parties if required. • The parties may opt to progress the matter in accordance with another GCFS policy, such as the Grievance Procedure Policy or Dignity at Work Policy. 156 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

19.9 POLICY REVIEW GCFS will review this Policy annually. 157 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

APPENDICES APPENDIX 1 – WHAT HAPPENS DURING MEDITATION? Mediation is a flexible process, and the mediation structure will change depending on the needs of the parties. Below is an outline of how mediation may be structured: 1. Separate Meeting (s) First contact with individuals The mediator will meet individuals separately to explain the role of the mediator and the process of mediation, including confidentiality, and to define the core issues and the outcome each party hopes to achieve. The first Meeting's primary aim is to allow each individual to tell their story and find out what they want out of the process. 2. Joint Meeting (s) Hearing the issues The mediator brings the participants together and invites them to give their side of the story. At this stage, the mediator will begin to summarise the main areas of agreement and disagreement and draw up an agenda with the parties for the rest of the mediation process. Exploring the issues Having identified the issues to explore, mediation is now about encouraging communication between the individuals, promoting understanding and empathy, and changing perceptions. This part of the process aims to begin to shift focus from the past to the future and look for constructive solutions. Building and writing an agreement As the process develops, the Mediator will encourage and support joint problem solving by ensuring the solution and agreements are workable and record any agreement reached. The mediator will also ensure that any solution(s) do not conflict with, or compromise GCFS practices and Policy and may need to consult the Mediation Coordinator in that regard appropriately. Closing the Mediation Once an agreement has been reached, the mediator will bring the process to a close, provide a copy of the agreement to those involved, and explain any responsibilities of the respective employees that may be affected. This is to implement the terms of that agreement, including appropriate review arrangements. In addition, it will be agreed who will receive copies, for instance, whether the relevant manager(s) or HR would receive a copy. 158 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

APPENDIX 2 - Mediation Request Procedure The procedure for making a mediation request is as follows: • The parties to the dispute must complete the 'Request for Mediation Form' and submit it to the Mediation Coordinator. The parties' request forms will not be shared unless both parties request that they be shared. • The Mediation Coordinator will acknowledge receipt of the Forms. Then, in consultation with management and HR as appropriate, the Mediation Coordinator will assess whether the case is suitable for mediation and communicate a decision to the parties, normally within three working days. • If the case is suitable for mediation, the Mediation Coordinator allocates the case to one of the mediators, based both on the type of the case and on the availability of mediators, and forward to them the completed request Forms. It is essential for the effectiveness and credibility of mediation that it takes place in a timely fashion. Therefore, the joint meeting between the two parties will generally occur within two weeks from when the two parties have submitted the Forms to the Mediation Coordinator. The Mediation Coordinator decides that mediation is not appropriate to a particular situation. The parties to the request will be so informed and advised of the rationale for the decision. In consultation with the relevant HR and line management, the Mediation Coordinator can discuss other options for dispute resolution with the parties if required. 159 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 20: CONFIDENTIAL DISCLOSURE (WHISTLEBLOWING) POLICY CODE OF PRACTICE ON PROTECTED DISCLOSURES ACT 2014 20.1 POLICY STATEMENT This Policy expresses the GCFS commitment to addressing concerns about potential/possible wrongdoing that may arise and protecting employees (as defined below) who make reports of misconduct under this Policy. In line with that commitment, employees who have concerns about any aspect of GCFS activities are encouraged and expected to come forward and voice those concerns. They may do so without fear of victimisation, subsequent discrimination, or disadvantage as a result of their disclosure. This Policy aims to give effect to the obligations and provisions of the Protected Disclosures Act, 2014 (hereinafter referred to as 'the Act') and does not replace any legal reporting or disclosure requirements arising under other legislation. Where statutory reporting requirements or procedures exist, these must be fully complied with as per the Act. 20.2 PURPOSE This Policy document sets out the framework for the approach to compliance and management of those issues that GCFS faces in the course of its business activities. The aims of this Policy are: • To encourage the reporting of suspected relevant wrongdoing as soon as possible in the knowledge that reports will be taken seriously and investigated as appropriate and that confidentiality will be respected in the manner provided by the Act. • To provide guidance as to how to raise concerns internally and to set out how those concerns will be dealt with; and • To reassure employees that genuine concerns can and should be raised, even if they turn out to be mistaken, without fear of penalisation. This Policy sets out GCFS internal procedures for making and dealing with protected disclosures as prescribed by section 21 of the Act. 20.3 SCOPE This Policy covers all employees in GCFS as defined by section 3 of the Act, which includes current and former employees, Board members, advisors, independent contractors, trainees, part-time, full-time, and agency employees. 20.4 PROTECTED DISCLOSURES A protected disclosure, as defined in the Act, is a disclosure of relevant information. If the employee's reasonable belief, it tends to show one or more relevant wrongdoings, the information came to the employee's attention in connection with his or her employment and is disclosed in the manner prescribed in the Act. 20.4.1 Relevant Wrongdoings The following matters are relevant wrongdoings for the purposes of the Act: • That an offence has been, is being or is likely to be committed. 160 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• That a person has failed, is failing or is likely to fail to comply with any legal obligation, other than one arising under the employee's contract of employment or other contracts whereby the employee undertakes to do or personally perform any work or services. • That a miscarriage of justice has occurred is occurring or is likely to occur. • That any individual's health or safety has been, is being or is likely to be damaged. • An unlawful or otherwise improper use of funds or resources of a public body or other public money has occurred or is likely to occur. • That an act or omission by or on behalf of a public body is oppressive, discriminatory, or • grossly negligent or constitutes gross mismanagement; or • That information tends to show any matter falling within any of the preceding paragraphs or is likely to be concealed or destroyed. 20.4.2 Policy Exclusion This Policy should not be used to raise complaints relating to your own personal circumstances or your terms or conditions of employment, such as the way you are being treated at work or workplace issues affecting you personally. In such cases, you should use the grievance policy or the anti-bullying and harassment Policy. For the avoidance of doubt, a matter is not relevant wrongdoing if it a matter which is the function of the employee or the employee's employer to detect, investigate or prosecuteand does not consist of or involve an act or omission on the part of the employer. 20.4.3 Assurance GCFS recognises that the decision to report a concern can be difficult to make, not least because of the fear of reprisal. However, if employees make allegations in good faith, they should have nothing to fear as they will be doing their duty to their employer, their colleagues, and to those to whom they provide a service. GCFS strong commitment to this Policy means that employees can raise concerns about wrongdoing in the knowledge that they will be supported and protected from repercussions. However, employees should not pursue their own investigations, however well-intended as a flawed or improper investigation could compromise GCFS's ability to take effective action. 20.4.4 Channels for making Protected Disclosure. This Policy guides employees on making an internal disclosure within GCFS. The purpose of this Policy is to provide an internal mechanism for making disclosures, reporting concerns, and investigating wrongdoing. However, the Act recognises that it may be appropriate for your concerns to be raised to an external body in some limited circumstances, such as a regulator or a person prescribed by Law, to be the recipient of the relevant wrongdoings. In these circumstances, the employee should consult the Act, which sets out the criteria that applies. The employee is encouraged to consult with GCFS if he/she believes an external disclosure should be made. 20.4.5 Raising a Concern under the Internal Disclosure Procedure. GCFS hopes that you will be able to make a protected disclosure to your manager. However, if you feel this is not appropriate. In that case, you should report any relevant wrongdoing to GCFS and confirm that you are making a protected disclosure under this Policy. If, for any reason, the employee feels that it is not appropriate to make a disclosure to his/her manager or a director of the company. In that case, the disclosure may instead be brought to the Compliance Officer. 161 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

Employees who wish to make a written disclosure are recommended to use the following format and keep a copy of the disclosure and any supporting documentation. 20.4.6 Format for Making an Internal Disclosure. • Describe the relevant wrongdoing. • Provide any information that supports the alleged relevant wrongdoing to assist the investigation of the matters raised in the disclosure. • Date the disclosure. • Provide your preferred contact details; and • State that the disclosure is made under the Act and whether you do/do not expect confidentiality. Although employees are not expected to prove the truth of the facts in the disclosure, they must have a ‘reasonable belief’ that there are grounds for their concern when making a disclosure using the internal procedure. 20.4.7 Confidentiality All disclosures will be treated in confidence, and every effort will be made to protect a employees' identity if the employee so wishes. Disclosures will be kept secure and in a form that does not endanger the employee's confidentiality, making the disclosure. The focus will at all times be on the information in the disclosure rather than the identity of the employee making the disclosure. It must be appreciated that it will not always be possible to protect the identity of the employee. A person's identity making a disclosure may have to be revealed where Law is required for the effective investigation of the disclosure to prevent, investigate, or prosecute a crime or in the public interest. 20.4.8 Anonymous Disclosures GCFS does not encourage anonymous disclosures as such disclosures make investigation difficult and, in some cases, impossible. 20.5 INVESTIGATION 20.5.1 Initial assessment Once an employee has made a disclosure under this Policy, GCFS will carry out an initial assessment to determine what action is appropriate, to include the scope of any investigation required. What action (if any) should be taken. GCFS will inform the employee of the outcome of its assessment. If it is clear that the concern falls more appropriately within a different policy/procedure, the employee will be informed that it should progress under that policy/procedure. 20.5.2 Investigation and outcome. If sufficient grounds for an investigation exist, your manager or GCFS will then appoint such person/person's (either internal or external to GCFS) who is or are more appropriately placed to investigate the particular disclosure in question ('the investigator(s). The scope and terms of reference of any investigation will be determined before the investigation being carried out. The employee may be invited to attend additional meetings to provide further information. Where possible, the employee will be informed of the progress of the investigation. Sometimes the need for confidentiality may prevent GCFS from providing specific details of the investigation. Therefore, all information concerning the investigation should be treated as confidential. 162 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

The investigator (s) will draft a report on the investigation ('the report'). The report will be sent to the Board and/or any other person(s) deemed relevant or necessary who will determine what GCFS should take (if any) action. Such action could include changes to how GCFS conducts its operations, disciplinary action (following the disciplinary procedure application), referral of the matter for consideration under a specific GCFS policy or procedure, or a report to an appropriate third party as An Garda Síochana. It should be noted that fair and due process requires any person accused of wrongdoing should be made aware of and allowed to respond to any allegations made against them. 20.6 UNTRUE ALLEGATIONS If an employee makes a disclosure under this Policy, but the information or allegation is subsequently not confirmed by the investigation, no action will be taken against the person. They will be fully protected from any less favourable treatment, penalisation, or victimisation. The person's motive for making the disclosure is not relevant, but if an allegation known to be false is made maliciously, then disciplinary action may be taken. 20.7 PROTECTION FROM PENALISATION GCFS is committed to good practice and high standards and is fully committed to supporting and protecting employees who make disclosures under this Policy. Direct or indirect pressure on employees not to disclose or make a disclosure contrary to this Policy will not be tolerated. GCFS recognises that penalisation can take many forms; it can be direct or indirect and may be perpetrated by fellow employees or management. Examples of penalisation include any unfair or adverse treatment (whether acts of commission or omission) that can result in an employee suffering any unfavourable change in his / her conditions of employment, including (but not limited to); • Suspension, lay-off or dismissal (including any dismissal within the meaning of the Unfair Dismissals Acts) or the threat of suspension, lay-off or dismissal. • Demotion or loss of opportunity of promotion. • Transfer of duties, change of location or place of work, reduction in wages, or change. of • Working hours. • The imposition of any discipline, reprimand, or other penalties (including a financial penalty). • Unequal treatment under sick leave or disciplinary policies, unfair selection for tasks. or • Attendance at events. • Coercion or intimidation. • Injury, damage, or loss. • Acts of reprisal, verbal harassment, jokes, comments, ridicule, or song. • Written harassment-text messages, e-mails, faxes, comments, or postings on social media. • Physical harassment-jostling, shoving, or any form of assault. • Intimidatory harassment, gesture, posturing, or threatening poses. • isolation or exclusion from social activities; and • Bullying. 163 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

GCFS will not penalise or threaten to discipline an employee for making a protected disclosure. GCFS will not allow any other person to discipline or threaten penalisation for having made a disclosure per this Policy. This protection extends outside the workplace, for example, to conferences and training outside the workplace and work-related social events. Penalisation or threats of penalisation by members of employees will not be tolerated. Such behaviour may constitute misconduct and may lead to disciplinary action up to and including dismissal. 20.8 COMPLAINTS PROCEDURE A complaint relating to matters arising in respect of invoking this Policy can be made under the Bullying and Harassment Policy or the Grievance and Disciplinary Policy as appropriate. Employees can make a complaint of penalisation under the Act to the Adjudication Officer, Workplace Relations Commission, in accordance with Schedule 2 of the Act. 20.9 COMMUNICATION, MONITORING AND REVIEW This Policy will be communicated to all employees upon commencement of employment in accordance with GCFS obligations under section 21 (2) of the Act. A copy of the Policy can be obtained by contacting your manager. In addition, the Policy will be reviewed annually. 164 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

APPENDIX A: Guidance for Managers in Dealing with Disclosures All reported disclosures about perceived wrongdoing in the workplace must be treated seriously. The manager to whom a concern is disclosed should: • Record the disclosure and the steps taken to deal with it. • Clarify the basis of the concerns raised with the employee. • Establish what evidence is available to support the concern. • Consider any personal interest the employee might have in the issue concerned. • Risk assesses the issue and takes immediate action if the alleged wrongdoing involves a serious loss or danger to others. • Carry out relevant inquiries promptly, sensitively, and discreetly, taking all reasonable steps to protect the identity of the maker of the disclosure. • If it is necessary to reveal the employee’s identity to undertake an effective • Enquiry consults with the employee. • Obtain evidence from any relevant witnesses. • Assess whether the disclosure report is based on a reasonable belief but ungrounded, based on a reasonable belief and grounded or a deliberately false report. • Take appropriate action if the disclosure is grounded. • If the disclosure is deliberately false, consider action under Disciplinary Policy. • Provide written feedback to the employee within the outcome within 20 days, including any proposed action. • Report the outcomes and forward all records to the Board. 165 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

Appendix B: Details that should be included in a Disclosure. It is recommended that, at a minimum, disclosures should include the following details: - • That the disclosure is being made under the Protected Disclosures Policy. • The discloser’s name, position in the organisation, place of work and confidential contact details. • The alleged wrongdoing date (if known) or the date the alleged misconduct commenced or was identified. • Whether or not the alleged wrongdoing is still ongoing. • Whether the alleged wrongdoing has already been disclosed and, if so, to whom, when and what action was taken. • Information in respect of the alleged wrongdoing (what is occurring/has occurred and how) and any supporting documentation. • The name of any person(s) allegedly involved in the alleged wrongdoing (if any name is known and the employee considers that naming an individual is necessary to expose the wrongdoing disclosed). • Any other relevant information. 166 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 21: PUBLIC HEALTH EMERGENCIES RETURN TO WORK & RESPONSE PLAN 21.1 INTRODUCTION This plan is designed to help GCFS minimise the risk that PUBLIC HEALTH EMERGENCIES pose to the health and safety of our employees, the stability of business operations, and the financial performance in the weeks and months following any alert. It is intended to provide the basic information required in preparing a continuity plan to mitigate the potential effects of PUBLIC HEALTH EMERGENCIES in our company. In developing our plan, we are aware that there is no way to predict what may happen in the weeks and months after a PUBLIC HEALTH EMERGENCIES is declared. Therefore, in as far as possible, our plan includes all the information currently available and includes the World Health Organisation’s advice that PUBLIC HEALTH EMERGENCIES are an immediate and very real risk to human health for the foreseeable future until vaccines or other measures are developed. As with any risk that threatens the viability of our company’s business operations, continuity planning is critical. In addition to the threat to human health, the economic impacts of Public Health Emergencies, including absenteeism in the workplace, or the possible impacts to supply-chain links in addition to travel disruptions, may be significant and widespread for the foreseeable future of the emergency. GCFS will take immediate steps to develop continuity plans that protect employees and to minimise possible disruptions to our customers, our local communities, and the economy. We are aware that while our decisions and actions cannot stop Public Health Emergency, however proper preparation may reduce its impact on our employees, our customers, our local communities, and the economy. This plan provides need-to-know information from the Health Service Executive, HSE website https://www2.hse.ie/coronavirus/ (for Pandemics. Please use this link as the foundation to develop your understanding of Public Health Emergencies). The Health Service Executive have many links with information, and we would ask all employees to inform themselves by utilising these links. In addition to these links, the Health and Safety Authority’s website https://www.hsa.ie/eng/topics/covid-19/ (As an example provides information to assist our understanding of the impact of Public Health Emergencies in the workplace) links is also available to everyone. Again, we would ask all employees to use these resources and familiarise themselves with this information, which demonstrates the need for individual responsibilities during PUBLIC HEALTH EMERGENCIES. 21.2 SCOPE OF THE PLAN This Return to Work & Response Plan covers all employees of GCFS. 21.3 COMMUNICATIONS Strong communication and a shared collaborative approach are essential for our company to protect each other against the spread of viruses in the workplace when a Public Health Emergency is declared. In providing these links to the HSE and HSA websites, it is intended to promote open communications with our employees, including up-to-date information essential in preventing the spread of viruses in the workplace. This is essential so that we can respond to the planned removal of restrictions if imposed by the Irish Government in the interest of public health due to any potential threats to Public Health. 167 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

21.4 RESPONDING AND ADAPTING TO CHALLENGES As with any emergency, we will do our utmost to adapt and learn from the reality of PUBLIC HEALTH EMERGENCIES. GCFS will work with our employees as we seek to ensure their ongoing health and safety in work, in line with Public Health guidance. Therefore, protocols may be supplemented by further guidance in line with changes advised by the HSE. 21.5 WORKPLACE ENGAGEMENT In line with the guidelines from the HSE, it may be necessary to implementcontrols required to comply with prevention measures in this plan. Therefore, we will communicate and explain all measures introduced in our company to all our employees and visitors to our company. In addition, we will appoint an employee (or additional appointments) representative as required, who will assist with the implementation of measures and monitor adherence to the measures in order to prevent escalation of the crisis. The appointment of these representatives will be communicated to all employees, and the company will provide training to these representatives. 21.6 SYMPTOMS OF VIRUSES (e.g., COVID 19) Infection from a virus that causes an illness can be identified by symptoms ranging from mild to severe, and in some cases, may be fatal. It may take anything from 2 days up to 14 days for symptoms of a virus to appear. However, they can be similar to the symptoms of colds and flu. Common symptoms of a virus include: • A fever (high temperature – 38 degrees Celsius or above). • A cough – this can be any kind of cough, not just a dry cough. • Shortness of breath or breathing difficulties. (For the complete list of symptoms, please refer to the HSE Website) It is important to remember that some people infected with viruses experience no symptoms at all and are called asymptomatic cases. (It is extremely important that social distance is maintained at all times, and this will be outlined later in the plan) 21.7 INFORMATION ON HOW A VIRUS CAN BE TRANSMITTED IN OUR WORKPLACE The virus that causes a PUBLIC HEALTH EMERGENCY is spread by infected people through fluid and droplets dispersed from the nose or mouth when the person with the Virus coughs, sneezes or speaks. The fluid or droplets land on objects and surfaces around the infected person. Colleagues will contaminate their hands by touching these objects or surfaces and then bring the virus into contact with their eyes, nose, or mouth by touching them with their contaminated hands. Viruses can also spread if droplets from an infected person lands directly on the mucous membranes of the eye, nose or mouth of a person standing close to them. It is still not known how long a virus may survive on surfaces in different conditions. Likewise, the period of survival may vary under different conditions (e.g., type of surface, temperature, or humidity of the environment). However, studies indicate that a virus can persist on surfaces for hours and up to several days in the absence of effective cleaning. Therefore, thorough, and regular cleaning of frequently touched surfaces is essential. If disinfection is required, it must be performed in addition to cleaning, never as a substitute for cleaning. While people are most likely to pass on the infection when they have symptoms, current information suggests that some infected people spread a virus to others prior to developing or displaying 168 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

symptoms themselves. At our discretion, or at the direction of outside authorities, we may require the isolation and quarantining of any employees showing symptoms of infection to our designated isolation room so that our emergency plans can be implemented safely. GCFS would ask all our employees to familiarise themselves with this information and remember the ways in which they as individuals are responsible for their behaviour. 21.8 RETURNING TO WORK AND OUR PUBLIC HEALTH EMERGENCY RESPONSE PLAN GCFS as an employer will follow the guidelines as advised and will: • Review and update our health and safety statement as required. • If risks are identified associated with work activities due to any public health emergency, changes will be made as required. • Develop a plan that will provide guidelines on responding if a suspected public health emergency is reported to our company. 21.9 IDENTIFICATION AND ISOLATION – VIRUSES In line with HSE guidelines, when a colleague reports they may have contracted a virus, there is a requirement for them to isolate themselves immediately. This is a crucial step in protecting our colleagues, customers, and suppliers, and we will: • Keep a log of contact/group work to facilitate contact tracing. • Inform our employees, customers and suppliers as required as to the purpose of the log. • Display information on signs and symptoms of the Virus. • Provide up to date information on Public Health advice issued by the HSE and Gov.ie. • Provide instruction for employees to follow if they should develop signs and symptoms of a Virus during work. Under the HSE guidelines, employees are required to: • Make themselves aware of the signs and symptoms of a Virus and monitor their own wellbeing. • Self-isolate at home before coming into work and contact their GP or the GP out of hour’s services for their area promptly for further advice if they display any signs or symptoms. Report to a manager immediately if any symptoms develop while at work. 21.10 MEASURES TO MINIMISE RISKS TO COLLEAGUES Before returning to work, the following pre-return to work steps should be put in place and completed by both GCFS and our employee. GCFS will: • Issue a pre-return-to-work form for employees to complete at least 3 days in advance of the return to work. This form will seek confirmation that our employee, to the best of their knowledge, have no symptoms of a Virus and also confirm that our employee is not self- isolating or awaiting the results of a Virus test. • It is necessary to include the following questions on this form. If an employee answers Yes 169 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

to any of them, they are advised to follow the medical advice they receive or seek medical advice before returning to work: o You have symptoms of cough, fever, high temperature, sore throat, runny nose, breathlessness, or flu-like symptoms now or in the past 14 days? Yes/No o Have you been diagnosed with a confirmed virus infection or of having a suspected Virus infection in the last 14 days? Yes/No o Have you been in close contact with a person who is either a confirmed or suspected case of contracting a Virus in the past 14 days (i.e., within 2 metres for more than 15 minutes accumulative in 1 day)? Yes/No o Has a doctor advised you to self-isolate at this time? Yes/No o Has a doctor advised you to cocoon at this time? Yes/No. Employees must: o Complete this form before they return to work. o Inform a manager if there are any other circumstances relating to a Virus. (The employee must include information which may be needed to be disclosed to allow their safe return to work in the interests of Public Health Safety). o Self-isolate at home and contact their GP or the GP out of hour’s services for their area promptly for further advice if they have any Virus symptoms. Stay out of work until all symptoms have cleared following self-isolation. Participate in any induction training provided on their return to the work. When employees return to work, they are required to request any updates on: o What an employee should do if they develop symptoms of a Virus o Details of how the workplace is organised to address the risk from Viruses. o An outline of the Virus response plan o Arrange for the putting in place of the necessary controls identified in the risk assessment to prevent the spread of Viruses in the workplace. 21.11 DEALING WITH A SUSPECTED CASE OF A VIRUS IN THE WORKPLACE In line with HSE guidelines, employees should not attend work if displaying any symptoms of a Virus. In the event that a suspected case of a Virus is reported during the course of work, the following are the steps outlined by the HSE as to how to respond: • The employee must contact a manager. • The employee must proceed to the designated isolation area, keeping at least 2 metres away from other employees and also making sure that colleagues maintain a distance of at least 2 metres at all times from them. • If face masks are available in the isolation area, the employee is to wear the face mask provided, particularly in a common area with colleagues or while exiting the premises. • If the employee is able to go home, they should do so after discussion with a manager. When the employee arrives home, they must call their doctor or out of hours GP service or the HSE and follow medical advice, which could include continuing self-isolation at home. • If the employee is unable to go home, they must contact their doctor or out of hours GP service or the HSE and follow medical advice. As long as the employee remains in work, they must avoid contacting or touching colleagues, surfaces, and objects. • While leaving or waiting to leave their workplace, it is necessary for employees to cover their mouth and nose with the face mask and use disposable tissues provided when they cough or 170 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

sneeze and put the tissue in the waste bag provided. • Arrange transport home or to a hospital after receiving medical advice. Under HSE guidelines, the use of public transport of any kind should not be used. • Before the employee leaves the isolation area, they should inform their manager if they have been in contact with colleagues or touched surfaces and objects. This is essential information so that appropriate cleaning of the isolation and work areas can be undertaken and completed. • The employee must provide any assistance if contacted by the HSE so that GCFS can assist the HSE in contact tracing of any employees who may have been in contact with them. Additional advice on dealing with a suspected virus case is available from the NSAI: https://www.nsai.ie/images/uploads/general/NSAI-Guidelines-for-COVID-19-2020-04-09.pdf The best way to prevent the person-to-person spread of a Virus is to use proper hand hygiene and respiratory etiquette and practice social and physical distancing. The current recommended distance to be maintained between people to minimise the risk of transmission is 2 metres. 21.12 HAND HYGIENE Regular handwashing with soap and water is effective for the removal of most viruses. This is a link to HSE guidelines on Hand Hygiene: https://www2.hse.ie/wellbeing/how-to-wash-your-hands.html GCFS would ask all employees to ensure they are familiar with and follow hand hygiene guidance and advice and remember to wash their hands before and after: • Coughing and sneezing • Eating • Preparing food • Being in contact with someone who is displaying any virus symptoms. • Being on public transport (if using it) • Being in a crowd • Arriving and leaving the workplace / other sites • Having a cigarette or vaping • Toilet use. 21.13 RESPIRATORY HYGIENE In addition to hand hygiene, good respiratory hygiene and etiquette is also essential: • Adopt good respiratory hygiene and cough etiquette. • Ensure you are familiar with and follow respiratory hygiene guidance. Note: Wearing of masks is not a substitute for other measures outlined above. However, if masks are worn, they should be clean, and they should not be shared or handled by other colleagues. Employees should keep up to date with the latest Public Health advice issued in regard to masks by Gov.ie/NPHET. 21.14 SOCIAL / PHYSICAL DISTANCING Social and Physical distancing is recommended to reduce the spread of infection. The current recommended distance to be maintained between people to minimise the risk of transmission is 2 171 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

metres. Under HSE guidelines, the following must be followed in the workplace so as to reduce the risk of transmitting Viruses. Under physical distancing requirements, employees may be asked to refrain from shaking each other’s hands. This includes customers and suppliers. • Maintain the required 2-metre distance at workstations, including office desks. • Maintain the required 2-metre distance when on breaks. • It may be required to change break times’ during a Public Health Emergency, and employees must follow any changes designed to prevent the spread of a Virus. • Maintain the required 2-metre distance from customers and suppliers. • Arrange meetings where possible using services such as Video Conferencing, for example. However, where face to face meetings are absolutely necessary, the length of the meeting and the numbers attending should be kept to a minimum, and participants must maintain physical distancing at all times. • Where one-way systems that ensure physical distance can be maintained while working or when entering or leaving work, these paths must be followed where practicable. • Employees must not congregate together in numbers above the HSE guidelines. All employees must follow this protocol at all times of the day. (e.g., break times, clocking in or out, changing rooms, washrooms, and showers) 21.15 AT-RISK AND VULNERABLE EMPLOYEES We would ask all employees who are in the ‘vulnerable’ or ‘at-risk’ categories to work from home where practical and with the agreement of a manager. An employee who is in the vulnerable or at- risk categories and cannot work from home must advise a manager immediately. All practical supports will be made available in the workplace, and they are to maintain the physical distance of the 2 metres requirements. The following HSE website will provide details on vulnerable’ or ‘at-risk’ categories: https://www2.hse.ie/conditions/coronavirus/people-at-higher-risk.html 21.16 WORKING FROM HOME Office work should continue to be carried out at home, where practicable, along with non-essential work. Advice on working from home on a temporary basis is available from the Health and Safety Authority using this (link by way of example) and within the Company Working from Home Policy. https://www.hsa.ie/eng/topics/covid19/covid19_faqs_for_employers_and_employees_in_relation_ to_homeworking_on_a_temporary_basis/faqs_for_employers_and_employees_in_relation_to_hom e-working_on_a_temporary_basis_covid-19_.html 21.17 BUSINESS TRAVEL The restrictions on movement require employees to plan and schedule business trips in line with HSE guidelines so, therefore: • All face-to-face interactions should be reduced to the absolute minimum, and as far as is reasonably practicable, technological alternatives should be made available (e.g., telephone or video conferencing). • Where work-related trips are necessary, the use of the same vehicles by multiple employees is not encouraged. The number of employees who share a vehicle – simultaneously or 172 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

consecutively – should be kept to a minimum as far as is reasonably practicable. • All employees are encouraged to travel alone if using their personal cars for work or at a maximum be accompanied by one passenger who shall be seated in adherence with physical distancing guidance. • Employees using company vehicles are required to have hand sanitisers and cleaning equipment for their work vehicle. They should speak with a manager to ensure they are provided with all supplies they require. (All employees must be aware when the company provides hand sanitisers and cleaning equipment, these suppliers are from work-related activates only) • Employees visiting customers or other sites must follow restrictions designed to reduce the risk of spreading the Virus and should follow the site infection prevention and control measures in place. In addition, we would ask employees to follow publichealth advice around preventing the spread of a Virus, where there is no plan in place at a customer or other sites to prevent the spread of the Virus. 21.18 PERSONAL PROTECTIVE EQUIPMENT In the event that employees are provided with Personal Protective Equipment (PPE), this equipment is for work activities only. Any introduction of PPE may be required to address health and safety risks, for example, exposure to hazardous chemicals. In the context of a Virus, the following PPE may be issued: • Overalls and protective aprons. • Protective headgear - safety helmets. • Safety glasses or goggles. • Gloves. • Respirators or masks. (Where gloves are used, they must not be considered a substitute for hand hygiene and hands must be washed when gloves are removed in line with HSE guidelines). When PPE is supplied to employees, it must be used in line with the training provided and must be regularly inspected, cleaned, maintained, and replaced as required. Further information on PPE is available at: https://www.hsa.ie/eng/Topics/Personal_Protective_Equipment_-_PPE/. In the introduction, it was stated that this plan is designed to help GCFS minimise the risk that the PUBLIC HEALTH EMERGENCIES pose to the health and safety of our employees, the stability of business operations, and the financial performances of GCFS. The plan cannot possibly cover every business situation, but it should help employees think and understand the issues that they must be aware of and issues that requires each individual to take responsibility for their own actions. GCFS asks all employees to read this document and familiarise themselves with the provisions and requirements of these plans as Public Health, and Employee Safety are of primary concern. 173 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 22: HUMAN RIGHTS POLICY 22.1 INTRODUCTION GCFS is committed to the highest standards of business and ethical behaviour including compliance with all applicable laws and regulations, as well as company policies, practices, and procedures. GCFS respects internationally recognised Human Rights as established in the Universal Declaration on Human Rights and the International Labour Organisation’s Core Conventions. In line with the UN Guiding Principles on Business and Human Rights, GCFS recognises the corporate responsibility to respect these principles and commit to 'know and show' this through on-going human rights due diligence. Furthermore, our efforts include on-going robust engagement with our business and major supply chain partners where possible to mitigate potential human rights impacts beyond our direct control. Our support of internationally recognised Human Rights is consistent with our dedication to enriching our workplace, partnering with our supply chain, preserving the environment, and supporting the communities where we conduct business. It is the commitment of GCFS to conduct its business in a manner that respects the rights and dignity of all people. 22.2 POLICY OBJECTIVES The objective of GCFS's documented policies as set out in the GCFS Code of Conduct for Employees is to provide an overview of expectations for employees and business partners. In addition, the Human Rights policy exists to: • Inform employees, business partners and customers of GCFS commitment to human rights. • Establish GCFS commitment to ‘know and show’ its respect for human rights through on-going human rights due diligence. • Maintain GCFS high ethical standards. • Contribute to the realisation of human rights globally. 22.3 POLICY SCOPE GCFS Human Rights Policy applies to all GCFS employees, anyone doing business for or with GCFS and others acting on GCFS behalf. This applies to all locations where GCFS conducts business and to all company-sponsored events. 22.4 DEFINITIONS Human rights are fundamental rights inherent to all human beings, regardless of nationality, place of residence, sex, sexual orientation, national or ethnic origin, colour, religion, language, or any other status. 22.5 GUIDELINES GCFS conducts its business in a manner that respects the rights and dignity of all people, complying with all applicable laws and regulations. Our policies reflect our commitment to respecting the protection of internationally recognised Human Rights. 22.5.1 All employment with GCFS is voluntary. We do not use child or forced labour in any of our operations or facilities. We do not tolerate any form of unacceptable treatment of employees, including but not limited to the exploitation of children, 174 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

physical punishment or abuse, or involuntary servitude. We fully respect all applicable laws establishing a minimum age for employment, to support the effective abolition of child labour worldwide. 22.5.2 Laws and Regulations GCFS abides by all laws and regulations regarding pay practices and the classification of employment according to job level and status. 22.5.3 Respect We respect our employees' right to choose to join or not join a trade union or to have recognised employee representation in accordance with local law. 22.5.4 Diversity Diversity is embraced at GCFS. We recognise that a diverse mix of backgrounds, skills and experiences drives new ideas, products, and services and provides us with a sustained competitive advantage.: 22.5.5 Elimination of Discrimination We believe everyone should be treated with respect regardless of their background. We are committed to the elimination of discrimination based on gender, race, class, economic status, ethnic background, sexual orientation, age, political beliefs, veteran status, marital status, or any other protected class. 22.5.6 Supply Chain Management The Group Supply Chain Management includes the requirement for all suppliers, vendors, contractors, consultants, and agents to adhere to GCFS's standards and Code of Conduct policies. In addition to this, GCFS is committed to the following principles: • GCFS respects all human rights. • GCFS commits to conducting on-going human rights due diligence to assess and mitigate potential human rights infringements. • GCFS expects those with whom it does business to respect all human rights. 22.6 RESPONSIBILITY The Human Rights policy is owned and maintained by GCFS's Human Resources function. GCFS is responsible for the administration, updating and communication of the policy. 22.7 COMPLIANCE Employees and suppliers are expected to comply with this and all applicable GCFS policies. Violation of this policy or the refusal to cooperate will result in disciplinary action, up to and including termination and referral to the appropriate authorities, where we have sound reason to believe that our partner organisations infringe Human Rights, we reserve the right to cease those relationships as warranted. Specific to this policy, employees and suppliers are expected to: • Never infringe on human rights. • Be alert to any evidence of human rights infringements in our direct operations or the operations of our business partners and report any situation in which a human rights infringement is suspected. 175 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

22.8 REFERENCES This policy reinforces GCFS's other relevant policy: • No Child or Forced Labour Policy For further information regarding human rights, please refer to: Universal Declaration of Human Rights: http://www.un.org/en/documents/udhr/ International Labour Organisation’s Core Conventions: http://ilo.org/global/standards/introduction-to-international-labourstandards/conventions-and- recommendations/lang--en/index.htm 176 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 23: CHILD LABOUR AND FORCED LABOUR POLICY 23.1 INTRODUCTION The protection of human rights and fundamental freedoms is a priority for GCFS and is codified and enforced through the company's Code of Conduct and the GCFS's Social Standards. GCFS will, therefore, not tolerate any form of child labour or forced labour. According to the International Labour Organization (ILO), approximately 218 million children between the ages of 5 and 17 are in employment worldwide. Of these, some 152 million work under conditions that violate their rights and deprive them of their childhood. It is estimated that 12 million people worldwide, half of which are children, are forced to perform work that they would not otherwise engage involuntarily under threat of punishment. The elimination of child labour and forced labour is a central challenge for the international community and is promoted by international organisations such as the United Nations. Nonetheless, due to the lack of comprehensive national and international mechanisms, the massive violation and curtailment of elementary human rights cannot be prevented. GCFS takes an active stand against child labour and forced labour. The GCFS Labour and Forced Labour Policy unconditionally prohibits and condemns both child labour and forced labour and at the same time contains procedural rules for addressing instances of child or forced labour. 23.2 GCFS's SOCIAL STANDARDS AND CHILD LABOUR AND FORCED LABOUR POLICY GCFS is committed to compliance with all GCFS's Social Standards and requires the same level of commitment from its business partners. These Standards set out the fundamental rights of employees and guidelines for environmental stewardship based on internationally recognised standards. The purpose of this Child Labour and Forced Labour Policy is to address the issue of child labour and forced labour in greater depth than in the Social Standards and provide background information. It entails no further obligations for business partners. 23.3 APPLICATION OF THE POLICY This Policy applies to all companies and undertakings in the GCFS. Compliance is mandatory for all employees. 23.3.1 Partners The Child Labour and Forced Labour Policy complement GCFS Social Standards, which are mandatory for companies that currently do business with GCFS. Acceptance of the GCFS Social Standards and as a result, this Policy by potential business partners is also a mandatory prerequisite for entering into new business relationships. GCFS expects its business partners to fulfil their duty of care and advises subcontractors and sub-suppliers on their obligation to comply with the GCFS Social Standards. The duties and obligations arising from these Social Standards apply for all employees of our suppliers, whether they are directly, indirectly, permanent, or so-called homeworkers, suppliers must inform their employees of their rights and obligation under the Social Standards and applicable domestic law in an appropriate manner. They must also designate a company representative to oversee compliance with the requirements contained in the GCFS Social Standards. The name of this company representative, who will be the point of contact for GCFS, must be communicated to GCFS. 177 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

23.4 CHILD LABOUR IN GENERAL 23.4.1 Distinction between Child Labour and Young Workers In keeping with internationally recognised standards, GCFS makes a distinction between child labour and young workers. GCFS will not tolerate child labour under any circumstances. The employment of young workers, i.e., minors who have reached the minimum age of employment and completed compulsory schooling is allowed under strict conditions and in compliance with Irish Employment Law. The distinction between child labour and young workers is based upon socioeconomic factors. In countries in which the educational system and the economy are not sufficiently developed, the existence of families can be jeopardised if minor children who have reached the minimum age of employment are not allowed to work. 23.4.2 Child Labour Definition In Ireland, under the Child Care Act 1991, the Children Act 2001 and the United Nations Convention on the Rights of the Child, a child is defined as anyone under the age of 18. Unless you are or were married, you cannot enter a legally binding contract until you are aged 18, except for specific contracts such as for apprenticeships or necessities like food. What a child can do is restricted by his/her age. Accordingly, child labour is first, work that deprives children of their childhood, their potential and their dignity and is harmful to their physical and mental development. In keeping with the ILO standards, GCFS defines child labour as: • Work that is mentally, physically, socially, or morally dangerous and harmful. • Work that fails to take into account compulsory schooling. • Work that prevents children from attending school. • Work that makes it necessary for children to leave school prematurely. • Work that requires children to combine school attendance with long and heavy work. The worst forms of child labour involve enslavement, separation of children from their families and exposure to hazardous conditions. 23.4.3 Prohibition of Child Labour GCFS is a nationally active business that has accepted its responsibility for adopting standards as defined in Irish Law and in the wider Irish society and actively seeks to ensure that its business partners act in line with Irish Law and the norms of Irish Society's Social Standards. Where activities are identified and practised by business partners that fail to comply with Irish Law or Irish Society's Social Standards, GCFS will require its business partner to correct its practice immediately. 23.4.4 Preventive Strategy Reliable control mechanisms will be implemented at the level of recruitment and selection procedures to prevent child labour. Within the recruitment and selection process, GCFS, therefore, will seek to confirm the age of applicants, where the age of the applicant is subject to examination. It is necessary to verify the age of applicants for employment by requiring the presentation of valid identification issued by an official Irish authority before employment. A copy of such identification and all other legally required documentation must be kept on file during the entire period of employment. In the event, it should prove impossible to present such identification, further legal proof of age such as a diploma, birth certificate or official document from the place of residence of the applicant may be accepted. 178 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

In cases in which the physical appearance of an applicant does not seem to be consistent with the documents presented, medical records from a reliable source may be required as proof of age. GCFS will, through dialogue with its business partners, seek to ensure that their recruitment and selection process is robust to prevent the hiring of children, under the age of employment in line with Irish Employment Law. 23.4.5 Dealing with Violations / Procedure In this Policy, GCFS has included a set of rules that cover procedural and investigatory measures to be adopted where a child is found to be employed by GCFS. GCFS will advise business partners of these sets of rules as required. The rules are set out below: • The child must cease work immediately. • GCFS will provide the child with appropriate compensation for the loss of employment. • GCFS will safeguard and promote the welfare of the child, which will include, for example, verification of continuation of compulsory education and financial assistance for the family of the respective child. GCFS will take it upon itself to monitor implementation of these measures. Where a business partner has identified a child in their employment, the business partner may turn to GCFS for advice. GCFS will also require proof of implementation of all necessary measures to ensure that hiring processes are designed to preclude child labour in the future through careful examination of documents. Proof of age must be kept on file for all employees. GCFS will also require formal confirmation to the effect that all possible actions have been taken and implemented. GCFS also reserves the right to verify the implementation of such actions on site. In the event a business partner should refuse to cooperate, GCFS reserves the right to terminate the business relationship as a last resort. 23.5 YOUNG WORKERS 23.5.1 Definition The Protection of Young Persons (Employment) Act 1996 is designed to protect the health of young workers and ensure that work carried out during school years does not put young people's education at risk. The Act sets minimum age limits for employment, rest intervals and maximum working hours and prohibits the employment of anyone under 18 on late-night work. The Act also requires employers to keep specified records for workers under 18. The Act generally applies to employees under 18 years of age. It defines children as being aged under 16, and young person’s refer to those aged 16 and 17. You can read more information in our document on working hours and rest breaks for children and young people. 23.5.2 Children Under the Act, GCFS cannot employ children aged under 16 in regular full-time jobs. Children aged 14 and 15 may be employed as follows: • Doing light work during the school holidays – they must have at least 21 days off work during this time. • As part of an approved work experience or educational programme where the work is not harmful to their health, safety, or development. 179 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• In the film, cultural, advertising work or sport under licences issued by the Minister for Business, Enterprise, and Innovation. Children aged 15 may do 8 hours a week of light work in school term time. The maximum working week for children outside school term time is 35 hours, or up to 40 hours if they are on approved work experience. 23.5.3 Young people The maximum working week for young people aged 16 and 17 is 40 hours, with a maximum of 8 hours a day. If a young person under 18 works for more than one employer, the combined daily or weekly hours of work cannot exceed the maximum number of hours allowed. Young persons are only permitted to work between 6 am and 10 pm. GCFS will seek to confirm with any employee within the age group as outline above if they hold additional employment. Where their combined working pattern is above the terms of the Act, GCFS will contact the employees' parent or guardian. GCFS will then, through discussion with the employees' parent or guardian, place the interest of the employee to the fore in any solution to the continued employment of the young employee. 23.5.4 Evidence of age and the Written Permission of Parents GCFS must see a copy of the young person's birth certificate, or other evidence of their age, before employing them. If the young person is under 16, GCFS will contact the applicant’s parent or guardian. 23.5.5 Payment of Wages All employees are entitled by law to a payslip. The payslip will detail the total pay before tax and all details of any deductions from the salary of the young employee. In Ireland, the National Minimum Wage is set annually under the National Minimum Wage Act 2000. Where GCFS employees a young person as identified in the legislation, GCFS will pay the young employee the full national minimum wage as valid throughout the period of employment of the young employee. GCFS will advise all young employees that GCFS has a strict no-tolerance position on tips/gratuities being offered to employees of GCFS by customers. In the case of young employees, as identified in the legislation, GCFS will consistently advise young employees of this position, in order to prevent young employees from being exploited by customers in any way. 23.5.6 Records to be kept by GCFS. GCFS must keep records for every employee under 18 that contain the following information: • The employee's full name. • The employee's date of birth. • The employee's starting and finishing times for work. • The wage rate and total wages paid to the employee. GCFS must retain these records for at least 3 years. 23.5.7 Summary of the Act. GCFS will provide all young employees aged under 18 years a copy of the official summary of the Protection of Young Persons (Employment) Act, along with other details of their terms of employment, within one month of commencing their employment with GCFS. GCFS will also display the official summary of the Act at a place in their workplace where it can be easily read. 180 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

23.5.8 Strategy for the Avoidance of Non-Compliance with Rules for the Protection of Young Workers In order to ensure compliance with rules for the protection of young workers, GCFS expects all minor workers to be appropriately registered with the responsible authorities. 23.5.9 Dealing with Violations/Procedure GCFS will work to prevent any violation of rules pertaining to the employment and protection of young workers, with GCFS or with its business partners. GCFS will take it upon itself to monitor implementation of these measures. Where a business partner has identified a young person in their employment, the business partner may turn to GCFS for advice. GCFS will also require proof of implementation of all necessary measures to ensure that hiring processes to recruit young people is in line with Irish Employment Legislation in the future through careful examination of documents. Proof of age must be kept on file for all employees. GCFS will also require formal confirmation to the effect that all possible actions have been taken and implemented. GCFS also reserves the right to verify the implementation of such actions on site. In the event a business partner should refuse to cooperate, GCFS reserves the right to terminate the business relationship as a last resort. 23.6 FORCED LABOUR 23.6.1 Prohibition on Forced and Compulsory Labour The primary legislation in Ireland on Forced Labour is Criminal Law (Human Trafficking) Act 2008 and its further amendment in 2013. The Act (s) prohibit sexual and labour exploitation among other exploitative practices. Labour exploitation is: • Subjecting the person to forced labour (including forcing him or her to beg); • Forcing the person to render services to another person; or • Enslavement of the person or subjecting him or her to servitude or a similar condition or state. The forced labour provisions are equally applicable to children. Forced labour means \"a work or service which is exacted from a person under the menace of any penalty and for which the person hasnot offered himself or herself voluntarily. The Acts prescribe long imprisonment terms and fine at the discretion of the court for trafficking a person to exploit his/her labour. Section 23 of the Employment Permits Act 2006 makes it an offence for employers to retain workers' passports, identity papers, qualification documents, driving licences. Further to this, employers cannot make deductions from their wages to pay recruitment fees, travel expenses or other costs related to obtaining a job in Ireland. GCFS will ensure that forced labour in all its versions will not be tolerated in any way within GCFS and will also be available to business partners may turn to GCFS for advice on this issue. 23.6.2 Prohibition of Forced Labour GCFS is a national company that takes an active stand against all forms of forced labour. GCFS strictly prohibits the use of forced labour and expects the same of its business partners. The freedom of workers may not be restricted and must always be ensured. 181 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

23.6.3 Preventive Strategy GCFS will not tolerate or condone any form of forced labour and expects the same of its business partners. Acceptance of the GCFS's Social Standards, which condemn and prohibit all forms of forced labour, is an essential prerequisite for establishing a business relationship with business partners. GCFS also provides its employees with annual training as regards the values and rules embodied in its Social Standards. Special attention is devoted to the Standards to the recognition of forced labour and related practices. When employees complete this training, they will be aware of their responsibilities and also capable of recognising and reporting violations of this policy. 23.6.4 Dealing with Violations/Procedure Any violation of the rules contained in the GCFS Social Standards must be remedied immediately. Measures must then be taken to prevent the repetition of the violation of the Social Standards. GCFS also expects the parties affected to receive appropriate compensation. GCFS sees it as its duty to monitor the implementation of these measures. Information regarding the implementation of the actions will, therefore, be requested from business partners as required. In the case of difficulties during the execution of such measures, business partners may turn to GCFS for advice. GCFS also reserves the right to verify the implementation of such actions on site. In the event, a business partner should refuse to cooperate. GCFS reserves the right to terminate the business relationship as a last resort. 23.6.5 Point of Contact in the Case of Violation Violations of the GCFS's Social Standards, whether actual or potential, may be reported directly to GCFS. GCFS will treat all reports of child labour or forced labour to it, in confidence and following a review of the information provided to it, GCFS will pass on this information to An Garda Síochána. All employees of GCFS and third parties such as, for example, customers, business partners, are free to contact An Garda Síochána at any time with their concerns. 23.7 REVIEW This Policy will be reviewed annually and or when changes are enacted through legislation. 182 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 24: ENVIRONMENTAL POLICY 24.1 INTRODUCTION Environmental concerns have increased the need for companies to be aware of and plan for energy management and consumption and are now the driving force for local industry to change the way energy is used and energy costs are viewed. Rather than being an inevitable cost of doing business, energy is now considered to be a manageable input to the process, much like any raw material or other resource costs. Energy consumption, carbon emissions and rapidly rising costs are issues that are driving finance organisations to focus on energy efficiency as a core element of their sustainability programs. With increased frequency, businesses are executing action plans to reduce energy costs and carbon emissions. GCFS is very much aware of the impact and benefits for the environment and society at large in implementing energy management and consumption practices. This policy offers guidance on how to implement successful sustainability and energy management programs. In GCFS, as in the broader financial services sector, we face a variety of challenges keeping up with the unprecedented pace of change. Driven by consumer trends, changing demographics and the ever- increasing prevalence of technology, business models are evolving as the marketplace continues to shift. In GCFS, we intend to embrace these challenges and strive as individuals and a Company to actively plan our part in sustainable energy policies and practices. 24.2 SCOPE OF THE POLICY This policy applies to all employees of GCFS. 24.3 STAKEHOLDER ENGAGEMENT We in GCFS are committed to on-going and constructive engagement with our key internal and external stakeholders, and through a process of two-way engagement, we incorporate their views into our business activities. We are engaged in partnerships with key stakeholder groups and relevant third parties where necessary to help achieve our goals and ambitions in meeting our plans to promote environmental concerns and promote sustainability programs. 24.4 RESPONSIBILITY At GCFS, we are mindful of our impact on the environment and recognise the fundamental importance of a healthy ecosystem for our shared future. We understand that our day-to-day activities contribute to some of the world's critical environmental challenges and our ability to successfully address these both as company and individuals increases in importance daily. We aim to minimise our impacts in accordance with this policy, and we seek to integrate environmental considerations into all aspects of our business. Our policy commits us to carry out our activities in an environmentally responsible manner, to comply with all applicable environmental legislation, implementing good environmental practice and continuously improving performance. 24.5 REDUCING EMISSIONS Like many organisations, GCFS is conscious of the potential impact climate change will have on people and the planet, and we continue to examine how we can manage the risks and opportunities that this presents for our business. Critical hazards include changing customer and consumer preferences, disruption to operations and supply chains as well as regulatory and policy responses to mitigate the worst effects of climate change. We at GCFS see an opportunity for organisations, who like GCFS, are now tackling their emissions with a plan which can support a transition to products and services with a lower environmental footprint. 183 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

24.6 USING WATER EFFICIENTLY Water plays a critical role in our daily activities as individuals and as a company. We will promote awareness for the conservation of this precious resource. There is increasing pressure on this shared resource, and by 2025 the UN estimates that two-thirds of the global population could be living under water stress conditions. We strive to manage our water use as efficiently as possible as follows: • Use water for essential handwashing, in accordance with the guidance of local government or national guidance, i.e., advice from Irish Water. • Turn all taps fully off after use. • Report any taps that do not turn off as soon as identified to the manager. • Report any water leaks as soon as identified to the manager. • Follow all instructions offered on how to deal with the issue. We also continue to view our water footprint within the broader context of global water risk. Given the uneven distribution of water resources, some of our communities are potentially more challenged by water stress. GCFS will follow all advice and guidelines on how to conserve water locally due to adverse weather conditions and the effect on the water supply to our communities. 24.7 GENERATING LESS WATER As global population and income levels rise, pressure on natural resources continues to grow. For companies to operate more sustainably and to ensure continued access to environmentally sustainable products, there is a clear need for a transition to a more circular economy. In GCFS, we are exploring ways to reduce, reuse and recycle materials. Where we do generate waste material, we seek to find ways in which this can be utilised elsewhere. It is incumbent on all members of staff, and customers where applicable, to dispose of any waste generated in the correct manner and the receptacles provided. GCFS will provide containers for recycling, food, and general waste. 24.8 RESTRICTED SUBSTANCES & CHEMICAL HANDLING GCFS is subject to requirements of the Health, Safety and Welfare Act and Regulations. GCFS provides guidelines to ensure safe management practices in relation to hazardous chemical substances and mixtures (henceforth known collectively as chemical agent(s) and their associated risks that are used and stored in areas over which it has control. Effective chemical agent management requires professional consideration of the safe, responsible, sustainable, and economical use of chemical agents throughout the chemical life-cycle – from procurement, storage, transport, use, through to disposal. All aspects of hazardous chemical use are governed by a comprehensive set of legislation to ensure the risks posed by chemical agents that may be harmful to health or the environment are suitably controlled. Please contact your manager if there is training that you feel is necessary for you to handle and manage chemicals correctly and in accordance with legalisation and Health and Safety protocols. 24.9 DEFORESTATION Forests play a critical role in supporting our ecosystem and are a source of fuel and food for over a billion people yet forests globally are under threat. According to the World Resources Institute, almost 16 million hectares of tree cover was lost in 2017. In GCFS, we will support sustainable agriculture practices and will not through investments support companies whose actions may result in deforestation. 184 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

24.10 MARKETING AND COMMUNICATIONS At GCFS, we are committed to providing clear product information which supports and advises consumers in making choices about our company and the actions we are taking in line with our responsibilities for the environment. All advertising and brand positioning conforms to national advertising codes of practice, and we are conscious of the potential impact of marketing to children and young people. We will support, where possible, any company or organisation that seeks to advise and inform our customers about the effects of climate changes and environmental concerns. We will support any awareness that brings this message to current and future generations of customers. 24.11 ENERGY MANAGEMENT PLANNING AND REVIEW Energy management planning is intended to be a process of \"continuous improvement\". A closed- loop feedback approach is most effective in demonstrating results that will justify further investment inefficiency. The following diagram shows the circular steps that are adopted into the planning process: Plan: Create the energy management plan, ensuring budgets, resources, are timelines are established to meet the targets and objectives of the plan. Include tracking and monitoring processes within the plan to ensure effective reporting to management. Do: Execute the plan by deploying the resources and budgets, prepare status reports, and implement the communication strategy. Check: Measure and monitor performance of projects and programs against the desired outcomes as planned and report to management, with recommendations for improvements and course corrections. Act: Analyse the variances to the plan and their causes. Recommend improvement, course corrections, and modifications to the plan. Whilst GCFS focuses on electrical energy efficiency; the scope of the plan must include all possible renewable energy supplies to ensure you have a complete understanding of opportunities for energy cost reduction and self-generation optimisation. GCFS will review this policy annually. 185 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 25: WASTE MANAGEMENT POLICY 25.1 INTRODUCTION There are many different types of waste, for example, household waste, packaging waste and electronic waste. In some cases, different types of waste require other methods of disposal. The disposal of waste can have a negative impact on people and the environment. For this reason, there are EU and Irish regulations for the correct disposal of waste. As population growth and rising levels of income put increasing pressure on natural resources, the current linear system of production, consumption and disposal is increasingly unsustainable. Given this increasing pressure on natural resources, we want to maximise the value we can extract from our inputs and minimise our waste as part of a more circular approach. Our priority is to generate less waste and to have a waste reduction and recovery programmes in place across all our offices. Recent legislation in the form of the EU Landfill Directive has changed the way we dispose of waste. The directive’s main aim is “to prevent or reduce as far as possible negative effects on the environment, in particular the pollution of surface water, groundwater, soil and air, and on the global environment, including the greenhouse effect, as well as any resulting risk to human health from the landfilling of waste during the whole life-cycle of the landfill”. GCFS is therefore committed to the protection of the environment through the implementation of an effective waste management programme that meets or exceeds all legislative and regulatory requirements placed on it. 25.2 EU WASTE DIRECTIVES The range of EU Directives dealing with waste management includes the Integrated Pollution Prevention and Control Directive (1996/61/EC) as well as the following: 25.2.1 Waste Framework Directive GCFS will follow The Waste Framework Directive (Directive 2008/98/EC on waste) which sets down basic requirements for handling waste and defines what is meant by \"waste\". In dealing with waste, GCFS will: • Ensure that the disposal and recovery of waste does not present a risk to water, air, soil, plants, and animals. • Not allow waste disposal to constitute a public nuisance through excessive noise levels or unpleasant odours or to degrade places of exceptional natural interest. • Prohibit the dumping or uncontrolled disposal of waste. • Establish an integrated and effective network of waste disposal outlets, prepare waste management plans, ensure that those who store waste handle it properly and ensure that waste treatment operations are licensed. • Require waste collectors to have special authorisation and to keep records. • Carry out inspections of companies involved in waste collection or disposal. • Undergo periodic inspections. The Waste Management Acts provide for a general duty on everyone not to hold, transport, recover or dispose of waste in a manner that causes or is likely to cause environmental pollution. GCFS will 186 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

follow the guidelines that prevent ecological damage and takes its responsibility in this regard with the utmost importance. 25.3 PRINCIPLES OF WASTE MANAGEMENT GCFS will apply the principles of the Waste Management Hierarchy to ensure that waste is dealt with in a way that impacts the least on our environment. 25.3.1 Waste Management Hierarchy Reduction: Since all waste disposal options have some impact on the environment, the only way to avoid impact is not to produce waste in the first place. GCFS will, therefore endeavour to reduce waste by judicious purchasing. Reuse: Before discarding an item check that someone else cannot make use of it. Examples include furniture, computers, and Peripherals. Recovery: Wherever possible, GCFS will recycle. Staff and visitors need to be fully engaged in this process to ensure that the recycling units are used and that only waste that cannot be recycled goes into the bins - and therefore to landfill. Disposal: Waste sent to landfill is the worst option in environmental terms and GCFS will strive to keep this to a minimum. 25.4 RESPONSIBILITIES 25.4.1 Property & Facilities GCFS is responsible for the development and initial implementation of the policy. All employees are responsible for the operation of the policy and for staying up to date with waste legislation affecting the company. Increasingly more elements within the waste stream are prohibited by legislation from entering the general company waste stream and should there be any doubt about how an item(s) should be dealt with; the Managing Director can be contacted directly. 26.2.2 Members of Staff All members of the company have a personal responsibility for the way their conduct impacts on the environment and should ensure that they think about all new purchase's guidelines are adhered to in line with our policy. 25.5 WHAT IS WASTE? 25.5.1 General Waste General waste, i.e., neither hazardous nor clinical, should be deposited into skips and mobile bins provided and will be collected by the designated contractors. Note: items that are not general waste will incur a cost recovery disposal charge. 25.5.2 Confidential Waste The importance and significance of Confidential Waste for GCFS require Particular care and attention of all staff. All waste should be shredded and should then enter the relevant waste stream (e.g., paper recycling, etc.). Where there is an issue in shredding confidential waste, then GCFS must be contacted immediately in order to arrange for the documents to be shredded. 25.5.3 Hazardous Waste Any hazardous waste must be disposed of according to the relevant legislation: The WEEE (Waste Electrical and Electronic Equipment) Directive aims to conserve landfill and support more sustainable 187 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

development by providing an impetus to boost recycling. The RoHS (Restriction of Hazardous Substances) legislation aims to reduce the environmental impacts of waste and improve recyclability. All employees of GCFS are required to familiarise themselves with a list of goods and items that can be disposed under this waste heading. Where GCFS is not fully utilising or aware of all items that can be disposed of under this waste heading, the Managing Director is to be informed to ensure GCFS is compliant with the legislation. Hazardous waste includes: • IT and telecommunications • Consumer equipment • Lighting equipment • Electrical and electronic tools • Leisure and sports equipment • Medical devices • Monitoring and control devices • Automatic dispensers GCFS will engage a service provider to have all equipment under this heading to be collected and disposed of in accordance with the legalisation. 25.5.4 Recycling All other waste should be recycled. Containers clearly marked with what can be disposed of are sited throughout company properties and can be used to recycle: • Paper • Newspapers • Envelopes • Cardboard • Cans and glass GCFS will engage a service provider in order to have all equipment under this heading to be collected and disposed of in accordance with the legalisation. ALL employees are asked not to place any other items in the bins as this can lead to the contamination of an entire recycling load which will then be taken to landfill with a direct cost to the company. The implications and damage on our environment are becoming increasingly evident by the careless disposal of recyclable materials. GCFS through implementing this Waste Management Policy is accepting its responsibility in fully implementing the Directives which have been transferred into Irish Law and asks all its employees to accept their induvial responsibilities fully. Toner and printer cartridges can be recycled via our current suppliers. Please return them to the relevant department to arrange this. END 188 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

Gerry Cuffe Financial Services Limited Employee Handbook Acceptance Form I have received and read the Employee Handbook June 2021. When reading the Employee Handbook, anything I was unsure of/or needed explaining I have asked my manager, to discuss and explain to me. Date: / / (Employee Name) Singed Employee Handbook Acceptance Form received and added to Employee’s File. Date: / / (Manager’s Name) 189 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2