MISSION STATEMENT

SMARTSEC FACILITIES SERVICES LTD aims to be a recognised brand within the security and facilities management industries, associated with quality and cost effectiveness. Working closely with our clients, staff and other service providers we aim to supply a service which is tailor made and specific to a client’s needs. With our experience and service offerings we aim to be able to supply our clients with every security and facilities requirement they may have.

It is our aim to encourage a friendly and helpful atmosphere on all our assignments, with the right staff and constant communication between all parties to ensure this is achieved. It is also important that we continue to seek methods to improve our standards and give the best and most cost-effective service possible. Dialogue with clients and staff is imperative with flexibility being the key.

QUALITY POLICY

It is our policy to ensure the continual improvement of the SMARTSEC overall performance, and to aim towards satisfying the expectations and needs of our Customers. To achieve this objective, SMARTSEC operates a Quality Management System that is described in the Quality Manual and satisfies the requirement of ISO 9001:2008 which is reviewed yearly.

Adherence to this policy involves all of the Company’s activities and services, and their effects. This policy is understood, implemented and maintained at all levels within the Company. The policy includes the setting and publication of our quality objectives and this policy is publicly available.

The Managing Director has the ultimate responsibility for the effective operation of the Quality Management System and ensuring a commitment to its continuous improvement.

Health & Safety Policy Statement

The following is a statement of the organisation’s health and safety policy in accordance with Section 2 of the Health and Safety at Work etc. Act 1974.

It is the policy of SMARTSEC FACILITIES SERVICES LTD to ensure so far as is reasonably practicable, the health, safety and welfare of all employees working for the company and other persons who may be affected by our undertakings.

SMARTSEC FACILITIES SERVICES LTD acknowledges that the key to successful health and safety management requires an effective policy, organisation and arrangements, which reflect the commitment of senior management. To maintain that commitment, we will continually measure, monitor and revise where necessary, an annual plan to ensure that health and safety standards are adequately maintained.

The Managing Director will implement the company’s health and safety policy and recommend any changes to meet new circumstances. SMARTSEC FACILITIES SERVICES LTD recognises that successful health and safety management contributes to successful business performance and will allocate adequate finances and resources to meet these needs.

The management of SMARTSEC FACILITIES SERVICES LTD looks upon the promotion of health and safety measures as a mutual objective for themselves and employees. It is therefore, the policy of management to do all that is reasonably practicable to prevent personal injury and damage to property. Also, the organisation aims to protect everyone, including visitors and members of the public, insofar as they come into contact with our activities, from any foreseeable hazard or danger.

All employees have duties under the Health and Safety at Work etc. Act 1974 and are informed of their personal responsibilities to take due care of the health and safety of themselves and to ensure that they do not endanger other persons by their acts or omissions. Employees are also informed that they must co-operate with the organisation in order that it can comply with the legal requirements placed upon it and in the implementation of this policy. SMARTSEC FACILITIES SERVICES LTD will ensure continued consultation with the workforce to enable all viewpoints and recommendations to be

discussed at regular intervals.

The organisation will ensure a systematic approach to identifying hazards, assessing the risks, determining suitable and sufficient control measures and informing employees of the correct procedures needed to maintain a safe working environment. We will provide, so far as is reasonably practicable, safe places and systems of work, safe plant and machinery, safe handling of materials and substances, the provision of adequate safety equipment and ensure that appropriate information, instruction, training and supervision is given.

We regard all health and safety legislation as the minimum standard and expect

management to achieve their targets without compromising health and safety.

Vision

SMARTSEC FACILITIES SERVICES LTD is committed to creating a culture in which diversity and equality of opportunity are promoted actively and in which unlawful discrimination is not tolerated. SMARTSEC FACILITIES SERVICES LTD recognizes the real business benefits of having a diverse community of staff and to this end, is working towards building and maintaining an environment which values diversity.

Policy Statement

SMARTSEC FACILITIES SERVICES LTD believes in the principles of social justice, acknowledges that discrimination affects people in complex ways and is committed to challenge all forms of inequality. To this end, SMRTSEC FACILITIES SERVICES LTD will aim to ensure that:

• individuals are treated fairly, with dignity and respect regardless of their age, marital status, disability, race, faith, gender, language, social/ economical background or being lesbian or gay and any other inappropriate distinction;

• it promotes an inclusive and supportive environment for staff;

Aims of the Policy and underpinning principles

 The aim of this policy is to ensure that in carrying out its activities SMARTSEC FACILITIES SERVICES LTD will have due regard to:

• promoting equality of opportunity, across all the area’s of the organisation

• promoting good relations between people of a diverse background

• eliminating unlawful discrimination

This policy is guided by the following principles, that:

• all staff, should enjoy a safe environment free from discrimination and harassment/bullying

• all employees should have equal access to quality services that are made available by SMARTSEC FACILITIES SERVICES LTD

• all staff should have equal access to opportunities for personal, professional or academic development and career, progression and promotion opportunities wherever possible.

Responsibilities

The Managing Director is responsible for ensuring the strategic development, implementation and review of the Equality and Diversity Policy and progress on the implementation across the organization.

The Managing Director is responsible for ensuring that procedures relating to staff recruitment, selection, career development discipline and grievance are carried out in accordance with the Equality and Diversity Policy.

 The Managing Director is responsible for:

• fostering a culture in which compliance with this policy is regarded as integral to the work of the area and in which equality and diversity issues are actively promoted;

• ensuring all staff are encouraged, supported and enabled to reach their full potential

• identifying appropriate staff development for themselves and their staff to meet the needs of their respective areas

Breach of the Policy

SMARTSEC FACILITIES SERVICES LTD will take seriously any instances of non-adherence to the Equality and Diversity policy by staff.  Any instances of non-adherence will be investigated and where appropriate will be considered under the relevant disciplinary policy.

Relevant Legislation

SMARTSEC FACILITIES SERVICES LTD has implemented its Equality and Diversity Policy in accordance with current legislation and codes of practice including:

• EU Anti-Discrimination Directives (which currently include the Race Relations Act 1976 (Amendment) Regulations 2003, Religion and Belief Regulation 2004 and Sexual Orientation Regulation 2004

• Race Relations Amendment Act 2000

• Human Rights Act 1998

• Disability Discrimination Act 1995

• Race Relations Act 1976

• Sex Discrimination Act 1975

• Equal Pay Act 1970 and Amendment 1983

Corporate hospitality means hospitality of any kind provided by SMARTSEC FACILITIES SERVICES LTD or its staff to non-Company employees in connection with the lawful business of SMARTSEC FACILITIES SERVICES LTD.

All corporate hospitality expenses which are likely to be above the sum of £(amount) (inclusive of VAT) must be approved in advance by a Director of SMARTSEC FACILITIES SERVICES LTD.  In addition, the employee’s line manager must agree in advance to the level of any corporate hospitality expenses, before the commitments are made, taking into account what is reasonable and proportionate in all the circumstances.

When claiming back expenses for corporate hospitality, the expense claim form must include details of the reason why the expenditure was necessary, the names of the persons being entertained, the companies they represent and a breakdown of the expenditure incurred.

All corporate hospitality expenditure will be closely monitored by SMARTSEC FACILITIES SERVICES LTD.

Corporate hospitality may also be received by an employee from another company, for example if the employee is invited to a client’s event in connection with their employment by SMARTSEC FACILITIES SERVICES LTD.

Whilst SMARTSEC FACILITIES SERVICES LTD does not wish to prohibit attendance at genuine corporate hospitality events, it does not believe that it is appropriate for employees to attend lavish, extraordinary or excessive corporate hospitality events held by customers, clients, suppliers, contractors or held by any other person or organisation with which SMARTSEC FACILITIES SERVICES LTD has, or might have, business connections.

This is because it is important to ensure that no employee acts in any way that is inconsistent with the integrity of the business by attending lavish, extraordinary or excessive corporate hospitality events in circumstances where it could influence, or be seen to influence, that employee’s business decisions or actions.

All employees are under an obligation to report a corporate hospitality invitation that they would wish to attend, including the nature of the event and the identity of the person or organisation offering the hospitality, to their line manager as soon as the invitation is received.

Failure to report the invitation, and then to attend the event without permission, constitutes a disciplinary offence and will be dealt with in accordance with SMARTSEC FACILITIES SERVICES LTD’s disciplinary procedure.  Depending on the gravity of the offence, it may be treated as gross misconduct and could render the employee liable to summary dismissal.

If SMARTSEC FACILITIES SERVICES LTD determines that the corporate hospitality is lavish, extraordinary or excessive, the employee will be required to send the person or organisation offering the hospitality a polite letter thanking them for their kind invitation but declining it and explaining that it is SMARTSEC FACILITIES SERVICES LTD’s policy that employees should limit their participation in corporate hospitality.

In cases where SMARTSEC FACILITIES SERVICES LTD determines that the hospitality is genuine, proportionate and reasonable, the employee may, at their line manager’s discretion, be permitted to attend the event (subject to any agreement relating to time off work where the event is taking place during normal working hours).

It is the policy of SMARTSEC FACILITIES SERVICES LTD to ensure that all our activities are, so far as is possible, sensitive to all issues relating to the protection of the environment.

Environmental considerations are taken into account in all purchasing decisions.  All plant, equipment and materials used by SMARTSEC FACILITIES SERVICES LTD are, to the best of our knowledge environmentally friendly.

Good Housekeeping is the duty of all employees and contractors; waste material is disposed of responsibly.

All Company vehicles are run on unleaded fuel or diesel.

This policy is under constant review and whenever possible more environmentally friendly products or methods of work will be introduced.

SIGNED BY THE EXECUTIVE WITH OVERALL RESPONSIBILITY FOR ENVIRONMENTAL ISSUES:

Rahib Siddiq

Managing Director

Reviewed Date March 2019

Next review date March 2020

Social Media Definition

Social media is an interactive online media that allows users to communicate instantly with each other or to share data in a public forum.  It includes social and business networking websites such as Facebook, MySpace, Bebo, Twitter and LinkedIn.  Social media also covers video and image sharing websites such as YouTube and Flickr, as well as personal weblogs (“blogs”).  This is a constantly changing area with new websites being launched on a regular basis and therefore this list is not exhaustive.

This policy applies in relation to any social media that employees may use.

Use of Social Media at Work

Option 1 – Ban on social media use at work

[Employees are not permitted to log on to social media websites or to keep a personal weblog (“blog”) using SMARTSEC FACILITIES SERVICES LTD’s IT systems and equipment at any time.  This includes laptop and hand-held computers or devices distributed by SMARTSEC FACILITIES SERVICES LTD for work purposes. SMARTSEC FACILITIES SERVICES LTD has added most of the websites of this type to its list of restricted websites. Where employees have their own computers or devices, such as laptops and hand-held devices, they must limit their use of social media on their own equipment to outside their normal working hours (for example, during lunch breaks).

However, employees may be asked to contribute to SMARTSEC FACILITIES SERVICES LTD’s own social media activities during normal working hours, for example by writing Company blogs or newsfeeds or managing a Facebook account or running an official Twitter or LinkedIn account for SMARTSEC FACILITIES SERVICES LTD.  Employees must be aware at all times that, while contributing to SMARTSEC FACILITIES SERVICES LTD’s social media activities, they are representing SMARTSEC FACILITIES SERVICES LTD.]

OR

Option 2 – Limited social media use at work

[Employees are only permitted to log on to social media websites or to keep a personal weblog (“blog”) using SMARTSEC FACILITIES SERVICES LTD’s IT systems and equipment outside their normal working hours (for example, during lunch breaks or before the working day has started or after the working day has finished) and this must not under any circumstances interfere with their job duties or have a detrimental effect on their productivity.  This includes laptop and hand-held computers or devices distributed by SMARTSEC FACILITIES SERVICES LTD for work purposes.  SMARTSEC FACILITIES SERVICES LTD nevertheless reserves the right to restrict access to any of these types of websites at any time.  Where employees have their own computers or devices, such as laptops and hand-held devices, again they must limit their use of social media on their own equipment to outside their normal working hours.

However, employees may be asked to contribute to SMARTSEC FACILITIES SERVICES LTD’s own social media activities during normal working hours, for example by writing Company blogs or newsfeeds or managing a Facebook account or running an official Twitter or LinkedIn account for SMARTSEC FACILITIES SERVICES LTD.  Employees must be aware at all times that, while contributing to SMARTSEC FACILITIES SERVICES LTD’s social media activities, they are representing SMARTSEC FACILITIES SERVICES LTD.]

OR

Option 3 – Open social media use at work

[SMARTSEC FACILITIES SERVICES LTD permits employees to make reasonable and appropriate use of social media websites or to keep a personal weblog (“blog”) using SMARTSEC FACILITIES SERVICES LTD’s IT systems and equipment or their own computers or devices, such as laptops and hand-held devices, during their normal working hours, provided this does not significantly interfere with their job duties or have a detrimental effect on their productivity.  Employees must not spend an excessive amount of time while at work accessing social media websites.  No more than [15 minutes] per day spent on social media websites during normal working hours is deemed acceptable.

Employees may also be asked to contribute to SMARTSEC FACILITIES SERVICES LTD’s own social media activities during normal working hours, for example by writing Company blogs or newsfeeds or managing a Facebook account or running an official Twitter or LinkedIn account for SMARTSEC FACILITIES SERVICES LTD.  Employees must be aware at all times that, while contributing to SMARTSEC FACILITIES SERVICES LTD’s social media activities, they are representing SMARTSEC FACILITIES SERVICES LTD.]

Company’s social media activities

Where employees are authorised to contribute to SMARTSEC FACILITIES SERVICES LTD’s own social media activities as part of their job duties, for example for marketing, promotional and recruitment purposes, they must adhere to the following rules:

• Use the same safeguards as they would with any other type of communication about SMARTSEC FACILITIES SERVICES LTD that is in the public arena.

• Ensure that any communication has a purpose and a benefit for SMARTSEC FACILITIES SERVICES LTD.

• Obtain permission from their line manager before embarking on a public campaign using social media.

• Request their line manager to check and approve content before it is published online.

• Follow any additional guidelines given by SMARTSEC FACILITIES SERVICES LTD from time to time.

The social media rules set out below also apply as appropriate.

Social media rules

SMARTSEC FACILITIES SERVICES LTD recognises that many employees make use of social media in a personal capacity outside the workplace and outside normal working hours.  While they are not acting on behalf of SMARTSEC FACILITIES SERVICES LTD in these circumstances, employees must be aware that they can still cause damage to SMARTSEC FACILITIES SERVICES LTD if they are recognised online as being one of its employees.  Therefore, it is important that SMARTSEC FACILITIES SERVICES LTD has strict social media rules in place to protect its position.

When logging on to and using social media websites and blogs at any time, including personal use on non-Company computers outside the workplace and outside normal working hours, employees must not:

• Other than in relation to SMARTSEC FACILITIES SERVICES LTD’s own social media activities or other than where expressly permitted by SMARTSEC FACILITIES SERVICES LTD for business networking websites such as LinkedIn, publicly identify themselves as working for SMARTSEC FACILITIES SERVICES LTD, make reference to SMARTSEC FACILITIES SERVICES LTD or provide information from which others can ascertain the name of SMARTSEC FACILITIES SERVICES LTD.

• Other than in relation to SMARTSEC FACILITIES SERVICES LTD’s own social media activities or other than where expressly permitted by SMARTSEC FACILITIES SERVICES LTD for business networking websites such as LinkedIn, write about their work for SMARTSEC FACILITIES SERVICES LTD – and, in postings that could be linked to SMARTSEC FACILITIES SERVICES LTD, they must also ensure that any personal views expressed are clearly stated to be theirs alone and do not represent those of SMARTSEC FACILITIES SERVICES LTD.

• Conduct themselves in a way that is potentially detrimental to SMARTSEC FACILITIES SERVICES LTD or brings SMARTSEC FACILITIES SERVICES LTD or its employees, clients, customers, contractors or suppliers into disrepute, for example by posting images or video clips that are inappropriate or links to inappropriate website content.

• Other than in relation to SMARTSEC FACILITIES SERVICES LTD’s own social media activities or other than where expressly permitted by SMARTSEC FACILITIES SERVICES LTD for business networking websites such as LinkedIn, use their work e-mail address when registering on such sites or provide any link to SMARTSEC FACILITIES SERVICES LTD’s website.

• Allow their interaction on these websites or blogs to damage working relationships with or between employees and clients, customers, contractors or suppliers of SMARTSEC FACILITIES SERVICES LTD, for example by criticising or arguing with such persons.

• Include personal information or data about SMARTSEC FACILITIES SERVICES LTD’s employees, clients, customers, contractors or suppliers without their express consent (an employee may still be liable even if employees, clients, customers, contractors or suppliers are not expressly named in the websites or blogs as long as SMARTSEC FACILITIES SERVICES LTD reasonably believes they are identifiable) – this could constitute a breach of the Data Protection Act 1998 which is a criminal offence.

• Make any derogatory, offensive, adverse, discriminatory, untrue, negative, critical or defamatory comments about SMARTSEC FACILITIES SERVICES LTD, its employees, clients, customers, contractors or suppliers, or any comments which might reasonably be considered to insult, damage or impugn SMARTSEC FACILITIES SERVICES LTD’s or their reputation or character (an employee may still be liable even if SMARTSEC FACILITIES SERVICES LTD, its employees, clients, customers, contractors or suppliers are not expressly named in the websites or blogs as long as SMARTSEC FACILITIES SERVICES LTD reasonably believes they are identifiable).

• Make any comments about SMARTSEC FACILITIES SERVICES LTD’s employees that could constitute unlawful discrimination, harassment or cyber-bullying contrary to the Equality Act 2010 or post any images or video clips that are discriminatory or which may constitute unlawful harassment or cyber-bullying – employees can be personally liable for their actions under the legislation.

• Disclose any trade secrets or confidential, proprietary or sensitive information belonging to SMARTSEC FACILITIES SERVICES LTD, its employees, clients, customers, contractors or suppliers or any information which could be used by one or more of SMARTSEC FACILITIES SERVICES LTD’s competitors, for example information about SMARTSEC FACILITIES SERVICES LTD’s work, its products and services, technical developments, deals that it is doing, future business plans and staff morale.

• Breach copyright or any other proprietary interest belonging to SMARTSEC FACILITIES SERVICES LTD, for example, using someone else’s images or written content without permission or failing to give acknowledgment where permission has been given to reproduce particular work – if employees wish to post images, photographs or videos of their work colleagues or clients, customers, contractors or suppliers on their online profile, they should first obtain the other party’s express permission to do so.

Employees must remove any offending content immediately if they are asked to do so by SMARTSEC FACILITIES SERVICES LTD.

Work and business contacts made during the course of employment through social media websites and which are added to personal social networking accounts amount to confidential information belonging to SMARTSEC FACILITIES SERVICES LTD and accordingly SMARTSEC FACILITIES SERVICES LTD may ask for them to be surrendered on termination of employment.

Employees should remember that social media websites are a public forum, even if they have set their account privacy settings at a restricted access or “friends only” level, and therefore they should not assume that their entries on any website will remain private or confidential.

Employees must also be security conscious when using social media websites and should take appropriate steps to protect themselves from identity theft, for example by setting their privacy settings at a high level and restricting the amount of personal information they give out, such as date and place of birth, schools attended, family names and favourite football team.  This information may form the basis of security questions and/or passwords on other websites, such as online banking.

Should employees observe inaccurate information about SMARTSEC FACILITIES SERVICES LTD on any web sources of information, they should report this to their line manager in the first instance.

Social Media References

Where employees (or ex-employees) have set up personal profiles on business networking websites such as LinkedIn, these websites may include the facility for the user to request their contacts or other users to provide them with open recommendations, endorsements or references which are then published on their personal profile web pages for other contacts or connections, or prospective contacts or connections, to read.  As these could potentially be construed as open references given on behalf of SMARTSEC FACILITIES SERVICES LTD, employees are prohibited from providing these types of recommendations, endorsements or references online to or for the benefit of other employees or ex-employees without the prior permission of their line manager.

If these types of recommendations, endorsements or references are requested online by clients, customers, contractors, suppliers or other Company-related business connections, employees should refer such requests to their line managers.

Social Media Monitoring

SMARTSEC FACILITIES SERVICES LTD reserves the right to monitor employees’ use of social media on the internet, both during routine audits of the computer system and in specific cases where a problem relating to excessive or unauthorised use is suspected. The purposes for such monitoring are to:

• Promote productivity and efficiency.

• Ensure the security of the system and its effective operation.

• Ensure there is no unauthorised use of SMARTSEC FACILITIES SERVICES LTD’s time, for example to check that an employee has not been spending an excessive amount of time using social media websites for non-work related activity when they should be working.

• Ensure that inappropriate, restricted or blocked websites are not being accessed by employees.

• Ensure that all employees are being treated with respect and dignity at work, by discovering and eliminating any material that is capable of amounting to harassment contrary to the Equality Act 2010.

• Ensure there is no breach of commercial confidentiality.

SMARTSEC FACILITIES SERVICES LTD reserves the right to restrict, deny or remove internet access, or access to particular social media websites, to or from any employee.

Contravention of this policy

Failure to comply with any of the requirements of this policy is a disciplinary offence and may result in disciplinary action being taken under SMARTSEC FACILITIES SERVICES LTD’s disciplinary procedure. Depending on the seriousness of the offence, it may amount to gross misconduct and could result in the employee’s summary dismissal.