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G4S Secure Solutions (UK)

Uncontrolled if downloaded or printed

Document ID number: SSCHS-POL-001 Version Number 015 Version Date: Dec -15

Document classification ISSUED of 22




Page Blank





Contents

Page Blank ........................................................................................................................ 2

1. Purpose ................................................................................................................... 5

2. Scope ...................................................................................................................... 5

3. Organisational Arrangements – Responsibilities...................................................... 5

3. Key Personnel ......................................................................................................... 6

4. Employer’s Duties ................................................................................................... 6

5. Management Responsibility .................................................................................... 7

6. Employee Responsibility ......................................................................................... 8

7. Golden Rules .......................................................................................................... 9

8. Health and Safety Assistance .................................................................................. 9

8. Safety Objectives .................................................................................................. 10

9. Planning and Organisation .................................................................................... 10

10. Continual Improvement ......................................................................................... 10

11. Control and Monitoring .......................................................................................... 11

12. Information and Training ........................................................................................ 11

13. Stakeholders and Interested Parties ...................................................................... 12

14. Communication ..................................................................................................... 12

15. Procedures ............................................................................................................ 12

16. Safety Representation ........................................................................................... 13

17. Regional / Sector Health and Safety Committees .................................................. 13

18. National Health and Safety Committee .................................................................. 14

19. Risk Assessment ................................................................................................... 14

20. Personal Protective Equipment (PPE) ................................................................... 15

21. Workplace Injury Reporting and Investigation ........................................................ 15

22. Serious and Imminent Danger ............................................................................... 16

23. Ionising Radiations Regulations ............................................................................ 17

24. Statistical Analysis of Collected Data ..................................................................... 17

25. Data Protection ..................................................................................................... 17

26. Insurance .............................................................................................................. 17

27. Company Liability .................................................................................................. 18





28. Use of the Company Discipline Code .................................................................... 18

29. Safety Rules .......................................................................................................... 18

30. Suppliers and Contractors ..................................................................................... 18

31. Approved Contractors ........................................................................................... 19

32. Customers ............................................................................................................. 19

33. Visitors .................................................................................................................. 19

34. Management Review ............................................................................................ 19

35. Review and Amendment of This Policy ................................................................. 19

36. Summary ............................................................................................................... 20

37. Company Organisation for Health & Safety ........................................................... 21





Health and Safety Policy

1. Purpose

This document defines the policy of G4S Secure Solutions (UK) Ltd on matters relating to

health and safety and details the responsibilities and the organisation for implementing and

monitoring the policy.

Because health and safety is fundamental to the effective and profitable running of the

company and the consequential wellbeing of all its employees, this Policy applies to all

employees; be they directors, managers, administrative staff or customer facing staff. All

have duties and obligations in law and under this policy.

Detailed statements reflecting legislation are contained in the following paragraphs.

Instruction and guidance for employees, covering a range of activities can be found on the

company’s Intranet ‘Link Up’ found at the url shown in the footnote1. This site contains the

G4S Secure Solutions (UK)’s Safety Management System Manual, detailed procedures and

processes, documents or policies specific to Site/Activity/Assignment which are issued to the

relevant Manager and their subordinates and also in relevant Safety Instructions.

The current version of any document within the company’s health and safety management

system is that which is currently located on Link Up. Existing arrangements will be utilised

for the review of specific events, with a view to the development of corrective or preventative

actions.

This Policy can be found on Link up at:

http://linkup/Interact/Pages/Content/Attachment.aspx?id=78

and it can also be obtained by all employees on ESS at:

https://ess.myg4s.com/servlet/CheckSecurity/JSP/sse_g7/sse_g7_p3_det.jsp?id=112.00000000

2. Scope

This policy is applicable to all businesses forming G4S Secure Solutions (UK), including the

following legal entities:

G4S Aviation Services (UK) Ltd Reg. No. 02837136 G4S Security Services (UK) Ltd Reg. No. 02380900 G4S Gurkha Services (UK) Ltd Reg No. 06304482 And G4S Fire and Security Systems, a trading name of G4S Secure Solutions (UK) Ltd.

3. Organisational Arrangements – Responsibilities

As a responsible company and employer, G4S recognises its health and safety

responsibilities and duties as defined under the Health and Safety at Work etc. Act 1974 and

1 http://linkup/Interact/Pages/Section/MainTwoColumnsLeft.aspx?homepage=0&section=1980

http://linkup/Interact/Pages/Content/Attachment.aspx?id=78

https://ess.myg4s.com/servlet/CheckSecurity/JSP/sse_g7/sse_g7_p3_det.jsp?id=112.00000000

http://linkup/Interact/Pages/Section/MainTwoColumnsLeft.aspx?homepage=0&section=1980





subsequent Acts, Regulations, Approved Codes of Practice (ACOP’s) and where applicable,

relevant industry standards, such as BS 7499.

To help attain and maintain appropriate standards of health, safety and welfare for its

employees and workers, the company seeks to always work in accordance with the

internationally recognised health and safety management standard OHSAS18001 for which

the company was first certificated in 2009 [certificate number 16005].

3. Key Personnel

In recognition of these duties and responsibilities, the HR Director has been appointed the

Executive Director with especial responsibility for Health & Safety and will be responsible for

ensuring that health and safety is given due prominence within Board discussion and

decisions and for ensuring that the company’s Board allocates adequate resources for

health and safety throughout the company. The HR Director will ensure that arrangements

are in place to keep the Company’s employees updated on changes in relevant legislation,

Regulations and appropriate British Standards affecting them and to ensure compliance with

same.

The Company’s nominated Health and Safety Advisor (The National Health, Safety &

Environmental Advisor [NHSEA]) will be available to advise on such matters as changes in

requirements of health and safety legislation, the performance and methods of compliance

and the use of best practises within the industry.

4. Employer’s Duties

It will always be the company’s intention to comply with all its legal obligations, in particular

its duties under the Health and Safety at Work etc Act 1974 and the Management of Health

and Safety at Work Regulations 1999. In particularly, so far as is reasonably practicable, it

will eliminate significant risks to all employees at work and will also ensure that all necessary

arrangements are in place to carry out this and other duties under the regulations,

principally: -

a. Procedures for planning, controlling and reviewing safety measures;

b. Appointment of suitably qualified ‘competent persons’;

c. Evacuation procedures in cases of serious and imminent danger e.g. fire, explosion etc.;

d. Information to employees regarding these arrangements and procedures; and

e. Appropriate health and safety training of employees.

To assist management in ensuring that it is both aware of what legislation is applicable and

to what extent, the company’s Health and Safety Advisor will ensure that systems are in

place to alert the business to changes in applicable legislation and the issue of new

legislation. To meet the above requirement, the company’s NHSEA currently subscribes to

the Health and Safety Executive’s weekly e-mail update bulletin, available from hsegeneral-

mailto:[email protected]





[email protected], the HAS’s equivalent and other electronic and printed

material.

The NHSEA will also ensure that a register of Applicable Legislation is maintained. This

may be produced internally or by external consultants.

5. Management Responsibility

Managers are responsible for ensuring that this safety policy is implemented within their own

departments or spheres of operation. Managers must monitor their workplace to ensure that

safe conditions are maintained. Where risks are identified the manager must ensure that

these are rectified, so far as is reasonably practicable. Management duties include the

following:

ensure appropriate levels of resource are allocated to H&S matters;

provide and maintain a safe place of work, safe systems of work, safe equipment and

machinery for work and a safe work environment;

provide their staff with such information and instruction as may be necessary to ensure

the health and safety at work of their employees and also ensure compliance with

relevant legislation;

ensure that where staff use equipment, they are suitably trained to use that equipment

safely;

ensure that where staff are provided with personal protective equipment [PPE], they are

trained in how to use or wear it correctly and safely, how to care for their equipment and

that staff are aware of how to request / order replacement equipment;

understand and implement all company health and safety policies and procedures

relevant to their area of responsibility;

ensure new employees are given appropriate induction training to include relevant local

(and where applicable), national emergency, first aid and accident reporting procedures;

to allow their staff to join trade unions and become Union Safety Representatives. If they

belong to a union with which the company has a Recognition Agreement, to then stand

for election and attend Consultation Committee meetings;

ensure safety and absence of health risks in connection with the use, handling, storage

and transport of articles and substances;

identify, manage and communicate, by means of the risk assessment process, hazards

associated with their staff’s working environment;

carry out any health and safety assessments, audits and inspections as required;

be responsible for good housekeeping and ensure that defects and unsafe conditions are

promptly reported and rectified;

mailto:[email protected]





appoint competent personnel to ensure compliance with statutory duties;

provide employees with health surveillance, where necessary; and

to promote awareness and understanding of health and safety throughout their

workforce;

6. Employee Responsibility

All employees of the Company must agree, as a term of their contract of employment, to

comply with their individual duties under sections 7 and 8 of the Health and Safety at Work

Act 1974 and Regulation 14 of the Management of Health and Safety at Work Regulations

1999 in that they will:

Make themselves familiar with and conform to this Health and Safety Policy and relevant

procedures at all times;

take reasonable care of their own health and safety;

consider the safety of other persons who may be affected by what they do or don’t do;

work in accordance with information and training provided;

refrain from intentionally or recklessly interfering with anything that has been provided for

health and safety purposes;

immediately report any hazardous defects in plant and equipment, or shortcomings in

existing safety arrangements to their manager or another responsible person;

not to undertake any task for which authorisation and/or training has not been given;

co-operate with G4S Secure Solutions to allow them to carry out their health and safety

duties towards the employee;

report all workplace injuries to company employees, to the company’s Control Room(s).

Wherever possible, this should be as soon after the incident as possible and by

telephone;

to report all serious threats of violent aggression or injury to themselves or other

company employees;

never put themselves in a situation that could cause injury to themselves or others; and

inform any visitor / contractor under their control of emergency procedures and relevant

hazards.

Failure by an employee to comply with the Company’s Health & Safety Policy or associated

procedures may result in disciplinary action. Serious breaches of this Health and Safety

Policy, company safety rules or safety procedures by an employee will be viewed as gross

misconduct and may result in summary dismissal.





7. Golden Rules

The company has introduced 12 Golden Rules (see figure 6. below) which are applicable

globally, across all activities and applicable to all employees and those who undertake

services on our behalf. Breaching any of the Golden Rules will have consequence.

Fig 1.0 G4S Golden rules of safety

Golden Rule 1: Review all risks associated with each task before starting

Golden Rule 2: Understand your safety responsibilities and report all unsafe acts and conditions

Golden Rule 3: Use appropriate Personal Protective Equipment (PPE)

Golden Rule 4: Obtain authorisation before entering a confined space

Golden Rule 5: Treat every firearm as loaded

Golden Rule 6: Check your vehicle before driving

Golden Rule 7: Always wear a seat belt

Golden Rule 8: Do not speed

Golden Rule 9: Always wear a helmet and high visibility equipment when riding a motorcycle

Golden Rule 10: Do not work or drive under the influence of alcohol or drugs

Golden Rule 11: Take a short break if required

Golden Rule 12: Never use a hand-held mobile telephone whilst driving

8. Health and Safety Assistance

Competent person(s) have been appointed to assist the company in meeting its health and

safety obligations. These people have sufficient knowledge and information to ensure that

appropriate advice and guidance can be given to Directors, managers and staff; to give

guidance on how statutory provisions are to be met and to monitor adherence to the safety

policy.

They are: -

The National Health and Safety Advisor (NHSEA)





The H&S Manager within G4S Fire & Security Systems

The above competent people are supported by operational managers and staff with formal

H&S qualifications, and individuals within specific higher risk contracts, that have a

dedicated contract specific responsibility.

8. Safety Objectives

In recognition of the company’s declared Values and in particular “Performance - we

challenge ourselves to improve performance year-on-year and to create long-term

sustainability” and the “Safety First” value:

Due to the nature of some of the services provided by the company, it must be appreciated

that risk cannot be entirely removed, but the company will always endeavour to minimise

those risks and to that end, a year on year reduction in RIDDOR Reportable injury frequency

rates and in particular the most serious RIDDOR Specified (Major) Injury frequency rates will

be the company’s overarching H&S objective. The company’s primary H&S targets are:

To reduce the violent injury specified injury frequency rate by 10% per annum

To reduce the slip/trip/fall specified injury frequency rate by 10% per annum

Success against these targets will be published monthly in the Management Systems

Review Group report which is issued to the Groups members and the EXCOM.

The company will also publish leading and lagging indices, which are published to the

management and EXCOM. The measurement period for H&S key performance indicators

[KPI’s] will be a rolling 12 month period.

9. Planning and Organisation

The Company has established both a management structure and arrangements for the

effective delivery of this Policy through its Operational and Non Operational Management

structures. Managers will be provided with instruction training and information on the

systematic approach to implementing the company’s Safety Management System and this

Policy.

The company will have in place appropriate systems and procedures to assess and control

risks to which employees and other people may be exposed to, due to the development or

deployment of new or novel products and services, or through the deployment of services at

new locations.

10. Continual Improvement

The company will always strive to reduce and if possible eliminate adverse events which

affect our employees, people who work for us or those who might be affected by our

activities. To this end, all adverse events will be investigated and wherever reasonably

practicable the identified potential improvements (designed to eliminate repetition) will be





implemented locally and if appropriate, published to the wider business via the H&S Update

process. This may include being published internationally via the Group Head of Safety.

Also, where technological change may allow improvements in safety or health, they will be

reviewed for suitability and if practicable implemented.

11. Control and Monitoring

Standards will be established within this Policy, other policies or procedures for relevant

environments and activities.

Performance will be measured against those standards and if shortcomings are revealed,

measures will be taken to ensure these are remedied and that the organisation learns from

the experience and continues to improve its performance.

Safety Representatives will be consulted as part of this process.

To improve the accountability and awareness of H&S within operational units, performance

indicators [both leading and lagging] will be developed and used within the company’s

normal operational / commercial review process – the Monthly Business Review.

12. Information and Training

All employees will be provided with comprehensible information on the health, safety and

welfare matters that are relevant to their duties and place of work. Training will be provided

for all employees to enable them to carry out their duties in a safe and responsible manner.

The HR Director will ensure that processes are in place to ensure all personnel who would

require information on the range of hazards identified are apprised of the necessary detail

prior to the commencement of work with the Company. This will include contractors and any

person who may lawfully enter onto Company premises.

All employees will undertake appropriate induction training upon commencing employment

with the company and such induction training will include relevant health and safety training.

Assignment specific training requirements will be detailed within site specific training

matrices as part of the Assignment Instructions.

Operational Management Training

All new operational managers on either joining the company or on taking up their first

managerial position are required to successfully complete the company’s mandatory

Management Health & Safety Training course.

New managers are also expected to undertake and where necessary, pass, any additional

safety training identified as required in their Job Descriptions. This additional training will be

required due to the nature of risks present at the sites they will be expected to manage and

will be in line with the relevant syllabi of either the Institute of Safety and Health (IOSH), the

British Safety Council (BSC) or the National Examination Board in Occupational Safety and





Health (NEBOSH). The specific level of training required and the course provider will be

determined by the company's NHSEA.

Managers will also be required to undertake relevant H&S e-Learning modules from the

prevailing provider. The range of modules required will be defined for the specific

managerial role, by the NHSEA.

13. Stakeholders and Interested Parties

The company has procedures in place to allow this policy and other information or

documentation to be made available to people or organisations requesting it.

The principle route for requests for information will be via the company’s Communications

Department (see process SSHSE-PRO-019).

Where the communication from an interested party is in the form of a complaint, the NHSEA

will ensure that the complaint is resolved within a reasonable period of time [bearing in mind

the severity of the issue], in line with the company Complaints Handling Procedure

(Standard Company Procedure SSCAD-SCP-009). They will maintain a register of such

complaints, detailing whether corrective or preventive action was required, if it was – what

was done and the date the issue was closed off.

14. Communication

The principle route for communication and implementation of the Company’s Health and

Safety Policy will be through the Company’s Health and Safety Committees.

This Policy and the Company’s Health and Safety Policy Statement will be available on the

company’s Intranet and the employee portal, ESS. The Policy Statement will be displayed in

prominent positions in all Company offices. Further, it will either be included within site

based Assignment Instructions or by other means brought to the attention of all employees

working on client sites or property.

15. Procedures

The current system for on-going formal communication and consultation in relation to health

and safety matters between management and the employee, is via the company’s Safety

Committees, but health, safety or welfare issues of an urgent nature identified by employees

should be raised directly with the employee’s line manager.

Staff side members of the company’s Local or National Negotiating Committees, within

which the H&S Committees meet, or any of their members will provide an avenue through

which any health and safety concerns identified by employees may be raised for more formal

discussion, whether they emanate from risk assessments or other routes.

Whilst the normal communication channel will take place between senior and line

management, the Company has detailed the NHSEA as the senior manager with special

responsibility for the implementation and operation of the risk assessment process.





The company’s NHSEA will be provided with the necessary training and resources to ensure

the proper operation of this process.

16. Safety Representation

G4S Secure Solutions (UK) Ltd. has a recognition agreement with the GMB Union. When

referring to ‘Safety Representatives’ or ‘Representatives of employee safety’ this policy

refers to both Union appointed Safety Representatives and company appointed

representative but the phrase Safety Representative will be used throughout this document,

and will be construed to mean either.

The Company undertakes to consult with safety representatives over issues relating to

health, safety and welfare and to provide the information they require in order to carry out

their functions.

Safety representatives are required to make representation on potential hazards, dangerous

occurrences and on general matters affecting the health and safety at work of the groups of

employees they represent. They also represent these groups in consultation with health and

safety inspectors.

Safety representatives are required to give the Company reasonable notice of their intention

to carry out inspections, to provide written reports following such inspections and to follow

Company procedures when disputes over health and safety issues arise.

Safety committees will meet regularly and will consist of both employer and employee

representatives and will be chaired by a person with executive power who can act upon the

decisions reached by the committee.

17. Regional / Sector Health and Safety Committees

The aims of the health and safety committees are; to improve the company’s health and

safety performance, to reduce the number of injuries and accidents, reduce the number and

severity of risks to which employees are exposed and to encourage and foster a positive

safety culture with all staff committed to working safely.

Issues with company wide implications raised at Local Negotiating Committees (LNC’s) will

be brought to the attention of appropriate line management via the NHSEA.

LNC’s will meet at their constituted frequency, but not less than twice per year and additional

members may be co-opted as and when necessary.

Minutes of meetings will be recorded and shall be made available to employees within the

Region / Sector and a copy shall be sent to the NHSEA.

The senior executive manager of the relevant health and safety committee will be charged

with responsibility for implementing changes that the Health and Safety Committee

collectively decides upon.





18. National Health and Safety Committee

The company’s National Health and Safety Committee will be held as part of the National

Negotiating Committee (NNC) and will meet in accordance with its constitution. The

committee will meet at least once per year and additional members may be co-opted as and

when necessary.

The aims and objectives of the NNC are detailed in the formal recognition agreement

reached between G4S and the GMB, a copy of which can be obtained on request.

Minutes of meetings will be recorded and shall be made available to employees and a copy

shall be sent to the NHSEA.

19. Risk Assessment

The company will ensure risk assessments are carried out on the tasks and duties

undertaken by its employees, workers and canine operatives. Where significant risks are

identified, these are to be recorded. Where only trivial risks are identified, the act of

assessment is to be recorded but the details of the assessment need not be.

Risk assessments are to be carried out by competent persons who may be client staff,

external consultants, company Supervisors, Managers or in some instances front line staff

e.g. Plant Protection Officers carrying out dynamic risk assessments while tackling a fire but

the primary responsibility for ensuring that assignments have both suitable and sufficient risk

assessments rests with Operational Management who will ensure that their management

teams undertake those assessments that are within their competence.

The company will ensure that it has appropriate and adequate resources, procedures &

processes in place to allow a suitable assessment of risk to be carried out; to ensure

assessments are appropriately reviewed and when / where required, the identified controls

are implemented.

Where required or necessary, the company will co-operate with its customers, statutory duty

holders or others in the assessment of risks to protect the safety of its own workers and

others who may be effected by its activities. The company expects and requires customers

to reciprocate and assist the company, when required to do so, to eliminate or reduce risk

exposure.

All controls identified by risk assessment for the elimination or reduction of risk will be

implemented by the company (so far as it is reasonably practicable to do so) to maintain the

health, safety and welfare of its workers and others.

Generic risk assessments may be used for Patrol & Response (P&R) assignments, where

significant site specific hazards have not been identified or reported. The standard operating

methods of P&R are such that typically encountered significant hazards are managed and

controlled by routine, so long as workers follow those methods at all times.





Risk assessments applicable to the duties undertaken within some contracts may be based

upon a generic template, but shall be modified within a reasonable period of time to include

site specific information and significant hazards & risks.

Where generic risk assessments are utilised they shall be reviewed for continuing

applicability and suitability at least annually and all such reviews will be recorded.

20. Personal Protective Equipment (PPE)

The company will provide PPE where it has been identified as required by company risk

assessment, client rule or subordinate company policy. Prior to the issue of some types of

PPE, the requesting manager must consult with the NHSEA (see risk assessment 09-05-01

PPE).

Canine units will be supplied with PPE, where risks of harm exist which cannot be managed

to a reasonable level by other means.

21. Workplace Injury Reporting and Investigation

In recognition of its duties (in the UK) under the Reporting of Injuries, Diseases and

Dangerous Occurrences (RIDDOR) Regulations, the Company has a system (see process

SSHSE-PRO-005-006) for reporting incidents and injuries, both internally and to relevant

enforcing authorities.

The defined process requires the employee, their colleagues or Supervisor / Manager to

report any injury to the Company’s National Control Centre (NCC). Once provided with the

required information, the NCC will escalate the incident to the necessary level of

management, according to predefined Control Room Escalation Procedures.

Failure by employees to report required incidents or for Control Room staff to incorrectly

follow their escalation procedures may be viewed as a breach of this Policy and may result

in disciplinary action. Serious breaches of this Policy may be viewed by the Company as

gross misconduct and may result in summary dismissal.

To comply with the Company’s statutory duty to maintain an Accident Book (BI 510), the

NCC will record workplace injury information in an appropriate format and make it available

for inspection by Inspectors of the HSE or other enforcing authorities.

The company will also maintain systems and procedures to allow employees to report near

miss and threat of violence, incidents.

It is the responsibility of line management to investigate injuries or near miss incidents to

their staff. Dependent upon the severity / seriousness of an incident, an investigation team

may be set up by the company’s NHSEA, which will operate in accordance with the Incident

Investigation Procedure (SSCHS-SOP-001-003).





Loaned Staff

In instances where staff are loaned between operating units or managers and are injured, it

is the responsibility of the manager with the immediate day to day control of the loaned

employee (at the time of injury) who will have prime responsibility for reporting and

investigating the injury or near miss.

Absent Managers

When a manager is covering the duties of an absent colleague e.g. they are on leave, it is

the responsibility of the manager covering the duty to report and investigate any injury to an

employee of the absent manager.

Fatalities & Life Threatening Injuries

If a fatality were to occur, it is imperative that the company’s escalation procedures are

followed (see process SSHSE-PRO-018-001), to ensure that;

Directors of the company are made aware of the incident at the earliest opportunity;

the Company’s crisis communications process is followed;

that the Group General Executive Council (GEC) is advised of the incident within 24

hours (by the Regional MD) and as the investigation develops, the corrective and

preventative measures put in place;

appropriate and necessary support is provided promptly to those affected by the

incident.

The same shall apply to incidents that although not resulting in a fatality, result in life

changing physical or psychiatric injury.

These processes will apply equally to incidents which involve employees, workers and

others, if potentially caused by G4S’ staff or actions.

Failure to report and / or investigate incidents or injuries may result in the application of the

company’s discipline code.

Canine Security

Incidents which result in injury to any security dog working for the company (either owned or

contracted) shall be fully investigated by the Canine Security Business and a copy of their

report will be forwarded to the NHSEA.

22. Serious and Imminent Danger

The Company recognises its responsibilities under Regulation 8 of the Management of

Health and Safety at Work Regulations, in that it will have appropriate procedures

established and in place to be followed in the event of serious and imminent danger, within

premises where the Company is the duty holder.





The Company expects and requires it’s Customers and Clients, on whose premises and

property our employees work, to also have appropriate procedures in place and (where

applicable) to periodically test these.

In situations where identified risks of serious or imminent danger remain unresolved, they

will be escalated to successively higher levels of management (within the Company and its

Customer) in an attempt to reach agreement on appropriate controls. Where this process

does not result in agreement being reached, the issue will be raised at Executive Board level

via the Company’s National Health & Safety Advisor and the HR Director.

Where necessary, the Board may decide to terminate contracts if the residual risks are found

to be intolerable.

23. Ionising Radiations Regulations

The Company recognises its obligations and duties under the Ionising Radiations

Regulations. The Company has consulted a Radiological Protection Advisor, will appoint

trained local Radiation Protection Supervisors and provide training and information for staff.

24. Statistical Analysis of Collected Data

To assist the company in learning from adverse incidents, collected data will be analysed to

identify trends, to assist management in making informed decisions, to support the general

commercial activities of the company e.g. to answer health and safety questions within

tenders, to provide information to enforcing authorities, stakeholders and other organisations

or bodies for whom it would be beneficial for the company to cooperate with.

The company currently classifies adverse incident severity in accordance with guidelines

published by the HSE and is in line with RIDDOR reporting requirements.

25. Data Protection

Where analytical data or information may be passed onto third parties, any personal data /

information which would allow that party to identify individuals [from the information / data

provided] will be deleted, removed or rendered unreadable in whatever format the analysis

or data would be presented to the third party.

The company will ensure that relevant sections of the Information Commissioner’s

publication “Employment Practices Data Protection Code” are followed.

26. Insurance

In recognition of its statutory and common law duties, the Company has taken out insurance,

with an approved insurer, against liability for death, injury and/or disease suffered by any of

its employees and arising out of and in the course of employment, provided that it was

caused by the negligence and/or breach of statutory duty on the part of the Company.

Copies of the current Certificate of Employers Liability Insurance shall be prominently

displayed within company offices so as to be available for inspection at all reasonable times





by employees and Health and Safety Inspectors. The Certificate shall also be available on

the Company’s Intranet and also via the employee portal ESS.

27. Company Liability

Prime responsibility for health and safety lies with the Regional Managing Director of the

Company and the EXCOM and the Company regards itself bound by any acts and/or

omissions of the Managing Director, any Executive Director or senior manager, giving rise to

liability. A proviso must exist that such acts and/or omissions must arise out of or in the

course of Company business, and that prosecution of any Director or senior manager shall

not prevent further prosecution against the Company.

28. Use of the Company Discipline Code

The Company’s Discipline Code can and should be used to ensure enforcement of this

Policy and the Company’s other health and safety policies, Codes of Practice, risk

assessments, method statements, guidance and instructions.

Persistent breaches or a single serious breach of health and safety rules or instructions by

an individual may result in their dismissal, in line with the company’s Discipline Code.

Use of the Discipline Code shall apply equally to executive, management and non

management staff.

29. Safety Rules

Company safety rules will be issued to all contractors and will be clearly stated in contractual

arrangements together with any special health and safety requirements.

In shared workplaces the Company will make arrangements for the exchange of all relevant

information arising from risk assessments and emergency procedures, particularly steps

required to protect contractors’ employees from other contractors and the occupier’s

undertakings in the workplace.

30. Suppliers and Contractors

The HR Director, on advice from the NHSEA, shall ensure that suitable policies and

procedures are in place to effectively manage the activities of suppliers and contractors.

Local management will ensure that the provided polices are implemented and that the

activities of contractors are carried out in a safe manner.

The NHSEA will verify that the policies and procedures are sufficient to plan, co-ordinate,

control and monitor the activities of contracted companies to effectively minimise the risks

presented to; our employees and workers, other persons on site and (where applicable) the

general public.





31. Approved Contractors

The Company will only use contractors who have proved themselves able to discharge their

primary responsibility to safeguard both their employees and other persons who may be

affected by their undertakings.

The approval process may include formal assessment or audit of the contractors’ safety

record, policies, procedures, method statements and other documentation as may be

deemed appropriate at the time and may include formal audit.

32. Customers

In recognition of the Company’s duties under s.6 of the Health and Safety at Work Act the

Company will supply services, machinery and / or parts which, so far as is reasonably

practicable, are safe for normal operational use and free from foreseeable health and

hygiene risks to customers. To that end the Company will provide customers on an on-going

basis with all necessary information relating to new and existing health and safety risks.

33. Visitors

In recognition of the Company’s duties towards the general public and all lawful visitors to

the Company’s premises, the Company regards the extent of its duties as compatible with

sections 2 and 5 of the Health and Safety at Work Act and the Occupiers’ Liability Act 1957

and 1984.

In particular where visitors are under a statutory duty to wear personal protective equipment

or otherwise take reasonable precautions for their own health and safety, failure to do so will

be regarded as a breach of the Company Policy, entitling the Company to take such

sanctions and measures as it considers appropriate, including requiring visitors to leave its

premise’s.

34. Management Review

The Management Review function is undertaken by the Management Systems Review

Group (MSRG), which is composed of the Company COO, the Head of Risk, Compliance &

Assurance (HRCA), the Knowledge & Information Manager (KIM), the NHSEA, and other

business Heads as is appropriate. The MSRG will meet biannually and a summary report is

periodically published by the RCA Team and issued to the MSRG members and EXCOM.

35. Review and Amendment of This Policy

This policy will be formally reviewed biennially by the NHSEA, the HRCA and HR Director. Any

identified amendments will be brought to the MSRG, National H&S Committee meeting(s) and

EXCOM for ratification and final approval by the Regional MD.

At any other time, if an urgent alteration was required arising from changes to or amendments

of; legislation, company policy or structural change, the approval of the Regional MD, HR

Director, HRCA, the NHSEA and the chair of the NNC will be required. The amended policy

would be brought to the next EXCOM and NNC meeting for formal ratification.





36. Summary

This policy has been prepared in furtherance of Section 2(3) of the Health and Safety at

Work etc. Act 1974 and binds all managers and employees in the interests of themselves,

other employees, visitors and customers.

We request that our customers and visitors respect this policy, a copy of which can be

obtained on demand.

Doug Hewitson December 2015

UK&I Regional Managing Director

G4S Secure Solutions (UK) Ltd





37. Company Organisation for Health & Safety

Regional Managing Director MD - Overall Responsibility for H&S w ithin the Company.

Executive

Committee

Members

H R Director (Director w ith special

responsibility for H&S)

HR Director - Director w ith especial responsibility for H&S.

Executive Committee Members - responsible for

ensuring implementation of H&S requirements w ithin their

area of responsibility

Management

Systems Review

Group

Selected GMB Senior Safety

Representatives & National

Officers (National Consultative Committee)

Head of Risk & Compliance(HS&E Advisors line manager)

Management Systems Review Group - The body

responsible for formally review ing the effectiveness of the

company's management systems.

Head of HR - Development of HR Policies

Line Manager

Senior GMB Safety

Representative (Regional Consultative Committee)

Compliance ManagerG4S Fire & Security Systems

Line Managers - Responsibility for ow n Staff.

National HS&E Advisor - Company's designated Competent

Person.

GMB Safety Representatives

They w ill also act as a local point of contact on H&S issues.

ALL EMPLOYEES

National Health, Safety &

Environmental Advisor

Region / Area

H&S Co-ordinators





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