Global Code of Conduct

Introduction From Rob Legge, Group CEO

As we follow our Vision and Mission to become the best facilities services business in the world, making people and places the best they can be, we want to achieve it by doing business in the right way. Our colleagues, customers, suppliers and other stakeholders will also look to us to do business the “right way”.

Guided by our TRUE Values of Trust, Respect, Unity and Empowerment, we are creating a workplace that inspires, motivates and supports each of us. We are also creating a culture built on solid principles that guide our actions and shape success for our customers and colleagues. We’re proud to be measured on what we do and how we do it.

We have developed this Code of Conduct, referred to as the “Code”, to help guide how we should go about our business in the right way every day and in every part of the world. The Code refers to conduct that is required, including ethical conduct, prohibited actions and behaviours, and how we should behave towards one another, our customers, suppliers and all stakeholders.

By continuing to uphold our TRUE Values and doing business the right way, our business will prosper as we positively impact the lives of our colleagues, customers and the communities we serve.

Rob Legge, Group CEO

OCS Code of Conduct

Why Do We Have a Code?

Our Code sets out the guidelines and standards for how we should behave as we do our business, every day, wherever we are and whatever we do.

What About Different Country Laws?

Our Code establishes our principles and guidance on common legal or ethical issues across our business. It’s not meant to cover every law and policy that might apply to you. As a global group, our Code is the highest standard and will always apply, even if it goes further than local country laws.

Does Our Code Include All the Policies I Need to Know?

Our Code and Group policies tell you what you need to know to do your job ethically. Our Code doesn’t replace our detailed policies, but clearly states our principles and the policy framework. As an OCS colleague, you’re responsible for knowing and complying with the policies that apply specifically to your work and the individual decisions you make.

How to Use Our Code

Our Code applies to us every day, wherever we are and whatever we do, including our Board of Directors and the Executive Committee. It guides every business decision we make.

Each one of us is expected to embrace our Code’s principles and:

• Show respect
• Act with integrity
• Work ethically and responsibly
• Fulfil our commitments to our customers

Breaches of Our Code

We must all comply with our Code, policies and the law. Any violations of our Code, policies, laws and regulations could lead to disciplinary action, including termination of employment and legal action.

Our Vision, Mission and Values

Our vision and mission are to become the best facilities services business globally, making people and places the best they can be. Our TRUE Values of Trust, Respect, Unity and Empowerment guide everything we do and everything that we don’t do. Our OCS Values are us at our best and are the foundation for success.

The OCS culture is built on solid principles that guide our actions and shape success for our customers and colleagues, resulting in us being a trustworthy global business that respects the communities and environment in which we operate.

We celebrate those who place our Values at the heart of their everyday roles through our internal recognition schemes and external communication channels, recognising and inspiring our colleagues, customers and everyone connected to the OCS world.

Trust

Honesty, consistency and excellence.

Built and maintained through transparency and communication.

Trust involves honesty and reliability, creating a secure environment for open communication and teamwork, which is crucial for long term success.

Respect

People, planet and purpose.

The starting point and ongoing position for every interaction.

Respect is treating everyone fairly, valuing contributions and creating an atmosphere where everyone can succeed personally and professionally.

Unity

Inclusive, diverse and together.

One team working towards the betterment of each other.

Unity means teamwork with a shared purpose, harnessing individual strengths for collective achievement, which is essential for reaching common goals.

Empowerment

Dynamic, driven and agile.

Providing the tools and skills to do more, achieving great things together.

Empowerment gives people the tools and confidence to succeed, encouraging initiative and greater investment in work and community.

Respect, Dignity and Fair Treatment

Diversity and inclusion matter to us, so we insist on a fair work environment free from discrimination and harassment. This is our commitment to ensuring that we have a work environment free from harassment and other offensive or disrespectful conduct.

Harassment is unwelcome verbal, visual or physical behaviour that creates an intimidating, offensive or hostile work environment.

Harassment may include:

• Offensive language, gestures, nicknames, jokes or banter
• Racial, ethnic, gender or religious slurs
• Degrading comments
• Intimidating or threatening behaviour
• Hostility towards others because of individual characteristics
• Excluding others from conversations or social events
• Displaying offensive emails, pictures or clothing
• Sexual harassment

Sexual Harassment

Sexual harassment could include:

• Unwelcome advances, propositions or flirting
• Unwanted physical contact or staring
• Inappropriate comments about someone’s appearance, including their clothing or body
• Lewd or suggestive remarks, questions, gestures, language, stories or jokes
• Sharing inappropriate images or videos

OCS will not tolerate verbal or physical behaviour considered intimidating, hostile or offensive. We’ll take appropriate disciplinary action in cases of unacceptable conduct.

We’re also committed to providing appropriate safeguards so no colleague’s human rights are compromised. Through our policies, we aim to:

• Prohibit child labour, forced labour and human trafficking
• Provide fair and equitable wages, benefits and other conditions of employment in accordance with local laws
• Provide humane and safe working conditions, including safe, clean and sanitary housing conditions
• Require our customers, suppliers and other business partners to adopt similar standards regarding human rights

Health and Safety

Everyone in OCS deserves to go home safe every day.

Our colleagues, families and customers rely on us to ensure this happens. That’s why health and safety is our top priority, and we’re committed to continuously monitoring, developing and strengthening our safety programme and culture.

We care for one another. We must all play our part in putting safety first and building a zero harm incident culture.

Our health and safety ethics and policies are the same in every country where we work.

We’re committed to the following:

• Visible leadership on health and safety and the environment
• Instilling safe behaviours and creating a strong safety culture
• Giving you the correct training and tools to enable you to do your job safely
• Adopting best practices in our work procedures
• Empowering you to make the right decisions about your safety
• Reporting health and safety incidents promptly, including near misses
• Monitoring, reviewing and reporting our health and safety performance accurately
• Continually improving our health and safety procedures
• Carrying out our work in a way that minimises any harmful impact on the environment and supports sustainable business

Our Health and Safety Golden Rules

Stop and say no if:

• You believe it’s not safe to do the job
• You believe the site isn’t safe
• You believe the equipment is faulty or you don’t have the correct equipment
• You’re not trained to do the job or don’t feel competent
• You don’t have the appropriate personal protective equipment
• You see something that could cause injury or damage the environment

Environment and Sustainability

We are committed to conducting our business activities responsibly.

We acknowledge the critical role we play in providing a safe and sustainable environment for our customers, colleagues and the communities in which we operate, assuring their health, safety and wellbeing, preserving the environment, and complying with all applicable health, safety, environmental, legal, quality and regulatory requirements.

We all have a responsibility and an opportunity, through our behaviours, to protect the environment and preserve the planet for future generations.

We all need to play our part in making OCS environmentally sustainable by doing the right thing.

How We Can All Play Our Part

• Reduce energy consumption: Conserve energy by turning off lights, computers and other equipment when not in use.
• Use natural resources considerately: Use natural resources efficiently, including water and paper.
• Work in an environmentally safe way: Carry out our work in a way that minimises any harmful impact on the environment.
• Minimise waste: Practise personal waste management by recycling and reducing waste generation. Use electronic documents instead of printing where feasible.
• Promote a culture of sustainability: Encourage colleagues to adopt sustainable behaviours and participate in environmentally sustainable initiatives.

We are committed to continuous improvement and constantly monitor and update our practices to ensure we deliver the best services in the right way for the benefit of our customers, colleagues, communities and the planet.

Compliance With Laws

OCS is a global business with one common standard.

We are headquartered in the United Kingdom. Many principles and guidance on common legal or ethical issues in our business are derived from UK laws and regulations.

OCS is committed to upholding the highest standard of ethics and integrity when carrying out its business.

Our Code applies to all parts of the business anywhere in the world. In some cases, our Code may impose higher requirements than the local laws in the country where you operate. In such cases, you are still required to adhere to the requirements of our Code.

Laws and Regulations

OCS respects and abides by all applicable supra national and international laws, regulations and standards.

Information Security and Protecting Personal Data

We must take care of personal data and protect information.

Personal Data

OCS respects the privacy of all our colleagues and other individuals and the confidentiality of personal data. We routinely hold and deal with information about individuals, such as employees, past and present, job applicants, customers, suppliers and other business partners. This includes names, telephone numbers, email addresses, employment contracts and employment records.

We’re an international business, and most countries have laws covering the collection, use, retention and transfer of personal data. Although these vary, our policies require that we:

• Obtain consent from the individual concerned, as required by local laws
• Only collect data that is adequate, relevant and used solely for the purpose for which it is collected
• Keep personal data up to date
• Keep personal data confidential and secure
• Don’t keep personal data for longer than necessary
• Don’t share personal data, internally or externally, unless this is relevant to the purpose for which it is collected
• Don’t transfer any personal data between territories without advice from the UK Data Protection Officer
• Report data breaches immediately

We must always keep personal information secure. Failure to comply with data protection laws can lead to criminal and financial sanctions for both OCS as a business and for us as colleagues.

Information Security

As colleagues, we must protect our company’s assets, including company data and information such as customer lists, operating manuals and other business and marketing material, ideas, designs, databases and records. You mustn’t use our company’s confidential information for personal gain or to provide an unfair advantage to a third party. All company information is confidential and should be kept secure.

Be vigilant for misuse or theft of company resources and report any concerns if you have them.

Bribery and Corruption

OCS will not tolerate bribery and corruption.

Bribery is a form of corruption that’s harmful and illegal. It can severely damage our reputation and have serious legal and financial repercussions.

Bribery means giving, offering, receiving or requesting a corrupt or improper payment or advantage in exchange for something in return.

Situations Where There Might Be Pressure to Pay a Bribe

• To win or keep a contract
• To obtain a licence or permit
• An attempt to influence someone or gain an improper advantage, such as donating to a charity sponsored by a customer or potential customer
• To secure payment of a debt
• To avoid a fine or penalty

Situations Where You May Be Offered a Bribe

Examples that should be refused and reported could include:

• A supplier or third party offers you a payment, loan or other financial benefit with the expectation that it would give them a business advantage.
• A supplier or third party offers you or your family a gift or hospitality with the expectation that OCS will give them a business advantage.

A bribe could include money, gifts, hospitality, entertainment, services, employment, charitable donations, preferable treatment or another advantage. Small, unofficial facilitation payments intended to ensure or speed up necessary actions are also bribery, so they are prohibited.

However, meals, hospitality and small gifts can be legitimate activities when handled in the right way. Reasonable and appropriate hospitality or entertainment is allowed to build or maintain good business relationships. However, it could be a form of bribery if it is excessive in value, inappropriate in nature, regular or intended to influence a business decision.

What about a third party acting for OCS, such as a supplier, partner, agent or consultant? If they pay or offer a bribe, we could be held liable. We must ensure that any third parties we work with don’t use bribery.

OCS will take consistent and swift disciplinary action against any colleague who commits bribery. Action can include dismissal and reporting to the relevant authorities, where you may be subject to criminal proceedings.

Fraud Prevention

We must record and report all information accurately and honestly.

Our financial records and the information we provide to our customers and other stakeholders must be accurate and complete. Our records are valuable business information and evidence of our actions, decisions and obligations. Our management teams, directors and tax authorities rely on our financial information to make informed decisions about our business.

Failing to record transactions accurately, falsifying or creating misleading information, or influencing others to do so could constitute fraud and result in fines or penalties for a colleague or OCS.

That’s why we must all ensure that:

• Any company information is recorded accurately, honestly and completely
• All business expenses are accurately recorded and supported by documentation

What About Money Laundering?

Money laundering is a form of fraud whereby someone tries to hide illegal funds or make the sources of illicit funds appear legitimate.

Legislation prohibits money laundering or financing for illegal or illegitimate purposes.

Potential indicators of money laundering include:

• Requests from a potential customer or supplier for cash payments or other unusual payment terms
• Paying large sums in cash
• Using multiple accounts or payment methods
• Using an account based in an unexpected location

Be vigilant for fraud or misreporting and immediately report any concerns.

Whistleblowing and Speaking Up

You should feel secure and supported in speaking up.

OCS takes malpractice and misconduct seriously, whether it’s committed by a colleague, supplier, customer or other third party. That’s why we want all colleagues to feel confident reporting any serious concerns so that we can deal with them fairly and adequately.

You must speak up if you believe that one or more of the following has happened or could happen:

• Any criminal activity
• Bribery
• Corruption
• Financial fraud or mismanagement
• Failure to comply with any legal or professional obligation or regulatory requirement
• Danger to health and safety
• Damage to the environment
• Conduct that is likely to damage our reputation
• Actions intended to hide any of the above

We treat all matters raised in the strictest confidence and make every effort not to reveal the identity of the colleague who raises a concern, unless you give your express consent.

Reporting

We have established a formal whistleblowing service, Safecall, to enable you to report serious concerns. Safecall allows you to make whistleblowing reports by phone using your local country freephone number or by visiting the dedicated OCS Safecall website.

Please see Appendix 1 for the Safecall contact details.

Personal Grievances

The whistleblowing procedure should not be used for grievances relating to your own personal circumstances or complaints, such as the way you have been treated at work, bullying, harassment, breach of employment legislation, hours, pay or issues with your managers.

For personal grievances or issues, you should use your local country’s HR grievance procedure.

Speaking on Behalf of Our Company

You must have authorisation to speak or write on behalf of OCS.

How we communicate with the media and other interested third parties demands specialist skills and experience because it can have important legal requirements. That’s why we manage it carefully.

Only colleagues with specific authorisation and training or briefing may communicate about OCS with the media or respond to any enquiries or questions we receive.

Similarly, when using your personal social media channels, you should be clear that you don’t speak on behalf of OCS. Please see our Social Media Playbook for more detailed guidance.

You must also:

• Ensure any personal community, charitable or political activity is not interpreted as being on behalf of or connected with OCS, unless it is authorised
• Obtain authorisation from your country or sector managing director before speaking at an event, giving an interview or writing material for publication in your capacity as an OCS employee

Protecting Yourself

We mustn’t allow conflicts between our personal interests and those of OCS.

As colleagues, we must always act in the best interests of OCS. We should be loyal in all matters affecting our company, including those that relate to our customers and other parties with whom our company has a commercial relationship.

A conflict of interest occurs when your personal interests or external relationships interfere or compete with the interests of our business, or influence our ability to make the right decisions.

Conflicts of interest could include:

• Working for or owning an interest in a competitor, customer or supplier
• Hiring or supervising a family member or friend without the knowledge and approval of your line manager
• Having outside employment that negatively affects your job performance or interferes with your OCS responsibilities
• Using company property, information or resources for your benefit or the benefit of others
• Choosing a supplier because of the hospitality they provide at sporting events

If you think that you have a potential or actual conflict of interest, you must disclose it promptly. Conflicts can often be resolved through an open and honest discussion.

Bring an actual or potential conflict of interest to the attention of your line manager immediately, or contact Safecall through the dedicated OCS Safecall website or the appropriate telephone number.