POLICY STATEMENTS

Black & White Engineering (B&W) is a consulting engineering firm specialising in the field of Building Services (MEP) Engineering.

B&W is committed to eliminating discrimination and encouraging diversity amongst its workforce. The aim is that our workforce will be representative of all sections of society and each employee feels respected. To that end, the purpose of this policy is to provide equality and fairness for all in our employ and not to discriminate irrespective of:

• Gender, marital, or family status
• Religious belief or political opinion
• Race, ethnic origin, colour, nationality, national origin
• Disability
• Sexual orientation
• Age

We oppose all forms of unlawful and unfair discrimination. All employees, whether part‐time, full‐time, or temporary, will be treated fairly and with respect. Selection for employment, promotion, training, or any other benefit will be based on aptitude and ability. All employees will be helped and encouraged to develop their full potential, and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the company. We are committed to the following equality principles:

• To create an environment in which individual differences and the contributions of all our staff are recognised and valued.
• Every employee is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying, or harassment will be tolerated.
• Training, development, and progression opportunities are available to all staff.
• Equality in the workplace is good management practice and makes sound business sense.
• We will review all our employment practices and procedures to ensure fairness.
• Breaches of our equality policy will be regarded as misconduct and could lead to disciplinary proceedings.
• This policy is fully supported by the Directors and has been agreed with staff.

The local Directors are specifically responsible for effective implementation of this policy. However, all employees are required to actively support this policy and help create the equality environment envisaged. To implement this policy, we will ensure that the policy is communicated to all employees, through induction, team meetings, distribution and display of written documentation, via the recruitment procedures, etc.

Who is this policy statement for?

Copies of this Global Equality and Diversity Policy Statement will be issued to all those with an interest. This statement will be promoted to employees, customers, and representatives of the local communities in which we operate.

It is B&W’s policy to achieve a quality of behaviour, product, and service that surpass our client’s needs and expectations with respect to environmental management and sustainable development. By adopting an integrated management system that is compliant with ISO 14001:2015, we can ensure that our processes are planned to allow all staff to achieve our very high standards as efficiently and consistently as possible, minimising the impact of the company activities on the environment.

It is B&W’s management representative’s duty to ensure all staff are empowered to share the responsibility of  implementing the QSE System and in turn, it becomes the responsibility of all staff to ensure that our services are carried out in accordance with the systems set.

Our environmental commitments

We will demonstrate our commitment to the protection of the environment through:

• The promotion of sustainable development in all our business activities.
• Compliance with legal and other relevant requirements.
• The continual improvement of our environmental performance throughout our operations and activities.
• Minimising waste and pollution throughout our operations and activities.

Our environmental objectives

To underpin these four commitments, we have adopted the following strategies:

• Engage with our clients and peers to promote, design, and deliver sustainable outcomes to meet their expectations and needs without compromising the ability of future generations to meet their own needs.
• Management and reduction of waste from our operations and activities.
• Adoption of energy and water efficiency best practice in our design and our construction activities.
• The identification and management of environmental risks associated with our business activities.
• Consideration of our neighbours, wildlife, and the wider environment.
• Promotion of improved environmental performance by our contractors and suppliers.
• Achievement and maintenance of an environmental management system conforming to ISO 14001:2015.

Environmental performance

Our objectives will be delivered through a programme of environmental targets and will be managed and monitored by our motivated team.

Who is this policy statement for?

Copies of this Global Environmental Policy Statement will be issued to all those with an interest. This statement will be promoted to employees, customers, and representatives of the local communities in which we operate.

B&W is committed to maintain a long‐standing commitment to respecting human rights, including the elimination of slavery and human trafficking in our supply chains and business operations. The aim is to oppose a zero-tolerance approach to modern slavery and to expect all those in our supply chain to comply with our values.

All employees, whether part‐time, full‐time, or temporary, will be safeguarded, treated fairly and with dignity and respect from their recruitment process and through all their career within our company. Our supply chain will be monitored as well to prevent any action or omission that could be interpreted or lead to possible illegal or inhumane labour practices.

We are committed to the following principles:

• To maintain a clear policy preventing slavery and human trafficking.
• To examine our supply chain and be clear with key providers regarding any possible illegal or inhumane labour practices.
• To seek to raise awareness so that our employees know what B&W is doing to promote their welfare.
• To inform our employees on the role they have in the active monitoring of suppliers and in the report to their management if they suspect a person in the supply chain who could be controlled or forced by someone to work or provide services.
• To keep eyes and ears open on any situation in the supply chain that could be considered as modern slavery or human trafficking.
• This policy is fully supported by the Directors and has been agreed with staff.

The local Directors are specifically responsible for effective implementation of this policy. However, all employees are required to actively support this policy. To implement this policy, we will ensure that the policy is communicated to all employees, through induction, team meetings, distribution and display of written documentation, via the recruitment procedures, etc.

Who is this policy statement for?

Copies of this Global Anti‐Slavery and Human Trafficking Policy Statement will be issued to all those with an interest. This statement will be promoted to employees, customers, and representatives of the local communities in which we operate.

It is B&W’s policy to achieve a quality of product and service that surpass our client’s needs and expectations. By adopting systems compliant with ISO 9001:2015, we can ensure that our processes are planned to allow all staff to work towards achieving our very high standard of product and services as efficiently and consistently as possible.

It is B&W’s management representative’s duty to ensure all staff are empowered to share the responsibility of implementing the QA System and in turn, it becomes the responsibility of all staff to ensure that our services are carried out in accordance with the systems set. Our staff are our greatest asset in attaining our goal to be market leaders ‐ our energy, drive, motivation, innovation, passion, and commitment give us our competitive edge. It is B&W management’s responsibility to ensure we maintain these traits in all B&W’s staff throughout the practice.

Our quality commitments

We will demonstrate our commitment to quality through:

• Providing a focus on customer requirements.
• Compliance with legal and other relevant requirements.
• The continual improvement of our performance throughout our operations and activities.

Our quality objectives

• Achievement and maintenance of a quality management system conforming to ISO 9001.
• Achievement and maintenance of an information management system for projects using BIM processes conforming to PAS1192‐2:2013.
• Monitoring and improving the satisfaction of our customers.
• Managing our processes carefully to maximise the benefits to our clients.
• Adoption of best practice in our construction activities.
• The identification and management of critical and business activities.
• Promotion of improved performance by our contractors and suppliers.

Quality performance

Our objectives will be delivered through a programme of quality targets and will be managed and monitored by our motivated team.

Who is this policy statement for?

Copies of this Global Quality Policy Statement will be made freely available to all those with an interest. This statement will be promoted to employees, customers, and representatives of the local communities in which we operate.

B&W is committed to respecting privacy and implementing systems that support our duty of confidentiality and in all our business relationships, and this confidentiality policy explains how we expect our business to treat confidential information. Our business will unavoidably receive and handle personal and private information concerning employees, projects, clients, partners, and our company. As such, we will strive to ensure that this information is well‐protected.

Aims of this policy

The purpose of this Confidentiality Policy is to lay down the principles that must be observed by all who work with B&W and have access to confidential information. This policy, where relevant, should be read in conjunction with the appointment letter and/or employment contract applicable to B&W employees, and other work rules, policies, and procedures applicable to B&W employees.

Scope

This policy applies to all B&W employees, contractors, sub‐consultants, temporary employees, and workplace students (all hereinafter referred to as employees). Confidential workplace information within B&W is generally broken down into three categories:

• Employee Personal & Management Information: All personal data of all employees and business management information will be kept safe, secure, and up to date in accordance with all local law and legislation including the Data Protection Act 2018. Compliance with this act is B&W’s implementation of the General Data Protection Regulation (GDPR), which will be adhered to as a minimum in the absence of any regional requirement.
• Project Information: All B&W projects will, as a minimum follow signed industry standard forms of appointment which shall typically include straightforward obligations on both parties not to disclose confidential information. The nature of this ‘confidential information,’ and how far the obligation extends, will vary between the different forms of contracts.

Standalone Non‐Disclosure Agreements (NDAs)

Our clients may have specific concerns about confidentiality, driven by the nature of their business or the project, and therefore wish to have a standalone NDA to reinforce the obligations placed on B&W, and in turn, our supply chain. The B&W QSE technical operating procedures for ‘appointment and project control’ ensure that NDA requirements are considered with our clients on all projects (and maintained where applicable). Our company-wide project NDA register is shared with all staff via our company SharePoint site.

Maintenance of Confidentiality and Non-Disclosure

On all projects, B&W project managers will establish the requirement for a NDA and implement where required. Once in place, employees will:

• Lock or secure confidential information at all times.
• Use secure waste removal service.
• Confidential information is viewed on secure devices only.
• Only disclose information to other employees when necessary and authorised.
• Store confidential documents inside our company premises (unless it’s necessary to move them for project / security purposes).
• Encrypt electronic information and safeguard databases.
• Implement a senior management authorisation procedure to control employee access to certain confidential information.

Exceptions

All our project appointment and standalone NDAs shall clearly define what information is to be treated as confidential, and the uses and disclosure that can be made of it. The definition shall not be so wide as to hinder our ability to perform the services or restrict our ability to comply with our obligations under these agreements.

In all instance, B&W confidentiality obligation agreement should not apply to the following information which shall be expressly excluded from our agreements, namely information that is;

• Already in the public domain
• Provided by third parties
• Already known to the consultant independently
• Required to be disclosed by law
• Developed independently
• Disclosed otherwise than by wrongful disclosure
• Necessary in connection with entry into the appointment
• Required for the proper performance of the services, or
• To be used in any legal proceedings

Breaching the duty of confidentiality

B&W will investigate all potential breaches of this confidentially policy. Any staff found to be in breach will face action in line with our company disciplinary procedures. Where appropriate, employees may be subject to legal action in response to breaches, to mitigate damages to B&W and our clients.

We are committed to conducting business with a high level of integrity and within the law. B&W does not tolerate any form of corruption or bribery in any of our dealings.

The purpose of this policy is to set out procedures and systems to uphold our zero‐tolerance position on bribery and corruption. This policy applies to all B&W’s employees, business dealings, and transactions across the business. The policy and procedures set out are communicated to the entire organisation through rigorous training. The employee handbook has a clause dedicated to company moral standards on bribery and corruption. All B&W employees must adhere to these. Violation of this policy are grounds for disciplinary action, dismissal, and for clients, termination of contracts.

What is bribery?

Bribery can be defined by offering, receiving, or soliciting an item of value with the intention of influencing the action of the recipient.

What is corruption?

Corruption is defined as dishonest behaviour by individuals in positions of power, typically involving bribery.

Gifts, Entertainment, Hospitality

All B&W staff must not participate or become involved in any activities conflicting with this policy. Any given or received gifts or entertainment must:

•  Be compliant to local laws.
•  Not to exceed in value of 30 USD, anything of a higher value must be consulted with a Director.
•  Be approved by a Director for out-of-office hospitality.
•  Be given at corporate level and not individual level.
•  Be given in good faith and not with the intention of influencing the recipient.

Concerns and Guidance

Our senior management is committed to implementing this policy within the organisation. Any person wishing to raise a concern in good faith can make contact confidentially directly with the Directors. No concern will be criticised or penalised in any way.

Penalties

Violation of this policy statement as well as any anti‐bribery local regulation could result in significant punishment. Internally for B&W, this includes termination of employment. Any fines imposed on individuals will not be paid by B&W.

It is B&W’s policy to provide a healthy and safe environment for our employees, sub‐contractors, visitors, and others through our behaviour, product, and service that surpass our client’s needs and expectations. By adopting systems that are compliant with ISO 45001:2018, we can ensure that our processes are planned to allow all staff to work toward achieving our very high standard of product and services as efficiently and consistently as possible, minimising the risk of injury or illness linked to the company activities through a wide implementation of preventive procedures and actions.

It is B&W’s management representative’s duty to ensure all staff are empowered to share the responsibility of implementing the QSE System and in turn, it becomes the responsibility of all staff to ensure that our services are carried out in accordance with the systems set.

Our Occupational Health and Safety commitments

We will demonstrate our commitments to occupational health and safety through:

• The promotion and the implementation of occupational health and safety principles in all our business activities.
• The compliance with legal and other relevant requirements.
• The continual improvement of our occupational health & safety performance throughout our operations and activities to meet the requirements of ISO 45001:2018.

Our Occupational Health and Safety objectives

We consider the health and safety of our employees, sub‐contractors, visitors, and others who may be affected by our operations to be our highest priority. We have adopted the following objectives:

• Give the management of Occupational Health and Safety at least equal consideration to all other business functions.
• Ensure that suitable and sufficient information training, instruction, and supervision are provided so that all employees can complete their work in safety.
• Encourage our team to participate in all elements of the Occupational Health and Safety management.
• Consult with our staff on Occupational Health and Safety matters through regular staff meetings which will include the development of policy, procedures, and review of accidents to ensure that preventative and protective measures are effectively monitored, and the promotion of the implementation of procedures that will prevent injury / ill health to employees to become the focus for continuous improvement initiatives.

Safety performance

Our objectives will be delivered through a programme of Health and Safety targets and will be managed and monitored by our motivated team.

Who is this policy statement for?

Copies of this policy statement will be issued to all those with an interest. This statement will be promoted to employees, customers, and representatives of the local communities in which we operate.