GPG Employee Handbook

MANAGING DIRECTOR WELCOME

Welcome to our Employee Handbook, which has been developed as a comprehensive and valuable resource for both new and existing employees.

The contents of this handbook have been designed to provide an overview of General Paints Group’s purpose, mission, and values as well as provide information on key employee services and policies covering different aspects of our work.

At General Paints Group (GPG), our people are at the heart of our business, and we strive to create jobs with meaning and responsibility, while living our values of Respect, Excellence and Partnership. Our values inform how we operate, how we interact with our colleagues, customers, suppliers, community, and ultimately how we achieve our company vision. I would encourage all employees to reflect on our core values and consider how we can uphold them in our daily interactions with each other and external stakeholders.

I want to thank all employees for continuing to contribute your unique talents and capability to deliver our shared purpose.

On behalf of everyone at GPG, I welcome you and I hope you all enjoy a rewarding career with GPG. I am always available and please feel free to contact me at 087 461 5996 or rachel.oconnor@generalpaints.ie

Rachel O Connor, Managing Director

ABOUT THIS HANDBOOK

The Employee Handbook provides a range of information to guide all GPG employees in their work. Taking the time to become familiar with the Handbook’s contents will help you to understand:

• GPG as an organisation and as an employer.

• The policies and agreements surrounding your employment.

• What you can expect from colleagues and what colleagues expect from you.

• How to raise a concern or grievance.

• Communication and consultation policies and procedures.

• How to seek guidance on accessing information relating to terms and conditions of Employment i.e. annual leave, statutory leave, pay and pension.

• How to access development opportunities within GPG.

• Your Wellness and Mental Health

Section 1 and Section 2 provides a comprehensive overview of the company, our mission, vision and our values, the people benefits and your duties as an employee. Section 3 to Section 7 is where you can find full details of company policies and procedures.

First Point of Contact

Your line manager in the first instance will be able to help with most questions or direct you to the appropriate area. The Human Resources Department is also available for any queries you may have.

Contract of Employment

The Employee Handbook and your individual contract of employment set out employment terms and conditions. You are encouraged to take time to read both documents carefully and direct any questions you may have to your line manager or human resources

Section 1: GPG as an Employer

1.1 OUR STORY

Like so many others, our founder, Ronan O’Connor, emigrated to the USA in 1950. It was his time working in a paint factory in San Francisco that inspired him with innovative ideas he wanted to bring back to his home country. He returned to Ireland with a dream of revolutionizing the Irish paint landscape. And so, in 1953, General Paints Group was born.

Now over seventyyearsand three generations later, Ronan’s vision continues to be realised, General Paints Group is Ireland’s largest, 100% Irish owned & operated, progressive paint company and proud parent to two thriving brands: Colourtrend and Curator.

From our home in an old famine workhouse in Celbridge, Co. Kildare, our high-quality, high-performance paints now travel all over the world with growing markets in the UK, US and the Netherlands.

Using our expertise, we sit at the forefront of paint technology, developing paints and unique colour palettes for locals and internationals alike, whether it be for their forever home, their new business or anything in between.

We are proud to be a family owned, independent business. Our people are our secret to success, a team who share an unwavering dedication to excellence, and an ambition and commitment to work together to create the most innovative and sustainable products and services. It is our people, since 1953, who have turned General Paints Group into an Irish success story to be proud of.

GPG is committed to producing high-quality, competitive products which are essential for the growth and sustainability of the company. In furthering this objective, the company’s policy on employee management is to maintain an open and communicative style. We strive to maintain our open-minded, communicative, and respectful atmosphere, where our team members are encouraged to speak up, challenge, network, and share.

We value people who share our ambition and become ambassadors for our brands and Group.

1.2 OUR MISSION AND PURPOSE

Our Mission is to “Embrace innovation, to create lasting, vibrant colour that protects our planet, so that we can build better futures for our people, customers, partners and communities” . Our Purpose is “To positively impact the world we live in”.

OUR COMMITMENT OUR PEOPLE

One of our company goals is to establish GPG as a business with a positive impact on all stakeholders, including our employees, customers, suppliers, community and the environment. Our ambition is to become a certified B-Corporation by 2025, this is a business that meets the highest standards of social and environmental performance, with a purpose beyond profit

COMMUNITIES

At GPG, we are committed to a culture of wellbeing. From our employee assistance programme to our mental health initiatives, we nurture and care for our people at GPG.

ENVIRONMENT

Our paints are water based and low VOC, meaning they are safer for you and your environment. At GPG, we are committed to reducing our environmental impact without compromising on quality. Our paints are designed to stand the test of time, giving you long-lasting finishes and vibrant colours.

CUSTOMERS

GPG is proud to be celebrating over 70 years in our local community in Celbridge, Co. Kildare.

From sponsored events like Waterford Walls and Seek Dundalk to our yearly participation in National Heritage Week, our sense of community and history is at the very core of our business

GPG is committed to delivering excellent services and quality products to our customers. Quality and our constant drive to innovate and continue to improve are at the centre of our business.

1.3 OUR VALUES

We value Respect, Excellence, and Partnership

We encourage everyone working with GPG to live the values through their communications, behaviours, relationships, and decisions, both internally and externally. Our vision is to build better futures for our people. customers, business partners and communities through our core values.

1.4 COMMITMENT TO QUALITY

General Paints Group’s quality policy is to deliver reliable, consistent products and services that surpass customer expectation, thereby realising the company mission “to embrace innovation to create lasting, vibrant colour that protects our planet, so that we can build better futures for our people, customers, partners and communities.”

We will achieve this by:

• Considering all stakeholders in decision making – our customers, our people, our community, and the environment.

• At all times complying with the applicable legislation, and the ISO 9001:2015 standard.

• Enterprise excellence; continually improving the effectiveness of all systems and processes.

• Setting meaningful and challenging goals and objectives for the company and for our people.

• Living our company values of Respect, Excellence and Partnership

Responsibilities of the Workforce

We are all responsible for the quality of the work that we do on a daily basis. Our quality documentation and Standard Operating Procedures (SOP’s) describe the correct way to carry out the activities associated with each position.

At all times, every one of us is responsible for ensuring that the appropriate SOP’s and work instructions are followed. There may be times when it appears that an instruction does not make sense, or you may have some suggestions as to how existing practices can be improved. If this is so, please discuss the issue with your manager or supervisor, who will investigate and come back to you with an answer or explanation

If you see any errors, again please point them out to your manager or supervisor. In addition, during the internal audits, which are carried out by our own staff, please be totally honest and open in answering any questions put to you and take any opportunity you may have to make suggestions for improvements or changes

1.5 COMMITMENT TO SOCIETY & THE ENVIRONMENT

Our ambition is to be the first Irish paint company to become a certified B-Corporation, meaning that our business will meet the highest standards of social and environmental performance with a purpose beyond profit. Certified B-Corporations are leaders in the global movement for an inclusive, equitable, and regenerative economy. Our mission is to embrace innovation to create lasting, vibrant colour that protects our planet, so that we can build better futures for our people, customers, partners and communities. We have a unique opportunity to act as leaders in sustainability within our industry.

Business as a Force for Good

We are committed to using business as a force for good. Our purpose beyond profit compels us to continually consider the impact of our practices and decisions in how we operate our business, care for our employees, the environment, and our customers, and how we interact within our communities every day. We therefore continually strive to improve our policies and processes in every department.

Community

At GPG, we are proud of our diverse range of community partnerships, which to date have included DEIS schools in Ireland, partners in Cambodia, street artists in Waterford and Dundalk as well as traditional Irish musicians in Mullingar. We are committed to donating 1% of our annual turnover towards charitable, community and sustainability initiatives. As a business, we are also committed to creating opportunities for GPG employees to volunteer and uphold our core values around partnership, enabling us to reach our goals and positively impact the world around us.

Environment

As an industry with heavy reliance on petrochemicals and water-intensive production processes, sustainability continues to present a challenge and ‘greenwashing’ within the industry is unfortunately common. At GPG, we never risk our reputation by making false claims. Instead, we are dedicated to tackling challenges at their roots and making the difficult changes that can truly create a meaningful and positive impact that we really need to see in the world around us.

Governance

We are very clear on our goals and objectives and have a roadmap that will help us on our journey. We as a business are committed to change and understand what is required to make it happen. From our Community Policy to our Supplier Code of Conduct Policy, the effective implementation of our policies and procedures will ensure the protection of our progress along our roadmap. We take ownership for our actions as a business and will continually strive to improve our policies and processes to work towards a sustainable future.

Workers

At GPG, we actively embrace people from all backgrounds and promote a culture of wellbeing for all our employees. A sense of community and history is at the heart of everything we do. We encourage continuous learning, enforce safe working conditions, treat our workers with dignity and respect, and ensure that our manufacturing processes always strive to be as environmentally responsible as possible while complying with all applicable health & safety laws and regulations in the jurisdictions we operate in.

Customers

Our customer service is second to none. While quality and innovation are the cornerstones of our business, we also workwith our customers on our Waste Awareness Programme to helpour customers approach their painting projects in a more environmentally conscious manner.

1.6 CODE OF ETHICS/BUSINESS CONDUCT

Purpose & Scope

General Paints Group (GPG) is widely regarded throughout the business communities in which it operates for its honesty, fairness, and business integrity, all of which are vital to the overall success of the business. To maintain this high reputation, it is incumbent on all employees to conduct their business and personal activities in a manner that does not adversely reflect on GPG.

It is now common practice for employers to introduce a formal Code of Business Conduct that provides guidance to Board members and employees (referenced as employees throughout) in recognising and resolving the ethical and legal issues they encounter in conducting their duties. The provisions of the Code of Conduct forms part of the Terms and Conditions of Employment for all employees.

The purpose of this Code is to set down the general principles and standards, which govern the professional activities and conduct of management and employees, both permanent and contract, of GPG thereby maintaining a high level of public confidence in our company

The Code of Conduct relates both to internal and external activities of GPG. Wherever we operate, we must ensure that our business is conducted and managed effectively, efficiently, and objectively in the interest of our employees, customers and business associates, in a manner consistent with the highest professional standards of accountability and responsibility and in accordance with the law. Employees are obliged to comply with policies and procedures, employee regulations, work rules and any standards and codes of practice adopted by GPG. This Code of Conduct is binding on all employees (including those on leave). Queries or concerns regarding business conduct should be directed to the employee’s Line Manager in the first instance and then to Human Resources.

Principles of the Code

GPG is committed to respect, integrity, fairness, and transparency in all its dealings. Therefore, it is essential that all employees conduct themselves and are seen to conduct all activities, to the highest standard possible.

GPG values are:

• Respect

• Excellence

• Partnership

Application of the Code

We make decisions based on objective and independent evaluations, and are committed to openness, fairness, and transparency in our decision-making. We develop the necessary competence and confidence in our people to enable them to carry out their jobs in a professional manner.

Obligations

Employees have an obligation to attend at work as required and perform their official duties honestly and efficiently, respecting the rights of the public and their colleagues. There are common law obligations also on all employees to properly perform the duties for which they are employed including:

• to obey the law

• to obey all lawful and reasonable instructions from the employer and to work as directed.

• to be competent and efficient in the performance of assigned duties.

• to refrain from conduct which might impair work performance.

• to show reasonable care, and neither use nor allow the use of the employer’s property, resources, funds for anything other than authorised purposes.

• to incur no liability on the part of the employer without proper authorisation

As well as being responsible for their own conduct, employees also have a duty to contribute to the smooth running of the workplace by treating their colleagues, trainees and the public with courtesy and respect. This means that GPG employees are expected:

• to avoid behaviour which might endanger or cause distress to their colleagues, or otherwise contribute to disruption of the workplace.

• to respect the privacy of individuals when dealing with sensitive information

• not to harass, bully or otherwise intimidate colleagues or customers.

• to have due regard for the safety, health, and welfare of others in the use of organisation property and resources.

Employees should be aware of and fulfil all regulatory and statutory obligations of the organisation and enforce them in a fair, responsible and consistent manner, acting within the legal authority given to them. Employees charged with the task of delivering services to customers must respect the individuals with whom they deal and ensure that the needs of the customer are met insofar as it is legally and economically possible. Employees have a duty to deal with customers with integrity, diligence and impartiality and with courtesy, consideration, fairness and promptness. Employees should respect the principle of non-discrimination and equal treatment for all customers.

Conflict of Interest

Employees are encouraged to participate actively in the communities in which they live and work. However, in engaging in outside activities, employees must avoid the risk of conflict with their official duties and comply with all GPG disclosure requirements.

Employees may not allow a situation to arise where there is a conflict or potential for conflict between their own interests and those of GPG. Employees must observe their duties and obligations to the organisation in accordance with the contract of employment and associated terms and conditions of employment. In addition, employees have common law duties of loyalty, fidelity and confidentiality to their employer. Employees must always act with personal integrity and their actions should be able to bear the closest public scrutiny.

Any employee who is involved with any outside organisation, whether economic, social, cultural or political, has the responsibility to ensure that such involvement is not prejudicial to the interests of GPG and that it does not create a conflict of interest or potential conflict with their employment with the organisation. This includes the direct or indirect offering or acceptance of financial or in-kind contributions or sponsorships to political parties, politicians, lobby groups, charitable organisation and advocacy groups, outside of those pre-agreed and publicly disclosed by the Managing Director Any employee becoming aware of such a conflict/potential conflict must declare this to his/her Line Manager in the first instance or Human Resources immediately, who will decide how the situation should be dealt with.

As a company GPG do not make any financial or in-kind contributions to political parties, politicians, or lobby groups. Any donations to charitable organisations are covered by our Community Policy and are granted under our three themes of Diversity, Equality & Inclusion, Learning & Development and Creativity & Culture.

Disclosure of information

Employees are prohibited from making use of, or disclosing, any confidential information gained as a result of employment with the organisation. The unauthorised use or disclosure of confidential information to which they have had access may lead to disciplinary action.

If an employee leaves the employment of GPG (resigns, retires or terminates the contract of employment) they are obliged to protect and respect the confidentiality of the organisation’s information.

An employee who is convicted of a criminal offence or given the benefit of the Probation Act when charged with a criminal offence must report the fact to his / her Line Manager in circumstances where it has implications for his / her position. In situations where this is unclear, the matter should be raised with employee’s line manager. In certain circumstances, this could have implications for their position. Such information will be treated in strict

confidence and no record of it will be kept unless the information is considered relevant to the position of the employee.

Gifts and entertainment

Under no circumstances may an employee solicit, either directly or indirectly, gifts, hospitality etc. for personal use, gain or benefit.

Under no circumstances may an employee accept the offer of any unsolicited gifts, including hospitality, travel, payments, services, or benefits-in-kind on a scale which could affect, or be considered to affect, the ability of an employee to exercise independent judgement on GPG matters. Any gifts received must be notified to the employees’ manager and will be held for distribution at the end of the year.

Outside occupation

Employees are obliged to give their full commitment to their duties and responsibilities in the organisation. In no circumstances should an employee engage in matters unconnected with his / her duties and responsibilities during GPG work hours.

GPG is dedicated to the health safety and welfare of all its employees. Under the Organisation of Working Time Act, 1997 the onus lies with GPG to ensure that all employees work within a 48-hour working week. Permission must be sought and obtained from the relevant Line Manager, before engaging in any outside work. Employees should not engage in work outside of GPG to the extent of impairing the employee’s work performance with the organisation.

There must be no conflict of interest or potential conflict between an employee’s organisational work / responsibilities and his / her involvement in any employment (including self-employment) outside of work.

Use of GPG resources

Use of GPG facilities such as electronic mail and telephone for private use is not permissible. In performing their GPG duties, employees must use resources prudently and only for the purpose for which they are intended. They must not use their position in the organisation to pursue private interest using company resources. Employees should ensure that resources provided are used economically for the purpose for which they were provided, treated with care, maintained and properly secured against theft or misuse. GPG resources include material and financial resources, employee time and skills, intellectual property, and official information.

Service to Stakeholders

We are committed to providing an excellent service to our various stakeholders, which is courteous, helpful, and timely in dealing with queries and requests. We are committed to making information readily available to our stakeholders. We respect the needs of our different stakeholders and seek to strike a balance between the high levels of environmental protection to which we are committed and the need for economic and social development.

Respect and Support for Colleagues

We believe that people flourish in an open and supportive workplace. We respect our colleagues as individuals with important contributions to make to our overall goals. We encourage teamwork, challenge, relationships, discussion, and debate to help make the best decisions. We want to be an employer of choice where our people can achieve fulfilling careers in a workplace with a high work ethic, and without discrimination.

Openness to Learning

In all of our activities we are open to new insights and greater understanding of ways to improve our organisation and ourselves. We do this by keeping abreast of new developments, which are incorporated into our working practices. The personal interest of an employee, political or public pressure must never guide our conduct.

Reporting and Investigation of Violations

Actions prohibited by this code must be reported to the Chairman of the Audit and Risk Committee.

After receiving a report of an alleged prohibited action, the Audit and Risk Committee Chairman will promptly take all appropriate actions necessary to investigate. All Directors, and employees of GPG are expected to cooperate in internal investigations of misconduct.

Enforcement

The company commits to taking prompt and consistent actions against violations of this code.

If, after investigating, a report of an alleged prohibited action, the Audit and Risk Committee determines a violation of this code has occurred, the Audit and Risk Committee shall consider the violation and will take such preventative or disciplinary action as it deems appropriate. Such action includes but is not limited to suspension, reassignment of duties, dismissal, and in the event of criminal conduct or other serious violations of the law, notification of appropriate governmental authorities.

Prohibition on Retaliation

It is the Company’s policy not to allow retaliation against any director or employee for reports made in good faith regarding acts of misconduct or suspected violations of this code.

Code of Conduct Review

GPG will review this Code of Conduct periodically. As it is not possible for this Code of Conduct to provide for every situation which may arise, employees must bear in mind that it is primarily their personal responsibility to ensure that all their activities, whether covered specifically or otherwise in this Code of Conduct, are governed by the ethical considerations implicit in the Code

1.7 EQUAL OPPORTUNITES EMPLOYER

Purpose & Scope

General Paints Group are an equal opportunities employer and as such GPG management are committed in the discharge of their duties, to the implantation of a comprehensive policy of equal opportunities in employment in which individuals are recruited and employed on the basis of their relevant merits and abilities without regard to Gender, Civil Status, Family Status, Race or Ethnic Origin, Religious Belief or Political Opinion, Age, Disability, Sexual Orientation or Membership of the travelling community and are given equal opportunities within the company. The purpose of this policy is to ensure that no applicant receives less favourable treatment on grounds not relevant to good employment practices.

GPG are awareof their responsibilities under equality legislation in the Republic ofIreland. This equalopportunity policy incorporates all these responsibilities and will ensure that any changes in such legislation will be automatically incorporated in its equality policy. This policy covers all current and perspective employees of GPG.

Responsibility

Whilst we all have responsibility to treat others with dignity and respect and to ensure that we do notdiscriminate unfairly, specifically responsibility lies with:

Management

To provide an atmosphere at work which promotes equal opportunities and is free from harassment and sexual harassment.

Human Resources

To operate recruitment, pay and benefits, selection and promotions policies based on merit and unbiased by considerations as detail on the grounds above.

All employees

To cooperate with management in implementing its equal opportunities programme and assist with the creation of an equality environment, which is our overall objective.

Implementation

The Managing Director has specific responsibility for the effective implementation of this policy. In order to implement this policy, the Company will ensure that:

• The Anti Bullying and Harassment policy is communicated to all employees through induction training and made known to job applicants.

• Managers are aware of their responsibilities through appropriate training.

• Staff involved in assessing candidates for recruitment or promotion will be trained in non-discriminatory recruitment and selection techniques.

• Consultation will take place with management on the implementation of this policy and any amendments to practice.

Definitions

Any reference to ‘equality grounds’ shall be taken to include all the following grounds:

• Gender (to include transgender)

• Civil or family status

• Religious belief or political opinion

• Disability

• Race or Ethnic Origin

• Nationality

• Sexual Orientation

• Age

• Membership of the Traveller Community

Direct Discrimination

Direct discrimination occurs when a person is treated less favourably than another is on any of the equality grounds listed.

Indirect Discrimination

Indirect discrimination can occur when a requirement or condition, which cannot be justified on

grounds other than any of the equality grounds, is applied equally but has the effect in practice of disadvantaging a considerably higher proportion of persons in one or other of the above groups.

Disability Discrimination

Disability Discrimination occurs when, for a reason related to his/her disability, a disabled person is. treated less favourably than other people and this treatment cannot be justified. It also occurswhen an employer fails to comply with the duty to make a reasonable adjustment in relation to the disabled person, and if the failure cannot be justified. An employer cannot justify less favourable. treatment if, by making a reasonable adjustment, it would remove the reason for the treatment.

Victimisation

Victimisation occurs when a person is treated less favourably than another because that person. has, for example, asserted rights under any of the discrimination laws or has helped another. person to assert such rights or given information to the relevant statutory body, or because it is. suspected that the person might do any of these things.

Policy

GPG are opposed to all forms of unlawful and unfair discrimination and are committed to implementing equal opportunities in all its employment policies, practises and procedures, without discrimination on any equality grounds. To this end, for all employees and job applicants, it will ensure that the principles of employment equality are applied to recruitment, pay and benefits, promotion, training and to all terms and conditions of employment. Specifically, this means:

• Equal access to employment, promotion, and training, on merit, without reference to any of the equality grounds.

• Equality in conditions of employment

• A working environment free from harassment on any of the equality grounds

Through this policy GPG will help all employees to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation. This will include where necessary taking lawful positive/affirmative action.

Affirmative Action

Where appropriate, lawful positive action measures such as special encouragement in advertisements or special training will be developed. These measures are available to us in certain circumstances, for example where there is an under-representation of a particular group in specific areas of work. Any act which contravenes the equal

opportunity policy and practice will be regarded as gross misconduct and may lead to disciplinary action including dismissal being taken against an employee in breach of the procedure.

Complaints

Employees who believe that they have suffered any form of discrimination, harassment or victimisation are entitled to raise the matter through the following procedures:

• Grievance policy

• Anti-Bullying and Harassment Policy

GPG are committed to ensuring all complaints of discrimination will be dealt with seriously, promptly and confidentially. Every effort will be made to ensure that employees making complaints will not be victimised. Any complaint of victimisation will be dealt with seriously, promptly, and confidentially. Victimisation will result in disciplinary action and may warrant dismissal.

The use of internal procedures does not replace or detract from the right of the employees to pursue complaints under any relevant legislation in either jurisdiction. Complaints on any of the grounds, apart from equal pay or fair employment, should be lodged with the Equality Authority within six months of the alleged act of discrimination.

Complaints on the grounds of equal pay can be lodged within three years before or three years after a specific date. Complaints to the Equality Authority must be within six months of the last alleged act of the discrimination.

Monitoring and Review

The provision of equality of opportunity between gender will be monitored through the collection and analysis of statistical data on the community background, ethnic background, gender, age, sexual orientation, civil status, status as a disabled person of all employees and job applicants. Progress on the implementation of this policy and any equal opportunities and affirmative/positive action programmes will be reviewed annually in consultation with management and employees. The Organisation will monitor and review its equal opportunities policy with regard to provision of equal treatment.

Section 2: Getting Started

2.1 A small flavour of the GPG People Benefits.

Learning & Development: in collaboration with your manager, you will have a personalised learning and development plan. Learning and development supports are available across our learning platforms. We also support exam and study leave for company approved exams. GPG are committed to the training and development of all employees and views training as the key to assisting each individual to be the very best that they can be.

Study Tuition Assistance and Exam Leave: During the Performance Review process, training needs may be identified. Also, employees may decide themselves to pursue further education. All requests for work-related education will be considered on an individual basis and dependent on circumstances. Time off for companysupported exams is also available as outlined in our exam leave policy

Hybrid Working: We aim to provide flexibility via hybrid working, supporting your overall work-life balance. If your role allows, you can avail of hybrid working, 2 days per week, once your training period has been completed. Monday is an anchor day allowing all colleagues to come together in the office. Full details are available in our Remote-Working Policy.

Annual Leave: All permanent full-time employees will receive 25 annual leave per annum. Part-time employees receive their entitlement on a pro-rata basis. The holiday year runs from 1st January to 31st December.

Christmas Closure: As a business, we close for the Christmas period. On average each year up to five days of your holidays may be fixed during the Christmas/New Year period. The number of fixed days to cover this period may change each year.

Employee Assistance Programme (Laya): Employee well-being is at the forefront of everything we do in GPG. We understand that our employees face difficult times and individual challenges. As a result, we have partnered with Laya Healthcare to provide an Employee Assistance Programme. This service is available 24 hours a day 365 days a year. Some of the supports on offer include mental wellbeing, counselling, financial and legal information, life coaching, and parenting coaching. This support is for you, your spouse/partner, and any dependents over 16

still living at home and is completely confidential. Please call 1800911909 or visit https://layaeap.ie/login for more information.

Mental Health Champion Programme: We have a number of trained mental health champions across the organisation. Details can be found on the Intranet/HR Policies and Procedures/Wellbeing or from your manager or HR. Here you will also find other external supports available.

Wellness and Social Calendar: We understand how essential it is to look after your health and wellness. Our partnership value and culture support opportunities to collaborate and connect with colleagues and team members, through monthly breakfasts, team events, and other social activities. We believe that by demonstrating our values of respect, excellence, and partnership we can all benefit from these ways of working.

Payment of wages: You are paid on fortnightly basis by bank transfer to your nominated bank account. Payslips are password protected and emailed each fortnight detailing payment of wages and taxes paid.

Bonus: All non-bonused employees have the opportunity to earn a bonus of between €500 and €3000 each year. This is based on company performance and individual performance. (50% Company 50% Individual). Bonus payments are made end November each year. Your manager will outline your individual objectives at the beginning of the financial year (November). The company reserves the right to amend or change this scheme

Pension: General Paints Group operate a Pension and Death in Service Benefit Scheme for permanent employees. The scheme operates on a defined contribution basis and that contribution is currently 10% of basic salary The company contributes 7% and the employee contributes the balancing 3% Staff members are eligible to join the Pension Scheme once they have successfully completed their probationary period. If you wish to contribute to a PRSA until such time as you become eligible to join the company Pension Scheme, we can facilitate this for you. Full details of the schemes are available from Human Resources.

Personal Retirement Savings Account (PRSA): All employees have the option to join the PRSA scheme at any time during their employment. You will be allowed access to the company nominated PRSA provider, to consult in relation to your pension requirements. Full details of the scheme, including an explanatory booklet and payroll deduction authorisation form is available on request from the Head of Finance.

GPG Sick Pay Scheme: The Scheme,which is opento all employeeswho have successfully completed their probationary period, is designed to help alleviate any hardship caused by loss of earnings due to absence from work through genuine illness. GPG Sickness benefit is paid in conjunction with

Statutory Sick Pay outlined below. Sickness benefit will be paid from day 4 of sickness and will be paid by the company at two-thirds of gross basic salary. (exceptions apply if Statutory Sick Pay owing)

Statutory Sick Pay (SSP): Under the new Act employees are entitled to 5 statutory sick days during 2024, increasing to 10 days by 2026. This entitlement is subject to you working for GPG for a minimum of 13 weeks and the submission of a medical certificate to cover each day of absence. SSP will be paid at 70% of basic gross salary up to a maximum of €110 a day.

You will be paid up to a maximum of 6 weeks in any one year or continuous period of absence on the submission of medical certificates.

This 6-week period includes your entitlements under the Statutory Sick Pay and GPG Sick Pay Scheme (5 Days SSP (1 Week) and 5 Weeks GPG Sick Pay Scheme).

Christmas saving Scheme: To assist your planning for the seasonal expense of Christmas you have the option to save through your salary which is annually reimbursed at the end of November.

Employee Parking: With the exception of MRCB, all GPG sites have employee parking. All parking spaces with direct access to the shop must remain open for our customers. Employee car parking is provided in general areas alongside the factory or retail store. Employees are required to park in these general areas to facilitate our retail customers and contractor vehicles. GPG is not responsible for any damage caused to employee vehicles

Bike to Work scheme: We are delighted to partner with Travelhub to make accessing the Cycle to Work benefit as easy as possible for everyone following the successful completion of their probation period.

Staff Paint Account: All permanent employees are entitled to purchase paint, wallpaper, and sundries at a discounted rate through a Staff Paint Account facility Paint purchased through the Staff Paint Account facility should be for that staff member’s personal use, should not exceed €1,500 in any calendar year and must be paid for within 30 days. No paint, product or sundries can be taken from our stores or the site by an employee without it going through their paint account.

Employee Recognition Awards: Yearly we have a peer-to-peer recognition award ceremony that shines a light on our fantastic colleagues as they demonstrate our values and guiding behaviours in action. We also celebrate our long serving employees.

Volunteering Programme: Our partnership with, and impact on our community is taken very seriously by GPG, and we recognise how important it is to our employees to contribute with purpose and give back as a company. Each year we choose a project in our community to support.

Refer a Friend Scheme: We have a very attractive friend referral policy that allows you to refer a friend to GPG. If your friend is appointed, you will receive a €100 gift card after 1 month of their employment, and another €150 gift card when they have successfully completed their probation.

2.2 Induction and Onboarding

A smooth and systematic orientation of new employees leads to a more positive integration into the company When a new employee joins the company, they will immediately undergo induction training that includes details of their job responsibilities, training plan, work and safety instructions, dignity and respect, EAP, grievance and disciplinary procedures, and general work guidelines about how the company operates. Each manager is responsible for ensuring that a new employee receives adequate support in their first weeks with the company

The purpose of the induction programme is to allow all new or promoted employees to be given the necessary information about their job and the organisation,to assist their integration into their new role in the organisation, to enhance their motivation, and to achieve improved productivity

All new employees receive induction from Human Resources. This includes being given information on their new role, the department they have joined, facilities available to employees, company policies and procedures, conditions and agreements relating to their employment, and access to this handbook, and other relevant information

The line Manager will introduce new employees to employees and managers and conduct them through the premises in order to allow them to familiarise themselves with all company facilities.

Health and safety procedures, including emergency procedures such as Fire, Evacuation and Accident reporting will also be explained and demonstrated at regular, prescribed intervals thereafter.

2.3 Your Duties and Obligations as a team member

Time Keeping and Attendance

It is the company’s policy to implement a high standard of time keeping and attendance across the company in order to facilitate the effective running of the business. The company expects all employees to be reliable and punctual in reporting for work All employees are paid on the basis of the hours specified in their contracts of employment and are required to commence and finish work at the designated times. The management has the right to manage time and attendance. Punctuality in terms of employees going to and returning from meal breaks is essential. High levels of unexpected absenteeism will be monitored and addressed in line with policy, Employees that are not at their workplace at the appointed starting times are considered to be late. If an employee has a record of lateness or high absenteeism this may, depending on the circumstances, be reflected in a counselling session / performance management. If the problem persists, the disciplinary procedure will be invoked.

Employees must get verbal permission from their manager prior to leaving the premises during working hours, regardless of the reason. Any absence from work during regular working hours which is not agreed with an employee’s manager may be subject to disciplinary action

Sickness

All employees are expected to be reliable, attend for work as expected and be on time in reporting for work If you are sick or unable to attend work for any other reason, you must contact your immediate manager, by phone, within 1 hour of your expected start date on the first morning of absence. You are required to outline the reason for your absence and your likely return to work date during the initial contact. In the event that your illness continues you are required to contact the company 1 hour before your expected start time, on the date you were due back to work, outlining the revised return to work date.

Dress Code

Employees should ensure that they adhere to the highest standards of personal appearance and groomingat all times and dress in clothesthat are suitablefor the worksituation Moderate jewellery may be worn once it does not present a safety hazard. Tattoos should be covered by standard clothing when meeting external clients.

General Hygiene

The company considers it important to maintain a clean working environment, and to ensure that the cleanliness and tidiness of the premises is kept to a high standard for the purpose of hygiene, safety, and customer satisfaction All employees are required to contribute to maintaining a clean and healthy working environment, thereby showing courtesy to fellow employees and visitors

Concerning general hygiene, we request that staff comply with good workplace hygiene and good hand and respiratory hygiene. Common areas including canteen and meeting areas should be left clean after use. All employees are responsible for ensuring that all areas that they use are kept clean and tidy to the highest standards possible. These areas include your workstation, reception area, printing and photocopying area, any communal areas you use, etc. All personal belongings i e handbags, coats, etc should be stored away in your desk area / or the locker provided

Please ensure that your work area is left clear at the end of your workday, with all equipment and documentation put away Please do not store food in your work area

Personal Hygiene

Employees are, with respect to clothing, personal hygiene and appearance required to present themselves in a professional manner, suitable for the role they are performing.

The following hygiene requirements are applicable to all employees:

• Maintain personal cleanliness by showering regularly.

• Oral hygiene (brushing of teeth) required.

• Use deodorant/ antiperspirant to minimize body odours.

Clean Desk

We operate a clean desk policy to protect any personal or sensitive information held or processed by the Company and to enable our culture of security and trust within GPG. We are committed to the protection of personal information, including that of customers, clients, and employees and as such utilise electronic systems for data reading and access where possible. Due to the nature of our business, it is necessary for the Company to retain some sensitive information and a large amount of personal information relating to employees, customers, suppliers, and other business partners.

In addition to being a requirement under Data Protection legislation, a clean desk policy is an important tool to ensure that all sensitive/confidential materials are removed from desks and workspaces, and locked away when the items are not in use, or an employee leaves his/her

workstation. An effective clean desk effort involving each GPG employee will increase employee’s awareness about protecting sensitive information, along with encouraging paperless and tidy work areas.

Paper usage in GPG is high, with many documents printed that may not need to be. Please think before printing a document if you really need to print it out. To reduce waste please dispose of recyclable products in the correct bins on a regular basis.

Staff Hub / Canteen Areas

Employees are required when using the kitchen/canteen areas to ensure that it is left in a clean, tidy condition. The worktop, table, etc. should be cleaned down before leaving the kitchen. All items that need to be refrigerated must be placed back in the fridge. All food items stored in the fridge must be removed following their expiry date. Please either wash or put all your dishes into the dishwasher and turn it on if it's full. Your help in unloading the dishwasher, would also be appreciated.

GPG Head Office Meeting rooms

Employees are required to book the meeting rooms via the meeting calendar in outlook and asked to be considerate of timings. If meetings run over, please ensure the room is not booked for another meeting. Meeting rooms should be left in a clean, tidy condition with all waste removed from the room.

Corporate, Social and Environmental Responsibility – Waste Management

The company is committed to being a responsible corporate citizen and supporting community and environmentally friendly practices. The company aims to support the environment and manage its business activities in a responsible manner. Please familiarise yourself with the waste management activities in your work area, which set to minimise wastage and maximise recycling. We require all employees to act in a responsible manner in relation to the use of materials and equipment and welcome all new suggestions to minimise wastage and streamline our business activities.

Personal Property

The company does not accept any responsibility for any personal property including motor vehicles belonging to an employee, which is left on the premises. Employees are strongly advised not to bring large sums of money or valuable articles to the workplace. Where lockers are provided, employees are required to use them for all personal belongings. As an employee you

should report all property lost or found to your direct manager Any employee found interfering with another employee’s belongings would be subject to disciplinaryaction,up to and including dismissal.

Personal Messages and Telephone calls

Personal phone calls should only be made or received when there is an urgent need to give or receive a short message. Frequent, extended, and non-urgent personal calls should not be made or taken during working hours

Use of Mobile Phones

In consideration of other team members and for health & safety, the use of mobile phones is forbidden on the floor. In all areas mobile phones whether for calls, texting, social media or playing games may only be used during breaks. In the event someone is trying to contact you in an emergency, please ask them to call reception on 01 6288224, where you will be notified immediately. Failure to adhere to this may result in disciplinary action.

Company Property & Information

Each employee is required to respect all company equipment used in the course of their employment, for example computers, materials, vehicles, equipment, printers. Misuse of such equipment or the unauthorised removal of any company property or information from the premises is considered a serious offence and would be dealt with under the disciplinary procedure.

Use of Company Phones

Business telephones and mobiles are not for private use. Where there is an emergency or a specific need then personal calls can be made/taken during business hours. Abuse of this facility may lead to disciplinary action. Where employees possess mobile phones, they should show consideration to work colleagues so that where possible, phones are switched off during the working day and personal calls are kept to an absolute minimum

Transport

Transport to and from work shall be the responsibility of the individual. Any temporary arrangements made from time to time by the company cannot be deemed to mean that the company has assumed responsibility other than for the temporary period unless otherwise agreed.

Standard Operating Procedures (SOPs)

All employees must adhere to the SOPs in place across the organisation. SOPs are a set of written instructions that describes the step-by-step process that must be taken to properly perform a routine activity.

SOPs should be followed the exact same way every time to guarantee that the organisation remains consistent and where relevant compliant with industry regulations and business standards.

Standard operating procedures provide the policies, processes, and standards needed for the organisation to succeed. They benefit GPG by reducing errors, increasing efficiencies and profitability, creating a safe work environment and producing guidelines for how to resolve issues and overcome obstacles. SOPs can be stand-alone task specific, team based or companywide.

Each department has its own set of SOPs appropriate to the tasks completed. In addition, there are companywide SOPs which must be followed by all employees.

Confidentiality/non-compete

Every effort is taken by GPG to ensure that the company’s and our clients’ affairs are treated with absolute confidentiality, and you should note the following provisions, in particular: -

You will be expected to keep all information concerning the company, its counter parties, and any other company with whom you are involved as an employee of the company, absolutely confidential. Any deliberate breach of confidence will be regarded as a matter justifying summary dismissal.

You will deliver to the company, on termination of your employment, or at any time it may so request, all memoranda, notes, records, manual, programmes or any other documents or property belonging to the company or relating to its or their customers and or counter parties, which you may then possess or have under your control. You may not, without the company’s consent, keep copies of same.

You may not remove from the company’s premises at any time, without proper advance authorisation, any document or other property which belongs to the company or contains or refers to any confidential information relating to the company, its counter parties and/or customers. You will return to the company, after termination of your employment any documents or other company property that subsequently comes into your possession or procurement in the future.

You will not share, access, or distribute any company information to your personal email address or personal devices, without specific authority from the Managing Director or HR.

You will not share any information regarding GPG employees, business, or customers with any third parties, during or after employment with GPG

Out of Office

GPG is committed to identifying our customer’s points of contact within the company and improving them all. To this end, please ensure that when you are out of the office, for longer than 24 hours, reception is aware of your absence and its duration, and who can be contacted in your absence. Auto response detailing the duration of, and who to contact in your absence should be set up for your email and voicemail. Please ensure land line, email, and mobile, messaging is consistent to ensure no disruption to our service to customers, during your absence.

Double Employment

It is a condition of your employment that you do not work for, nor have any interest in any other company or business, nor undertake any other activity which might interfere with the proper performance of your duties or compete in any way with the company’s activities without first obtaining, in writing, the consent of the Human Resource Director.

Where permission is granted, there is a legal requirement for the company to ensure that an employee working outside the company in his/her own time does not exceed the maximum 48hour average working week Therefore, all employees are required to inform their manager, in writing, should they currently, or intend in the future, to carry out a second job, stating the days/hours of work. Regular reports will be required thereafter.

Medical Examination

The company reserves the right to ask potential new employees to attend for medical examination prior to taking up a position with the company or during employment. When this right is exercised by the company, and at the company’s expense, the medical examination will be carried out by the company doctor.

Fraud

Any employee suspected of fraudulent or related activities against the company will be immediately investigated. If necessary disciplinary action up to and including dismissal and legal action may be taken.

Private Trading

Private Trading on the company ’ s premises is not permitted and may lead to summary dismissal.

Statements to the Media

No employee of the company may speak or communicate in any way with local or national newspapers, magazines, radio, or television channels etc. on matters concerning GPG’s affairs without prior authorisation from the Marketing Department.

Fidelity / Confidentiality

Employees are required not to divulge secrets, or any information regarded as confidential by the Company to any third party during, or after, their time of employment with the Company. This directive specifically relates to information on the company’s financial position and annual performance, product formulations, pricing structures, growth plans, projections, etc.

No employee may set up or run, or propose to run any business, which might be deemed to be in conflict with their employment with the company. During your employment with GPG, you may not, without the consent in writing of the company, at any time either solely or jointly, carry on or be engaged or be concerned or interested in any business, trade or calling, other than that of the company while on company time. Failure to adhere to this may result in disciplinary action up to and including dismissal. The removal of any product formulations or information sensitive to GPG and the solicitation of business from the company will be considered as gross misconduct

Flexibility / Interchangeability

Due to the nature of our business and the product we manufacture, employee flexibility is required The company reserves the right to make changes to duties carried out and hoursworked according to business/ customer requirements.

Transferring to another work location

At the request of management, you may on occasion be required to work at another location Such transfers may be short term or permanent Where possible the company endeavours to supply you with as much notice as possible. Transport to and from a new location on either a permanent or temporary basis, will be the responsibility of the employee.

Lay off/ Short time working.

The employer reserves the right to lay you off from work or reduce your working hours, where through circumstances beyond its control it is unable to maintain you in employment. You will receive as much notice as is reasonably possible prior to such lay-off or short-time. No payment will be made for any period of layoff Payment will only be made for hours actually worked during any period of short time.

2.4 Working Hours, Rest Periods and Timekeeping

The purpose of our Organisation of Working Time policy is to communicate the company's commitment to the health, safety and welfare of all employees regarding their working time.

Normal weekly working hours are as laid down in your contract of employment and total 39 hours per week Employees working more than 39 hours per week must have hours preapproved and signed off by their manager. Any hours worked outside the 39 hours are unpaid unless authorised by a manager. Employees who are contracted to work variable hours will be given a minimum of 48 hours advance notice of their working hours.

It is company policy to pay all full-time employees on the basis of a 78-hour fortnight. Start and finish times vary depending on local requirements and as specified in individual contracts of employment. For rostered employees, a fortnightly roster will be produced, and available to you on the HR app, outlining your working hours for the fortnight ahead. You will be required to be in attendancein a timely manner during all the required periods. No change of personnel may take place without prior approval of your manager.

Breaks

Employees at work for more than 6 hours are entitled to a 30 min lunch break each day, which is unpaid. There is a legal requirement that all such employees must take a minimum of 30 minutes for their lunch break Employees who are at work for more than 4.5 hours and less than 6 hours will be entitled to a 15-minute unpaid break If you are unable to take a rest break in your job, you are advised to notify your manager in writing (within one week) that you were unable to take this break. Your manager will look at the reasons why you were unable to take your break and any health and safety issues that might or have arisen relating to you and your job. If you do not notify your manager within one week you will forfeit that break. If after investigation you are offered the

break and refuse, you are at fault and the Company is not obliged to offer you a further rest break. However, we do aim to ensure employee’s rest breaks are taken.

As per each employee’s contract of employment, from time-to-time business dictates the need for you to be flexible in your hours of work Each employee must be prepared to allocate any additional time necessary to fulfil your role, meet deadlines and complete any tasks reasonably requested at the discretion of the company. In the event that employees are required to work extra hours, every effort will be made to ensure that they are given prior notice as soon as possible to enable them to work

Rest Periods

Each employee is entitled to a minimum of 11 hours consecutive rest per day Every employee must take a complete day’s rest once a week, preceded by 11 hours daily rest Any requirement to work 7 consecutive days will be discussed with the relevant employee and in such instances the employee will be entitled to 48 hours continuous rest in a 14-day period. Unless stated in a contract of employment, employees’ weekly rest period shall include a Sunday

There is a legal requirement to ensure that employees do not work more than an average of 48 hours a week over a 4-month reference period. To enable us to regulate all employees’ working hours you are required to record your working hours and breaks from the time you start work each day to completion time. You will be given details of the system we use to record working hours by your manager. Persistent lateness, leaving before your scheduled finishing time, absenteeism, or failure to record hours will be regarded as a non-compliance with company policy and is therefore subject to the disciplinary procedure

Protection of Young Persons

GPG operate in line with the requirements of the Protection of Young Persons Act which outlines conditions of employment, hours of work and rest periods for 16- and 17-year-olds.

Workinghours,timeoffandrest periodsfor16&17yearsolds

Maximum working day: 8 hours

Maximum working week: 39 hours

Half hour rest break after 4.5 hours work

Daily rest break: 12 consecutive hours off

Weekly rest break: 2 days off, as afar as practicable to be consecutive.

Recording hours of work

GPG keeps a record of each employee’s hours of work for payroll, break and leave purposes through our HR App. For rostered employees, rosters are generated through the app and are available for all employees to access through their phone or computer on a weekly basis. Any differences in your working hours and rostered hours, must be notified immediately to your manager. Acceptance of published rosters are taken as agreement that rostered hours were worked; breaks were taken, and hours are correct for payroll purposes. You will also be required to sign that hours worked are correct.

For all other employees, you will need to generate your weekly timesheet on the HR App. A timesheet will then be automatically submitted by the App, reflecting your normal working hours, at the end of each week. Any hours outside of this, which are manually edited, will be submitted to your manager for approval. Time in lieu arrangements must be pre-agreed with your manager, following the correct procedure. Failure to adhere to the above or falsifying records is a disciplinary offence.

Part Time Working

The company is committed to the equal treatment of all employees and will therefore provide equal terms and conditions of employment to part-time employees, on a pro-rata basis, comparable with those offered to full-time employees. Requests for part-time working will be considered and facilitated where feasible in line with business requirements. The company will provide information on the availability of full-time and part-time positions which may enable employees to transfer from full-time to part-time work and vice versa

The company defines a part-time employee as an employee whose normal hours of work are less than the number of hours of work in the company, namely 39 hours per week A part-time employee will have his/her agreed contractual hours outlined in their contract of employment, and the following conditions apply:

• Remuneration benefits will be pro-rated to those of an equivalent full-time employee, based on the number of contracted hours of a part-time employee

• Salary increases will be administered similar to full-time employees, on a pro-rated basis.

• Part-time employees will have their annual leave entitlement calculated under the company's holiday policy, on a pro rata basis.

• Part-time employees who work a minimum of 40 hours during the 5 weeks preceding a public holiday will qualify for public holiday benefit. Where the employee’ s normal weekly hours require them to work on the day in which the public holiday falls, they will receive a normal day's pay.

• Part-time employees who are not due to work on the public holiday are entitled to the benefit of 1/5 of their normal weekly pay, or the equivalent in time off, to be agreed with their manager.

• Part-time employees will have full access to relevant training and development programmes Training and development requirements will be assessed in the normal manner.

Requests to return to full-time work will be accommodated where possible. However, there is no automatic right to return to full time employment. If a part-time employee wishes to return to full-time employment, they must do so by applying for any other full-time positions advertised internally by the usual process or otherwise by request, at all times, the company reserves the right to revert the position to full-time where it deems fit, i e., the arrangement no longer meets the business needs. Three months’ notice will be given to the employees.

Section 3: Working Together

3.1 Dignity and Respect

GPG is committed to working together to maintain a workplace environment that encourages and supports the right to dignity and respect in the workplace.

As well as treating people with dignity and respect, GPG strives to create a supportive environment in which all employees can flourish and reach their full potential, regardless of differences, experience, or education.

Attitudes and behaviours contribute to a positive working environment. Our Values of Respect Excellence and Partnership underpin everything we do.

Our policies and procedures outlined in this section underpin how we GPG are committed to a supportive and safe environment for all employees.

GPG are committed to: Creating an environment that promotes and encourages respect for others - supported by Anti Bullying & Harassment policy and Company Values

Treating all employees, the same equally and offering equality of opportunity

As well as treating people with dignity and respect GPG strives to create a supportive environment in which all employees can flourish and reach potential regardless of differences, experience, or education.

3.2 Grievance Procedure

Purpose and Scope

GPG is committed to creating and operating within an environment where every employee is treated with dignity and respect, and that fair and reasonable employment practices are operated across the board. We do realise however that problems are bound to occur from time to time and that failure to provide a procedure to deal adequately with these grievances, in a timely manner, may lead to disputes affecting not only the aggravated party but potentially all those employed within the organisation.

We want to ensure that all employees have open access to a process where they can discuss any problems or concerns relating to their employment with the company. Full recognition is given to the significance of personal grievances and both employees and employer are determined that all grievances will be dealt with without undue delay and at the earliest possible stage of this procedure. We believe that good communication can help to avoid misunderstandings and that most grievances can be handled by the immediate line manager without recourse to formal procedures.

The Company has the following grievance procedure in place and is committed to complying with the same thus ensuring that all grievances raised are handled consistently in accordance with the procedure.

The purpose of this document is to inform employees about the procedure. All employees of GPG are covered by this policy.

Responsibility

All employees must read the Grievance procedure and if they have any questions in relation to their understanding about the procedure address them with their manager or the HR department.

It is the responsibility of every manager within the company to deal with all grievances both effectively and efficiently, in accordance with this procedure, so that employees feel their problems have been addressed, and to note and notify their manager and/or the HR Department on the issues which emerge, as appropriate. The HR Department are responsible for providing assistance to managers in dealing with grievances.

Policy

In order to create an atmosphere of openness, problem-solving and mutual support, the following steps have been designed to resolve disagreements. The procedures are not to replace normal manager/employee dialogue but in situations where either this has failed to resolve the issue, or the employee considers that a more formal approach is appropriate. At each step, you may have a colleague with you.

You will not be penalised or victimised as a result of airing a grievance. If you feel that this is occurring, you should report it immediately to your line manager or their nominated deputy from time to time.

You may be disciplined in accordance with the Disciplinary Procedure if grievances are made in bad faith or maliciously. We reserve discretion to deal with any grievance in light of its specific facts in accordance with natural justice and fair procedures.

Procedure

Informal Discussion

It is often preferable for all concerned that grievances are dealt with informally. This is likely to produce solutions, which are speedy and effective. The informal procedure for dealing with grievances is outlined below.

If you have a grievance, you should approach your manager who will discuss the matter with you. If your grievance involves personal or other sensitive issues, which you would consider inappropriate to raise directly with your immediate Manager, you should seek advice from the HR department. If discussing the issue informally does not result in an acceptable outcome, you should invoke the formal procedure as outlined below.

Formal Grievance Discussion

At any stage in the formal process, you may choose to be accompanied by a colleague.

Stage One: Initial Formal Discussion

Failing settlement informally, the matter should be lodged in writing to your manager. Your manager or another appropriate person will investigate the grievance and will hold a meeting with you to discuss the outcome of the investigation. The outcome of this meeting will be communicated to you in writing, within three working days.

Stage Two: Second Formal Discussion

Should the problem remain unresolved, a meeting will be arranged between you, your manager, and a member of the Leadership team, to discuss the matter further. The meeting will be held within seven working days and the outcome of this meeting will be communicated to you in writing.

Stage Three: Final Discussion

Should the problem remain unresolved, you should present the problem or dissatisfaction in writing to the HR Director. You should also give your manager a copy of this letter. A meeting with the HR Director and any other interested parties will then be scheduled. The meeting will be held within seven working days and the outcome of this meeting will be communicated to you in writing.

Remote Investigations.

We will always endeavour to hold face to face investigation and disciplinary meetings and/or hearings. However, if this should not be feasible for public health/other government prescribed

reasons, or where otherwise necessary, then we may choose to proceed with a remote meeting/hearing in the interest of a timely resolution to the process.

External Stage

Should the matter remain unresolved, and the employee is dissatisfied and wishes to pursue the matter further then they may do so externally. It may be referred to an appropriate 3rd party. During the period in which the above procedure is being followed, normal working – under protest, if necessary, will continue.

Right to Be Accompanied

This does not apply at the Informal Resolution Stage. The right to be accompanied does apply when the formal procedure is being used. The accompanying person may be a work colleague, deemed appropriate by management to be involved in the investigation process. The Manager hearing the grievance has the right to know in advance of the meeting who the accompanying person attending the meeting will be.

Confidentiality

Where matters concerning any grievance are confidential, we will do our best to maintain confidentiality. Where witnesses and third parties are involved, it will be appreciated that this can be difficult to do. Regardless of whether a matter is being dealt with informally or formally, we cannot guarantee confidentiality.

3.3 Disciplinary Procedure

Purpose and Scope

General Paints Group (GPG) takes the view that in most cases, individual commitment and performance will be consistent with achieving company objectives. Should difficulties or problems arise, GPG is committed on a day-to-day basis to their resolution in an open, fair, frank, and timely manner. These procedures are designed to help and encourage everyone to achieve and maintain the required standards of conduct, attendance, and job performance. The following procedures will be applied in a fair and reasonable manner with due regard to the rights and responsibilities of the parties concerned.

Responsibility

All present employees of GPG.

Policy

The company is committed to treating all staff fairly and equitably and to helping employees to perform effectively However, there will be occasions when it may be necessary to invoke disciplinary procedures that are designed to protect the interests of both the company and its employees

When work falls below an acceptable standard, help will be given to the employee to improve. If standards of work continue to fall and there is a necessity for action, it will automatically begin with a pre-disciplinary informal discussion. Similarly, when an employee’ s behaviour is inappropriate and unacceptable, and this is officially deemed misconduct, it will mean the initiation of a pre-disciplinary informal discussion or the disciplinary procedure, depending on the severity

If disciplinaryaction should become necessarythen each casewill be treated consistentlyand fairly, and the disciplinary procedure will be strictly observed at all steps.

The employee will be given the opportunity to provide their version of events and any extenuating circumstances will be considered An employee’ s natural rights will be upheld at all times, and employees will have the right to:

• Know the case against him/her.

• Reply

• Due consideration

• Representation

• Appeal

All managers are required to use their best efforts to:

• Provide feedback at early steps to encourage and support employees to improve.

• Ensure that all cases are thoroughly investigated.

• Avoid any discrimination.

• Prepare carefully and be consistent.

• Keep adequate records.

• Adhere to this procedure.

Breaches of rules and regulations will mean the initiation of Step 1 of the formal disciplinary procedure If the company views an incident sufficiently serious, the person may be dismissed immediately, and the normal procedures will not apply.

Procedure

Stages of Disciplinary action

Investigation

An investigation will usually precede a disciplinary process. However, where the facts concern a matter of potential gross misconduct, we reserve the right to bypass the investigation process and go straight to a disciplinary hearing.

Prior to taking the decision to invoke the disciplinary procedure, the company will ensure that the situation has been thoroughly investigated. This is a fact-finding process and will necessitate. the gathering of detailed information as well as the carrying out of formal interviews, taking of written statements, etc

Proper investigation is an integral part of the process and on occasions may require employees to be suspended on full pay, whilst it is carried out Suspension on pay is not considered to be an action taken under the disciplinary procedure, it is there to ensure that issues are dealt with in a fair and reasonable manner, and adequate protection given to all employees

Equally, the employee has the right to gather information in their defence, so they can present details if the decision is taken to invoke the disciplinary procedure.

Once the investigation has been completed the manager will inform the employee of the findings and the outcome. Where the decision is taken to invoke the disciplinary procedure then the employee will be informed of the case against them, so they can respond in an informed manner at a disciplinary hearing.

Where the decision is taken not to take disciplinary action, the employee will be counselled. and details of the issue placed on the employee’s personnel file for record keeping purposes.

Remote Investigations

We will always endeavour to hold face to face investigation and disciplinary meetings and/or hearings. However, if this should not be feasible for public health/other government prescribed reasons, or where otherwise necessary, then we may choose to proceed with a remote meeting/hearing in the interest of a timely resolution to the process.

Informal Pre-Disciplinary Counselling Discussion

Where appropriate, prior to using the formal aspects of the company ’ s disciplinary procedure a pre-disciplinary counselling discussion will be held with the employee.

Minor misconduct, poor performance or minor breaches of rules will normally result in informal counselling or advice being given by the immediate manager. If that approach is not successful, the company is likely to escalate it to the formal disciplinary procedure

Steps in the Formal Disciplinary Procedure

This procedure will be used in cases of breaches of the rules or poor performance that have not been remedied by informal counselling. Normally the procedure will follow the steps listed below, although it is acceptable to move directly to Steps 2, 3 or 4 if a case appears sufficiently serious

From the first formal step of the disciplinary procedure there will be the presence of the immediate manager (if appropriate) in conjunction with another member of the management team. Employees are advised and have the option to have a willing work colleague present

At each step in the procedure a disciplinary meeting will be held where all the facts will be considered, and any mitigating circumstances discussed Where a warning is issued a copy will be placed on the employee’ s personnel file for the specified period. All warnings issued under this procedure will state clearly that the employee will be liable for further disciplinary action should their performance not improve or should there be a further breach of company rules. In the event of no further misdemeanours occurring and the performance improving, the warning will be removed, and the employee’ s file will be clear. The employee will also be advised of their right to appeal against the decision to take disciplinary action

Remote disciplinaries.

We will always endeavour to hold face to face investigation and disciplinary meetings and/or hearings. However, if this should not be feasible for public health/other government prescribed reasons, or where otherwise necessary, then we may choose to proceed with a remote meeting/hearing in the interest of a timely resolution to the process.

The steps in the disciplinary procedure are as follows:

Step 1: Verbal Warning

At the meeting an action plan including a scheduled time for improvement and date for reappraisal will be set. A record of the verbal warning will be given to the employee and a copy will be retained on the personnel file for 6 months unless there is repetition within the agreed review period. If there is no improvement in the situation, there will be a re-evaluation and an escalation to Step 2. This can happen before the end of the verbal warning period.

Step 2: First Written Warning

At the meeting, an action plan including a scheduled time for improvement and date for reappraisal will be set. A record of the written warning will be given to the employee and a copy

will be retained on the personnel file for 6 months unless there is repetition within the agreed review period. If there is no improvement in the situation, there will be a re-evaluation and an escalation to Step 3 This can happen before the end of the first written warning period.

Step 3: Final Written Warning

If the act is sufficiently serious in the first case, or there is still a failure to improve your work performance or conduct, a final written warning will be given to the employee A copy of this Final written warning will be retained on the personnel file for 12 months and will state clearly that the next step will be termination of employment if conduct and/or performance do not improve

Step 4: Suspension without pay.

In exceptional circumstances, dependent on the individual case, the company may exercise its discretion to suspend without pay This is action short of dismissal.

Step 5: Dismissal

There are two alternative courses of action available at this step in the procedure, depending on the circumstances: An employee will be procedurally dismissed if they have failed to improve during the previous steps Appropriate notice or payment in lieu of notice will be made.

In an instance of gross misconduct an employee will be dismissed without going through the previous steps of the procedure. In these circumstances a full investigation will be conducted, and a disciplinary meeting will be held which will follow the normal process and uphold an employee’s natural rights. Due to the serious nature of the situation, such as the offences outlined under Gross Misconduct, the option of dismissal warrants serious consideration, and the process is likely to result in dismissal without notice or payment in lieu of notice.

Offences

Misconduct

The Company will normally consider the following list of offences as misconduct and appropriate reason for initiating disciplinary action:

• Failure to follow the procedures in respect of absence due to sickness or injury.

• Minor breach of the written statement of terms and conditions of employment

• Minor damage to company property

• Minor breach of company rules

• Minor failure to observe company policies or procedures.

• Regular unreasonable and/or unexplained absences

• Poor time keeping

• Poor job performance

• Unauthorised use of and/or breaches of GPG IT/ Email usage policy

These examples are not exhaustive or exclusive, and offences of a similar nature will be dealt with under this procedure.

Gross Misconduct

In the case of gross misconduct or if all the appropriate stages of the above procedure have been exhausted, you may be dismissed, but only after consideration of other possible disciplinary sanctions.

Gross misconduct is misconduct serious enough to destroy the employment contract and make any further working relationship and trust between you and the Company impossible. It is not possible to set down a definitive list of all specific offences constituting gross misconduct, and, in any event, all cases will be dealt with on their own facts. The following non-exhaustive list provides examples of conduct which will be considered to be gross misconduct.

• Gross incompetence/ negligence

• Failure to adhere to Covid-19 guidelines and procedures.

• Failure to carry out the duties assigned to a position satisfactorily.

• Being disruptive, uncooperative, and negative in approach to work

• Acting in a manner which will bring the company into disrepute.

• Unauthorised use of the company ’ s assets and equipment

Insubordination e.g. refusal or deliberate failure to carry out duties or obey reasonable instructions, except where employee safety may reasonably be in jeopardy.

• Being absent from work without contacting the company

• Wilful/ deliberate absence from duty

• Sexual harassment, harassment, bullying, intimidation, violence

• Using threatening behaviour or language

• Serious breach of rules, policies or procedures, especially those designed to ensure safe operation and working environment.

• Breach of safety rules

• Sleeping during working hours

• Divulging or misusing confidential information causing a breach of fidelity / confidentiality

• Theft or unauthorised possession, serious neglect or malicious damage of any property or facilities of the company or of any employee of the company

• Consumption of alcohol or drugs, or intoxication by reason of drinks or drugs during working hours, or whilst representing the company, which could affect work performance in any way or have an impact on other employees.

• Having illegal drugs or alcohol in the possession, custody, or control of the employee while

• at work or on the company’s premises

• Smoking on the premises, with the exception of the designated areas

• Defrauding or attempting to defraud the company, its customers, suppliers, or fellow employees.

• Unauthorised or inappropriate use of telephone, e-mail, Internet and/or computer systems

• Falsification of any company records including reports, accounts, expenses claims or selfcertification forms.

• Claiming payment for hours or overtime not worked

• Serious or deliberate damage to company property

• Striking or threatening someone, violent, dangerous or intimidatory conduct

• Gambling or money lending while at work or on the premises

• The soliciting of gratuities from customers or suppliers

• Behaving in a manner that causes disrepute to the company.

• Bringing unauthorised person(s) onto company premises

• Conviction of any criminal offence which may render the employeeunsuitable for employment.

• Serious abuse of timekeeping and attendance procedures

• Unauthorised use of and/or breaches of GPG IT/ Email usage policy

• Failure to follow a company Standard Operating Procedure

This list of examples is not exhaustive or exclusive, and offences of a similar nature will be dealt with under this procedure. Gross misconduct will result in the initiation or escalation of the companydisciplinaryprocedure and may result in immediatedismissalwithout noticeor pay in lieu of notice.

If you are accused of an act of gross misconduct, you may be suspended from work while we investigate the alleged offence. During the period of suspension, you may be refused access to any of our premises and information and communications systems and subject to such other conditions as we may impose. You may be suspended without pay where there is a live final written warning on your personnel file and a further disciplinary breach has occurred within the term of the final written warning.

Any investigation in relation to a breach of the disciplinary procedure shall be carried out by us in accordance with fair procedures.

If, on completion of the investigation and after a disciplinary hearing, we are satisfied that gross misconduct has occurred, the result may be summary dismissal without notice or payment in lieu of notice.

Appeals

If you wish to appeal against a dismissal or other disciplinary action taken you should inform us in writing within seven days from the date of notification of the decision. At the appeal, any disciplinary penalty imposedwill beconsidered. Wewill endeavour,whenever practicable, ensure that theperson hearing the appeal has had no previous involvement in the disciplinary decision.

Disciplinary sanctions will take effect automatically pending the outcome of any appeal hearing. For the avoidance of doubt, this means that should a decision to terminate employment be communicated, all salary entitlement will cease on the date of notification of the decision to terminate.

You have the right to representation at any appeal hearing. At this meeting, you will be given your opportunity to fully present your case. As the person hearing your appeal has not previously been involved in the disciplinary process, you will receive a full and fair hearing. You will have only one right of appeal and the outcome of this appeal is final. Where a decision to dismiss is appealed and the decision is upheld, the date of termination of employment will be the original date of dismissal and not the date of the outcome of the appeal.

3.4 Anti Bullying and Harassment Policy

INTRODUCTION

Purpose and Scope

General Paints Group (GPG) is committed to protecting the dignity of all employees. In particular we are committed to creating an environment which respects diversity and equality, and where all team members are free from all forms of bullying, harassment and sexual harassment.

No bullying or harassment or sexual harassment within GPG or in connection with our work will be tolerated. Complaints of bullying or harassment may be dealt with either in a formal or an informal way. Complaints by employees or other persons in the workplace of bullying or harassment at work will be treated with fairness, sensitivity, respect and (as far as possible) confidentiality for all parties concerned. Any person accused of bullying or harassment will be afforded natural justice and treated with fairness and sensitivity.

The negative effects of bullying and harassment cannot be over-emphasised. Workplace bullying and harassment adversely affect an organisation by undermining employee morale and can result in absenteeism, stress-related illnesses, and higher turnover of staff. Bullying and harassment can have a devastating effect on the health, confidence, morale, and performance of those subjected to it. Bullying and harassment may also have a damaging impact on employees not directly subjected to inappropriate behaviour but who witness it or have knowledge of it.

The policy applies to employees both in the workplace and at work-associated events such as meetings, conferences, and work-related social events, whether on the premises or off-site.

Responsibility

Both GPG’s management and its employees have responsibilities for creating and contributing to the maintenance of a work environment free from bullying and harassment. Employees also have an obligation to cooperate with the investigation of complaints of bullying or harassment. Managers have a particular responsibility to implement this policy and to make every effort to ensure that bullying and harassment does not occur, particularly in work areas for which they are responsible. Managers and managers have an obligation to deal promptly and effectively with any incidents of bullying or harassment of which they are aware or ought to be aware.

Bullying, sexual harassment and harassment by employers, employees, and nonemployees such as suppliers, customers and business contacts will not be tolerated and could lead to disciplinary action (in the case of employees) and other sanctions, for example the suspension of contracts or services, or exclusions from premises (in the case of non-employees whom the employee might reasonably expect to come into contact with during the course of their employment

This document sets out:

• Section 1 - Respect, Dignity and Equal Opportunity at Work Policy

• Section 2 – Diversity, Equity and Inclusion Policy

• Section 3 - Bullying and Harassment & Sexual Harassment Policy

• Section 4 - Responsibilities – Employee and GPG

• Section 5 - Definitions of Bullying, Harassment and Sexual Harassment

• Section 6 – Preventative Measures

• Section 7 - Special Complaints procedure for raising a complaint.

SECTION 1: RESPECT, DIGNITY AND EQUAL OPPORTUNITY AT WORK

GPG is committed to creating an environment that promotes equality and dignity at work, that protects the dignity of employees and encourages respect for others. We are committed to treating all employees, customers, and business contacts equally and offering equality of opportunity, regardless of gender, civil status, family status, sexual orientation, religious belief, age, disability, race or membership of the Traveller community.

As well as treating people with dignity and respect, GPG strives to create a supportive environment in which all employees can flourish and reach their full potential, regardless of differences, experience, or education. Harnessing the wide range of perspectives this diversity brings promotes innovation and helps make us more creative and competitive.

All employees are required to take personal and individual responsibility to comply with these policies and behave in a non-discriminatory way and not to participate in any acts of inappropriate behaviour, harassment, or bullying. An individual will decide what behaviour is acceptable - not what the perpetrator, employer or another colleague finds acceptable.

Attitudes and behaviours that do not contribute to a positive environment and which are contrary to our policies are detrimental to everyone and therefore will not be tolerated. Our policies and procedures will underpin the principles and objectives of this policy.

SECTION 2: DIVERSITY, EQUITY AND INCLUSION POLICY

GPG is committed to a workplace environment that promotes diversity, equity and inclusion and creates an open, equal and inclusive culture where everyone feels valued.

GPG believes that embracing inclusivity, equality and diversity in the workplace benefits not just the organisation but also individual employees and our customers. All our employees bring their own background, work style, distinct capabilities, experience, and characteristics to their work. We

recognise that our talented and diverse workforce reflects the diversity of our customers and markets, and we want to utilise the widest range of skills, knowledge and experience in our business while complying with legislation.

We recognise that a “one-size-fits-all” approach to managing people does not achieve fairness and equality of opportunity for everyone. As well as treating people with dignity and respect, GPG strives to create a supportive environment in which all employees can flourish and reach their full potential, regardless of differences, experience, or education. Harnessing the wide range of perspectives this diversity brings, promotes innovation, and helps make us more creative and competitive.

GPG committed to an inclusive working environment which respects diversity of characteristics including but not limited to sexual orientation, age, gender, race, ethnicity, disability, civil status, family status, membership of the Traveller community, personality, thinking style and religious beliefs. We will formulate and implement policies and practices that value diversity, provide equality of opportunity, and ensure that no job applicant, employee, customer or business associate receives less favourable treatment. We will also ensure that other policies and practices reflect our commitment to treating people fairly, promoting an integrated way of working and respecting the dignity of employees at all times.

This overall policy is supported by appropriate harassment and bullying policies, and disciplinary and grievance procedures. Employees who believe they have suffered discrimination, harassment or victimisation are entitled to raise matters through the appropriate GPG grievance or Bullying and Harassment Complaints procedure. A copy of these policies/procedures can be obtained by contacting HR or your manager.

Complaints will be treated seriously and will be dealt with in a confidential, expeditious manner in as far as reasonably practicable. Employees who make complaints will not be victimised for doing so. Victimisation, if proven, may result in disciplinary action which could result in a sanction of up to and including dismissal. Employees should be aware that making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our disciplinary procedure. Pursuance of complaints through these internal procedures does not prejudice an employee in pursuing matters through other available means.

This policy does not alter or amend employees’ contracts of employment or form a part of any such contract of employment. GPG may amend or change this policy from time to time. The policy will be

reviewed on a regular basis to assess its compliance with updates to the relevant legislation, and to assess the effectiveness of its implementation and operation in creating a truly integrated workplace.

Managers are expected to promote an integrated workplace and proactively eliminate any potential inequities that may run counter to our policy.

Our recruitment policy reflects our belief that diversity in all areas, including cultural, generational, language and national backgrounds, is necessary in helping us succeed in both domestic and global markets. GPG will not discriminate against any prospective employee during the recruitment process. Interviews will be carried out objectively and individuals will be judged on merit and their ability to do the job. It is our policy to ensure that as much accommodation as possible is carried out to facilitate the participation of individuals with special needs in the recruitment process and in the workplace.

Performance appraisals and feedback will be carried out in a sensitive, non-discriminatory manner. GPG will offer the same development and training opportunities to all employees to achieve high standards of performance. We will reward excellence and employees will be promoted based on merit.

SECTION 3: ANTI-BULLYING, HARASSMENT, AND SEXUAL HARASSMENT POLICY

Policy

GPG believe that fundamental to the concept of equality and respect for others, in the working environment, employees should be free from any activity or behaviour that adversely affects a person’s dignity. We believe bullying, harassment and sexual harassment are totally unacceptable forms of behaviour in the workplace. Every team member has a right to dignity in the workplace and should be free to conduct their work without intimidation, humiliation, or harassment.

Behaviour which is contrary to our policy on bullying, harassment and sexual harassment will not be tolerated by us, whether this behaviour is directed at other team members, clients, customers, associates of the Company or members of the public.

Allegations of bullying, harassment or sexual harassment will be dealt with in an objective and sensitive manner with the utmost confidentiality being preserved for all parties involved. It is

important to note that while we will make all reasonable efforts to protect the confidentiality of the process, confidentiality cannot be guaranteed.

The purpose of the GPG policy on bullying, harassment and sexual harassment is twofold:

Raise awareness of expected standards of behaviour

First, it is to make all team members aware of the standards of behaviour which are expected when you are carrying out duties in the course of your employment and/or in the workplace. Every team member, regardless of their position, has an obligation to be aware of the effects of their own behaviour on others and is asked to respect and consider the beliefs of their colleagues. The same standards are expected to be observed when you are away from our premises on business, e.g., at client meetings and at any work-related event which takes place outside of office hours, e.g. the Christmas party/Friday night drinks/socialising with suppliers or customers.

Complaints regarding behaviour which is alleged to be bullying/harassment/sexual harassment will be investigated in accordance with our complaints procedure and if the complaint is well founded, the person complained about will be dealt with under our Disciplinary Procedure. Accordingly, penalties or sanctions may be imposed up to and including a final written warning or dismissal.

Raise awareness of procedures

Secondly, the purpose of this policy is to promote awareness of the steps which you should take if you feel you are being bullied, harassed, or sexually harassed. Accordingly, any team member who considers that they have experienced such behaviour at or in connection with their work should report it through the Anti-Bullying and Harassment complaint’s procedure.

SECTION 4 – RESPONSIBILITIES – EMPLOYEE AND GPG

Employee responsibility

All employees have a responsibility for ensuring the dignity and respect of their colleagues and contacts in the workplace, and to creating and contributing to the maintenance of a work environment free from bullying/harassment or from conduct likely to contribute to bullying or harassment.

Depending on its severity, bullying, harassment, or sexual harassment may constitute gross misconduct with sanctions of up to and including a final written warning or dismissal.

GPG responsibility

GPG has a responsibility to ensure that sexual harassment, harassment and/or bullying do not occur and that any complaints are addressed speedily and appropriately. Accordingly, all managers and directors of the Company are expected to:

• Manage and conduct work activities in such a way as to prevent any behaviour which is likely to put at risk any employee’ safety, health, and welfare at work.

• Be a good example by treating all in the workplace with courtesy and respect.

• be vigilant for signs of harassment/bullying/sexual harassment and take action before a problem escalates.

• respond sensitively to a team member who makes a complaint.

• ensure the procedure to be followed if a complaint is made.

• ensure that a team member making a complaint is not victimised for doing so.

• ensure that those who participate in an investigation, for example as a witness, are not victimised for doing so.

• monitor and follow up the situation after a complaint is made so that the inappropriate behaviour does not recur.

SECTION 5: DEFINITIONS – BULLYING, HARASSMENT & SEXUAL HARASSMENT

The interchangeable use of the words harassment and bullying can lead to a misunderstanding of what each one relates to. They are legally distinct concepts and so a behaviour can be deemed to be either bullying or harassment, not both.

Bullying

Whereas harassment can comprise of one isolated incident, workplace bullying normally involves repeated inappropriate behaviour by one or more persons against another or others at the place or work and/or in the course of employment which could reasonably be regarded as undermining an individual’s right to dignity at work. The inappropriate behaviour can be direct or indirect and verbal, physical, or otherwise. Bullying behaviour may be practiced via cyber or digital means and applies to all employees in Ireland irrespective of whether employees work a fixed location, at home or are mobile.

Workplace bullying is defined in the Code of Practice for Employers and Employees on the Prevention and Resolution of Bullying at Work as:

“Repeated inappropriate behaviour, direct or indirect, whether verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment which could reasonably be regarded as undermining the individual’s right to dignity at work. An isolated incident of the behaviour described in this definition may be an affront to dignity at work but as a once off incident is not considered to be bullying”.

Bullying is more than a single occasion and can include, conduct offensive to a reasonable person, for example, oral or written slurs, physical contact, gestures, jokes, displaying pictures, flags/emblems, graffiti, or other material that state/imply prejudicial attitudes that are offensive to fellow employees.

If you feel that you are being bullied, we urge you to air your grievance as soon as possible and in accordance with our Anti- Bullying and Harassment Complaints Procedure.

Other examples of bullying behaviour include.

• personal insults and name calling

• persistent unjustified criticism and sarcasm

• public or private humiliation

• shouting at staff in public and/or private

• sneering

• instantaneous rage, often over trivial issues

• unfair delegation of duties and responsibilities

• setting impossible deadlines

• unnecessary work interference

• making it difficult for staff to have access to necessary information.

• aggression

• not giving credit for work contribution

• continuously refusing reasonable requests without good reason

• intimidation and threats in general

This list is illustrative rather than exhaustive.

What is not bullying at work?

It is important to distinguish bullying from other inappropriate behaviours or indeed appropriate workplace engagement. As set out in the definition above, a once-off incident of bullying behaviour may be an affront to dignity at work and may be unsettling but does not of itself make for an adequate level of distress as to fall within the definition of bullying and other remedies should be sought for these scenarios. As a once-off, such behaviours cannot be presumed to be done in a targeted, purposeful, and unremitting way.

Apart from once-off behaviours, other on-going behaviours which may upset or unsettle a person may not come within the bullying definition either. Behaviour considered bullying by one person may be considered routine interaction by another, so the ‘reasonableness’ of behaviours over time must be considered. Disrespectful behaviour, whilst not ideal, is not of itself bullying. Conflicts and disagreements do not, of themselves, make for a bullying pattern either. There are various workplace behavioural issues and relationship breakdowns which are troubling, upsetting, and unsettling but are not of an adequate level of destructiveness to meet the criteria required for a bullying case. Objective criticism and corrections that are intended to provide constructive feedback to an employee are not usually considered bullying, but rather are intended to assist the employee with their work.

Bullying does not include:

• Expressing differences of opinion strongly.

• Offering constructive feedback, guidance, or advice about work related behaviour which is not of itself welcome.

• Reasonable and essential performance management of a team member at work shall not be regarded as bullying behaviour the continued signalling to a team member that their performance is at a level below required standards.

• Reasonable and essential disciplinary actions taken against a team member on grounds of safety, health, and welfare.

• Reasonable corrective action taken by an employer or manager relating to the management and direction of employees (for example managing a worker's performance, taking reasonable disciplinary actions, or assigning work)

• Workplace conflict where people disagree or disregard the others ‘point of view.

This list is illustrative rather than exhaustive.

Harassment

The Employment Equality Acts 1998 – 2015 define harassment as unwanted conduct which is related to any of the 9 discriminatory grounds, which has the purpose of violating a person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment for the person. It may consist of one incident or a series of incidents. The unwanted conduct may consist of acts, requests, spoken words, gestures, or the production, display or circulation of written words, pictures, or other material.

All team members should take care to ensure that their acts or conduct do not offend those that they come into contact with through their employment and to particularly ensure that no offence is caused on any of the following grounds:

• gender

• civil status

• family status

• sexual orientation

• religious belief

• age

• disability

• race

• membership of the Traveller community.

Acts or conduct which can constitute harassment includes.

• spoken words (such as jokes, comments, ridicule, or songs)

• physical harassment (such as jostling, shoving or any form of assault)

• intimidatory harassment (such as gestures, posturing or threatening poses)

• isolation or exclusion from work related social activities.

• pressure to behave in a manner that the team member thinks are inappropriate, for example pressure to consume alcohol where this is contrary to a team member’s religious beliefs

• written words or pictures – whether the team member creates or circulates these, for e.g., via office e-mail, text messages or notices.

• online harassment – e.g., contact on social media.

• any other material, for e.g., videos, social media posts etc.

This list is illustrative rather than exhaustive.

Sexual Harassment

Sexual harassment is any form of unwanted verbal, non-verbal or physical conduct of a sexual nature which has the purpose or effect of violating a person’s dignity and/or creating an intimidating, hostile, degrading, humiliating, or offensive environment for the person.

Many forms of behaviour can constitute sexual harassment. It includes examples like those contained in the following list (this list is not exhaustive nor does its order imply significance):

• Physical conduct of a sexual nature This may include unwanted physical contact such as unnecessary touching, patting, or pinching or brushing against another employee’s body, assault, and coercive sexual intercourse.

• Verbal conduct of a sexual nature This includes unwelcome sexual advances, propositions or pressure for sexual activity, continued suggestions for social activity outside the workplace after it has been made clear that such suggestions are unwelcome, unwanted, or offensive flirtations, suggestive remarks, innuendos, or lewd comments.

• Non-verbal conduct of a sexual nature This may include the display of pornographic or sexually suggestive pictures, objects, written materials, emails, text-messages, social media posts or faxes. It may also include leering, whistling, or making sexually suggestive gestures.

• Gender-based conduct This includes conduct that denigrates or ridicules or is intimidatory or physically abusive of an employee because of his or her sex such as derogatory or degrading abuse or insults which are gender-related.

This list is illustrative rather than exhaustive. A single incident may constitute sexual harassment.

In this policy, the expression “bullying and/or harassment” should be read as including “bullying, harassment and/or sexual harassment”.

Intention irrelevant

It should be noted that it is the impact of the behaviour which is relevant and not the motive or intent behind it. The intention of the perpetrator of the sexual harassment, bullying or harassment is irrelevant. The fact that the perpetrator has no intention of sexually harassing, bullying, or harassing the employee is no defence. The effect of the behaviour on the employee is what is relevant. It is up to the employee to decide what behaviour is unwelcome (in line with the definitions included earlier in this policy) irrespective of the attitude of others to the matter.

Action

GPG reserves the right to take action, up to and including dismissal against all inappropriate behaviour in relation to Bullying, Harassment and Sexual Harassment.

SECTION 6 – PREVENTATIVE MEASURES

As a business we have put the following preventative measures/actions in place to support all employees,

• Promotion and reinforcement of a positive workplace culture

• GPG values in place which support a positive culture.

• Effective Anti-Bullying and Harassment policy developed, used, and promoted regarding improper and proper behaviours.

• Widespread policy awareness

• Appropriate training as required for those managing complaints and for line management

Contact Person/appropriate advisory support services available.

• Training will also be provided for all staff at induction or via appropriate awareness raising initiatives.

• This policy will be updated on a regular basis and in line with legalisation.

• Clear goals for all.

Contact Person role.

Two employees have been designated as the contact person in respect of this policy. Contact names and contact details are available as an appendix to this handbook, on the HR App or from HR. If any employee has any question or query about the operation of this policy or requires any clarification about it, they may approach the designated contact person for advice, which will be given in strictest confidence. Please note that speaking to the designated contact person is not the same as making a formal or informal complaint.

The role of the Contact Person will be one of a supportive one, to listen, and offer guidance on options in line with company policy and procedures, all on a strictly confidential basis. The personnel for this role have been carefully selected and trained. The main purpose of the role is supportive listening and information provision. The Contact Person will have no role in the investigation of any complaints and will not be tasked with any further involvement in the details or right and wrongs of a complaint.

What to do if you have a complaint

If you feel that you are being bullied, please consult our Bullying and Harassment Complaints Procedure below for guidance on the next step to take. If you are unsure whether an incident or incidents constitute bullying, please discuss this with a contact person, your line manager, HR or whoever you deem to be appropriate.

All employees have a right to make a complaint if they feel they have been harassed, sexually harassed, or bullied.

SECTION 7: COMPLAINTS PROCEDURE

Any complaint about, or awareness of, alleged bullying requires quick, calm, and consistent attention. We believe that early intervention offers the best possible potential for a good outcome, particularly regarding restoring workplace relationships.

Mediation is also an important consideration for resolving issues. It is particularly useful at early stages however may be used at any stage during the process. It is an informal voluntary process where an impartial and competent third party enables individuals to work through conflict or disagreement, with a view to improving their relationship. It is a valuable tool at any stage in a procedure, but particularly beneficial at the earliest possible stage.

Anyone who believes that he/she has become subject to harassment or bullying directly or, who observes or has knowledge of harassment or bullying towards another employee or, group of employees, is advised to take the following steps immediately:

Stage 1 –Initial Informal Response

This response is suitable for non-seriouscomplaints, suchas in scenarioswhere it is likely the accused is not even aware of his behaviour negatively impacting others. It is a very informal mechanism that should be designed to be flexible in order to allow for minor complaints to be quickly dealt with.

Ideally, this initial informal response would effectively address the unwanted behaviour without any recourse to any other action.

It is preferable for all concerned that complaints of bullying or harassment are dealt with informally whenever possible. This is likely to produce solutions that are speedy, effective, and conducive to a positive working environment. Thus, in the first instance a person who believes that he or she is the

subject of bullying/harassment should ask the person(s) responsible to stop the offensive behaviour, but only if they feel comfortable in doing so. This should be done quickly and calmly, focusing on the facts regarding acts done and their consequences.

If it is more suitable, the individual who perceives that they are the recipient of unacceptable behaviour should put their concerns in writing, again focusing on the offending acts and their effects on them.

Where an employee perceives that the concerns relate to an immediate manager, the employee may wish to discuss the matter informally with their manager’s manager or a person at the next level of management.

A person may seek help and advice on a confidential basis from a contact person (details available in appendices, on HR App or from HR) particularly where a person finds it difficult to approach the alleged perpetrator(s) directly. The role of the contact person is not to judge but rather to provide advice and assistance about the organisation’s policy and options to resolve a concern.

Having consulted with the contact person, the complainant may request the assistance of a manager or manager in raising the issue with the alleged perpetrator(s). In this situation the approach of the manager or manager should be by way of a confidential, non-confrontational discussion with a view to resolving the issue in an informal, low-key manner.

Whilst we would always recommend that employees exhaust the initial informal response before escalating the complaint, we recognise that it may not always be suitable and that a complainant may decide, for whatever reason, to bypass the initial informal response mechanism. Choosing not to use the initial informal response will not reflect negatively on a complainant in the secondary informal process or the formal procedure.

Stage 2 – Secondary Informal Process

A complainant is obliged to invoke this stage of the process if Stage 1 is not suitable or is unable to deal with the complaint. This process is more protracted than the initial response but still informal.

A designated employee with special training in the management of complaints will be assigned to handle the complaint on behalf of the organisation. This will be someone with authority within the organisation.

We would recommend that the employee submits their complaint in writing, but where the complaint is verbal, the designated person handling the complaint will write up the complaint and provide the complainant with a copy.

The designated person will then attempt to establish the facts and context of the complaint before deciding on the next actions to be taken. (It should be noted that if no concrete examples of inappropriate behaviour are given by the complainant, the accused will have no recourse to repudiating any accusation that is not specific and therefore the complaint will fail)

If, however, after the designated employee has established the facts, they believe the accused has a case to answer, the person complained of will be presented with the complaint and will be allowed the chance to respond. They will organise a meeting with the accused to record his/her response.

Thereafter a method should be agreed to progress the issue to resolution so that both parties can return to a harmonious working environment whilst the process continues.

If it is found that there has been inappropriate behaviour from the accused, steps should be put in place to stop the behaviour and to monitor it going forward to prevent a reoccurrence. This will include the drawing up of a plan with agreed actions which is to be signed by both parties at the final meeting.

It is recognised that it may not always be practical to use the informal procedure, particularly where the bullying or harassment is serious or where the people involved are at different levels in the organisation. In such instances the complainant should use the formal procedure set out below.

Stage 3 -Formal Procedure

In the event that the initial informal response and the Secondary Informal Process has failed or is inappropriate in the circumstances, the formal procedure should be used as follows:

The complainant should make a formal complaint in writing that should be signed and dated. Where this is not possible, a written record should be taken of the complaint by the assigned person and signed by the complainant and dated.

The complaint should be confined to precise details of alleged incidents of bullying, including their dates, and names of witnesses, where possible.

The complainant and the respondent should be advised of the aims and objectives of the formal process, the procedures and approximate ideal timeframe involved, and the possible outcomes. Both parties should be assured of support as required throughout the process.

An initial meeting should be organised by the employer at which each person is met with separately, starting with the person making the allegation. The other party, when met with, should be given a copy of the complaint in full and allowed the opportunity to respond. Both should be given any relevant documents including the company Anti-Bullying and Harassment policy.

Investigation

The investigation will be governed by terms of reference including:

• That the investigation will be conducted in accordance with the Anti Bullying and Harassment Policy

• An indicative timescale for its completion will be provided.

• The scope of the investigation will be outlined.

• Confidentiality will be upheld at all times.

All parties to the process have a responsibility to participate without undue delay in any investigation initiated in response to an allegation of bullying.

The scope of the investigation should indicate that the contact person will decide based on the facts before them whether the behaviour complained of May, on the balance of probabilities have occurred. The investigator will not uphold or dismiss the allegations and/or suggest or impose sanctions.

Statements from all parties, including witnesses will be recorded in writing as the use of written statements tends to make matters clearer from the outset and maintains clarity throughout the investigation. Copies of the record of their statements will be given to those who make statements to the investigator. Copies will also be provided to the complainant and the person complained of and should result in findings of fact only.

If possible, all parties should continue to work normally during the investigation. This may mean that alternative temporary work arrangements will be made for one or more of the parties whilst the process is ongoing. Any such arrangements will in no way represent a presumption of guilt on either party.

The objective of an investigation is to ascertain whether, on the balance of probabilities, the behaviours complained of occurred, if having already been established that the behaviours come within the description of workplace bullying, harassment, or sexual harassment. Details of the complaint, responses of the person complained against, witness statements and, other relevant evidence are relied on for this purpose.

The investigation will be conducted by a designated member of staff, ideally someone more senior in rank to the parties involved. Where this is not possible, the company reserves the right to avail of an external 3rd party investigator who will oversee the investigation. In either case, the person nominated will have appropriate training and experience and be familiar with the procedures involved. The investigation will be conducted thoroughly, objectively, with sensitivity, utmost confidentiality, and with due respect for the rights of both the complainant and the person complained of.

The investigator will meet with the complainant and the person complained of and any witnesses or relevant persons on an individual confidential basis with a view to establishing the facts. A work colleague may accompany the complainant and the person complained of, if so desired.

The investigation will consider all material and evidence before it and a decision will be made on balance of probability, as to whether the complaint is valid. If the investigator concludes that the accused employee has a case to answer on the balance of probability, then the investigator may recommend whether or not the employer should invoke the Disciplinary procedure.

Appeal

Both parties are entitled to avail of the appeals process. The reason for appeal should be outlined in writing to management. The appeal should be submitted within 5 working days from the date of the decision. The appeal will be heard by someone not involved in the original investigation but of at least the same seniority as the original investigator. The appeal will focus on the conduct of the investigation in terms of fair process and adherence to fair procedure. It is not a re-hearing of the original issues. The outcome of the appeal will be final.

Action post-investigation

Should a case of bullying or harassment be proven then a disciplinary hearing may take place and the organisation may take appropriate disciplinary action. The disciplinary action will be taken in line with the organisation’s disciplinary policy. This can include a warning, transfer, demotion, or other

appropriate action up to and including dismissal. Records of any warnings for bullying/harassment will remain on the employee’s file as appropriate.

Retaliation

Regular checks will be made to ensure that the bullying/ harassment has stopped and that there has been no victimisation for referring a complaint in good faith. Retaliation of any kind against an employee for complaining or taking part in an investigation concerning bullying/harassment at work is a serious disciplinary offence.

Malicious Complaints

If a complaint is found to be malicious, then appropriate disciplinary action up to and including dismissal may be imposed, after due process.

A malicious complaint can be described as an allegation being made without foundation, and with malicious intent, where a person knowingly or without regard to whether it is true or not, accuses another person of allegedly bullying them. This could also apply to where one person maliciously complains of someone allegedly bullying a third party, without fully exploring the veracity of the claim.

Breaches of the Anti-Bullying and Harassment policy

Discrimination, bullying and harassment will not be tolerated by the organisation. Breaches of the organisation’s equal opportunities and dignity at work policy will be regarded as misconduct and may be subject to disciplinary action under the disciplinary procedure. In addition, should employees feel that they have not been treated fairly with regard to employment equality, they may utilise the grievance procedure.

Victimisation

Employees will not be penalised, treated less favourably or subject to other adverse treatment because of pursuing rights by way of taking action, supporting action or giving notice of intention to take or support action under equality legislation.

Diversity, Equality and Inclusion training

GPG is committed to ensuring that all employees undergo inclusivity, equality and diversity training. This training includes raising awareness of equality, inclusion and diversity-related issues. The equal opportunities and dignity at work policy and legislative requirements will be included in training

courses for managers, especially those involved in recruitment, selection, and personal progress reviews.

Monitoring

The organisation’s equal opportunities and dignity at work policy will be reviewed on a regular basis to assess the effectiveness of its implementation and operation in creating a truly integrated workplace.

COMMUNICATION

General communication to Employees

GPG is committed to effective communication of this policy. It will be communicated effectively to all GPG employees and where necessary those we come into contact with during our work. This policy will be communicated through training and will also be included as part of GPG staff handbook.

Communication to new employees

New employees, including those in management and all other positions of responsibility, will be made aware of the policy as part of any formal induction process to familiarise them with their job and their working environment and any rules and regulations that apply. They will also be made aware of its existence in the staff handbook.

Support Contacts

Their role is to enable you to better understand the Anti Bullying and Harassment Policy which explains bullying, harassment, and sexual harassment. The policy provides information on a range of options available to you and the Support Contact can discuss these options with you to allow you to decide what course of action, if any, you wish to take.

This support is available to all staff on a confidential basis. The only individual who will know about your visit is the support contact person.

3.5 Performance and Conduct Management

GPG is committed to the success of each and every one of its employees. Our success lies in the capabilities of our employees and their continued high level of performance. Our values of Respect, Excellence and Partnership define who we are, what we stand for and how we behave. They underpin our actions, determine our success, and help us work towards achieving our Mission and Values. They form a critical part of our performance management process.

Through the performance management process, a constant line of communication will be established beginning with the onboarding process, followed by regular 1-2-1’s with your manager, probation reviews, and continued throughout the duration of the employment relationship. The performance review process provides an avenue to review behaviours, performance and establish goals for the next review period.

Our performance management system is in place to enable our employees to work to clearly defined values and goals and receive feedback on their performance on a regular basis and runs in tandem with our organisation strategy and corporate objectives. This enables us to help each employee understand their role thereby enhancing the performance of both the employees and the Company.

Each year every employee will have two formal reviews - Interim and Annual.

Interim Review

Interim Reviews will take place during April each year. The Interim Review meetings also provide the employee with an opportunity to discuss significant accomplishments or identify issues or obstacles related to his or her performance that require attention from the manager. This is a coaching opportunity in which the manager can reinforce how he or she can help the employee, in words and in actions. Interim Reviews help minimise surprises and provide documentation in preparation for the annual performance evaluation. If significant corrections need to be made, a more formal and timely Performance Improvement Plan can be put in place.

Annual review

The review period for the annual appraisal process is the financial year Nov 1st to Oct 31st. Employee appraisals take place in October/ November each year. Being an annual event the preparation for

appraisals should not be carried out at the last minute. Performance appraisals are based on the overall performance of the employee throughout the year and not based on recent activity. It is the responsibility of both the manager and the employee to be prepared for the process.

One to One meetings

Regular one-on-one meetings will continue to be the most effective forum for communication between manager and employee, as well as from employee to manager. Performance reviews are an additional, and more focused, opportunity for the manager and employee to share feedback to be sure performance continues to remain on track with the required job duties and agreed upon goals and expectations. Along with ongoing value-added feedback.

Performance Improvement Plans (PIP)

When a manager deems it appropriate and an employee’s performance or behaviour is not meeting expectations, to assure agreement and clear communication on GPG’s expectations, Managers will develop a performance improvement plan for that employee, clearly stating which performance areas needs improvement, expectations, timeframes, and the process for determining improvement. A copy of the plan, signed by the manager and the employee, should be forwarded to the Human Resources Department for inclusion in the personnel file.

Probationary Periods

All new employees are required to satisfactorily complete a probationary period of a minimum of 6 months. During this period, performance on the job and potential abilities are evaluated after 1, 3, & 6 months to determine suitability for the position and the company. Further reference checks may be carried out. Prior to the end of your probationary period (6 months), a formal performance review meeting will be held between the employee and his or her manager and if satisfactory, your position will be confirmed.

The company reserves the right to extend the probationary period of an employee for a further 6 months up to a total 12 months, where this is deemed necessary and following discussions with the employee, in order to adequately evaluate the individual’s overall suitability.

During the probationary period either party may terminate the contract by giving one weeks’ notice in writing. The Company, at all times, reserves the right to pay you your basic salary in lieu of notice, except in the case of summary dismissal outlined under the disciplinary procedure. The company is not obliged to use the disciplinary procedure during the probationary period.

In conjunction with performance reviews regular 1-2-1 meetings will be held with employees to review progress and plan the future development of the company. Individuals will be provided with details of the performance standards necessary in their job and feedback on their individual performance, as appropriate. The company is committed to treating all staff fairly and equitably and to helping employees perform effectively

The high standards of work, conduct and appearance of our employees help maintain the company ’ s reputation with the public These policies are to ensure the company ’ s standards, rules and regulations are upheld at all times by all employees The disciplinary procedure defines the process by which failure to meet these standards will be handled. We want to remind employees that at all times they should feel free to raise matters of concern to them with their own manager or the HR Department, preferably in that order.

3.6 Remote Working

Purpose and Scope

GPG aims to facilitate all those whose role and outputs enable them to work remotely, whilst recognising that this may not be possible for all roles. This policy applies to all employees whose role has been deemed suitable for working remotely and who satisfy the criteria outlined in the policy. The purpose of this policy is to outline our guidelines for employees whose roles and tasks are suited to remote working.

Responsibility

The Human Resource department and Heads of Function are responsible for this procedure. As an employee you are expected to comply fully with all company policies including information security policies that are in place and report any breaches of these policies of which you may become aware.

Definition

Remote working – carrying out the day-to-day functions associated with your role or other tasks assigned by your manager, while working remotely away from Head Office. This assumes your location would normally be your home address within the country of Ireland.

Policy

GPG are committed to the wellbeing of all our employees. We value the presence of our employees at their contracted workplace as we believe it is the only place where certain duties can be carried out, along with providing the opportunity to meet, innovate and collaborate in person. To support development of relationships, collaboration, networking, and culture, Mondays are an anchor day within GPG, with all GPG based employees required to be on site for the day.

GPG also understands the benefits remote working can offer. This policy aims to promote positive employment conditions where employees are supported during periods of remote working.

Remote working is not a replacement for dependent care, or an alternative to caring responsibilities, and employees must have the same arrangements in place when working remotely as they have when working in the office.

Where employees require time off to care for children or other dependents, these should be discussed with their manager, and we will consider alternative leave arrangements which may include altered hours, working-up time taken, rearranging parental leave, taking annual or unpaid leave.

In instances where an employee is unable to attend the office on a scheduled day due to sickness, there is no option to work from home on that day, and the day will be recorded as a sick day.

We will strive to ensure that access to remote working does not have any unintended discriminatory impact. This policy will be updated as we understand what work’s best and how to improve our ways of remote working, and we invite feedback on this.

It is expected that employees working remotely will dedicate their full attention to their job duties during their periods of work and work to maintain the required standard of performance.

Employees will take responsibility for their own safety and perform their duties in accordance with all relevant safe working procedures. Employees are required to comply with the standards, behaviours and policies laid down in the contract of employment and employee handbook.

Procedure

It is recognised that certain roles/ tasks are not suitable for remote working e.g. customer facing roles – reception, retail, e-commerce, and operational roles – production, technical, logistics. Each

Head of Function will determine which roles and tasks in their respective departments can operate remotely. Where roles are deemed suitable for remote working, an automatic two day per week remote working will apply. We will continue to monitor all roles to ensure suitability.

Remote Working – Two days per week

As outlined above, where roles are deemed suitable for remote working, eligible employees, with the exception of our anchor day Monday, may work remotely two days per week, in consultation with their Head of Function. This day must be taken as a full day, and days not worked remotely in one week cannot be carried over. Heads of Function will agree remote working days with each employee, which may be the same day each week, or days may vary, subject to the requirements of the department. To assist with planning meetings etc, employees are required to ensure calendars are updated at least two weeks in advance identifying which days are being worked at home and which are in the office.

Dependent on the requirements of the business employees may be asked to change their remote working days or to be present in the office in excess of three days in a week. While efforts will be made to reschedule remote working days for that week, this may not always be possible.

This policy is dependent on employees agreeing to be flexible as required.

Criteria for considering suitability for remote working.

When considering requests for remote working GPG will factor in a number of criteria including, but not limited to the following:

• The requirements of the role/ department

• The suitability of the role for flexible working

• Costs associated with the proposed arrangement.

• Health and Safety issues

• The need to respect the privacy and data protection rights of information and staff.

• The impact and effect of the proposed arrangement on the workload of other staff

• The need for, and effect on normal supervisory arrangements in operation

• Availability of staff resources

• The availability of a dedicated space for a home office (desk, chair and monitor) which gives privacy and contributes to a productive work environment.

• Completion of a VDU assessment

CONDITIONS GOVERNING ALL REMOTE WORKING

Communication during remote working

• Staff members must ensure all contact details are up to date with HR and on GPG HR App, to enable communication (e.g., home address, phone number and email) prior to remote working.

• It will be essential that contact is maintained between the employee and their Head of Function or Manager

• The maintenance of good communication with colleagues and/or team members will be a priority.

• All-important updates will be communicated by and to employees in a timely manner via email or the HR App

• Normal one-to-one meetings, and team meetings will continue as normal in person, through phone, email, or MS Teams for business purposes.

• Staff must be available for all calls and virtual team meetings during their normal working hours.

• Employees may be required to attend the office or other reasonable location for meetings, or other events which GPG expects the employee to attend.

• All leave requests and procedures for reporting illness etc. continue to apply as heretofore under a remote working arrangement.

Employee Training

All employee training must be undertaken as required by GPG whether online or in person either in Head Office or offsite.

Health and Safety when working remote.

GPG values its employees and their contribution to the organisation and in this context takes responsibility for setting out clearly our policy for remote working safely and productively where appropriate. It is recognised that remote working will not be possible in all instances. GPG owes employees a duty of care to ensure as far as is practicable that the conditions in which staff work are safe and that the risk of injury is reduced. This includes a duty of care to the mental health and wellbeing of employees at work. Responsibility for health and safety at work rests with the employer whether or not thatworkis being done at the employee’s home. The provisions of the Safety, Health, and Welfare at Work Acts 2005 and 2014 apply in full and any decision to work remotely is taken having regards to the hazards pursuant to Section 19 of the 2005 Act. Staff have a duty to protect their own safety and the safety of fellow staff.

• Employees must identify a quiet private space where their home office will be located.

• The homeworking environment and workstation shall be assessed by each staff member in the first instance, using the homeworking risk assessment checklist from the H&S Authority 2020 https://www.hsa.ie/eng/topics/remote_working/appendix_1_homeworking_risk_assessment_ch ecklist.pdf

• HR will review the assessment to ensure it complies with requirements and provide advice if required.

• The Safety, Health and Welfare at Work Act 2005 (Part 2, Section 13) recites the duties of employees. These duties include taking reasonable care to protect the safety of themselves and others who might be affected by their acts or omissions.

• Staff will be required to cooperate with the employer as far as is necessary to enable compliance with the relevant statutory provisions. If having conducted a workplace assessment, the employee is unsure as to whether the homeworking environment and workstation is safe, they shall notify the HR manager who will seek the advice of a competent person (i.e., someone with sufficient training, experience, and knowledge) to advise on this.

• If having carried out both assessments if a suitable homeworking environment remains unavailable, the employee will be unable to avail of remote working.

Data Protection

GPG takes the subject of information security very seriously and aims to comply with the requirement of the data protection laws with regard to the collection, storage, processing, and disclosure of personal data. All policies in relation to GDPR and Data Security apply when working from home.

We regard the lawful and correct treatment of personal information by the Organisation as very important both to successful operations in Head Office and remotely and for maintaining confidence between ourselves and our customers and suppliers. We therefore make every effort to ensure that personal data is treated lawfully and correctly. We fully endorse and adhere to the principles of data protection, as detailed in the data protection laws and in our own policy.

GPG expects all its employees with access to personal information to be aware of and adhere to the principles of data protection, as set out in our policy and to respect the need for confidentiality and to avoid improper use or transfer of such information. All employees undertaking working from home must ensure that their working processes adhere to the requirements of the policy.

Ensure your computer, laptop, or device, is used in a safe location, for example where you can keep sight of it and minimise who else can view the screen, particularly if working with sensitive personal data. Conversations either by telephone or via Teams or Zoom, must be conducted in such a way that they are confidential and cannot be overheard or viewed by non GPG employees.

In the event that it is necessary to bring home company documents, it is the responsibility of the employee to ensure that all documents are securely stored and locked away when not in use.

Contractual Elements

Employees are responsible for checking with their house insurance provider to ensure home working is covered by their insurance policy.

Employees working from home can claim tax relief. This payment is to cover expenses such as heating and electricity costs. Employees can make a claim online at the end of the year. To do this, you must submit receipts to your local Revenue office.

Working Time

Remote working arrangements are subject to compliance with the Organisation of Working Time Act 1997 and therefore all staff are required to log their hours on the HR App, to include hours of attendance at work, rest periods, and annual leave. Annual Leave is unaffected by remote working and the normal notification procedures apply. All employees must be contactable during working hours via phone, MS Teams & MS outlook.

Rest periods.

As per the organisation of working time act 1997, employees must ensure they are taking adequate rest breaks. Ensure you are maintaining normal working hours and switching off in the evenings, this is extremely important.

Right to Disconnect

Whilst the right to disconnect is not enshrined in Irish law, it is acknowledged that developments in technology have made us constantly contactable even outside of work hours. Whilst the occasional intrusion into personal time may be unavoidable in the event of unforeseencircumstancesor events, we have an obligation to curtail working patterns in line with legislation. This obligation should be adhered to when contacting others.

Remote Investigations, Disciplinary, Grievance and Bullying and Harassment

All remote investigations, disciplinaries and grievances will be held in line with our policies as stated in the company handbook.

Equipment

Employees must ensure they follow all guidelines as outlined in GPG Telephone, E-mail & Internet Policy, and our employee handbook. Employees must also ensure that any equipment being used is in good working order and appropriate for their own safety, comfort, and wellbeing.

We will provide company laptop, and the necessary tools, and access to the company network and company-required software, for all remote working employees. Access to the company network from personal equipment is strictly forbidden. Equipment and systems that we provide remain the property of GPG. Employees must keep them safe and avoid any misuse. In addition, we will provide desk, chair, laptop, screens, keyboard and mouse and headset.

If a device is lost or stolen, you should contact your manager or Head of Function immediately. To protect the organisations data, please ensure you do not leave your laptop unattended while you are logged into your work account. Make sure your devices are turned off, locked, or stored carefully when not in use.

All employees, whether using company equipment must:

• Keep all systems password protected, and ensure a screen is always locked or off when not in use.

• Store equipment in a safe and clean space when not in use.

• Ensure all company information is kept out of reach of non-company employees.

• Follow all GDPR, data encryption, protection standards and settings at all times, ensuring that anyone who is not an employee does not have access to company information, whether confidential or not.

• Make sure that any device has the necessary updates, such as operating system updates (like iOS or android) and software/antivirus updates.

• Refrain from downloading suspicious, unauthorised, or illegal software.

3.7 Right to Disconnect

The world of work has changed profoundly over recent years. Technological advances mean that we are always contactable and accessible. where, when, and how we work continues to change at an accelerating pace. Employers and employees are experiencing both challenges and benefits arising from new ways of working including remote working arrangements, which encapsulates how long, where, and at what times employees work as well as the location of where work gets done. However, we are conscious that this can create risks, expectations, or pressures to work longer hours that often encroach on home life. Disconnecting from work is vital to a healthy and sustainable work life balance. Staff’s mental health, wellbeing and personal down time is important to us. In this context we support our staff’s right to disconnect.

As an employer, we do not expect staff, normally, to work more than their contractual working hours. If you find you are, you should talk to your line manager or HR. If you do receive a work email, or any other form of communication outside of working hours, there is no expectation that you read it or respond until you are working. We are committed to this statement and to providing staff a fair right to disconnect. This right and policy apply to all staff within GPG including agency and contract workers.

We wish to make very clear that there should be absolutely no detrimental impact on your career with us for expressing your right to disconnect. This will not lead to victimisation and will not negatively impact your performance rating or promotional chances. We will take seriously and investigate any such victimisation. Equally, staff who may be perceived to be connected’ outside of work hours will not be treated more favourably.

All staff, including those engaging in mobile, shift or fixed working arrangements or remote working are reminded to switch off from work, to monitor their working hours and to take breaks in accordance with the Organisation of Working Time Act 1997 (OWTA 1997), away from work devices. Staff must take reasonable care of their health and safety in accordancewith section 13 of the Safety, Health and Welfare at Work Act 2005 (SHWWA 2005). Staff are encouraged to seek support in relation to the above if necessary.

Employees working from home are encouraged to schedule post-work leisure activity, in order to create some separation from the end of their workday and the beginning of their personal time.

OBLIGATIONS ON EMPLOYERS AND EMPLOYEES

Creating a culture in which employees feel they can disconnect from work, and work-related devices will require a joint approach by GPG management and employees.

Employer obligations

• To provide information to employees on their working time, in accordance with the relevant legislation.

• To ensure a safe workplace, in line with the health and safety legislation.

• To not penalise an employee for acting in compliance with any relevant provision of the health and safety legislation.

Employee Obligations

• Ensuring that they manage their own working time and section 13(1)(a) of the SHWWA places an obligation on an employee, while at work, to take reasonable care to protect their safety, health and welfare and the health and safety of co-workers.

• Cooperating fully with any appropriate mechanism utilised by an employer to record working time including when working remotely.

• Being mindful of their colleagues’, customers’/clients’, and all other people’s right to disconnect (e.g., by not routinely emailing or calling outside normal working hours).

• Notifying the employer in writing of any statutory rest period or break to which they are entitled to and were not able to avail of on a particular occasion and the reason for not availing of such rest period or break.

• Being conscious of their work pattern and aware of their work-related wellbeing and taking remedial action if necessary.

Role of Managers

Managers play a central role in the successful implementation of this policy and will demonstrate clear commitment to the Policy through leadership and being active role models in this respect. Managers will ensure work allocated can be completed during working hours and keep a record of employees working hours through the HR App.

Working hours

Due to the nature and variety of roles within GPG, ‘normal working hours’ may be very different across the organisation. We believe in staffing and allocating work in a way that it can be completed within the working week. It is only in unusual or extraordinary circumstances that additional hours should be required. We do seek flexibility and support for this, when necessary, but it should not be a regular and ongoing part of the working week.

The fulltime expected hours in this company are 39 but all staff should refer to their individual contract of employment for clarification on their contracted hours. We do not expect staff to work more than these hours. If staff have to, dependent on your contract, and by agreement in advance, you will either be paid Overtime or Time in Lieu arrangements will apply. All hours worked will be recorded on the HR App.

We also recognise that certain roles within GPG do not always operate on a standard hour’s basis, but in a manner responsive to business needs. With this in mind we aim to find an appropriate balance for GPG and employee.

There will be occasional legitimate situations when it is necessary to contact staff outside of normal working hours, including but in no way limited to ascertaining availability for rosters, to fill in at short noticefora sickcolleague,where unforeseeable circumstances may arise, wherean emergency may arise, and/or where business and operational reasons require contact out of normal working hours.

GPG also recognise that business and operational needs may dictate that there will be situations which clearly require some out-of-hours working by some employees depending on the service being provided, the employee’s role, the needs of customers/clients and the unique requirement of critical services and as agreed in an employee’s terms of employment.

In certain departments there is the requirement to work across global time zones. Working across different time zones and international travel may result in colleagues connecting at different times outside of normal working hours to complete their objectives. This does not mean that the recipient needs to respond in the same time period. Clear guidance around disconnecting and expectations for responding to digital communications globally will be discussed individually with affected employees.

Regardless of your role or hours of work we respect the right of every employee to be able to disconnect in line with this policy.

COMMUNICATIONS

Where possible, e-mails should be checked or sent only during normal working hours.

Tone and sense of urgency in written communications should be proportionate, particularly those sent outside of normal working hours – texts or emails sent outside of normal working hours may be easily misinterpreted by the recipient as to its urgency.

Due to differing/non-standard patterns of work in the organisation, some employees may send communications at times which are inopportune for other employees, e.g., weekends. The sender should give due consideration to the timing of their communication and potential for disturbance, and the recipient should understand that they will not be expected to respond until their working time recommences.

Employees should not feel that they must respond to social communications from colleagues outside of their working hours, as social media platforms are not an acceptable, or recognised, means of communication in GPG.

Managers will monitor the timings of email and other communications andbring it to an employee’s attention if they notice that they are sending emails at odd hours or logging in excessively, as this may be a sign that they are finding it difficult to manage their workload or ‘switch-off’.

Where communications are sent outside agreed working hours, unless business and operational needs dictate that an immediate response is required, senders should state that an immediate response is not expected or use the “delay send” options and set it to a specified time on the next closest working day.

Please ensure that your out-of-office notifications are properly activated when you are out of the office and that your out-of-office message correctly directs the recipient to the appropriate colleague. Please respect out-of-office notifications when you receive them from others.

Emergency situations will occur, and, in this event, communications will be sent that require a response. In the case of an urgent or time-sensitive situation after normal working hours, please consider sending a text or making a phone call rather than an email. It is our aim that such communications should be the exception, not the norm.

Meetings

With more flexible ways of working often comes more meetings. While meetings are a core part of how we work we are also conscious of trying to minimise unnecessary meetings and meeting fatigue. Therefore, we ask those calling meetings to avoid doing so during normal lunch or break times, as often staff feel obliged to forego their break to attend. This shouldn’t happen. Meetings should only be scheduled, where possible during normal working hours. Meetings should not be held over break times and only those necessary should be invited.

Due to the requirement of our business to schedule calls with the US, there will be occasions where there may be early morning or evening meetings. In this event Time in Lieu will be agreed in advance with your manager.

We respect people’s time by only inviting them to meetings where they play an active role and have something to contribute. Employees should be mindful of and manage how much virtual communication they have each day.

Share and adopt meeting best practices: for example, ensure there is a clear agenda with relevant material shared in advance, and actions are recorded and shared post the meeting.

We also appreciate that if staff need to block time in their diary for vital work to be done, they should do so. Diary time is not just for meetings and because someone is ‘free’ in their diary does not mean they are not busy.

Compliant Procedure

While we hope complaints aren’t necessary, we believe having a fair and transparent complaint procedure is a vital part of working life. Should you feel this policy is being breached, for example, by the following, not exhaustive list, then you should speak out:

• Being contacted regularly outside of normal work hours.

• Being expected to regularly work through lunch or other breaks.

• Being penalised for not being available out of normal working hours or favourable treatment for employees who stay connected out of hours.

If you encounter problems in availing of your right to disconnect, please speak to the person(s) in question in the first instance if you feel comfortable doing so. If you feel that you cannot approach the person(s) directly, then, we encourage you to speak out to your manager. However, we acknowledge that it may be your line manager who is in breach of this policy and so we invite you to speak to a different line manager, or a member of the HR Team to try have the issue resolved informally. Should this not be successful in resolving the concern, then a formal complaint under the grievance procedure can be made.

These guidelines should be read in conjunction with other policies contained within this handbook e.g. Anti Bullying and Harassment Policy, Social Media policy, Dignity at Work, Confidentiality Policy, Data Protection, and all other related policies.

We reserve the right to amend and update this policy over time in line with best practices, learnings, and any changes in legislation.

3.8 Wellness and Mental Health Supports in the Workplace

This section aims to:

• Help employees understand the various components of employee wellbeing and the supports that are available to you at work.

• Ensure that employees know what services are available to them in the event of ill health or personal or work-related problems throughout their career.

• Ensure employees understand their responsibility in complying with Health and Safety legislation and Workplace Health and Wellbeing procedures.

• Make employees aware of the Employee Assistance Programme and Mental Health Champions across the organisation that can offer assistance.

HR and Line Managers aim to promote and maintain the physical, mental, and psychological wellbeing of all GPG employees. A meaningful and safe work culture exists where the organisation enables healthy behaviours among employees, supports them to take responsibility for their own health and wellbeing, and where employees feel valued, are emotionally engaged, and deliver services that they are proud of.

Wellbeing

Wellbeing can be described as having a healthy and happy existence. The World Health Organisation defines wellbeing in its broadest sense as “an optimal state of health,” concerning an individual’s physical, mental, emotional, and spiritual state of being. It is important that you aim to look after all of your health so that you have a balanced approach to your overall wellbeing.

GPG are committed to supporting all employees in living well. To do this we develop an “Annual Wellbeing Calendar” covering a broad range of initiatives including physical, financial, and emotional wellbeing initiatives. We encourage all employees to get involved in areas of interest to you.

Wellness Committee

GPG Wellness Committee is made up of volunteers across departments within the business. It is chaired by HR and meets every 6-8 weeks. The purpose of the Committee is to plan, promote and implement wellness initiatives to help enable good mental and physical health. The Committee prepares an annual Wellness Calendar by November each year, for the following year.

Mental Health

GPG are committed to creating an open culture around mental health and playing a role in challenging mental health stigma.

 Mental health includes our emotional, psychological, and social well-being.

 It affects how we think, feel, and act. It also helps determine how we handle stress, relate to others, and make healthy choices.

 Mental health is important at every stage of life,

Mental Health Champion Support Available

GPG has a number of trained Mental Champions across the organisation whose role is to:

• Create a Safe Space to Talk.

• Listen without Judgement.

• Encourage Sharing.

• Help with Motivation.

• Show Kindness.

• Encourage Positivity.

• Create Awareness.

• Encourage Belief.

• Signpost available supports.

All support offered is in complete confidentiality.

The Mental Health Champions details are available on HR Intranet/HR Policies & Procedures

Folder/Wellbeing or from your manager or HR Department

Employee Assistance Programme (Laya HealthCare)

Available to you and your family members 24/7, 365 Days a Year.

By free phone numbers

ROI: 1800 911 909

UK: 0800 0988 350

By email: hello@layaeap.ie

Through online portal

www.layaeap.ie

Where you can Live Chat or request a call back at a time that suits you.

External Supports Available via Mental Health Ireland

https://www.mentalhealthireland.ie/get-support/

Managing Stress

The company is committed to providing a positive environment in which employees do not feel over-stressed. We recognise that stress is not always a negative occurrence and indeed a moderate level of stress can be seen as a positive factor. It is only when the stress under which employees are placed becomes excessive that there should be cause for concern

In order to implement a positive environment and minimise the negative impact of stress, the company commits to the following:

• Making employees aware of the Safety Statement, which highlights the company ’ s commitment to protect the health and safety of all employees.

• Inform all employees of the company’s grievance and dignity at work policies that provide employees with the opportunity to raise issues, explore the underlying causes and have them resolved

• Regularly re-assessing job descriptions and employee needs, and taking action where employees highlight causes of stress in relation to work practices or conditions. Of particular concern is job planning, reliability of work systems, working patterns and breaks. Employees will have the opportunity to input into the decisions about changes relating to these.

• Providing information on stress and ways of coping with stress relating not only to work but also to stress, which could be developed outside of work.

• Committed to providing internal supports through our Wellness activities, our EAP, Mental Health Programme, and signposting external supports.

Wellness and Mental Health Policy

Purpose and Scope

We understand that our wellbeing and mental health is impacted by a range of factors, including. the working environment and our workplace relationships with others. As a business we commit to actively committed to creating a supportive and psychologically safe environment where our people can flourish.

Responsibility

The Human Resource department is responsible for this policy.

Values

The values that inform our behaviour in relation to wellbeing and mental health mirror our organisational values of Respect, Partnership and Excellence, underpinned by our equality, diversity, and inclusion commitments.

Policy

The definition of mental health is: ‘A state of well-being in which the individual realises his or her own abilities, can cope with the normal stresses of life, can work productively and fruitfully and is able to make a contribution to his or her community. (WHO)’

We are committed to:

• Actively promoting employee wellbeing and positive mental health.

• Enabling individuals to develop and manage their own mental health.

• Helping those experiencing mental health difficulties, as far as possible, to recover.

• Building and maintaining organisational systems that impact positively on mental health, promote equality, and reduce stigma around mental health.

• Raise awareness across the organisation and at all levels of the organisation about the importance of promoting mental health in the workplace.

• Help each individual learn how to take responsibility for managing their own mental health effectively and learn how they can enable/support the mental health of others.

• Eliminate or reduce organisational risk factors in relation to mental health (e.g. bullying, stress, discrimination or harassment), wherever possible.

• Enable positive mental health and equality in practice through the provision of timely and appropriate reasonable accommodation and supports for individuals who are experiencing mental health difficulties or mental illness.

• Providing mental health awareness training, employment equality training and additional training as required, to enable employees to carry out their role.

• Having a Wellness Committee in place. The committee will comprise of employees from across the business, that will champion Mental Health initiatives and support fellow employees.

• Consulting with staff on an ongoing basis to gather their views about mental health and equality issues, and their feedback about the potential impact of policies, procedures, and programmes on workplace mental health. We will also consult with other parties as appropriate.

• Developing an annual Wellness Calendar to ensure that this policy is fully implemented. Activities will be mainly driven by our workplace Wellness committee in conjunction with HR.

Policy Objectives

• We recognise that mental health difficulties (e.g. stress, anxiety, and depression) is covered on the grounds of Disability by the Employment Equality Acts, and we are committed to the provision of reasonable accommodation, where appropriate and necessary.

• We are also committed to our legal responsibilities under the Safety, Health, and Welfare at Work Act 2005, including identifying and assessing psychosocial risk (e.g. stress or bullying), and reducing such risks.

• We are committed to consulting with staff and using recognised audit tools. In the event that we are aware of individual employees with mental health difficulties we will work with them to identify particular risks and seek to implement measures to reduce those risks.

• We are committed to eliminating or reducing organisational risk factors in relation to an employee’s wellbeing and mental health (e.g. bullying, stress, discrimination, or harassment)

Disclosure

There is no obligation on any staff member to disclose that they have a mental health difficulty. A mental health difficulty may not impact on a person’s capability to carry out the demands of their job and in the case, they may feel there is no reason to disclose.

However, it is difficult for us to support appropriately a staff member if we are unaware of any difficulties they are experiencing. We are committed to working positively with anyone disclosing information about their mental health difficulties, so that we can identify what may help them to function productively in work.

A disclosure will usually take place between a staff member and their manager in the first instance; however, a staff member may choose to speak directly to their Head of Function or HR.

In the case of a disclosure that has arisen due to a mental health difficulty interfering with the individual’s ability to do their job, we will adopt a partnership approach with the individual to explore and clarify the following:

• What difficulties is the person experiencing, and how is this stopping/hampering the person doing their job?

• What supports (reasonable accommodations) would be needed to “close the gap” and enable the person to be fully capable to carry out the demands of their job?

• How do we make a decision about reasonable accommodation, and how do we effectively and sensitively communicate that decision?

• How do we effectively and sensitively implement a reasonable accommodation?

In order for this partnership approach to be successful, it is necessary for the individual to be open to disclosing their current difficulties and to exploring options through conversation. The aim of this supportive conversation is to explore and identify how we can work together in order for them to be able to carry out their work in a safe and supported way. It is difficult to help a staff member if they are unwilling to engage with the supports and resources that are available to them or talk through how solutions can be found.

We are committed to respect for individual privacy and confidentiality. Information that is disclosed to us will be treated sensitively and will be stored in accordance with our legal responsibilities under the Data Protection legislation.

Case by Case Basis

No two people will experience a mental health difficulty the same way. Each person will be supported on a case-by-case basis. We will adopt a partnership approach, through conversation, working with each individual to explore what support options are most suitable for them. In some cases, this may be to signpost counselling supports; reorganise workload; an individual may require some leave on compassion grounds; or they may be referred (with explicit consent) to our Occupational Health provider who will perform a health assessment and map out how best to support the individual.

Reasonable Accommodation

We will support any employee requesting our help on the grounds of disability and (in this case) mental health difficulties, in compliance with the Employment Equality legislation. These supports (known as reasonable accommodations) are provided to enable an employee with a mental health difficulty or another disability to access employment, participate or advance in employment and undertake training. We will adopt a partnership approach, working with each employee to explore reasonable accommodation options that are suitable and individualised

Building Wellbeing and Mental Health Awareness

We are committed to providing mental health awareness training and employment equality and diversity training to all staff at all levels of the organisation. This training will include but not be limited to equality legislation, with particular reference to mental health and reasonable accommodation. Our Wellbeing and Mental Health policy will be distributed and explained to all employees as part of their training. Wellbeing and mental health will be included in our strategic and operational training and development plans, and further training will be provided on specific issues to particular groups as needs are identified.

Manager Guidance

We ask Managers to stay connected to their team and remain vigilant in relation to the wellbeing of team members. Discussing wellbeing with your team members should form part of your regular conversations and could form part of your formal Professional Development Planning (PDP) conversations. This policy will help you prepare for the conversation, what you can expect and how to signpost to different support resources.

If a staff member makes a mental health difficulty or illness disclosure to you

Discuss together with the individual the questions as set out in the ‘Disclosure’ part of this policy adopting a partnership approach.

Work through the supports and resources available to the individual and explore options that may help such as the Employee Assistance Programme (EAP), HR or Occupational Health, or their own GP/counselling service who may be aware of their difficulty.

Where you have agreed on any reasonable accommodations that could be introduced to help support the staff member at this time, develop an action plan and agree to check in regularly to ensure the current arrangements are working for everyone. HR is available to support you during this time.

If a staff member has not made a disclosure to you but you are concerned about their mental health

If you perceive that a staff member is in a state of emotional or psychological distress due to observed behaviours (conflicts with colleagues, erratic behaviour, absences, struggling to carry out duties) as a first step, reach out to them. Showcase supports available to them via the Mental Health Champion Programme and Employee Assistance Programme.

If a manager has tried to engage with the team member on multiple occasions with no response to discuss their observations and genuine concerns, and there is a continued concern for their welfare, managers are advised to contact HR. Where HR are made aware of and are concerned about a team member’s health and safety, HR will reach out to meet with the team member, possibly leading to advice to speak to our occupational health provider.

Occupational Health

Where an individual agrees to be referred to Occupation Health, a referral form is filled in in partnership with the individual and HR. Occupational Health will carry out an assessment and provide a recommendation report on how best to support the individual.

GPG will follow all reasonable recommendations set out in the assessment report. This report is shared with the individual and will map out the partnership approach to be taken by GPG and the individual to best support the staff member to be able to carry out their role, where it is deemed safe to do so, and with any required reasonable accommodations in place. This will be an on-going conversation and partnership and can be revisited as often as required.

Additional Resources for Individuals

We offer an Employee Assistance Programme (EAP) that gives our staff the support that they need to help them manage their health and wellbeing issues effectively. Our LAYA EAP provides free, confidential, professional counselling available to you and your family (16 years old+) 24 hours a day, 365 days a year. Freephone ROI: 1800 911 909 or visit www.layeap.ie

Additional Resources for Managers

HR is available to speak to if you have concerns about a member of your team's mental health or performance where if could be related to a mental health issue.

The EAP phone service is also available for our people managers to speak to an advisor on a range of topics such as coaching, time management and conflict resolution. Freephone ROI: 1800 911 909 for phone support or visit www.layeap.ie

Additional Resources for Employees

To raise mental health awareness and combat the stigmas associated with them, we have committed to:

• Providing Mental Health Awareness Training. These workshops are being scheduled annually through LAYA our EAP providers, for both managers and employees explaining important elements of mental health. Suicide Awareness Training is also available and promoted throughout the year.

• Promoting Mental Health Awareness initiatives and World Mental Health Day.

• Proactively support staff wellbeing. Through periods of change such as staff returning from maternity leave, death of a family members or loved one, individual retirement support etc.

• Keep employees informed. This policy will be reviewed and updated as required annually by HR and the Wellness Committee. Any changes will be communicated to staff.

• Continue to provide information and resources through activities on our Wellness Calendar to support our Wellbeing.

Section 4: Attendance and Leave Management

4.1 Attendance Management

Purpose and Scope

General Paints Group (GPG) expects all employees to conduct themselves in a professional manner during their employment. This includes practising good attendance habits. All employees should regard coming to work on time, working their roster as scheduled, taking the correct breaks and leaving at the scheduled time as essential functions of their jobs, i.e. good attendance habits form an integral part of every employee’s job description. The purpose of this policy is to detail the Company’s approach to good attendance management.

All employees are covered by this policy.

Responsibility

Heads of Function, Managers and the Human Resource Department are responsible for this policy.

Policy

GPG aims to create and maintain a culture and working environment which maximises and motivates employee attendance at work. Each employee is required to attend for work punctually each day. Unplanned nonattendance at work has a significant impact on the running and operation of the company.

This attendance management procedure aims to provide a consistent approach to managing attendance in the workplace while at the same time taking individual circumstances into account to act reasonably. All matters in relation to attendance management will be handled in a consistent, confidential, and sensitive manner. At GPG we work together as a team. This policy is intended to increase every employee’s sense of team by being aware of the effect that an absence may have on another staff member i.e. increased workload, additional hours etc. Therefore, each of us will make every effort to adhere to the policy.

Reporting

In accordance with the employee handbook and your contract of employment, you yourself are required to notify your manager of any absence within one hour of your expected start time on the first morning of absence. You must report directly by telephone stating the reason for your absence and the expected duration.

Definition of Authorised Leave

Authorised leave can be defined as legitimate absence from work due to statutory entitlement or other types of leave permitted by GPG. Most such leave is planned and authorised in advance but there are incidences whereby legitimate leave will not be planned including Force Majeure leave and sick leave.

Statutory Entitlements

▪ Annual Leave

▪ Maternity/Adoptive Leave

▪ Parental Leave

▪ Parents Leave

▪ Paternity Leave

▪ Force Majeure Leave

▪ Carer’s’ Leave

▪ Health & Safety Leave

▪ Statutory Sick Leave

▪ Leave for Medical Care Purposes

▪ Domestic Violence Leave

▪ Public Holidays

GPG’s provisions

▪ Compassionate Leave

▪ Study & Exam Leave

Conditions for taking Authorised leave

In general, leave must be planned in advance and be pre-authorised by the relevant Head of Function or Department Manager. Heads of Function or Department Managers are responsible for ensuring that adequate staffing levels are maintained at all times prior to granting requests for leave.

Definition of Absenteeism

Absenteeism is defined as time lost attributable to sickness or any other cause that is not provided for through statutory entitlement or conditions of employment. For example, statutory entitlement such as annual leave or maternity leave is not counted as absenteeism, but long-term sickness absence is regarded as such. Therefore, the definition includes:

▪ Sick leave (certified and uncertified)

▪ Occupational injury

▪ Unexplained leave

▪ Abandonment of duty

▪ Poor time keeping, lateness etc.

Types of absence

Leave that is not an entitlement and is not agreed with the employee’s manager in advance is deemed to be ‘absence’. Types of absences are outlined below:

Sick Leave – Certified and uncertified

Certified Sick Leave is an illness that is certified by a GP for a certain period.

Uncertified Sick Leave is sick leave taken by an employee that has not been certified by a GP.

Unexplained Leave

This includes all incidents of absence that are not notified to the relevant manager. All such incidents will be regarded as serious and will be investigated in accordance with GPG Disciplinary Procedure. Depending on the outcome of an investigation sanctions may be imposed on an employee in accordance with the Disciplinary Procedure up to an including dismissal.

Abandonment of Duty

If an employee leaves his/her post without explanation an investigation may ensue. In the case of a workplace emergency the Emergency Response procedure must be followed. In the case of a personal emergency every effort must be made to make the relevant manager aware of the reason for the abandonment of duty. Employees who abandon their post (legitimately or otherwise) must never leave potential hazards unattended or reported.

Occupational Injury

GPG places great emphasis on the safety, health, and welfare of all our employees. All employees have a responsibility to report any injury in the workplace to their manager and to record it in accordance with our Accident/Incident reporting procedure.

Time Keeping

Employees are required to attend work on time. All employees are entitled to a 15-minute morning break and a 30-minute lunch break. Persistent lateness arriving to work or returning from breaks and poor timekeeping will be investigated, monitored, and may result in disciplinary action in accordance with GPG Disciplinary Procedure.

Management of Annual Leave and break

In order that we can continue to provide an excellent service to our customers and that we operate in a productive and efficient manner it is the responsibility of each department manager to ensure that annual leave and break times are effectively managed. Therefore, annual leave and break times must be staggered and fit in with the requirements of the department.

Good Attendance Habits

Good attendance habits form an integral part of every employee’s job description. These can mean the following:

▪ Appearing for work in good time and no later than the start of your rostered hours.

▪ Being at your workstation ready for work at your correct time

▪ Remaining at your workstation or desk unless the needs of the job require being elsewhere, except during authorised rest breaks.

▪ Taking only the time allowed for breaks.

▪ Remaining at work for your complete rostered hours unless excused by your manager.

▪ Not leaving work until the scheduled end of your day, including Fridays before bank holiday

▪ weekends and the breakup day before Christmas, unless excused by your manager.

▪ Leaving at the end of the day, unless you have been given advance permission from your manager to work past that point.

▪ Calling in personally and notifying your manager if you are going to be either absent or late, unless a verifiable emergency makes it impossible for you to do so.

Recording

All incidents of authorised leave and absenteeism must be recorded on the HR System.

Authorised Leave Recording

Authorised leave must be formally recorded, on the HR System, in accordance with procedures i.e. holiday request forms, applications for maternity leave, parental leave etc.

Absenteeism recording

All incidents of absenteeism must be formally recorded, on the HR System. In accordance with procedures (i.e. absence from work without prior authorisation including certified and uncertified sick leave) must be recorded on a Return-to-Work Form and signed by both the employee and manager.

Return to work conversation

On return to work a conversation between the employee and the manager must be conducted. This conversation will confirm details of the absence and that the individual is fit to return to work. This applies to sick leave (certified and uncertified), unexplained leave, occupational injury, and abandonment of duty. This conversation will also provide an opportunity for the manager to discuss attendance levels, patterns etc. with an employee if appropriate.

All individuals should complete the return-to-work form on the day of return to work following an absence without prior authorisation and once signed by both the manager and employee following the return-to-work conversation forwarded to HR for filing.

Disciplinary matters

Issues in relation to attendance at work and poor timekeeping will be initially addressed informally with the employee by their manager. If there are no improvements individual targets for attendance levels will be set and the employee will receive a warning under GPG Disciplinary procedure that a significant improvement is required. The situation will be monitored on an ongoing basis and if there is no improvement, disciplinary action up to and including dismissal may be taken.

Action may also be taken in respect of other unacceptable patterns of absence e.g. regular Monday or Friday absence, sickness occurring before and after public holidays, lateness, part day absences, taking of prolonged breaks. Instances such as above may result in a disciplinary interview.

GPG discipline procedure may be invoked where there is evidence that an employee has deliberately or persistently breached this policy for example by.

• Not reporting absence in the correct way

• Taking sick leave when he/she is not sick

• Taking persistent short absences

• Persistently arriving in late to work

• Persistently abusing break times

Payment

Time sheets will be submitted on a weekly basis by Department Managers, indicating hours worked, holidays, sick leave, and any other absenteeism. Employees will be paid for hours worked, planned holidays and sick leave if the employee qualifies. Adjustments will be made the following week.

4.2 Annual Leave Policy

Purpose and Scope

The purpose of this policy is to ensure that all employees enjoy the benefit of their annual leave & public holiday entitlements, reflecting the company’s commitment to the health & welfare of all its employees. Any changes in the prevailing legislation will automatically apply.

Policy

The holiday year runs from 1st January to 31st December. All holidays must be taken within this period and cannot be carried forward. In cases where due to exceptional circumstances you have been unable to take your leave, by agreement with your manager, a maximum of three days can be carried into the following leave year. You will be required to take carried over leave in the first three months of the following the leave year. Where you are not in a position to take annual leave due to certified illness, carried-over leave must be taken in the fifteen months following the leave year in question. No payment can be made in lieu of annual leave as this is against legislative requirements.

Due to the seasonality of our business, all employees are required to take 5 days of annual leave by the end of April. This is in addition to any days which may be carried over.

Holiday entitlement

In accordancewith the Organisation ofWorking Time Act 1997, all employees are entitled to holidays irrespective of employment status or length of service. The present holiday entitlement is 25 working days for full-time employees. New and part-time employees will receive their entitlement on a prorata basis. A maximum of 2 weeks' holidays may be taken at any time. Requests for holidays in excess of 2 weeks must be requested in writing to the Human Resources.

Fixed days

On average each year up to five days of your holidays may be fixed during the Christmas/New Year period. The number of fixed days to cover this period may change each year. The remaining days are available to staff members to take once, requested through the app, and approved by management in advance. All holidays must be requested as per the procedure below. We reserve the right to request employees to work during the fixed day shutdown, in line with the needs of the business

Procedure, Holiday Requests

All General Paints Group employees are required to request annual leave through the HR App. Only one person from each department may be permitted to be on holiday at any given time. On receipt of the request, your manager will either approve requests or decline your request, through the App explaining why if it is not possible to agree to the request. Every effort will be made to approve requested holidays, but the decision will be dependent on cover required for the business and the number of requests already received and approved. If requests are not received in line with this procedure, and through the App, then you will not be granted leave. Once approved your holidays are recorded on the HR App.

Holiday leave must be authorised, and you should not book or pay any deposits on holidays until your request is fully authorised. If you do not follow this procedure and take leave without approval from your line manager, you will be considered Absent Without Leave (AWOL) and may be considered as gross misconduct and subject to disciplinary proceedings, with potential sanctions of up to and including a final written warning or dismissal.

Your entitlement to annual leave shall accrue on a month-by-month basis and in accordance with the number of months worked during the annual leave year.

Leaving the Company

Upon the termination of employment, you will be entitled to payment in lieu of any accrued or unused annual leave entitlements. We reserve the right to require that you take any unused annual leave entitlements during the notice period even if booked to be taken after the end of the notice period. If you leave employment during the annual leave year, your annual leave entitlement in that year will be calculated on a pro-rata basis for each complete month of service.

Upon termination of your employment, if you have taken annual leave which has exceeded your accrued entitlement then this excess payment shall be deducted from any salary due to you.

Holiday Records

All holidays are recorded on the HR System. Please inform your manager immediately of any change in holiday requirements.

Sickness whilst on annual leave

If you fall sick during a period of annual leave, and produce at the time, a doctor’s statement to the effect that you are unfit for work, the period of your sickness will be treated as sick leave and not annual leave. We reserve the right to seek further clarity as to the nature of the sickness and request that you undergo an independent medical assessment with an appointed company doctor. Your statutory annual leave entitlements will continue to accrue while you are absent on sick leave.

Use of annual leave

During holidays or at any other time during your employment, you may not engage in any employment or occupation which may compromise your employment relationship with us. This should be read in conjunction with our Conflict of Interest of Policy/Code of Conduct Failure to comply with this Annual Leave Policy may result in disciplinary proceedings in line with the Disciplinary Procedure with potential sanctions of up to and including a final written warning or dismissal.

Public Holidays

All full-time permanent employees will be entitled to nine Public Holidays in line with current government regulations.

New Year’s Day (January 1st)

First Monday in February, or 1 February if the date falls on a Friday

St. Patrick’s Day (17th March)

Easter Monday

First Monday in May

First Monday in June

First Monday in August

Last Monday in October

Christmas Day (25th December)

St. Stephen’s Day (26th December)

It should be noted that Good Friday and Christmas Eve are not Public Holidays.

Part-time employees will receive on a pro rata basis; a Public Holiday provided they have worked for at least 40 hours in the preceding five weeks up to the day before the Public Holiday.

4.3 Sick Leave Policy

Purpose and Scope

The purpose of this procedure is to detail the Company’s policy on sick leave and to reflect the introduction of the Sick Leave Act 2022 which came into effect on 1st January 2023.

All employees are covered by the Company’s sick policy.

Responsibility

The Human Resource Department and Department Managers are responsible for this policy.

Procedure for Reporting of Illness

The following procedure outlines the benefits to which an employee is entitled should he/she become ill. Different benefits and conditions will be applicable, depending on the length of the illness.

Short Term Illness

An employee who is absent from work, or late arriving for work, must notify his/her supervisor within one hour of the time they were expected to start work. This is not the responsibility of a relative, friend or spouse. An employee must inform their supervisor directly of the reason for the absence and the expected date of return. Contact by text, email or another colleague is unacceptable. Only in exceptional circumstances where the nature of a team member’s illness renders them incapable of personally telephoning their line manager or their nominee will a call be accepted from a third person.

Absence for 3 days or more

If an employee is absent due to illness for more than 3 days, a medical certificate must be sent to the manager so that it is received no later than the end of the third day of absence.

Ongoing absence (In excess of one week)

In the case of ongoing illness (in excess of one week), the employee must telephone his/her manager at least 1 hour prior to the close of business on the last working day of sickness, advising that the absence is continuing or that they are returning to work. Medical certificates should be submitted each week to cover the period of absence. Medical certs are only accepted on a week-by-week basis and any changes to this are at the discretion of HR An employee must provide a medical certificate on his/her return to work stating that he/she is fit to return to work.

Failure to produce a medical certificate may lead to the instigation of disciplinary procedures. Any misrepresentation on a certificate may also lead to the instigation of disciplinary procedures.

In cases where employees are consistently absent, whether medically or self-certified, and where such absence clearly shows an unacceptable pattern and/or a failure to meet contractual obligations i.e. to attend work, a detailed investigation will be conducted by the employer, after which the disciplinary procedure may apply.

All medical information will be treated confidentially.

Returning to Work

In the event of you failing to return to work on the day originally indicated, you must:

▪ Again, make contact with the company.

▪ Explain why you are unable to return to work.

▪ Advise what day you expect to return to work.

▪ Provide an updated medical certificate if applicable!

Long Term Illness

It is Company policy to treat all employees who are seriously ill for a prolonged period of time with sensitivity and care. Each case will be dealt with individually, while following Company policy. An employee will not be paid for long term sick leave. However, he/she will be entitled to benefits from the Department of Social, Community & Family Affairs provided certain PRSI contribution conditions are complied with. An employee is required to maintain regular contact with his/her manager for the duration of the illness as it is important to maintain relationships rather than to have to rebuild them.

Occupational Sick Leave

Weekly medical certificates must be submitted to the employee’s manager.

Company Doctor

The Company Doctor may call upon an employee during any period of illness. The Company reserves the right to require any employee to undergo a Medical Examination conducted by the Company Doctor. Should an employee be deemed unfit for work, they will not be allowed to continue work until they have been passed fully fit.

Returning to Work - long term illness

In the case of long-term illness, when an employee wishes to return to work, he/she may be required to meet with the company doctor in order that the employee’s capability to return to work can be assessed. The capacity in which an employee is capable of returning to work will be discussed in the presence of the employee. A return-to-work form will be completed by the doctor and signed by both the doctor and the employee and then passed to the employee’s manager.

If the employee is capable of returning to work but not to the same job or same conditions, whilst the company may assess the situation with a view to finding suitable alternative employment for the employee, the company is not obliged to do so.

Depending on the circumstances of each individual case and the effects on business requirements, the company may be forced to terminate employment in appropriate circumstances.

Payment During Sickness

Statutory Sick Pay

The Sick Pay Act 2022 came into effect on the 1st of January 2023 and is being phased in over four years. Under the new Act employees are entitled to 5 statutory sick days during 2024. This entitlement is subject to you working for GPG for a minimum of 13 weeks and the submission of a medical certificate to cover each day of absence.

Statutory sick leave days can be consecutive days or non-consecutive days. Sickness benefit will be paid at 70% of basic gross salary up to a maximum of €110 a day.

GPG Sick Pay Scheme

The Scheme is designed to help alleviate hardship caused by loss of earnings due to absence from work through genuine illness. It is non-contributory and is financed and administered by the Company. The Scheme applies to all permanent employees who have completed their probationary period.

Under the GPG Sick Pay Scheme, no payment will be made for the first 3 days of absence. However, on the submission of a medical certificate, you may now avail of Statutory Sick Pay to cover this period. Please note if you have used all your SSP entitlement no payment will be made for first 3 days waiting period.

An employee absent through illness or injury for more than three consecutive working days must provide a doctor’s certificate not later than the end of the third day of absence.

GPG Sick Pay is paid by the company at two thirds of gross basic salary.

Employees are responsible for claiming any further social welfare and pay related benefits to which they may be entitled. This is done by sending medical evidence of incapacity for work directly to the Department of Social Welfare on the appropriate form which is available from most Doctors. This must be done within 7 days of becoming incapable of work. The social welfare payment should top up earnings to almost the full normal amount.

Duration of Benefit

Sickness benefit will be paid up to a maximum of 6 weeks in any one year or continuous period of absence on the submission of medical certificates. This 6 week period includes your entitlements under the Statutory Sick Pay (5days,1 Week) and GPG Sick Pay Scheme (5 Weeks)

Medical certificates should be submitted on a weekly basis except where otherwise agreed.

Company Rights

• The company may extend the duration in exceptional circumstances.

• The company reserves the right to refer employees to the company Doctor for examination during any absence from work.

• The company reserves the right to disqualify an employee from the scheme, if it considers that s/he is abusing the scheme.

• Where there is a pattern of frequent short-spell absences, disciplinary procedures may be invoked.

• The company reserves the right to modify or suspend the scheme in conjunction with legislation or exceptional circumstances.

Review of Procedure

This procedure will be reviewed annually, and modifications will reflect changes to Sick Pay Act 2022 entitlements.

4.4 Maternity Leave

Purpose and Scope

GPG are committed to fulfilling their obligations under The Maternity Protection Acts, 1994 and 2004 by providing to eligible employees who are pregnant; time off without pay for maternity leave and additional maternity leave, the accrual of annual leave during this time and the right to return to work following this period; time off without loss of pay for antenatal care or to attend one set of ante-natal classes; the right to health and safety leave; protection against unfair dismissal on grounds of pregnancy; the provision of either breaks or reduction in working hours to facilitate breastfeeding. All the rights and protections outlined below also apply to transgender men who are pregnant or have given birth. A gender recognition certificate, in accordance with the Gender Recognition Act 2015, will be required.

The policy covers employees who have; informed their employer that they are pregnant, have given birth in the last 14 weeks or who are breastfeeding for no longer than 26 weeks following the birth of their baby. It covers part-time, full time and agency workers. It also covers male employees in the event of the mother’s death

Responsibility

The Human Resource department is responsible for this policy.

Maternity Leave entitlements

An employee must notify their supervisor, in writing, of their intention to take maternity leave no later than 4 weeks before their maternity leave begins. The employee must produce a medical certificate confirming the pregnancy and giving the expected date of confinement.

A pregnant employee is entitled to 26 consecutive weeks maternity leave. The employee must take at least 2 weeks leave before the expected date of the birth of the baby and no less than 4 weeks after the birth of the baby. Within these parameters, the employee can choose how to divide their maternity leave before and after the baby's birth. The company understands that in the case of a premature birth, the employee’s 26 weeks of maternity leave begins immediately and dates from the day of the birth.

An employee is entitled to an additional 16 weeks of maternity leave in addition to the 26 weeks, should it be required, but there is no state payment for this additional leave. If an employee wishes to take additional maternity leave, they must notify their supervisor in writing of this intention, preferably when giving written notification of their intention to take maternity leave or otherwise no later than 4 weeks before the originally set date of return to work.

Payment during maternity leave

During maternity leave and additional maternity leave, you will be deemed to be in employment and your employment rights, with the exception of remuneration, are preserved as if you were present at work.

During maternity leave, you will not be paid by GPG. Employees who have the necessary PRSI contributions are entitled to maternity benefit from the Department of Employment Affairs and Social Protection. It is recommended that you apply at least six weeks before the start date of your maternity leave. Claims should be made on MB1 forms, which can be completed or requested online at www.welfare.ie. GPG will complete the MB2 form (not earlier than 16 weeks before your

baby is due).

During the 16-week period of additional maternity leave, no payment is made by the Department of Employment Affairs and Social Protection.

While the employee is not entitled to remuneration during the 26 weeks, all conditions of employment including full holiday and public holiday entitlements are retained.

Miscarriage

There is no entitlement to statutory maternity leave for a miscarriage occurring up to and including the 24th week of pregnancy. Any confinement occurring after the 24th week is covered.

Stillbirths and miscarriages

If you have a stillbirth or miscarriage at any time after the 24th week of pregnancy or your baby has a birth weight of at least 500 grammes, you are entitled to full maternity leave. This means you can take the basic 26 weeks’ maternity leave and 16 weeks’ additional maternity leave. If you have enough PRSI contributions, you can get Maternity Benefit for the 26 weeks’ basic maternity leave.

Premature births

If your baby is born before the date when you are due to start maternity leave, you can take extra maternity leave. You get 26 weeks’ leave, starting from the day your baby is born, plus extra leave for the number of weeks between your baby’s actual date of birth and the date you had planned to start your maternity leave. Maternity Benefit is payable for the whole of this extended maternity leave.

Fathers Leave in the event of the death of mother or partner.

Fathers can take maternity leave if the mother or birthing parent dies within 40 weeks of the birth. If they die within 24 weeks of the birth, he can choose to take the 16 weeks’ additional maternity leave. If the mother or birthing parent dies more than 24 weeks after the birth, the father can take maternity leave up until 40 weeks after the birth. The leave starts within 7 days of the mother or birthing parent’s death.

An employee will be entitled to return to his usual job, so far as it is reasonably practicable when his leave ends. However, if this is not possible, the employee will be offered suitable alternative work.

Ante-Natal/ Post-natal medical care

An employee is entitled to such time off as is necessary from her normal working time, without loss of pay, to attend medical or related ante-natal or post-natal care, and to attend one set of antenatal classes. This is subject to the employee giving their supervisor two week’s written notice of any appointment and must be able to produce a certificate/record that the visit took place. If an employee needs urgent medical attention, they must give written notice of the appointment within 1 week of the appointment, taking place.

We require that, where possible, the appointments are at the beginning or at the end of the working day. If an appointment finishes before the end of the working day, you are required to return to work.

Ante-natal classes

Pregnant employees are entitled to paid time off to attend one set of ante-natal classes (other than the last three classes). This is a once off entitlement. An expectant father is entitled, on a once-off basis, to paid time off to attend the last two classes before the birth.

Written notification must be given to your manager/HR with the dates and times of each class at least two weeks before the first class.

Health and Safety Leave

GPG will assess any risk to an employee who is:

• Pregnant

• Has recently given birth; or

• Is breastfeeding.

Therefore, if you are pregnant, it is imperative that you inform your manager, so that we can carry out a risk assessment as soon as possible. If a risk is identified and cannot be removed from the work process, then we will take the following steps to ensure that you are no longer exposed to the risk:

a. temporarily adjust your working conditions or working hours, to the extent needed to avoid the relevant risk.

b. if step (a) is not feasible, then you will be transferred to other work, or

c. if step (b) is not feasible, then you will be given health and safety leave.

GPG will pay for the first 21 calendar days of health and safety leave, thereafter a social welfare benefit may apply.

If you become aware that you are no longer vulnerable to the risk for which you have been granted health and safety leave, you are obliged to inform HR in writing of the fact, as early as reasonably practicable. Likewise, if a risk no longer exists, or if GPG is in a position to offer suitable alternative work, HR will notify you in writing and the health and safety leave will expire seven days after receiving the notification to return to work.

Returning to work following Health & Safety Leave

Health and safety leave ends on commencement of maternity leave if the employee is pregnant or ends not later than the 26th week after the birth if the employee is breastfeeding.

Additional maternity leave and sickness

You may request to terminate unpaid additional maternity leave in the event of a medically certified illness, thereby allowing you to transfer to the sick leave scheme. This is subject to approval by HR. Requests for termination of the additional maternity leave and acceptance of this by GPG must be in writing.

Please note that if you choose to transfer to the sick leave scheme, then the remainder of the additional maternity leave cannot be taken at a later date following the period of sick leave.

Postponement of maternity leave

Maternity leave and/or additional maternity leave may be postponed in the event of the hospitalisation of your child, subject to the agreement of HR. In order to request this postponement, you must already have taken at least 14 weeks maternity leave, with not less than four of those weeks being after the date of confinement.

You should request the postponement of the leavein writing as soon as possible. This request should also include a letter of confirmation from the hospital.

Breastfeeding

If you are breastfeeding, you are entitled to a reduction in working hours of one hour per day or (where suitable facilities are available) a break of one hour per day to use the facilities provided in the workplace. The one-hour break may be split into shorter periods of time totalling one hour. Parttime employees will be entitled to a pro rata benefit.

The entitlement may be availed of for up to 104 weeks after the date of confinement, provided you

inform your manager of your intention when you are advising the organisation of your intention to return to work. You will be paid during this time.

Returning to Work following Maternity Leave.

An employee must notify her supervisor inwritingof her intention to returnto work and the intended date of return, not later than 4 weeks before her intended return. This notification requirement is essential and should be brought to the employee’s attention. When maternity leave ends, an employee will be entitled to return to her usual job so far as it is reasonably practicable. However, if this is not possible, the employee will be offered suitable alternative work, with terms and conditions not substantially less favourable than those she had in her original job.

Company Cars

Company cars are provided for business purposes only and will not be retained by the employee during maternity leave. If an employee wishes to have the use of a Company car whilst on leave, a request must be made to the employee’s direct manager. Any arrangements which may be made will be done so on an individual basis.

Mobile phone

Company mobile phones will not be retained by the employee whilst on leave unless at the request of the company.

Employment protection

An employee who is absent on maternity leave will be treated as if they had not been absent. At the end of your maternity leave, you will be entitled to return to your original job under terms and conditions no less favourable than those that would have applied if you had not been absent. However, you must give at least four weeks written notice of the return-to-work date.

Applying for Leave

An employee must notify their supervisor, in writing of their intention to take maternity leave no later than 4 weeks before their maternity leave begins.

Form: RD HR 11 Notice of Intention to take Maternity Leave Form

The employee must produce a medical certificate confirming the pregnancy and giving the expected date of confinement.

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your Manager or HR Department

4.5 Paternity Leave

Purpose & Scope

General Paints Group are committed to fulfilling their obligations under the Paternity Leave and Benefit Act 2016. Paternity Leave is single period of 2 weeks of unpaid leave available to a “relevant parent” on the birth or adoption of a child, where the date of birth or day of placement falls on or after 1st September 2016.

Responsibility

The Human Resources department is responsible for this policy.

Policy

Paternity Leave entitlements

Eligible employees, who are deemed to be a ‘relevant parent’ are entitled to 2 weeks leave at any time from the date of birth or day of placement of the child up to 26 weeks thereafter. Paternity leave is available for stillbirths after 24 weeks of pregnancy.

In the case of multiple births, or where more than one child is being adopted at the same time, the maximum of 2 weeks consecutive leave still applies.

Eligibility to take paternity leave

Paternity leave is available to employees who are deemed to be the “relevant parent” of a child. Only one person who is a “relevant parent” in relation to a child can be entitled to paternity leave in respect of that child. There is no qualifying period for entitlement to paternity leave.

Under the Paternity Leave and Benefit Act 2016 a “relevant parent” is defined as:

(a) in the case of a child who is, or is to be, adopted the spouse, civil partner or cohabitant, as the case may be, of the qualifying adopter of the child, or

(b) in any other case.

(i) the father of the child,

(ii) the spouse, civil partner or cohabitant, as the case may be, of the mother of the child, or

(iii) a parent of the child under section 5 of the Children and Family Relationships Act 2015 where the child is a donor-conceived child within the meaning of Part 2 of that Act.

Part- time and Casual Hours staff

A staff member who is on less than full hours who is the relevant parent is entitled to paternity leave on a pro-rata basis.

Fixed Term and Specific Purpose contracts

A staff member who is on a fixed term or specific purpose contract of employment is entitled to paternity leave during the term of their contract. Paternity-related entitlements will cease on expiry of the contract unless the contract is followed directly by another contract.

Entitlement on the death of the relevant parent

In the event of the death of the relevant parent entitled to the paternity leave within a period of 28 weeks after the birth or placement of the child and before availing of some or all of the paternity leave, the leave shall transfer to the surviving parent.

Postponement of paternity leave due to late birth/postponed adoption placement

An employee who is a relevant parent may postpone a period of paternity leave where the date of birth occurs after the date selected by a relevant parent in their notification to the company or where the date of placement is postponed in the case of adoption. The relevant parent may select another date on which paternity leave will commence.

Postponement of paternity leave due to illness of the relevant parent

In the event that an employee becomes ill before a period of paternity leave has commenced, the period of leave may be postponed. Notification of a request to postpone the leave due to illness must be received by the HR as soon as possible after becoming ill and must be accompanied by a medical certificate. The employee must follow up in writing confirming the request to postpone the leave as soon as is reasonably practicable but not later than the day on which the postponed leave begins. The leave may be postponed until such time as the relevant parent is no longer sick. The period of postponed leave must end not later than 28 weeks after the date of birth or day of

placement. The employee must notify the company when they intend to take the postponed paternity leave not later than the day the employee commences the leave.

Postponement of paternity leave when the child is hospitalised

If the child is hospitalised, the employee may request in writing to postpone all or part of their paternity leave. Postponement of paternity leave in such circumstances is subject to approval by the organisation. The company will respond to the request for postponement as soon as practicably possible with a decision on the matter.

Where HR agrees to postpone the leave, the leave will be postponed with effect from a date agreed by both parties. The employee will return to work on a date agreed by HR and employee. The postponed leave, which must be taken in a continuous block not later than 7 days after the discharge of the child from hospital or such other date as may be agreed upon between the employee and the company. The employee must notify the company when they intend to take the postponed paternity leave not later than the day the employee commences the leave.

It is important to note that if the employee falls ill during the period of postponement of paternity leave, and requests to be viewed as being on sick leave from work, the employee will forfeit the remainder of the paternity leave which cannot be taken at a later date following the period of sick leave.

Transferred paternity leave

Where a relevant parent entitled to paternity leave in relation to a child dies, an employee who is the surviving parent of the child will be entitled to the leave. This entitlement exists up to 28 weeks after the date of birth or day of placement of the child.

Holiday and Public Holiday Entitlement

While on paternity leave employees retain the right to accrue annual leave and public holidays as if the employee had not been absent from work.

Paternity Benefit or pay during Paternity Leave

Continuation of salary during paternity leave is not a statutory entitlement. The Department of Social Protection provides Paternity Benefit to the qualifying and relevant parent in question. The applicant is responsible for completion of the relevant forms. Please note Paternity Benefit payment is taxable income.

Employment Rights

During the period of paternity leave, the employee is treated as if they are present at work with all contractual benefits still applying such as annual leave and public holidays and other entitlements as per their contract of employment but with the exception of pay.

Probation

Should an employee be on probation on the date that paternity leave commences, probation will be suspended on that date and will recommence once the employee returns from leave.

Company Property

The employee may be required to return company property (e.g. company car, laptop, mobile phone, etc.) to the company during the period of paternity leave, depending on operational and business needs.

Abuse of paternity leave

Where the organisation has reasonable grounds for believing that an employee who is on paternity leave is not using the leave for the purpose for which it is intended, the organisation may, by notice in writing given to the employee, terminate the leave and the notice will contain a statement in summary form of the grounds for terminating the leave and will specify the day by which the employee must return to work. If, following an investigation, an employee is found to have abused this leave, he or she may be subject to disciplinary action, up to and including dismissal.

Applying for leave

The relevant parent must notify their manager of their intention to take paternity leave not less than 4 weeks before commencement of such leave by completing the following form:

Form: RD HR 18 Notice of Intention to take Paternity Leave Form

The following documentation must also be submitted.

In the case of a birth:

• A copy of the medical certification confirming the pregnancy and specifying the expected date of birth of the child concerned or

• A copy of the birth certificate where notification is given after the birth.

In the case of an adoption:

• A declaration / official placement order

• A copy of the placement certificate where notification is given after the date of placement

• In the case of a foreign adoption, a Declaration of Suitability from the Adoption Authority of Ireland, in advance of the date of placement or written confirmation of placement as soon as possible after the placement.

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your manager or HR Department

4.6 Parents Leave

Purpose and Scope

The purpose of Parents Leave is to provide seven weeks paid leave in the first two years of the child’s birth or adoptive placement. This policy covers all current employees of GPG.

Responsibility

The Human Resource department is responsible for this policy.

Policy

Each parent is entitled to 5 weeks paid parent’s leave for a child born or adopted on or after 1 November 2019. Parent’s leave increased from 5 weeks to 7 weeks for children born or adopted after 1 July 2022.

This leave is specifically for parents during the first two years of the child’s birth or adoptive placement. Parent’s benefit is paid while you are on parent’s leave from work if you have enough social insurance (PRSI) contributions. You will not receive a payment from the company whilst on Parents leave, however, if you qualify for Parents Benefit you will receive €245 each week. Parent’s leave is non-transferable between parents to ensure that both parents are encouraged and supported in taking time out from work to spend with their child.

Procedure

Relevant parents can take parent’s leave for eligible children. A relevant parent is one of the following:

▪ A parent of the child

▪ A spouse, civil partner or cohabitant of the parent of the child

▪ A parent of a donor-conceived child as provided for under section 5 of the Children and Family Relationships Act 2015

▪ The adopting parent or parents of a child

▪ The spouse, civil partner, or spouse of the adopting parent of the child (if the parents have not adopted jointly).

▪ Each member of a married couple of the same sex, a couple that are civil partners of each other, or a cohabiting couple of the same sex.

You can take this leave as:

▪ One continuous period of 7 weeks leave or

▪ Periods of not less than one week

▪ Parent’s leave cannot be transferred between parents – except in specified circumstances such as the death of one of the parents

▪ You must give 6 weeks’ notice to GPG

Postponement

Your employer can postpone your parent’s leave for up to 12 weeks. Your employer could postpone your leave for the following reasons:

• Seasonal variations in the volume of work

• No replacement to carry out your work

• The nature of your duties

• The number of other employees also taking parent’s leave

• Any other relevant matter

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your manager or HR Department

4.7 Parental Leave

Purpose & Scope

The purpose of this policy is to provide unpaid parental leave to employees who are natural or adoptive parents to take care of a child before the child reaches 12years of age or age 16 years in the case a child with a disability or long-term illness. A person acting in loco parents with respect to

an eligible child is also eligible. All full time and part-time employees who are parents and meet certain criteria outlined below.

Responsibility

The Human Resource department is responsible for this policy.

Policy

Any full-time employee who is a natural or adoptive parent or acting in loco parentis for a child is entitled to 26 weeks unpaid leave or shorter periods, with the agreement of the Company, to enable him/her to take care of his/her child. The leave must be taken before the child reaches 12 years of age or 16 years in the case of a child with a disability or long-term illness. In the case of adopted children if the child reaches 12 years of age. However, if the child is aged between ten and twelve years at the time of the adoption, the leave must be taken within two years of the adoption order. In addition, an extension may also be allowed where illness or other incapacity prevented the employee from taking the leave within the normal period.

The unpaid parental leave may be taken either as a continuous block of 26 weeks or two separate periods of a minimum of six weeks each. If the leave is taken in this way, there must be at least ten weeks between each separate period. Where an employee has more than one child, parental leave is limited to 26 weeks in a 12-month period. Parents of twins or triplets can take more than 26 weeks of parental leave in a year. Leave will be recorded in the employees’ Confirmation Document.

Full-time employees who have less than 1 years’ service may be entitled to a pro rata parental leave entitlement after 3 month’s service if the child is about to go beyond the specified age limit. The parental leave entitlement is one week’s unpaid leave for each month of continuous employment. Periods of training or probation will be extended to take account of the number of week’s absence due to parental leave.

Permanent part-time employees will be entitled to unpaid parental leave on a pro-rata basis. This is calculated on the average number of hours worked per week in the 14 working weeks prior to the commencement of the parental leave.

All employment rights are protected while on parental leave. Public holidays, holidays, sick leave emergency leave or maternity leave are not considered to be part of parental leave.

Procedure

If you are applying for Parental Leave the following Documentation must be completed:

Confirmation to employee

The appropriate Manager will produce a Confirmation Document, for the employee to sign at least 4 weeks prior to the date of commencement.

Postponement by Company

In cases where the leave could have an adverse effect on the business, the company reserves the right to postpone its commencement for up to 6 months. Such a requirement will always be discussed with the employee, and then put formally in writing.

Signed copies of all Confirmation Documents will be held by both employee and the company. It is important for all employees availing of this leave to keep their own records. All company copies must be retained by the appropriate Manager and held on the individual’s personnel Record.

Abuse of Parental Leave

Parental Leave is granted solely for the purpose of taking care of the child concerned. Employees found abusing their entitlement to parental leave will immediately have their parental leave entitlement terminated and will be subjected to the company disciplinary process. The company reserves the right to discontinue the employee’s salary, pension, and medical insurance. Employees will return to their normal job on completion of their period of parental leave, in so far as is practicable.

Apply for Leave

Employees must fill out and submit a Notice of Intention to take Parental Leave Form, not later than six weeks before the commencement of the leave. The request must specify the commencement date, duration, and mechanism for taking the parental leave. A Birth Certificate for the child must be attached.

Form: RD HR 17 Notice of Intention to take Parental Leave

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your manager or HR Department

4.8 Adoptive Leave

Purpose and Scope

The purpose of this policy is to outline the circumstances in which time-off will be given to team members who have adopted a child. This policy provides leave to all adopting couples same sex and opposite sex. Any changes in the prevailing legislation in respect of adoptive leave will automatically apply. It is our policy not to pay any salary or other benefits to team members during any periods of adoptive leave.

Responsibility

The Human Resource Department has responsibility for this policy.

Policy

The Company will operate the following policy concerning adoptive leave.

Adopting Mothers and Sole Male Adopters

Pursuant to the Adoptive Leave Act (as amended from time to time) all adopting couples’ same sex and opposite sex can choose which of the couple should be able to take the adoptive leave. The parent who does not avail of the adoptive leave is entitled to paternity leave. The parent availing of the adoptive leave is entitled to 24 weeks adoptive leave from the date of placement during which a team member may claim social welfare adoptive benefit provided the team member has the necessary PRSI contributions. The local Department of Social Protection office will advise you if you are entitled to social welfare payments.

An additional 16-week unpaid adoptive leave can be taken immediately after the 24-week period, provided that the procedure below is followed. Social welfare adoptive leave benefit will not be paid during this additional 16 weeks. This 16-week period is known as ‘additional adoptive leave’.

The parent in choosing to take the leave, must give notice of intention to take adoptive leave no later than four weeks before the expected date of placement.

In the case of an Irish adoption, the team member must, no later than four weeks after the date of placement, produce a certificate of placement to us. In the case of a non-Irish adoption, a declaration of eligibility and suitability must be produced as soon as is reasonably practicable.

Additional Adoptive Leave

If the parent choosing to take the leave wishes to take additional adoptive leave of up to 16 consecutive weeks, he/she must inform us of this intention, at the same time as notification is given for adoptive leave or no later than four weeks before he/she is expected to return to work at the end of adoptive leave. The additional adoptive leave must follow immediately on from the original adoptive leave.

In foreign adoption cases, the parent choosing to take the leave may take some of the additional leave before the placement of the child. If you wish to do so, you must notify your line manager or their nominee in writing four weeks before the leave is due to begin. A declaration of suitability and eligibility must also be supplied.

Protection of Rights

While you are on adoptive leave, all statutory and contractual employment rights are protected, except the right to remuneration and superannuation benefits/contributions. All periods of adoptive leave are unpaid by us. You must give four weeks written notice to us of your intention to return to work. If an adopting father’s entitlement is less than four weeks, he must notify us of his intended return date at the same time as he gives his notification of taking leave

Returning to Work

An adopting parent must provide his/her employer with written notification of his/her intention to return to work no later than 4 weeks before the intended date of return.

If an adopting father’s entitlement is less than 4 weeks, he must notify his employer of his intended return date at the same time as he gives his notification of taking leave.

When adoptive leave ends, an employee will be entitled to return to his/her usual job so far as is reasonably practicable. However, if this is not possible, the employee will be offered suitable alternative work.

Payment during Adoptive Leave

An employee who is on adoptive leave will be entitled to payment form the Department of Social Protection for up to 24weeks. Payment will be available if the employee has paid the relevant PRSI contributions and provides a certificate of placement in the case of Irish adoptions, or a declaration of eligibility and suitability in the case of foreign adoptions. The parent who does not avail of the adoptive leave is entitled to paternity leave, from the Department of Social Protection

Apply for Leave

The parent in choosing to take the leave, must give notice of intention to take adoptive leave no later than four weeks before the expected date of placement.

Form: RD HR 19 Notice of Intention to take Adoptive Leave

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your manager or HR Department

4.9 Carers Leave

Purpose and Scope

The purpose of this policy is to provide for the temporary absence from employment of employees from the purpose of the provision of full-time care and attention to a person requiring it. The policy covers all permanent employees with one year’s continuous service.

Responsibility

The Human Resource Manager is responsible for this policy.

Policy

The entitlement to carer's leave applies to employees who have been employed for a continuous period of 12 months by the company. An eligible employee will be entitled to leave from employment to provide care for a person requiring it, for a period not exceeding 104 weeks, the duration of which to be agreed in conjunctionwith the HR Department. You may apply to take carer’s leave in one continuous period of 104 weeks or for a number of periods not exceeding a total of

104 weeks. If you do not take carer’s leave in one continuous period, there must be a gap of at least 6 weeks between the periods or carer’s leave. The company reserves the right to refuse applications for periods of carer's leave that are less than 13 weeks but will give such applications due consideration.

The person the employee proposes to provide full-time care and attention for must be deemed a relevant person by a deciding officer, from the Department of Social Community and Family Affairs, whose decision will be based on specific medical information of the relevant person. In order to receive company approval to take a period of carer's leave a written decision from the Deciding Officer must accompany the completed 'Notice of Intention to Take Carer's Leave' form. The company may request evidence from the employee that he/she is providing care and attention for the relevant person. Employees are not entitled to a period of carer's leave where another employee of the company is absent from employment, during the same period, on carer's leave for the same relevant person.

The period of carer's leave is unpaid by the company and employees are limited in respect of any paid employment which they may undertake the period of carer's leave, see HR for details. The company will favourably consider requests from individuals on Carer's Leave for limited part-time working as permitted by the Department or as permitted under the Carer's Leave Act. An employee may be entitled to Carer's Benefit (administered by the Department of Social Community & Family Affairs) but entitlement to this benefit is not a condition for entitlement to carer's leave from the company.

Procedure

Employees must provide the company with a minimum of 6 weeks’ notice of the intention to commence carer's leave. In exceptional or emergency circumstances this notice period may be waived and the company may accept notice as soon as is reasonably practicable.

Protection of Employment Rights

While an employee is on carer's leave all statutory and contractual employment rights are protected except the right to remuneration. An employee's right to annual leave and public holidays is maintained only during the first 13 weeks from the commencement date of the period of carer's leave.

An employee's absence from work during a period of carer's leave will not be treated as part of any other leave to which the employee is entitled such as sick, annual, adoptive, maternity, parental or Force Majeure leave.

Employees found abusing their entitlement to carer's leave will immediately have their carer's leave entitlement terminated and will be subject to the company disciplinary policy

Return to Work

Employee's must notify the company in writing, not less than 4 weeks before the date on which the employee is due to return to work, of his/her intention to return to work. Employees will return to their normal job on completion of the period of carer's leave in so far as is reasonably practicable.

Applying for Leave

A 'Notice of Intention to Take Carer's Leave' form must be completed by the employee wishing to avail of carer’s leave. No less than 2 weeks prior to the intended commencement date a 'Carer's Leave. Confirmation Document' must be signed and completed by both the employee and his/her manager.

Form: RD HR 13 Notice of Intention to take Carers’ Leave

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your Manager or HR Department

4.10 Force Majeure Leave

Purpose and Scope

The purpose of Force Majeure leave is to provide paid leave, in the event that a member of an employee’s family has suffered an illness or injury, and the employee’s immediate presence is required. This policy covers all current employees of GPG.

Responsibility

The Human Resource department is responsible for this policy.

Policy

The immediate family members covered by the Act include:

• Natural or adoptive child of the employee

• Spouse or person with whom the employee is living as husband or wife.

• A person to whom the employee is in loco parentis.

• Brother/sister of the employee.

• Parent or grandparent of the employee

• A person who resides with the employee in a relationship of domestic dependency.

Employees will be entitled to up to 3 days paid Force Majeure leave in any 12 consecutive months or up to 5 days in 36 consecutive months. Force Majeure leave is available to any employee whose situation meets the following criteria:

• Urgent

• Immediate

• Indispensable

The nature of Force Majeure leave means that for urgent family reasons due to the injury or illness of an immediate family member it cannot, by definition, be forecast or predicted in advance. Therefore, it must relate to the injury or illness of an immediate family member which is not foreseeable or otherwise generally predictable. Both the injury and illness must be so significant that it requires the indispensable and immediate presence of the employee concerned. Therefore routine, minor, or predictable illnesses or injuries will generally not be covered by Force Majeure leave.

Prior medical appointments will not be deemed eligible by the company for Force Majeure leave.

Applying for Leave

Prior notice does not arise in the case of Force Majeure leave. As soon as is reasonably practicable after an employee has availed of the entitlement, they must give written notice by completing the Notice to Employer of Force Majeure Leave Form which outlines a summary of the facts entitling them to the leave and return it the Human Resource department.

Form: RD HR 24 Notice of Intention to take Emergency Leave Force Majeure

On receipt of the completed form, the Human Resource department., in consultation with the employee, if required, will determine if the absence qualifies as Force Majeure. If so, HR will notify

payroll, and payment will be processed in the next payroll run. The company may where it deems appropriate request further information i.e. medical certificates, hospital reports etc.

The company wishes to state that all matters appropriate to reasons for this type of leave will remain strictly confidential and any relevant documentation will be kept in the personnel files.

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your Manager or HR Department

4.11 Leave for Medical Care Purposes

Purpose and Scope

The purpose of leave for Medical Care Purpose is to provide the employee with unpaid leave to deal with serious medical care for a child or other relevant person like a family member. Unpaid leave for medical care is different to force majeure leave, which is paid leave for an urgent family crisis.

Leave for medical care purposes is a short-term unpaid leave that employees can avail of for the purposes of providing personal care or support to certain specified persons.

Responsibility

The Human Resource department is responsible for this policy.

Entitlement

You can apply for the leave to care or support your:

• Child (including an adopted child)

• Spouse or civil partner

• Cohabitant

• Parent or grandparent

• Brother or sister

• Housemate (any other person to those listed above who lives in the same house as you)

The person must need significant care or support for a serious medical reason. A person is considered to be in need of significant care or support for a serious medical reason where, owing

to the person’s disability, injury or illness, her or she requires such care or support that includes the presence of the employee at the place where the person is.

The immediate family members covered by the Act include:

• Natural or adoptive child of the employee

• Spouse or person with whom the employee is living as husband or wife.

• A person to whom the employee is in loco parentis.

• Brother/sister of the employee.

• Parent or grandparent of the employee

• A person who resides with the employee in a relationship of domestic dependency.

The sick person must need significant care or support for a serious medical reason.

Leave for medical care purposes shall consist of one or more days on which, but for the leave, the employeewould beworking. The entitlement applies when the presenceofthe employee is required at the place where the disabled/ill/injured person is located.

The leave shall not exceed 5 days in any period of 12 consecutive months and shall not be taken in a period of less than one day. Part days shall be regarded as full days for the purposes of the maximum number of days an employee can take. There is no minimum service requirement for the leave.

Applying for the leave

Due to the nature of leave for medical care purposes it may not be possible to apply for the leave in advance. However, where it is possible to provide advance notice of an intention to take leave for medical care purposes, employees are encouraged to do so.

When an employee takes or intends to take the leave, an employee is required to inform the organisation as soon as reasonably practicable. Employees must fill out and submit a Notice of Intention to take Leave for Medical Care Purposes as soon as you are aware that leave is required.

Form: RD HR 20 Notice of Intention to take Leave for Medical Care Purposes

If notice not possible in advance as soon as is reasonably practicable after an employee has availed of the entitlement, they must give written notice by completing the Leave for Medical Care Purpose Form which outlines a summary of the facts entitling them to the leave and return it the Human Resource department.

The employee may also be required to provide relevant evidence in relation to the person for whom the relevant care or support is or is proposed to be provided. This may include a certificate signed by a medical practitioner or such other evidence as GPG may require in order to show that the person concerned was in need of significant care or support for a serious medical reason.

The medical cert does not need to state the nature of the medical condition. It only needs to be a statement of fact that the person is, or was, in need of significant care or support for a serious medical reason.

On receipt of the completed form, the Human Resource department., in consultation with the employee, if required, will determine if the absence qualifies Leave for Medical Care Purpose.

All your employment rights, except remuneration, are protected while you are on leave for medical care purposes. You will return to your normal job on completion of the period of leave

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your manager or HR Department

4.12 Compassionate Leave

Purpose & Scope

The purpose of the GPG’s compassionate leave policy is to provide time off for employees in the event of a personal or family crisis. All employees are covered by the Company’s compassionate leave policy.

Responsibility

The Human Resource Department has responsibility for this policy.

Policy

The Company understands that employees require time off in the event of bereavement. In such circumstances however, compassionate leave will always be granted at the discretion of the company. Paid compassionate leave will be allowed to staff members in the case of the death of a close family member.

The entitlement is:

• three days paid leave on the occasion of the death of a parent, spouse, brother, sister or child,

• two days paid leave on the occasion of the death of a mother or father-in-law, an

• one days paid leave on the occasion of the death of a grandparent, aunt, uncle, brother-inlaw or sister-in-law.

Applying for Leave

Requests for compassionate leave for reasons other than those listed above should be made through a staff member’s manager and will be decided upon at the discretion of management on a case-bycase basis.

4.13 Domestic Violence Leave

Purpose & Scope

The purpose of this leave is to provide for a period of paid time away from work for staff members who have suffered, are suffering or are at risk from domestic violence or abuse. This leave will enable the staff member to take the time they need to seek assistance in a structured and supported environment, where decisions are victim led.

Responsibility

The Human Resource department is responsible for this policy.

Policy

GPG recognises the prevalence of domestic violence in our society and the impact it may have on our staff members. In line with our values and our commitment to the health and safety of our staff, we oppose all forms of domestic violence and seeks to support victims andsurvivors of such violence through the provision of leave and other resources.

All staff members are eligible for domestic violence leave. There is no minimum service period required to qualify for this leave.

Domestic violence leave will be granted to a staff member who has been the victim of an act or acts of domestic violence or abuse. For the purposes of this policy domestic violence will be defined as follows:

“Domestic violence (sometimes referred to as domestic abuse, family violence, or intimate partner violence) involves violent, threatening, or otherwise abusive behaviour by a family member/intimate relation, including but not limited to physical and sexual assault, psychological abuse, coercive control, financial abuse, stalking or dating abuse.”

You are eligible if the person perpetrating the domestic violence and abuse is your:

• Spouse, civil partner or relevant person

• Cohabitant

• Current or former intimate partner (current boyfriend or girlfriend)

• is a child of the employee or relevant person who is of full age and is not, in relation to the employee or relevant person, a dependent person

You are also eligible for domestic violence leave if you are supporting a 'relevant person'. A ‘relevant person’ is someone who has experienced or is experiencing domestic violence or abuse and that person is your:

• Spouse or civil partner

• Cohabitant

• Intimate partner

• a child of the employee who has not attained full age

• person who, in relation to the employee, is a dependent person.

You have a right to 5 days of domestic violence leave in any consecutive 12 months. If you work part-time, you are entitled to domestic violence leave on a pro-rata basis. This means, for example, if you work 50% of a normal working week, you are entitled to 2.5 days’ leave

The leave does not need to be taken all at once. It can be taken as single or multiple days. An absence for part of a day is counted as one day. Domestic violence leave is paid leave.

Purpose of Domestic Violence Leave

The purpose of the leave is to enable an employee who is subjected to domestic violence, or an employee supporting a ‘relevant person’ to do any of the following:

• Seek medical attention

• Obtain services from a victim service organisation

• Obtain psychological or other professional counselling

• Relocate temporarily or permanently

• Obtain a court order such as a safety order, barring order or protection order

• Seek advice or assistance from a legal practitioner

• Seek assistance from the Garda Síochána

• Seek or obtain any other relevant services

All employment rights are protected while on domestic violence leave.

Procedure

If you are applying for Domestic Violence Leave, due to the sensitivity of the situation, please contact the HR Department. Human Resources will also make available all other supports within the business i.e. Employee Assistance Programme and Mental Health Champion support.

Apply for Leave

Employees must fill out and submit a Notice of Intention to take Domestic Violence Leave as soon as you are aware that leave is required. In emergency situations please contact the HR Department directly.

Form: RD HR 21 Notice of Intention to take Domestic Violence Leave Purposes

Abuse of Domestic Violence Leave

Employees found abusing their entitlement to domestic violence leave will immediately be investigated and may be subjected to the company disciplinary process up to and including dismissal.

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your Manager or HR Department

4.14 Jury Service Leave

Purpose and Scope

The purposeof the jury service policy is to providea policy in accordance with statutory requirements to allow employees paid time off for jury duty. All employees are covered by the jury service policy.

Responsibility

The Human Resource department is responsible for this procedure.

Policy

Employees who are called for jury duty will be entitled to time off with pay for the required length of time. If an employee does not have to attend court, he/she is expected to report to work each day. An employee who is summoned to jury duty must inform his/her supervisor as soon as possible and produce the jury summons.

Payment

The company will pay your wages in full when you are on Jury service only. If you are acting as a witness, then the court in question is obliged to pay you.

Applying for Leave

Jury Summons must be provided to employee’s manager. Jury Service Leave Form must be submitted to manger for duration of jury service. This cannot be completed in advance but must be completed as soon as reasonably practicable.

Form: RD HR 22 Jury Service Leave

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your Manager or HR Department

4.15 Study and Exam Leave

Purpose and Scope

The purpose of the study and exam leave policy is to allow employees paid time off while studying for exams.

This policy applies to employees who are studying for company approved exams.

Responsibility

The Human Resource department is responsible for this policy.

Policy

GPG are committed to the development of all its employees. To support this:

• Each employee is entitled to a half days study leave per exam (1st sitting only) to a maximum of 3 exams or 1.5days.

• No paid leave will be granted for second or subsequent sittings.

• Any additional leave must be taken at the employees’ own expense and must firstly be cleared with relevant supervisor.

• The days of exams are also treated as paid leave (in addition to study leave) up to a maximum of 3 exams or 3 days. When an exam takes place in the evening/ night or weekend, a half day exam leave applies.

Applying for Leave

Employee must confirm in writing to manger time off required for exams/study leave.

Form : RD HR 25 Notice of Intention to take Study Leave

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your Manager or HR Department

4.16 Time off in Lieu (TOIL)

Purpose and Scope

The purpose of this policy is to provide guidance to managers and employees on the operation of Time Off in Lieu (TOIL), to ensure that arrangements are fair for employees and GPG.

This policy applies to hours that are required to be worked outside of a salaried employee normal working hour

Responsibility

Heads of Function and the Human Resource department is responsible for this procedure.

Definition

Time off in Lieu (TOIL) is defined as: "time off, which you are allowed to take, for hours worked beyond your contracted hours".

Policy

GPG’s success relies on the skills, energies, and commitment of its staff. On occasions staff may be required to work beyond their contracted hours in order to meet the requirements of the job. This goodwill and adaptability make it possible to provide a responsive and flexible service and cope with varying work demands.

GPG also has a duty and is committed to protecting the health and safety of its staff by ensuring that they do not work excessive hours and that they are recompensed by taking TOIL for extra time worked. Additional hours must be agreed in advance with managers and monitored appropriately. It is the line manager’s responsibility to oversee their team’s workload so that work is done within the normal working week.

This policy does not form any part of any contract of employment and may be amended at any time. GPG recognises that TOIL allows staff to respond flexibly to service needs. In order for TOIL to be managed appropriately, Managers and staff will adhere to the following principles:

TOIL is not a tool to be used to accrue time to enable extra days leave to be taken. Staff should generally carry out their duties within their contracted hours.

TOIL is an exceptional rather than a routine occurrence. It is to ensure that when employees have to work beyond their contracted hours, this time can be taken back Staff should plan work in advance and any TOIL that is to be accrued must be agreed in advance with an employee’s line manager.

• Staff must agree in advance with their line manager any time to be worked outside of contracted hours.

• Staff may accrue TOIL in multiples of thirty minutes.

• Staff should not build up excessive amounts of TOIL, or if there is a risk of this happening, then the employee should discuss the reason why with their line manager in the first instance, in order that duties can be reviewed.

Taking and Recording TOIL

TOIL must be taken within four weeks of its accrual otherwise it will be lost. This ensures that hours do not accrue over an extensive period of time and that the member of staff receives the appropriate rest days.

On leaving employment, all TOIL must be at a zero balance. Staff will not be paid in lieu of accrued TOIL which has not been taken by the final date of employment. Any such accrued TOIL will be lost

Applying for TOIL

Staff must obtain their line manager’s approval before taking any TOIL, by requesting it through the HR App. The time requested should be clearly designated ‘TOIL’, with an explanation of when the time was accrued. The time should also be recorded on the Time in Lieu form and submitted to the employee’s manager.

Form: RD HR Time in Lieu Form

Relevant Documentation:

Available on HR Intranet/HR Policies & Procedures Folder or from your Manager or HR Department

Section 5: Health & Safety

5.1 Safety Statement & Identification of Hazards in the workplace

It is company policy to provide a safe and healthy work environment for all employees, either onsite or working remotely, and to meet our duties to customers, contractors, and visitors. The company acknowledges its role in protecting the safety, health and welfare of all people employed in the organisation and affected by the workplace. We are committed to implementing safe work systems and methods to ensure the safety, health, and welfare of all.

The company understands its legal obligations and its commitment to comply with the Safety, Health and Welfare at Work Act, 2005, and any other legislation such as the General Applications Regulations 1993 or as required under EU Law.

The company recognises that its obligations are to provide the following:

• A safe place of work

• Safe systems of work

• Appropriate information and training to ensure safety

• Preparation and revision of emergency plans

• Prevention of risk to health from any activity

• Hygiene facilities as appropriate

The success of this policy will depend on the co-operation of all employees. It applies to all employees, whether onsite or remotely. It is therefore important that you acquaint yourself with all areas of the Safety Statement and Safety Policy You should ensure that you understand your role and the overall arrangements for health and safety within the company and within your individual department and workspace You should also be aware that you have an obligation to take care of your own safety and that of others who might be affected by your actions.

Disregard for the Health & Safety policies will be regarded as serious misconduct and may result in disciplinary action being taken. If you are in doubt with regards to any safe system of work, please ask for assistance.

Identification of Hazards in the Workplace

The company will appoint competent person(s), either from within or outside the organisation, to carry out a risk assessment and identify hazards in all areas of the workplace. Assessments will be carried out as and when required; such assessment will take into account any changes arising from adjustments in work practices or the introduction of new equipment Co-operation will be expected and forthcoming from all staff. A written copy of the assessment will be kept on file.

Should anyone consider that a hazard or important issue has not been dealt with or dealt with appropriately, then he/she should bring the issue/hazard to the attention of the appropriate manager. Managers must also ensure that all complaints are reported, and any unsafe behaviour, practices or equipment is immediately dealt with.

Where possible all risks will be eliminated. Where it is not possible, then the risks will be limited or controlled at an acceptable level. Control and protection procedures will include safe systems of work, personal protective clothing and equipment and any other control necessary.

5.2 Employers Commitment

Informing Employees on Health and Safety

On commencing employment, as part of their induction process, all employees will receive training to ensure that they understand the safety precautions and the emergency procedures to be followed.

• All employees directly involved in manual handling tasks will receive such training at during their induction.

• All employees directly involved in specialised tasks, or the use of hazardous materials, equipment or work processes will receive relevant training during their induction

• Training in first aid will be given to a selected number of employees

• Training in fire prevention and procedures to be followed in the event of a fire.

Informing Visitors on Health and Safety

Visitors are to be requested to observe the safety procedures at all times and to conduct themselves in a safe manner. Visitors should be accompanied while on the premises. While this is not always possible, employees should follow this guideline as closely as is reasonably practicable.

In order to secure the safety, health and welfare of employees, the company will commit to the following:

• Carry out risk assessments, identify hazards and prepare a safety statement, taking account of the general principle of prevention

• Management will be fully familiar with the organisation’s safety statement and ensure all employees are informed of its contents and any subsequent revisions.

• Employees will be informed of hazards and risks identified, the protective and preventative safety measures, and the names of designated employees representing health and safety processes

• Organise methods and systems for managing and conducting work activities to ensure, as far as possible, the health and safety of employees

• Ensure that there are safe means of access and egress to the place of work, and endeavour to ensure that the equipment and facility is safe and without risk to health

• Prevent, as far as possible, any improper conduct or behaviour likely to put the health and safety of the employees at risk

• No employee will be dismissed or penalised for complying with or exercising their rights under the health and safety statutory provisions

• A Safety Committee, this committee will meet to review all safety issues and accidents/dangerous occurrences in order to ensure compliance with the safety statement and relevant legislation

• Provide written information and instructions regarding fire safety on the premises to ensure that employees are aware of the actions to be taken in the case of an emergency

• Ensure that properly maintained fire protection equipment is available and that fire exit routes are kept clear

• Provide and maintain first aid boxes on the premises

• Ensure that all employees receive adequate safety training and instruction appropriate to the task performed

• Will consider and support any representation about health and safety from any employee

• Dedicate the resources necessary to ensure, as far as is reasonably practicable, the safety, health and welfare of its employees and visitors to the premises

• Co-operate and communicate with other employers who share the place of work in relation to health and safety compliance.

• Relevant health and safety information will be provided to another employer if that employer has any employees based at this company’s places of work

• Report accidents and dangerous occurrences to the Health and Safety Authority (HSA)

The Safety Statement will be reviewed by management and the Safety Committee and will be changed as appropriate Compliance with the safety statement is the ultimate responsibility of management, who will be supported in this by audits carried out by the Safety Committee and evaluation of accident reports and statistics.

Provision of Personal Protective Equipment

Personal Protective Equipment (PPE) is designed to protect employees from risks to their health and safety and includes all protective equipment and clothing. All employees will be informed, before they begin work, of the safest method of carrying out their particular work and will be given instructions and training on how to use PPE correctly Before commencing work, employees will also be made aware of the PPE they are required to wear and use when carrying out their work.

Employees will be provided with all the necessary PPE Employees MUST wear and use all required PPE at all required times and in the correct manner. Failure to do so will result in disciplinary action up to and including dismissal. Employees will not be charged for the cost of any PPE used solely for work

Employees have a duty to check their PPE and ensure that it is maintained and stored correctly. Should an employee consider that there are any defects in his/her PPE or that it does not meet his/her needs, he/she should immediately inform the manager. Employees must not begin or continue to work if there is something wrong with their PPE The Plant Manager will regularly check the functionality of all PPE.

5.3 Employee Duties

All employees are actively encouraged to participate in the safety process on matters relating to safety, health and welfare at work The company will appoint a Safety Officer to support initiatives on health and safety across the company. This does not take away any employee’s or manager’s responsibility in this area. Employees have access to anyone in the company for addressing issues. The senior management of the organisation, however, has overall responsibility for compliance with health and safety requirements.

The names of relevant designated health and safety representatives (Safety Officer, Fire Officer, Fire Marshals, and First Aid Officers) will be placed on noticeboards to ensure employees are aware of who to contact with regard to health and safety.

The co-operation of employees in matters relating to Safety, Health and Welfare is of paramount importance in order to have an effective Health and Safety policy

Each employee has a duty to:

• Take reasonable care for his/her own safety, health, and welfare and that of any other person who may be affected by his/her acts or omissions while at work

• Co-operate with the company and any other person to such extent as will enable the company or the other person to comply with any of the relevant statutory provisions

• Ensure that he/she is not under the influence of an intoxicant so as to endanger his/her own health and safety or that of any other person, and submit to any appropriate and reasonabletests for intoxicants as required by the organisation.

• If an employee becomes aware that they are suffering from any illness or physical or mental impairment which, in the course of carrying out work activities, could expose the employee or other employees to a health and safety risk, the employee should immediately notify management, or a medical practitioner nominated by the management (who must then inform the employer). Action will be taken by the management to ensure compliance with the safety legislation.

• Not engage in improper conduct or other behaviour that is likely to endanger his/her safety or that of any other person

• Attend such training as may be required to ensure compliance with health and safety legislation.

• Adhere to safe lifting methods and use any personal protective equipment, including appliances, equipment or other means or things provided to secure safety, health, and welfare at work, in such a manner so as to provide the protection intended

• Report to the company or your manager, without unreasonable delay, any defects in equipment, place of work or system of work, or any other contravention of the statutory provisions which might endanger safety, health, and welfare of which you become aware.

• Not interfere with or misuse any appliance or protective clothing or convenience provided for securing safety, health, and welfare

• Be aware of the person responsible for safety, health, and welfare on the premises.

• The organisation has provided and will continue to maintain work areas and facilities which are safe, clean, and healthy All employees, however, have a duty through proper use of work areas and facilities, including toilets, kitchens etc. to keep the workplace in a safe, clean, and healthy condition for the continued benefit of themselves and their fellow employees

• Employees must inform their manager immediately of any injury no matter how minor An accident report must be completed jointly by the employee and their manager and returned to the safety representative within 24 hours. Employees are also obliged to inform their manager of any hazard or incident (whether it be a machine or dangerous behaviour on the part of an individual(s)) which may affect their own health and safety or that of any other person. The manager must follow up on that information with a view to preventing any similar incidents in the future.

• If employees are in any doubt about any actions to be taken in relation to safety, they must consult their manager immediately as failure or delay in doing so could result in injury to themselves or others.

• Where an employee wilfully or knowingly disregards his/her duty in relation to an individual’s health and safety, he/she may be subject to disciplinary action, up to and including dismissal.

5.4 Safety Committee

The company provides a consultation mechanism, in the shape of the Safety Committee, to communicate with employees concerning health and safety at work to ensure they are fully informed and involved in the company's safety procedures.

The Safety Committee is comprised of employees selected on a volunteer basis. The Safety Committee will meet regularly. If employees wish to sit on the Safety Committee, they should communicate this to their manager.

Appropriate safety training will be provided to all Safety Committee members to enable them to conduct their duties, as appropriate.

The Safety Committee will have the authority to:

• Request advice on matters of accident prevention and fire safety

• Carry out regular audits using the audit forms provided

• Represent the workplace when meeting with officers from the Health and Safety Authority (HSA)

Safety Officer

The Safety Officer will,

• Be aware of his/her duties and responsibilities required by legislation and will endeavour to ensure correct use of work area and equipment.

• Inspect the place of work after giving reasonable notice to the management or immediately in the event of an accident, dangerous occurrence, or imminent danger

• Investigate complaints relating to health and safety after giving reasonable notice to management.

• Endeavour to ensure that all repair and maintenance work is completed to standards meeting legal requirements and that all defects are attended to promptly

• Ensure that all accident report forms are completed and followed up as appropriate

• Accompany the HSA on all inspections of premises and ensure that their recommendations are carried out.

• Provide information on health and safety matters and make representations to the management on such matters

• Ensure that the Safety Statement is read and understood by all employees and appropriate third parties.

• Act as an advisor and carry out spot checks on all departments from time to time

• Update hazard identification and risk reduction statements as required.

5.5 Fire prevention and Evacuation

The following rules help to minimise the risk of fire:

• All electrical appliances should be switched off when not in use

• Electrical leads should be renewed at the first sign of wear in the outer covering

• Electrical points should not be overloaded

• All doors should be kept closed

• The use of portable heaters is discouraged

All staff will be familiarised with the fire instructions and the evacuation procedures. All corridors, stairs and all other routes of fire exits should be kept completely clear of obstructions along with the exits themselves

Evacuation Procedures

All employees must be fully knowledgeable about the following procedures as they may save your life or somebody else’s in the event of an emergency

In the event of a fire or the fire alarm going off:

• Inform the Fire Brigade. This should ideally be done by a Fire Officer, but in their absence the most senior person present

• If possible close all doors and windows to prevent fire from spreading.

• Leave the building immediately using the nearest fire exit Leave the building by the stairs

• Do not delay or return to collect your personal belongings

• Walk – don’t run, by the appointed route to the assembly area

• Form groups according to Department, to ensure that any missing personnel can be quickly identified.

• It is the responsibility of the Department Manager and/or Fire Marshals to ensure that all roll call lists are kept up to date. In the event of an evacuation, it is the responsibility of each Department Head to identify to the Fire Marshal any missing employees, contractors, or visitors

• Each Department Manager will have a deputy to cover this role in his/her absence

• Never re-enter the building no matter how tempting. Wait for all clear from the Fire Safety Officer / Brigade before re-entering building.

If you are adjacent to the fire and it is minor enough to use a fire extinguisher, then choose the nearest and most appropriate fire extinguisher to put out the fire.

Never Attempt to tackle a fire that puts you at risk

Make sure you know:

• What the fire alarm sounds like

• The nearest Break Glass alarm unit

• Your Fire Safety Officer

• The appointed route and location of the assembly area

• Layout of the building

• The nearest fire extinguisher - read the instructions and learn the colour coding

• Your assembly points

If you don’t know the answers to any of the above, then you should find out immediately in the interest of your own and other people’ s safety.

Fire Officer

The Fire Officer will have responsibility for the co-ordination of any emergency evacuation.

The Fire Officer will consult with and inform Fire Marshals and employees on evacuation procedures in the organisation. Fire Officers will also be source of information regarding health and safety.

It will be the Fire Officer’s responsibility with the Safety Officer to devise, execute and regularly practice evacuation procedures by way of fire drills and to ensure that all employees receive regular training in this area.

The Fire Officer will also carry out fire inspections of the premises and regular inspections of the fire protection systems.

The Fire Officer will liaise with the emergency services and will give instructions for re-entering the building. The Fire Officer will have a deputy to act in his/her absence

Fire Warden

A Fire Warden is an employee who is responsible for:

• Evacuation of other employees in the areas for which they are responsible in any emergency

• Consultation with the Fire Officer concerning all emergency issues

• Communicatingany changes in evacuation procedures to employees

Fire Wardens will also ensure that in the area for which they are responsible, equipment, articles, substances, or work methods that could lead to a fire or another emergency, are always stored correctly and never left unattended

Fire Wardens will also be a source of information should an employee have any question concerning emergency procedures

Fire Warden Procedure

On hearing the alarm, encourage all employees in your surrounding area to move quickly and calmly to the nearest exit.

Checkyour surrounding areas for remaining employees and then leave the building immediately

All Fire Wardens must be trained in the use of fire extinguishers. Do not tackle a fire that is not in your control. Employee safety is of paramount importance.

Fire Wardens, once outside the building, should report to the Fire Officer and await further instruction.

Environmental and EPA Information

We take our Environmental responsibilities very seriously. Information on our emergency procedure and EPA is available from the Head of Operations or the Technical team.

5.6 Accidents, Hazards and Risks

The most common forms of accidents in any office are falls and trips Employees should always be careful to look out for potential hazards In the case of any potential hazards being noticed by an employee, you must report it immediately.

Managers are responsible for taking action to eliminate or reduce the exposure All injuries and accidents at work must be reported to your manager and the relevant documentation completed

Accidents are rarely found in areas where good housekeeping is practiced. You will help to prevent injury and make your work environmenta more pleasantone by keeping it clean and tidy

Accidents and First Aid

All employees should be aware of the location of the First Aid box. If an injury occurs to yourself or to another employee you should be aware of whom to go to, to get First Aid, and you should also report the incident. If the employee is unable to go to the First Aid Officer, then a colleague should locate a member of the first aid-team and bring him/her to the scene.

All members of the First Aid team will be trained by a recognised body for 24 hours, with a written exam at the end. The names of the First Aid Officers will be placed on the notice board Minor accidents will be treated by the First Aid Officer. Major accidents will be sent for further treatment on the advice of the First Aid Officer.

A witness to an injury should not attempt to move any employee unless it is to remove him or her from immediate danger.

All employees are required to complete a written account of any incident or accident they have witnessed or experienced on the accident report form and return it to the Safety Officer forsigning and filing.

The HR Department will, when necessary, fill out the correct forms to notify the HSA of accidents and dangerous occurrences. The HR Department will keep a copy of all these forms and also the written accounts of the accidents and incidents for 10 years.

Electrical Hazards and Risks

Common electrical faults or hazards to watch out for include the following:

• Loose connections

• Defective installation

• Unearthed equipment

• Overloaded circuits

• Trailing leads

• Worn or damaged appliances

• Damaged cables

• Broken switches

• Damp or wet electrical appliances

• Incorrect light bulb used in lighting appliance

Never open or interfere with electrics in a machine. The proper course of action where a breakdown occurs is to report the matter so that a competent electrician can deal with it. All electrical faults should be reported to your manager and vigilance is required in relation to communal equipment such as photocopiers, faxes and computers Defective equipment should be disconnecteduntil it has been properly repaired by a competentprofessional While a defective machine is awaiting such repair, it should have a warning sign attached to it, and staff in the immediate vicinity told that the machine is out of bounds and should not be used

Manual Handling

It is essential that all new employees who will be required to lift goods attend Manual Handling Training as part of their induction process Lifting correctly is one of the many activities we need to do properly if we are to avoid back problems later in life. There are eight steps to safe lifting:

• Assess the area and size up the load – ask for assistance if necessary

• Keep feet parted to ensure you have a broad stable base

• Bend your knees to reach or lower the load.

• Grip the object with the palms of the hands and support underneath and at the side, as far as possible

• Lift using leg muscle, keeping the back straight (but not necessarily erect)

• Keep the load close to the body (the heaviest part of an unevenly weighted object should be closest to the body and/or the ground)

• Keep elbows and chin tucked in

• Use body momentum

Due to the nature of the manufacturing industry, there is always a potential for slipping hazards

• Appropriate footwear is to be worn at all times

• Ensure that floors are kept dry and free from debris

• Observe good housekeeping practices – clean floors immediately, ensuring that wet floor signs are always used.

**These rules apply whether the object is heavy or light**

Furniture and Cabinets

The use of filing cabinets should be considered carefully to ensure that drawers are not fully loaded, and the heavier load should preferably be put in the lower drawers. In addition, one drawer at a time should be in use and when use of this has been completed it should then be closed Care should always be taken of metal objects on furniture especially objects with sharp edges.

5.7 Smoking & Vaping

Smoking in the workplace is prohibited by the Public Health (Tobacco) Act 2002 - 2015(as amended) and it is an offence to smoke in an enclosed workplace.

It is our policy that the workplace is smoke & vape -free and that all team members have a right to work in a smoke-free environment. Smoking & vaping is prohibited in Company vehicles and in the workplace, except in designated smoking areas. No smoking is allowed at the front of any Company premises. This policy applies to all team members, suppliers, customers, contractors, and visitors.

As employers we are aware of our common law and statutory duties to protect the health and safety of our team members. Unfortunately, there is no conclusive medical opinion on the safety of ecigarettes and as such we are concerned that such devices could upset other team members or customers particularly if they are pregnant, trying to give up smoking or are concerned about the vapour from e-cigarettes.

You are permitted to smoke and vape only in designated areas during breaks or meal breaks. Extinguished cigarettes and other tobacco waste must be disposed of properly in the receptacles provided.

Infringement of this policy by team members may be dealt with under our disciplinary procedures and sanctions may be imposed up to and including a final written warning or dismissal.

5.8 Intoxicants – Alcohol and Drugs in the workplace

Employees generally will be encouraged to seek help or assistance from the organisation’s support service. If an employee is provided with support and they do not accept it, or their performance does not improve, the disciplinary procedure may be invoked.

A controlled substance means any drug not legally obtainable. Legally prescribed and over- thecounter drugs become controlled substances when they have not been prescribed for medical treatment by an accredited physician, or they are not used for the purpose for which they were intended, or when excessive doses are taken.

5.9 Visitors

All visitors must sign the Visitors book in the reception area and be made aware of all necessary safety procedures associated with being on the premises.

Visitors must wear a security badge provided to them at all times. For their safety, visitors should be accompanied by a member of staff at all times. Visitors going through the plant are required to wear a high-vis vest Employees are not permitted to show visitors around the premises without the prior consent of their manager.

5.10 Safe driving policy and use of company cars

Company Cars

Employees who have a company car or for whom driving is an essential requirement of their job, will be issued with a copy of the GPG Vehicle policy. Please refer to your manager or the Human Resource Director if you require further information. Employees who come under this category must be aware that the receipt of penalty points or the loss of their driving licence may result in the termination of their employment with the company. Drivers are personally responsible for settling, at their own expense, any fines imposed for parking or other offences. You are required by the company to abide by the details of this policy whilst driving on company business. For your personal safety, these rules should also be followed whilst driving outside of work hours and on personal business. Failure to adhere to the driving policy may result in disciplinary action.

Where a driving licence is a requirement of the post (as per your contract of employment), loss of your licence may lead to termination of your employment.

Use of Company Cars

The company requires that all employees must agree to the conditions below prior to using their own vehicle for driving on company business The company accepts no liability or responsibility for any accidents or incidents in which an employee is involved while travelling on company business

When required to use your vehicle for company business, you are personally responsible to ensure that:

• Your vehicle is fully insured, including use for such business purposes

• You have an up-to-date Tax and Vehicle Test Certificates as per legal requirements

• Your car has been fully maintained and is in roadworthy condition

• Your vehicle is not overloaded with materials

• You follow the Rules of the Road, driving regulations and speed limits at all times

• You have a driver’s licence which legally permits you to drive, and you do not exceed the maximum number of penalty points (currently 12)

• You follow the company regulations with regard to working hours and rest breaks.

When travelling significant distances, or over a number of days, maximum use must be made of public transport, wherever feasible, in order to reduce tiredness and stress associated with driving long distances.

Mobile Phones

In accordance with safe driving practice and Government regulations, mobile telephones are not to be held on person or used while driving. You are personally responsible to ensure that:

You do not have your mobile phone switched on whilst driving, unless placed in a fixed incar hands free set or phone is switched to Bluetooth. Mobile phones that are not in a fixed in-car hands free kit, or switched to Bluetooth, should either be switched off, or have all calls diverted to voicemail or the office.

You do not carry a mobile phone on your person whilst driving, unless it is switched off.

5.11 Right of Search

The company reserves the right to search an employee and/or their belongings upon entering or leaving the workplace. The company also reserves the right to inspect lockers, desks, offices and the contents of bags, cases or parcels being taken by you off the premises.

An employee who refuses to co-operate fully with any search request may be subject to disciplinary action. An employee who is found to be in possession of any property belonging to the company or to any other party other than the employee being searched is liable to serious disciplinary action up to and including dismissal, following a full investigation. An employee is entitled to have a witness in attendance during any search. If you witness shoplifting/ stealing by another staff member, you must immediately report the occurrence to your direct manager.

GPG employees whose workplace is within another company’s premises are subject to that company’s security and search policies.

5.12 CCTV

The Company recognises the right of an individual to privacy and in particular to the rights of individuals set out in the Data Protection Acts 1998-2008. However, for the safety and security of team members and customers, and to protect and secure the business from trespass, pilferage

and theft, Closed Circuit Television (CCTV) cameras operate on the Company’s premises. CCTV may also be used to ensure Health, Safety and Security of our team members and to assist in maintaining a safe working environment. The Company adheres to the legal standards for the use of CCTV in line with the Data Protection Acts (as may be amended from time to time).

Purpose of CCTV

CCTV cameras will be in operation for the purposes of supervision of Health and Safety compliance, wellbeing, and security, and where necessary, for the purpose of evidence in a disciplinary procedure.

There are a number of CCTV cameras located both externally and internally within General Paint Group’s premises The CCTV systems operated are for the safety and security of our staff, buildings, information and property located or stored on the premises and assets.

Legislation

Data retained by CCTV footage will only be retained for a period of approx. 30 days depending on the department/branch in question and the purpose of the data retention is to review footage from time to time in the interests of security, ofhealth and safetyand in theinterest of appropriate performance management of team members where necessary.

The data obtained through CCTV monitoring will not be disclosed in any manner incompatible with the purpose of supervision and health and safety compliance, save and except where required by law. All CCTV footage will be kept safe and secure under lock and key monitored by an appointed security company

CCTV footage may, where necessary, be used in the context of a disciplinary procedure. In such circumstances, copies of the CCTV footage will be shared with the team member in advance of any disciplinary procedure taking place. A team member will be offered an opportunity to comment on the CCTV footage during a disciplinary procedure. However, CCTV footage can only be viewed on GPG premises and not be released if other people are present in the footage. CCTV may be installed or removed at the Company’s discretion.

Access Requests from an Garda Siochana

From time to time and for particular and justified reasons, An Garda Síochána may require copies of CCTV images to be supplied to it. Where those images are within the control of the Company, upon request from An Garda Síochána, those images will be supplied to them.

Receipt of this policy and signature of the agreement of the receipt of the emplmanual, confirms your understanding and agreement to the fact that CCTV cameras will be in operation for the

purposes of supervision of Health and Safety compliance, wellbeing, and security, and where necessary, for the purpose of evidence in a disciplinary procedure.

If you have any queries at any time in relation to this policy, please contact a member of management.

Section 6: Leaving GPG

This section outlines the various leaving options and how they are administered

6.1 Termination Policy

Employment can be terminated for a variety of reasons, as outlined in the following procedures:

• Dismissal

• Retirement

• Redundancy

• Resignation

Dismissal

An employee’s employment will be terminated in any of the following circumstances:

• The employee’s contract is for a fixed term or purpose and the term has ended or the purpose for which the contract was created has been achieved or ceased to exist.

• The employee is dismissed for reasons of redundancy.

• The employee is dismissed as a result of a disciplinary offence.

Statutory Minimum Notice

If the Company terminates employment for any reason other than a summary dismissal the employee will be given the following statutory minimum periods of notice. If appropriate, employees will be given payment in lieu of notice.

Payment in lieu of Holidays

All employees who are due holidays when their employment is terminated will receive payment in lieu of holidays.

Outstanding Payments

When there are outstanding loans, holidays owing or wages have been overpaid on termination of employment, the amount owning may be deducted from the amount owed to the employee or vice versa.

References

References will be provided on request.

6.2 Retirement Policy

GPG values employees of all ages and is committed to supporting and encouraging a culture that does not tolerate discrimination on any ground.

We want to ensure that all employees of General Paints Group in particular those who are approaching retirement, are advised of company policy in relation to managing their final year of employment.

Retirement Age

The company contractual retirement age is when the employee reaches their 66th birthday.

Procedure

Human resources will communicate with employees within 9 months of their contractual retirement date with a view to discussing matters such as the following to assist with the transition to retirement:

• the date on which the employee will retire

• succession planning arrangements

• Retirement Course

• any other necessary arrangements

HR will also engage with the employee in order to finalise any outstanding annual leave accrued or other issues outstanding. Where applicable, arrangements for the return of GPG equipment will also be finalised.

The process for the handover of duties to a work colleague will also be discussed and finalised at this time. Employees are required to co-operate with any GPG requests regarding the transfer of duties linked to succession planning arrangements

Request to work beyond the company retirement age

Not less than 3 months before the contractual retirement date, an employee may request, in writing, an extension to the retirement date indicated. Applications will be considered on an individual basis and in line with business needs. In the event an extension is approved, the duration and any terms and conditions of the extension will be specified in any such agreement, as will the legal basis underpinning the extension provided.

Whether a contract is issued as a result of this request will be considered on an individual caseby-case basis having regard to the expressed wishes of the employee and having taken into account the specific requirements of the business at that time.

The granting of a request for an extension beyond the contractual retirement age does not indicate a universal policy of GPG nor does it affect the mandatory retirement age of GPG which is when a, employee has their 66th birthday.

Should a decision be made to refuse the request of the employee to work beyond the contractual retirement age, the grounds for this decision will be communicated to the employee.

Appeal process

An appeal in relation to a decision not to grant a request to work beyond the contractual retirement age can be appealed through GPG’s grievance procedures which can be found in our employee handbook

An employee may be accompanied by a work colleague to any meeting at which the GPG reserves the right to review this policy from time to time, taking into account the practical impact of the policy in the workplace, developments in relevant legislation and case law and the business needs of GPG.

6.3 Redundancy Policy

In the event a role becomes redundant we will ensure that employees impacted by redundancy are treated in a fair, consistent and sensitive manner.

This policy will apply to any employee who has in excess of two years’ service with GPG and whose role no longer exists wholly or mainly due to:

• the fact that the employer has ceased, or intends to cease, to carry on the business for the purposes of which the employee was employed, or has ceased or intends to cease, to carry out that business in the place where the employee was so employed, and/or

• the fact that the requirements of that business for employees to carry out work of a particular kind in the place where he was so employed have ceased or diminished or are expected to cease or diminish, and/or

• The fact that his employer has decided to carry on the business with fewer or no employees, whether by requiring the work for which the employee had been employed (or had been doing before his dismissal) to be done by other employees or otherwise, and/or

• the fact that the employer has decided that the work for which the employee had been employed (or had been doing before his/her dismissal) should henceforward be done in a different manner for which the employee is not sufficiently qualified or trained, and/or

• the fact that the employer has decided that the work for which the employee had been employed (or had been doing before his/her dismissal) should henceforward be done by a person who is also capable of doing other work for which the employee isnot sufficiently qualified or trained.

Responsibility

The HR Department are responsible for fair and equitable treatment for all employees during a redundancy process and adherence to procedure as laid out under the Redundancy Payments Act 1967 - 2014

Policy

GPG recognise that redundancy is a sensitive matter that can have far reaching consequences for those involved. In the even that a redundancy is necessary, GPG will ensure that:

All staff who are affected are given fair and equitable treatment

• Wherever practicable redundancies will be avoided through alternative means

• So far as possible changes are affected with the understanding and agreement of staff involved.

Procedure

In the event of redundancy the company is not bound to the policy of “last in, first out”. GPG are committed to ensuring redundancies will be dealt with in a consistent, open and transparent manner in accordance with legislative provisions and with due regard to the rights of those involved.

6.4 Resignation

Should an employee wish to resign, they must confirm in writing to their manager and HR, detailing their expected last day of work. On receipt by HR , acceptance will be confirmed in writing. An employees contact of employment will specify the amount of notice that an employee is required to give.

6.5 Exit Interviews

GPG wishes to ensure that as an employer, we are providing policies, procedures and work practices that promote a positive environment and enable employees to carry out their duties effectively.

Feedback on the relevancy of such policies, procedures and work practices ensure that they are being implemented correctly and are sufficient for the company. It is therefore company practice to conduct an exit interview with each employee, prior to their termination of employment date.

The Human Resources department will conduct this interview at a time, agreeable to both parties, during the employee’s final working week. During this confidential interview the employee will be asked some questions based on their experiences with the company. The employee will be required to complete the company’s confidential Exit Interview Form during the interview, which will be dated and signed, by both the employee and the HR department.

Section 7: General GPG Policies

7.1 Whistleblowing

GPG encourages, and supports, accountability andtransparency, and we encourage all employees to voice concerns internally in a responsible and effective way when they discover information which causes them serious concern. Consultation, integrity, and transparency goes to the heart of our culture and avoids an individual having to resolve a difficult ethical situation alone.

Purpose & Scope

This Policy applies to all of those working on our behalf in whatever capacity, be they directly employed or otherwise. Any changes to the prevailing legislation in respect of whistle blowing will automatically apply.

This aim if this policy is to:

• encourage you to feel confident and safe in raising concerns and disclosing information

• provide avenues for you to raise concerns in confidence and receive feedback on any action taken

• ensure that you receive a response where possible to your concerns and information disclosed

• reassure you that you will be protected from penalisation or any threat of penalisation.

It is important to note that should you have a concern in relation to your own employment or personal circumstances in the workplace it should be dealt with by way of our Grievance Procedure. Likewise concerns arising in regard to workplace relationships should generally be dealt with through our Anti Bullying and Harassment policy.

It is also important to note that this policy does not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be complied with fully.

Responsibility

Employees

Will ensure that they raise serious concerns about any aspects of work and/or practices which affect the integrity of GPG and/or the safety of employees or the public.

Managers

• Will ensure that their team members are aware of and follow approved GPG procedures (e.g. financial, security, health, and safety etc.).

• Will advise of any Whistleblowing cases brought to their attention immediately with their Head of Function and the HR Director

• Will respond to Whistleblowing submissions positively within the timescales set out within this policy.

HR Director

• Will take overall responsibility for overseeing the appropriate application and ensure adherence to the requirements of the Whistleblowing policy and procedures

• Will maintain a record of all Whistleblowing allegations

• Will provide proactive support and advice to managers as required

• Will ensure that this policy is subject to formal review on a regular basis.

Policy

We are committed to maintaining an open culture, with the highest standards of honesty and accountability, where our workers can report any concerns in confidence.

Whistleblowing occurs when a worker raises a concern or discloses information which relates to wrongdoing, illegal practices or unethical conduct which has come to his/her attention through work.

Our whistle-blowing policy is intended to encourage and enable employees to raise concerns within ourworkplace rather than overlooking aproblem or “blowing thewhistle” externally. Under this Policy a worker is entitled to raise concerns or disclose information without fear of penalisation or threat of less favourable treatment, discrimination, or disadvantage.

A concern or disclosure should relate to a relevant wrongdoing such as possible fraud, crime, danger, or failure to comply with any legal obligation which has come to your attention in connection with your employment and about which you have a reasonable belief of wrongdoing.

A personal concern, for example a grievance around your own contract of employment would not be regarded as a whistleblowing concern and would be more appropriately processed through our Grievance Procedure.

Safeguards & Penalisation

Any employee who makes a disclosure, and has a reasonable belief of wrongdoing, will not be penalised by GPG, even if the concerns or disclosure turn out to be unfounded.

Penalisation includes suspension/dismissal, disciplinary action, demotion, discrimination, threats or other unfavourable treatment arising from raising a concern or making a disclosure on the basis of reasonable belief for doing so. If you believe that you are being subjected to penalisation as a result of making a disclosure under this procedure, you should inform your line manager/senior manager immediately.

Employees who penalise or retaliate against those who have raised concerns under this policy will be subject to disciplinary action.

Employees are not expected to prove the truth of an allegation. However, they must have a reasonable belief that there are grounds for their concern. It should be noted that appropriate disciplinary action may be taken against any worker who is found to have raised a concern or raised a disclosure with malicious intent.

Confidentiality

GPG are committed to protecting the identity of the colleague raising a concern and will ensure, as far as possible, that relevant disclosures are treated in confidence. The focus will be on the wrongdoing rather than the person making the disclosure.

However, there are circumstances, as outlined in the Protected Disclosures Act 2014, where confidentiality cannot be maintained particularly in a situation where the worker is participating in an investigation into the matter being disclosed. Should such a situation arise, we will make every effort to inform the worker that their identity may be disclosed.

Procedure

A concern may be raised anonymously. However, on a practical level it may be difficult to investigate such a concern. We would encourage employees to put their names to allegations, with our assurance of confidentiality where possible, in order to facilitate appropriate follow-up. This will make it easier for us to assess the disclosure and take appropriate action including an investigation if necessary.

How to raise a concern

As a first step, appropriate concerns should be raised with your line manager or their Head of Function. However, should you not wish to use this route, for example given the seriousness and sensitivity of the issues involved, you should approach a member of the Leadership Team or the HR Director.

Concerns may be raised verbally or in writing. Should you raise a concern verbally we will keep a written record of our conversation and provide you with a copy after our meeting. Should you raise a concern in writing we would ask you to give the background and history of the concern, giving relevant details, insofar as is possible, such as dates, sequence of events and description of circumstances.

The earlier you express the concern the easier it will be for us to deal with the matter quickly. Having raised your concern with us, we will arrange a meeting to discuss the matter with you on a strictly confidential basis. We will need to clarify at this point if the concern is appropriate to this procedure or is a matter more appropriate to our other procedures, for example our Grievance or Anti Bullying and Harassment procedures. You can choose whether or not you want to be accompanied by a colleague. In regard to confidentiality, it is important that there should be an awareness of respecting sensitive company information, which, while unrelated to the disclosure, may be disclosed in the course of a consultation or investigation process.

How we will deal with your disclosure

Having met with you in regard to your concern and clarified that the matter is in fact appropriate to this procedure, we will carry out an initial assessment to examine what actions we need to take to deal with the matter. This may involve simply clarifying certain matters, clearing up misunderstandings or resolving the matter by agreed action without the need for an investigation.

If, on foot of the initial assessment, we conclude that there are grounds for concern that cannot be dealt with at this point, we will conduct an investigation which will be carried out fairly and objectively. The form and scope of the investigation will depend on the subject matter of the disclosure.

Disclosures may, in the light of the seriousness of the matters raised, be referred immediately to the appropriate authorities. Likewise, if urgent action is required (for example to remove a health and safety hazard), this action will be taken.

It is important to us that you feel assured that a disclosure made by you under this policy is taken seriously and that you are kept informed of steps being taken by us in response your disclosure. In this regard we undertake to communicate with you as follows:

We will:

• acknowledge receipt of your disclosure and arrange to meet with you as outlined above

• inform you of how we propose to investigate the matter andkeepyou informed of actions, where possible, in that regard including the outcome of any investigation, and should it be the case, why no further investigation will take place. However, it is important to note that sometimes the need for confidentiality and legal considerations may prevent us from giving you specific details of an investigation.

• inform you of the likely time scales in regard to each of the steps being taken but, in any event, we commit to dealing with the matter as quickly as practicable.

It is possible that in the course of an investigation you may be asked to clarify certain matters. To maximise confidentiality such a meeting can take place off site, and you can choose whether or not to be accompanied by a willing work colleague.

Where a concern is raised or a disclosure is made in accordance with this policy, but the allegation is subsequently not upheld by an investigation, no action will be taken against the worker making the disclosure and the worker will be protected against any penalisation. It is important to note that if an unfounded allegation is found to have been with malicious intent, then disciplinary action may be taken.

How the matter can be taken further

The aim of this Policy is to provide an avenue within this workplace to deal with concerns or disclosures in regard to wrongdoing. We are confident that issues can be dealt with “in house” and we strongly encourage workers to report such concerns internally.

We acknowledge that there may be circumstances where an employee wants to make a disclosure externally, and the legislation governing disclosures The Protected Disclosures Act 2014 provides for a number of avenues in this regard.

It is important to note however that while you need only have a reasonable belief as to wrongdoing to make a disclosure internally, if you are considering an external disclosure, different and potentially more onerous obligations apply depending on to whom the disclosure is made

7.2 Fraud Policy

Purpose and Scope

GPG is and wishes to be seen by all as being honest and opposed to fraud in the way it conducts its business. The company’s fraud policy addresses the responsibility of employees for the detection and reporting of fraud or suspected fraud. This policy is limited to financial and assetrelated fraud within the company.

For the purposes of this policy, an employee refersto a staff memberwho receives remuneration, either full or part-time from the company. The term also includes any volunteer or contractors who provided services to the company through an official arrangement with the company.

Responsibility

This policy is the responsibility of the Managing Director and the Head of Finance.

Policy

It is the policy of the Company to identify and promptly investigate any possibility of fraudulent or related dishonest activities against the company and, when appropriate, to pursue legal remedies available under the law. The company aims to promote a culture which encourages the prevention offraud by raising awareness of theneed for high standardsof personal conduct.

Any act of fraud ascertained upon investigation, or pursuant to a criminal conviction, or through written or oral acknowledgment by the employee(s) concerned, shall result in the appropriate disciplinary and legal actions against the employee(s) and/or entities, to include the possibility of termination of employment, restitution and/or forwarding information to the appropriate authorities for criminal prosecution. The repayment of losses will be sought in all cases and the company would normally expect to recover all costs in addition to the recovery of losses.

Definitions

Fraud shall include but not be limited to:

• Theft or misappropriation of company assets

• Submitting false claims for payments or reimbursement

• Accepting or offering a bribe or accepting gifts or other favours under circumstances that

• might lead to the inference that the gift or favour was intended to influence an employee's decision-making while serving the company

• Accepting a commission from or paying same to a third party in a personal capacity

• Black-mail or extortion

• Off Books' accounting or making false or fictitious entries

• Knowingly creating and/or distributing false or misleading financial reports

• Paying of excessive prices or fees where justification thereof is not documented

• Violation of the company's procedures with the aim of personal gain or to the detriment of the company.

• Wilful negligence intended to cause damage to the material interest of the company

• A dishonourable or irresponsible or deliberate act against the interests of the company

Reporting Fraud

It is the responsibility of all staff to report any suspicions of fraud without delay according to the procedure laid out below. Persons, who cover up, obstruct, fail to report, or monitor a fraud that they become aware of, or ought to have been aware of, will be considered to be an accessory after the fact and may be subject to disciplinary action and/or discharge. Persons who threaten retaliation against a person reporting a suspected fraud shall be subject to disciplinary action up to and including termination of employment.

Great care must be taken in dealing with suspected dishonest or fraudulent activities to avoid:

• Incorrect accusations

• Alerting suspected individuals to an investigation underway

• Treating employees unfairly

• Making statements that could lead to claims of false accusations or other charges.

In the case of all employees and management, the incident, facts, suspicions or allegations should not be discussed with anyone inside or outside the company, unless specifically directed to do so by the Director investigating the incident. In particular, the matter should not be discussed with the individual suspected of fraud.

Fraud can be detected at any level within the company and the following general principles should apply in the reporting of suspected fraud:

• A person who suspects that fraudulent practice may be operating should, in the first instance, report the matter to their direct superior immediately.

• Should it be inappropriate to make such a report to an immediate superior, the report should be made to that person's manager

• Once a report of suspected fraud is made to supervisor/manager that person should report the suspicion to the Managing Director.

• No investigation of the suspected fraud should take place until the Managing Director has been informed.

References for Employees Disciplining or Prosecuted for Fraud

Where there is a request for a reference for a member of staff who has been disciplined or prosecuted for fraud or a dishonest activity, the Human Resource department shall prepare any reply to a request for a reference having regard to company policies and employment law.

7.3 Confidential Data Protection Policy

Overview

Confidential data is typically the data that holds the most value to a company. Often, confidential data is valuable to others as well, and thus can carry greater risk than general company data. Other areas for consideration are regulatory requirement as well as Privacy concerns and Personal Identifiable Information as laid down by the EU General Data Protection Regulation of 2016. For these reasons, it is good practice to dictate security standards that relate specifically to confidential and private data.

Purpose and Scope

The purpose of this policy is to detail how confidential data, should be handled. This policy lays out standards for the use of confidential data and outlines specific security controls to protect this data.

The scope of this policy covers all company-confidential data, regardless of location. Also covered by the policy are hardcopies of company data, such as printouts, faxes, notes, etc. particular consideration should be given to personal data governed under the EU General Data Protection Regulation.

Responsibility

It will be the responsibility of Managers, Heads of Function, and the HR Department to ensure this policy is adhered to and to address any breaches.

Policy

Treatment of Confidential Data

Forclarity,thefollowingsectionsonstorage,transmission,anddestructionofconfidentialdata are articulated.

Storage

Confidential information must be removed from desks, computer screens, and common areas unless it is currently in use. Confidential information should be stored under lock and key (or key card/keypad), with the key, key card, or code secured.

Transmission

Strong encryption must be used when transmitting confidential data, regardless of whether such transmission takes place inside or outside the company's network. Confidential data must not be left on voicemail systems, either inside or outside the company's network, or otherwise recorded.

Destruction

Confidential data must be destroyed in a manner that makes recovery of the information impossible. The following guidelines apply:

• Paper/documents:(crosscut) shredding is required.

• Storage media (CD's, DVD's): physical destruction is required.

• Hard Drives/Systems/Mobile Storage Media: physical destruction is required. If physical destruction is not possible, then it should be stored in secure area until a decision is made by the Head of Finance.

Use of Confidential Data

A successful confidential data policy is dependent on the users knowing and adhering to the company's standards involving the treatment of confidential data. The following applies to how users must interact with confidential data:

• Users must be advised of any confidential data they have been granted access. Such data must be marked or otherwise designated "confidential."

• Users must only access confidential data to perform his/her job function.

• Users must not seek personal benefit, or assist others in seeking personal benefit, from the use of confidential information.

• Users must protect any confidential information to which they have been granted access and not reveal, release, share, email unencrypted, exhibit, display, distribute, or discuss the information unless necessary to do his or her job or the action is approved by his or her supervisor.

• Users must report any suspected misuse or unauthorized disclosure of confidential information immediately to his or her supervisor.

• If confidential information is shared with a third party, the company must indicate to the third party how the data should be used, secured, and, destroyed. A Processor Contract must be in place to govern the processing activity.

Security Controls for Confidential Data

Confidential data requires additional security controls in order to ensure its integrity. GPG has gone to great lengths to ensure that at least an adequate level of Security and Data Protection Technology has been implemented a summary of which is currently in place includes:

• High Availability pair of Managed Firewalls

• Full Datto DR solution for server back-up and DR

• Intune for Mobile Device Management

• Service Patch Management for Workstations and Server

• Webroot Antivirus for all servers PC and Laptops

• Webroot Secure DNS

• Spam Titan Email Filtering

• Datto SaaS Protection for All Microsoft Office365 Accounts

The rules and guidance on use of these technologies should be adhere to at all times.

As well as the technologies that keep the Data secure you should also adhere to the following guidelines:

• Strong Encryption. Strong encryption should be used when available for confidential data transmitted internal or external to the company. Confidential data should when available be stored in encrypted form, whether such storage occurs on a user machine, server, laptop, or any other device that allows for data storage.

• Network Segmentation. The company must use firewalls, access control lists, or other security controls to separate the confidential data from the rest of the corporate network.

• Authentication. Two-factor authentication must be used for access to confidential data (If such technology is available)

• Physical Security. Systems that contain confidential data, as well as confidential data in hardcopy form, should be stored in secured areas. Special thought should be given to the security of the keys and access controls that secure this data.

• Printing. When printing confidential data, the user should use best efforts to ensure that the information is not viewed by others. Printers that are used for confidential data must be located in secured areas.

• Emailing. Confidential data must not be emailed inside or outside the company without the use of strong encryption if the technology is available.

• File Transfer Protocol FTP. Only approved FTP services should be used when having to send files of any size and any level of confidentiality inside or outside the company, check with your manager for approved vendors

• Mailing. If confidential information is sent outside the company, the user must use a service

• that requires a signature for receipt of that information. When sent inside the company,

confidential data must be transported in sealed security envelopes marked "confidential."

• Discussion. When confidential information is discussed, it should be done in non-public places, and where the discussion cannot be overheard.

• Confidential data must be removed from documents unless its inclusion is absolutely necessary.

• Confidential data must never be stored on non-company-provided machines (i.e., home computers).

• If confidential data is written on a whiteboard or other physical presentation tool, the data must be erased after the meeting is concluded

Examples of Confidential Data

The following list is not intended to be exhaustive but provides guidelines on what type of information is typically considered confidential. Confidential data can include:

• Employee or customer social security numbers or personal information

• Medical and healthcare information

• Customer data

• Company financial data (if company is closely held)

• Sales forecasts

• Product and/or service plans, details, and schematics,

• Network diagrams and security configurations

• Communications about corporate legal matters

• Passwords

• Bank account information and routing numbers

• Payroll information

• Credit card information

• Any confidential data held for a third party and explicit processing instruction within a processing contract must be strictly adhered to.

Emergency Access to Data

A procedure for accessing confidential and critical data during an emergency is often a good ideaifthecompany handlesinformationthatisintegraltothehealth,well-being,orprotection of other persons or entities. If the company maintains this type of data, it will consider establishing such a procedure in case the normal mechanism for access to the data becomes unavailable or disabled due to system or network problems.

Applicability of Other Policies

This document is part of the company's set of policies. Other policies may apply to the topics covered in this document and as such the applicable policies should be reviewed as needed.

Enforcement

This policy will be enforced by the Leadership Team. Violations may result in disciplinary action, which may include suspension, restrictionof access, or more severe penalties up to and including termination of employment. Where illegal activities or theft of company property (physical or intellectual) are suspected, the company may report such activities to the applicable authorities.

7.4 Email and Internet Policy

Email is an essential component of business communication; however, email and internet usage present a particular set of challenges due to its potential to introduce a security threat to the network. Email can also impact GPG’s liability by providing a written record of communications, so having a well thought out policy is essential. This policy outlines expectations for appropriate, safe, and effective email usage.

Purpose and Scope

The purpose of this policy is to detail the company's guidelines for email and internet usage. This policy will help the company reduce risk of a web based or email-related security incident, foster good business communications both internal and external to the company, protect the company’s reputation and our brands, and provide for consistent and professional application of the company's electronic communications principles

The scope of this policy includes the company's email and web system in its entirety, including desktop and/or web-based email applications, server-side applications, email relays, and associated hardware. It covers all electronic mail sent from the system, as well as any external email accounts accessed from the company network and the right to monitor such activity.

This policy applies to all employees of the company, who have access to a company email account or the internet.

Responsibility

The Head of Finance is responsible for this policy.

Policy

Proper Use of Company Email Systems

Users are asked to exercise common sense when sending or receiving email from company accounts. Additionally, the following applies to the proper use of the company email system.

Do not subscribe to electronic services or other contracts on behalf of GPG unless you have the express authority to do so. Authority for subscriptions including electronic subscriptions such as these rests with the Leadership team. Unless you have been delegated authority, you have no permission or authority to enter into any binding commitment on behalf of GPG via e-mail or internet.

Sending Email

When using a company email account, emails must be addressed and sent carefully. Users should keep in mind that the company loses any control of email once it is sent external to the company network. Users must take extreme care when typing in addresses, particularly when email address auto-complete features are enabled; using the "reply all" function; or using distribution lists in order to avoid inadvertent information disclosure to an unintended recipient. Careful use of email will help the company avoid the unintentional disclosure of sensitive or non-public information.

Extra caution needs to be taken with e-mails in respect of any disparaging remarks that may be contained within. An e-mail should be regarded as a written formal letter, the recipients of which may be much wider than the sender intended hence any defamatory or careless remarks can have very serious consequences as can any inappropriate innuendo. Avoid the use of indecent, obscene, sexist, racist or other inappropriate remarks whether in written form, in cartoon form or otherwise.

Documents prepared by GPG for customers may be attached via the e-mail. However, excerpts from reports other than our own if substantial may be in breach of copyright and the author’s consent ought to be obtained particularly were taken out of its original context. Information received from a customer should not be released to another customer without prior consent of the original sender. If in doubt consult the Head of Finance.

Personal Use and General Guidelines

Users are provided with access to GPG emails and internet for business use. We understand that on occasion users may use them for personal use, once this is limited to exceptional circumstances and as long as A) such usage does not negatively impact the corporate computer network and B) such usage does not negatively impact the user's job performance.

• The following is never permitted: spamming, harassment, communicating threats, solicitations, chain letters, or pyramid schemes. This list is not exhaustive but is included to provide a frame of reference for types of activities that are prohibited.

• The user is prohibited from forging email header information or attempting to impersonate

another person.

• Email is an insecure method of communication, and thus information that is considered confidential or proprietary to the company may not be sent via email, regardless of the recipient, without proper encryption if available.

• It is company policy not to open email attachments from unknown senders, or when such attachments are unexpected.

• Email systems were not designed to transfer large files and as such emails should not contain attachments of excessive file size.

Please note that the topics above may be covered in more detail in other sections of this policy.

Business Communications and Email

The company uses email as an important communication medium for business operations. Users of the corporate email system are expected to check and respond to email in a consistent and timely manner during business hours.

Additionally, users are asked to recognise that email sent from a company account reflects on the company, and, as such, email must be used with professionalism and courtesy.

Email Signature

An email signature (contact information appended to the bottom of each outgoing email) is required for all emails sent from the company email system and look like:

John XXXXXX

Head of YYYYYYY

General Paints Group MaynoothRoad, Celbridge, Co Kildare, W23 X7R8

T: + 353 1 6288224

E: john.xxxxxx@generalpaints.ie

W:www.generalpaintsgroup.com

Email signatures may not include personal messages (political, humorous, etc.). Our IT support can assist in email signature setup if necessary.

Auto-Responders

The company recommends the use of an autoresponder if the user will be out of the office for an entire business day or more. The auto-response should notify the recipient that the user is out of the office, the date of the user's return (if determined safe to do so), and who they should contact if immediate assistance is required.

Mass Emailing

The company makes the distinction between the sending of mass emails and the sending of unsolicited email (spam). Mass emails may be useful for both sales and non- sales purposes (such as when communicating with the company's employees or customer base) and is allowed as the situation dictates but maybe restricted by Regulatory requirements, especially in relation to ‘consent’ as laid down by the EU General Data Protection Regulation.

Sending of spam is strictly prohibited.

It is the company's intention to comply with applicable laws governing the sending of mass emails. For this reason, as well as to be consistent with good business practices, the company requires that email sent to multiple recipients external to the company have the following characteristics:

• The email must contain instructions on how to unsubscribe from receiving future emails (a simple "reply to this message with UNSUBSCRIBE in the subject line" will do).

• Unsubscribe requests must be honoured immediately and so have a controlled and recorded process to handle them.

• The email must contain a subject line relevant to the content.

• The email must contain contact information, including the full physical address, of the sender.

• The email must contain no intentionally misleading information (including the email header), blind redirects, or deceptive links.

Note that emails sent to company employees, existing customers, or persons who have already inquired about the company's services may be less restrictive from the above requirements.

Opening Attachments

Users must use care when opening email attachments. Viruses, Trojans, and other malware can be easily delivered as an email attachment. Users should:

• Never open unexpected email attachments.

• Never open email attachments from unknown sources.

• Never click links within email messages unless he or she is certain of the link's safety. It is

• often best to copy and paste the link into your web browser, or retype the URL, as specially formatted emails can hide a malicious URL.

The company may use methods to block what it considers to be dangerous or emails or strip potentially harmful email attachments as it deems necessary.

Monitoring and Privacy

Users should expect no privacy when using the corporate network or company resources. Such use may include but is not limited to the transmission and storage of files, data, and messages. The company reserves the right to monitor any and all use of the computer network. To ensure compliance with company policies this may include the interception and review of any emails, or other messages sent or received, inspection of data stored on personal file directories, hard disks, and removable media.

Company Ownership of Email

Users should be advised that the company owns and maintains all legal rights to its email systems and network, and thus any email passing through these systems is owned by the company and it may be subject to use for purposes not be anticipated by the user. Keep in mind that email may be backed up, otherwise copied, retained, or used for legal, disciplinary, or other reasons. Additionally, the user should be advised that email sent to or from certain public or governmental entities may be considered public record.

Company email sent from personal email accounts may be considered as company email and will be governed by relevant Regulatory Requirements.

Contents of Received Emails

Users must understand that the company has little control over the contents of inbound email, and that this email may contain material that the user finds offensive. If unsolicited email becomes a problem, the company may attempt to reduce the amount of this email that the users receive, however no solution will be 100 percent effective. The best course of action is to not open emails that, in the user's opinion, seem suspicious. If you receive any offensive, unpleasant, harassing, or intimidating messages via, or if you are particularly concerned about an email, or believes that it contains illegal content, inform your manager immediately. It is important that we trace such e-mails as quickly as possible.

Access to Email from Mobile Phones

Many mobile phones or other devices, provide the capability to send and receive email. The company permits users to access the company email system from a company issued mobile phone only. Refer to the Mobile Device Policy for more information.

Email Regulations

Any specific regulations (industry, governmental, legal, etc.) relating to the company’s use or retention of email communications must be listed here or appended to this policy. Particular attention should be given to the EU General Data Protection Regulatory requirements as relevant to your own circumstances.

External and/or Personal Email Accounts

The company recognises that users may have personal email accounts in addition to their company-provided account. The following sections apply to non-company provided email accounts:

Use for Company Business

Users must use the corporate email system for all business-related email. Users are prohibited from sending business email from a non-company-provided email account.

Access from the Company Network

Users are permitted to access external or personal email accounts from the corporate network, if such access uses no more than a trivial amount of the users' time and company resources.

Use for Personal Reasons

Users are required to use a non-company-provided (personal) email account for all nonbusiness communications. The corporate email system is for corporate communications only. Users must follow applicable policies regarding the access of non-company- provided accounts from the company network.

Confidential Data and Email

The following sections relate to confidential data and email:

Passwords

As with any company passwords, passwords used to access email accounts must be kept confidential and used in adherence with the Password Policy. At the discretion of the Head of Finance, the company may further secure email with certificates, two factor authentications, or another security mechanism.

Emailing Confidential Data

Email is an insecure means of communication. Users should think of email as they would a postcard, which, like email, can be intercepted and read on the way to its intended recipient.

The company requires that any email containing confidential information, regardless of whether the recipient is internal or external to the company network, be encrypted using commercialgrade, strong encryption. The ability to encrypt email is provided to each employee by using Microsoft 365 outlook email encryption.

Further guidance on the treatment of confidential information exists in the company's Confidential Data Policy. If information contained in the Confidential Data Policy conflicts with this policy, the Confidential Data Policy will apply.

Company Administration of Email

The company will use its best effort to administer the company's email system in a manner that allows the user to both be productive while working as well as reduce the risk of an email-related security incident.

Filtering of Email

A good way to mitigate risk from email is to filter it before it reaches the user so that the user receives only safe, business-related messages. For this reason, the company will filter email at the Internet gateway and/or the mail server, in an attempt to filter out spam, viruses, or other messages that may be deemed A) contrary to this policy, or B) a potential risk to the company's IT security. No method of email filtering is 100 percent effective, so the user is asked additionally to be cognizant of this policy and use common sense when opening emails.

Additionally, many email, and/or anti-malware programs will identify and quarantine emails that it deems suspicious. This functionality may or may not be used at the discretion of the Head of Finance.

Email Deletion

Users are encouraged to delete email periodically when the email is no longer needed for business purposes. The goal of this policy is to keep the size of the user's email account manageable and reduce the burden on the company to store and backup unnecessary email messages.

However, users are strictly forbidden from deleting email in an attempt to hide a violation of this or another company policy. Further, email must not be deleted when there is an active investigation or litigation where that email may be relevant.

The company must note and document here any applicable regulations or statutes that apply to email deletion. A system may be used to retain ALL email in case of regulatory eDiscovery in the future.

Retention and Backup

Email should be retained and backed up in accordance with the applicable policies, which may include but are not limited to the Confidential Data Policy, Backup Policy, and Retention Policy.

Unless otherwise indicated, for the purposes of backup and retention, email should be considered operational data.

Account Activation

Email accounts will be set up for each user determined to have a business need to send and receive company email. Accounts will be set up at the time a new hire starts with the company, or when a promotion or change in work responsibilities for an existing employee creates the need to send and receive email.

At times, unique email accounts may be given to non-employees, contractors, or other individuals authorised to conduct certain aspects of the company’s business.

Account Termination

When a user leaves the company, or his or her email access is officially terminated for another reason, the company will disable the user's access to the account by password change, disabling the account, or another method. The company is under no obligation to block the account from receiving email and may continue to forward inbound email sent to that account to another user or set up an auto-response to notify the sender that the user is no longer employed by the company.

Storage Limits

As part of the email service, email storage may be provided on company servers or other devices. The email account storage size must be limited to what is reasonable for each employee, at the determination of the Head of Finance. Storage limits may vary by employee or position within the company.

Prohibited Actions

The following actions shall constitute unacceptable use of the corporate email system. This list is not exhaustive but is included to provide a frame of reference for types of activities that are deemed unacceptable. The user may not use the corporate email system to:

• Send any information that is illegal under applicable laws.

• Access another user's email account without

o the knowledge or permission of that user - which should only occur in extreme circumstances,

o the approval of company executives in the case of an investigation,

o when such access constitutes a function of the employee's normal job responsibilities.

• Send any emails that may cause embarrassment, damage to reputation, or other harm to the company.

• Disseminate defamatory, discriminatory, vilifying, sexist, racist, abusive, rude, harassing, annoying, insulting, threatening, obscene or otherwise inappropriate messages or media.

• Send emails that cause disruption to the workplace environment or create a hostile workplace. This includes sending emails that are intentionally inflammatory, or that include information not conducive to a professional working atmosphere.

• Make fraudulent offers for products or services.

• Attempt to impersonate another person or forge an email header.

• Send spam, solicitations, chain letters, or pyramid schemes.

• Knowingly misrepresent the company's capabilities, business practices, warranties, pricing, or policies.

• Conduct non-company-related business.

The company may take steps to report and prosecute violations of this policy, in accordance with company standards and applicable laws.

Data Leakage

Data can leave the network in a number of ways. Often this occurs unintentionally by a user with good intentions. For this reason, email poses a particular challenge to the company's control of its data.

Unauthorised emailing of company data, confidential or otherwise, to external email accounts for the purpose of saving this data external to company systems is prohibited. If a user needs access to information from external systems (such as from home or while traveling), that user should notify his or her supervisor rather than emailing the data to a personal account or otherwise removing it from company systems.

The company may employ data loss prevention techniques to protect against leakage of confidential data at the discretion of the Head of Finance.

Enforcement

This policy will be enforced by the Head of Finance and/or Leadership Team. Violations may result

in disciplinary action, which may include suspension, restriction of access, or more severe penalties up to and including termination of employment. Where illegal activities are suspected, the company may report such activities to the applicable authorities. If any provision of this policy is found to be unenforceable or voided for any reason, such invalidation will not affect any remaining provisions, which will remain in force.

7.5 Social Media at Work

Social media usage for work purposes is controlled by Managing Director, Heads of Function and Managers.

Approval will be grantedby your manager where use is required for an employee’s job role. Social media usage for personal reasons does not need approval by the Company. When using social media, either in a personal or work capacity, during or outside working hours, posts on social media must not:

• compromise the Company, disclose confidential data or disclose sensitive data

• damage the Company’s reputation or brand

• breach copyright or data protection

• contain libel or defamatory content

• engage in bullying or harassment

• be of illegal, sexual or offensive content

• interfere with work commitments

• use the name of the Company to promote products or political opinions.

Employees should ensure they consider the Company’s other policies on marketing, promotion, sales and branding. Social media content attributable to you that breaches the terms of this policy, or the other related policies, may result in an investigation and disciplinary action under the Company’s disciplinary policy.

If an employee is using or has access to company social media sites for work purposes, they must take adequate security measures to protect the passwords for those sites such as the use of twofactor authentication. Two-factor authentication should only be linked to a work mobile or work email address.

Any customer data shared via social media direct messaging is subject to GDPR guidelines and should be treated sensitively.

Social Media and Recruitment

Recruitment processes are increasingly utilising social media as a method of engaging jobseekers. Due to the increasing amount of content posted online, viewing candidate’s social media profiles is a quick and effective way of checking details contained in a CV or getting an idea of the personality of the candidate

Enforcement

All employees should be aware that the organisation regularly monitors the internet and social media in reference to its work and to keep abreast of general internet commentary, brand presence and industry/ customer perceptions. The organisation does not specifically monitor social media sites for employee content on an on-going basis, however employees should not expect privacy in this regard. The organisation reserves the right to utilise for disciplinary purposes any information that could have a negative effect on the organisation or its employees, which management comes across in regular internet monitoring, or is brought to the organisation’s attention by employees, customers, members of the public etc.

Non-compliance with the general principles and conditions of this social media policy and the related internet, email and confidentiality policies may lead to disciplinary action, up to and including dismissal.

7.6 Expenses and Credit Card Policy

Purpose and Scope

To ensure all expenses claimed are within Revenue guidelines and that they are submitted correctly and in a timely manner. This policy applies to employees authorised to incur and claim expenses on the company’s behalf.

Responsibility

The Head of Finance is responsible for overseeing this procedure. Managers are responsible for ensuring expenses are submitted and authorised in line with policy guidelines, and for taking action if required.

Policy

All expenses claimed must be incurred wholly, exclusively and necessarily in the performance of the duties of the employment.

All employees should be made aware of the need for cost control within the company and to this end should not abuse the authority given to them by way of expense claims or company credit

card. If an item is deemed unreasonable then it will not be refunded. Furthermore, the employee (and the manager if the expense has been authorised) will be reprimanded.

Specifically:

• Any fines or parking tickets incurred will not be paid by the company.

• Alcohol expenses should be limited to one or two social drinks – except in the case of customer entertainment which will be judged on an individual basis.

• Lunch allowances should not be claimed where someone else pays for the lunch. It is the employees’ obligation to inform the company should this occur.

• Commercial rates should be asked for in hotels.

• Under no circumstances may company credit cards be used for the purchase or payment of personal items.

This document is not intended to be definitive and any uncertainty regarding whether an expense is claimable or not should be clarified by the accounts dept.

Expenses

Employee expenses are any costs an employee incurs while carrying out their duties and where costs have been approved in advance.

Expenses will only be reimbursed or covered by GPG where:

• Authority has been received in advance to generate expense

• Expense is incurred wholly, exclusively, and necessarily in the performance of their duties

• Vouched receipts are submitted with the claim

Expenses will be paid through payroll.

Claiming Expenses

Where an employee has access to NetSuite, they will claim their own vouched expenses, accompanied by a receipt before the 25th of each Month. See SOP Fin069. Where an employee does not have access to NetSuite, managers are responsible for processing expense claims on behalf of their employee.

Approval of expenses

Managers and Heads of Function are responsible for reviewing and approving employee expenses in NetSuite.

Credit Cards

GPG employees with a company credit card will receive their previous month's bill by the 15th of the month. Each employee is responsible for uploading their corresponding Credit Card receipts into NetSuite before the 25th of the month. Any discrepancies will be discussed with the employee and repaid where necessary through the next payroll.

Subsistence Allowances

Employees are entitled to reasonable meal (breakfast, lunch and dinner) expenses while traveling away from their normal place of work. The following are specific daily expenditure limits and accommodation; any expense outside of these limits will need to be approved in advance by your manager and when expenses are being submitted, supported and explained.

• Breakfast €12/£12

• Lunch €12/£12

• Dinner €25/£25

• Hotel Accommodation €140/£140 Sept – may, up to a maximum of €180/£180 during June, July and August. A commercial rate should always be sought.

Airport Parking

Employees parking at the airport for the purposes of making a flight are required to use the longterm parking facilities regardless of the duration of their journey. The short-term parking facility should only be used when you are required to either collect or drop someone off. Airport car parking expenses will only be reimbursed on this basis.

Private Vehicle used for Company Business

An employee who uses their own personal car for occasional business travel will be reimbursed on a rate per km basis, as per Revenue rates (see table below). Mileage is reimbursed at a fixed rate per km and must be the lesser of home to the business venue or office to the business venue. Your manager will advise you of the current rate, which may vary once the employee goes over 2,000 miles per annum, in line with Revenue approvals. This reimbursement rate encompasses all costs in connection with the operation of the vehicle including repairs, fuel, oil, depreciation, and insurance.

7.7 Staff Paint Account

Purpose and Scope

All permanent employees are entitled to purchase paint, wallpaper and sundries at a discounted rate. No paint, product or sundries can be taken from our stores or the site by an employee without it going through their paint account.

The purpose of this policy is to set out how a staff member may avail of this facility. This policy applies to all GPG employees. Any individual who is not an employee of the company may not avail of this preferential discount.

Responsibility

The Head of Consumer Experience is responsible for this procedure.

Retail Store Managers are responsible for ensuring that paint purchased in their store, is purchased as per policy.

Manufactured Paint

On occasion a processed batch may be unsuitable for sale to our customers or stockists.

• Unsalable paint is sent to ENVA for disposal.

• If it can be recycled it goes back into the manufacturing process.

• Usable paint may be offered to staff to buy at a preferential price.

Returned Paint

During rebranding, discontinuation of ranges, etc. paint can be returned to GPG Returned paint may be given to charities or local organisations at different times during the year by the Community Committee. All paint given out must be recorded.

Shop Mistints

When mistints occur in one of our stores these are recorded in a book, stating when the mistint occurred and who tinted the paint Mistints are then placed on the shop floor for sale at a reduced price.

Policy

At no time can an employee take any product or sundries from the site without it going through their paint account.

All permanent employees are entitled to purchase goods at a preferential price through their Staff Account. Goods purchased through the Staff Paint Account facility must only be for your personal use or that of your immediate family. You may not apply your employee discount to purchases you make for anyone from whom you will be reimbursed.

Purchases through a Paint Account should not exceed €1,500 in any calendar year. Goods purchased through the paint account facility must be paid for within 30 days.

All staff accounts outside terms of 30 days will be placed on hold until back in terms. Furthermore, if debt extends beyond 60 days the outstanding amount will automatically be deducted from the next salary payment.

Procedure

Staff purchasing goods through a paint account must go through the same procedures as any other customer. This is as follows:

• The order is placed with a member of the shop staff,

• Documentation is prepared by the shop staff,

• Documentation is signed by the staff member placing the order prior to taking possession of the order.

• Payment may be made at the time of purchase or paid within 30 days.

Payment of Account

A statement is generated and forwarded on a monthly basis to each staff member who has purchased goods during that month.

Goods purchased through the paint account facility must be paid for within 30 days.

In the case of an employee failing to pay off a paint account debt within this 30 day time frame, their account will be placed on hold until back in terms. If debt extends beyond 60 days the outstanding amount will automatically be deducted from the next salary payment.