GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 July 2012 ws - ®MERLIN MERLIN ENTERTAINMENTS GROUP HEALTH, SAFETY AND SECURITY GROUP STATEMENT OF POLICY AND RESPONSIBILITIES SAFETY - THE MERLIN WAY CONTENT Preface Policy Statement Organisation - Implementation - Accountability - Board - Health, Safety & Security Sub-Committee - Chief Executive Officer - Director Health, Safety & Risk Management - Executive Board - Appointed Person Arrangements - _—_—Heallth, Safety & Security Committee - Senior Management - Site Heads of Department Employees - Responsibilities - Disciplinary Action NOTE: THIS POLICY STATEMENT SHOULD BE READ IN CONJUNCTION WITH HS001/A - ‘HEALTH, SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM’ MEG Statement of Policy & Responsibilities July 2012 1GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 PREFACE This Health, Safety and Security Policy is applicable to all Merlin Entertainments Group sites and shall form the first part of each venue's Health and Safety Manual. It provides a framework for action aimed at ensuring continuous improvement of our health, safety and security performance, together with a genuine commitment to action, It describes the Group’s commitment to the health, safety and welfare of our guests, our employees, contractors and other visitors to our premises and attractions. To be effective, it requires a positive contribution by each and every person, in order to control risk and to improve the impact of what we do on the environment, This will be achieved on each site by all persons contributing to good, sound systems of work and assessment of risk, regular monitoring of these and the keeping of adequate records. Together, these will form a key measure in assessing our overall business success, to keep the Merlin Entertainments Group at the forefront of our industry. Accidents on our sites cause pain, suffering and stress to individuals. Accidents and security incidents also reduce efficiency and are very costly to the business. Safety and security therefore, are integral to everything we do within the Merlin Entertainments Group and freedom from incidents and loss is our ultimate target. The Group is committed to supporting everyone mutually, with the aim of eliminating accidents, incidents and work related ill health. This in tum will contribute to the enhancement of customer and staff satisfaction and improvement in the general culture and success of the business. ‘A W hone Dated: July 2012 NICK VA eg CHIEF EXECUTIYE OFFICER -y & Responsibilities July 2012 2GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 d > 4 *®MERLIN ENTERTAINMENTS GROUP HEALTH, SAFETY AND SECURITY THE MERLIN WAY POLICY STATEMENT. It is the policy of Merlin Entertainments Group, together with its wholly owned subsidiaries (“The Group”), to give the health, safety and welfare of its guests, its employees, contractors and other visitors, priority equal to that of its objectives for commercial success and customer service. For the avoidance of doubt, we will never allow profit considerations to come before identified Health & Safety needs or requirements. Consequently, the Group aims to provide and maintain throughout all its operations, the highest practical health, safety and security standards. This will be achieved through an effective Health, Safety and Environmental Management System, supported by an appropriate organisational structure, the genuine commitment of management and an effective communications framework, in order to maximise the contribution of individuals at all levels. We recognise that there is a need to control risk effectively and to have proactive maintenance procedures and adequate systems of work. The efficiency of such systems and procedures will be reviewed through regular monitoring and will be subject to audit. The aim therefore, is to ensure effective prevention and this is achieved via good safe systems and training, which will also help to avoid financial loss to the business. To this end, both management and employees as a team will aim to make incidents on our sites a thing of the past. A copy of the Group Health Safety and Security Policy, together with the more detailed site information, will be available to everyone. Signed: we aeanrBretn eA VA My, JOHN SUNDERLAND NICK VARNEY CHAIRMAN (CHIEF EXECUTIVE OFFICER MEG Statement of Policy & Responsibilities July 2012 3GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 1 12 ORGANISATION FOR IMPLEMENTING THE HEALTH, SAFETY AND SECURITY POLICY OF THE MERLIN ENTERTAINMENTS GROUP The organisation and arrangements for implementing the Group Health, Safety and Security Policy outlined in this document covers all sites and departments within the control of the Merlin Entertainments Group, irrespective of their location. However, hazards vary from site to site and therefore this document outlines the general philosophy of approach and should be referred to with the more detailed Site Health and Safety Procedures Implementation The Group Health, Safety and Security Policy is to be implemented through the existing Management Structures across the Group. This will ensure that Health, Safety & Security is integral to day-to-day business. Accountability The Board of Merlin Entertainments Group represents the interests of the Shareholders, with regards to monitoring and evaluating the performance of the Operating Group. The Board devolves day-to-day executive operational responsibility to the Chief Executive Officer (CEO) but the Board is ultimately responsible for ensuring that the Group’s Health, Safety and Security Policy is fulfilled on all sites of the Group, by all employees, and has appointed the Health, Safety and Security Sub-Committee to ensure that this happens. Reporting to the CEO is an Executive Board, which manages the business on a day-to-day basis and which has delegated responsibility for Health, Safety and Security within their respective units. Reporting to the Chief Financial Officer (CFO), who reports to the CEO, is the Director of Health, Safety and Risk Management. THE BOARD In that such persons collectively form the Corporate Body, the Board of Merlin Entertainments Group is ultimately responsible, as the Named Persons, for ensuring the effectiveness of the Group's Health, Safety and Security policy. They have appointed the Health, Safety and Security Sub-Committee, on its behalf, to fulfil this role and appoint the CEO to manage these matters on a day-to-day basis. THE HEALTH, SAFETY AND SECURITY SUB-COMMITTEE Has been delegated by the Board to take such decisions necessary to ensure compliance with the content of this Policy, procedures and systems outlined herein and will commit to seeking progressive improvements to the Health, Safety and Environmental Management System. The Committee is chaired by the Chairman and includes, the CEO, the CFO, the Director of Health, Safety & Risk Management, the Managing Director, Resort Theme Parks and others who may be co-opted from time to time. The Chair of the Sub-Committee will report back on status, progress and issues at each Board meeting. MEG Statement of Policy & Responsibilities July 2012 4GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 31 3.2 33 35 3.6 4a 42 The Sub-Committee will sign off the Group Health Safety and Security Policy on behalf of the Board and will review the Policy at least every two years. ‘The Sub-Committee will review the effectiveness of the organisation, arrangements and responsibilities to ensure compliance with the Policy, together with the delivery of an effective health and safety environment. It will agree Terms of Reference, which will include monitoring the performance of the business from the perspective of health, safety and security as well as the frequency of meetings. It will consider all matters referred to it by the Board, the Director of Health, Safety and Risk Management or other Senior Managers of the business and will make recommendations for change or improvement where appropriate. So far as is reasonably practical, they will ensure compliance with the requirements of appropriate legislation and that arrangements are in place to effect any necessary changes, whilst giving due regard to the business needs. They actively support the CEO to carry out his responsibilities and in turn ensure that he keeps them informed of all health and safety related matters that do affect, or could affect the business. In order to measure performance, they shall be provided at each Sub-Committee Meeti via the organisational arrangements described herein, with information relating to, but not limited to: - the number of Reportable injuries and incidents across the business ~ the number of ‘non-reportable’ injuries across the business ~ details of other major incidences and issues which affect a site’s health, safety and security performance CHIEF EXECUTIVE OFFICER (CEO) The CEO, on behalf of the Board, is the person responsible for all day-to-day aspects of health, safety and security within the Group, although for operational reasons, some matters need to be delegated to nominated senior management. Particular responsibility is assigned to the CEO for ensuring that: There is a Group Health, Safety and Security Policy which is reviewed as and when necessary, but at least once in every two year period and that this takes into account best practice, compliance with legislation and the business needs, in order to safeguard the health safety and welfare of all guests, employees and visitors to sites. Alll practical steps are taken to ensure the individual competency of Senior Management Team Members and that an effective organisation structure exists, in order to ensure compliance with the Group's Health Safety and Security Policy and to meet statutory requirements. MEG Statement of Policy & Responsibilities July 2012 5GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 43 44 45 4.6 47 52 54 55 5.6 ‘There are at each site, detailed Site Health and Safety Procedures that clearly state the means by which safe conditions shall be achieved on that site and that the Appointed Person* for that site ensures that these are adhered to, together with the Group Policy. Provisions exist 10 audit the effectiveness of all arrangements and to provide competent independent advice on Health and Safety from a Group perspective, together with separate site arrangements, in order to enhance the Health, Safety and Environmental Management System (HS001/A) Each site produces, on a monthly basis, such information as is requested, in order that health, safety, security and environmental management performance can be measured. The regular Business Reviews will also include relevant information and discussion regarding health, safety, security and environmental management performance. Board members are named individuals and therefore are responsible for all health and safety matters which affect, or could affect the business. Given their responsibilities as part of the Corporate Body, they shall be kept informed by the CEO of all issues that could affect, or are likely to affect, the Group’s overall safety performance. There is included on all Board meeting agendas and in the Group’s Annual Report, a section covering the overall performance of Health and Safety, within the Risk Management Report. DIRECTOR OF HEALTH, SAFETY AND RISK MANAGEMENT Is the person so appointed who is responsible to the CEO, via the CFO, for ensuring that: ‘The CEO is kept informed of all matters that affect, or could affect safety and security and subsequently the business, at every site within the Group. All data is provided as might be requested, in order that performance can be measured and that information is provided for the MEG Board, the Health Safety and Security Sub- Committee and Executive Board Meetings as part of the Risk Management report. This will be of such content as to enable decisions to be made when appropriate. Group Policies, Procedures and Systems are in place where required and relevant and that the Group has access to professional Health & Safety Advisors as appropriate If auditing or review identifies non-compliance with any Group Health and Safety or Security Policy or procedure, that the necessary corrective action is taken by the appropriate Managing Director and/or Appointed Person. He progresses all advice appertaining to any new or amended Act, regulation or guidance brought to his attention by safety or security advisors to the Group or other sources of such information. He will present an Annual Report of Health and Safety performance to the Board within the Risk Management report * The Appointed Person is usually the most senior person on the site ~ see #7 below MEG Statement of Policy & Responsibilities July 2012 6GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 61 62 63 64 65 6.6 67 1 THE EXECUTIVE BOARD The Executive Board is appointed by the CEO to manage the day-to-day business of the Group and as such, its members are responsible to the Chief Executive for all matters relating to health, safety and security within their teams or on the sites within their specific area of responsibility. For operational reasons, some matters need to be delegated on a day- to-day basis. Nevertheless, particular responsibility is assigned to the Executive Board (EB) members for ensuring that: All reasonable practical steps are taken to ensure the competency of Appointed Persons who are their direct or indirect reports (via Divisional Directors) and that an effective organisation structure exists within each team and on every site for which the EB members are responsible. The Group Health Safety and Security Policy and the content of any associated documentation are complied with, Site-specific procedures are in place where necessary and that all such procedures or systems clearly state the means by which safe conditions will be maintained and how compliance with the Health, Safety and Environmental Management System will be achieved. Such procedures will be reviewed annually. There is readily available on every site, detailed Site Health & Safety Procedures which include a copy of this Group Policy and site-specific procedures. Provision exists for each site to monitor and as required, to audit the effectiveness of all safety arrangements and to provide competent Health and Safety advice. Suitable and sufficient measures are in place to measure a site’s Health Safety and Security performance. Effective communication is maintained with the site’s Appointed Person on all relevant health, safety and security matters. APPOINTED PERSON ‘The Appointed Person shall be the most Senior Manager at each location, usually the site Director/General Manager/Attraction Manager, and he/she shall be responsible to his/her line manager as appropriate, for all matters relating to Health, Safety and Security at the location. His/her duties and responsibilities, as outlined, are applicable to the whole site and to all activities on the site. However, although such duties may be delegated on a day- to-day basis, this does not absolve him/her from ultimate responsibility. Any person to whom duties are delegated shall ensure that the Appointed Person is kept fully informed of all relevant matters. ‘The responsibilities of the Appointed Person will be directed, therefore, to: The application and support of the Group Health, Safety and Security Policy via detailed Site Health and Safety Procedures and appropriate security procedures which, whilst aimed at compliance, will also take account of ensuring that a good safety and security culture exists on the site. MEG Statement of Policy & Responsibilities July 2012 1GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HSO01 72 13 14 15 7.6 4d 18 19 7.10 Ensuring the competency of Department Heads, who themselves shall ensure the competency of all employees within their department. Ensuring that Department Heads, in consultation with employees and professionals, as appropriate, have thoroughly assessed the specific risks of all activities within their area of responsibility and that they have appropriate safety and security procedures and safe systems of work in place which are aimed at the reduction of risk to all guests, visitors and employees. The Appointed Person must also ensure that their Department Heads have a commitment to making progressive improvements in the Health, Safety and Environmental Management System. Ensuring that the assessments of risk and associated safe systems of work, and all other H&S procedures and systems, are communicated appropriately and adequately and brought to the attention of employees undertaking the activities in question. They must ensure that the associated documents are readily and easily accessible to those employees. The provision of Emergency Plans for the site and the availability of nominated and suitably qualified First Aiders in appropriate numbers for the size and scale of the site Ensuring that all managers and employees receive H&S training appropriate to their position and job role, and the risks and hazards associated with their job role. Such training will include Induction Training and Job Specific training. Ensuring that all employees are consulted with regularly with regards to Health & Safety related matters. This shall be through both formal mechanisms; either a site H&S Committee or a Works Council, (where these are in place), and through informal mechanisms in day to day contacts. Formal mechanisms shall have a cross section of employees from all levels and areas of the business on site. Investigation of incidents which identifies the root cause of such incidents and which is aimed at prevention of similar occurrences, together with the notification of incidents both at Group level, in line with Group guidance and where applicable to the enforcement authority. Ensuring that procedures are monitored, audited as required and regularly reviewed. Providing guests and other visitors with appropriate information such they can take informed decisions with regards to their own safety when choosing to participate in any activities provided on the site, e.g. restrictions on rides; advice for people with disabilities, ARRANGEMENTS FOR IMPLEMENTING THE HEALTH, SAFETY AND SECURITY POLICY Health, Safety and Security related matters shall be dealt with via the existing Management Structure and in accordance with the Health Safety and Environmental Management System. (Described in HS001/A) Arrangements should be such as to ensure that all persons are competent to carry out work for which they are appointed and that they are kept informed on all matters which could affect their own, or that of their customers’ or colleagues’, health safety and security. MEG Statement of Policy é& Responsibilities July 2012 gGROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 8.1 8.2 8.2.1 8.2.3 8.2.4 1 Whilst not limited to the following, such arrangements shall include: Health, Safety & Security Sub-Committee Such a forum shall be appointed by the Board and is described as in section 3 above. CFO, Executive Board Members, Site Appointed Persons and Group Heads of Department ‘They shall be responsible to ensure that the Board, the Health, Safety and Security Sub- Committee and Executive Board are kept informed, via their line manager or the Director Health, Safety & Risk Management, of all Health Safety and Security issues which could affect the business. ‘They should ensure that all policies or procedures initiated or approved by the Board, the Health, Safety and Security Sub-Committee or the Executive Board are communicated to all appropriate persons on the sites or within the areas for which they have responsibilities. In addition, they should ensure maintenance of the effectiveness of such policies and procedures through regular monitoring and introducing corrective action as necessary. They should ensure that performance is measured on a monthly basis by monitoring: ~ all incidents of a reportable nature + all non-reportable injuries and incidents They should also ensure that accident statistics are reviewed to identify trends. They should keep all resources under review and allocate such monetary amount or other resources necessary, including the production of an ‘action plan’ following an audit or other appropriate report, to ensure that Health, Safety, Security and Environmental related matters are dealt with effectively. Heads of Department Department Heads shall ensure there are suitable and sufficient safety and security procedures in place for all activities within their area of responsibility. They must also ensure that systems are in place to ensure the competency of all employees for whom they have responsibility within their teams. The must ensure that all employees for whom they have responsibility, are aware of the Group Policy and of their responsibilities under it and the law. EMPLOYEES Responsibilities Employees have a legal responsibility for the safety of themselves and for others, including guests, colleagues and all visitors to their sites. They must only use machinery, equipment, dangerous substances, transport, equipment and safety devices in strict accordance with their training and instruction and according to the safe systems of work laid down in operating procedures and/or Safe Systems of Work/Codes of Safe Working Practice. They must also behave in a safe manner at all times. Employees also have a duty to inform the Company of any dangerous, or potentially dangerous situation, or any shortcomings in the Company’s health and safety arrangements, MEG Statement of Policy & Responsibilities July 2012 9GROUP HEALTH, SAFETY AND SECURITY POLICY REF: HS001 92 Employees who feel that their concems with regards to a H&S related issue have not been addressed appropriately or adequately at the local level should bring this to the attention of the Director of Health, Safety &Risk Management. It is the duty of managers and supervisors at all levels to ensure that employees are aware of these responsibilities. Disciplinary Action Documentation shall be readily available to all employees, which clearly states that action will be taken against any employee who shows wilful disregard for safe working practices. Where disregard for safe working practices by an employee could or does seriously affect the safety or health of a guest, visitor or employee, or the security of company assets, that person may be subject to dismissal without notice. Failure to comply with any Company or Site Procedures or with legal requirements could result in individual prosecution by an Enforcement Authority, in addition to internal disciplinary action. MEG Statement of Policy & Respon: July 2012 10