Guiding Principles to Ethical and Responsible Business

Message
from the
CEO
As the world’s leading security and facility services company
with operations in more than 100 countries, we are committed
to setting the highest standards and leading the industry
through uncompromising integrity while upholding the highest
ethical standards.

It’s critical to our continued success that we act legally,

ethically and with integrity. Our Code is the playbook for that
success. It provides the fundamental values, principles and
standards necessary to make sound, ethical, legal and moral
business decisions while living our values and driving our
long-term progress.

Every team member is expected to review and follow this Code.

If you observe conduct that does not comply with our Code,
say something. I can assure you that we are listening and will
respond appropriately.

In the end, our goal is to drive a strong ethics and compliance

culture that builds trust, promotes integrity and improves the way
we engage with each other and our business partners. Our Code
is a critical part of that. Join me in upholding it in everything we
do as a global team.

Stay safe,
Steve Jones, Global Chairman and CEO

2
 4 Our Responsibilities
4 Our Values, Our Culture, Our Code
5 Using Our Code
6 Speak Out

Table of 7 Complying with the Law

Contents 8
8
Our People and Safety
Our People
9 Health and Safety
10 Human Rights
10 Combating the Trafficking of Persons
11 Diversity, Equity and Inclusion
12 Bullying and Harassment
13 Ethical Behaviour Towards Animals
13 Drugs and Alcohol

14 Our Business with Integrity

14 Anti-Bribery and Corruption
15 Gifts & Entertainment
16 Political Contributions
17 Conflicts of Interest
18 Competition and Antitrust
19 Financial Integrity
20 Anti-Fraud & Dishonesty
21 Anti-Money Laundering and Counter Terrorist Financing

22 Our Business Partners

22 Our Environment
23 Our Customers
24 Our Suppliers and Other Third Parties
24 Our Communities

25 Our Assets and Reputation

25 Protecting Our Confidential Information and Assets
26 External Communications
27 Our Brand and Intellectual Property

28 Implementation
28 Glossary 3
 OUR RESPONSIBILITIES
Our Responsibilities

Our People and Safety

Our Business with

Integrity

Our Values, Our Culture, Our Code

Our Business Partners
We champion ethical and responsible business practices throughout our organisation. Our Code
empowers us to act with integrity in our interactions with our colleagues, customers and communities.
As the cornerstone of our culture, it shapes how we collaborate and ensures our values are deeply
embedded in our operations.

Our Assets and

Reputation
PURPOSE VISION MISSION
There for you™, Be the world’s most trusted The company, through
serving and safeguarding services partner. its unparalleled customer
customers, communities, relationships, provides
proactive solutions, cutting-
and people around
edge smart technology, and
the world. tailored services that allow
Implementation customers to focus on their
core business.

VALUES

Glossary

4
 Our Responsibilities Using Our Code
Our Code provides the principles of our key policies and commitment to doing business legally,
ethically, and with integrity.

Adherence to our Code is mandatory for everyone who works for us in whatever capacity and
at any location across the Company, which includes employees, board members, directors
and officers. Additionally, third-party shareholders, partners, contractors, representatives and
agents working on our behalf are required to follow our Code.
Our People and Safety
Failure to follow our Code may result in disciplinary action, up to and including termination.
Page 6 on Speak Out outlines how to confidentially report actions inconsistent with our Code.
Do not hesitate to use Speak Out and encourage others to do the same if they have concerns.

As an employee, it is mandatory that you understand your individual responsibilities in applying

our Code when performing your role.

Your responsibilities
Our Business with
Integrity
• Read and understand our Code and apply it every day in your role.
• Complete all mandatory training.
• Speak up and ask questions if unsure about making the right decision or raise concerns of
instances of noncompliance with our Code.
• Cooperate fully and honestly during any investigation.
• Make informed decisions based on our values.

Our Business Partners Our leaders’ and managers’ additional responsibilities

• Lead by example, and be a positive role model of our Code and values and create a
working environment where you discuss our Code and values with your team.
• Ensure everyone on your team understands our Code and values.
• Encourage colleagues to ask questions and raise concerns. Listen and respond promptly
and protect them from any form of retaliation.
Our Assets and • Ensure suppliers, contractors and subcontractors act in a manner consistent with our Code.

Reputation

Implementation

Glossary

5
 Our Responsibilities

Speaking Up
Our People and Safety
We all have a responsibility to speak up when actions, behaviours or decisions undermine our values or
our Code. If you suspect wrongdoing, there are a number of ways to raise your concern. All concerns will
be taken seriously and handled confidentially.

Our speak up channels

• Contact your manager or another manager

• Contact Human Resources (HR), Ethics & Compliance (E&C) or Legal Services Group (LSG)
Our Business with
• Contact Speak Out
Integrity
If the matter relates to issues such as your work schedule, uniform or pay questions, contact your
manager or HR for the quickest resolution.

Speak Out

Speak Out is our global confidential telephone and web-based service that employees and third parties
Our Business Partners can use to report breaches of our Code or other wrongdoing, 24-hours a day, seven days a week.
The Speak Out helpline is administered by an independent third party. You can report your concern
anonymously in accordance with any local laws.

For more information including local phone numbers and online reporting you can visit:

U.S. and Canada aus.ethicspoint.com (888) 260-5948

Mexico aus.ethicspoint.com (800) 926-0023
Our Assets and International g4s-speakout.com Country phone numbers can
Reputation be found at g4s-speakout.com
TSS tss.ethicspoint.com 0808 196-8164

Concerns can be raised in confidence, and will be treated sensitively, with information being shared on
a need to know basis and only for investigating and handling purposes. We will fairly and objectively
examine all concerns and take appropriate action.

We do not tolerate retaliation in any form. Allegations of retaliation will be taken seriously, investigated,
Implementation and addressed appropriately.

Glossary

6
 Our Responsibilities
Complying with the Law What would
You must comply with all laws and regulations. Breaking the law harms our
you do?
business and damages trust and our reputation. In some countries, local laws It is a legal
or specific security industry standards are more stringent than our policies requirement in our
and standards. In that event, stricter requirements apply. Where our Code country to acquire
Our People and Safety security permits for
reflects the local laws, failing to follow our Code could constitute breaking
the law. As well as facing disciplinary action for violations, you may also face our business. The
fines and criminal prosecution. requirement is not
enforced by the
government, and
we do not think our
competitors have
Our Business with them. Do we have to
Integrity
do this?

Answer:
Yes. You must
always comply
with the law.
Our Business Partners Without exception
and regardless of
the behaviour of
other companies.

Our Assets and

Reputation

Your Decision Tool

Implementation
We must always act ethically, with integrity, making good decisions. If you are not sure about a decision, the
following can help guide your decision making:

• Is your decision consistent with the law, our Code, and our values?
• What would happen if everyone made a similar decision?
• What are the potential impacts of your decision?
Glossary • Could you stand by your decision if it became public or headline news?

If you are still unsure, speaking to your manager or another trusted colleague can help to make the
right decision.
7
 OUR PEOPLE AND SAFETY
Our Responsibilities

Our People
We are committed to fostering a work environment that attracts, develops, and retains top talent. Our
leadership is dedicated to creating an exceptional employee experience through building trust, acting with
Our People and Safety empathy, and supporting our teams. We define exceptional employee experience as a rich environment
that develops employees at every level, promotes from within, focuses on employee total rewards, and
provides a workplace that is inclusive and diverse. We strive to ensure that our people feel heard, valued,
supported, and have the resources to unlock their full potential.

To ensure we are listening to our teams, we regularly seek feedback from employees. We develop
I-Care leaders at every level of the organisation through ongoing training and development and
Our Business with
Integrity provide employees with career advancement opportunities, so they can continue to learn and grow
within the organisation.

By upholding these values and principles, the organisation can achieve increased engagement,
innovation, and discretionary effort that is key to our future success.

Our Business Partners

Our Assets and

Reputation

Implementation

Glossary

8
 Our Responsibilities Health
and
Safety
Our People and Safety

Our Business with

Integrity
Health and safety are top priorities, which means ensuring we identify and address health
and safety related risks, consult appropriate persons on health and safety matters to manage
those risks, and deliver appropriate training. We investigate all incidents and “near misses” and
regularly review health and safety performance to drive improvements. Our goal is “zero harm.”

You must always comply with health and safety laws, customer safety requirements and our
health and safety policies, procedures and standards. You must complete all health and safety
training, always use and wear all safety equipment correctly and follow all procedures that help
Our Business Partners protect you.

Workplace Violence
Violence has no place at our offices, locations, posts or job sites. This includes intimidation,
violent acts, and/or threats of violence. We will not tolerate this conduct.

Use of Force
We are committed to the safety of our employees, customers and communities and have strict
Our Assets and
standards regarding use of force. Our primary responsibility in a security role is to detect and
Reputation
deter while involving law enforcement when needed. You must strictly comply with our use of
force policy and procedures using de-escalation techniques unless protecting yourself or others
from immediate harm, to the extent permitted by Company policies and applicable law and
consistent with your training. Where we provide Care and Rehabilitation services, we comply
with the standards set by the relevant authorities and government agencies for our use of force
procedures, training, and incident review processes.

Weapons
Implementation
No Company employee or anyone acting on the Company’s behalf may carry, possess, or store
a firearm or other weapon, including less lethal weapons, during the course and scope of their
employment, except as permitted by applicable Company policy. In matters where relevant
country or U.S. state law prohibits such a restriction, Company policy prohibits the carrying of a
personal firearm to work, as well as having a personal firearm available in any compartment of a
Company vehicle or private vehicle being used for work purposes.

Glossary

See the Company’s health and safety policies for more information.

9
 Our Responsibilities
Human Rights
We are committed to respecting human rights and fulfilling humanitarian
responsibilities towards our employees, customers, suppliers, investors,
and communities we serve.

We closely monitor human rights abuses, which can be complex and hard
Our People and Safety to identify and include modern slavery, unnecessary or illegal use of force,
mistreatment of detainees, restricting freedom of movement, and criminal
What would
and sexual exploitation. you do?
I work as a security
Importantly, a business can violate an individual’s human rights as follows:
professional at an

• Directly, by abusive actions or policies. airport. During the

last few months, I
Our Business with • Actively colluding with or supporting the violation of human rights by have noticed the
Integrity states, partners, customers or other parties. same passenger
being accompanied
• Indirectly, through its links to subcontractors or suppliers which abuse
by different children.
human rights as they support or act on our behalf.
The children are
You must report any human rights violations to your manager or Speak Out. all roughly the
same age and look
fearful. Should I say
Our Business Partners anything?

Answer:
Yes. Well done for
being alert. This
may be a case of
human trafficking
Our Assets and or child labour and
Reputation
you should tell
your supervisor or
manager about your
concerns.

Implementation
Combating the
Trafficking of Persons
We prohibit employees, agents, and subcontractors from engaging in human
trafficking or any related activity. We take our responsibility to combat human
trafficking seriously by following proper hiring requirements and labour laws
in all jurisdictions where we do business. If in the course of your job duties
Glossary
you witness anyone engaged in suspected trafficking-related activities, you
must immediately report this conduct to your manager or Speak Out, as well
as law enforcement authorities.
10
 Our Responsibilities
Diversity, Equity and Inclusion
Our success depends on having diverse employees representing the world in which we operate,
proudly serving to the best of their abilities. This is achieved by recruiting people from all backgrounds
and providing them with equal opportunities to progress and grow.

• You must always behave in a way which recognises the value of diversity and demonstrates
inclusive behaviours.
Our People and Safety
• Be open to new ideas, listen to suggestions and welcome different points of view regardless of
where they come from.
• Never discriminate against people based on personal characteristics such as their race, color,
ethnic origin, age, nationality, disability, gender, sexual orientation, gender identity, marital status
or any other characteristic protected by law.
• Anyone involved in decisions affecting the employment or care of others is required to attend
training to ensure they understand their responsibilities and legal obligations to make decisions
Our Business with that are objective and fair.
Integrity
• Challenge any unacceptable or inappropriate behaviour so it can be addressed.
We are an equal opportunity employer that does not tolerate discrimination against any employee
or applicant on the basis of any legally protected characteristic or status. This applies to all terms
and conditions of employment, including pay rates, terminations, promotions, evaluations or other
aspects of career development.

Our Business Partners

For more information, please review the Company’s Diversity, Equity and Inclusion Policy.

Our Assets and

Reputation

Implementation

Glossary

11
 Our Responsibilities

Our People and Safety

What would
you do?
At the site where I
work, the customer
Our Business with and my colleagues
Integrity
use abbreviated
names for me,

Bullying and Harassment which are rude

and they know
I dislike them.
A safe, respectful and inclusive work environment is critical for fostering a
Should I report this
caring culture. We are committed to ensuring that no employee is bullied,
or just accept it as
Our Business Partners harassed or discriminated against in any way by a supervisor, other
workplace banter?
employees, customers or their employees or any other person in the
workplace. Any behaviours that create a hostile, degrading, intimidating Answer:
or offensive environment will not be tolerated. Bullying and harassment Answer: You
of any kind is unacceptable. should report it to
your supervisor
• While on duty, always treat others with respect and be aware of how
or via Speak
Our Assets and your behaviour affects others including those in our care.
Out. We will not
Reputation • Do not engage in behaviours that could be seen as abuse or
tolerate any form
harassment, such as name calling, innuendo, inappropriate jokes or
of harassing
purposely misgendering people.
behaviour that
• Never engage in displaying or sharing offensive or inappropriate undermines the
images, graffiti or content of a sexual nature. dignity of others

• Never engage in physical behaviours such as touching, pinching, at work.

Implementation patting, coercion or violence, whether actual or threatened.

• Be an ally for others and challenge and report behaviours that are not
in line with our policies, our Code or our values.

We do not tolerate retaliation and will take any retaliation concerns

seriously. Retaliation can include denying a training opportunity, rejecting
holiday requests, blocking promotions or similar type behaviour.

Glossary

12
 Our Responsibilities Ethical Behaviour
Towards Animals
The Company acts in accordance with applicable laws related to the
prevention of cruelty to animals and the Company’s canine care and
protection policies. The Company will not tolerate mistreatment or cruelty
Our People and Safety towards animals. We believe all animals deserve:

• Freedom from hunger and thirst by ready access to fresh water and diet
to maintain health and vigor.
• Freedom from discomfort by providing an appropriate environment,
including shelter, transport, and a comfortable resting area.
• Freedom from pain, injury or disease by prevention or rapid diagnosis
and treatment.
• Freedom to express normal behaviour by providing sufficient space,
Our Business with
proper facilities, and companionship.
Integrity
• Freedom from fear or distress by ensuring conditions and treatment(s),
which avoid mental suffering.

What would
you do?
I noticed a security

Our Business Partners Drugs and Alcohol professional arriving

for work in the
morning. Her speech
You are not permitted to use, possess, or be under the influence of
was slurred and she
any substance that could impair your ability to perform your job, such
was unsteady on her
as alcoholic beverages, marijuana, illegal drugs, misused prescription
feet. Should I say
medications, or other unauthorised controlled substances in the something?
workplace or while engaged in job related activity.

Our Assets and If you are taking a prescribed or over-the-counter medication that may
Answer:
Yes, before she
Reputation affect your ability to work safely, you must immediately inform your
puts herself or her
manager and HR.
colleagues at risk,
raise your concerns
See the Company’s human resource policies for more information. with her supervisor,
HR or Speak Out.

Implementation

Glossary

13
 OUR BUSINESS WITH INTEGRITY
Our Responsibilities
Anti-Bribery and What would
Corruption you do?
On checking the
We compete on merit, win business fairly and work with reputable delivery note for
customers and suppliers. Neither employees nor anyone acting on the a delivery to a
Company’s behalf may offer, make, promise, request or accept a bribe, customer, you
Our People and Safety
kickback or any other improper payment, gift, favor or other item of value notice that there are
in connection with the Company’s business. three bags missing.
When asked about
the shortage, the
Our Global Anti-Bribery and Anti-Corruption Policy is simple.
delivery driver
Remember:
immediately offers
• We do not accept or offer bribes.
you some money
• We do not accept or offer kickbacks or illegal payments
Our Business with in exchange for not
of any kind.
Integrity saying anything.
• We do not tolerate corruption in any form.
Should you accept
the payment?
Local laws and customs are not an exception to this rule; regardless of
location and context, we never pay or receive bribes. If you need help Answer:
navigating a culturally sensitive situation, speak with your manager, No, the payment
contact HR, E&C or Speak Out.
being offered
Our Business Partners Facilitation payments are small amounts of money or goods sometimes
is a bribe and
accepting it would
known as “grease payments” given to government officials to expedite the
be inconsistent
performance of a routine task, or to take action, already within their scope
of authority. These are also considered bribes and are forbidden. with our values,
our Code and
Those found to have been involved in bribery or any form of corrupt Global Anti-
practices, whether directly or indirectly, will be subject to disciplinary Bribery and Anti-
action, up to and including termination of employment, and may also face Corruption Policy,
Our Assets and criminal charges. and possibly the
Reputation law. You should
For more information, please review the Company’s Global decline the money
Anti-Bribery and Anti-Corruption Policy. and promptly
report the matter
to your manager or
Speak Out.

Implementation

Glossary

The personal safety of our employees is our highest priority. If any payments
are demanded to protect colleagues from imminent harm, any such payment
must be reported as soon as practical to LSG or E&C.
14
 Our Responsibilities Gifts and
Entertainment

Our People and Safety

What would
you do?
You have received a
small box of cookies
to celebrate the
New Year from a
local recruitment
Our Business with supplier who has
Integrity been involved
in a number of
appointments. They
are worth about $5
and are a traditional
offering the New
Year. Should these
cookies be returned
Our Business Partners Gifts or entertainment of customers and potential customers are permitted or is it okay to keep
under certain circumstances and must not be excessive. Exchanging gifts them and share them
and entertainment to develop good business relations is permitted and must with colleagues?
follow region-specific guidance as to the nature and amount of the expense
and appropriate approval processes. Answer:
It is acceptable
Importantly, gifts to or entertainment of a potential customer around the to keep small
time of a bid for that customer is prohibited. We are strictly prohibited from gifts of nominal
Our Assets and providing, or receiving gifts, gratuities, or entertainment from government value that are not
Reputation officials or government employees. For those doing business with the U.S.
going to influence
or be perceived
Government, refer to Gift Giving – Business Courtesies and Entertainment
as influencing
When Dealing With Federal Government Employees for additional details. your decision to
use a particular
You must refrain from giving or accepting: cash; cash equivalents, such as supplier. Always be
prepaid gift cards; stocks; checks; money orders; loans; lavish entertainment; transparent about
and favors from customers, competitors, or vendors. Please see any region- any gifts received
specific policy for further guidance. with your manager
Implementation and thank the
Any variance from these rules requires prior written approval from your supplier promptly.
manager in accordance with our policies. Stay alert, use common sense, Your local gifts
and entertainment
and do not put yourself or the Company at risk.
policy states the
Always follow the guidance in this Code, the relevant gifts and entertainment value threshold for
gifts and approval
policy and any local policies and follow the strictest requirement.
process for
variances.
Glossary
For more information, please consult with your leadership and
review the relevant local policies.

15
 Our Responsibilities

Political Contributions What would

you do?
We do not prohibit employees from voluntarily making personal political I am using my social
contributions, participating in the political process on personal time, or media profile to help
expressing personal views on legislative or political matters. Involvement raise awareness of a
Our People and Safety
in civic affairs or political activities is a personal choice. If you speak out political candidate. Is
on public issues, you must make it clear that you are speaking only for that okay? I only use

yourself and not for the Company or in your capacity as an employee or social media on my
own time and there is
representative of the Company.
no mention of my job
Campaign finance and ethics laws, as well as Company policy, prohibit on my profile.

Our Business with the use of Company funds, assets, services, or facilities on behalf of a
Integrity political party except under limited circumstances. The Company will not Answer:
Yes, so long as you
compensate or reimburse you or any employee, in any form, for any political
do not claim to be
contribution. Any political solicitation made during business hours on or at
speaking for the
Company facilities must be approved in advance by senior management. Company and you
do it on your own
Personal political activities can sometimes create a conflict of interest with
time. You might
the Company. Speak with your manager if you believe your political activity
want to review local
Our Business Partners might affect (or even appear to affect) your role in the Company and/or the laws to determine
Company’s disclosure obligations. whether such
involvement with the
political candidate
triggers disclosure
obligations.

Our Assets and

Reputation

Implementation

Glossary

16
 Our Responsibilities Conflicts of Interest
The Company policy on conflicts of interest is straightforward. In the course and scope of your duties
with the Company:
• Always act in the best interest of the Company.
• Always protect the Company’s reputation.
• Protect and enhance the trust of our customers and suppliers.
Our People and Safety • Do not allow financial, personal, or social activities to interfere with commitments to the Company.
A conflict of interest arises if your personal, professional, social, financial or political interests or activities
interfere with your responsibilities to the Company, or your ability to make objective decisions for the
Company. Being transparent and proactive in disclosing and recording conflicts of interest allows them to
be appropriately managed, protecting you and the Company.

Our Code cannot describe every potential conflict of interest. The list below describes some of the
more common examples:
Our Business with
Integrity • Workplace relationships: such as having personal or romantic relationships with other
Company employees, vendors, customers, or an employee, tenant, or customer at the account
to which you are assigned.
• Working with close relatives and friends: such as supervising a family member who also
works at the Company in your managerial line.
• Resourcing: such as being involved in the hiring process of a candidate that is a close relative
or someone with whom you have a close relationship.

Our Business Partners • Political appointments: running for, or accepting an appointment to, a political or
government office.
• Outside employment or business opportunities: such as holding a second job outside of
the Company that conflicts with your work here. You should discuss any second job with your
manager to determine if a conflict or potential conflict exists.
• Personal investments: such as having any personal interest, dealings or ownership in any
business that is either a competitor, customer, supplier, Company business partner (actual or
contemplated), trade association, or industry standard-setting organisation.
Our Assets and
Reputation Importantly, even the appearance or perception of a conflict is a problem. You must report any actual,
potential or perceived conflict to your manager.

Implementation

Glossary

17
 What would
Competition and
Our Responsibilities
you do?
After a meeting with

Antitrust several competitors,

we agreed to go for
a quick lunch. The
We compete fairly and ethically and comply with competition and antitrust
topic of business
laws. These laws are intended to ensure that competition between
acquisitions came
Our People and Safety companies is fair and protects the public. Sharing competitor information, up and they started
agreeing to fix prices, allocating markets and other practices that would talking about their
inhibit competition is prohibited. expansion plans. I
excused myself and
Never enter into inappropriate discussions with competitors. Never enter left the meeting. Was
into agreements, formal or not, expressed or implied, that unreasonably
I right to do so?
restrict competition. This includes:

Our Business with • Agreements with competitors to charge customers the same price Answer:
Yes, you did the
Integrity (price fixing), reduce competition in bidding (bid rigging), or divide
markets or service territories (market allocations). right thing. Never
participate in
• Agreements not to sell to or buy from competitors and/or suppliers
conversations
(boycotts).
about confidential
• Requiring a customer to buy an item or service as a condition to buying business matters
another item or service (tying). with competitors.
• Never discuss confidential information about the Company with State your reason
for leaving the
Our Business Partners competitors or seek confidential information from them. Be particularly
conversation before
careful at industry forums, trade association meetings and similar
you walk away
gatherings to avoid participating in any informal discussions with
and ask that your
representatives of competitors about anticompetitive topics. decision to leave
due to concerns
over the topic of
For additional information, please review the Company’s Global Fair discussion be
Competition and Antitrust Policy. noted. If you are not
Our Assets and
sure whether the
Reputation
topic of discussion
is permissible,
exercise caution
and leave the
meeting.

Implementation

Glossary

18
 Our Responsibilities Financial Integrity
Recordkeeping, Accounting and Internal Controls

We strictly adhere to laws, regulations, accounting principles, ethical practices, and other criteria designed
Our People and Safety to ensure full accountability and reliability in our accounting records, systems, and financial statements.

We maintain accurate, auditable books and records of account that fairly reflect our transactions,
and we maintain an effective system of internal controls to ensure integrity and completeness of our
financial records.

We expect employees to accurately collect, record, and report Company information, including payroll-
related data, time and attendance records, test and training results, cost and pricing data, invoice and
Our Business with billing records, purchase orders, and all other data that supports our books and records.
Integrity
Employees with responsibility for preparing and maintaining the Company’s financial statements must
comply with our internal accounting policies and procedures, which are based on generally accepted
accounting practices, as well as with laws and regulations and Company policies governing record
retention and preservation. Absolutely no false or misleading entries may be made for any reason.

Our Business Partners External Audits and Reviews

On an annual basis, the Company engages an independent accounting firm to audit its books and
records of account. At times, federal, state, and local government regulators and inspectors, inclusive
of tax auditors, insurance auditors, and other qualified inspectors, might subject the Company to routine
operational audits and inspections. We fully cooperate with such audits and reviews and promptly,
completely, and accurately address requests for information. Employees are prohibited from concealing,
destroying, or altering original documents and records; delaying communication of information or records;
Our Assets and
Reputation knowingly providing false or misleading statements or inaccurate information to auditors or inspectors; or
otherwise obstructing access to information.

If you have any questions or concerns about an audit or investigation at your site, consult your manager.

Insider Trading Laws

Implementation As an employee of the Company, you may have access to material non-public information concerning the
Company or its vendors, suppliers, or customers. Common examples of such information include, but are
not limited to: new service contracts, personnel changes, marketing strategies, proposed mergers and
acquisitions, and financial results or other strategic plans. It is a criminal offense to use inside information
for illegal purposes.

If in possession of material non-public information, you must not share that information internally or
Glossary externally without prior approval. Moreover, you must not use that information or engage in any action to
take advantage of that information, such as buying or selling Company securities (if and when publicly
available) based on that non-public information.

19
 Our Responsibilities
Anti-Fraud and What would
you do?
Dishonesty An employee has
prepared the monthly
Do not engage, directly or indirectly, in dishonesty, fraud, theft, embezzlement,
performance report
falsification of records (including but not limited to falsifying timecards, injury
Our People and Safety reports, property claims, training records, and expense reports), whether in for a customer.

paper or electronic form. When his manager

checks the report,
Fraud encompasses acts such as deception, bribery, forgery, extortion,
she asks him to
corruption, theft, conspiracy, embezzlement, misappropriation, false
increase some of
representation or concealment of material facts, and collusion which may
the lower KPI scores
result – directly or indirectly – in financial or personal gain to the perpetrator,
because they may
Our Business with the Company, or a third party.
give the customer a
Integrity
Report attempts or suspected acts of fraud, deceit, or dishonesty to your poor impression of
manager or via Speak Out. The business may attempt, where practical the Company. What
and appropriate, to recover losses using civil and/or criminal remedies and should he do?
report such attempts to law enforcement.
Answer:
Refuse to make

Our Business Partners For additional information, please consult with your leadership and the change and
review the relevant local policies. escalate the matter
to the relevant
business leader or
via Speak Out.

Our Assets and

Reputation

Implementation

Glossary

20
 Our Responsibilities

Anti-Money Laundering What would

and Counter Terrorist you do?
The police inform the

Financing
Company that they
Our People and Safety are investigating one
of our customers for
suspected money
Anti-money laundering (AML) and counter terrorist financing (CTF) laws
laundering. The police
seek to prevent the financial system from being used to receive and
request confidential
legitimately transfer the proceeds of crime, to finance terrorism, or evade
information about
taxes, and to stop entities and individuals from hiding, benefiting from and
previous transactions.
facilitating money laundering or the financing of terrorism. You must:
Our Business with Should I comply with
Integrity • Never become involved in money laundering or conduct business with
the police request?
What should I tell the
persons who are suspected to be linked to illegal activity.
customer?
• Never conceal, disguise, convert or transfer the proceeds of crime.

• Never remove the proceeds of a crime from a country. Answer:

You should
• Never acquire, use or possess the proceeds of a crime.
immediately report
• Never aid or abet, facilitate or procure such activities. the request to your
Our Business Partners manager, who
• Never assist or facilitate any party with the unlawful evasion of taxes.
can consult with
Our cash solutions businesses handle cash and other valuables belonging LSG and ensure
to customers and third parties, which increases their exposure to the risk that the Company
of money laundering or terrorist financing. To mitigate that risk, employees cooperates
working with those businesses must adhere to additional rules and business- with the police
specific policies. Those employees should ask their manager about any investigation in the
Our Assets and additional compliance expectations specific to their role with the business. appropriate way
Reputation and in accordance
• Promptly seek advice from your manager and LSG if any demand or with applicable
request is received from a law enforcement agency in connection with laws, policies
alleged money laundering or terrorist financing. and contractual
commitments. Do not
• Do not “tip off” customers or third parties if you become aware that law
notify the customer
enforcement agencies are conducting an investigation into suspected
about the police
money laundering or terrorist financing, as this could itself be a
investigation, as this
Implementation criminal offense.
could assist them in
We are committed to complying with all applicable AML and CTF laws evading the law.
and regulations.

For additional information, please consult with your leadership and

review the relevant local policies.
Glossary

21
 OUR BUSINESS PARTNERS
Our Responsibilities

Our People and Safety

Our Business with

Integrity

Our Business Partners

Our Environment
Our Assets and
Reputation We strive to reduce our impact on the environment, setting targets for any reductions in carbon
intensity and the management of waste, water, vehicle emissions and energy consumption.

We collaborate with others to find ways to operate more sustainably. Where opportunities permit, we
also partner with our customers, contractors and suppliers to achieve the same. We encourage you to:

• Explore every opportunity to adopt more sustainable practices that reduce energy and water
consumption and produce less waste.
Implementation
• Protect the environment for the future. Never litter.

• Switch off engines and equipment when not in use and treat water as a scarce resource
regardless of where you live.

• Notify us if you have ideas about how to reduce our environmental impact. We are listening and
would like to hear them.

Glossary

22
 Our Responsibilities Our Customers
We look to partner with reputable customers who respect our people and
share our values. Our goal is to develop and enhance long-term customer
relationships. At the heart of these relationships is a bond of trust and
openness, honesty and transparency throughout all our interactions.

Our customers entrust us with their most valuable resources—their people,

Our People and Safety their information and their assets. In return, we commit to behaving in line
with our values and to ensure our work is of the highest quality. We value our
customers and any treatment of their assets or information in a dishonest or What would
disrespectful way is prohibited.
you do?
We comply with applicable laws and regulations, including trade sanctions I process invoices
and restrictions imposed on countries, individuals and governments. for our customers
and have noticed
• You must always be truthful in your dealings with customers. Never
Our Business with promise what you know we cannot deliver or deliver less than we that the costs have
Integrity have promised. more than doubled

• Charges and costs must always be accurate and lawful. for one of them.
This seems strange
• Never agree to contracts with customers unless you have written approval
to proceed. If you are unsure, check with your local finance department. given the size of
the contract has not
• Do not pressure customers to buy our services or commit to a contract
changed. Should I
they do not want.
say something?
Our Business Partners Government Services

We serve many government agencies and other public authorities globally.

Answer:
We comply with all laws and regulations applicable to relationships Yes, always raise
and potential relationships with such agencies and authorities and their concerns about
employees. These laws may vary by country and it is your responsibility to invoices with the
maintain awareness of the laws that may apply to you. Employees serving relevant account
governmental entities in the U.S. must also follow the Company’s Guidelines
or local finance
Applicable to U.S. Government Procurement Activities. The policies are
Our Assets and manager so they
available on the Company intranet sites or ask your manager.
Reputation can investigate.
Customer invoices
must be accurate.

Implementation

Glossary

23
 Our Responsibilities
Our Suppliers and Other
Third Parties
We set high ethical standards and want to work with reputable third parties (e.g., suppliers, vendors and
subcontractors) who share our commitment to ethical business practices. When necessary, we help
Our People and Safety suppliers and other third parties enhance their standards.

You must follow all procurement policies when engaging suppliers and other third parties. Treat them
with respect, fairness and honesty and enable them to perform effectively. Never approve expenditures
that are outside your delegated authority. If you are not sure of your expenditure limits, seek guidance
from the local finance department. Follow-up with your local team about applicable procurement and
third-party due diligence policies. Ensuring appropriate due diligence is performed on our business
partners is critical to our success.

Our Business with

Integrity

Our Communities
We care about our communities and operate in a respectful way. This includes encouraging voluntary
work, sponsorship of community projects and charitable fundraising for a variety of causes. We will also
serve local interests by providing good employment opportunities with meaningful work and fair wages.

Our Business Partners We will share our knowledge, expertise and resources to help raise the standards for the industry and for
the benefit of our communities.

Our Assets and

Reputation

Implementation

Glossary

24
 OUR ASSETS AND REPUTATION
Our Responsibilities

Protecting Our Confidential

Information and Assets
Our People and Safety We protect the confidentiality of information belonging to the Company, our employees, our customers
and suppliers.

Use of Resources

Inappropriate and illegal use of Company or customer property is prohibited. Use good judgment in the use
of Company and customer-provided property. The Company reserves the right to inspect and review the
contents of electronic equipment connected to its network and to monitor use of the Company’s IT network
Our Business with to maintain and ensure its safety and integrity. Employees have no expectation of privacy when using the
Integrity Company’s IT network or electronic equipment.

Do not use Company resources to transmit, store, or download materials that are in violation of applicable law
(i.e., movies, unlicensed software, or stolen software) or that could be considered threatening, maliciously
false, or obscene. In addition, you are strongly encouraged to use only company-issued hardware and
software to conduct business. If this is not possible or practical, please consult your manager. Only utilise
customer property in accordance with our Code and written agreements with the customer.

Privacy and Confidentiality

Our Business Partners
The Company handles personal information of its employees and customers, as well as that of individuals
who might visit our and our customers’ facilities or become involved in a security event (e.g., a courier,
witness, etc.). We also create confidential and proprietary business information. The Company is committed
to lawfully collecting, processing, transmitting and protecting personal and confidential information, and to
securing the networks and systems on which that information is stored. Compliance policies and guidance
regarding potentially applicable U.S. and international privacy and information security laws are available
on the Company’s intranet.
Our Assets and
Reputation Personal Information: Any information that relates either directly or indirectly to an identifiable person
(e.g., name, date of birth, government-issued identification number, address, email, phone number,
ethnicity, gender and other information that alone or in combination with other elements of personal
information could be used to identify a specific individual).

Confidential Business Information: Any information that relates to the Company’s business dealings,
including but not limited to, financial, marketing and statistical data, competitive information, and other
non-public company information.
Implementation
Failure to protect both personal and confidential business information from unauthorised access could
subject the Company or yourself to civil and/or criminal action, give both the Company and our customers’
competitors an unfair advantage, or lead to reputational damage.

You must take precautions not to handle, view, or share such information outside the scope of your job
duties. Employees who inadvertently do so must protect this information from any further disclosure
subject to applicable laws.
Glossary You must also ask your manager before utilising any third-party technology solution to ensure it has been
approved for use by the IT Department.

25
 Our Responsibilities

Our People and Safety

Our Business with

Integrity

What would
you do?
I found some

External information about the

Company on LinkedIn
Our Business Partners
Communications which includes
photos taken at work
which I think puts our
We are bound by Company policies regarding speaking with the media
colleagues at risk.
and posting information on the Internet. Only designated spokespeople are
What should I do?
permitted to speak to the press on behalf of the Company or make public
posts or statements on behalf of the Company. If you are contacted by a
member of the media, direct them to either pressna@aus.com or media@ Answer:
Our Assets and g4s.com or tell your manager. Raise it with your
Reputation manager or a
Employees who utilise social media or other internet sites for personal
member of the
purposes should carefully consider how the information they share affects
or reflects on the Company if they are identifiable as a Company employee. communications
Do not share or post online any of the Company’s confidential or proprietary team so they can
information or any information that would compromise a customer’s security follow up and seek
or business operations or reveal confidential personal information. to have it removed,
if appropriate.
This does not prohibit employees from engaging in protected concerted
Implementation
activity. This policy does not and should not be interpreted to infringe upon
an employee’s right to communicate with others related to issues concerning
wages and other terms and conditions of employment.

Employees must adhere to fair, forthright, and legal sales and marketing
practices and present only truthful, non-deceptive information.

Use social media wisely and always think about the way information may be
Glossary received or perceived.

26
 Our Responsibilities
Our Brand and
Intellectual Property
Our People and Safety We require all employees to protect and respect our brands and other intellectual
property and use them appropriately. Our Company family of brands, which
includes our logos and any trademarks, are our intellectual property. Across the
world, wherever we operate, our brands are important. It reflects our common
identity and values and represents an organisation that can be trusted. We all
have a responsibility to safeguard our brands from any misuse.

Our Business with We must follow laws pertaining to copyright protection in all jurisdictions in
Integrity which we operate. This includes laws that prohibit duplication of print materials,
licensed computer software, and other copyright-protected works. We also
have a responsibility to respect the intellectual property and brands of other
organisations too.

Our Business Partners

Our Assets and

Reputation

Implementation

Glossary

27
 IMPLEMENTATION
Our Responsibilities Our Code is intended to help you do business ethically and with integrity. To make that possible, it is widely
distributed and regularly updated.

When committing to work with or for us, you are committing to following our Code. In some cases, it will form
part of your contract of employment. In many cases the terms within it are also the law.

Please follow it and if you have any concerns raise them with your manager or via Speak Out.
Our People and Safety
Our Code can not be waived without prior written approval from the Allied Universal Global Chief Compliance
Officer. Our Code sets out our expectations of everyone we work with and our commitment to doing business
legally, ethically, and with integrity. Failure to comply with our Code will be addressed through appropriate
actions, which may include disciplinary up to and including termination of employment.

Our Business with

Integrity

Our Business Partners

Our Assets and

Reputation
GLOSSARY

Company - includes Allied Universal and all Allied Human Resources - HR

Universal subsidiaries, affiliates, and related companies
Legal Services Group - LSG
worldwide, including G4S Limited and its subsidiaries.
Implementation
Global Code of Ethics - Our Code
Ethics & Compliance - E&C

Glossary

May 2024 | 1259022702 © 2024 G4S, An Allied Universal® Company