Lucas UK Group Limited...Lucas UK Group Limited The Integrated Quality & Environmental System s...

L u c a s U K G r o u p L i m i t e d T h e I n t e g r a t e d Q u a l i t y &

E n v i r o n m e n t a l S y s t e m s M a n u a l

This manual describes the organisation, policies and processes of Lucas UK Group. It describes how our services are delivered, measured and controlled to ensure continuous business improvement whilst incurring minimal

environmental impact.

This manual contains the relevant references from the ISO 9001:2015 and ISO 14001:2015 Standards to which it complies.

Version 1 Revis ion 2 2 of 68 | P a g e Last Dated 07 Jan 2020 Uncon t ro l le d doc umen t onc e pr in ted & there f ore n ot s ub je c t to up da te

TABLE OF CONTENTS 1.0 BUSINESS OVERVIEW, CONTEXT, SCOPE AND POLICIES .................................................................................................................................................. 4

1.1 BUSINESS OVERVIEW AND CONTEXT ................................................................................................................................................................................... 4

1.2 External Factors and Interested Parties............................................................................................................................................................. 5

1.3 Organisational Scope of ISO 9001 and ISO 14001 Registration ...................................................................................................................... 6

1.4 Qulity and Environmental Policy Statement ...................................................................................................................................................... 7

1.5 Management System Overview ......................................................................................................................................................................... 8

1.6 Corporate Planning & Management ................................................................................................................................................................... 9 2.0 ORGANISATIONAL STRUCTURE, ROLES AND RESPONSIBILITIES.................................................................................................................................. 10

3.0 RISKS TO THE BUSINESS ...................................................................................................................................................................................................... 16

4.0 PERFORMANCE MEASURES AND IMPROVEMENTS .......................................................................................................................................................... 19

5.0 HUMAN RESOURCES MANAGEMENT AND COMMUNICATIONS ....................................................................................................................................... 21

5.1 Training ............................................................................................................................................................................................................... 21

5.2 Performance Review .......................................................................................................................................................................................... 22

5.3 New Employees .................................................................................................................................................................................................. 22

5.4 Orgnaisational Knowledge ................................................................................................................................................................................ 22

5.5 Internal and External Communication.............................................................................................................................................................. 23 6.0 INFRASTRUCTURE RESOURCES MANAGEMENT ............................................................................................................................................................... 25

6.1 Physical Resources and Working Environments ............................................................................................................................................ 25

6.2 IT Infrastructure ................................................................................................................................................................................................. 26 7.0 MANAGEMENT OF DOCUMENTATION RESOURCES AND CONTROLS ............................................................................................................................ 27

7.1 General Documentation Management .............................................................................................................................................................. 27

7.2 Documentation Updates and Issue .................................................................................................................................................................. 30

7.3 Control of Records and Reports ....................................................................................................................................................................... 30

7.4 Documentation and Data Security .................................................................................................................................................................... 31 8.0 ENVIRONMENTAL MANAGEMENT AND PLANNING ............................................................................................................................................................ 32

8.1 Environmental Risks & opportunities (Aspects and Impacts) of the Business ........................................................................................... 32

8.2 Environmental Legislation ................................................................................................................................................................................ 32

8.3 Emergency Preparedness ................................................................................................................................................................................. 33

8.4 Monitoring Environmental Performance .......................................................................................................................................................... 33

8.5 Operational Controls ......................................................................................................................................................................................... 35

8.6 Communications & awareness ......................................................................................................................................................................... 36

8.7 Environmental Management Policy Statement ............................................................................................................................................... 38 9.0 THE MANAGEMENT OF BUILDING REFURBISHMENT AND ASSOCIATED BUILDING TRADES SERVICES OPERATIONS ......................................... 39

9.1 BID stage ............................................................................................................................................................................................................ 40

9.2 WIN stage............................................................................................................................................................................................................ 42

9.3 DELIVER stage ................................................................................................................................................................................................... 44

9.4 FINISH stage ....................................................................................................................................................................................................... 48

9.5 Care of Property, Tools and Equipment........................................................................................................................................................... 51 10.0 MANAGEMENT OF EXTERNAL RESOURCES AND PURCHASING ..................................................................................................................................... 53

10.1 Supplier Selection and Performance Monitoring ............................................................................................................................................ 53

10.2 Subcontractor Evaluation and Performance Monitoring ................................................................................................................................ 53

10.3 Purchasing and Receipt .................................................................................................................................................................................... 54 11.0 CLIENT PERCEPTIONS, FEEDBACK AND COMPLAINTS.................................................................................................................................................... 55

11.1 Client Feedback ................................................................................................................................................................................................. 55

11.2 THIRD PARTY OR Client Complaints ............................................................................................................................................................... 55 12.0 INTERNAL AUDITING .............................................................................................................................................................................................................. 57

13.0 MANAGING NON-CONFORMITIES & CORRECTIVE ACTIONS ............................................................................................................................................ 59

14.0 MANAGEMENT REVIEW ......................................................................................................................................................................................................... 62

15.0 CHANGE HISTORY .................................................................................................................................................................................................................. 64

16.0 REGISTER OF HOLDERS ........................................................................................................................................................................................................ 64

17.0 GLOSSARY OF TERMS & ABBREVIATIONS ......................................................................................................................................................................... 64

APPENDIX 1 CORRESPONDENCE BETWEEN ISO 9001:2015 AND THIS MANUAL ............................................................................................................................. 65

APPENDIX 2 CORRESPONDENCE BETWEEN ISO 14001:2015 AND THIS MANUAL ........................................................................................................................... 67

APPENDIX 3 – ACCREDITATIONS............................................................................................................................................................................................................... 68


Using This Manual

This Manual describes the quality and environmental management systems of Lucas UK Group Ltd. also referred to here as Lucas It contains the mandatory procedures and sections required by ISO 9001 and ISO 14001, as well as references to those procedures and records employed by the Lucas UK Group Ltd for the running of its day to day operations that reside outside this manual. All key processes described in this manual incorporate a primary objective statement that defines the fundamental purpose of that process, and therefore implies its criteria for success. Key procedures or sections in this manual are allocated Process Owners which are indicated at the start of the relevant section unless a default owner is assigned throughout. The process owner is responsible for ensuring the effective operation of the process and its outcomes. References are made to specific documentation or other artefacts outside this manual using the form shown in the following example – e.g. “recorded in Aspects & Impacts Register, aspects of the company's activities, products and services that could impact upon the environment, and over which it has control or influence. This list shall be a considered an updated as required at each Management review and at other times following significant changes in operations or legislation. See also Appendix 2 which contains references to other Lucas UK Group Ltd Procedures. The Appendix contains a table of cross references from the ISO 9001:2015 and ISO 14001:2015 Standards showing where in the manual each of the requirements are being met or otherwise dealt with.


1.0 BUSINESS OVERVIEW, CONTEXT, SCOPE AND POLICIES

1.1 BUSINESS OVERVIEW AND CONTEXT Lucas UK Group comprises two companies, Lucas Finishing Specialists Ltd (LFS) & Lucas Fit Out Ltd (LFO). LFS is a major painting & decorating contractor within the construction Industry and LFO is a major fit out contractor within the construction industry. We originally formed as S. Lucas Ltd in 1976 by Sam Lucas and as a result of a diversified range of services offered by the Lucas UK Group Ltd. LFO was established in late 2007. In September 2017 the Group name changed to Lucas UK Group Ltd and S Lucas Ltd, the Painting division became Lucas Finishing Specialists Ltd. Danny Lucas is the Managing Director of Lucas Finishing Specialists Ltd and of Lucas Fit Out Ltd. Both companies are run with a very ‘hands on approach’ and are built on a values of Excellent & Prompt Service, Teamwork, Quality & Reliability, Proactiveness with a Lean & Innovative approach in order to deliver a quality product on time, within budget and in a safe manner.

This ethos has proved very successful and hence the purpose of the IMS is to translate what we do every day into a written business system, which is user friendly and will ensure that all management, through to site operatives and supply chain ensure that these core values are implemented and maintained.

We are one of the UK construction industry's leading specialist fit out and finishing contractors. As a group we are split into LFS and LFO offering the complete rang e of decorating and fit out services required for major construction projects, for sensitive and sometimes historic buildings refurbishments, and for general, high quality domestic decorations. We deploy our highly trained multi-disciplinary team of experienced, safety-conscious workforce, to deliver on time projects that comply with the highest quality, safety and environmental standards – and all backed by our own laboratory facilities developing bespoke, high performance finishes and a logistics infrastructure that ensures timely and cost-conscious delivery. LFO provides a range of fit out packages for contractors and consultants, suitable for all construction programmes. Most importantly, we are the only point of contact a project will ever need as we bring together all the relevant trades and skills under our project management team. Lucas fulfils a growing need in the UK where, precision and timely delivery is paramount. Although our services are offered country wide our main demographic is London and the South East. It is the intention of the Lucas UK Group Ltd to maintain and build on its position and reputation within its market through its commitment to quality and professionalism in all that it does, while always striving for a lean approach and continual improvement.


1.2 EXTERNAL FACTORS AND INTERESTED PARTIES To varying degrees Lucas must take account of external factors, issues and influences that could potentially have an impact on its operation, as well as those 3rd parties that may have an expectation in what we do. The main third parties that the management must take account of are;

3rd Party Context

Clients Specify and pay for the services provided by Lucas. Clients can represent the private or public sectors. Clients, whether directly or indirectly, can be architects, property developers, surveyors, local authorities or private individuals etc.

Certification and Accreditation Bodies Assessments and surveillance visits for ISO certification and other accreditations, i.e. Achilles Building Confidence, FSC, FORS, SMAS, Constructionline and the Dulux Contract Partnership.

Competitors Management needs to be aware of what its competitors are doing and ensure business is not lost to other similar services providers. The Directors need to ensure that the Lucas UK Group Ltd keeps pace with the market and environmental requirements as well as any technical developments within its industry.

Regulatory – HSE and Environment Agency and Local Authorities

Lucas ensures that it remains compliant with all relevant legislation or regulatory requirements. References to legislation relating to its operation are held in our Legislation Register. The EA and HSE facilitate the enforcement of legislation and produce guidance on compliance. Our Legislation Register is subject to Bi-annual review, it seeks to identify applicable legal requirements and other requirements related to the company's H&S, Environmental and other legal aspects, and explains how the requirements apply to the company’s operational aspects. The group shall endeavor to remain informed regarding changes of legislation by means of the facility offered by the governmental agencies via the internet. This information shall be reviewed at each management review.

Suppliers (external resources) Suppliers (external resources) are managed according to their importance. They can include eg self-employed staff, sub-contracting companies, construction material suppliers and waste services etc. Minor suppliers can include those for stationary, IT support and other administrative functions.

Staff All employees have designated roles and responsibilities with their performance continually reviewed.

The implied activities or objectives contained within the context of the 3rd parties listed above are supported by virtue of the Lucas management system and by further referencing to LUKG IMS Doc 1-2 Rev0 – Interested Parties, Internal & External Issues of Concern document where we have provided a a simple and pragmatic approach has been adopted to understand LUKG’s organisation’s context, to both Quality and Environmental elements of our IMS, this is:

a. Identifying the internal issues that can affect the services, investments and interested parties


b. Identifying the external issues that can affect the services, investments and interested parties

c. Identifying who are the interested parties and what are their needs and expectations i.e. requirements

d. Developing a system for regular review and monitoring of the internal issues, external issues and interested parties and which of these become compliance obligations

1.3 ORGANISATIONAL SCOPE OF ISO 9001 AND ISO 14001 REGISTRATION For the purposes of certification to both ISO 9001 and ISO 14001 the scope of the Lucas UK Group Ltd.’s business is: The management of building refurbishment and associated building trades Our BSI ISO 9001 Registered No FS 23467 Our BSI ISO 14001 Registered No EMS 552100 The EMS and the QMS elements are integrated wherever this is practicable. This IMS aims to cover all aspects of the company’s operations that lead to the supply of product and service to the customer, including:

• Corporate management and planning • Marketing • Training • Control of suppliers and sub-contractors • Operations and logistics • Product acceptance procedures and client feedback

This manual will be subject to regular review to ensure it remains complaint, for legal and ISO standards reasons.


1.4 QUALITY AND ENVIRONMENTAL POLICY STATEMENT The following combined quality and environmental policy statement is made available to all Lucas UK Group Ltd personnel as well as any 3rd parties as required. It is regularly reviewed and signed by the Managing Director and displayed within the Lucas UK Group Ltd office and on our Lucas UK Group Ltd intranet and on our website. ________________________________________________________________________________ Lucas UK Group provides diverse range of Building Finishing and Fit Out services, from its offices in Wrotham, near Sevenoaks in Kent. Our primary objective is to provide high quality products and services are provided to its customers, to ensure that quality requirements are determined and satisfied throughout all phases of a contract, and to ensure that the products and services supplied to the customer are fit for purpose irrespective of size and complexity whilst consistently meeting the needs of its clients. In the course of its operations, Lucas UK Group are fully committed to protect the environment in all its undertakings and to ensure that compliance with all relevant statutory and regulatory requirements is ensured, particularly in regard to environmental legislation where a primary aim is the proper disposal of waste and avoidance of pollution to water, land or air in order to protect the environment from any adverse effect. All company personnel have a responsibility for quality and are required to conform to the quality procedures and as such are encouraged to inform the directors and contracts managers of any changes that could improve the quality of our services.

We strive to satisfy customers’ requirements with regards to all quality and environmental aspects. Alternative procedures to those stated, or otherwise required by the customer, shall only be used after agreement with the company’s management and after their effectiveness and control have been suitably demonstrated.

All the sections within our system are regularly independently audited to make sure we are adhering to the Quality system. The ultimate goal of the system is to produce an effective business model that will ensure that our clients receive a quality product and that we carry out the work as effectively as possible to enable us to maximise our profitability. In order to achieve the aims of this policy the Lucas UK Group Ltd maintains an Integrated (Quality and Environmental) Management System that meets the requirements of both ISO 9001:2015 and ISO 14001:2015 and which thereby ensures that:

• Our work is only carried out by competent and trained personnel • Responsibilities are understood and communicated • Quality and environmental objectives are continually monitored • Client perceptions are pro-actively sought and acted upon wherever necessary • Sustainability is a primary concern regarding purchasing of materials and waste disposal • The expectations of external 3rd parties and stakeholders are considered • Any business risks or opportunities for improvement are identified and acted upon

The outcomes and effectiveness of the management systems are subject to continual review by the Directors, as well as periodic audits, to ensure that the systems in place are both fit for purpose and provide a platform for continual quality and environmental improvement.” Furthermore, we strongly believe that the success of our business is measured within our company accounts, the repeat business and testimonials we get from our clients, lack of customer complaints and zero defects within our works. AUTHORISED BY:

D A Lucas Managing Director Lucas UK Group 7 January 2020


1.5 MANAGEMENT SYSTEM OVERVIEW The following high-level schematic shows the interactions of the core business processes and the management system of Lucas.

External influences and issues. Interested parties and their expectations Markets, clients, competition, innovations etc. Regulatory and legislation

Bid (9.0)

Clients

Internal Audit (12.0) Monitoring and measuring effectiveness of business, quality and environmental processes

Management Review (14.0) Reviews of business & environmental performance, risks,

audits, client feedback, non-conformities, incidents, corrective actions etc.

Performance measurement & review

Continual Improvement

Opportunities & Initiatives

(4.0)

Suppliers

Equipment purchases and

rentals, subcontract and other services as

required (10.0)

Deliver

Environmental Aspects, controls, incidents and legislation compliance (8.0)

Non-conformities & Corrective Actions (13.0) Including environmental Incidents

Leadership & Management Commitment

Policies, Business Context, Setting Objectives, Opportunities for

Improvement (1.0)

Managing Risk

Identifying risks to the business.

Risk based thinking applied throughout

(3.0)

Management of Resources/Documentation (5.0/6.0/7.0) Training, competence, reviews. Physical & IT infrastructure

External Resources

Client Perceptions Gathering feedback from clients and managing any complaints

(11.0)

Win

Finish


1.6 CORPORATE PLANNING & MANAGEMENT Interaction of Company Processes

The above diagram aims to visualise the PDCA model and show how we take a progressive view to our approach to the management of our IMS.


2.0 ORGANISATIONAL STRUCTURE, ROLES AND RESPONSIBILITIES

The head office of the Lucas UK Group Ltd is located at: 11 Invicta Business Park, London Road, Wrotham, Kent, TN15 7RJ

Lucas Organisation Structure


Roles and Responsibilities

The Lucas UK Group Ltd is structured so each department is controlled by a Manager who is ultimately responsible to the Managing Director. The roles assigned to Lucas UK Group Ltd personnel are as follows: Managing Director • Overall responsibility to establish, implement, maintain and improve the IMS. • Responsible for overall control of Lucas UK Group Ltd operations and procedures. • Responsible for the overall financial control of the Lucas UK Group Ltd, all capital and site

expenditure, Lucas UK Group Ltd accounting and management wage structure. • Responsible for the Lucas UK Group Ltd insurances including claims of public and employer’s

liabilities. • Ensure all legal requirements are met. • Ensure compliance with the Health & Safety at Work Act and various other regulations. • Responsible for the implementation of the Lucas UK Group Ltd’s health & safety and

environmental policies • To approve and authorize the Integrated Management System (IMS) • Ensure the Lucas UK Group Ltd IMS is implemented and maintained by the SQE & Operations

Director. • Refined procedures • Run a tight ship • Target right projects • Drive margin not turnover • Settle down as strong team • Stay focused on delivery, quality & service • Enjoy what we do • Never get complacent • Maintain financial strength Commercial Director • Supports Lucas UK Group Ltd operations by maintaining office systems and supervising staff. • Alongside other staff to maintain the upkeep of Quotation records • To produce client quotations • Responsible for selecting, approving and reviewing subcontractors and suppliers from the Lucas UK

Group Ltd.’s approved lists • Targeted, organised and responsive bidding • Refine commercial procedures • Refine purchasing • Monthly reports/cashflow management • Review T's&C's/payment notices in line with current Payment Act • Establish clear structure and responsibilities • Team development • Build choice, capability and commitment in supply chain Finance Director • Supports Lucas UK Group Ltd operations by maintaining office systems and supervising staff. • Responsible for Lucas UK Group Ltd accounts • Tradex for TP and Dulux • Continued team development/capability • Auto enrolment


• Liaison with the Bank, Accountants, HR Consultant and Insurers Head of Logistics • Supports Lucas UK Group Ltd operations by maintaining office systems. • To manage waste transfers in line with our regulation and our objectives. • Streamlined procedures to maintain all facilities including new Innovation Centre and Museum • Encompass and develop joinery workshop resource into logistics team Inc. spray booth training • Ongoing team development on procedures, responsibilities and systems i.e.. running tight ship on

spray booth and workshop planner, org chart board and job descriptions • Review/implement vehicle fleet requirements • Maintain stock budget control Head of Accounts & Human Resources • Supports Lucas UK Group Ltd operations by maintaining office systems. • Responsible for the Lucas UK Group Ltd personnel contracts of employment and HR • Tradex for TP and Dulux • PO App with photo • Streamline on-boarding/timesheet procedures • Continued team development/capability • Auto enrolment • All HR documentation reviewed/updated Accounts Assistants • LFS Accounts and Purchase orders • LFS and LFO wages • LFS and LFO sub-contractor queries/updates • Lucas app clocking in and out • Credit card reconciliation Head of Business and Project Support • Supports Lucas UK Group Ltd operations by maintaining office systems. • Maintain training budgets/training requests and reviews/Mace Business • Continued team development/capability • Client Feedback/Drive continued customer feedback • Support/Establish wider safety responsibilities • Site Safety Inspections/requests and upkeep • SQE/Mental & Wellbeing Bulletins, Notices and Toolbox Talks • Painting Method Statements, Quality Plans, ITP’s, COSHH Assessment developing • Pre-Qualification Assessments • LFS Tenders • H&S Intranet maintenance and review • Awards/Events/McLaren Technology Centre coordinating • Branding/Branded stationary/clothing Business and Project Support Assistant • RAMS Registers & Toolbox Talks –Fortnightly • Operations and Maintenance Manuals • Training bookings and CITB • Painting Method Statements, Quality Plans, ITP’s, COSHH Assessments • Environmental/Sustainability reporting -painting • Operations and Maintenance Manuals


• Contractor Submittals i.e. Tech subs, samples, schedules • Lucas Safety Cards • LFS Tenders Document Controller • Site Inductions/deliveries • Contractor Submittals i.e. Tech subs, samples, schedules • Painting Method Statements, Quality Plans, ITP’s, COSHH Assessments • Site stationary requirements • LFO and Painting Site Files • Lucas Safety Cards • LFS Tenders • LFS & LFO web-based systems Head of Innovation, Digital and Marketing • Supports Lucas UK Group Ltd operations by maintaining office systems. • Website Maintenance • Resource planning • Social media strategy • ProTools to retail market • Lucas Breathe/BLF and Teamstore • Lucas Team/Entropy and Concierge app • LFS and LFO Capability documents • Bespoke signage/presentations IT Support Assistant • Lucas app • New email addresses/email groups/email signatures • Logins and Passwords • Site IT Equipment i.e. printers, tablets, laptops • Intranet • PC Issues • Site IT equipment i.e. printers, tablets and laptops • Technical support

Digital and Marketing Assistant • Social media • Video productions • Support marketing activities • Bespoke presentations • LFS/LFO capability documents SQE & Operations Director • Internal auditing of the environmental management system. Advise and assist management and staff

regarding environmental matters • Responsible for ISO Audits both internal and external • Supports Lucas UK Group Ltd operations by maintaining office systems. • Monthly reports to include S, Q and E KPIs • Consider amalgamated ISO system to incorporate 18001 / 45001 for safety once transitioned to ISO

9001/14001 2015 models • Maintain, review and audit FSC control


• Additionally, the SQE & Operations Director is to maintain sufficient systems and procedures to ensure the continual successful registration and certification to the following bodies which in part assess our Health Safety & Environmental performance. o ISO 9001 o ISO 14001 o FSC o FORS – Silver o Dulux Paint Partnership o Achilles Building Confidence o SSIP via SMAS o ConstructionLine o Waste Carrier Licence

Operations Directors • To consider environmental aspects and impacts of materials chosen to meet customers’ requirements. • To ensure that sufficient and accurate information is included in method statements to enable minimal

environmental impact when carrying out work, in particular, with regard to use of materials, disposal of waste, and dealing with accidental spillage.

• Supports Lucas UK Group Ltd operations by maintaining office systems and supervising staff. • To instigate annual appraisals and maintain records • To ensure the Quality Management System is adhered to • Responsible for Lucas UK Group Ltd accounts • Monthly senior management project tours • Ongoing development of site managers • Refine spraying division/structure Senior Commercial Manager • To consider environmental aspects and impacts of materials chosen to meet customers’ requirements. • To ensure that sufficient and accurate information is included in method statements to enable minimal


• Supports Lucas UK Group Ltd operations by maintaining office systems and supervising staff. • Alongside other staff to maintain the upkeep of Quotation and purchase spreadsheet • To produce client quotations • Responsible for selecting, approving and reviewing subcontractors and suppliers from the Lucas UK

Group Ltd.’s approved lists • To ensure the Quality Management System is adhered to Head of Fit Out • To consider environmental aspects and impacts of materials chosen to meet customers’ requirements. • To ensure that sufficient and accurate information is included in method statements to enable minimal

environmental impact when carrying out work, in particular, regarding use of materials, disposal of waste, and dealing with accidental spillage.

• To ensure the Quality Management System is adhered to • Develop S/PM capability/responsibility for “whole project” • Develop managers/supervisors • Refine design procedures and design team capability • Refine project reporting format with PMs • Maximise fit out team input into bids • Build choice, capability and commitment in supply chain • Establish impactful bid/capability document


Contract Managers, Site Managers and Foremen • To consider environmental aspects and impacts of materials chosen to meet customers’ requirements. • To ensure that sufficient and accurate information is included in method statements to enable minimal


• To order materials in quantities and package sizes optimised to reduce waste in the form of unused material and of packaging.

• To ensure that materials are used in accordance with:

a. supplier’s recommendations, b. safety data sheets, c. method statements and d. COSHH assessments

• To ensure that any environmental protection measures required for operations and foreseeable

emergency situations are in place. • To communicate the requirements of the environmental management system to staff and any

subcontractors in the course of their work. • To communicate any incidents that may have environmental impact, or methods and examples of

good practice, throughout the company management structure. All Other Employees • To operate according to the requirements and spirit of the environmental management system • To communicate any occurrences that may have environmental impact, or methods and examples of

good practice, via the company management structure.

Subcontractors • Responsible for undertaking activities in a professional manner and to comply with all policy and

procedures as issued by Lucas UK Group.


3.0 RISKS TO THE BUSINESS Objective: To ensure that the Lucas UK Group Ltd operates an effective system for pro-actively identifying and managing perceived risks to the smooth running of the business, as well as to the environment. Process Owner: The Directors Risk based thinking is applied continually throughout the business and to its processes, and management have identified the potential risks that may pose a threat to the smooth running of the Lucas UK Group Ltd operation and have graded both the probability of each risk manifesting itself as well as the potential impact on the Lucas UK Group Ltd. Where appropriate preventive or mitigating actions have been implemented to reduce the level of risk to that which is deemed acceptable to the business. For major disruptive risks (e.g. denial of access to office) a Business Continuity Plan has been developed that sets out subsequent actions and responsibilities following such an incident. The currently identified risks are set out in the Business Risk Register, which is subject to periodic management review, and updated should conditions change. Process owners (as defined in this manual) are responsible for continually reviewing any specific risks that may be inherent in the owned process(es) and for ensuring that any mitigating or preventive actions are either implemented or proposed. Consideration of a risk may give rise to a potential opportunity for improvement, and so will be reviewed to determine what actions should be taken accordingly. Risks may also be associated with any changes made to the management system and therefore whenever significant changes are planned the management or change owner (see change process below) will consider and document any potential risks that could manifest themselves by virtue of the changes. Any such changes and their implications will be discussed at management reviews where the level of planning and controls required will be determined. Risks related to the environment are dealt with in the relevant sections of this manual. Lucas UK Group – 8 Steps for an Effective Change Management Process Lucas UK Group Ltd recognises that is constantly experiencing change. Whether caused by new technology implementations, process updates, compliance initiatives, reorganization, or customer service improvements, change is constant and necessary for growth and profitability. A consistent change management process will aid in minimizing the impact it has on our company and staff. Below you will our find our 8 essential steps approach to ensure our change initiative is lean and successful. 1. Identify What Will Be Improved Since most change occurs to improve a process, a product, or an outcome, it is critical to identify the focus and to clarify goals. This also involves identifying the resources and individuals that will facilitate the process and lead the endeavour. We acknowledge at this stage that knowing what to improve creates a solid foundation for clarity, ease, and successful implementation.


2. Present a Solid Business Case to Stakeholders Upper management who both direct and finance any new endeavour, champions of the process, and those who are directly charged with instituting the new normal. All have different expectations and experiences and therefore we will ensure that a high level of "buy-in" from across the company is expected and achieved. The process of onboarding the different parties varies with each change framework, but all provide plans that call for the time, patience, and communication. 3 .Plan for the Change This is the "roadmap" that identifies the beginning, the route to be taken, and the destination. We integrate resources to be leveraged, the scope or objective, and costs into the plan. We understand that a critical element of planning is providing a multi-step process rather than sudden, unplanned "sweeping" changes. This involves outlining the project with clear steps with measurable targets, incentives, measurements, and analysis. We will apply universal caution to practice patience throughout this process and avoid shortcuts. 4. Provide Resources and Use Data for Evaluation As part of the planning process, resource identification and funding / contractual negotiations are crucial elements. These can include infrastructure, equipment, and software systems. We also consider the tools needed for re-education, retraining, and rethinking priorities and practices. Identify and gathering data along with its analysis is critical element. We use a lean management process to ensure clarity of clear reporting on progress, allowing for better communication, proper and timely distribution of incentives, and measuring successes and milestones. 5. Communication This is the "golden thread" that runs through the entire practice of change management. We fully recognise that identifying, planning, onboarding, and executing a good change management plan is dependent on good communication. There are psychological and sociological realities inherent in group cultures. Those already involved have established skill sets, knowledge, and experiences. Providing clear and open lines of communication throughout the process is a critical element in all our change management challenges. We advocate transparency and two-way communication that provide avenues to vent frustrations, applaud what is working, and seamlessly change what doesn't work. 6. Monitor and Manage Resistance, Dependencies, and Budgeting Risks Resistance is a very normal part of change management, but it can threaten the success of our change projects. Most resistance occurs due to a fear of the unknown. It also occurs because there is a fair amount of risk associated with change – the risk of impacting dependencies, return on investment risks, and risks associated with allocating budget to something new. We will seek to anticipate and prepare for resistance by arming leadership with tools to manage it, in order for a smooth change lifecycle. 7. Celebrate Success Recognizing milestone achievements is an essential part of any project. When managing a change through its lifecycle, we understand it’s important to recognize the success of teams and individuals involved.


8. Review, Revise and Continuously Improve We recognise that change is difficult and even painful, it is also an ongoing process. Every change management strategy has the potential to need to be adjusted throughout a project. Like communication, we will endeavour to imbed this through all steps to identify and remove roadblocks. And, like the need for resources and data, this process is only as good as the commitment to measurement and analysis.


4.0 PERFORMANCE MEASURES AND IMPROVEMENTS Objective: To allow management the means of monitoring the performance of the Lucas UK Group Ltd at appropriate levels and to ensure that any opportunities for improvements are properly managed so as to benefit the Lucas UK Group Ltd and its stakeholders Process Owner: SQE & Operations Director Performance Measures and KPIs The Directors are committed to continual improvement, only by monitoring key performance measures (Quality, and Environmental) and reviewing outcomes to determine if the objectives within our IMS are suitable, adequate and effective, and whether any further continual improvement can be achieved. Factual data is gathered by monitoring and measuring the quality of its services, as well as environmental measures Current measures are listed in the KPI Log and are subject to management review to determine if targets are being met and if possible whether they can be further improved upon – i.e. raising the bar. Key IMS Objectives

Quality

• Have no customer complaints • Have a customer satisfaction score of over 80% on all elements of service provision • Maintain Site Health & Safety Audit scores of over 80% on all projects • Maintain an AFR of less than 1.00 • Close out 100% NCR within agreed timeframes • Maintain all accreditations and statutory inspection requirements within required timeframes

Environmental • Have no customer or landlord complaints • Have no enforcing authority action or proceedings • Have no spills • Maintain FSC accreditation in line with current FSC Chain of Custody requirements • Measure utilities usage to identify potential for un-identified or unexpected surge in demand

and to identify areas where spend to save opportunities may be appropriate. • Record vehicle usage carbon data for FORS • Reduce waste to minimums • Reduce waste to landfill quantities • Promote the use of environmentally friendly materials

Improvement Opportunities & Initiatives Opportunities for further quality or internal efficiency improvements, as well as environmental, may become evident at any time, or may arise through consideration of a risk. Improvements may also be proposed by staff. Any such improvement opportunities and their associated objectives or outcomes will be reviewed and implemented according to their merits.


Any one-off improvement initiatives are recorded using the Improvement Opportunities & Initiatives Tracking Log with progress monitored via management review. The entry in the Log will indicate if an improvement opportunity has arisen from an identified risk.


5.0 HUMAN RESOURCES MANAGEMENT AND COMMUNICATIONS Objective: To manage the Lucas UK Group Ltd.’s human resources in the most effective way such that the required levels of service and environmental care are consistently met. Process Owner: Head of Accounts & HR (HofA&HR) / Head of Project Support & Training

(HofPST) Personnel are employed based on their existing skills, knowledge and experience in similar marketplaces as required. This is evidenced through a combination of personal CV, previous employer references and appropriate qualifications and skillsets. Roles and responsibilities are defined in Job Descriptions (see 2.0) and job holders are expected to work within their areas of expertise.

5.1 TRAINING The company has documented requirements for training and certification for all staff in order to promote competence. Training can take the form of external class based, on-line, or internal on-job familiarisation and may be necessitated by any of the following:

• Appointment of new personnel • New working practices • Change of duties or responsibilities • As a result of an appraisal, audit or review • Expiry date of existing certification • Change of or new legislation

The HofPST is responsible for maintaining the electronic employee Training & Development matrix and updating the intranet Skills Framework database as new qualifications are gained or other changes occur When a need for further employee training is identified (e.g. certificate expiry), the HofPST arranges for the appropriate training via the Provider. As a part of the contracting procedure, subcontractors working for the Lucas UK Group companies shall be required to complete a questionnaire. This requests a copy of their health & safety policy, their arrangements for the management of quality assurance and their environmental impact. They shall be required to work under the supervision of the company's management structures. Both Office and Site staff shall receive training in order to satisfy competence at their appropriate level.


5.2 PERFORMANCE REVIEW An annual appraisal of each employee’s job specific work elements is undertaken by the relevant Department Manager, using the Annual Performance Appraisal Form. Details of the review dates of appraisals are logged on the Employee Training Database. Where new training or re-training is identified the requirement will be passed to the HofPST for arranging. Staff may raise issues pertaining to skills, training and competence during the reviews or at any other time.

5.3 NEW EMPLOYEES Our HofA&HR oversees the ‘onboarding’ process of all new employees. All new employees will be issued with an Offer of Employment Letter, Contract of Employment and an Employee Information and Detail Request Form to complete, sign and return. They are also provided with a Lucas UK Group Ltd Information & Policies Document.

New employees are given a copy of our Employee Handbook as part of their induction package and are a made aware of the contents of both our IMS Manual and our Health, Safety and Environmental Policy document, and where appropriate our Driving Policies.

Changes to policies and IMS requirements are disseminated via Directors and Managers via differing appropriate methods, eg emails, posters staff briefings, safety notices, Toolbox Talks, meetings and Company events etc.

The employee is required to sign the Personnel Induction Check List to confirm their understanding of its content. Induction documentation contains information on relevant forms to be completed by employees during their employment, such as those relating to holiday requests, sickness, Lucas UK Group Ltd vehicles, expenses, timesheets etc. The relevant department Manager will undertake and complete a Probationary Appraisal Form with the new employee after their 6-month probationary period.

5.4 ORGNAISATIONAL KNOWLEDGE Often activities undertaken allow knowledge to be gained via experience, where perhaps it may not have been foreseen: Internal sources of knowledge and information may come from:

a. requirement changes b. near miss, incident, accident c. conducting specialist work activities d. intellectual property


e. from addressing changing needs and trends f. lessons learned from failures and successful projects g. capturing and sharing undocumented knowledge and experience h. the results of improvements in processes, products and services;

External sources of knowledge and information may come from:

a. standards b. academia c. conferences d. gathering knowledge from customers or external providers and suppliers

Where we identify gaps in our knowledge training will be arranged to fulfill the requirement. Lucas UK group will aim to capture this information for future reference and where applicable issue timely bulletins for wider consumption. This information can then be used and shared to achieve our objectives. A central record shall be maintained for ease of reference to assist in planning and execution of future projects.

5.5 INTERNAL AND EXTERNAL COMMUNICATION Internal Communication The Directors ensure that all staff are made aware of any changes to Lucas UK Group Ltd policies or the requirements of the management systems, along with any other important information, via a variety of media which may include; emails, notice boards, memos as well as ad-hoc staff meetings if necessary. The office layout is open plan, and the Directors operate an “open door” policy which generally allows for ease of communications in either direction. Information about our IMS and specifically all environmental aspects (including any occurrences that may have environmental impact, or methods and examples of good practice) is freely communicated throughout the Company via the supervision and management structure. These will be subject to regular update and communication to all employees to ensure that the IMS, its objectives, the contributions employees are needed in participation to its success along with any implications of non-conformance. The Lucas site manager’s handbook contains a copy of the HS&E Policy, and an induction checklist, which details general environmental procedures and standards. These are discussed with all operatives during induction training for each site, and the induction training register forms a record of this training. Any additional information specific to a particular job (for example, particular waste disposal arrangements, or information regarding environmental aspects and potential environmental impacts particular materials and processes to be used) is detailed in the relevant method statement and COSHH assessments. The method statement briefing training register forms a record of this training. Both Office & Site staff shall receive appropriate training in line with their environment and the expectations required of them.


An internal system is used by Senior Management to issue regular bulletins, instructions and news items to all staff whenever appropriate External Communication We communicate our integrated quality and environmental policy to external interested parties as it wishes to demonstrate a high standard of social responsibility where environmental issues are concerned. External communication of our Integrated Q&E Policy is delivered via the Lucas UK Group Ltd.’s own web site, as well as any other public locations that may be appropriate including the Lucas UK Group Ltd.’s offices. On request we will communicate copies of any relevant IMS and specifically environmental information documents other than any of a confidential nature.

a. The Companies HS&E Policy is available to all via the Company’s web site.

b. Method statements and COSHH statements (which detail waste disposal arrangements, and when relevant, provide information regarding environmental aspects and potential environmental impacts materials and processes to be used) are offered to customers for approval.

Any form of documented external communications or records received regarding the IMS from an external interested party are maintained on file.


6.0 INFRASTRUCTURE RESOURCES MANAGEMENT Objective: To manage the Lucas UK Group Ltd.’s infrastructure in the most effective way such that these resources assist Lucas UK Group Ltd personnel to achieve their business and quality targets Process Owner: SQE & Operations Director / Logistics Manger

6.1 PHYSICAL RESOURCES AND WORKING ENVIRONMENTS The physical infrastructure that is necessary to support the business comprises the Head Office at Invicta Business Park, Wrotham, Kent. Employees are encouraged to provide feedback to management on any concerns related to the work environment at each office site, which the Directors have determined are conducive to the nature of work being carried out. A significant amount of work is carried out in the field and the nature of sites under investigation can vary greatly, and often include working in the vicinity of other construction trades. Site health & safety assessments are made prior to work commencing at any site and appropriate PPE is always worn. Periodic working environment inspections are conducted by Directors, Contracts Managers, Site Mangers and our Safety Team. Designated senior members of staff (both within the office and at site) are trained to undertake various environmental management and health and safety responsibilities that include but not limited to:

• Providing first aid • Undertaking Fire Warden Duties • Issuing, maintaining and periodically reviewing PPE • Face Fit training & testing • Carrying out periodic environmental and site safety surveys

Any significant issues or proposed changes will if necessary be raised with all personnel prior to any action being taken. Actions arising from any concerns will be noted accordingly during subsequent management review meetings. Whilst at work all staff are subject to UK Health & Safety regulations, as well as any other applicable environmental legislations, plus any local or survey site requirements. Our Health Safety & Environmental Policy document describes how HS&E is managed both within offices and at project sites. The Lucas UK Group Ltd makes use of a range of tools and equipment (i.e. assets) to carry out its operations both in office and the field, and these are managed so as to ensure that required Assets are always available and operational when needed, safe to use and where applicable in date for any required statutory inspection and test. Lucas UK Group Ltd vehicles are provided for operational use and it is the responsibility of the HofA&HR and the Logistics Manager to ensure that all vehicles are serviced according to manufacturers’ specifications and that all paperwork is in order and maintained. The SQE and Operations Director maintains all systems to ensure we remain FORS compliant.


Employees are encouraged to minimise as far as possible the use of resources (e.g. electricity, water and gas etc.) and to ensure that general office waste is disposed of in an appropriate manner, as well as according to any specific waste regulations. Wherever necessary, systems or procedures are put in place to ensure this remains legally complaint and is adhered to (See Environmental Aspects & Impacts, 8.1).

6.2 IT INFRASTRUCTURE The Lucas UK Group Ltd is highly dependent upon its IT infrastructure for the operation of its business and this is maintained by Utilize our 3rd party support organisation. Internal interaction with Utilize is managed and authorized by IT Support Manager To ensure resilience the working directories on the server and cloud drive are backed up daily to Utilize systems.


7.0 MANAGEMENT OF DOCUMENTATION RESOURCES AND CONTROLS Objective: To ensure that all documented information used in the management of the business is managed so as to ensure that the business and its systems can be operated in the most efficient manner, and provide evidence of doing so. Process Owner: Managing Director

7.1 GENERAL DOCUMENTATION MANAGEMENT The Management System comprises any documentation needed to operate, control and measure the business and its internal processes and that is essential for its efficient operation. These may include, but are not limited to, operational procedures, instructions, checklists, drawings, forms and records, as well as any statutory or regulatory policies or guidelines etc. that are generated externally, but with which the business must either comply or be aware of. The level of documentation used to support the business is that which the Directors have determined is that required to ensure effective management control and visibility, whilst incurring minimal administrative overheads. The level of detail within procedures, or even the need for a procedure at all is a risk-based judgement that takes into account the complexity of the process and skills of the person carrying out the work in question. All controlled documents are listed and allocated a unique number. Their issue and distribution are recorded on the Master Record File which is maintained by the SQE & Operations Director / Hof PST. An electronic version is held on the server as “read only” for reference and information. Any amendments will be advised to all departments concerned via email. Copies of superseded documents are retained for one year, unless there is a legal requirement stipulating otherwise. The control and update of technical, financial and legislative information shall be available in the relevant department and dealt with as follows:

• Product and technical information to be controlled and updated by the Directors • Financial and Employment legislation to be controlled by the Finance Director • Project documentation to be controlled by the HofPST • Health and Safety Legislation controlled by the SQE & Operations Director • Account information controlled by the HofA&HR • Quality & Environmental documentation controlled by the SQE & Operations Director

Technical and legislative information sourced by virtue of Professional Body memberships is disseminated throughout the Lucas UK Group Ltd at regular staff meetings and where appropriate documents are published on our intranet. A Legal Register outlining requirements and how Lucas UK Group discharge these duties will eb maintained by the SQE & Operations Director.


Project specific documentation is held electronically in a file set up under the unique project number, where hard copies are required these are controlled accordingly via the HofPST. Issued copies are not subject carry the annotation of ‘not subject to update’. All correspondence received into the Lucas UK Group Ltd by post is date stamped on receipt, however the majority of client enquiries are received by telephone or email. Quality Assurance Document Control and Forms

• The purpose is to ensure that essential documents and data relating to the management of the company, including health, safety, quality and environmental management systems are maintained and controlled.

• Responsibilities lie with the Directors, Contracts/Project Managers, Site Managers and other

users of controlled documents.

Procedure: • The Managing Director will approve all documents prior to use. • The master of each internal controlled document is filed on the Lucas UK Group server in the

folder ‘controlled documents. The name of each document file contains the document reference number, the latest revision number and the date of the last revision. The footer of each document shall show the document reference number, the latest revision number and the date of the last revision. When controlled documents are revised, the previous revision is archived to the ‘obsolete documents’ folder.

• A copy of each controlled document is maintained up to date on the Lucas UK Group Intranet.

This forms the approved source of copies for use by Company personnel.

• Internal management forms are maintained separately for each project & are issued to site within the site file by a Director. All documents used will be legible & readily identifiable by use of individual job numbers. The upkeep of the forms on the site is the responsibility of the Foreman. These forms will be approved & checked by the Contracts Manager.

• External documents will be controlled by head office. They are date stamped when received

and issued to site by a Director if required. The Foreman must destroy Superseded documents within the site files. Superseded documents at head office are marked Superseded & archived by a Director.


Quality Records

• The purpose is to ensure that all quality records are returned to Head Office for storage/archiving in a suitable environment and in a manner allowing for easy retrieval.

• Responsibilities lie with the Director, Managers and Site Supervisors and/or nominated personnel.

Procedure:

• Files must be clearly named and marked

• Records will be held for 6 years at head office or the nominated archiving company, unless otherwise stated.

• The records maintained will include the following so long as they are applicable or exist:

a. Quality management records b. General Correspondence c. Training records d. Programme e. Specification f. Finishes Schedule g. Scope of Works h. Variations i. Purchasing information j. Customer comments and or complaints k. Financial details l. Quality Inspection Checklists m. Internal Audits n. Control of non-conforming products o. Corrective action p. Preventative action q. 6-Monthly Review of Current Legislation via our Legal Register

Environmental Assurance The following are documents and records considered to ensure the effective planning, operation and control of processes that relate to significant environmental aspects:

a. Method statements. b. COSHH assessments c. Method statement briefing registers. d. Waste transfer notes. e. Internal Audit reports. f. Minutes of Management review meetings. g. 6-Monthly Review of Current Environmental Legislation via our Legal Register


7.2 DOCUMENTATION UPDATES AND ISSUE Any personnel can propose a change to a procedure or document which then needs to be agreed by the document owner. If required, agreement will be sought from other relevant staff depending upon the scope and usage of the changes proposed. New IMS documents will be approved in the first by the Managing Director. The following points are taken into account when considering changes to documentation:

• Why make the change, what is the need, how will it improve things? • Will the change require any training of staff, or just communication of the change? • Will procedure changes require any monitoring?

The HofPST & HofA&HR are responsible for determining the distribution of documents and ensuring the Master Record File is updated, as well as distributing any amendments to holders of hard and electronic copies and ensuring obsolete documents are replaced with latest issues using the Integrated (Quality & Environmental) Management System Amendment Notice. The Master Document Control Record will also be updated to reflect the current document version number of all issued documents. The document will be marked with the revision status and date of issue. Superseded versions are kept in a file folder called “Obsolete Documents”. Any hard copies made are up to date at time of production but are uncontrolled. Method statements and COSHH assessments are approved before issue by the commercial director or commercial manager.

7.3 CONTROL OF RECORDS AND REPORTS Records can relate to any aspect of the business and its systems and will often provide evidence of performance or compliance with procedures and/or legislation and are therefore stored in such a way that they can be easily retrieved when needed. Records, in whatever format, are subject to an appropriate retention period as determined by either the Directors or by legislation. The following table summarises retention periods for categories of records used.

Record Description Maintained by Retention Period Enquiries & Quotes Relevant Dept. Manager Project Records Relevant Dept. Manager Accounts / Financial Records Directors / Accounts

Manager

Legal / Statutory Records Directors Quality& Environmental Records Office Manager Personnel / Training Directors


Copies of method statements, COSHH assessments, and internal audit reports are kept on site in the site file. These shall be transferred to the archive at the head office on completion of the contract, where they shall be available for reference.

7.4 DOCUMENTATION AND DATA SECURITY Any client or 3rd party data held by the Lucas UK Group Ltd is kept secure and handled in accordance with the requirements of the Data Protection Act and the General Date Protection Regulations. Once any client or 3rd party owned data is no longer required it is either returned to the owner or disposed of in such a way as to protect the integrity of all parties. Lucas UK Group Ltd sensitive paper-based records no longer required are destroyed by shredding. To protect data Lucas UK Group Ltd employs username and password authentication on desktop PC’s and laptops. All Lucas UK Group Ltd files are stored on a server at HO, and on a secure cloud drive provided by Utilize. Access to admin, HR and accounts files is restricted to the relevant personnel. Data backups are carried out daily Antivirus applications ‘Trustwave’ are used to protect systems and data from viruses, malware spyware etc. Remote scanning of all emails is also carried out by the internet service provider also using ‘Trustwave’. CD Rom held data is destroyed by physical destruction of the disc once no longer required.


8.0 ENVIRONMENTAL MANAGEMENT AND PLANNING Objective: To ensure that activities carried out by the Lucas UK Group Ltd are managed so as to minimise its impact on the environment in order to meet its Environmental Policy (which is an integrated part of our Health Safety & Environmental Policy). . Process Owner: SQE & Operations Director

8.1 ENVIRONMENTAL RISKS & OPPORTUNITIES (ASPECTS AND IMPACTS) OF THE BUSINESS The Lucas UK Group Ltd maintains a Risks & Opportunities (Aspects & Impacts) Register which holds a record of all environmental aspects, and related impacts, resulting from the activities and processes of the Lucas UK Group Ltd that have an interaction with the environment by virtue of the Lucas UK Group Ltd’s operations. The register denotes the significance rating of each Aspect based on the sum of the Probability and Severity ratings. The significant aspects are those rated 8 or above. The Lucas UK Group Ltd sets targets aimed at reducing (where practicable) its consumption of various non-renewable resources:

• Waste Disposal • Spray booth operations at Wrotham Logistics Centre • Transport operations • Air conditioning • Timber • Gas, Electricity • Water • Vehicle Fuel • Paper

Should a new Aspect or environmental risk be identified, or an existing level of risk change, then this will be raised at management review and the outcome acted upon and recorded as necessary The Risks & Opportunities (Aspects & Impacts) Register is subject to periodic review to determine if any updating is necessary due to changes in working conditions, infrastructure, legislation or Codes of Practice etc. Reviews will also determine if any targets can be improved upon, or alternatively whether any are consistently not being met and require some form of further action. Any changes or updates made to the Risks & Opportunities (Aspects & Impacts) Register are communicated to employees.

8.2 ENVIRONMENTAL LEGISLATION The Lucas UK Group Ltd is committed to maintaining an awareness of, and ensuring compliance with, all relevant legislation and Codes of Practice pertaining to its operations. Any changes in legislation are monitored by the SQE & Operations Director, but the use of a number of websites and auto email services.


Should changes occur, the Legislation Register will be updated as required and the changes communicated to employees. Our Legislation Register is subject to Bi-annual review, it seeks to identify applicable legal requirements and other requirements related to the company's H&S, Environmental and other legal aspects, and explains how the requirements apply to the company’s operational aspects. The group shall endeavour to remain informed regarding changes of legislation by means of the facility offered by the governmental agencies via the internet. This information shall be reviewed at each management review Any changes in environmental legislation will be reviewed against the Risks & Opportunities (Aspects & Impacts) Register to ensure they are taken account of where the relevant Aspects and Impacts are concerned. We shall ensure we work with any Regulatory Authority that may require us to take actions to ensure compliance is achieved.

8.3 EMERGENCY PREPAREDNESS The Lucas UK Group Ltd have made preparations related to a range of envisaged incident types at both its offices and any work site that Lucas UK Group Ltd personnel may attend. The nature of an incidents can vary but will often involve unplanned discharges, or an increased risk of this. Incidents may also threaten the health & safety of Lucas UK Group Ltd personnel and any others present. The actions to be taken in the event of an incident, whether at a Lucas UK Group Ltd office, or at a project site, are set out in the Emergency Plan. Following any incident an Internal Incident Report / Event Report Form must be completed and this forms the basis of the subsequent review leading to appropriate corrective and/or preventive actions. Typical incidents may include: First Aid incident, Fire and Spillage of Liquids. First Aid and Fire is covered by our HS&E Policy document. The Spillage of Liquids it is considered that this is very unlikely that such spillage would escape and to ground or water courses because the quantities used and stored are small and use his normally inside buildings. Any such spillage would be immediately cleaned up and any resulting waste would be dealt

8.4 MONITORING ENVIRONMENTAL PERFORMANCE The Lucas UK Group Ltd checks, monitors or measures its environmental performance using a variety of methods that are relevant to the particular aspect. As a minimum the Lucas UK Group Ltd monitors and measures its environmental performance via the KPIs or objectives it sets itself (see 4.0) as well as carrying out appropriate checks or measurements on other significant aspects.


The outcomes of the measuring and checking processes are recorded either via the Risks & Opportunities (Aspects & Impacts) Register or using another more appropriate means in order to show performance over time. Internal auditing and management review are used as a means of further verifying the usefulness of these measures. The company uses the environment agency’s website, and the CITB “Construction site safety (health, safety and environmental information)” publication and http://www.legislation.gov.uk/ to keep abreast of changes to environmental legal requirements. The internal audit evaluates compliance with the environmental management system, and thereby compliance with legal and other commitments. The regular Management review shall consider the internal audits, and general compliance of the environmental management system to the legislative requirements and any other requirements to which the Company is committed. The records of the internal audits and minutes of the management review meetings shall form a record of the periodic evaluations. LUKG aims to achieve the following environmental objectives:

• To reduce the amount of waste for disposal to as low a level as is reasonably practicable. • To promote awareness amongst all group personnel of the environmental aspects and impacts

of their operations, and the methods recommended to minimise detrimental impact

The methods by which these objectives can be achieved are outlined in section 8.5 “operational control”. Targets Target 1 - waste

• Unused product, now rendered unfit for use for reasons of remaining size, quantity or type, or • Packaging.

A measure of either volume or weight versus turnover, for example, would have little meaning, due to the variety of materials used. Even a comprehensive record of every piece of waste would be of little value. The variety of projects undertaken is such that figures that could result from a job where exemplary practices were followed could appear similar to those from another where less care was taken. The experience of the site managers is such that it would be clear to them if, with hindsight, the logistics of each project could have been handled any better in terms of quantities and package sizes ordered, or numbers of deliveries made. This is discussed and results recorded at each internal audit. Target 2 – Utilities i.e. Gas Electricity & Water consumption at head office The Use of gas is restricted to unit 6 for the spray booth operations and heating and to unit 14 for heating.

http://www.legislation.gov.uk/


Use of Electricity is low in relation to the size of the company. Use at head office and the logistics centre is limited to operation of computer systems, and small domestic items such as kitchen appliances. Use of Water is restricted to welfare use, it is not used for any commercial purpose. Head office and associated unit’s utility bills are monitored at internal audit. Utilities usage charts shall be reviewed at management review. The target shall be that usage should not rise significantly without good reason, such as introduction of additional facilities. Target 3 – Environmental management training All staff should be trained in environmental matters relating to each project at induction training. This training is specified in the Lucas induction training checklist, and in relevant project method statements, and recorded on induction training registers, and method statement briefing registers. Induction training registers are checked at internal audits. Target 4 – Promotion of Environmentally friendly materials The use of environmentally friendly materials is to be discussed with customers at the contracting stage of each project where appropriate. A record is to be made on the contract review form. Targets and objectives are discussed at management review.

8.5 OPERATIONAL CONTROLS The need for operational controls is determined according to the level of environmental risk and the nature of the process or work involved.

Where new projects are concerned, environmental assessments are carried out prior to commencement of work, and any further operational controls required are identified and form part of documents such as Construction Phase Plans (CPPs) or Risk Assessment Method Statements (RAMS), these are put in place as part of every project.

Purchases of materials or services will take account to any environmental aspects related to the product’s lifecycle, though the Lucas UK Group Ltd will not necessary carry out full end-to-end lifecycle analysis.

Controls can take the form of procedures, instructions or guidelines and the extent of these will be determined according to the nature and likely impacts of the risks involved.

The following operations are associated with environmental aspects:

• Cleaning of brushes and tools See Risks & Opportunities (Aspects & Impacts) Register of the group’s activities for procedures and controls. Instruction in these procedures and controls is given during induction training at each site.

• Dealing with unused materials

See “Environmental aspects and impacts register” of the group’s activities for procedures and controls. Instruction in these procedures and controls is given during induction training at each site.

• Disposal of waste materials, packaging, office waste and etc.


See “Environmental aspects and impacts register” of the group’s activities for procedures and controls. Instruction in these procedures and controls is given during induction training at each site.

• Operations at the spray booth facility

See “Environmental aspects and impacts register” of the group’s activities for procedures and controls.

• Control of goods and services purchased

Communication of procedures to sub-contractors and suppliers is achieved at time of purchase by means of verbal interaction and instructions on purchase orders and contracts. In addition, sub-contractors shall work under the supervision of the company's management structures.

As a part of the contracting procedure, subcontractors working for the Lucas UK Group companies shall be required to complete a questionnaire and to supply their health & safety policy, their quality assurance policy, and their environmental policy. They shall be required to work under the supervision of the company's management structures.

• Control of goods and services purchased

Communication of procedures to sub-contractors and suppliers is achieved at time of purchase

Other Controls can also take the form of visible signage and notices – e.g. labeling of waste bins.

8.6 COMMUNICATIONS & AWARENESS The management ensures that all Lucas UK Group Ltd personnel or subcontractors understand the nature of the environmental aspects of the Lucas UK Group Ltd and their potential impacts, and are expected to perform their jobs in such a way as to minimise such impacts, as well as being encouraged to identify and suggest further improvements. Any changes or improvements made regarding environmental management are communicated to all affected staff via the most appropriate means. Records of any communications between Lucas UK Group Ltd and third parties (stakeholders) regarding environmental issues are maintained on file to allow for ease of retrieval. The Lucas UK Group Ltd has made public its commitment to the environment via our web site as well as via other media as appropriate.


The following diagram describes the main elements of the environmental elements of our IMS, and their interaction with reference to related documents:

Consideration of which materials to use for each job.

Responsibility:

Commercial director/manager, in discussion with customer

Consideration of quantities and package sizes to purchase.

Responsibility:

Contracts managers, in consultation with site supervisors

Control of processes to reduce or avoid detrimental environmental impact, including consideration of foreseeable unplanned

occurrences or emergencies that may arise.

Responsibility:

Commercial director/manager, in discussion with customer

Records: Method statements; COSHH assessments

Disposal of packaging and waste material.

Responsibility:

Contracts managers, in consultation with site supervisors (disposal using site facilities);

Warehouse manager (disposal when returned to warehouse

Records: Transfer notes

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8.7 ENVIRONMENTAL MANAGEMENT POLICY STATEMENT The Lucas UK Group comprises two companies Lucas Finishing Specialists & Lucas Fit Out Ltd. Lucas Finishing Specialists is a major painting & decorating contractor and Lucas Fit Out Ltd is a major fit out contractor, both operating within the construction industry. The Lucas UK Group: • is committed to provide a framework for setting, achieving and maintaining its environmental

objectives and obligations • is committed continual improvement of the environmental management system to and take

opportunity to enhance our environmental performance and the prevention of pollution • is committed to the protection of the environment and minimise any detrimental impact on

the environment that may result from its activities, and to consider its performance in this regard, and opportunities for improvement on a continuing basis.

• Operates an environmental management system conforming to the requirements of BS EN ISO

14001 - 2015. • is committed to compliance with all applicable legal and other requirements. • is committed to open communication of its environmental policy, requirements and objectives

and performance throughout the organisation. Makes this policy available to all via its web site. This policy is to be reviewed, annually, in respect of changes to company structure, technological developments and identified omissions. Director ultimately responsible for Health Safety & Environmental matters Signature: Date: 01 June 2019

Print Name: Danny Lucas


9.0 THE MANAGEMENT OF BUILDING REFURBISHMENT AND ASSOCIATED BUILDING TRADES SERVICES OPERATIONS Objective: To ensure that the processes controlling the Management of Building Refurbishment and Associated Building Trades Services Operations are effective and deliver consistently high quality outcomes to the complete satisfaction of clients. Process Owner: The Directors This section contains or refers to the procedures that describe the operational and business processes of Lucas UK Group Ltd in order to meet its business objectives. The performance and outputs of the various processes are continually monitored in order to ensure that the planned results or outcomes are met. This may be done either by specific output measures (quality and environmental) associated with key processes, via internal audits, through customer feedback or by observation. The routine engagements of new clients is normally considered to incur a relatively low level of risk, however risk based thinking is embedded across the entire operation such that management and staff are constantly aware of risks to the integrity of services provided, as well as the business as a whole. Should any new or increased risks be identified these will be referred up to the Directors where they would be noted at management review and if appropriate recorded in the Risk Register. All business processes are interrelated in that they form part of an overall management system, therefore a deficiency or failure in one area may potentially have a detrimental effect on another which in turn may impact customer service levels or environmental performance. The Management System Schematic shown in 1.5 describes how the various system elements are integrated. The process flows shown in the subsections below constitute high level procedures and, where appropriate, refer to more detailed procedures held outside this manual. There are four main sections that encompass our process, these are known internally as: 1. Bid Stage 2. Win Stage 3. Deliver Stage 4. Finish State

Where any specific environmental controls are necessary these are, wherever possible, incorporated into normal operational procedures.


9.1 BID STAGE The following flow shows the High-Level process involved from customer enquiry through to quotation acceptance or rejection.

This is further broken down as follows to give focus and to encompass the Lucas Lean approach:

Bid Step 1 Step 2 Step 3

Receive enquiry Tender period Submit tender PQQ Enquirers out Agree financials

Bid or no bid Queries raised In what format Have we got the resource Mid bid Establish retentions Does it suit the pipeline Enquires back Saved on Server & Office Hard Copy

Put on tender log Put together Followed up If lost enquiry scrapped

Quote Verification Quote is give a unique number and

checked/reviewed by Director.

Client

Quote Delivered Quote sent to the client along with

Terms & Conditions

Project Setup Process (9.2)

Defined Requirement Where client requirement is clearly defined job is costed based on external resource charges (tools, materials,

subcons etc.) plus internal rates and margins.

Outcome only Defined Where client requirement is expressed only in terms of

end result, further discussion with client is required to

ascertain info regarding site, planned developments etc.

Quote Rejected Rejected Quotes are noted on Accounts

System.

Quote Follow-ups Outstanding Quotations

periodically followed up with Client/Prospect

New Enquiry or Client Order

Quote Accepted On receipt of Quotes acceptance, and/or

Purchase Order the Quote is cross checked against the requirements by a Director or the Senior Commercial

manager.


• Receipt of Enquiry - Enquiries are solicited by marketing and sales effort. An informative and visually effective website is maintained, including details of contacts for clients and examples of projects. There is frequent communication with existing and potential clients, through which awareness of potential future projects are maintained.

• Decision to price or tender – taken by Director. Decline in writing or by phone.

• Price enquiry – Arrange site visits, sub-contact enquiries and material prices as necessary.

• Submit tender – file in alphabetical order

• Enquire of success of tender

• Enquire as to the progress and success or otherwise of the tender. Tender will be scrutinized

by client. If tender is successful, an order will be dispatched. • Receive and accept order – order will be reviewed by the Director. This will highlight any

outstanding information required from the client and any information that Lucas need to provide.

• Enter job details into the computer system – construct and generate the job number.

• Agree a start date – obtain any outstanding information and requirements from the contract

review. Arrange a pre-start meeting if necessary and attend the meeting with the Contracts Manager.

• Set up a head office file for the contract and site files, both of which will include the following:

a. Contract Review Form b. Scope of works to be done c. Specification d. Finishing schedule/drawings e. Programme f. Tender breakdown

• More specifically, the site files will include but not limited to the safe systems of work, risk assessment and COSHH Assessments. Copies to be kept in the site file


9.2 WIN STAGE The following flow shows the High Level process involved from tender award and encompasses the pre-construction activities.


Win Step 1 Step 2 Step 3 Step 4

Post Tender Interviews Pre Start Meeting Start Up Design & Procurement Who goes Who goes Who attends TES / wallpaper Schedules

What is our agreed angle What do we clarify What checklists do we follow Programme What do we capture /

document What do we capture /

document Actions arising / setting Up

files (soft & hard) Design checklist (tec Subs,

samples, RFIs Dwgs) Actions arising Contract review Trackers & reports Job announcement Scan contract Material requisitions & call offs

Job no (all ret jobs – new Job no)

Post Tender Interviews

Pre Start Meeting

Start Up

Requests for Information and Design Queries & Variations

Design & Procurement

Tender Award

Client


• On some projects, Lucas UK Group shall be required to provide designs of some details in accordance with the client’s design scheme. The Client normally provides architectural drawings that specify the layout and type of all construction elements (such as windows, doors and partitions) and specify all finishes. Lucas UK Group might typically be responsible for such things as:

• the layout and design of systems such as plumbing and electrical work, that would connect to

service outlets as specified by the client.

• the detailed structure and fixing arrangements for partition walls, windows, built in furniture, cabinets etc.

• This type of work falls within the expertise of competent tradesman, and the subcontracting

firms that Lucas UK Group would employ. • In some cases, detailed drawings shall be required. These shall be produced in association

with relevant competent sub-contractors, possibly including suppliers and architects. These organisations shall be chosen from the Lucas UK Group list of approved subcontractors, and so shall be subject to checks on their competency as described in the Lucas UK Group health and safety policy and procedures manual.

• The Lucas UK Group Project Manager, in consultation with senior management, may decide

that Lucas UK Group should verify that elements of the design are structurally safe; for example, tests may be required to ensure that fixings shall safely carry the specified load. Testing on site may in some circumstances be required. Lucas UK Group shall entrust any such verification work to competent subcontractors or suppliers. Records of any such work would be maintained in the site file.

• In-house verification of the design shall be by the Project Manager, in consultation with

subcontractors, architects, and senior management as applicable. It must be verified that the design meets the specification, and all legal requirements. When satisfied, the designs shall be offered to the client, who shall approve them. If the customer uses an electronic project documentation management system (such as “BIW”), then the approval status shall be recorded here. Otherwise, the client’s representative shall sign the drawings to record the approval, and copies shall be retained in the site file.

• Final validation of the design shall be deemed to be complete when the finished work is

handed over to the client and approved by them. Form 4.2 “inspection checklist”, signed by the Lucas UK Group Project Manager (or his delegated representative) and the client (or their representative) forms a record of the validation, and is retained in the site file.


9.3 DELIVER STAGE The following flow shows the High-Level process involved from tender award and encompasses the pre-construction activities.


Deliver 1 Step 1 Spans deliver duration Spans deliver duration Spans deliver duration

Set Up Site Document Control Work On Site Project Reporting

Site Files / Intro / Handover Conject / YJ / Who Inductions Open items / key issues/ drop line on programme

Site packs, office, eqpt Uploads / approvals DABS/PPE/RPE/FaceFit/RAMS/TBTs Plant returns

Initial plant, materials etc Downloads / distribution Clocking in / out & wage sheets TBTs & RAMS registers PPE O&Ms / as builts ITP / QA Environmental returns

Lucas project folders on server and hard copy files Production

Standard Filling system Housekeeping Short term programmes

Post Tender Interviews

Pre Start Meeting

Start Up

Requests for Information and Design Queries & Variations

Design & Procurement

Tender Award

Client


Deliver 2 Spans deliver duration Spans deliver duration Spans deliver duration Spans deliver duration

Safety Control S/C Control Purchase Control Commercial Control

CITB training Plan Start up meetings / firm orders & terms PO procedures Budgets & EDF

Daily AFR count Copy orders on site Attach quotes Monthly valuations & IPCs (up & down)

TBTs & RAMS registers Vo control Panning POs (avoid repeat / small orders) Valuation control

Safety visits & tours Valuation / IPC control Requisition planning Final accounts (up & down) Audits & reports Safety Ordering materials Monthly reporting

Clocking in / Out Liaison with accounts (vals / IPC / invoices)

Quality Daywork control s/c retentions Retention schedule Pipeline& workload planner

Deliver 3

Spans deliver duration Spans deliver duration Spans deliver duration Spans deliver duration Finance Payroll & HR Control Logistics Control Spray Booth Control Joinery Workshop Control

Onboarding Inventory / asset register / stock / T Cards / PA Testing Job sheets Job sheets

Weekly & monthly payroll Site Plant requests & Site deliveries Work planner Work planner

Credit control Plant delivery notes Stock control Stock control PO/PL/S/C Liabilities Plant transfer notes Stock ordering Stock ordering

Banking Site collections Eqpt testing & maintenance FSC CIS /PAYE Eqpt Maintenance Eqpt testing & maintenance

Cashbook / Cashflow Waste transfers VAT returns FORS

Daily monthly reporting Staff contracts / Company

Handbook

Holiday Planner / logging Client retentions

Project Setup Process The following flow shows the project setup process

Allocation of Project Lead Project allocated to a Director who allocates

contract manager

Project Admin PM converts Quote to project number

All correspondence copied to Project File

Project Directory

Project Controls Setup PE verifies accuracy of Project Brief, and

any changes, and completes Project Control Form which holds target dates and identifies technical resources to be used.

From Quotation Process

(9.1)


• Make Sure job is ready for work to commence prior to committing resources.

• Arrange labour (including foreman) and plant materials.

• Ensure competence of staff and subcontractors for the required work. Services form sub-contracting companies are subject to evaluation via the Lucas UK Group form 4.10 “Supply Chain Contractor Registration” and consideration of their response by reference to the competence checks as described in the Lucas Group health and safety policy and procedures manual. Approved sub-contractors shall be added to the approved subcontractor list. The list is maintained in electronic form, with facilities to record assessments of performance as they continue to work for the Company. Only approved sub-contractors may provide services to the Company. Self-employed individuals are required to complete form 4.11 “Registration form/Training record”.

• Products purchased are mostly proprietary branded products or building materials. The

Principle Contractor or client shall usually determine the specification of products for a project, often in consultation with Lucas UK Group Ltd. The project management team shall purchase products for projects from suppliers with which Lucas UK Group has set up an account. The person making the purchase on behalf of Lucas UK Group shall evaluate the supplier by means of enquiry direct to the supplier, and/or by reference to their marketing information. The supplier shall be selected based on their ability to supply the required specification of product or service:

RAMS passed to client and Subcons

Client

Risk Assessments PE carries out site specific risk assessment

and produces RAMS and other docs depending on whether Company is main

contractor or act as subcontractor.

Desk Study & Data Review Process

(9.3)

Resources & Procurement PE allocates appropriate Company

personnel and sources external contractors, orders plant etc. Purchase Orders placed

on Contractors and suppliers.

Resources & Procurement

Resources & Procurement Site Manager will carry out the H&S site induction on arrival at site for all who may

attend site during project.

Unforseen Hazards If unforeseen conditions are subsequently identified on-

site the SM makes additions to the RAMS and

communicates the findings with those affected


a. in the required quantities, b. to the acceptable timescales, c. at acceptable cost.

• The purchase order forms a record of this evaluation. The Lucas UK Group purchase order

shall include the specification of the product. Exceptionally, products may be purchased from other suppliers on a cash basis, and in such a case, there shall be no purchase order, but specification shall be verbally agreed with the supplier

• Ensure foreman understands site file – That is finishes, specification and programme. Agree

rates, prices and targets for carrying out the work.

• Ensure that all labour is aware of the safety requirements and any hazardous materials on site before work commences.

• If required, produce control sample to ascertain exact quality requirements

• Regular visits take place to review or carry out the following:

a. Labour levels b. Labour performance c. Material flow d. Any defective materials must be dealt with in line with quality procedure 5.3 “control of

non-conforming Products and workmanship”. e. Plant levels and plant security f. Quality of work, including obtaining a written acceptance from the client g. Programme h. Availability of future areas and quality of preceding trade’s work i. Safety j. Variations – Agree value of variations or method of valuing them before proceeding. k. Resolve any local problems l. Report to Director regarding job progress and any problems. Keep director informed of

any changes to the contract m. Submit wage returns for labour every Wednesday morning n. Review the project with Directors every Friday morning at Head Office. o. Attend meetings as required by the client. p. Submit valuations in line with dates issued by the client and enter figures onto construct q. Reconcile suppliers and subcontractors’ invoices and make payments at the end of each

month r. Rigorously pursue any late or underpayments. When invoices are paid enter payment onto

construct s. Produce a cost and value report every month and incorporate in review meetings at Head

Office.


9.4 FINISH STAGE The following flow shows the steps involved for the completion of a project, and final payment request.

Finish Step 1 Step 2

Project Close Out Post Contract Snagging Chase retention

Off hire plant Paint storage Clear site Warranties / bonds

Archive paperwork Job Close off announcement Customer feedback / case studies

Retention period and defects close out MGD Certs

Lessons Learnt

• Ensure the following:

• Quality of the work – Obtain written acceptance of the work from the client by completion of

quality form 4.2 “Inspection sheet”. Communication with the client throughout the project should ensure the client’s satisfaction with the job. The client should be encouraged to add any comments to the form. These are important to ensure that customer satisfaction with product and service is reviewed, and to enable continuous consideration of ways to improve.

• At the completion of the project, the directors and managers involved review all aspects recording the results on the Lucas Group intranet “project close out” facility. Aspects reviewed include the performance of: a. the customer, b. each sub-contractor, c. and each supplier.

End of Project

Request for Payment The Director submits Sales Invoice, either

hard copy or electronic, to the client on completion of project, or at agreed point.

Request for Payment Received payment posted onto the

Accounts system as well as any retentions, exceptionally.

Overdue Payments The Company Secretary is responsible for chasing any

overdue payments.

End


• The review of subcontractors includes assessing their competence. Information may be recorded on the subcontracting firms list (spreadsheet) so that it may be used to influence selection for future projects.

• Feedback is solicited from customers, verbally on site, and meetings with the client that may occur, and where appropriate by telephone calls to customers by Lucas staff.

• Customer satisfaction is also monitored by means of form LUKG/IMS/Form11-4 the “private clients sign off sheet”, which has a questionnaire and space for comments and suggestions.

• Many customers send in unsolicited testimonial letters, which are also monitored as a measure of customer satisfaction.

• All waste materials are cleared from the site and that any surplus is removed to the stores at the company warehouse.

• All unused materials are accounted for and returned to the stores or transferred to another

job. • Plant and equipment is accounted for, and returned to stores, to the hirer (if applicable) or

transferred to another site.

• Work areas are left clean and tidy

• Submit and agree final account to ensure that payment is made and track retention monies

• File paperwork at Head Office prior to archiving.


9.5 CARE OF PROPERTY, TOOLS AND EQUIPMENT

9.5.1 Calibration of Measuring Resources and Equipment Where Lucas UK Group Ltd utilises monitoring or measuring equipment for site investigation or analysis work, such equipment is serviced and if necessary calibrated, according to the manufacturer’s specification or guidelines. The servicing or calibration status of measuring equipment is either clearly marked on the equipment, or if not practicable, then available via serial number reference to the Lucas UK Group Ltd Calibration Plan and Records. If no date recorded for Calibration or Calibration has lapsed through nonuse, then the Logistics Manager will be responsible to Calibration must occurs prior to its use.

9.5.2 Care of Clients’ Property Lucas UK Group Ltd employees, and its subcontractors, will have access to client property and possibly equipment and therefore any personnel working at a client’s site will take all necessary and reasonable precautions in order to avoid damage loss or deterioration to the site or any materials or equipment contained within it, any matter of a non-conforming nature will be reported to the Clients representative.

Work at project sites is controlled via CPPs or RAMS or any other applicable procedures or stipulations. “non-conforming products and workmanship”, any defects caused by faulty products or workmanship should be discovered by the site manager and corrected before offering to the client for approval. If during or following handover to the client, the client determines that anything does not conform to specification or to the Companies high standards, the site manager shall either correct the problem (if he agrees that it is non-conforming,) or discuss the matter with the contracts manager and or managing director. A course of action shall be agreed with the client. Preventative Actions - Preventing future non-conformance or deciding what could be a potential nonconformity is the responsibility of the Quality Manager, who will be responsible for implementing any changes deemed suitable with the approval of the MD, together with monitoring & recording the results of any action taken. Initially each project is thoroughly vetted to ensure there is sufficient information to be able to carry out the project. This is the responsibility of a Director when setting up the individual site files. Prior to commencing the work on site the foreman will offer up a sample area, which will be benchmarked for the rest of the project. On site it is the responsibility of the foreman & Contracts Manager to ensure products and workmanship are to specification, and to the required standard. When a problem has been identified, it is important to ascertain the root cause. This may be achieved by a simple site inspection in conjunction with the client, by calling in technical representatives from the materials suppliers or by further investigation from independent bodies such as the Paint Research Association. The form LUKG IMS Form 13-4 NCR Form “Non-conformance report” is used to record the facts of the case. A copy of the completed report is filed in the site file, and another is sent to the SQE and Operations Director. Completed reports are filed (in electronic form) on the Company server. The


SQE and Operations Director analyses the information to determine any trends, and the effectiveness of preventive action. Where appropriate, information is distributed to Company personnel using email.

9.5.3 Storage of Materials and Samples Where materials are kept by Lucas UK Group Ltd for analysis, they are stored in appropriate environmental conditions such that the risk of escape or leakage, and hence resulting environmental pollution, is regarded as negligible. To cater for any incident involving leakage of liquids, spill kits are kept at strategic locations.

9.5.4 Management of Waste Resulting from Site Works All waste materials, including used PPE, are disposed of in an appropriate manner and where necessary via specialist and licensed waste carrier. Disposal is the responsibility of the Site Manager via the appropriate site methods or by back loading to our Logistics Centre by using our internal transfer system and our Logistics Team. Recycling is carried out wherever it is practicable to do so.


10.0 Management of External Resources and Purchasing Objective: To ensure a mutually beneficial relationship with key suppliers and subcontractors that will help portray a positive image of the Lucas UK Group Ltd to its clients. Process Owner: The performance of the Lucas UK Group Ltd.’s key suppliers, whether in the purchasing of materials or subcontract services, has a direct bearing on client satisfaction. The Lucas UK Group Ltd has a policy of using only “Approved Suppliers”, these having met the Lucas UK Group Ltd’s criteria in terms of quality of service/product, delivery and cost. The choice of suppliers varies depending on their nature, but the Lucas UK Group Ltd will endeavour to use those suppliers that have evidenced the highest levels of performance and quality, but balanced also with cost considerations. Lucas UK Group Ltd do not routinely carry out full end-to-end product environmental life cycle assessments, however there may be situations where the management does decide to do this in order to improve its environmental performance, and the outcome of such assessments will be documented.

10.1 SUPPLIER SELECTION AND PERFORMANCE MONITORING Purchasing requirements primarily relate to operational processes, PPE and office supplies and are purchased from suppliers who have demonstrated good product reliability and service. Selecting a new major supplier or contractor presents some potential risk to the business and is therefore assessed partly through its existing reputation in the marketplace as well as, where possible, through a trial period to assess the supplier’s product quality or level of service, and by using our web-based Company specific Pre-Qualification Questionnaire system. The criteria for approving new suppliers may include the following;

• Product and service quality • Prices • Availability • Environmental (sustainability) considerations • H&S Safety performance

In the event of sub-standard product quality or a service issue the details will be noted in the Event Report Form, and an appropriate action taken depending on the issue.

10.2 SUBCONTRACTOR EVALUATION AND PERFORMANCE MONITORING The Lucas UK Group Ltd maintains an Approved List of Subcontractors who have proved to be reliable and produce high quality work, and these are used wherever possible. Potential new subcontractors are required to register and completed our web-based Company Specific Pre-Qualification Questionnaire system prior to approval and contract award. The questionnaire and associated information is captured by this system and held electronically.


Subcontractor performance is continually monitored and if necessary, discussed at managers meetings and any issues of concern noted on an Event Report Form for further discussion at the Management Review Meetings. Consultants will be approved by their professional qualifications and reputation, personal experience and/or recommendation. They will be expected to sign a Consultancy Agreement prior to commencing work.

10.3 PURCHASING AND RECEIPT The Lucas UK Group Ltd ensures that its requirements of suppliers are clearly stated via a written Purchase Order which will include a full description of the item or service required so as to avoid errors in delivery and subsequent dissatisfaction. Orders are reviewed and authorised prior to placement on the supplier. Delivered goods are inspected on arrival by the purchaser who will endorse the Delivery Note along with the Project Number for reference. Collected goods will be checked at the time of collection. Supplier or subcontractor invoices received are reconciled against Purchase Orders and then passed to the Director / Senior Commercial Manager or Contracts Managers for their approval. Approved Invoices are entered onto the accounts system by the accounts department who will arrange payment, usually at the end each month. Any materials / goods that are found to be unacceptable will be notified to the Directors who will advise regarding the action to be taken and inform the supplier accordingly. Any suspect or reject products will be segregated or otherwise identified so they cannot be used in error.


11.0 Client Perceptions, Feedback and Complaints Objective: To ensure that the Lucas UK Group Ltd has in place a system for gathering and acting upon the perceptions of its clients to embed continuous improvement. Process Owner: Hof PS&T Lucas UK Group Ltd is committed to ensuring maximum satisfaction of its clients thereby ensuring continuation of business relationships.

11.1 CLIENT FEEDBACK A Client Feedback Questionnaire is periodically made available as an online survey and all clients used within a certain time period are requested to respond. The frequency will be as decided by the Directors, but these are generally sent at the end of each project, using LUKG/IMS/Form11-4. Clients can also leave feedback or comments on the Lucas UK Group Ltd twitter feed which is monitored for such comment. Feedback received by telephone or post will be recorded by the receiving employee and passed to the H0fPST for follow up action.

All feedback is reviewed and analysed along with sales figures and related client data to determine any negative, or positive, trends. Charts are produced to visualize and share the results both internally and where requested externally. Satisfaction is also evidenced by virtue of additional or repeat work from previous or existing clients/contractors.

11.2 THIRD PARTY OR CLIENT COMPLAINTS Any Third Party or Client complaints received at head office should be considered by the managing director, or his delegate. Action resulting shall be promptly communicated to those who made the complaint, and any others who may be concerned.

Any minor problems on site arising from activities carried out by Lucas Group should be addressed promptly by site management. If there is any doubt as to how to resolve the matter satisfactorily, the matter should be referred to head office, and dealt with as above.

The investigation of a complaint serves a two-fold purpose.

• To quickly correct the specific cause of dissatisfaction • To prevent a recurrence, including the removal or mitigation of any outstanding risk

Any client complaints received by Lucas UK Group Ltd personnel are recorded on the Event Report Form which would be forwarded to the Directors for review. The investigation by the Directors will determine what (if any) corrective action is required.


The Directors and/or Contract Manager will ensure the client, having made the complaint, is kept informed of its progress and eventual solution. The client will be asked to confirm their satisfaction or acceptance of the outcome of any corrective action. The Directors will regularly review any complaints to determine if any underlying trends are apparent that may require further preventive or mitigating actions.


12.0 INTERNAL AUDITING Objective: To ensure that the Lucas UK Group Ltd is operating an effective Integrated (Quality and Environmental) Management System, such that the Lucas UK Group Ltd’s Management of Building Refurbishment and Associated Building Trades Services Operations are consistently delivered as planned and improved upon where possible. Process Owner: SQE & Operations Director A rolling Internal Audit Schedule is maintained for a minimum of a year in advance and is maintained by the SQE and Operations Director. Greater emphasis is given to processes that are considered more critical to the business, where greater risks (including environmental) are inherent, or where performance or results of previous audits are found to be less than satisfactory.

Audits are conducted by nominated personnel who are suitably qualified or trained to undertake auditing and not directly responsible for the area under audit. The SQE & Operations Director will conduct a six-monthly check to ensure that the ISO 9001 & 14001 standards are still current. Any discrepancies found are recorded on the Audit Report Form & Corrective Action Request. The auditor will complete the Deficiency Noted field and, where appropriate, discuss and agree the recommendations for solutions with the auditee and then complete the (proposed) Corrective Action field. A timescale and responsibility for the implementation of the corrective action will also be agreed and noted. The auditor then copies the form and files it in the Audit File to await the review date and a copy given to the person responsible for the corrective action.

The corrective action will be verified at the specified due date and if satisfactory the Corrective Action Form will be marked “completed”.

Internal auditing of the IMS shall be carried out using the quality and environmental system audit forms. There is a form for internal audit at site, and another for an office-based system audit. The office-based systems audit is carried out six monthly timed top occur shortly before the management review. Projects are selected for audit on the basis of the significance of potential environmental risk. Most major projects would be audited once. Smaller projects would be audited if for example hazardous substances such as materials containing lead or asbestos were involved. The completed records are retained in the site file, and copies are filed on the companies file server. The details of quality audits are held in the Audit File and the results analyzed at the Management Review Meetings.


Internal Quality Audits

• The purpose is to ensure that employees understand and use the quality system properly and

to monitor its effectiveness and practicality.

• The responsibilities lie with the Directors. Procedure:

• Formal internal audits will be carried out at six monthly intervals and will normally be scheduled to take place shortly before external audits i.e. April and October annually.

• Internal audits will cover the four core system processes of:

a. Bid Stage b. Win Stage c. Deliver Stage d. Finish Stage

• A record of internal audit and findings will be logged on an internal audit report. • Findings from internal audits will be discussed at the annual management review meeting.

• Any non-conformance must be corrected and logged.

• The auditor will not audit their own work.

• Management review – the quality system will be formally reviewed in conjunction with

internal audits, minutes of these meetings will be recorded.

• The review will cover:

a. Actions from previous meetings b. Status of corrective and preventative actions c. Process performance and product conformity d. NCRs arising from both internal and external audits e. Trends f. Customer complaints and feedback g. Supply chain assessment h. A review of the quality policy and objectives i. Changes to the quality system and procedures j. Recommendations for improvement k. Staff training needs


13.0 MANAGING NON-CONFORMITIES & CORRECTIVE ACTIONS Objective: To ensure that non-conformities and service or environmental impacting issues in general are managed and corrected in a consistent manner so as to ensure an effective outcome. Process Owner: SQE & Operations Director In most cases, non-conformities will be dealt with according to the procedures governing the relevant area of work. Non-conformities can arise from (but not limited to) the following:

• A deviation from a procedure or erroneous outcome from a project • A client complaint • A supplier or subcontractor issue • Poor Workmanship • A H&S or environmental incident, or near-miss • Internal Audits (see 12.0)

A non-conformity may also apply to an identified risk situation that must be corrected, mitigated or removed. Should an issue/incident/non-conformity be identified by any member of staff, it should be brought to the attention of a Director by completing an LUKG IMS Form 13-4 NCR Form (Event Form). The Directors or relevant Department Manager will discuss and agree on the corrective action, and if appropriate, further preventive action to be undertaken, and assign an owner. A corrective action or resolution will involve the following;

• Identifying the corrective action necessary to remedy the immediate situation • Ascertaining the underlying root cause of the problem (where appropriate) • Ensuring the effective implementation of the corrective action • Ensuring the effective implementation of any further preventive action • Ensure that any procedure revisions necessary are enacted, suitably recorded and circulated

All fields of the Event Report must be completed and the form held on file by the appropriate person to await the corrective action and target review date. This will then be re-evaluated and the root cause of the initial problem evaluated. All Event Reports will be logged on the Corrective Action Tracking System maintained by the SQE & Operations Director for trend analysis and reporting at management review meetings. Control of Non-conforming products and workmanship The responsibilities lie will all personnel involved


Procedure Unacceptable products must be segregated from other products and appropriate action should be taken to return/dispose of unacceptable products. Any refunds to be agreed and Head Office to be notified. Unacceptable workmanship will be rectified before it is offered to the client for acceptance. This is monitored visually by the Contracts Managers and Site Managers/Supervisors and documented with the use of the Site Inspection Checklist. Any departure from established procedures that form part of the IMS would normally come to light by means of observations or discussions of supervision, or during internal or external audit. Such non-conformance would be due either to a lack of knowledge of the correct procedure, or a deliberate act. In the former case the failure of communications would normally be expected. In the case of a deliberate action the responsible manager should consider appropriate action to prevent recurrence. The purpose is to ensure that non-conforming products and workmanship are identified and dealt with accordingly. Free verbal communication throughout the management structure is encouraged, and prevents repetition of non-conformance, and situations that may lead to non-conformance at all locations where the company operates. Record and review Any non-conformance should be recorded using an internal audit form, which shall record action taken to mitigate any environmental impacts, and action taken to prevent recurrence. This form should be returned to head office (usually by a contracts manager or SQE & Operations Director). All such non-conformance would be considered at the Management review Corrective and Preventative Action

• The purpose is to ensure that all employees adhere to the Quality Management System and procedures.

• The responsibilities lie will all personnel involved Procedure

Corrective Actions - “non-conforming products and workmanship”, any defects caused by faulty products or workmanship should be discovered by the site manager and corrected before offering to the client for approval. If during or following handover to the client, the client determines that anything does not conform to specification or to the Companies high standards, the site manager shall either correct the problem (if he agrees that it is non-conforming,) or discuss the matter with the contracts manager and or managing director. A course of action shall be agreed with the client. Preventative Actions - Preventing future non-conformance or deciding what could be a potential nonconformity is the responsibility of the Quality Manager, who will be responsible for implementing any changes deemed suitable with the approval of the MD, together with monitoring & recording the results of any action taken. Initially each project is thoroughly vetted to ensure there is sufficient information to be able to carry out the project. This is the responsibility of a Director when setting up the individual site files.


Prior to commencing the work on site, the foreman will offer up a sample area, which will be benchmarked for the rest of the project. On site it is the responsibility of the foreman & Contracts Manager to ensure products and workmanship are to specification, and to the required standard. When a problem has been identified, it is important to ascertain the root cause. This may be achieved by a simple site inspection in conjunction with the client, by calling in technical representatives from the materials suppliers or by further investigation from independent bodies such as the Paint Research Association. The “Non-conformance report” is used to record the facts of the case. A copy of the completed report is filed in the site file, and another is sent to the SQE manager. Completed reports are filed (in electronic form) on the Company server. The SQE & operations Director analyses the information to determine any trends, and the effectiveness of preventive action. Where appropriate, information is distributed to Company personnel using email.


14.0 MANAGEMENT REVIEW Objective: To ensure that the performance of the business and its people are continually reviewed to minimise the opportunities for client dissatisfaction and other issues of concern and ensure that the Lucas UK Group Ltd continues to improve in all that it does. Process Owner: The planning and improvement of the business and it’s supporting Management Systems is facilitated through the management review process which focuses on all key activities and their respective outputs and any performance measures. Management review meetings are held annually as a minimum and include at least one of the Directors, plus any others who may be invited and reviews the health & safety, quality and environmental management systems The following items of relevance to the environmental management system are extracted from the agenda for the meeting:

• Results of internal audits and evaluations of compliance with legal requirements and with other requirements to which the organization subscribes,

• Communication(s) from external interested parties, including complaints, • The environmental performance of the organization, • The extent to which objectives and targets have been met, • Status of corrective and preventive actions, • Follow-up actions from previous management reviews, • Changing circumstances, including developments in legal and other requirements related to its

environmental aspects & impacts, and • Recommendations for improvement.

Management review topics (inputs) include as a minimum:

# Topic or Agenda Item Typical Records/Documents Reviewed

Persons Attending / Apologies for Absence

1. Purpose of Meeting & Review of Previous Minutes & Objectives

Minutes

2. Report on Quality Manual & Interested Parties include legislation compliance, Operational Controls, H&S and emergency/incident planning

As required

3. Report on Organisational Structure, Roles & Responsibilities including

As required

4. Report on Risks to the Business Review including any additional external issues or risks/threats that may impact the business or 3rd party expectations that need to be acted upon

Risk Register

5. Report on Performance Measures and Improvements KPIs and objectives including progress on improvement initiatives (Quality & Enviro)

KPI Log Improvement Initiatives Tracking Log


6. Report on Human Resources Management & Communications including new staff, training, performance & general HR issues

HR Records, Training Matrix etc.

7. Report on Infrastructure Resources Management resources including vehicles and IT

As required

8. Report on Management of Documentation Resources & Controls Current projects/work in progress and resources

Project Files As required

9. Report on Environmental Management and Planning Review of Enviro Aspects

Aspects, Legislation &, Emergency Planning Registers & controls

10. Report on the Management of Building Refurbishment and Associated Building Trades Services Operations

Event Report Form As required

11. Report on Management of External Resources & Purchasing Supplier & subcontractors and their performance and Quotations & Marketing and Accounts

Accounts data

12. Report on Client Perceptions, Feedbacks & Complaints

Feedback / complaints records

13. Report on Internal & External Auditing Results Audit Reports & Schedule

14. Report on Managing Non-Conformities & Corrective Actions Outstanding including issues requiring attention and related trends

Event Report Form

15. Report on Management Review

16. Objectives for Next Period

17. Changes that could affect the management systems and Any other Business

As required

The SQE & Operations Director prepares and distributes the meeting minutes which will include any actions agreed, the action owner and agreed completion date. Manager’s meetings are also held and may contribute to the management review process.


15.0 CHANGE HISTORY

# Description Author Version Date

1. Original A Price 1.0 1 Jan 2018

2. Annual Review – no significant changes A Price 1.1 4 Jan 2019

3. Annual Review – no significant changes N Martens 1.2 7 Jan 2020

4.

5.

16.0 REGISTER OF HOLDERS

Copy No Name Position Held Version Date Issued

001 Company Server Intranet 2015-001 01 Nov 2017

17.0 GLOSSARY OF TERMS & ABBREVIATIONS

Acronym Description

CAR Correction Action Request / Report

CPP Construction Phase Plan

EMS Environmental Management System

HR Human Resources

H&S Health & Safety

ISO International Standards Organisation

KPI Key Performance Indicator

MD Managing Director

NC Non-conformity

PE Project Engineer

CM Contracts Manager

QA Quality Assurance

IMS Integrated (Quality & Environmental) Management System

RAMS Risk Assessment & Method Statements

WIs Work Instructions


APPENDIX 1 CORRESPONDENCE BETWEEN ISO 9001:2015 AND THIS MANUAL

ISO 9001:2015 Manual 4.0 Context of the Organisation (title only)

4.1 Understanding the Organisation & its context 4.2 Understanding needs & expectations of interested parties 4.3 Determining the scope of the QMS 4.4 The QMS and its processes

1.0 1.2 1.3 1.5

5.0 Leadership (title only)

5.1 Leadership Commitment 5.1.1 General 5.1.2 Customer Focus 5.2 Policy 5.2.1 Establishing the quality policy 5.2.2 Communicating the quality policy 5.3 Organisational roles & responsibilities

1.0 1.0, 11.0 1.4 1.4 2.0

6.0 Planning (title only)

6.1 Actions to address risks & opportunities 6.2 Quality Objectives & planning to achieve them 6.3 Planning of changes

3.0 4.0 3.0, 4.0, 14.0

7.0 Support (title only)

7.1 Resources 7.1.1 General 7.1.2 People 7.1.3 Infrastructure 7.1.4 Environment for the operation of processes 7.1.5 Monitoring & measuring resources 7.1.6 Organisational knowledge 7.2 Competence 7.3 Awareness 7.4 Communication 7.5 Documentation

5.0 5.0 6.0 6.0 6.0, 9.5 5.4 5.0 5.0 5.0 7.0

8.0 Operation (title only)

8.1 Operational planning & control 8.2 Requirements for products & services 8.2.1 Customer communication 8.2.2 Determining the requirements for products & services 8.2.3 Review of the requirements for products & services 8.2.4 Changes to requirements for products & services 8.3 Design & development of products & services 8.3.1 General 8.3.2 Planning 8.3.3 Inputs 8.3.4 Controls 8.3.5 Outputs 8.3.6 Changes 8.4 Control of externally provided processes, products & services 8.4.1 General 8.4.2 Type and extent of control 8.4.3 Information for external providers 8.5 Production & service provision 8.5.1 Control of production & service provision 8.5.2 Identification & traceability 8.5.3 Property belonging to customers or external providers 8.5.4 Preservation 8.5.5 Post-delivery activities 8.5.6 Control of changes 8.6 Release of products & services 8.7 Control of nonconforming outputs

9.0 9.1 9.0 10.0 9.0 9.0 9.0, 10.0 9.5 9.5 11.0 4.0, 9.0, 14.0 9.0 9.0, 12.0

9.0 Performance evaluation (title only)


9.1 Monitoring, measurement, analysis & evaluation 9.1.1 General 9.1.2 Customer satisfaction 9.1.3 Analysis & evaluation 9.2 Internal audit 9.3 Management review

4.0, 14.0 11.0 14.0 12.0 14.0

10.0 Improvement (title only)

10.1 General 10.2 Non-conformity & corrective action 10.3 Continual improvement

4.0, 14.0 13.0 4.0, 14.0


APPENDIX 2 CORRESPONDENCE BETWEEN ISO 14001:2015 AND THIS MANUAL

ISO 14001:2015 Manual 4.0 Context of the Organisation (title only)

4.1 Understanding the Organisation & its context 4.2 Understanding needs & expectations of interested parties 4.3 Determining the scope of the EMS 4.4 Environmental management system

1.0 1.2 1.3 1.5

5.0 Leadership (title only)

5.1 Leadership Commitment 5.2 Environmental policy 5.3 Organisational roles & responsibilities

1.0 1.4 2.0

6.0 Planning (title only)

6.1 Actions to address risks & opportunities 6.1.1 General 6.1.2 Environmental aspects 6.1.3 Compliance obligations 6.1.4 Planning actions 6.2 Environmental objectives & planning to achieve them 6.2.1 Environmental objectives 6.2.2 Planning actions to achieve environmental objectives

3.0, 8.0 3.0, 4.0, 8.0 8.1 8.2 8.0 8.0 4.0, 8.1 8.0

7.0 Support (title only)

7.1 Resources 7.2 Competence 7.3 Awareness 7.4 Communication 7.4.1 General 7.4.2 Internal 7.4.3 External 7.5 Documented information 7.5.1 General 7.5.2 Creating and updating 7.5.3 Control of documented information

5.0 5.0 5.0 5.0 5.0, 8.6 5.0, 8.6 7.0, 8.0 7.0 7.0

8.0 Operation (title only)

8.1 Operational planning & control 8.2 Emergency preparedness

8.5, 9.0 8.3

9.0 Performance evaluation (title only)

9.1 Monitoring, measurement, analysis & evaluation 9.1.1 General 9.1.2 Evaluation of compliance 9.2 Internal audit 9.2.1 General 9.2.2 Internal audit programme 9.3 Management review

4.0, 8.4, 14.0 8.4, 14.0 8.2, 12.0. 14.0 12.0 12.0 12.0 14.0

10.0 Improvement (title only)

10.1 General 10.2 Non-conformity & corrective action 10.3 Continual improvement

4.0, 14.0 13.0 4.0,13.0, 14.0


APPENDIX 3 – ACCREDITATIONS

Accreditation Membership No FSC TT-COC-003947

FORS Silver 002618

ISO 9001 FS 23467

ISO 14001 EMS 552100

Dulux Paint Partnership Contract Partner

Achilles Building Confidence 4900250

ConstructionLine Gold 456

SMAS Contractor

Waste Carriers License CBDU219490

Considerate Constructors C2224

Carbon Footprint CF2019-2413

Plastic Oceans Partner

Lucas UK Group Limited...Lucas UK Group Limited The Integrated Quality & Environmental System s...

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