It is the policy of the Company to ensure that employees’ use of either alcohol or drugs (prescribed drugs or other drugs) does not impair the safe and efficient operation of the firm’s activities.

The Company will therefore seek to ensure that the organisation, people and equipment are not put at risk as a result of accidents or incidents caused by the misuse of drugs or alcohol in the work place.

To achieve this objective the Company will implement the following measures:

Alcohol

• Employees must not consume alcohol during working hours (or have previously consumed alcohol resulting in residual alcohol levels being present in their blood) such that their blood alcohol levels exceed the legal limits in place in relation to drink driving laws.

• Where alcohol consumption is evident, the Directors will make employees aware of the long-term and short-term effects of consuming excessive amounts of alcohol through the provision of information and referral to sources of self-help.

• Where appropriate, the Directors may discuss matters confidentially with employees and refer them for professional help.

• Consumption of alcohol such that employees’ blood alcohol levels exceed the legal limits in place in relation to drink driving laws; or such that employees are unable to perform their duties satisfactorily may lead to disciplinary action and, ultimately, to dismissal.

Drugs

• Possession or use of those drugs which are normally declared illegal is prohibited. Such drugs include for example, but are not limited to: Marijuana, Cocaine and Heroin.

• Anyone using legally prescribed drugs must inform the Director to whom they report on a day to day basis if their doctor advises that the drugs may impair their ability to perform their duties safely.

• Use of illegal drugs may lead to disciplinary action and, ultimately, to dismissal.

The Directors intend that the advantages to all of the Company’s staff in operating this policy should be a more productive workforce, improved morale and retention of staff, whilst providing help and support for any employee who might be affected by alcohol or drug related problems.