Purpose

This policy sets out our commitment to creating and maintaining a working environment where every member of our team is treated fairly and respected at all times. We recognise that our project work requires exceptional teamwork, trust, and communication. A culture of fairness and respect directly supports safety, performance, and wellbeing.

Scope

This policy applies to:

• All employees, freelance divers, and subcontractors
• All supervisors, managers, and company representatives
• All work undertaken on vessels, barges, pontoons, shore-based sites, workshops, and offices
• All work-related interactions, including travel, training, and digital communication

Our Commitments

Fairness

We commit to:

• Providing equal opportunities in recruitment, training, and progression
• Making decisions based on competence, qualifications, and operational needs
• Ensuring work is allocated fairly and transparently
• Addressing concerns or complaints promptly and impartially

Inclusion

We commit to:

• Creating a team culture where everyone feels valued and able to contribute
• Encouraging open communication and listening to all voices, regardless of role or seniority
• Removing barriers that prevent individuals from participating fully in work activities
• Supporting neurodiverse, disabled, or otherwise disadvantaged team members with reasonable adjustments where possible

Respect

We commit to:

• Treating all colleagues, clients, and stakeholders with dignity
• Maintaining professional behaviour on-site and during travel
• Promoting a zero-tolerance approach to bullying, harassment, discrimination, or victimisation
• Respecting differences in background, culture, beliefs, and working styles

Expected Behaviour

All personnel are expected to:

• Communicate clearly, calmly, and professionally — especially during safety-critical operations
• Follow instructions from supervisors and respect the chain of command
• Challenge unsafe or disrespectful behaviour appropriately and without fear of retaliation
• Support colleagues, especially new or those less experienced
• Maintain a positive, cooperative attitude in high-pressure environments

Unacceptable Behaviour

The following behaviours are not tolerated under any circumstances:

• Bullying, intimidation, or verbal abuse
• Discriminatory remarks or actions relating to race, gender, age, disability, religion, sexual orientation, or any protected characteristic
• Hazing or initiation practices
• Deliberate exclusion of team members from briefings, tasks, or social interaction
• Misuse of authority or seniority
• Retaliation against anyone who raises a concern

Reporting Concerns

We encourage anyone who experiences or witnesses unfair, discriminatory, or disrespectful behaviour to report it. Reports can be made to:

• MMC Directors
• The MMC Supervisor
• The QHSE Manager

All reports will be:

• Taken seriously
• Treated confidentially where possible
• Investigated promptly and fairly
• Followed by appropriate action

No individual will be disadvantaged for raising a genuine concern.

Responsibilities

Management

• Lead by example and uphold FIR principles
• Ensure supervisors receive appropriate training
• Investigate concerns and take corrective action
• Promote a culture of openness and accountability

Supervisors

• Maintain a respectful and inclusive team environment
• Address inappropriate behaviour immediately
• Ensure all team members are briefed, supported, and heard
• Encourage reporting without fear

All Personnel

• Follow this policy at all times
• Treat colleagues with fairness, inclusion, and respect
• Report concerns promptly
• Support a positive team culture

Training and Awareness

We will provide:

• FIR awareness training for all staff
• Additional support for supervisors and managers
• Regular reminders during toolbox talks, project briefs, and safety meetings

Review

This policy will be reviewed annually or following any significant incident, regulatory change, or operational development. Feedback from the team will be incorporated into future revisions.

APPROVED BY:

Sam Connelly
Director – July 2026