Workplace Drug & Alcohol Policy

1. Policy Statement

Imperial Security is wholly committed to maintaining a safe, healthy and professional working environment for all members of our workforce, our clients, and the members of the public with whom our personnel interact on a daily basis. The nature of the security industry demands the highest standards of alertness, sound judgement, physical capability and personal conduct at all times. The consumption of alcohol or the use of drugs whether illegal substances, prescription medications, or over-the-counter remedies where these impair performance is incompatible with the responsibilities placed upon every individual working under the Imperial Security banner.

This policy applies to all individuals engaged by Imperial Security in any capacity, including directly employed security officers, door supervisors, close protection operatives, event security personnel, hotel and concierge security staff, CCTV operators, key holding responders, mobile patrol officers, warehouse and construction site security guards, educational security operatives, corporate and retail security personnel, as well as all temporary workers, agency staff, subcontractors and contractors deployed on behalf of or alongside Imperial Security.

Imperial Security recognises that substance misuse can sometimes be associated with underlying health difficulties or personal circumstances. Whilst our primary obligation is to protect the safety and security of our clients, the public and our own workforce, we are also committed to supporting individuals who voluntarily seek assistance with substance-related issues, and to treating all matters with appropriate sensitivity and confidentiality.

This policy has been developed in compliance with United Kingdom legislation, including but not limited to the Health and Safety at Work etc. Act 1974, the Misuse of Drugs Act 1971, the Road Traffic Act 1988, the Security Industry Authority (SIA) licensing requirements, and the Equality Act 2010. It also reflects the standards expected by our industry accreditations and the clients to whom we are contracted.

2. Purpose & Objectives

The purpose of this policy is to clearly set out Imperial Security's position on drug and alcohol use, to define the obligations of all personnel, and to establish the procedures that will be followed when the policy is suspected or confirmed to have been breached. The specific objectives of this policy are as follows:

• To ensure the health, safety and wellbeing of all employees, clients, contractors and members of the public who may be affected by the actions of our personnel.
• To protect the professional reputation and operational integrity of Imperial Security and the clients we serve.
• To maintain full compliance with SIA licensing conditions, which mandate that licence holders must not be under the influence of alcohol or substances when working in a licensed role.
• To create a clear, transparent and fair framework for managing cases of suspected or confirmed impairment in the workplace.
• To support and, where appropriate, assist employees who present with substance misuse issues, in accordance with our duty of care.
• To deter the use of drugs and alcohol through a programme of education, training and proportionate testing.
• To ensure that all personnel understand their individual responsibilities in relation to this policy.

3. Scope of This Policy

This policy applies to all individuals who carry out work for or on behalf of Imperial Security, regardless of their employment status, the duration of their engagement, or the location at which they are deployed. This includes, but is not limited to:

• Directly employed security guards and operatives across all service lines.
• Door supervisors and club bouncers operating at licensed premises.
• Close protection officers and personal bodyguards.
• Event security and crowd management personnel.
• Hotel, front-of-house and concierge security staff.
• Corporate and reception security officers.
• Retail loss prevention and security officers.
• Construction site security guards.
• Warehouse and logistics security personnel.
• CCTV monitoring and control room operators.
• Key holding and alarm response operatives.
• Mobile patrol security officers.
• Night security operatives.
• Educational security staff deployed at schools, colleges and universities.
• Subcontractors and relief security guards deployed through Imperial Security.
• All support staff, administrative personnel, and management employees.

This policy applies at all times when an individual is carrying out duties on behalf of Imperial Security, is present on a client's site or premises, is travelling to or from an assignment in a company or client vehicle, is attending company premises, training events or meetings, and at any time during a working day or shift including rest breaks taken on or adjacent to the work site.

4. Definitions

4.1 Alcohol

For the purposes of this policy, 'alcohol' refers to any substance containing ethanol that is consumed in any form, including but not limited to beer, wine, spirits, cider, alcopops, and any other beverage that results in or may contribute to impairment of performance. The legal drink-drive limit in England and Wales (80mg of alcohol per 100ml of blood) does not represent the acceptable threshold for personnel on duty. Imperial Security operates a zero tolerance approach to alcohol during working hours. Any detectable level of alcohol during a shift regardless of when it was consumed may be considered a breach of this policy if it contributes to or is reasonably suspected of contributing to impairment.

4.2 Drugs

The term 'drugs' within this policy encompasses a broad range of substances, including:

• Illegal drugs: All substances classified under the Misuse of Drugs Act 1971, including Class A substances such as cocaine, heroin, MDMA and methamphetamine; Class B substances such as cannabis, amphetamine and ketamine; and Class C substances.
• Prescription medications: Legal medications obtained by valid prescription which may, in certain doses or circumstances, impair an individual's ability to perform their duties safely and effectively.
• Over-the-counter medications: Legally available medications, such as antihistamines, cough suppressants or cold remedies, which carry warnings regarding drowsiness, reduced concentration or impaired reaction time.
• New Psychoactive Substances (NPS): Substances designed to mimic the effects of illegal drugs, regulated under the Psychoactive Substances Act 2016.
• Performance-enhancing substances: Any substance used to artificially enhance performance, where that use is not medically sanctioned and may carry risks to health or safety.

4.3 Impairment

'Impairment' means any reduction in an individual's physical or cognitive ability to perform their role to the standard required by Imperial Security and by the SIA. Signs of impairment may include, but are not limited to: slurred speech, unsteady gait, bloodshot or glazed eyes, slowed reaction time, poor concentration, erratic or uncharacteristic behaviour, smell of alcohol or cannabis, excessive sweating, dilated or constricted pupils, or any other observable change in a person's normal conduct or appearance.

4.4 Zero Tolerance

'Zero tolerance' means that Imperial Security will not accept any level of impairment whilst on duty, and will not permit any individual to attend for duty who is reasonably believed to be under the influence of alcohol or drugs. Zero tolerance does not preclude the company from taking a supportive approach where an employee voluntarily discloses a dependency issue before a formal investigation has been commenced. Once a breach is confirmed, however, disciplinary procedures will be initiated.

5. General Rules & Standards of Conduct

All personnel engaged by Imperial Security are expected to comply with the following standards at all times. These rules are non-negotiable and failure to adhere to them may result in disciplinary action, up to and including summary dismissal.

5.1 Prohibited Conduct

1. Attending work, a client site, company premises or any assignment in a state of impairment caused by alcohol or drugs.
2. Consuming alcohol immediately before or during a shift, including during meal breaks, rest periods or any time on duty.
3. Using, possessing, purchasing, selling, supplying or facilitating the supply of illegal drugs at any time on company premises, client premises, or whilst carrying out any duty on behalf of Imperial Security.
4. Reporting for duty with a blood alcohol content at or above the legal drink-drive limit, or at any level which a manager or supervisor reasonably believes is affecting the individual's performance.
5. Concealing or failing to disclose the use of prescription or over-the-counter medication that may affect fitness for duty.
6. Refusing to cooperate with a reasonable request for a drug or alcohol test in accordance with the testing procedures set out in Section 8 of this policy.
7. Attempting to adulterate, tamper with or otherwise undermine the integrity of a drug or alcohol test.

5.2 Driving & Vehicle Use

Any member of staff who is required to drive in the course of their duties including mobile patrol officers, key holding responders, close protection operatives, and any other personnel who drive a company or client vehicle must at no time do so whilst over the legal alcohol limit or whilst impaired by any substance. Personnel should be aware that alcohol consumed the evening prior to a shift may still be present in the system at levels above the legal limit at the commencement of the following day's duties. Personnel in doubt should not drive and must notify their line manager immediately.

5.3 Medication & Fitness for Duty

Personnel who are prescribed medication by a medical professional, or who are taking over-the-counter remedies, and who believe that such medication may affect their ability to perform their duties including impacting reaction times, concentration, physical capability or judgement are required to notify their line manager or the Human Resources Department before commencing their next shift. In such cases, Imperial Security will take reasonable steps to make an informed decision on fitness for duty, which may include a temporary redeployment to a non-operational role, a temporary adjustment of duties, or in certain circumstances a period of authorised absence.

Personnel are not required to disclose the specific nature of any medical condition, only the potential impact of their medication on their fitness to work in a safety-critical role. This information will be treated in strict confidence.

6. Responsibilities

6.1 Responsibilities of All Personnel

• To comply fully with this policy at all times and to present for duty fit and unimpaired.
• To disclose any medication that may affect fitness for duty before commencing a shift.
• To report any concerns regarding the behaviour of a colleague who appears to be impaired to a line manager or supervisor as promptly as possible.
• To cooperate fully with any reasonable request for a drug or alcohol test.
• To seek assistance voluntarily if experiencing difficulties with substance use, by contacting their line manager or the Human Resources Department in confidence.

6.2 Responsibilities of Supervisors & Line Managers

• To be conversant with this policy and to communicate its requirements clearly to all personnel under their supervision.
• To monitor the conduct and condition of personnel at the start of and throughout each shift, and to be alert to signs of potential impairment.
• To initiate the appropriate procedures set out in this policy where impairment is suspected, without delay.
• To maintain confidentiality in respect of any matter arising under this policy, disclosing information only on a need-to-know basis.
• To document all incidents, observations and actions taken in connection with suspected or confirmed breaches of this policy, using the company's standard incident reporting forms.
• To treat all matters with fairness, consistency and in a non-discriminatory manner in accordance with the Equality Act 2010.

6.3 Responsibilities of the Human Resources Department

• To maintain and review this policy at regular intervals, ensuring it remains compliant with current UK legislation and SIA requirements.
• To provide guidance and support to managers and supervisors in handling matters arising under this policy.
• To coordinate and oversee the company's drug and alcohol testing programme.
• To provide employees with access to appropriate support, including referral to occupational health or employee assistance programmes where applicable.
• To maintain accurate and confidential records of all testing, disclosure and disciplinary matters arising under this policy.

6.4 Responsibilities of Imperial Security Management

• To model appropriate behaviour and to uphold this policy at all times.
• To ensure that adequate resources are allocated to the effective implementation of this policy, including testing, training and employee support mechanisms.
• To ensure that this policy is applied consistently across all service lines, client sites and geographic locations.
• To review and update this policy in response to changes in legislation, SIA requirements, industry best practice, or operational experience.

7. SIA Licensing Compliance

Imperial Security is an SIA Contractor and operates in strict accordance with the requirements set out by the Security Industry Authority. All SIA-licensed personnel are reminded that as a condition of their licence, they are prohibited from carrying out any licensable activity whilst under the influence of alcohol or drugs.

Breaches of SIA licence conditions may result in the suspension or revocation of an individual's SIA licence, which would render them unable to work in any licensed security role. In addition to any internal disciplinary action taken by Imperial Security, the company reserves the right and in certain circumstances may be legally obliged to notify the SIA of any confirmed breach of licensing conditions.

Personnel are reminded of their personal obligation to inform Imperial Security and, where relevant, the SIA, of any criminal conviction including drug-related offences or drink-driving convictions, as these may affect their licensing status. Any individual who fails to disclose a relevant conviction may be in breach of both this policy and their SIA licence conditions.

8. Drug & Alcohol Testing Programme

Imperial Security operates a proportionate and legally compliant drug and alcohol testing programme. By accepting an offer of employment or engagement with Imperial Security, all personnel agree to participate in this testing programme as a condition of their engagement. The testing programme is structured around the following categories:

8.1 Pre-Employment Testing

All individuals offered a role with Imperial Security will be required to undergo a drug and alcohol screening as part of the pre-employment process. An offer of employment or engagement is conditional upon a negative test result. Where a positive result is obtained, the offer will ordinarily be withdrawn. In exceptional circumstances, and where a candidate can provide evidence of participation in a structured treatment programme, the company may at its discretion review the position.

8.2 Random Testing

Imperial Security reserves the right to conduct unannounced, random drug and alcohol testing of any member of its workforce at any time during working hours or immediately prior to the commencement of a shift. Random testing will be conducted without prior notice and will be entirely random in the selection of individuals. No individual should assume that they will not be selected, regardless of role, seniority or length of service.

8.3 For-Cause Testing (Reasonable Suspicion)

Where a supervisor or manager has reasonable grounds to suspect that a member of personnel is under the influence of alcohol or drugs whilst on duty, they are authorised to require that individual to submit to an immediate test. Reasonable grounds may include observable signs of impairment, the smell of alcohol, a report by a client or colleague, involvement in an accident or near-miss incident, or any other circumstance that gives rise to a genuine and documented concern about an individual's fitness for duty.

The supervisory manager should, wherever practicable, seek a second management opinion before requiring a for-cause test, and should document the specific observations and reasons for their concern in writing before the test is administered.

8.4 Post-Incident Testing

Following any accident, incident, near-miss or any situation that has or may have resulted in injury, damage to property, harm to a member of the public, or a significant security breach, any personnel who were directly or materially involved may be required to undergo immediate drug and alcohol testing. Post-incident testing is a proportionate safety measure and does not in itself constitute an allegation of misconduct. The results will, however, be taken into account as part of any subsequent investigation.

8.5 Return-to-Work Testing

Where an individual has returned to work following a period of absence related to substance misuse, or following a previous confirmed breach of this policy that did not result in dismissal, Imperial Security may require that individual to undergo regular unannounced testing for a defined period as determined on a case-by-case basis. Such testing will be agreed with the individual as part of their return-to-work agreement.

8.6 Testing Methods & Standards

Drug and alcohol tests will be administered by trained and competent personnel, or by an accredited third-party occupational health provider, in accordance with applicable UK standards and best practice. Tests will be conducted in a manner that preserves the dignity and privacy of the individual being tested. Results will be communicated sensitively and confidentially.

Alcohol testing will typically be conducted by means of a calibrated and CE-marked breathalyser device. Drug testing will typically involve an initial oral fluid (saliva) screen or urine screen. Any positive screening result will be subject to confirmatory laboratory analysis before any disciplinary action is initiated, unless the individual declines to submit to confirmatory testing, in which case the initial result may be treated as confirmed.

A positive result is one that indicates the presence of any controlled substance above the prescribed cut-off levels as set by the testing laboratory. For alcohol, a positive result for on-duty purposes is any reading above zero, in keeping with Imperial Security's zero tolerance approach.

9. Procedure for Managing Suspected Impairment

9.1 Immediate Steps

Where a supervisor, manager or colleague reasonably suspects that a member of personnel is impaired whilst on duty, the following immediate steps should be taken:

8. Remove the individual from operational duties immediately, without confrontation and without causing unnecessary embarrassment, where it is safe to do so.
9. Ensure the individual is supervised and not left alone, particularly where there are concerns about their safety or the safety of others.
10. If the individual was driving or was about to drive, ensure that they do not do so. Contact emergency services if necessary.
11. Contact the line manager or duty supervisor to report the situation, documenting the specific observations that gave rise to the concern.
12. If the individual's condition suggests a medical emergency, contact emergency services immediately by dialling 999 before taking any other step.

9.2 Investigation

Following the immediate steps above, Imperial Security will conduct a fair and thorough investigation in accordance with its standard disciplinary and investigation procedures. The individual will be informed of the allegation in writing and will be given the opportunity to respond. They will have the right to be accompanied by a trade union representative or a workplace colleague at any formal meeting.

Where a confirmatory laboratory test result is pending, the individual may be suspended on full pay, or redeployed to a non-operational role, pending the outcome of the investigation. No disciplinary sanction will be imposed until the investigation has been concluded, except where it is necessary to take immediate protective action.

9.3 Outcomes

The outcome of an investigation under this policy will depend on the specific circumstances, the individual's history, any mitigating factors, and the severity of the breach. Possible outcomes include:

• No further action, where the allegation is found to be unsubstantiated.
• Informal management action or coaching, for a first low-level concern with no confirmed positive test.
• Formal written warning, for a confirmed breach that does not involve illegal drug use and where there are significant mitigating circumstances.
• Final written warning, for a more serious confirmed breach or a repeated breach.
• Dismissal with notice, for a serious confirmed breach where dismissal is proportionate in the circumstances.
• Summary dismissal (dismissal without notice), for gross misconduct, including but not limited to testing positive for illegal drugs whilst on duty, attending for duty severely impaired, or refusing to submit to a test.

The decision to dismiss will not be taken lightly and will only be made following a full and fair investigation. All dismissal decisions are subject to the company's standard appeal procedure.

10. Self-Referral & Support for Substance Misuse

Imperial Security acknowledges that dependency on alcohol or drugs is a complex issue that can affect people from all walks of life. We believe that employees who are struggling with substance misuse should be encouraged and supported to seek help voluntarily, and we aim to create an environment in which individuals feel safe to do so without fear of immediate disciplinary action.

Any employee who, before they are required to submit to a test and before any formal investigation has been commenced, approaches Imperial Security voluntarily to disclose that they have or may have a problem with alcohol or substance misuse will be dealt with in the first instance through a supportive pathway rather than a disciplinary one. This may include:

• A confidential referral to an occupational health provider or the company's Employee Assistance Programme (EAP), where available.
• Referral to an appropriate external support organisation, such as the NHS, Alcoholics Anonymous, Narcotics Anonymous, or FRANK.
• A temporary adjustment of duties where this is practicable and where it does not place the individual, colleagues, clients or members of the public at risk.
• An agreed return-to-work plan incorporating monitoring and support, subject to satisfactory progress.

The availability of support under this section is subject to the individual's genuine commitment to the support pathway and their continued compliance with this policy and with Imperial Security's standards of professional conduct. Where a self-referring individual is subsequently found to be in breach of this policy whilst engaged in an agreed support programme, the company reserves the right to recommence disciplinary procedures.

The fact that an employee has self-referred will be treated as strictly confidential and will only be shared with those who have a genuine need to know in order to facilitate the support process.

11. Confidentiality & Data Protection

All information relating to drug and alcohol testing, self-referrals, medical disclosures, investigations and outcomes under this policy will be treated as sensitive personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Such information will only be shared with those who have a genuine and legitimate need to know, and will be stored securely in accordance with the company's Data Protection Policy.

Test results and related records will be retained only for as long as is necessary for the purposes for which they were collected, as set out in the company's data retention schedule. Individuals have the right to access personal data held about them in connection with this policy, subject to the exemptions provided by applicable data protection legislation.

Managers and supervisors who handle information in connection with this policy must ensure that they comply with their obligations under the company's Data Protection Policy and must not disclose information to third parties including clients without explicit authorisation from the Human Resources Department or the company's data protection officer.

12. Legal & Regulatory Framework

This policy has been developed having regard to the following key pieces of United Kingdom legislation and regulatory guidance:

13. Policy Review & Communication

This policy will be reviewed by the Human Resources Department no less than annually, and in any event following any significant change in relevant legislation, SIA guidance, industry best practice, or operational circumstances that may affect the policy's scope or application. Reviews will be conducted in consultation with management and, where appropriate, with employee representatives.

All personnel will be required to confirm in writing by signature of the acknowledgement form at the end of this document that they have read, understood and agree to comply with this policy as a condition of their engagement with Imperial Security. Copies of this policy are available from the Human Resources Department and are accessible via the company's internal staff documentation portal.

Any questions regarding this policy should be directed to the Human Resources Department in the first instance. Any concerns about how this policy is being applied may be raised through Imperial Security's standard grievance procedure.