Our Policies

Acting responsibly

CCTV Policy Statement

We believe that CCTV and other surveillance systems have a legitimate role to play in helping to maintain a safe and secure environment for all our staff and visitors. However, we recognise that this may raise concerns about the effect on individuals and their privacy. This policy is intended to address such concerns. Images recorded by surveillance systems are personal data which must be processed in accordance with data protection laws. We are committed to complying with our legal obligations and ensuring that the legal rights of staff, relating to their personal data, are recognised and respected.
This policy is intended to assist staff in complying with their own legal obligations when working with personal data. In certain circumstances, misuse of information generated by CCTV or other surveillance systems could constitute a criminal offence.

Definitions

For the purposes of this policy, the following terms have the following meanings:

CCTV: means fixed and domed cameras designed to capture and record images of individuals and property.
Data: is information which is stored electronically, or in certain paper-based filing systems. In respect of CCTV, this generally means video images. It may also include static pictures such as printed screen shots.
Data subjects: means all living individuals about whom we hold personal information as a result of the operation of our CCTV (or other surveillance systems).
Personal data: means data relating to a living individual who can be identified from that data (or other data in our possession). This will include video images of identifiable individuals.
Data controllers: are the people who, or organisations which, determine the manner in which any personal data is processed. They are responsible for establishing practices and policies to ensure compliance with the law. We are the data controller of all personal data used in our business for our own commercial purposes.
Data users: are those of our employees whose work involves processing personal data. This will include those whose duties are to operate CCTV cameras and other surveillance systems to record, monitor, store, retrieve and delete images. Data users must protect the data they handle in accordance with this policy and our data protection policy.
Data processors: are any person or organisation that is not a data user (or other employee of a data controller) that processes data on our behalf and in accordance with our instructions (for example, a supplier which handles data on our behalf).
Processing: is any activity which involves the use of data. It includes obtaining, recording or holding data, or carrying out any operation on the data including organising, amending, retrieving, using, disclosing or destroying it. Processing also includes transferring personal data to third parties.
Surveillance systems: means any devices or systems designed to monitor or record images of individuals or information relating to individuals. The term includes CCTV systems as well as automatic number plate recognition (ANPR), body worn cameras, unmanned aerial systems and any other systems that capture information of identifiable individuals or information relating to identifiable individuals.

About this policy

We currently use CCTV cameras and other surveillance systems to view and record individuals on and around our premises. This policy outlines why we use surveillance systems, how we will use them and how we will process data recorded by CCTV cameras and other surveillance systems to ensure we are compliant with data protection law and best practice.
We recognise that information that we hold about individuals is subject to the Data Protection Act (DPA). We are committed to complying with all our legal obligations under the DPA. The images of individuals recorded by CCTV cameras in the workplace are personal data and therefore subject to the DPA. We also seek to comply with best practice suggestions from the Information Commissioner’s Office (ICO).
This policy covers all employees executives, directors, officers, consultants, contractors, casual workers, and agency workers and may also be relevant to visiting members of the public.
We may amend this policy at any time without consultation. The policy will be regularly reviewed to ensure that it meets legal requirements, relevant guidance published by the ICO and industry standards.
A breach of this policy may, in appropriate circumstances, be treated as a disciplinary matter. Following investigation, a breach of this policy may be regarded as misconduct leading to disciplinary action, up to and including dismissal.

Personnel responsible

The Site Manager has delegated responsibility for ensuring day-to-day compliance with relevant legislation and the effective operation of this policy.
Responsibility for keeping this policy up to date has been delegated to the Executives.

Reasons for the use of CCTV and other surveillance systems

We currently use CCTV and other surveillance systems around our site as outlined below. We believe that such use is necessary for legitimate business purposes, including:
- to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
- for the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime;
- to support law enforcement bodies in the prevention, detection and prosecution of crime;
- to assist in day-to-day management, including ensuring the health and safety of staff and others;
- to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings; and
- to assist in the defence of any civil litigation, including employment tribunal proceedings;
This list is not exhaustive and other purposes may be or become relevant.

Monitoring

Camera locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV cameras will not focus on private homes, gardens or other areas of private property.
Images are monitored by authorised personnel.
Staff using surveillance systems will be given appropriate training to ensure they understand and observe the legal requirements related to the processing of relevant data.

How we will operate any CCTV and surveillance systems

Where CCTV cameras and surveillance systems are placed in the workplace, we will ensure that signs are displayed at the entrance of the surveillance zone to alert individuals that their image may be recorded. Such signs will contain details of the organisation operating the system, the purpose for using the surveillance system and who to contact for further information, where these things are not obvious to those being monitored.
Live feeds from CCTV cameras will only be monitored where this is reasonably necessary, for example to protect health and safety.
We will ensure that live feeds from cameras and recorded images are only viewed by approved members of staff whose role requires them to have access to such data. This may include staff involved with disciplinary or grievance matters. Recorded images will only be viewed in designated, secure offices.

Use of data gathered by CCTV and other surveillance systems

In order to ensure that the rights of individuals recorded by CCTV and other surveillance systems are protected, we will ensure that data gathered is stored in a way that maintains its integrity and security. This may include encrypting the data, where it is possible to do so.
We may engage data processors to process data on our behalf. We will ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.

Retention and erasure of data gathered by CCTV and other surveillance systems

Data from CCTV cameras and other surveillance systems will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes, data will be kept long enough only for incidents to come to light.
At the end of their useful life, all images stored in whatever format will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.

Use of additional surveillance systems

Prior to introducing any new surveillance system, including placing a new CCTV camera in any workplace location, we will carefully consider if they are appropriate by carrying out a privacy impact assessment (PIA).
A PIA is intended to assist us in deciding whether new surveillance cameras are necessary and proportionate in the circumstances and whether they should be used at all or whether any limitations should be placed on their use.
Any PIA will consider the nature of the problem that we are seeking to address at that time and whether the surveillance camera is likely to be an effective solution, or whether a better solution exists. In particular, we will consider the effect a surveillance camera will have on individuals and therefore whether its use is a proportionate response to the problem identified.
No surveillance cameras will be placed in areas where there is an expectation of privacy (for example, in changing rooms) unless, in very exceptional circumstances, it is judged by us to be necessary to deal with very serious concerns.

Ongoing review of CCTV and other surveillance system use

We will ensure that the ongoing use of existing CCTV and other surveillance cameras in the workplace is reviewed to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.

Human Rights Act 1998

The systems will be operated with due regard to the Human Rights Act 1998 and in particular the provisions of Article 8, conveying on an individual the qualified right to respect for his or her private and family life.
No interest will be shown in private property and cameras will not look into such areas. In addition the use of cameras elsewhere will be proportionate to the objectives detailed in this policy.
Extra MSA Staff will have clear guidelines and any inadvertent contraventions will be recorded and the reasons for the occurrence given. The scheme will be managed and audited to ensure that individuals’ privacy is not breached.
The day-to-day management of the cameras will be the responsibility of the Site Manager who will report to a member of the senior management team.
Only Extra MSA staff will have access to the office where the cameras are located. Designated Extra MSA staff will also have access to all recorded material retained, providing such access is in accordance with both the objectives and purposes of the scheme and is authorised by the senior management team. Dummy cameras may be used in the scheme.

Requests for disclosure

We may share data with other group companies where we consider that this is reasonably necessary for any of the legitimate purposes.
No images from our CCTV and other surveillance cameras will be disclosed to any other third party, without express permission being given by the Site Manager. Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced.
In other appropriate circumstances, we may allow law enforcement agencies to view or remove CCTV and other surveillance footage where this is required in the detection or prosecution of crime.
We will maintain a record of all disclosures of CCTV or other surveillance camera footage.
No images from will ever be posted online or disclosed to the media.

Subject access requests

Data subjects may make a request for disclosure of their personal information and this may include CCTV and other surveillance images (data subject access request). A data subject access request is subject to the statutory conditions from time to time in place and should be made in writing.
In order for us to locate relevant footage, any requests for copies of recorded images must include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual.
We reserve the right to obscure images of third parties when disclosing data as part of a subject access request, where we consider it necessary to do so.

Complaints

Please use the contact us page on this web site

Requests to prevent processing

We recognise that, in rare circumstances, individuals may have a legal right to prevent processing likely to cause substantial and unwarranted damage, or to prevent automated decision making.

Competition terms and conditions – (2025)

Each calendar month, Extra MSA will launch a review competition on its social media pages. Extra MSA will give away a £50 voucher to spend at either Nando’s, Pizza Express, or Starbucks. To be in with a chance of winning, users must comment ‘done’ under the competition post. Extra MSA will then DM the users and ask for a screenshot of their review of an Extra MSA site published on either Google, Tripadvisor or Facebook. The screenshot must be published during the month of the competition, clearly showing which platform the review was left on, and for which Extra MSA location.

T&Cs

- One entry per account, per competition per month.

- A new review needs to be posted each month to be able to be re-entered. To validate the entry, Extra MSA will get in touch with the users via DM where a screenshot of the review can be shared. The screenshot will need to be shared with Extra MSA via DM before the last day of the month.

- The winner will be chosen at random and notified in the comment section (via the channel they entered the competition on), during the first five working days of the following month (e.g. January winner notified in the first five working days of February).

- After tagging them in the comments, Extra MSA will also contact the winner via DM to finalise the voucher details. Winners have five working days from the day of notification to respond. If a winner does not respond during this time, Extra may select an alternative winner at its discretion and the prior winner will no longer be eligible to receive a prize.

- The competition period extends from 00:01 am on the first day of the month and finishes at 11:59 on the last day of the month.

- Winners will be notified via either X, Facebook, Threads or Instagram by Extra MSA or its representatives (and may be tagged as winners publicly).

- Prizes will be awarded in the form of electronic vouchers (sent by email), and subject to the conditions put in place by the retailer in question in terms of its use.

- The decision of Extra MSA and its representatives will be final, and no correspondence will be entered into regarding the allocation of prizes.

- The competitions are open to residents of the United Kingdom aged 18 years or over. Extra MSA reserves the right to request proof of age at its discretion.

- Extra MSA reserves the right to cancel or modify the competitions at any stage, without warning.

- Extra MSA reserves the right to amend these Terms and Conditions or cancel the Prize Draw (or any part of it) without notice if required by law or due to reasons beyond our reasonable control. We also reserve the right to cancel the Prize Draw or amend these Terms and Conditions for a specific reason where it’s reasonable or valid to do so.

- We reserve the right to void or remove an entry or withdraw a prize without notice, particularly if it is believed the entrant has not adhered to the terms and conditions or has otherwise not acted in the spirit of the competition.

- This competition is run by Extra MSA and its partners and is in no way aligned with either X, Facebook, Threads or Instagram. As such, those organisations hold no responsibility in relation to the competition.

- Extra MSA will not be liable (to the extent permitted by law) for any loss or damage arising out of organising or holding this Prize Draw or as a result of your participation in the Prize Draw.

- By entering, you agree that the company’s decision is final in all cases of dispute or query.

June 2025 Father’s Day competition terms and conditions

To celebrate Father’s Day 2025, Extra MSA has launched a competition on its social media pages.

This will run from Wednesday June 4^th at 00:01am until Sunday 15^th June at 11.59pm. There is maximum one entry per account.
This will be a photo competition where Extra will give away an M&S hamper or an M&S voucher worth £50. The winner will be presented with the choice between the two upon notification of their win. If selected, the items in the hamper will be chosen according to the winner’s dietary requirements.
To be in a chance of winning, users must do the following depending on the channel where they enter the competition:
- X: users must share a selfie with, or a picture of, their father, father figure, or a dad that inspires them, in the comment section of the competition post and tag @ExtraServicesUK. Users must also follow Extra MSA.
- Facebook: users must share a selfie with, or a picture of, their father, father figure, or a dad that inspires them, in the comment section of the competition post and tag @Extra MSA. Users must also follow Extra MSA.
- Instagram: users must share a selfie with, or a picture of, their father, father figure, or a dad that inspires them, to their stories and tag @extraservicesuk. Accounts must be public in order for Extra to verify the story has been published. Users must also follow Extra MSA.
The shared content needs to be publicly viewable on X, Facebook or Instagram feeds / stories, and by publishing, the users agree to Extra MSA re-sharing that content on social media and other marketing materials.
The winner will be chosen at random and notified (via the channel they entered the competition on), during the w/c 16^th Winners may be tagged as winners publicly.
The winner will have five working days from the day of notification to respond. If a winner does not respond during this time, Extra may select an alternative winner at its discretion and the prior winner will no longer be eligible to receive a prize.
Prizes will be awarded in the form of a physical hamper delivered to the winner’s address, or an email voucher sent to the winner’s email address. Extra MSA will clarify with the winner if there are any dietary requirements to be considered if the hamper is selected.
The decision of Extra MSA and its representatives will be final, and no correspondence will be entered into regarding the allocation of prizes.
The competitions are open to residents of the United Kingdom aged 18 years or over. Extra MSA reserves the right to request proof of age at its discretion.
Extra MSA reserves the right to cancel or modify the competitions at any stage, without warning.
Extra MSA reserves the right to amend these Terms and Conditions or cancel the Prize Draw (or any part of it) without notice if required by law or due to reasons beyond our reasonable control. We also reserve the right to cancel the Prize Draw or amend these Terms and Conditions for a specific reason where it’s reasonable or valid to do so.
We reserve the right to void or remove an entry or withdraw a prize without notice, particularly if it is believed the entrant has not adhered to the terms and conditions or has otherwise not acted in the spirit of the competition.
This competition is run by Extra MSA and its partners and is in no way aligned with either Twitter, Facebook, Threads or Instagram. As such, those organisations hold no responsibility in relation to the competition.
Extra MSA will not be liable (to the extent permitted by law) for any loss or damage arising out of organising or holding this Prize Draw or as a result of your participation in the Prize Draw.
By entering, you agree that the company’s decision is final in all cases of dispute or query.

COOKIE POLICY

Last updated July 25, 2024

This Cookie Policy explains how Extra MSA ("Company," "we," "us," and "our") uses cookies and similar technologies to recognize you when you visit our website at https://extraservices.co.uk ("Website"). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, Extra MSA) are called "first-party cookies." Cookies set by parties other than the website owner are called "third-party cookies." Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

We use first- and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Website for advertising, analytics, and other purposes. This is described in more detail below.

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

The Cookie Consent Manager can be found in the notification banner and on our website. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. You may also set or amend your web browser controls to accept or refuse cookies.

The specific types of first- and third-party cookies served through our Website and the purposes they perform are described in the table below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):

Essential website cookies:

These cookies are strictly necessary to provide you with services available through our Website and to use some of its features, such as access to secure areas.

Name:	TERMLY_API_CACHE
Purpose:	Used to store visitor’s consent result in order to improve performance of the consent banner.
Provider:	extraservices.co.uk
Service:	Termly View Service Privacy Policy
Type:	html_local_storage
Expires in:	1 year

Name:	csrf_token
Purpose:	Helps prevent Cross-Site Request Forgery (CSRF) attacks using Javascript.
Provider:	extraservices.co.uk
Service:	Django View Service Privacy Policy
Type:	http_cookie
Expires in:	30 days

Analytics and customization cookies:

These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customize our Website for you.

Name:	_ga
Purpose:	Records a particular ID used to come up with data about website usage by the user
Provider:	.extraservices.co.uk
Service:	Google Analytics View Service Privacy Policy
Type:	http_cookie
Expires in:	1 year 1 month 4 days

Name:	_ga_#
Purpose:	Used to distinguish individual users by means of designation of a randomly generated number as client identifier, which allows calculation of visits and sessions
Provider:	.extraservices.co.uk
Service:	Google Analytics View Service Privacy Policy
Type:	http_cookie
Expires in:	1 year 1 month 4 days

Name:	mc
Purpose:	Used by quantserve to record unique numbers that identify your browser and interaction history. It expires in 5 years
Provider:	.quantserve.com
Service:	Quantcast Measurement Service View Service Privacy Policy
Type:	server_cookie
Expires in:	1 year 1 month

Advertising cookies:

These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

Name:	__qca
Purpose:	These cookies are associated with a B2B marketing platform, formerly known as Bizo, which is now owned by LinkedIn, the business networking platform. This sub-domain is connected with LinkedIn's marketing services that enable website owners to gain insight into types of users on their site based on LinkedIn profile data, to improve targeting.
Provider:	extraservices.co.uk
Service:	LinkedIn View Service Privacy Policy
Type:	html_local_storage
Expires in:	persistent

Name:	IDE
Purpose:	Used to measure the conversion rate of ads presented to the user. Expires in 1.5 years.
Provider:	.doubleclick.net
Service:	DoubleClick View Service Privacy Policy
Type:	server_cookie
Expires in:	1 year 11 months 29 days

Name:	_gcl_au
Purpose:	Used by Google AdSense for experimenting with advertisement efficiency across websites using their services.
Provider:	.extraservices.co.uk
Service:	Google AdSense View Service Privacy Policy
Type:	http_cookie
Expires in:	2 months 29 days

Name:	landing
Purpose:	Used to track user interactions with online advertisements
Provider:	pagead2.googlesyndication.com
Service:	DoubleClick View Service Privacy Policy
Type:	pixel_tracker
Expires in:	session

Name:	test_cookie
Purpose:	A session cookie used to check if the user’s browser supports cookies.
Provider:	.doubleclick.net
Service:	DoubleClick View Service Privacy Policy
Type:	server_cookie
Expires in:	15 minutes

Name:	__qca
Purpose:	These cookies are associated with a B2B marketing platform, formerly known as Bizo, which is now owned by LinkedIn, the business networking platform. This sub-domain is connected with LinkedIn's marketing services that enable website owners to gain insight into types of users on their site based on LinkedIn profile data, to improve targeting.
Provider:	.extraservices.co.uk
Service:	LinkedIn View Service Privacy Policy
Type:	http_cookie
Expires in:	1 year 26 days

Unclassified cookies:

These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

Name:	qcSes
Provider:	extraservices.co.uk
Type:	html_session_storage
Expires in:	session

Name:	receive-cookie-deprecation
Provider:	.doubleclick.net
Type:	server_cookie
Expires in:	5 months 27 days

Name:	elementor
Provider:	extraservices.co.uk
Type:	html_local_storage
Expires in:	persistent

How can I control cookies on my browser?

As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser's help menu for more information. The following is information about how to manage cookies on the most popular browsers:

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit:

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our Website or opened an email including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Do you use Flash cookies or Local Shared Objects?

Websites may also use so-called "Flash Cookies" (also known as Local Shared Objects or "LSOs") to, among other things, collect and store information about your use of our services, fraud prevention, and for other site operations.

If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

Do you serve targeted advertising?

Third parties may serve cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. They can accomplish this by using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details, or other details that directly identify you unless you choose to provide these.

How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please therefore revisit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at compliance@extramsaproperty.co.uk or by post to:

Extra MSA

Administration Office

Peterborough, PE7 3UQ

United Kingdom

Phone: (+44)1733405183

Modern Slavery Policy

Effective date 19/12/2024

Extra MSA (Motorway Service Areas) Group & subsidiary operating companies.

Extra MSA Property UK Ltd, Extra MSA Baldock Ltd, Extra MSA Beaconsfield Ltd, Extra MSA Blackburn Ltd, Extra MSA Cambridge Ltd, Extra MSA Cobham Ltd, Extra MSA Cullompton Ltd, Extra MSA Leeds Ltd, Extra MSA Peterborough Ltd Extra.

Business Profile

Extra operates 10 Motorway Service Areas (MSA) across England. Two of the Locations (Tibshelf and Winchester) are fuel filling stations only, operated & insured by Shell & BP. Extra operates the business 24/7, 365 days per year as obliged by operating covenants from National Highways to serve the safety of the strategic motorway road network (SRN)

The 8 full MSA’s operated by Extra contain retail shops, food & drink outlets, Hotels, meeting rooms for hire, fuel filling stations, parking for all types of vehicles, overnight parking, electric vehicle charging and indoor & outdoor seating areas. Some locations might include walking areas, lakes, and small wooded areas.

Corporately, Extra includes a Senior Management Team, Finance Team & will work closely with a carefully selected set of third-party professionals and consultants.

Operationally, Extra are responsible for managing & maintaining all the indoor and outdoor communal areas. The brands, hotels & fuel filling stations are separately operated by the respective tenants with their own employees.

Operational employee personnel include Cleaners, Security, Grounds Persons, Maintenance, Supervisors & Site Managers supported by a small Area Management Team & Administration Office.

Introduction

All businesses create, and are exposed to, risk as part of their everyday operational activities. The acceptability of risk relates to the standards adopted by each person, the company, our stakeholders, and the regulatory authorities. Risks that are acceptable are ones where no additional control measures may be necessary.

It is important that we identify and deal with ‘significant risks’ rather than trivial issues and concentrate on those that might cause ‘foreseeable’ harm or damage. It is important to acknowledge that not everyone will initially appreciate how they can be harmed, and everyone will have different opinions as to what constitutes ‘safe’ behaviour. It is therefore necessary for us to determine what is acceptable and what controls are required to be implemented to ensure a safe working environment and compliance with regulatory standards.

Our risk management programme forms the basis of our Health and Safety Management System and should be clearly understood by personnel at all levels of the organization.

We are working to guard against being complicit in human rights violations & uphold the rights of our employees and any other individuals that we are in contact with, directly or indirectly.

We work hard to build trust in society, which is why we seek to behave & act in accordance with recognized human rights standards. Including, but not limited to: Human Rights Act 1998 – https://www.legislation.gov.uk/ukpga/1998/42/contents

Scope

Our Modern Slavery Policy applies to all Extra MSA group Employees, stakeholders, and Partners. We also expect our suppliers to respect and adhere to this policy.

Principles

We will seek to avoid causing or contributing to adverse human rights impacts through our own activities and address such impacts, if they do occur, in a timely and appropriate manner.

Seek to prevent or mitigate adverse human rights impacts that are related to our operations, products, and services through our business relationships.

Provide for or cooperate in their remediation through legitimate processes, if we identify that we have caused or contributed to adverse human rights impacts. Continue to look for ways to support the promotion of human rights within our operations and our sphere of influence.

Policy

This sets out our position with respect to modern slavery and sits alongside our

Employment Handbook, Health and Safety Policy, Violence & Aggression Policy, and the Human Rights Policy.

Our statements below draw upon the Modern Slavery Act 2015- https://modernslavery-statement-registry.service.gov.uk/

Child Labour:

Extra MSA group will not use child labour and will comply with all relevant laws in this regard. We do, however, support legitimate workplace apprenticeships, internships and other similar programmes that comply with the applicable laws and regulations.

Modern Slavery:

Extra MSA Group will not use forced, bonded or involuntary labour, and workers are not required to lodge ‘deposits or identity papers with the firm and can leave after giving reasonable notice, with all wages owed to be paid. We have a zerotolerance approach towards human trafficking. Our policy can be found at https://extraservices.co.uk/policies/modern-slavery-policy/

Health & Safety:

All Extra MSA group employees will work in an environment that is both safe and healthy, in line with our Health and Safety Policy.

Discipline:

Extra MSA Group prohibits physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation. Disciplinary and grievance procedures are clearly documented and communicated to all employees in our Employee Handbook. All disciplinary measures of a serious nature are recorded and actioned.

Freedom of Association:

Extra MSA Group recognises that all its employees have the right to form and join organisations of their own choosing if this does not contravene any specific contract clauses. The company takes active measures to seek employees’ views about the business. Extra MSA group does not recognise a trade union.

Working Hours:

MSA group will ensure that working hours are reasonable and comply with the law and industry standards. No person will be treated less favourably if the work part time or are casual workers

Equality:

Extra MSA Group is fully committed to eliminating discrimination in recruitment, training and working conditions, on grounds of race, colour, sex, age, religion, political opinion, national extraction, sexual orientation, disability, or social origin and to promoting equality of opportunity and treatment as outlined in the Employee Handbook.

Employment Terms:

Extra MSA group will provide written and clear contracts which detail the terms and conditions of its staff employment. We will ensure that work performed by employees is based on UK employment law and practice.

Remuneration:

Extra MSA Group will, at a minimum, provide wages and benefits that meet national living wage standards. We will provide employees with clear written information on their pay and conditions. The firm prohibits deductions from employees’ wages as a disciplinary measure. Extra MSA Group is committed to equal pay and benefits for work of equal value.

Grievance:

Where a human rights violation is identified, we will work with all parties involved to seek access to remedy, compensation, and justice for the victim. We will also investigate the root cause so that we can take appropriate steps to prevent such a violation reoccurring.

Whistleblowing:

Our ‘Whistleblowing’ helpline (Protect – An independent whistleblowing charity) 020 311 2520 or whislte@protect-advice.org.uk is available to all staff and Partners who come across unethical behaviour that cannot be resolved locally or for which the normal consultation process is not suitable. Anyone raising a genuine concern which is in the public interest will be protected from victimisation. Third parties including suppliers can also telephone or email the helpline.

Implementation & Review:

The Operations Director is responsible for the company’s’ Human Rights Policy. Senior Management Team will review the policy on an annual basis with respect to its relevance and effectiveness and will make improvements, as necessary. Our Human Rights Policy and our Modern Slavery Policy are both accessible to our employees via the companies Intranet & interested parties on the public facing website https://extraservices.co.uk/ or upon request.

CEO Approval

I have reviewed and approved the Modern Slavery Policy as presented by the Group Operations Director.

Waste Management Policy

Issue 1

Effective date 19/12/2024

Page 1 of 10

Extra MSA Group & subsidiary operating companies (also “the Group”)

Business Profile

Extra MSA Group operates 10 Motorway Service Areas (MSA) across England. Two of the Locations (Tibshelf and Winchester) are fuel filling stations only, operated & insured by Shell & BP. Extra MSA Group operates the MSA’s 24/7, 365 days per year as obliged by operating covenants from National Highways to serve the safety of the strategic motorway road network (SRN).

The 8 full MSA’s operated by Extra MSA Group contain retail shops, food & drink outlets, hotels, meeting rooms for hire, fuel filling stations, parking for all types of vehicles, overnight parking, electric vehicle charging and indoor & outdoor seating areas. Certain locations include walking areas, lakes, and small wooded areas.

Operationally, Extra MSA Group are responsible for maintaining all the indoor and outdoor communal areas. Hotel waste is disposed of by Extra MSA group and therefore included in this policy, however fuel filling stations are not.

Operational employee personnel include Cleaners, Security, Grounds Persons, Maintenance, Supervisors & Site Managers supported by a small Area Management Team & Operations Admin Office. At least 1 Extra employee will be present at each location, and it may vary between 1 & 7 people depending on onsite trading pattern, trade volume and the time of day or night.

Extra MSA Group work with all its branded tenant partners across food and drink, hotel accommodation, business meeting rooms, fuel filling stations and electric vehicle charging sectors.

Introduction

This Waste Management Policy forms part of the Groups sustainability framework and helps support the Group’s Environmental, Social and Governance policies.

The policy aims to reduce negative environmental impacts arising from our waste activities, seeking to prevent, reuse, repurpose and reduce waste from our operations. The Policy also aims to ensure that the Group manages waste issues in accordance with the prevention of pollution and compliance with environmental legislation at all times.

The Group is committed to implementing an effective and responsible waste resource management process that meets and ideally exceeds legislative, regulatory, and best practice legislation and guidance. The Group has a “Duty of care” to effectively manage waste, and this is a legal obligation to ensure the safety or well-being of others.

Policy

This Policy is approved by the Extra MSA Group CEO; it represents the group’s direction to the business on managing operational risks in connection with managing waste responsibly. Compliance with this policy is mandatory through aligning the Operational Management System processes and people behaviors to the commitments below.

The Group adopts the ‘waste hierarchy’ of prevention, reuse, recycling, other recovery, and disposal. The Group implements processes, procedures and initiatives that ensure compliance with environmental legislation and best practice, and which encourage waste producers to reduce the overall waste that they produce and prevent waste production wherever possible.

Waste Hierarchy

Figure 1 – Waste hierarchy graphic

The Group has a robust and comprehensive recycling infrastructure and all employees, tenant employees and customers are encouraged to make use of these facilities to maximise recycling as much waste as is possible.

The Group’s Waste Management Policy also includes the need to consider end-of-life disposal costs and environmental impact when making procurement decisions including the construction of new or refurbished buildings.

The Policy also ensures that we are complying with regulation, legislation, and best practice to minimise the risk of immediate and future pollution or harm to health when carrying out operational activities.

Targets

This policy requires that by 2030 at the latest, the Group has successfully reused or recycled over 75% of total annual waste by tonnage. At the policy’s effective date, 100% of our waste is diverted from landfills.

The Group also aspires to increase recycling rates to greater than 95% of total annual tonnage and score ‘+90’ in the Zero Waste Index (ZWI).

In addition to the recycling targets, the Group aims to reduce plastics by using a combination of alternative materials in partnership with tenant brand partners.

Plastic Waste Reduction

The Group recognises the adverse impact of plastic waste, from production through to disposal. Plastic pollution can have a harmful impact on the marine environment and the Group is seeking to reduce plastic use and wastage at all operational MSA locations.

The Group is committed to engaging with tenants on waste procedures, identifying sources of single use plastic in packaging and finding alternative compostable alternatives.

Extra MSA, in conjunction with tenants, operates a water refill scheme. Whereby, customers can request their bottles, containers, and other vessels to be filled with mains potable water.

To reduce the use of disposable coffee cups which contain a plastic liner, all coffee shops offer a discount if the customer provides a reusable cup. Extra MSA Group also provides specialist waste disposal services to recycle disposable cups.

Site Waste Management

The Group has in place several internal and external waste management and recycling facilities.

Compliance

Employees, Tenant Employees, Contractors, and other users are required to have appropriate procedures and waste management processes & training in place as applicable to ensure that waste generated is managed, stored, and disposed of safely and in line with the Groups policies.

Waste Transfer Notes must be obtained by the Groups Operations Department when using an external approved service provider/contractor to dispose of waste.

Waste minimisation

Waste should be prevented or minimised wherever possible. The Group encourages Employees, Customers & Tenant Employees to minimise plastic waste as much as possible by using reusable bottles for drinks.

Monitoring and Reporting Performance

The Group’s waste contractor records and monitors the amount of waste that is disposed of and recycled daily. This monitoring data includes regular audits of our recycling to ensure that it is uncontaminated by other inappropriate materials. The monitoring data is recorded and reported on a monthly basis to internal and annually to external stakeholders including the Group’s investors and the UK Government.

Figure 2 – Extract of the Power BI Waste Dashboard

Hazardous Waste

1.1 Definition

Hazardous Waste is waste that can be harmful to health or the environment. It includes infectious biological/clinical waste, chemicals, solvents, pesticides, fluorescent light tubes, equipment containing fluorinated gases/liquids, non-edible oils, batteries, asbestos, and paints.

1.2 Policy Statement

The Group will manage, as far as is reasonably practicable, all hazardous waste activities falling under its control in a manner such as to minimise the harm to human health or the environment.

1.3 The Group will achieve this by:

Producing and communicating procedures to enable employees to comply with their ‘duty of care’ for the management of hazardous wastes and monitor these procedures to ensure compliance. Applying the waste management hierarchy with the aim of minimising the generation of hazardous waste.

1.4 Responsibilities

The Group Operations Director has responsibility for health and safety matters at the Group. The Director delegates responsibility for undertaking aspects of these duties through line management and identified roles, namely via the Senior Management Team and Operations Department leadership structure.

The following people are identified as having responsibilities (in addition to any other responsibilities under other health and safety policies) for the management of hazardous waste in those areas, and for those relevant persons, that fall under their control:

1.4.1 Senior Team Management & Area Managers are responsible for ensuring that:

Departmental arrangements for the management of hazardous wastes are put in place, communicated, and monitored.
Competent persons are identified to implement the arrangements for the management of hazardous waste.
Where practicable, aim to minimise the procurement of hazardous materials to prevent redundant materials needing to be disposed of as hazardous waste.
Ensure sufficient allocation of appropriate storage facilities for hazardous wastes until such time as it can be collected.

1.4.2 Site Managers are responsible for:

Ensuring the management and disposal/recovery of hazardous waste is included in the risk assessments and local procedures for the tasks undertaken by their employees.
Ensuring that relevant workers are informed of the significant findings of such risk assessments and that local procedures are followed for the management of hazardous wastes.

1.4.3 Estates Operations Department personnel are responsible for:

Segregation of hazardous waste under their management, such as WEEE and asbestos- containing waste, and storing them safely and securely before arranging for their disposal in accordance with relevant legislation.
Ensuring that staff who may encounter hazardous waste are adequately trained to carry out their duties.
Maintaining records, at the premises, of hazardous waste consignment notes, consignee returns and any other related documents (such as carrier schedules or rejected loads) for at least 3 years.
Undertaking periodic ‘duty of care’ audits of licenced waste contractors.

1.4.4 The Groups Occupational Health, Safety and Wellbeing department (Group Operations Director) is responsible for:

Ensuring that the appropriate licence/s is renewed with the regulatory authority when required.
Ensuring that procedures are established to ensure the ‘best available techniques’ for the correct identification, segregation, labelling and storage of hazardous wastes on university premises under its control.
The production and communication of procedures and guidance regarding the management of hazardous waste, under its remit, on university premises.
Managing the collection of hazardous waste, under its remit, from university storage facilities by authorised licensed contractors.
Undertaking periodic ‘duty of care’ audits of licenced waste contractors.
Maintaining records, at the premises, of hazardous waste consignment notes, consignee returns and any other related documents (such as carrier schedules or rejected loads) for at least 3 years.

1.4.5 Employees are required to:

Follow the Groups procedures to manage hazardous wastes. This includes the correct identification, segregation, disposal, and storage of hazardous wastes in dedicated, labelled containers with prompt removal when full.

Accepted Materials and Recycling

Extra MSA employees, tenant employees and customers are encouraged to recycle wherever possible in line with site waste procedures. Signage is provided to educate and guide correct separation of waste streams.

Waste Disposal

All waste disposal is arranged by Extra MSA’s waste broker. Extra MSA Group has pledged to avoid 100% waste from landfill.

Waste that has been separated in recycling bins is sent to a Materials Recycling Facility (MRF) or specialist waste recycling plants.

All general waste is to be sent to an incineration plant, and zero waste will be sent to a landfill.

Implementation & Review:

The Group Operations Director is responsible for the company’s’ Waste Management Policy. The Groups’ Senior Management Team will review the policy on an annual basis with respect to its relevance and effectiveness and will make improvements, as necessary. Our Waste Management Policy is accessible to our employees via the companies Intranet & interested parties on the public facing website https://extraservices.co.uk/ or upon request.

CEO Approval

I have reviewed and approved the Supplier Code of Conduct Policy as presented by the Group Operations Director.

Environmental, Social and Governance (“ESG”) Policy

Effective Date 19/12/2024

Extra MSA Group & subsidiary operating companies:

Introduction

Extra MSA Group (“The Group”) is a motorway service area operator in the UK.

The Group has undertaken an ESG materiality assessment to identify the issues material to its operations and long-term resilience, which was endorsed by the Board of Directors.

This ESG Policy details the Company’s commitments and objectives in relation to the material ESG matters as derived from the materiality assessment.

Governance

This policy applies to the Extra MSA Group in its entirety and will be updated periodically by management to reflect regulatory, industry, market, and other developments.

Extra MSA Group recognises the impacts its activities have on the environment, natural resources and the community and is committed to integrate ESG considerations in all aspects of its business. This policy applies to the Group and its contractors.

Suppliers shall adhere to the principles of this policy and observe and comply with all applicable environmental, human rights, health, safety, labour and conduct Laws of the jurisdictions in which they do business.

The Board of Directors has ultimate oversight for the implementation of the ESG Policy, which will review and approve annually, at a minimum.

Materiality Statement

ESG matters material to Extra MSA Group include:

Climate change risk and resilience: assessment, identification and management of the likelihoods, consequences and impacts of climate change and adaptation and mitigation efforts, covering both climate transition risk (policy and legal, technology, market and reputation risk driven by the transition to a low carbon economy) and climate physical risk (acute and chronic risk driven by the physical impact of climate change)

Greenhouse gas emissions and Net Zero: the release of greenhouse gas emissions and the identification, assessment and implementation of initiatives aimed at progressively reducing them, contributing to achievement of net zero carbon targets aligned to a scientific approach

Natural capital: awareness, recognition, monitoring and management of the company’s dependency and impact on the world’s natural resources, including reduction of pollution, efficient resources sourcing, management and consumption, waste management and protection of land, soil, air, water, and all living organisms

Health, safety, and wellbeing: policies, processes, training, recording, reporting and investigation of incidents concerning employees, contractors and users making up the occupational health, safety, and wellbeing management systems

Fair working conditions: fair pay, equal pay for work of equal value, freedom of association, representation, training, and development

Diversity, equality, and inclusion: ensuring equitable, fair, and unbiased access to opportunities for all, at all levels and a workplace free from harassment and discrimination, in alignment with Principle 6 of the UN Global Compact

Modern slavery: monitoring of labour standards and working conditions. Whilst Extra MSA Group operations are in an OECD jurisdiction, protection of human rights against instances of child, forced or compulsory labour is deemed material

Stakeholder engagement: interactions with stakeholders and lobbying activities can have a material impact on Extra MSA Group’s performance

Board composition, skills, and diversity: the composition of the Board, the presence of non-executive and/or independent directors and employee representatives, the independence of the Board Chair, cognitive, gender, age, race and background diversity and its regular assessment

Fraud, bribery, and corruption: the adoption and implementation of policies and processes aimed at ensuring alignment with the highest ethical standards, including anti-bribery, anti-fraud, and anti-corruption provisions in alignment with Principle 10 of the UN Global Compact

Oversight of sustainability: the integration of sustainability into governance frameworks and the degree of Board involvement

Cyber security and data protection and privacy: the policies, processes, monitoring, and reporting of the protection of the internet connected systems and of data

Responsible procurement and supply chain management: ensuring the procurement strategy for the Company for vehicles, infrastructure, and equipment upholds sustainability, human rights, and anti-corruption / bribery standards, including, inter alia, no engagement in and condonement of any forms of forced and compulsory labour, as per principle 4 of the UN Global Compact, no engagement in and condonement of child labour, as per principle 5 of the UN Global Compact

Transparency and reporting: transparent reporting of sustainability information and verifiable data

The table below summarises the ESG topics material to Extra MSA Group and addressed by this policy. These topics were deemed material because they were rated ‘medium’ or ‘high’ risk in GRESB Infrastructure assessment or considered to have high environmental or social impact and/or high fiscal impact in the double materiality assessment.

Topic / Sub-topic	GRESB Relevance	Double Material Relevance / Alignment
Air pollution	Medium	E2 – Pollution of air
Energy consumption	Medium	E1 – Energy
Greenhouse gas emissions	Medium	E1 – Electric vehicles
Material sourcing and resource efficiency	Medium	E5 – Resource Use
Waste management	Medium	E5 – Waste
Climate-related risks (transition and physical)	N/A	E1 – Climate change mitigation
Biodiversity and habitat	No relevance	E4 – Habitat loss, landscape fragmentation and loss of grasslands
Net Zero	Medium	E1 – Climate change mitigation
Employee engagement	Medium	S1 Diversity, gender equality, training skills development
Customer satisfaction	Medium	–
Health and Safety employees	High	S1 Health and safety
Health and Safety – supply chain	Medium	S2 Health and safety
Health and Safety – community	Medium	S4 Health and safety
Health and Safety – users	High	S4 Health and safety
Diversity and inclusion	High	S4 Responsible marketing practices
Stakeholder relations	Medium	–
Local employment	High	S3 Land related impacts
Community development	Medium	S3 Land related impacts
Board composition	Medium	–
Board ESG oversight	Medium	–
Fraud	Medium	–
Delegating authority	Medium	–
Independence of Board Chair	Medium	–
Remuneration Committee	Medium	S4 Executive Compensation
Shareholder rights	Medium	–
Conflicts of interest	Medium	–
Cyber security	Medium	S4 Cyber security
Data protection and privacy	High	S4 Cyber security
Lobbying activities	Medium	–
Political contributions	Medium	–
Whistleblower protection	Medium	G1 Whistleblowing protection
Audit committee structure/independence	Medium	–
Bribery and corruption	Low	G1 Corruption and bribery
Labour standards and working conditions	Low	S2 Forced labour S2 Child labour

The following risks are deemed ‘low relevance’ and will continue to be monitored although not categorised as material to the business:

Water management
Freedom of association

ESG Policy

Extra MSA Group commitments and objectives in relation to ESG include:

Extra MSA Group is committed to Net Zero Targets by 2050 or sooner, aligned to the science-based targets;
Comply with all environmental laws of the jurisdictions in which it does business;
Develop and maintain robust H&S policies and processes to ensure the safety of all employees, contractors, users, and community members, fostering a strong safety culture at all levels, including in the selection of suppliers;
Assess, monitor and report its impacts on the environment, including greenhouse gas emissions, air pollution and water inflows and outflows aiming at progressively reducing them;
Adopt a strategic approach to waste management, aiming to increase recycling rates to 75% and divert 100% of waste from landfill;
Embed ESG and resource efficiency considerations in its procurement processes and materials sourcing, seeking alternatives that promote the efficient use of resources and energy as well as clean and low energy solutions;

Monitor and assess its resilience to climate-related risks, including transition and physical risks and identify initiatives to contribute to the achievement of global Net Zero targets;
Create and foster a diverse, equitable and inclusive working environment, where employees are valued and their perspective accounted for via employee engagement, promoting a working environment free from harassment and discrimination, including via offering equal remuneration for work of equal value;
Protect human rights, including freedom of association, ensuring labour standards, and working conditions comply with local regulations and international conventions and best practices;
Ensure no engagement in and condonement of any forms of forced and compulsory labour and child labour;
Adopt a strategic approach to stakeholder relations and lobbying activities, disclosing to the Board of Directors political contributions;
Endeavour to make a positive contribution to local employment and community development;
Uphold to the highest standards of corporate governance and business ethics, and align with the relevant standards on anti-fraud, anti-bribery, and anti-corruption, protecting shareholder rights and ensuring transparency;
Comply with laws, regulations, and guidelines and to perform regular conformity assessments to ensure compliance with applicable requirements;
Identify and manage conflicts of interest, notifying the Board as appropriate;
Pro-actively monitor and manage cyber security, with due care given to data protection and privacy, especially with reference to personal information;
Ensure its approach to ESG is revised annually to align with latest best practices and regulations, as applicable to the company and its shareholders; and
Provide the Board with transparent and reliable ESG information to support its oversight on such matters.

Implementation & Review:

The Operations Director is responsible for the company’s’ ESG Policy. Senior Management Team will review the policy on an annual basis with respect to its relevance and effectiveness and will make improvements, as necessary. Our ESG Policy is accessible to our employees via the companies Intranet & interested parties on the public facing website https://extraservices.co.uk/ or upon request.

CEO Approval

I have reviewed and approved the Environment; Social & Governance (ESG) Policy as presented by the Group Operations Director.

Tom Dobson

Dec 20, 2024

Human Rights Policy

Effective date 19/12/2024

Extra MSA (Motorway Service Areas) Group & subsidiary operating companies.

Business Profile

Corporately, Extra includes a Senior Management Team, Finance Team & will work closely with a carefully selected set of third-party professionals and consultants.

Operational employee personnel include Cleaners, Security, Grounds Persons, Maintenance, Supervisors & Site Managers supported by a small Area Management Team & Administration Office.

Introduction

Our risk management programme forms the basis of our Health and Safety Management System and should be clearly understood by personnel at all levels of the organization.

We are working to guard against being complicit in human rights violations & uphold the rights of our employees and any other individuals that we are in contact with, directly or indirectly.

Scope

Our Human Rights Policy applies to all Extra MSA group Employees and Partners. We also expect our suppliers to respect and adhere to this policy.

Principles

We will seek to avoid causing or contributing to adverse human rights impacts through our own activities and address such impacts, if they do occur, in a timely and appropriate manner.

Seek to prevent or mitigate adverse human rights impacts that are related to our operations, products, and services through our business relationships.

Policy

This sets out our position with respect to human rights and sits alongside our Employment Handbook, Health and Safety Policy, Violence & Aggression Policy, and the Modern Slavery Policy.

Our statements below draw upon the Human Rights at Work concepts – https://www.gov.uk/employment-status/worker

Child Labour:

Modern Slavery:

Health & Safety:

All Extra MSA group employees will work in an environment that is both safe and healthy, in line with our Health and Safety Policy.

Discipline:

Freedom of Association:

Working Hours:

MSA group will ensure that working hours are reasonable and comply with the law and industry standards. No person will be treated less favourably if the work part time or are casual workers

Equality:

Employment Terms:

Remuneration:

Extra MSA Group will, at a minimum, provide wages and benefits that meet national living wage standards. We will provide employees with clear written information on their pay and conditions. The firm prohibits deductions from employees’ wages as a disciplinary measure. Extra MSA group is committed to equal pay and benefits for work of equal value.

Grievance:

Whistleblowing:

Implementation & Review:

CEO Approval

I have reviewed and approved the Human Rights Policy as presented by the Group Operations Director.

Stakeholder Engagement Policy

Issue 1

Effective date 19/12/2024

Extra MSA (Motorway Service Areas) Group & subsidiary operating companies.

Business Profile

Corporately, Extra includes a Senior Management Team, Finance Team & will work closely with a carefully selected set of third-party professionals and consultants.

Operational employee personnel include Cleaners, Security, Grounds Persons, Maintenance, Supervisors & Site Managers supported by a small, Area Management Team & Administration Office.

Introduction

Extra MSA Group is committed to conduct its business in accordance with the applicable laws and regulations and to abide to the highest ethical and business conduct standards. The Company acknowledges the long-term sustainability of its business model requires engagement with its stakeholders, defined as those groups and entities whose decisions and opinions have an influence on and, at the same time, are affected by the Company activities, products or services and associated performance.

Governance

This Stakeholder Engagement Policy sets forth the Company’s fundamental principles and commitments underpinning the engagement with its stakeholders. The Board of Directors may approve other corporate policies and other materials addressing specific stakeholders.

This Stakeholder Engagement Policy will be updated periodically by the Senior Management team to reflect regulatory, industry, market and other developments and approved by the Board of Directors annually, at a minimum.

Relevant Stakeholders for the Company include:

Government / Regulators;
Users / customers;
Tenant Brands;
Employees;
Contractors;
Board of Directors;
Shareholders;
Suppliers;
Lenders and the financial community;
Local communities; – Media; and – the environment.

Policy

Extra MSA Group is committed to:

Act responsibly towards all Relevant Stakeholders
Actively listen to the Relevant Stakeholders’ legitimate concerns and interests
Factor consideration of the legitimate concerns and interests of all Relevant Stakeholders in the planning, implementation, and delivery of its strategy, having care to address conflicts between stakeholder concerns
Respond to the legitimate interests of the Stakeholders with which the Company interacts
Promote participation and engagement with and by all Relevant Stakeholders by setting up tailored and regular engagement mechanisms in the form of surveys, focus groups or others, as appropriate, providing feedback on the outcomes of the engagement process
Encourage the recognition by all Relevant Stakeholders of the Company commitments to community development, the environment, local employment, diversity, and inclusion and other environmental, social and governance (“ESG”) matters as included in its ESG Policy
Contribute through all the above to maintain its corporate reputation in all the countries in which it operates and does business

Stakeholder Engagement Program

The Company provides training to all its employees. The Company has an Employee Handbook describing grievance processes available to all employees.

The Company has a Supplier Code of Conduct which underpins engagement policy & plan with its suppliers and that is regularly evaluated and reviewed to ensure alignment with the latest regulations and best practices.

The Company has adopted a Whistleblower Policy which details the whistleblower process, being a stakeholder grievances process.

The Company regularly engages with shareholders and lenders. On matters concerning financially material climate risks, the company will use the recommendations of the TCFD as basis for engagement, providing stakeholders with information on physical and transition climate risks, including regular GHG emissions reporting.

Extra MSA Group has undertaken a materiality assessment to form its ESG strategic objectives. The materiality assessment was developed using the GRESB, ESRS and EFRAG double materiality frameworks with scoring shared with employees, shareholders, investors and the board as part of the relevant stakeholders list and engagement process.

Implementation & Review:

The Group Operations Director is responsible for the company’s’ Stakeholder Policy. The Board & Senior Management Team will review the policy on an annual basis with respect to its relevance and effectiveness and will make improvements, as necessary. Our Stakeholder Policy is accessible to our employees via the companies Intranet & interested parties on the public facing website https://extraservices.co.uk/ or upon request.

CEO Approval

I have reviewed and approved the Stakeholder Engagement Policy as presented by the Group Operations Director.

Supplier Code of Conduct Policy

Issue 1

Effective date 19/12/2024

Extra MSA (Motorway Service Areas) Group & subsidiary operating companies.

Extra MSA Property UK Ltd, Extra MSA Baldock Ltd, Extra MSA Beaconsfield Ltd, Extra MSA Blackburn Ltd, Extra MSA Cambridge Ltd, Extra MSA Cobham Ltd, Extra

MSA Cullompton Ltd, Extra MSA Leeds Ltd, Extra MSA Peterborough Ltd, Extra MSA Warrington Ltd

Business Profile

The organisational structure of, Extra includes a Senior Management Team, Finance Team, Operations Team, Development Team and will work closely with a carefully selected set of third-party professionals and consultants.

Introduction

Extra MSA Group has a Board of Directors, comprising of representatives of the management, 4 Non-Executive Directors and an Independent Chairperson.

Governance

Extra MSA Group is committed to conduct its business in accordance with the applicable laws and regulations and to abide to the highest ethical and business conduct standards.

This Supplier Code of Conduct sets forth the Company’s fundamental ethical and business conduct requirements for its suppliers. Suppliers are responsible for ensuring that their personnel, agents, representatives, suppliers, subcontractors, and other business partners understand and comply with the requirements set forth in this Supplier Code of Conduct. It is the responsibility of the supplier to notify Extra MSA Group in writing of any known or suspected violation of this Supplier Code of Conduct.

Extra MSA Group will assess the supplier’s compliance with the principles and commitments of this Supplier Code of Conduct during the provision of services and/or furnishing of products. Such assessment might include, inter alia, on-site inspections of facilities and review of information such as books, records, certifications, permits and other documentation evidencing supplier’s compliance with this Supplier Code of Conduct.

This Supplier Code of Conduct will be updated periodically by management to reflect regulatory, industry, market and other developments and approved by the Board of Directors annually, at a minimum.

Policy

Commitments

The Supplier must:

Never offer, promise, authorise or provide, directly or indirectly, anything of value (including, without limitation, business gifts or courtesies) with the intent or effect of inducing anyone to forego their duties and provide unfair business advantage to Extra MSA Group, the supplier, or others. The Supplier and all its employees, agents, representatives, suppliers, subcontractors and other business partners will comply with all the laws on anti-bribery, anticorruption, anti-money laundering and the prevention of fraud and other financial crime, including tax evasion and its facilitation, in all the countries in which the supplier and any of its affiliates or associates conducts business, directly or indirectly;
Not give or receive from any director, employee or representative of Extra MSA Group any gift, entertainment or other favour of material value, or any commission, fee, or rebate, with the intent or effect of inducing anyone to forego their duties and provide unfair business advantage to Extra MSA Group, the supplier, or others;
Never engage in any illegal anti-competitive conduct or deceptive trade practices;
Comply with all applicable data protection, privacy and information security laws and regulations, including those pertaining to Extra MSA Group;
Protect the confidential, proprietary, and personal information it processes by implementing appropriate technical and organisational measures to ensure a level of security appropriate to risk and continued compliance with applicable data protection and privacy regulations. The supplier must only engage subcontractors and other business partners who ensure the same level of technical and organisational security. The supplier must, without undue delay, notify Extra MSA Group if it reasonably suspects a data breach of any information processed on behalf of Extra MSA Group occurred, making available all information reasonably requested to assist in the investigation and remediation of such breach and ensure compliance with all obligations under the applicable law;
Avoid conflicts of interest or situations giving the appearance of a conflict of interest, promptly notifying Extra MSA Group of any instances of actual or apparent conflict between the supplier’s interest and that of Extra MSA Group;
Recognise that adverse effects of its activities on the community, environment and natural resources must be minimised. To this end, the supplier must comply with all applicable environmental laws including, without limitation, those which relate to (i) obtaining and maintaining required environmental permits, approvals and registrations, as well as complying with applicable operational and reporting requirements; (ii) the handling, removal, transportation and disposal of hazardous materials used by the supplier; and (iii) monitoring, controlling, treating and sanitising air emissions, waste water and solid wastes;
Seek opportunities that promote the efficient sourcing of materials, use of resources and energy, as well as clean energy and low emissions solutions;
Comply with the United Nations Universal Declaration of Human Rights, respecting the human rights & modern slavery legislation, without limitation, temporary, migrant, student, contract, direct and any other type of employee, in all its operations. The supplier must not engage in or condone child labour and commits to combat the unlawful exploitation and employment of children, therefore prohibiting any use of child labour by vendors, subcontractors, and other business partners, working with law enforcement authorities to address any such instances the supplier becomes aware of;
Respect the free choice of all persons and strictly prohibit forced or compulsory labour and commit to not do business with, tolerate or associate with organisations and entities that condone or are engaged in the practice of coercing or imposing work with little or no freedom of choice, working with law enforcement authorities to address any such instances the supplier becomes aware of;
Commit to the highest standards of equality, diversity, and inclusion, ensuring an equitable, diverse, and inclusive workplace, free of harassment and discrimination;
Commit to safe and secure working conditions, providing a safe and secure workplace to all its employees;
Comply with all health, safety, and security laws of the jurisdictions in which it does business and limit worker exposure to potential safety hazards through proper design, engineering and administrative controls, preventative maintenance, and safe work procedures. If necessary to perform a job, the supplier will provide workers at no cost the proper personal protective equipment and ensure its proper maintenance;
Record, track, and report all occupational injuries and illnesses as required by the applicable laws, encouraging worker reporting, classifying, and recording cases of injury and work-related illness, providing necessary medical treatment, and investigating and implementing corrective actions to eliminate their causes;
Commit to be an ethical employer, respecting its employees’ contributions and rewarding them fairly, while striving to improve labour standards;
Ensure employees are free to raise concerns without fear of retaliation in any form, providing whistleblower protection;
Comply with all laws concerning employees’ freedom of association and collective bargaining; and
Cooperate with Extra MSA Group in the assessment of the supplier’s compliance with this Supplier Code of Conduct, promptly correcting any instances of non-conformance identified during such assessments and agreeing to participate in Extra MSA Group -selected third-party monitoring services as Extra MSA Group may direct at the own expense of the supplier.

Implementation & Review:

The Group Operations Director is responsible for the company’s’ Supplier Code of Conduct Policy. The Board & Senior Management Team will review the policy on an annual basis with respect to its relevance and effectiveness and will make improvements, as necessary. Our Supplier Code of Conduct Policy is accessible to our employees via the companies Intranet & interested parties on the public facing website https://extraservices.co.uk/ or upon request.

CEO Approval

I have reviewed and approved the Supplier Code of Conduct Policy as presented by the Group Operations Director.

Employee Code of Conduct Policy

Issue 1

Effective Date: 19/12/2024

Extra MSA Group & subsidiary operating companies (referred to as “The Group”).

Business Profile

The 8 full MSA’s operated by Extra MSA Group contain retail shops, food & drink outlets, hotels, meeting rooms for hire, fuel filling stations, parking for all types of vehicles, overnight parking, electric vehicle charging and indoor & outdoor seating areas. Some locations include walking areas, lakes, and small wooded areas.

The Group business structure includes a Senior Management Team, Finance Team & work closely with a carefully selected set of third-party professionals and consultants.

Operationally, Extra MSA Group are responsible for managing & maintaining all the indoor and outdoor communal areas. The brands, hotels & fuel filling stations are separately operated by the respective tenants with their own employees.

Operational employee personnel include Cleaners, Security, Grounds Persons, Maintenance, Supervisors & Site Managers supported by a small, Area Management Team & Administration Office.

Introduction

Extra MSA Group has a Board of Directors, comprising of representatives of the shareholders, management, 4 Non-Executive Directors and an Independent Chairperson.

Governance

This Code of Conduct applies to the Board of Directors and all employees of the Group and will be updated periodically by management to reflect regulatory, industry, market, and other developments, at a minimum annual frequency.

The Group shall conduct its business in accordance with the applicable laws and regulations and abide to the highest ethical standards. In case of conflict between the law and the provisions of this Code of Conduct, the law shall prevail.

Policy Commitments

The Board of Directors shall endeavour to:

The responsible stewardship of the Company, providing strategic guidance to the management team in the achievement of the Company’s goals;
Oversee the integration of ESG (Environment, Social, Governance) considerations into all aspects the Company’s business, including climate-related matters;
Comply with the law and abide to the highest ethical standards, acting with probity and prudency in the exercise of their function, collectively and individually protecting the reputation of the Company;
Treat each other and employees with dignity and respect, promoting a culture of equity and inclusivity and a work environment that is free from discrimination, threats, bullying and harassment;
Work to the highest personal and professional standards, acting solely in the interest of the company and its long-term success, taking competent decisions based on the best evidence, without discrimination or bias;
Conduct themselves with integrity, professionalism, and good judgement;
Make use of the Company’s name and resources only in the interest of the Company;
Not accept gifts and hospitality which might reasonably appear to compromise their personal judgement or integrity. Not give gifts, hospitality and political contributions or engage in lobbying activities which might reasonably appear to compromise a counterparty’s judgement or integrity;
Not engage in fraud, bribery, and corruption, ensuring alignment of the company’s policies and practices with regulations and best practices, including, inter alia, the UN Global Compact;

Engage with stakeholders with understanding, respect, and insights;
Respect the obligation of confidentiality in respect of information received in the course of their duties, abiding to this obligation after the end of their mandate;
Avoid any situation which might give rise to a conflict of interest. Where conflicts of interest arise, the Board of Directors and each of its members commit to transparently disclose them and collaborate in their efficient resolution;
Actively promote and support the principles of this Code of Conduct in others, challenging poor behaviour where it occurs; and
Report illegal activities, unethical behaviours and/or violations of the Code of Conduct to the Chairperson. No retaliation against the whistleblower will be tolerated.

All employees shall endeavour to:

The responsible operation of the Company, executing the plan of the management team and Board of Directors;
Implement integration of ESG considerations into all aspects of the Company’s business, including climate-related matters;
Comply with the law and abide to the highest ethical standards, acting with probity and prudency in the exercise of their function, collectively and individually protecting the reputation of the Company;
Treat each other and all company stake holders with dignity and respect, promoting a culture of equity and inclusivity and a work environment that is free from discrimination, threats, bullying and harassment;
Work to the highest personal and professional standards, acting solely in the interest of the company and its long-term success, taking competent decisions based on the best evidence, without discrimination or bias;
Conduct themselves with integrity, professionalism, and good judgement;
Make use of the Company’s name and resources only in the interest of the Company;
Not accept gifts and hospitality which might reasonably appear to compromise their personal judgement or integrity. Not give gifts, hospitality and political contributions or engage in lobbying activities which might reasonably appear to compromise a counterparty’s judgement or integrity;
Not engage in fraud, bribery, and corruption, ensuring alignment of the company’s policies and practices with regulations and best practices, including, inter alia, the UN Global Compact;
Engage with stakeholders with understanding, respect, and insights;
Respect the obligation of confidentiality in respect of information received in the course of their duties, abiding to this obligation after the end of their mandate;
Avoid any situation which might give rise to a conflict of interest. Where conflicts of interest arise, commit to transparently disclose them and collaborate in their efficient resolution;
Actively promote and support the principles of this Code of Conduct in others, challenging poor behaviour where it occurs; and
Report illegal activities, unethical behaviours and/or violations of the Code of Conduct to the Chairperson. No retaliation against the whistleblower will be tolerated.

Implementation & Review:

The Group Operations Director is responsible for the company’s’ Employee Code of Conduct Policy. The Board & Senior Management Team will review the policy on an annual basis with respect to its relevance and effectiveness and will make improvements, as necessary. Our Supplier Code of Conduct Policy is accessible to our employees via the companies Intranet & interested parties on the public facing website https://extraservices.co.uk/ or upon request.

CEO Approval

I have reviewed and approved the Supplier Code of Conduct Policy as presented by the Group Operations Director.

Extra MSA Energy Policy

Issue 1

Effective date 19/12/2024

Extra MSA (Motorway Service Areas) Group & subsidiary operating companies. Extra MSA Property UK Ltd, Extra MSA Baldock Ltd, Extra MSA Beaconsfield Ltd, Extra MSA

Blackburn Ltd, Extra MSA Cambridge Ltd, Extra MSA Cobham Ltd, Extra MSA Cullompton Ltd, Extra MSA Leeds Ltd, Extra MSA Peterborough Ltd

Business Profile

Extra MSA, also known as “The Group,” operates 10 Motorway Service Areas (MSA) across England. Two of the Locations (Tibshelf and Winchester) are fuel filling stations only, operated & insured by Shell & BP. Extra operates the business 24/7, 365 days per year as obliged by operating covenants from National Highways to serve the safety of the strategic motorway road network (SRN)

Corporately, Extra includes a Senior Management Team, Finance Team & will work closely with a carefully selected set of third-party professionals and consultants.

Operational employee personnel include Cleaners, Security, Grounds Persons, Maintenance, Supervisors & Site Managers supported by a small Area Management Team & Administration Office.

Introduction

This Energy management system and Energy Policy has been compiled to set out Extra MSA Groups’ intentions and goals with respect to energy use and management. Its purpose is to help embed efficiency and environmental awareness into everyday business, reducing environmental footprint and costs whilst working towards a science-based target of Net Zero.

Policy

As part of our environmental, social and governance (ESG) strategy, Extra MSA is committed to responsible energy management and will practise energy efficiency throughout the groups operating companies, including plant and major equipment.

Extra MSA Group will implement and operate an energy management system to reduce energy wastage, improve working conditions, minimise environmental damage and raise awareness of sustainable energy issues.

Extra MSA Group will reduce its environmental impact caused by energy consumption and achieve Net Zero carbon by 2050 at the latest. We will do this by reducing energy wastage, reducing dependence on fossil fuels, investing in energy efficient equipment and renewable energy generation.

Extra MSA Group will reduce peak power demand to aid in the expansion of the electric vehicle charge point roll-out to ensure national net zero emission vehicle targets are met.

Extra MSA Group will control energy consumption to avoid wasted expenses through passive controls and reactive on-site management.

Extra MSA Group will adopt technology to allow the granular monitoring of energy data and to assist personnel with alert notifications.

Extra MSA Group will take a forward-thinking approach to the investment of innovative technology to reduce reliance on fossil fuels

Extra MSA Group will invest in renewable energy generating solutions and energy storage technology to improve energy independence

Extra MSA Group will collaborate with its stakeholders, including tenant brand partners, suppliers, and local communities, to promote and achieve energy efficiency goals. By engaging with stakeholders, we aim to foster a culture of sustainability and shared responsibility, ensuring that everyone involved understands and supports our commitment to reducing energy consumption and achieving Net Zero carbon emissions.

Energy Management System Action Plan

Extra MSA Groups’ Energy Team will carry out the action plan and ensure resources are made available. During the coming year, the following energy management activities will be undertaken:

Record Energy Performance Certificate (EPC) ratings and form an improvement plan to upgrade EPC ratings to a minimum C rating by April 2027 and minimum B rating by April 2030, in line with mandatory legislation.
Identify energy efficiency improvements to the plant, building fabric and equipment.
Ensure air conditioning systems are maintained by an accredited assessor with documents stored on SharePoint.
Report changes in building use or occupancy times to ensure heating, ventilation, cooling, and other services are provided efficiently.
Review historic and current energy use to identify trends. Address under performance and non-conformities and take corrective action.
Monitor, measure, benchmark, and review energy performance against targets on an annual basis.
Identify sources of significant energy use via smart sub-metering (EMaaS / Energy Radar).
Check the smart sub-metering equipment located on key circuits and labelled to easily identify in the EMaaS System.
Identify current and future energy risks on each MSA and remedial actions to de-risk future power expansion.
Procure electricity that is derived from renewable sources and bundled with energy attribute certificates. Renewable Energy Guarantees of Origin should be collated from suppliers on an annual basis.
Ensure employees have appropriate training tailored to their needs.
Where reasonable contractors and tenants should be trained and aware of operational procedures.
Arrange regular meetings with energy champions to raise awareness of the importance of saving energy, train individuals and incorporate into normal employee onboarding.
Where required, utilise external specialist consultants to undertake energy audits, track individual actions and embed the Energy Management System.
Review energy related internal and communication announcements
Review the Energy Action Plan on a bi-weekly basis and close out actions in a timely manner.
Undertake management review of this Energy Policy and Energy Management System.

Roles and Responsibilities

The Energy Team is comprised of:

Role	Responsibility
ESG Manager	Overseeing the reporting of energy data, the energy action plan and providing adequate training to Extra MSA employees.
Site Managers	Identifying and actioning energy wastage across their respective MSA. Liaising with occupiers and contractors on-site to meet energy goals.
Area Managers	Ensuring equipment is operating effectively and supporting the investment proposals.
Energy Champions	Assist in identifying energy wastage
Management Team	Approving and supporting energy-related investment decisions

Extra MSA will utilise expert knowledge from external consultants to aid in this Energy Policy.

Other Groups:

The Group Operations Director is the senior decision maker for the energy strategy. The Group Operations Director will raise energy issues with the management team and at the quarterly board meetings as appropriate.

The ESG Manager will take energy discussions to the ESG subcommittee.

Implementation & Review:

The Group Operations Director is responsible for the company’s Energy Policy. The Board & Senior Management Team will review the policy on an annual basis with respect to its relevance and effectiveness and will make improvements, as necessary. Our Energy Policy is accessible to our employees via the companies

Intranet & interested parties on the public facing website https://extraservices.co.uk/ or upon request.

CEO Approval

I have reviewed and approved the Energy Policy as presented by the Group Operations Director.

Our Policies

Acting responsibly

CCTV Policy Statement

Definitions

About this policy

Personnel responsible

Reasons for the use of CCTV and other surveillance systems

Monitoring

How we will operate any CCTV and surveillance systems

Use of data gathered by CCTV and other surveillance systems

Retention and erasure of data gathered by CCTV and other surveillance systems

Use of additional surveillance systems

Ongoing review of CCTV and other surveillance system use

Human Rights Act 1998

Requests for disclosure

Subject access requests

Complaints

Requests to prevent processing

Modern Slavery Policy

Business Profile

Introduction

Scope

Principles

Policy

Waste Management Policy

Business Profile

Introduction

Policy

Waste Hierarchy

Targets

Plastic Waste Reduction

Site Waste Management

Monitoring and Reporting Performance

Hazardous Waste

1.1 Definition

1.2 Policy Statement

1.4 Responsibilities

Accepted Materials and Recycling

Waste Disposal

Environmental, Social and Governance (“ESG”) Policy

Introduction

Governance

Materiality Statement

ESG Policy

Human Rights Policy

Business Profile

Introduction

Scope

Principles

Policy

Stakeholder Engagement Policy

Business Profile

Introduction

Governance

Policy

Stakeholder Engagement Program

Supplier Code of Conduct Policy

Business Profile

Introduction

Governance

Policy

Employee Code of Conduct Policy

Business Profile

Introduction

Governance

Policy Commitments

Extra MSA Energy Policy

Business Profile

Introduction

Policy

Energy Management System Action Plan

Roles and Responsibilities

Locations

Info & Policies

Other Policies