1.0 Scope

This Health & Safety Policy applies to all activities undertaken by Halfords Group PLC and sets out the arrangements for managing health, safety, and welfare across all business operations. The policy applies to all colleagues inclusive of directors, managers, contractors, temporary or agency workers, visitors, and any other persons who may be affected by the Company’s activities.

The scope covers all workplaces under the Company's control, including offices, consumer garages, retail outlets, depots, distribution centres, workshops, customer premises, vehicles and any remote or home-working environments where work is undertaken on behalf of the Company. It encompasses all work-related activities, operations, equipment, machinery, processes and services provided by Halfords Group PLC.

The policy is designed to ensure compliance with all applicable health and safety legislation, industry standards, and customer requirements, while promoting a positive safety culture that supports our ultimate goal of zero accidents, zero incidents and zero occupational illnesses. It establishes the framework for defining responsibilities, assessing and controlling risk, consulting with colleagues, providing suitable information, instruction, training and supervision, and driving continuous improvement in health and safety performance.

All colleagues covered by this policy are required to comply with its requirements and actively contribute to maintaining a safe and healthy working environment. Where shortfalls or safety concerns regarding compliance are identified, these will be addressed through appropriate support, guidance, and management processes to help ensure standards are maintained. The policy will be regularly reviewed to ensure it remains relevant, effective, and aligned with legal and organisational requirements.

2.0 Purpose

At Halfords, we are committed to providing and maintaining a safe, healthy and supportive working environment for all colleagues, contractors, visitors and others who may be affected by our activities. We believe that everyone has the right to return home safe and well at the end of each working day, and we recognise our responsibility to protect the health, safety and wellbeing of all those who work with and on behalf of the Company.

Our health and safety vision is underpinned by a culture of care, respect, accountability and shared responsibility. We are committed to fostering a positive safety culture in which hazards are identified and controlled, risks are effectively managed, and health, safety and wellbeing considerations are integrated into all business activities and decision-making processes.

Our ambition is clear: zero major events. Achieving this objective requires more than compliance with legal requirements and Company procedures. It requires the active engagement and commitment of all colleagues to identify unsafe conditions, challenge unsafe behaviours, report concerns, learn from incidents and near misses, and take appropriate action to prevent harm.

3.0 Health & Safety Organisation

We recognise that effective health and safety management requires continued commitment and involvement at all levels of the organisation. The Executive Board provides strategic leadership and accountability for health and safety performance, ensuring adequate resources, governance,

and oversight are in place. Our Operational Boards monitor performance within their respective areas, ensuring risks are effectively managed and that health and safety objectives are achieved. The Senior Leadership Group is responsible for translating these strategic objectives into business priorities and driving a positive health and safety culture throughout the organisation. The Group Health & Safety Department provides specialist advice, guidance, assurance, and support to the business, helping to develop standards, monitor compliance, and promote continual improvement. Operational Management is responsible for implementing health and safety arrangements within their areas of control, ensuring that risks are assessed, controls are maintained, and colleagues are provided with appropriate information, instruction, training, and supervision. All our Colleagues have a responsibility to work safely, follow company procedures, report events and safety concerns, and actively contribute to maintaining a safe and healthy working environment for themselves and fellow workers.

3.1 Executive Board

Our Executive Board has ultimate accountability for the effective management of health, safety, and welfare throughout the organisation. The Board is responsible for setting the strategic direction for health and safety, ensuring it remains a core business value and is embedded within decision-making processes at all levels. This includes establishing health and safety objectives, approving policies and standards, and ensuring that sufficient resources, competence, and organisational arrangements are in place to manage risks effectively. The Executive Board regularly reviews safety performance, significant events, emerging risks, compliance obligations, and assurance activities to ensure that all appropriate controls are operating effectively. Through visible leadership and active engagement, our Executive Board promote a positive safety culture, demonstrate their commitment to continuous improvement, and ensure that health & safety considerations are integrated into business planning, operational activities, and organisational change.

3.2 Operational Boards

Our Operational Boards are responsible for providing leadership and oversight of health and safety performance within their respective business units, ensuring that Group health and safety objectives are effectively implemented and maintained. They are accountable for monitoring significant risks, reviewing performance indicators, investigating trends, and ensuring that appropriate control measures are in place to prevent harm and promote a safe working environment. Our Operational Boards ensure that health and safety considerations are integrated into operational planning, decision-making, projects, and organisational change activities. They regularly review audit findings, event investigations, compliance matters, and improvement plans, taking appropriate action to address identified issues and share good practice across the business. Through active engagement with Operational Management and the Group Health & Safety Department, Operational Boards support continuous improvement, allocate resources where necessary, and promote a positive health and safety culture that encourages accountability, collaboration, and proactive risk management throughout their areas of responsibility.

3.3 Senior Leadership Group

The Senior Leadership Group (SLG) is responsible for championing the organisation's health and safety strategy and ensuring that health and safety objectives are effectively translated into operational delivery. As leaders of their respective functions and business areas, they are accountable for promoting a positive safety culture, demonstrating visible leadership, and ensuring that health and safety considerations are integrated into day-to-day business activities, planning, and decision-making. The Senior Leadership Group is responsible for ensuring that significant risks are identified, assessed, and managed appropriately, and that adequate resources, competence, training, and support are provided to enable safe operations. They monitor health and safety performance, review events, audits, inspections, and compliance matters, and take timely action to address identified issues whilst driving continual improvement. Working collaboratively with Operational Boards, Operational Management, and the Group Health & Safety Department; the Senior Leadership Group ensures that organisational standards are consistently applied, legal obligations are met, and the health, safety, and wellbeing of colleagues and others affected by our Company's activities remain a key business priority.

3.4 Group Health & Safety Department

Our Group Health & Safety Department is responsible for providing best-in-class leadership, advice, guidance, and assurance to support the effective management of health and safety across the organisation. The department develops and maintains the Company's health and safety policies, procedures, standards, and management systems, ensuring alignment with legal requirements, industry best practice, and organisational objectives. It provides specialist support to the Executive Board, Senior Leadership Group, Operational Boards, and Operational Management in identifying, assessing, and controlling risks, while promoting a consistent approach to health and safety governance and compliance. The department monitors organisational performance through audits, inspections, investigations, and performance reporting, identifying trends and opportunities for improvement. It also supports the development of health and safety competence through training, communication, and engagement initiatives, while working collaboratively with colleagues at all levels to foster a positive safety culture and drive continual improvement in health, safety, and wellbeing performance across the business.

3.5 Operational Management

Our Operational Management teams are responsible for the day-to-day implementation and management of health and safety arrangements within their areas of control. They are accountable for ensuring that work activities are planned, organised, and carried out safely, with suitable risk assessments and control measures in place to protect colleagues, contractors, customers, and others who may be affected by the Company's operations. Operational Managers ensure that all colleagues receive appropriate information, instruction, training, supervision, and resources to carry out their duties safely and in compliance with our company requirements. They are responsible for promoting safe behaviours, monitoring performance, addressing unsafe conditions or practices, and ensuring that events, hazards, near misses, and safety concerns are reported, investigated, and acted upon appropriately. Through regular engagement with Colleagues, Operational Boards, and the Group Health & Safety Department; Operational Management plays a key role in fostering a positive safety culture, driving continual improvement, and ensuring that health and safety remains an integral part of operational decision-making and performance.

3.6 Colleagues

All colleagues are recognised in having an important role to play in maintaining a safe and healthy workplace. They are expected to take reasonable care of their own health and safety, as well as that of their fellow colleagues and others who may be affected by their actions or omissions. Colleagues are responsible for following company policies, procedures, safe systems of work, and any instructions provided to them, while making proper use of equipment, tools, and personal protective equipment where required. They are encouraged to actively identify and report hazards, unsafe conditions, near misses, accidents & incidents, and general safety concerns, contributing to the continuous improvement of workplace safety. All colleagues participate in relevant training, are openly invited to consultations, committees, and safety initiatives, cooperate with management and the Group Health & Safety Department in supporting the development of a positive safety culture. We recognise that when our colleagues work collaboratively and responsibly, this ensures that health and safety remains a shared priority and an integral part of everyday business activities.

4.0 Health & Safety Working Practices

At Halfords we recognise that organisational change, new business activities, projects, equipment, processes, technologies, and ways of working can introduce new or increased health and safety risks if not properly planned and controlled. To ensure the health, safety, and wellbeing of colleagues, contractors, customers, and others who may be affected by our operations, all significant changes to established working practices, as well as the introduction of new processes, activities, products, services, or projects, will be subject to a structured assessment and approval process prior to implementation.

Any significant changes introduced within our operations are firstly assessed based on potential impacts towards health and safety, and ensuring that appropriate risk management arrangements are established (commonly known within Halfords as Operational Impact Assessments -OIA). Suitable controls, procedures, resources, training, and supervision shall be implemented to eliminate and/or mitigate hazards wherever reasonably practicable, and reduce any residual risks to an acceptable level. The level of assessment and control applied will be proportionate to the nature, scale, and complexity of the proposed change.

4.1 Risk Assessment

Risk Assessment is a fundamental component of the Halfords' health and safety management system and forms the basis for identifying hazards, evaluating risks, and implementing effective control measures to prevent harm, ill health, and loss. We are committed in ensuring that:

• all work activities, workplaces, processes, and equipment are subject to suitable and sufficient risk assessment, enabling risks to be eliminated wherever reasonably practicable, or reduced to the lowest achievable level.

• risk assessments shall be reviewed regularly based on an individual risk profile. Any operational task or activity rated as High shall be reviewed at least annually, with Medium or Low risk assessments reviewed at a period not exceeding three years. Additionally, risk assessments shall also be reviewed following any significant change to working practices, equipment, processes, legislation, working environment, or following a significant event (accident or incident).

• where risk assessments identify deficiencies, hazards, or opportunities for improvement, the responsible manager must ensure that corrective and preventative actions are implemented within appropriate timescales, and that adequate resources are allocated to address the findings.

• all risk assessments will not be considered complete until all reasonably practicable control measures have been implemented, any outstanding actions have been appropriately managed, and the assessment has been formally reviewed and authorised by the manager responsible for the task/area concerned.

• completed risk assessments are communicated to affected colleagues, contractors, and other relevant parties to ensure that identified hazards, control measures, and responsibilities are fully understood.

• all risk assessments shall be readily accessible to colleagues undertaking the work, including external partners, and contractors. Additionally, customers and regulatory authorities where required shall also be granted access following approval from the Group Health & Safety Department.

• to provide assurance that risks are being effectively managed, all risk assessments are subject to monitoring, review, and audit. Any assessment found to be inadequate, out of date, or not meeting the standard of being suitable and sufficient will be deemed incomplete and must be revised without delay.

• the Group Health & Safety Department shall provide guidance, support, and challenge where necessary to ensure compliance with company standards and legal requirements.

• all managers and colleagues involved in the risk assessment process receive appropriate information, instruction, training, and support to enable them to effectively identify hazards, assess risks, and implement proportionate control measures, thereby supporting the Company's commitment to continual improvement in health and safety performance.

4.2 Safe Systems of Work

Safe Systems of Work (SSOW) are a critical element of our health and safety management framework, and are designed to ensure that tasks are carried out consistently, safely, and in a controlled manner. Where a risk assessment identifies that a work activity requires specific controls, procedures, or methods of operation to manage risks effectively, a documented Safe System of Work must be developed and implemented before the activity commences.

The Group Health & Safety Department in conjunction with Operational Management are responsible for ensuring that suitable and sufficient Safe Systems of Work are prepared, approved, and maintained for all activities where there is a foreseeable risk of harm, ill health, damage, or operational disruption. No task requiring a Safe System of Work shall be undertaken until the documented procedure has been communicated, understood, and embedded within the relevant work activity.

To ensure consistency and effectiveness, all Safe Systems of Work must:

• Follow a logical and sequential step-by-step process.

• Be written in clear, concise, and easily understandable language.

• Include diagrams, photographs, illustrations, or other visual aids where these will enhance individual understanding.

• Clearly identify hazards, risk controls, required personal protective equipment, and key safety precautions.

• Highlight critical control measures and safety responsibilities.

• Include contingency arrangements and guidance on actions to be taken in the event of equipment failure, abnormal conditions, emergencies, or other foreseeable events.

• Be reviewed whenever there are changes to equipment, processes, legislation, personnel, risk assessments, or following a significant event or safety concern.

Operational Management are responsible for ensuring that all colleagues, contractors, and other relevant persons affected by a Safe System of Work receive appropriate information, instruction, training, and supervision. Managers must verify competence and understanding before individuals undertake the activity and maintain suitable records of communication and training in accordance with Company procedures.

Safe Systems of Work must be readily available to those undertaking the task and stored in both electronic and, where appropriate, hard copy formats within the relevant operational area. For higher-risk activities, or where failure to follow the documented procedure could result in significant injury or harm, the Safe System of Work must be prominently displayed at the point of work and incorporated into routine operational controls.

Compliance with Safe Systems of Work is a fundamental expectation of all colleagues, and forms an integral part of the Halfords Health and Safety Management System. Adherence to these arrangements helps ensure that risks are effectively controlled, legal obligations are met, and a safe working environment is maintained. Where deviations from established Safe Systems of Work are identified, these will be investigated and managed through appropriate leadership, coaching, corrective action, and performance management processes to ensure the continued protection of people and the consistent application of Company standards.

5.0 Health & Safety Training

Halfords recognises that competent, well-trained colleagues are essential to maintaining a safe, healthy, and productive working environment. The Company is committed to ensuring that all colleagues are provided with the appropriate health and safety information, instruction, training, and supervision necessary to enable them to undertake their duties safely and effectively, and to fulfil their responsibilities under health and safety legislation and Company standards.

Operational Management are accountable for identifying the health and safety training requirements of colleagues within their areas of responsibility, and for ensuring that all mandatory, role-specific, and task-related training is completed before work activities are undertaken. This includes induction training, refresher training, specialist operational training, and any additional development required following changes to legislation, processes, equipment, working practices, or identified risks.

The Group Health & Safety Department will provide professional guidance and support to assist managers in determining competence requirements, developing training programmes, and ensuring training content remains aligned with legal obligations, industry best practice, and Company expectations. Managers shall seek advice whenever specialist support is required to assess training needs or deliver effective learning solutions.

Training records must be accurately maintained and readily available to demonstrate compliance, monitor competence, and support workforce development. Managers must regularly review training completion and competency levels to ensure colleagues remain suitably qualified and capable of carrying out their duties safely.

Where events (accidents & incidents), safety concerns, audits, visible safety leadership observations, investigations, or performance reviews identify deficiencies in competence, knowledge, understanding, or procedural compliance, appropriate corrective action shall be taken immediately. This may include coaching, reassessment, additional supervision, targeted development, or formal refresher training. Where an event has occurred as a result of a failure to follow established procedures, instructions, or Safe Systems of Work, the individual(s) concerned must successfully complete the necessary retraining and demonstrate understanding and competence before resuming the relevant activity. All such interventions shall be formally recorded and may be subject to further performance monitoring and review.

Health and safety training programmes shall be subject to regular monitoring to ensure they remain effective, proportionate, and aligned with organisational needs and risk profiles. The Group Health & Safety Department will review training performance, compliance levels, emerging training needs, and programme effectiveness, ensuring that adequate resources and investment are maintained to support continual improvement in both workforce competence and health and safety performance.

Through the provision of effective training, and the development of competence at all levels of the organisation, Halfords aims to ensure that every colleague has the knowledge, skills, and confidence required to work safely, make informed decisions, and contribute positively to a strong and sustainable safety culture.

6.0 Health & Safety Monitoring & Supervision

Halfords is committed to maintaining the highest standards of health and safety, and recognises that this requires robust monitoring, measurement, and regular reviews of performance. Our organisation believes that continuous improvement can only be achieved through the proactive evaluation of policies, procedures, behaviours, and operational controls to ensure they remain effective, relevant, and aligned with legal requirements and business objectives.

Both monitoring and performance reviews are essential components of the Halfords Health and Safety Management System and provide assurance that risks are being effectively managed, controls are operating as intended, and opportunities for improvement are identified and acted upon in a timely manner. Through a combination of workplace inspections, audits, visible leadership observations, investigations, performance reporting, and colleague engagement, we assess both compliance and the overall effectiveness of our health and safety arrangements.

The Company will maintain processes for monitoring, investigation, reporting, and performance analysis to identify trends, share learning, drive accountability, and support continual improvement across all areas of the Group.

The Group Health & Safety Department will undertake a programme of planned and unannounced audits, inspections, and assurance activities across the business. These assessments will evaluate compliance with legal requirements, policies & standards, management systems, and operational procedures, whilst identifying areas of good practice and opportunities for improvement. Findings and recommendations shall be reported to the appropriate levels of management to ensure timely corrective action, along with continuous enhancement of health and safety performance.

Operational Management are responsible for maintaining safe working environments through regular and systematic workplace inspections, visible safety leadership observations, and health and safety checks. These monitoring activities shall be conducted at defined frequencies, including daily, weekly, monthly, and annual reviews where applicable, and must be completed in accordance with Company standards, risk profiles, and operational requirements. Managers are responsible for ensuring that identified hazards, defects, unsafe conditions, and non-conformances are promptly addressed and that corrective actions are effectively implemented and monitored to completion.

Halfords expects all colleagues to contribute to the monitoring process by remaining vigilant to unsafe conditions, behaviours, and practices by reporting hazards, safety concerns and events without fear of blame or reprisal. The Company is committed to fostering an open and positive reporting culture where colleagues are actively encouraged to raise concerns and participate in the continuous improvement of workplace safety.

Where unsafe acts, unsafe conditions, or breaches of Company standards are identified, Operational Management are responsible for taking immediate and proportionate action to eliminate or control the risk. This may include the implementation of additional controls, provision of coaching or retraining, review of existing procedures, increased supervision, or the application of performance management processes where appropriate. Particular attention will be given to repeated, deliberate, or serious failures to comply with health and safety requirements, especially where such actions have the potential to place individuals or others at risk of harm.

Health and Safety performance data, audit findings, incident trends, compliance metrics, and key performance indicators such as our PATHS (Positive Attitude Towards Health & Safety) metric shall be regularly reviewed through the Company's governance structure. All Operational Boards shall review health and safety performance every month to ensure any emerging risks are identified, lessons are learned, resources remain appropriate, and continual improvement objectives are being achieved.

7.0 Health & Safety Reporting

All accidents, incidents, safety concerns, visible safety leadership observations, audits and inspections shall be analysed to identify trends, emerging risks, recurring causes, and opportunities for improvement. Health and Safety performance shall be reviewed through the Company's health and safety governance structure (3.0 Health & Safety Organisation) every month to provide assurance that corrective actions are effective and organisational risks are being managed appropriately.

The Group Health & Safety Department must be informed of all significant accidents, incidents, safety concerns, and investigation outcomes and will provide guidance, oversight, support, and challenge where appropriate. The department may undertake or participate in investigations involving serious incidents, high-potential near misses, recurring trends, or matters of significant organisational risk to ensure that lessons are identified and shared across the business.

All events meeting the requirements of the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR), or any subsequent legislative requirements, must be reported immediately to the Group Health & Safety Department to ensure statutory reporting obligations are fulfilled within the required timescales. Relevant findings and recommendations arising from such incidents will be communicated through the Company's governance processes to support organisational learning and risk reduction.

Operational Management are responsible for ensuring that all reported events are appropriately recorded, assessed, and investigated in a manner proportionate to the actual or potential severity of the incident. Investigations must seek to identify immediate, underlying, and root causes, including any deficiencies in risk management arrangements, procedures, training, supervision, equipment, communication, or organisational controls. Operational Management must ensure that investigations are completed within appropriate timescales, and that all findings are documented accurately and comprehensively.

8.0 Review

The Health and Safety Policy shall be maintained and formally reviewed by the Director of Health & Safety at least annually, and more frequently where significant changes in legislation, organisational structure, business activities, risk profile, industry best practice, or incident trends necessitate revision. The review process will ensure that the policy remains effective, relevant, and aligned with the Company's strategic objectives, legal obligations, and commitment to continual improvement in health and safety performance. Any amendments arising from the review shall be communicated throughout the organisation to ensure ongoing understanding, compliance, and consistent application of the Company's health and safety standards. The Executive Board shall be provided with appropriate assurance that the policy continues to support the effective management of health, safety, and wellbeing across all areas of the business prior to approval.