Operational, Safety, and Service Standards

At Commercial Diving & Maritime, we are committed to delivering high-quality, reliable, and safe solutions across all of our projects. These policies outline our approach to communication, payments, project delivery, and client relationships to ensure clarity and professionalism at every stage.

All invoices are due within 30 days of issue unless otherwise agreed in writing.

Work may be paused or withheld if payments are delayed beyond the agreed timeframe.

Any additional work or variations requested outside the original agreement will be agreed and billed separately.

• All project timelines are agreed upon before work begins and depend on the timely receipt of required approvals, information, and site access.

• Unexpected weather conditions, safety concerns, or access restrictions may impact delivery schedules.

• Any changes to timelines will be communicated promptly to ensure transparency.

• Any changes to agreed scopes, specifications, or schedules must be confirmed in writing.

• Additional costs arising from revisions or variations will be communicated before work proceeds.

• Should a project be cancelled after mobilisation or commencement, costs for work completed and any associated expenses will remain payable in full.

• Refunds are not available for completed work or mobilisation fees once incurred.

• All work is carried out in accordance with relevant Health and Safety Executive (HSE) regulations and industry standards.

• Our teams operate under strict safety procedures and risk assessments to protect both personnel and the environment.

• Clients are expected to provide safe access to work sites and disclose any known hazards in advance.

• All communication should be directed through 07770-598346

• Our standard working hours are Monday to Friday, 8:00am – 5:00pm. Enquiries received outside these hours will be addressed the next working day.

All client information, site details, and documentation are treated as strictly confidential and handled in accordance with UK GDPR guidelines. We do not share client information with third parties without explicit consent.

Overview & Introduction

Commercial Diving & Maritime Ltd (CDM) needs to collect and use certain information on individuals and clients. It can include businesses, employees, sub-contractors, contractors and suppliers.

This policy establishes our commitment to protecting personal data in compliance with the General Data Protection Regulations (GDPR) May 2018. This policy ensures that all information is collected, processed, stored, and handled responsibly, transparently, and securely. CDM Ltd will maintain high standards and safeguard the rights of individuals.

Scope & Why this Policy Exists

· This policy exists to protect the personal details of all employees, contractors, customers and third-party service providers

· The Data Protection Officer (DPO) is responsible for handling personal data within Commercial Diving and Maritime Ltd.

· We will ensure that we follow good practice, comply with data protection laws and are open to how we store and manage data.

· We will protect the rights of our customers, suppliers and staff.

· This includes how we protect ourselves from risks of data breach.

Data Protection Principles

We adhere to GDPR principles, ensuring that data is:

· Processed lawfully, fairly, and transparently.

· Collected for specific, legitimate purposes.

· Minimised to what is necessary.

· Accurate and kept up to date.

· Stored securely and only retained as required.

· Protected with appropriate security measures: strong passwords on PCs, automatic screensavers, encrypted removeable devices, firewalls, anti-virus software.

· Ensure quality management practices that enhance data security and operational efficiency

Responsibilities

· The Data Protection Officer (DPO) oversees compliance, risk management, and incident responses.

· The DPO will ensure only people who have access to data should be those who need it for their work.

· Vendors and third parties must adhere to this policy when handling our data.

Data Collection & Processing

Personal data is collected transparently, ensuring individuals know:

· Why their data is being used

· Their rights regarding access, correction, and deletion

· Our security measures to protect their information

· Processing aligns with legal bases such as consent, contractual necessity, or legitimate business interests.

Individual Rights

Under GDPR, individuals can:

· Access their data and request corrections or deletions

· Restrict processing in certain cases

· Object to automated decision-making

Security Measures

To protect data, we implement:

· Encryption and secure storage solutions: local storage solutions

· Regular audits to ensure ongoing compliance

· Access controls with authentication requirement: Strong passwords

Data Breach Response

In the event of a breach the following will take place:

· Immediate containment and investigation by the DPO.

· Affected individuals and regulatory bodies (e.g., ICO) will be notified if required.

· Preventative measures will be taken to improve security eg regular change of passwords on digital data storage

This policy has been reviewed and approved by the appropriate authority and is effective as of the date below. All employees, contractors, and relevant stakeholders are expected to comply with the provisions outlined herein. The policy will be reviewed periodically and may be updated to reflect changes in company operations, legislation, or best practices.

Policy Statement

At Commercial Diving & Maritime Ltd, we are committed to integrating sustainability into every aspect of our diving and associated operations. We recognise our responsibility to minimise environmental impacts, conserve resources, and support the local marine ecosystem. This policy sets out our objectives and actions to drive continuous improvement and align with ISO 9001 principles.

Scope

This policy applies to all company activities, including yard, diving and office operations, dive equipment maintenance, vessel operations, employee and contractor commuting, and procurement. It covers our Cornwall facilities as well as all on-site locations where we deliver diving services.

Principles and Objectives

· Comply with all relevant environmental legislation, permits, and industry codes of practice.

· Prevent pollution, reduce waste, and limit greenhouse gas emissions.

· Conserve energy and water through efficient use and investment in low-impact technologies.

· Source goods and services that demonstrate environmental performance and ethical practices.

· Foster a culture of environmental awareness, training, and engagement among staff and stakeholders.

· Monitor, measure, and report on sustainability performance, driving continual improvement.

Energy and Emissions Reduction

· Install LED lighting, motion sensors, and programmable controls across our yard and office to reduce electricity consumption.

· Optimise vessel routing and maintenance schedules to minimise fuel use and engine idling.

· Evaluate low-emission engines or alternative fuels for future boat upgrades.

· Encourage car-sharing, electric vehicle use, and journey planning for all staff commuting and site travel.

Waste Management and Recycling

· Implement a “reduce, reuse, recycle” hierarchy across our yard and office.

· Segregate waste streams (metal, plastics, paper, hazardous fluids) with clearly labelled bins.

· Partner with licensed waste carriers to ensure responsible disposal of oils, solvents, batteries, and electronic equipment.

· Repair or refurbish dive gear whenever safe and cost-effective, extending equipment life.

· Donate or responsibly recycle redundant office furniture and electronic devices.

Water and Marine Protection

· Use biodegradable lubricants and cleaning agents for equipment maintenance and vessel cleaning.

· Conduct dive operations under controlled guidelines to prevent disturbance to marine habitats and minimise sediment plumes.

· Install drip trays and spill-response kits in the yard to prevent soil and water contamination

Sustainable Procurement

· Establish supplier criteria that prioritise environmental certifications, ethical labour practices, and lifecycle impacts.

· Source reusable packaging and consolidated deliveries to reduce transport emissions.

· Review procurement to identify opportunities for more sustainable alternatives in consumables, safety supplies, and spare parts.

Training and Engagement

· Provide all employees and contractors with sustainability induction, highlighting policy objectives and individual responsibilities.

Continuous Improvement

We will regularly evaluate new technologies, practices, and partnerships to enhance our environmental performance. Feedback from staff, clients, and community partners will inform goal-setting and action plans, ensuring our sustainability policy evolves and remains impactful.

Roles and Responsibilities

· Top Management is accountable for policy implementation, resource allocation, and target-setting, oversees day-to-day environmental controls, vessel efficiency, and waste management.

· Health, Safety & Environment (HSE) Lead coordinates training, incident response, and community engagement.

· All Employees and Contractors are responsible for adhering to this policy, reporting issues, and proposing improvements.

By adopting and enforcing this sustainability policy, we demonstrate our dedication to environmental stewardship and align with our core values of integrity, accountability, and community support.

This policy has been reviewed and approved by the appropriate authority and is effective as of the date below. All employees, contractors, and relevant stakeholders are expected to comply with the provisions outlined herein. The policy will be reviewed periodically and may be updated to reflect changes in company operations, legislation, or best practices.

Purpose This policy outlines our commitment to ensuring that our supply chain upholds high standards of environmental stewardship, ethical conduct, and social responsibility. As a responsible UK based company, we recognise our role in promoting sustainable practices and influencing positive change through our procurement decisions.

Here we set out our expectations for suppliers to actively manage and uphold these standards, not only within their own operations but also across their supply chains.

Scope This policy applies to all suppliers, contractors, and service providers engaged by Commercial Diving & Maritime Ltd and extends to their subcontractors and upstream suppliers.

Our Commitment We are committed to working with suppliers who:

• Comply with all applicable laws and regulations, including the UK Modern Slavery Act 2015 and relevant environmental legislation.

• Uphold human rights and fair labour practices, including safe working conditions, fair wages, and the prohibition of forced or child labour.

• Demonstrate environmental responsibility, such as reducing carbon emissions, minimising waste, and using sustainable materials where possible.

• Operate ethically, with transparency, integrity, and accountability in all business dealings.

• Uphold ethical business conduct, including anti-bribery, anti-corruption and transparent reporting practices.

• Cascade these standards to their own suppliers and subcontractors, ensuring alignment with this policy.

Supplier Expectations We are committed to working with suppliers who:rs who:

• Implement policies and practices that align with the principles outlined in this policy.

• Monitor and improve their environmental and social performance.

• Notify us of any breaches or risks related to ethical, social, or environmental standards.

Due Diligence and Monitoring

We will:

• Conduct periodic reviews of our supply base to assess compliance with this policy.

• Prioritise suppliers who demonstrate a proactive approach to sustainability

• Work collaboratively with suppliers to address any areas of concern.

Continuous Improvement

We are committed to reviewing and updating this policy regularly to reflect evolving best practices and legal requirements.

This policy has been reviewed and approved by the appropriate authority and is effective as of the date below. All employees, contractors, and relevant stakeholders are expected to comply with the provisions outlined herein. The policy will be reviewed periodically and may be updated to reflect changes in company operations, legislation, or best practices.

Purpose

This policy outlines our commitment to fostering an inclusive workplace where everyone is treated fairly, free from discrimination, and able to contribute fully to the success of the company. It also provides clear direction for embedding inclusive practices across every aspect of our diving operations. These practices align with ISO 9001’s focus on stakeholder satisfaction and continual improvement, while ensuring compliance with the Equality Act 2010.

Objective

To cultivate a workforce that reflects the rich diversity of the communities we serve, ensuring that recruitment, promotion and development opportunities are open and accessible to people of all backgrounds, experiences and perspectives. We will embed inclusivity into every stage of our hiring and career-development processes, striving to remove unconscious bias and broaden our outreach to under-represented groups.

Furthermore, we will foster a workplace culture in which every individual feels respected, supported and empowered to contribute their best. We will maintain clear, confidential channels for raising concerns, provide timely and appropriate support for anyone experiencing discrimination or harassment and ensure that reasonable adjustments, whether in equipment, schedules or physical access, are routinely considered and implemented.

Scope

Covers all organisational functions, from project planning, site and diving operations to office administration, ensuring equal opportunity. Applies to all staff, contractors, trainees, applicants, visitors, and clients in every aspect of recruitment, employment, training, promotion, and day-to-day operations.

Policy Statement

We are open to, and celebrate, differences in:

· Age

· Disability

· Gender reassignment

· Marriage and civil partnership

· Pregnancy and maternity

· Race, nationality, or ethnic origin

· Religion or belief

· Sex

· Sexual orientation

We will not tolerate any form of unfair treatment, harassment, or victimisation.

Embedding Inclusive Practices

Recruitment and Selection

Inclusivity is embedded into our recruitment process through a values-led, person-centred approach. We are fully committed to fairness, transparency, and equal opportunity in line with the Equality Act 2010 and we focus on removing bias through mindful decision-making, clear criteria, and ethical conduct, ensuring that every candidate is treated with dignity and respect. We provide a level playing field for all candidates throughout the recruitment process and each applicant is assessed solely on their individual merits and suitability for the role.

Everyday Operations

We maintain awareness of different experiences and perspectives in daily interactions, from client engagement to on-site coordination, and aim to foster a sense of belonging across the team. By embedding inclusive practices into practical workflows, we reduce barriers and set a standard of fairness that reflects our professional values.

We recognise that inclusive practice begins with everyday actions, from planning dive teams to allocating resources. We are committed to fair treatment at every level, and our staff are empowered to make decisions that respect individual needs while upholding the collective goals of the team. This ensures inclusion is not an add-on, but an integral part of how we operate safely, efficiently, and ethically.

Training and Support

All new employees/sub-contractors will complete a one-off Equality and Diversity induction module within their first three months. We see training not just as a skills upgrade, but as a way to embed inclusive thinking into the fabric of our operations. From onboarding, to dive team briefings and Tool Box Talks, we include discussions on dignity, fairness, and inclusive decision-making. These informal but intentional opportunities help ensure that inclusion becomes second nature, integrated into how we think, operate, and support each other in often challenging environments.

Responsibilities

· Senior Management: lead by example, monitor adherence, allocate resources.

· Line Managers: apply policy in recruitment, performance reviews, and team management.

· All Employees: treat colleagues with respect, report concerns promptly.

Review

This policy will be reviewed in management meetings and adjusted as we learn from audits, feedback, and changing legislative requirements.

Commercial Diving and Maritime Ltd are committed to upholding fundamental human rights, preventing modern slavery or forced labour in our operations and supply chain, and ensuring compliance with the Human Rights Act 1998 and the Modern Slavery Act 2015. Furthermore, we strive to embed respect for human rights and eradicate all forms of modern slavery throughout our diving operations, back-office functions, and supply chain.

Scope Applies to all employees, contractors, agents and suppliers.

Our Committment

· We recognise every individual’s right to dignity, freedom of movement and fair treatment.

· We will not tolerate any form of forced, bonded or child labour in our business or among our suppliers.

· We shall not employ or procure services from anyone under duress, coerced or trafficked.

· We shall respect the rights to privacy, fair pay, reasonable working hours and safe conditions

Legal Compliance

We commit to the UK Modern Slavery Act 2015 by:

· Conducting risk-based due diligence on all new and existing suppliers.

· Including anti-slavery clauses in our purchase orders and contracts.

· Transparent and continuous improvement

· Governance & review

We adhere to the Human Rights Act 1998 by:

· Respecting privacy, non-discrimination (Equality Act 2010) and freedom from degrading treatment

· Providing grievance channels for any suspected rights violation.

· Providing targeted training and awareness.

Responsibilities

· Leadership ensures resources for training and audits.

· Procurement vet suppliers against our Modern Slavery risk matrix.

· Employees must report concerns via grievance channels

Review & Improvement

We will review this policy annually, audit high-risk suppliers and update this policy in line with legislative changes.

This policy has been reviewed and approved by the appropriate authority and is effective as of the date below. All employees, contractors, and relevant stakeholders are expected to comply with the provisions outlined herein. The policy will be reviewed periodically and may be updated to reflect changes in company operations, legislation, or best practices.

Commercial Diving & Maritime Ltd are committed to protecting the health, safety, and welfare of every person who works with or under our operations. We believe that a proactive safety culture not only safeguards our team but also drives performance, quality, and customer confidence.

We will comply with all relevant legislation, industry standards, and client requirements, continually striving to exceed baseline obligations. We are equally committed to the safety of any other persons, such as visitors, contractors and clients whose health and safety may be affected by our actions.

Our commitment is rooted in the Health and Safety at Work etc. Act 1974 and expanded by an array of additional regulations covering things such as dive safety, fire safety, PPE, manual handling, COSHH, working time regulations and display screen equipment. We strive not just for compliance but for a genuinely proactive safety culture in all our commercial diving activities.

The identification, assessment and control of health and safety and other risks, is a management responsibility and equal in importance to service and quality. Commercial Diving & Maritime Ltd believes that the involvement and co-operative effort of each individual within the organisation is essential to achieve continuous improvement of all aspects of Company performance.

The Health and Safety at Work etc. Act 1974 also places a legal requirement on every employee and sub-contractor to take reasonable care for the health and safety of him/herself and of others who may be affected by his/her conduct at work. Co-operation with the management in observing safety regulations and in the use of appropriate protective safety equipment is essential to ensure the successful implementation of this policy.

Leadership & Accountability

Senior management will:

· Provide visible leadership and adequate resources for health and safety initiatives.

· Define clear responsibilities for all levels of staff, ensuring every individual understands their role in maintaining a safe workplace.

· Review our Occupational Health & Safety performance at least bi-annually to set new targets, allocate resources, and address emerging risks.

Review & Improvement

· Regular performance monitoring, management reviews, internal audit and annual third-party audits ensure ongoing compliance and continuous improvement in line with HSE guidance and ISO 9001 requirements.

Risk Management

We will:

· Identify, assess, and control hazards through routine site inspections, risk assessments, and method statements.

· Implement a “stop-work authority” policy empowering anyone to halt operations if they believe an unsafe condition exists.

· Ensure all incidents, near-misses, and non-conformances are reported, investigated, and analysed to prevent recurrence.

Competency & Training

We recognise that trained; empowered people are our strongest defence against harm. To that end, we will:

· Provide comprehensive induction, specialised technical training, and refresher courses for all personnel.

· Verify qualifications, licenses, and medical fitness for roles that carry specific risks.

· Encourage open dialogue, toolbox talks, and safety briefings to share lessons learned and best practices.

Continuous Improvement

· We will measure and report performance transparently, using key performance indicators to drive improvement. Regular management reviews, internal audits, and third-party assessments will ensure the ongoing effectiveness of our system and foster a culture of shared responsibility.

Most accidents and occupational ill health are preventable, and this is our goal in both the long and short term. The detailed objectives, organisation and controls for achieving this are set out in our Company Operations Health and Safety Manual and our Dive Operations Health & Safety Manual.

This policy has been reviewed and approved by the appropriate authority and is effective as of the date below. All employees, contractors, and relevant stakeholders are expected to comply with the provisions outlined herein. The policy will be reviewed periodically and may be updated to reflect changes in company operations, legislation, or best practices.

Who We Are

We are a specialist diving company, established in 2009. We are based in Cornwall, UK, operating from a dedicated yard and office facility that also serves our Plymouth operation. Our core services include shipping, dockyard support, underwater civil engineering, inspection, maintenance, Harbour moorings and construction support. We maintain a fleet of 6 vessels for equipment transport, stores runs, and dive operations, supported by a team of qualified divers, supervisors, and administrative staff.

Scope of Our Operations

Our Quality Management System covers all activities from project enquiry and planning through execution, equipment maintenance, vessel operations, and post-project review. It applies to onshore office processes, yard asset management, marine logistics, dive planning and execution, health and safety compliance, and continual improvement initiatives in accordance with ISO 9001:2015 requirements.

In carrying out our activities we will comply with all legal requirements, codes of practice and all other requirements applicable to our activities.

Quality Objectives

In order to deliver our services to the highest possible standards, we will maintain an effective and efficient Quality Management System that meets the needs of the company in pursuit of its primary objectives, the purpose and context of the company, and is based upon the requirements of ISO 9001:2015. As such, the Directors of CDM are committed to the following:

• Strive to satisfy the requirements of all of our customers, stakeholders and interested parties whenever possible, meeting and exceeding their expectations.

• Acknowledge that the key to success in fulfilling this policy is a total commitment to continuous quality maintenance and improvement across the organisation. This commitment will be effected by working with clients to fulfil their needs and through implementing procedures and processes that are reliable, efficient and economical.

• Comply with all legal requirements, codes of practice and all other requirements applicable to our activities.

• Ensure all employees are aware of the Quality Policy and are committed to the effective implementation of the Quality Management System.

• Recruit employees who are customer-focused and provide all required resources and equipment and ensure that every employee is suitably trained. To encourage staff to develop their knowledge and skills so that they can deliver the best possible service at all times.

• Maintain a management system that will achieve these objectives and seek continual improvement in the effectiveness and performance of our management system based on “risk”.

• Carry out continual reviews to facilitate better planning and sharing of best practices which will enable regular updates of our quality system. This is intended to ensure CDM will consistently be able to deliver a service to the satisfaction of all our clients and of which we can be proud.

• Proactively seek feedback from our customers on how well our services meet their requirements and set objectives for continual improvement.

• Analyse the causes of any complaint or problem and take appropriate action to prevent recurrence

Key Performance Indicators

To drive consistent performance and customer satisfaction, we have established the following core measurable objectives:

· Achieve at least 95% client satisfaction rating on post-project surveys.

· Deliver 95% of contracted projects on schedule and within agreed budgets.

· Maintain no more than 2 non-conformities in external ISO 9001 audits.

· Ensure 100% diving and support equipment readiness through scheduled maintenance and pre-dive inspections.

· Provide 100% of relevant staff with up-to-date training and competency certifications.

Achieving Our Quality Objectives

We embed quality through a process-based approach. Senior leadership defines roles, allocates resources, and fosters a culture of risk-based thinking. Project plans include robust risk assessments, clear deliverables, and traceable documentation. We monitor key performance indicators, including schedule adherence, equipment reliability, and safety metrics by way of internal audits, corrective/preventive actions. Frontline feedback drives continuous improvement across all functions.

Commitment to Quality

Top management is fully committed to sustaining and enhancing our Quality Management System. By aligning our strategic objectives with ISO 9001 principles, we ensure that quality underpins every decision, from tender to handover. This commitment results in safer dive operations, greater client confidence, optimised resource use, and long-term business resilience.

This policy has been reviewed and approved by the appropriate authority and is effective as of the date below. All employees, contractors, and relevant stakeholders are expected to comply with the provisions outlined herein. The policy will be reviewed periodically and may be updated to reflect changes in company operations, legislation, or best practices.