Response _tothe Coroner's Repor Following the inquest relating into the death of Samuel Clarke, which occurred on the construction site at Bank Street; Canary Wharf three issues were raised by the Coroner and set out in the 'Prevention of Future Deaths report' received on June 2018. The purpose of this document is to provide an overview of the security arrangements employed across Canary Wharf's construction projects to explain measures taken to prevent unauthorised entry and to respond specifically to the three concerns raised by the Coroner in the report Overview of Securty_Arrangements Canary Wharf Contractors (CWCL) place considerable importance on health, welfare, safety and the security of its sites: Requirements for all projects follow and in most cases exceed the standards set out in the relevant construction legislation and associated HSE guidance. In relation to security, our projects employ qualified and industry accredited security companies to manage its sites. The implementation of site security procedures is overseen by CWCL project managers. Procedures are tailored to the respective projects but in all cases significant security measures are employed in order to deter, identify and locate intruders with the aim of ensuring their safety and the protection of the site Measures include the following:
1. The site perimeter is secured by a plywood hoarding, 2.4 metres in height in line with industry requirements. The hoardings are also fitted with system of wires which when broken, offer a visual indication to patrolling security staff that the fence may have been scaled:
2. CCTV is in operation across the Canary Wharf Estate, around the perimeter of the site boundary and within certain areas of the project: The CCTV, pertinent to each site, is monitored by a dedicated security guard located within the project and relayed back to an external control room: The guard works in conjunction with another security guard also based on the site:
3. Projects have security presence 24/7 Security guards carry out various functions including patrols of the site and welfareloffice areas, monitoring of the CCTV , managing visitors, notifying senior management of any incident as appropriate and initial Iialson with emergency services.
4. Within each site certain areas secured to deter and restrict intruders entering: For example, stair cores leading to the top of the building; crane bases to prevent intruders climbing to the top of the tower cranes and barriers surrounding excavations and trenches:
5. Various patrol validation points are located within the site boundary: During the regular patrols the security guards are required to swipe these points to demonstrate that have patrolled the associated areas: The patrols are monitored to ensure are completed properly- As project evolves additional patrol check points may be introduced, dependent on the size and complexity of the site layout:
6. Where there is a risk of fall from height, suitable scaffold handrailing or edge protection guarding is installed in accordance with requirements set out in Work at Height Regulations 2007 and relevant industry standards: 22nd_ from are they they

The projects have suitable and sufficient lighting to illuminate safe pedestrian access and egress and traffic routes. Additional task lighting is also used when works are in progress Canary Wharf Group has recently obtained a high court injunction (Canary Wharf Investments v Brewer [2018] EWHC 1760 (QB) (23 February 2018)) covering the Canary Wharf Estate. Breach of the court order may constitute contempt of court and result in fine or imprisonment: Notices are displayed around various locations on the estate, warning that the injunction applies to any person trespassing in breach of the orders. This measure seeks to deter and protect individuals who may seek to gain unauthorised access t0 sites: Following Samuel's death a review of the project was conducted by the HSE Inspector Sharon Boyd: The Inspectors review included the fall prevention measures, the site perimeter, access hardware, the general site layout and the security procedures. The Inspector was generally satisfied with the site arrangements and controls implemented. meeting was convened by the Inspector with the project security provider which was attended by Canary Wharf Groups Head of Security: The meeting discussed the procedures to ensure clarity relating to the protocols in the event of trespassers. Following this review meeting, amendments were made to the security procedures to ensure clear protocols across all projects in the event of trespassers: As part of the procedural review, Canary Wharf Group has engaged with the Metropolitan police for specific guidance, in the event of persons being identified as entering a project: The Metropolitan Police have informed Canary Wharf Group that their deployment to construction sites will be dependent on the individual circumstances and the dynamic risk assessments of the officers attending or, if it is more serious, the local Duty Inspector. entry

Response_to the Coroner s Concerns Please find below response to the matters of concern raised within the Coroner's Prevention of Future Deaths Report Concern 1 Turnstile height. During the inquest it was stated that the gap under the turnstile where Samuel accessed the site had been reduced by Scm (from 3Ocm to 25cm) following his death: This was an incorrect estimate as the gap had in fact been reduced by 1Ocm (from 3Ocm to 2Ocm) by the introduction of a robust plywood ramp spanning the entire base of the turnstiles So as to raise the ground level The photo below showing the reduction in gap was sent to the HSE (Inspector as a sufficient control measure to prevent similar unauthorised access. The inspector confirmed receipt and required no further action. The turnstiles are located within an area where CCTV is in operation. During normal working hours the entrance is used by the entire workforce to enter and exit the project; monitored by the construction security office which is situated adjacent to the turnstiles. Following concerns raised at the inquest_ a further review of the turnstile was undertaken. As a result at the end of each day shift, temporary solid panels are installed to the inside face of the turnstile pods aimed at preventing any unauthorised out of hours access to the site via this route. See photo 2 below: This issue does not affect any other existing projects but on future projects where access to site is via a turnstile direct from public realm, similar security measures will be adopted. CWCL undertook a review of the access control entry points and the site perimeters across all of its projects to identify any potential areas where intruders could access the projects: This has resulted in the gaps at the base of delivery also reduced. Photo 1 - Reduction in gap gates being

OLb Photo 2 - Photo taken from inside the site showing a turnstile without the demountable panel installed and a turnstile with the demountable panel in place. Concern 2 Company Contingency Plan Following Samuel's death, site instructions have been reviewed and amended to clarify the action to be taken in the event of trespass and to ensure personnel are not put at risk: The Company's security procedures, in terms of communication and escalation to the Emergency Services, have been amended accordingly: briefing has been held with all construction security guards to ensure the updated procedures are understood. These instructions outline clear roles and responsibilities for the communication and escalation processes for the Wharf Estate security provided by Canary Wharf Management Ltd (CWML) as well as for the security companies engaged by Canary Wharf Contractors Ltd (CWCL) to provide site security: The security procedures include instructions for a search and seek procedure for a trespasser by the site security provider. This may require the site team to escalate an incident to CWCL project management and the construction security control room_ The security companies can call upon roaming supervisor to assist with search and to seek further guidance if required. CWML security staff can assist CWCL site personnel in response to trespass activity to avert a risk to life or to prevent serious injury: In these circumstances the CWML security staff may enter the site at the invitation of a member of CWCL management or their nominated representative. This process is reliant on a nominated member of CWC staff Canary

responding to a call and attending site prior to the plan being implemented: safety briefing will be conducted detalling required Personal Protective Equipment; which will be provided by CWCL and site specific hazards: recommended control measure must be in place before any deployment of CWML security staff commences: They will be accompanied on site at all times by a member of CWCL site security or management: The final decision as t0 entry onto a CWCL construction site will rest with the CWML Security Duty Manager who must satisfy themselves that appropriate measures are in place to maximise the safety of security staff deployed. Security patrols must remain within the safe areas and (without additional protection measures) cannot venture beyond safety barriers Or into hazardous areas where risk to life could Occur in contravention to our duty of care: The following table outlines the specific actions to be taken by the construction security providers and the Canary Wharf Estate security in terms of communication and escalation: Table: Escalation Protocol for Site Trespass Event Actlon (nprlorlty orded Responslble Accountable Notes Trespa8s by unauthorleed contact7ho polico CWCL securlty CWVCL Site Thls appllee In ovory case 0f pereonle onto a CWCL vla tha 999 eyetem provlder Manager treepa8e onto a conetructlon elte constructlon &lte regardleee of whether the poreonle Call the Eetate Managing Dlrector are on slte or have loft: Control Centre on Security 020 74182606 Provider Site eecurity hae noL beon Call the Eetate CWCL 8ecurity Managing Dlrector breached but & pereonle le Control Centro on provlder Securlty suspected ol preparlng to do 020 7418 2606 Provlder If there Is @QY eu8plclon that an SO Or 'attempting to do 80. Intruder may have entered a elte Eetato Control ECC Control Head ot Security - undetected in the Interlm perlod (Incident detected by CWCL Contre to warn other Centre Manager CWML thon tho Egtate Control Centro wlll slte securlty) CWCL sltee be reeponelble (or contactlng the Pollce Eatate Control ECC Control Head of Securlty - Centre to deploy Centre Manager CWML CWML robources to Inveetlgate Slte gecurity hae not been Estate Control ECC Control Head of Securlty _ breached but a personls I8 Centre to deploy Centre Manager CWML It there Is any susplclon that an suspected of preparing t0 do rosource8 to Intruder may have entered a elte 80 Or 'attempting to do 80. Inveetlgate undetected in the Interlm perlod then the Egtate Control Contre wlli (Incldent detected by CWML If conflrmed ECC Control Head of Securlty - be reeponelble tor contectlng the securlty) attempupreparatlon Centre Manager CWML Pollce to breach site gecurlty to warn other CWCL eltes Any

Concern 3 Torches used by the security guards The torches used by the security guards during night time patrol were Maglite ? Cell torches: These torches are designed for harsh environments and used by the emergency services_ Although they are believed to be sufficiently adequate and appropriate for night time patrols, the security guards now use a more powerful INFRAY flashlight; which has a beam distance of 240 metres and 800 lumens_ Furthermore certain areas of the projects, such as walkways are constantly illuminated: Following the incident a lighting review was conducted to ensure all appropriate areas are Iit.