City of London Coroner’s Court Before HM Senior Coroner Ms Alison Hewitt Response to the Report to Prevent Future Deaths on behalf of LS One New Change Limited STATEMENT OF

I, , of Land Securities Properties Limited, will say as follows:
1. My name is , and I am Head of Workplace Operations and a Senior Leader within Landsec Securities Properties Limited. I am duly authorised to make this statement on behalf of LS One New Change Limited. One New Change (‘ONC’) is owned by LS One New Change Limited (‘Landsec’). The information contained within this statement has been collated through consultation with stakeholders and it is true to the best of my knowledge and belief.
2. I make this statement in response to the Report to Prevent Future Deaths dated 3 July 2023 made by HM Senior Coroner Ms Alison Hewitt. At the outset, I would like to offer my personal, sincere condolences to Ms Tirgari’s family and friends at this extremely difficult time. The safety of our visitors is our utmost priority and Landsec is committed to ensuring every visitor has a safe and enjoyable experience while visiting our sites.
3. Landsec is grateful for the opportunity to comment and contribute to the efforts that seek to prevent future tragedy. The purpose of this statement is to provide information on the arrangements in place at the time of Ms Tirgari’s death and changes made subsequently. We wish to assure the Learned Coroner that sufficient action has been taken to prevent persons being able to climb the perimeter wall and that there is no risk to any persons who visit ONC. Background
4. I have been employed by Landsec Securities Properties Limited for over 10 years and have approximately 22 years property management experience. I have extensive knowledge of Landsec’s assets and hold overall responsibility for the operational management of a commercial and mixed use property portfolio, in excess of 5 million square feet, including ONC.
5. As Head of Workplace Operations, I am responsible for the operational delivery of all property related services including security, engineering, cleaning and front of house. I am also responsible for the management of all directly employed operational management staff (of which there are 53 and our out-sourced service partner teams, of which there are 527). One New Change
6. On 25 December 2006, LS One New Change Limited took a 155 year leasehold interest from the City of London over the land where ONC is now built. Landsec was responsible for the development, construction and practical completion of ONC and remains the property manager of the Site.
7. ONC has approximately 310,000 square feet of offices over levels 2 to 6 and circa 210,000 square feet of retail over ground floor, lower ground floor and first floor. There is a restaurant and bar on level 6 currently leased to Madison Restaurant Limited.
8. The public roof terrace is private land, located on level 6, a photograph of which is exhibited at Appendix 1. Since the terrace opened in November 2010, Landsec estimate that approximately 25 million members of the public have visited. 1

9. A Section 106 Agreement is in place between the City of London and Landsec. A Section 106 Agreement is a legal agreement between a planning authority and developer, or undertakings offered unilaterally by a developer, that ensure certain extra works relating to the development are undertaken. Under the terms of the Section 106 Agreement dated 7 June 2006 between the City of London and Landsec, Landsec are ‘……to keep the Roof Terrace open to the public for access on foot as a viewing area for recreation and viewing purposes (to which access may be gained by members of the public free of charge) at all times from the Roof Terrace Area Opening Date….’ As per the plan, exhibited at Appendix 2, Annexure 7 to the Section 106 Agreement, the terrace is to remain open to members of the public from 6 am through to midnight every day of the week. Circumstances of Ms Tirgari’s death
10. I have had the opportunity to review the CCTV footage which captured the tragic events on 1 June 2023. It is my understanding the CCTV footage has been provided to the Learned Coroner.
11. Following a detailed review of the CCTV, the facts as we currently understand them are that:
• Ms Tirgari arrived at ONC at 14:12. She looked up from the ground floor on New Change Passage towards the public roof terrace

and entered it at 14:13, reaching level 6 at 14:14.
• Once on the public terrace, Ms Tirgari walked , located approximately 4.7 metres away from the perimeter wall. It appears from the CCTV that Ms Tirgari engaged in a conversation with another visitor for approximately 10 minutes.
• At 14:32, Ms Tirgari had something to drink and walked under the Tensabarriers (weighted posts incorporating retractable safety tape capable of being linked to other Tensabarrier stands, thereby acting as a continuous fence) and over to the perimeter wall.

Once over the wall, Ms Tirgari leaves the view of the camera.
12. At this very early stage in the proceedings, and in the absence of any findings of facts from the Coronial investigation, we have acted upon the data we hold. We will ensure that we share any additional evidence that comes to light during the course of our investigation. Safety measures in place at ONC on 1 June 2023
13. The Learned Coroner is directed to Appendix 3 which encloses a plan of the public roof terrace, the location of the security officers, photographs of the exclusion zone and photographs of the warning drop signs, all of which were in place at the time of Ms Tirgari’s death.
14. At the time of Ms Tirgari’s death, Landsec had the following measures in place:
• One walking patrol security officer on the public roof terrace during opening hours, (6am to midnight), as annotated by the red dot on the attached plan at Appendix 3.
• Two metre continuous exclusion zone along the southern boundary of the public roof terrace (from west to east) and parallel with the perimeter wall, as annotated by the green line on the attached plan at Appendix 3. This zone was delineated by Tensabarriers.
• Security officers changed over on the day of incident at the location of the green dot. 2

• ‘Warning Sudden Drop’ signs were, and remain located, at 3.7 metre to 7.4 metre intervals along the vertical edge of the perimeter wall. Please see the image at Appendix 3, which is an example. The Design and Height of the Perimeter Wall
15. During the design and construction of ONC, Landsec ensured that it complied wholly with the Building Regulations which were in place at the time. The Building Regulation Approved Document Part K: ‘Protection from Falling, Collison and Impact’ and section K2: ‘Protection from falling’ requires public accessible pedestrian guarding to be 1100mm high.
16. Landsec’s architects have reviewed the information it holds relating to the height of the perimeter wall. The architects have confirmed following a review of the archived information that:
• The perimeter raking guarding by the section of green roof is approximately a minimum 1100mm AFFL (Above Finished Floor Level) but varies according to changes in the terrace level for drainage;
• The perimeter raking guarding to the lower terrace is a minimum of 1100­ 1155mm AFFL but varies according to changes in the terrace level for drainage;
• The perimeter wall is a minimum of 1100mm by the scenic lift and a minimum of 1830mm at the base of the stairs to the lower section of Madison’s restaurant terrace;
• The perimeter wall is a minimum of 1100mm by the scenic lift then generally increases in height with variations in level as the public terrace steps down. The variations are due to the general geometry of the perimeter wall, which in some places has a gradient to the top surface, with other changes due to the geometry of the stepped terracing levels, plus further minor variations in floor finish levels to allow for drainage falls.
17. At the time of constructing ONC between 2007-2010, I have been informed that Public Health England’s ‘Preventing Suicides in Public Places, a practical resource’ (2015) and The City of London’s SPG document ‘Preventing Suicides in High Rise Buildings and Structures, Planning Advice Note’ (April 2022) was yet to be published. The two incidents identified to the Learned Coroner in 2023 were the first incidents of this kind at ONC. Current Safety Measures
18. Immediately after the incident on 1 June 2023, the following additional preventative measures were implemented in addition to those listed at paragraph 14 above:
• The public roof terrace was immediately closed until further notice.
• Two lines of Tensabarriers were installed across the width of the terrace entrance, as annotated by the two green lines on the drawing enclosed at Appendix 4.
• Two Landsec security officers were positioned between the Tensabarriers from 12:00/noon to 00:00/midnight each day.
• The two scenic lifts were re-programmed:
• The right hand side lift was re-programmed to grant access to the lower ground, ground and first floor. There was no access to level
6.
• The left hand side lift was reprogrammed to coincide with Madison’s opening hours (12:00/noon to 00:00/midnight). Access 3

was permitted to level 6 only from the ground floor where Madison’s staff and ONC security officers were located.
• One Landsec security officer was positioned outside the scenic lifts on the ground floor from 07:00 to 00:00/midnight to engage with public and advise why the terrace is closed.
• During the week commencing 5th June 2023, Madison moved their planters across to the top of the first step to the public roof terrace, thereby providing a further physical barrier to prevent the public accessing the roof terrace (as annotated by the blue line on the drawing attached at Appendix 4.)
• Two additional security officers were located at Madison.
19. In addition, Landsec has appointed a team to design and install a hoarding approximately
2.5 metres in height across the terrace in the current location of the Tensabarriers. Following advice from Landsec’s structural engineers and its fabrication team, this hoarding is due to be installed in early September 2023. It is to remain in situ until the permanent works (discussed below) are completed which is estimated between April and June 2024. Future Works
20. Since Ms Tirgari’s death Landsec has held planning meetings with the City of London’s planning team, including the Planning and Development Director, the Senior Planning Officer and the Senior Public Health Practitioner. A pre-planning application meeting with the City of London is being sought for September 2023 and, subject to the outcome of that meeting, a full planning application will be submitted in October 2023, with works estimated to be completed between April and June 2024.
21. At the time of writing, I can confirm that the proposed permanent works are currently at the design stage and no final decisions have yet been made. However, capital has been set aside to ensure sufficient funding of the future works. Landsec are currently exploring a number of options such as the installation of a frameless and transparent glazed, cantilevered screen (approximately 2000mm high) which will span the entire length of the public roof terrace. The screen will be set back from the existing perimeter wall by a minimum of 600mm to enable cleaning on both sides of the glazing.
22. To assist in the design, Landsec has appointed the following project team:
• : Project manager and contract administrator. will act in the capacity of contract procurement, management and administration of the construction contract.
• : Architect. will design the proposed works and has worked with Landsec for over 10 years. It has been engaged on projects at ONC for over 3 years.
• Planning consultant with expertise in advising property owners in the City of London. will submit the planning application on Landsec’s behalf to the City of London and will liaise with them.
• : Provision of advice regarding St Paul’s heights analysis and associated CGI imagery.
• Specialist structural engineer. have over 65 years’ structural engineering experience and will provide Landsec with structural advice regarding the works and their integration within the existing structure. It will be also be responsible for the façade, as Arup are specialists in the design and engineering of facades. 4

23. Landsec has undertaken an extensive consultation with a range of stakeholders to ensure that the measures that have been put in place, and the proposed measures which will be taken, are effective. Conclusion
24. We would like to again express our deepest condolences to Ms Tirgari’s family and thank the Learned Coroner for allowing Landsec the opportunity to respond and contribute to efforts being taken by all to prevent future tragedy.
25. Landsec is committed to ensuring the health, safety and well-being of every person who visits and works at ONC.
26. Landsec is a company that had a sensible and considered risk management system in place at the time of the incident. Since this incident, we are conducting a review of the safety of the roof terrace, learning lessons, and using resources to ensure that ONC is a safe and enjoyable place to visit.
27. If I, or the team, could assist you further, then please do not hesitate to contact me. Signed: Dated: 25/08/2023 5

City of London Coroner’s Court Before HM Senior Coroner Ms Alison Hewitt Response to the Report to Prevent Future Deaths on behalf of LS One New Change Limited APPENDIX 1

Photograph of the public roof terrace pre-incident

City of London Coroner’s Court Before HM Senior Coroner Ms Alison Hewitt Response to the Report to Prevent Future Deaths on behalf of LS One New Change Limited APPENDIX 2

Public roof terrace: Section 106 Annexure 7

City of London Coroner’s Court Before HM Senior Coroner Ms Alison Hewitt Response to the Report to Prevent Future Deaths on behalf of LS One New Change Limited APPENDIX 3

Public roof terrace: Location of security officers and Ms Tirgari on 1 June 2023

Image showing the two metre exclusion zone. 1 Please note, at the time of the incident the security officer was not situated in this exact position by the two metre exclusion zone. Please refer to the plan above for the location of the security officers at the time of the incident. 1

Example of several warning signs placed on the perimeter wall

City of London Coroner’s Court Before HM Senior Coroner Ms Alison Hewitt Response to the Report to Prevent Future Deaths on behalf of LS One New Change Limited APPENDIX 4

Current measures Post 1 June 2023 Public roof terrace post 1 June 2023: Looking towards Madison: line of planters across first step to the terrace, two lines of tensabarriers and two security officers in attendance between midday and midnight in addition to Madison security officers within their demise

Public roof terrace post 1 June 2023: Looking from Madison - line of planters across first step to the terrace, two lines of tensabarriers and two security officers in attendance from midday to midnight in addition to Madison security officers within their demise.