Sublime Timing Ltd

Sustainability Policy

Registered location: Wisbech, Cambridgeshire, United Kingdom

Policy owner: Martin Jennings, Managing Director

Effective date: October 2026

Next scheduled review: October 2027

1. Policy Statement and Scope

Sublime Timing Ltd ("Sublime Timing", "the Company", "we") provides professional race and event timing services, including chip timing, live results, participant registration support and associated event technology, to event organisers across the United Kingdom.

We recognise that our activities, products and services have an impact on the environment, on the people we work with and on the communities in which events take place. We are committed to conducting our business in a responsible and sustainable manner, to minimising our negative environmental and social impacts, and to making a positive contribution wherever we can.

This policy sets out our approach to environmental, social and ethical responsibility. It follows the structure of recognised environmental management principles, including those set out in ISO 14001, as a framework for good practice. The Company does not currently hold ISO 14001 or any other sustainability certification, and this policy makes no claim to that effect.

Scope. This policy applies to:

• all Company operations, including office and administrative activity, equipment storage and maintenance, and on site event delivery;

• all directors, employees, contractors, temporary staff and volunteers acting on behalf of the Company;

• the services we provide to clients and the events at which we operate; and

• our relationships with suppliers, partners and service providers, to the extent that we can reasonably influence them.

2. Commitment, Leadership and Governance

Sustainability is integral to how we plan, deliver and improve our services. Overall responsibility for this policy rests with the Managing Director, Martin Jennings, who is accountable for:

• ensuring that this policy is implemented, communicated and adequately resourced;

• setting the Company's sustainability priorities and objectives;

• ensuring that sustainability considerations are built into business planning, procurement and operational decisions;

• monitoring performance and ensuring that corrective action is taken where required; and

• reviewing this policy at least annually, and sooner if there is a significant change to the business, its operations or the relevant legislation.

All staff, contractors and representatives of the Company are expected to understand this policy, to follow it in their day to day work and to raise any concerns or suggestions for improvement with the Managing Director.

3. Legal Compliance

As a minimum, we will comply with all applicable environmental, health and safety, employment and other legislation and regulatory requirements relevant to our activities, together with any other requirements to which the Company subscribes, including client and event organiser requirements. Relevant legislation includes, but is not limited to:

• the Environmental Protection Act 1990, including the waste duty of care;

• the Waste (England and Wales) Regulations 2011 and the waste hierarchy;

• the Waste Electrical and Electronic Equipment (WEEE) Regulations 2013;

• the Waste Batteries and Accumulators Regulations 2009;

• applicable packaging waste regulations;

• the Health and Safety at Work etc. Act 1974 and associated regulations;

• the Equality Act 2010;

• the Bribery Act 2010;

• the Modern Slavery Act 2015;

• the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations; and

• road traffic and vehicle legislation relevant to the transport of people and equipment.

We will keep up to date with changes in legislation and best practice, and we will seek to go beyond minimum legal requirements where it is practicable to do so.

4. Environmental Management

We will identify the significant environmental aspects of our operations and take practical steps to manage and reduce them. Our principal environmental impacts arise from energy use, travel and transport to events, the use of electronic equipment and consumables, and waste.

4.1 Energy

• Use energy efficiently in our offices, storage facilities and at events.

• Switch off lighting, computers, chargers and equipment when not in use.

• Choose energy efficient equipment, lighting and appliances when replacing or purchasing items.

• Use rechargeable battery systems for event equipment and manage charging cycles to avoid unnecessary energy consumption and to extend battery life.

• Consider renewable or lower carbon energy tariffs when reviewing energy contracts.

4.2 Emissions

• Seek to understand and reduce the greenhouse gas emissions associated with our operations, with particular focus on travel and transport, which we recognise as our most significant source of emissions.

• Avoid the use of fuel powered generators at events wherever venue power or battery solutions provide a suitable alternative.

• Favour lower emission vehicles when vehicles are replaced or hired, where operationally suitable.

4.3 Travel and Transport

Delivering timing services requires the movement of staff and equipment to event venues across the country. We will manage this responsibly by:

• Shared vehicle travel: arranging for event teams to travel together in shared vehicles wherever possible, rather than in multiple separate vehicles.

• Route planning: planning journeys in advance to select efficient routes, avoid unnecessary mileage and, where possible, combine visits to multiple events or locations within a single trip.

• Fuel efficient driving: encouraging and expecting fuel efficient driving practices, including smooth acceleration and braking, adherence to speed limits, avoiding unnecessary idling and keeping vehicles correctly maintained, with tyres at the correct pressure.

• Consolidated equipment transport: consolidating timing equipment, infrastructure and consumables into the minimum number of vehicle loads, and packing equipment efficiently to reduce the number of journeys required.

• Remote working and virtual meetings: using video calls and online collaboration for client meetings, planning and pre event briefings where a site visit is not essential.

• Overnight stays: where events are far from base or span consecutive days, considering local accommodation in preference to repeated long return journeys, where this reduces overall travel.

5. Procurement and Supply Chain

We recognise that the goods and services we buy have environmental and social impacts beyond our own operations. We will:

• give preference, where quality, value and suitability are comparable, to UK based and local suppliers, reducing transport distances and supporting the regional economy;

• consider durability, repairability, energy efficiency, packaging and end of life options as part of purchasing decisions, not only initial cost;

• source from reputable suppliers and manufacturers that demonstrate responsible environmental, labour and ethical practices;

• avoid suppliers known to be involved in unethical practices, including forced labour, child labour or bribery;

• purchase recycled, recyclable or responsibly sourced materials and consumables where available and suitable; and

• communicate our expectations to suppliers and work collaboratively with them to improve standards.

Supplier expectations. We expect our suppliers and subcontractors to:

• comply with all applicable environmental, employment, health and safety and anti bribery legislation;

• treat their workers fairly, pay at least the legal minimum wage and respect workers' rights;

• take reasonable steps to minimise their own environmental impact, including in packaging and delivery;

• uphold the principles of this policy when working on our behalf; and

• inform us promptly of any issue that may affect their ability to meet these expectations.

6. Resource Use, Waste and the Circular Economy

We apply the waste hierarchy of prevent, reduce, reuse, recycle and recover, with disposal as the last resort.

6.1 Reusable Professional Equipment

• Our core timing systems, including timing decoders, antennas and timing mats, are professional grade equipment designed for repeated use over many years and many events.

• Our Starlink satellite internet units and associated connectivity equipment are reusable assets deployed across events, providing reliable live connectivity without the need for additional on site infrastructure.

• Equipment is cleaned, inspected, maintained and repaired after use to maximise its service life, and is stored correctly to prevent damage.

• Event infrastructure such as gantries, signage, cabling and cases is reused from event to event wherever possible.

6.2 Consumables: Timing Chips and Race Numbers

• Timing chips and race numbers (bibs) are ordered in line with confirmed participant numbers, with only a sensible operational contingency, to avoid over ordering and waste.

• We work with organisers to agree entry deadlines and final numbers in good time so that orders can be accurately placed.

• Where reusable timing chip systems are appropriate to an event, we will discuss these with the organiser.

• Surplus unprinted stock is retained for future use wherever possible rather than discarded.

6.3 Recycling and General Waste

• Provide recycling facilities for paper, card, plastics, metals and other materials at our premises.

• Ensure that all waste is handled, stored and disposed of in accordance with the waste duty of care, using licensed waste carriers and appropriate facilities.

• Minimise the use of single use items in our operations and at events.

6.4 Packaging

• Reduce packaging on goods we dispatch and request minimal or recyclable packaging from our suppliers.

• Reuse packaging and transit cases where possible, and recycle packaging that cannot be reused.

6.5 End of Life Electronics (WEEE) and Batteries

• Electronic equipment is repaired or refurbished where economically and technically viable.

• Equipment that is still serviceable but no longer required will be offered for reuse, resale or donation where appropriate.

• Electrical and electronic equipment that has reached the end of its life is disposed of through authorised WEEE recycling routes in accordance with the WEEE Regulations.

• Batteries are collected separately and recycled through approved battery recycling schemes.

• Data bearing devices are securely wiped or destroyed before disposal.

7. Digital First Operations

Our services are designed around digital delivery, which reduces paper use and printing and improves the participant experience.

• Live online results: results are published live online during and after events, removing the need for printed results boards and printed results sheets as standard. Printed results will be provided only where specifically required by the organiser.

• Email notifications by default: participant communications, such as entry confirmations, race information, race numbers and results notifications, are delivered by email or other digital means by default.

• Paperless administration: quotations, contracts, invoices, purchase orders and records are created, sent and stored electronically. Printing is kept to a minimum and, where required, recycled paper is used and printed on both sides.

• Digital tools: we use cloud based systems for collaboration, file sharing and event planning, reducing the need for physical documents and travel.

• Data storage: we will be mindful of the energy associated with data storage, retaining data only for as long as necessary in line with our data protection obligations.

8. Events

We work at venues ranging from city centres to rural and environmentally sensitive locations, and we take our responsibility to those places seriously.

8.1 Working with Organisers

We will work in partnership with event organisers to help reduce the overall environmental impact of their events by:

• recommending digital alternatives to printed materials, including online results, digital race information and electronic communications;

• advising on accurate ordering of race numbers and timing chips based on confirmed entries;

• supporting organisers' own sustainability objectives and complying with their environmental requirements on site;

• encouraging participants, through digital communications where we are asked to support them, to consider car sharing and public transport to events; and

• sharing learning and good practice gathered from other events.

8.2 Leave No Trace

• Our teams will leave every venue as they found it, or better.

• All Company equipment, cabling, fixings, cable ties, tape and packaging will be removed at the end of each event.

• Waste generated by our operations will be taken away or disposed of using the facilities provided by the organiser, with recyclable materials separated.

• We will take care to avoid damage to grass, surfaces, paths, trees, wildlife habitats and other features of the venue, and will follow any site specific environmental instructions.

• Vehicles will be parked only in designated areas, and engines will not be left idling.

9. People, Health, Safety and Wellbeing

We are committed to providing a safe and healthy working environment for our staff, contractors, clients, participants and members of the public who may be affected by our activities. We will:

• comply with health and safety legislation and maintain appropriate risk assessments for our office, storage and event activities, including manual handling, working at height, working near roads and courses, electrical safety and lone working;

• provide appropriate training, information, supervision and personal protective equipment, including high visibility clothing at events;

• plan event schedules to avoid excessive working hours and manage driver fatigue, particularly for early starts and long journeys;

• support the physical and mental wellbeing of our people and encourage an open culture in which concerns can be raised without fear;

• invest in the training and development of our staff; and

• treat everyone with fairness, dignity and respect.

10. Equality, Diversity and Inclusion

We are committed to equality of opportunity and to creating an inclusive environment for our staff, clients, suppliers and event participants. We will:

• not discriminate on the grounds of any protected characteristic as defined by the Equality Act 2010, namely age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation;

• recruit, train, develop and reward people on the basis of ability, merit and potential;

• not tolerate harassment, bullying or victimisation of any kind;

• support inclusive events, including accurate and respectful recording of participant information and support for organisers in providing results categories that reflect their participants; and

• make reasonable adjustments wherever needed so that people can work with us and take part in events.

11. Community and Charity Support

Many of the events we support raise funds for charities and good causes and bring communities together through sport and physical activity. We aim to contribute positively to the communities in which we live and work by:

• supporting community, grassroots, school and charity events;

• encouraging participation in physical activity and the health benefits it brings;

• considering support, in kind or otherwise, for local and charitable causes;

• using local businesses and services where practicable, both near our base in Cambridgeshire and at event locations; and

• being a considerate neighbour at every venue and to the residents affected by events.

12. Ethics and Responsible Business Conduct

12.1 Anti Bribery and Corruption

We conduct our business honestly and with integrity. We operate a zero tolerance approach to bribery and corruption in any form, in line with the Bribery Act 2010. No employee, contractor or person acting on our behalf may offer, give, request or accept any bribe, inducement or improper payment. Gifts and hospitality must be reasonable, proportionate and transparent.

12.2 Modern Slavery and Human Rights

We are opposed to modern slavery, human trafficking, forced labour and child labour in all their forms, and we support the aims of the Modern Slavery Act 2015. We will take reasonable steps to ensure that these practices do not occur in our business or our supply chains, will select suppliers with care and will act promptly on any concern raised.

12.3 Data Protection and GDPR

We handle significant volumes of personal data on behalf of event organisers and participants, and we treat this responsibility with the utmost care. We will:

• process personal data lawfully, fairly and transparently, in accordance with the UK GDPR and the Data Protection Act 2018;

• collect only the data necessary for the purpose and retain it only for as long as required;

• protect personal data with appropriate technical and organisational security measures;

• respect the rights of individuals, including rights of access, correction and erasure;

• comply with the Privacy and Electronic Communications Regulations in our electronic communications; and

• ensure that any third parties processing data on our behalf provide equivalent protection.

12.4 Fair Dealing and Whistleblowing

We will deal fairly with clients, suppliers and competitors, pay suppliers on agreed terms and avoid conflicts of interest. Anyone working with us may raise concerns about wrongdoing in confidence with the Managing Director, and no one will suffer detriment for raising a concern in good faith.

13. Communication and Transparency

• This policy will be communicated to all staff and contractors and will form part of induction for new team members.

• The policy will be made available to clients, event organisers, suppliers and other stakeholders on request, and will be shared proactively with clients as part of tender, onboarding and event planning processes where appropriate.

• We will be honest and transparent about our environmental impacts and will openly disclose significant sustainability risks associated with our operations, in particular travel and transport emissions, the use of single use consumables such as race numbers and disposable timing chips, and the management of electronic equipment at end of life, together with the steps we are taking to manage them.

• We will not make misleading environmental claims about our services.

• We welcome feedback from clients, participants, suppliers and staff on our sustainability performance.

14. Continuous Improvement

We are committed to continually improving our environmental and social performance. We will:

• review our processes with clients after events, including what worked well and where impacts could be reduced at future events;

• seek and act on feedback from suppliers on opportunities to reduce packaging, transport and waste in our supply chain;

• identify, assess and adopt new technologies, equipment and working practices that reduce environmental impact while maintaining the quality and reliability of our services;

• set and review sustainability objectives as part of business planning; and

• encourage staff to put forward ideas for improvement.

15. Monitoring and Review

• The Managing Director will monitor the implementation and effectiveness of this policy, including compliance with legal requirements and progress against the commitments it contains.

• Relevant information, such as travel and mileage, energy use, consumables ordered and waste and recycling arrangements, will be monitored to inform decisions and identify opportunities for improvement.

• This policy will be reviewed at least annually, and sooner in the event of significant changes to the business, its activities, client requirements or legislation.

• The next scheduled review is October 2027.

Authorisation

This policy has been approved and is fully supported by the Managing Director on behalf of Sublime Timing Ltd.

Signed: ______________________________

Name: Martin Jennings

Position: Managing Director, Sublime Timing Ltd

Date: October 2026