HSE policies & standards.

Because we have a strong regard for environmental protection and safety, we conduct our activities in a manner that protects the physical environment, our employees, our customers and the general public. We comply with environmental, stewardship and safety laws and regulations, and we develop and implement programmes to ensure compliance.

We are both responsible and responsive in our efforts related to environmental protection and employee safety. Where we become aware of environmental and product-safety risks not covered by existing laws or regulations, we develop our own good-faith standards and practices based on comprehensive and relevant scientific data. We cooperate with the public, government, industry and employees in identifying environmental and safety goals and in developing effective control programmes. Each operating unit is expected to be guided by this policy in forming plans, setting objectives and conducting day-to-day activities.

To deliver every project in a professional and timely manner, we assemble a team of personnel who are knowledgeable and eager to perform their duties in a technically sound manner, while placing their own safety — and that of the project — as their highest priority. The team is a well-structured staff responsible for all facets of running the project.

• Safety Manager — responsible for all safety promulgation and the enforcement of our safety policy.
• Project Manager — oversight responsibility for all operational activities, including project management, engineering, procurement and operations.

We use the Permit-to-Work system, which is standard throughout our company and to which both company and sub-contract personnel must adhere. Certain work tasks are identified as carrying higher risk than others, so the Permit to Work is invoked to make workers fully aware of what types of high-risk work may be going on at any given time.

Prior to starting such a task, the senior person involved must complete the Permit to Work. When the permit is filled out, a meeting is held with all involved so that the specific safety gear and PPE can be assembled before the task begins.

We audit our overall operations within both our management and HSE systems, reviewing both our current operations and those proposed for the future. To achieve this, we have adopted the following hierarchy for risk control:

• Eliminate or reduce risks using prevention and mitigation measures.
• Combat risks at source through engineering controls and collective protective measures.
• Minimise risk through the design of suitable systems, and ensure all employees are properly trained.

Where both practical and possible, we strive to eliminate risks by means of physical engineering controls and safeguards that can be more reliably maintained than those which rely solely on people. Where risk cannot be completely eliminated by engineering, we use the procedural method to minimise it. Once procedures are developed they are archived and remain active until amendments are required. All workers are trained in the procedures and are made aware of amendments; through their working experience, workers are encouraged to identify any part of a procedure that should be amended and pass that suggestion to their immediate supervisor, who then advises the HSE Manager and engineers.

We, our client companies, external auditors and joint client/SCPL teams conduct planned audits on the work sites. Copies of the final reports are made available to us and to the client company, and — to facilitate prompt action on deficiencies — draft recommendations are given.