Kele's QHSE Policy

This policy document defines how Kele manages Quality, Health, Safety & Environment (QHSE) in order to ensure legal compliance and international practice standards. As a responsible organization Kele has a Quality, Health, Safety & Environment Policy which is supported by detailed requirements for Quality, Health, Safety & Environment Management (QHSE Management) arrangements.

In summary, the project managers and site managers have accountability for the quality, health, safety & environment implementation and performance of their project. Specific duties and responsibilities may be decentralize to project managers and supervisors in order that the policy and standards are effectively communicated, implemented and monitored.

Kele enables the provision of suitable and sufficient resources, training and supervision as part of business planning and management, to ensure that all managers, supervisors and employees are properly able to discharge their responsibilities under this policy.

Kele is primarily a construction management and contracting company conducting business in the Middle Eastern Construction Industry. QHSE performance is one of our greatest strengths and one we value highly. Kele regards the health & safety of employees, the environment and the communities we operate in, as a core business element and a strategic imperative. The principles that
govern our Quality, Safety, Health & Environmental Policy are integral to the business and our dedication to QHSE is embedded in these seven principles;

• Identify, assess and manage risks to employees, contractors, the environment and the communities we operate in.
• Set and achieve targets that promote efficient use of resources and include reducing and preventing pollution.
• Promote sustainable development of all our employees and contractors through training, awareness and transparent
  business practices.
• Allocate appropriate resources to meet or, where less stringent than our standards, exceed applicable legal and other requirements.
• Understand, promote and uphold fundamental human rights within our sphere of influence, respecting tradition, cultural heritage and religion.
• Encourage a diverse workforce and provide a work environment in which everyone is treated fairly and with respect.
• Sustain continuous QHSE improvement strategies.

To achieve this, we will:

• Implement and maintain a riskbased Quality, Health, Safety & Environment management system.
• Promote integrity by holding our project management teams accountable for effective leadership and management of QHSE.
• Integrate Quality, Health, Safety & Environment resource and training provision into our business plans.
• Engage regularly, openly and honestly with people affected by our operations, and take their views and concerns into account in our decision-making.
• Regularly review our performance and the performance of our stakeholders.
  
  In implementing this policy, we will engage with and support our employees, contractors, suppliers, customers, business partners and host communities in sharing responsibility for meeting our requirements.

General Organisation and Management

The Kele QHSE Policy requires a systematic approach to Quality, Health, Safety & Environment Management (QHSE Management). Responsibility for conformance and compliance to company standards and legal requirements is decentralized and delegated to projects. Quality, Health, Safety & Environment management systems shall be based on BS EN ISO 9001:2008, BS OHSAS 18001:2007,
BS EN ISO 14001:2004, international standards, guidance and practices to meet local requirements and legislation.

General Responsibilities

Each Project Head and Department Head has the responsibility and accountability for the Quality, Health, Safety & Environment practices and performance of their respective areas of responsibility in accordance with the requirements of this policy document.

The Project Heads and Department Heads are also responsible for making certain that appropriate documented and certifiable Quality, Health, Safety & Environment management systems and arrangements are in place to meet the local risk profile, local legislation and Kele procedures and standards.

Managers and supervisors are to promote, encourage and monitor the Quality, Health, Safety & Environment of their teams and employees. Managers and supervisors shall make certain that their teams and employees have adequate knowledge and training of the Quality, Health, Safety & Environment requirements relevant to their activities.

All employees are obliged to set a personal example and take reasonable care for the health, safety and welfare of themselves and others who may be affected by their acts or omissions at work. All employees shall have knowledge of the Quality, Health, Safety
& Environment requirements relevant to their activities

The Company Quality, Health, Safety & Environment Department is responsible for establishing Company Strategy & Policy, providing specialist advice, disseminating best practice, monitoring and reporting on performance.

Consultation

Employees will be consulted on changes to work procedures and arrangements that affect the health, safety and welfare of the employees. Information will be given in good time to allow comments and feedback to be considered and necessary changes
made.

Quality, Health, Safety & Environment Responsibilities

The following Quality, Health, Safety & Environment responsibilities are the main duties of management and employees and are in addition to the duties outlined under general responsibilities.

Management Committee

The Management Committee shall:

• Periodically review, direct, endorse and support the Quality, Health, Safety & Environment Strategy and Policy and performance improvement programme.
• Lead by example and personally undertake periodic Quality, Health, Safety & Environment Reviews.
• Plan and budget for the provision of adequate Quality, Health, Safety & Environment resources
• Monitor and review the effectiveness of Quality, Health, Safety & Environment management and performance.
• Appoint members of the QHSE Committee

Project Heads

Project Heads shall:

• Periodically review the adequacy of the Project’s Quality, Health, Safety & Environment management arrangements in order to ensure that they deliver practices and performance that are in conformance with Company Policies and Standards and in compliance with local legislation.
• Ensure that adequate resources are provided and competent Quality, Health, Safety & Environment staff with the necessary expertise are available to fulfil their responsibilities under the Kele Quality, Health, Safety & Environment Policy.
• Direct the implementation of corrective actions when performance fails to meet regulatory or company standards.
• Be accountable for the effective leadership and management of QHSE.

Managers

Managers shall:

• Organize business activities to enable, so far as reasonably practicable, a working environment that is safe and without risk to health.
• Coordinate, implement and monitor the provision and maintenance of a safe working environment and systems of work, so far as is reasonably practicable including monitoring the adequacy of Quality, Health, Safety & Environment training and instruction to address the local Quality, Health, Safety & Environment risks and impacts.
• Integrate and consider Quality, Health, Safety & Environment issues as part of core business operations so that Quality, Health, Safety & Environment is addressed and managed throughout the project life cycle.
• Select and manage the performance of supply partners (project management teams, contractors, vendors and suppliers) so that the supply partners consider Quality, Health, Safety & Environment issues, deliver their services and products in accordance with
  KELE’s Quality, Health, Safety & Environment Policy.
• Satisfy themselves that employees and other persons under their control are competent and properly supervised.
• Ensure that adequate protective clothing and safety equipment is available and that it is correctly used.
• Take corrective action when Quality, Health, Safety & Environment standards are not maintained.
• Be accountable for the effective implementation and management of QHSE.

Employees

Employees shall:

• Make themselves familiar with the KELE Quality, Health, Safety & Environment Policy document and comply with its requirements.
• Encourage and monitor supply partners Quality, Health, Safety & Environment performance in relation to the delivery of their services, operations and activities.
• Use all tools and equipment provided for their work correctly and use the appropriate protective clothing and safety equipment as supplied.
• Not interfere with or misuse anything provided in the interests of quality, health, safety and welfare.
• Cooperate with their management and supervisors or any other person so far as is necessary to enable them to comply with any Quality, Health, Safety & Environment responsibility and/ or requirement imposed on them.
• Timely report unsafe acts and unsafe conditions to management and Quality, Health, Safety & Environment appointed
  representatives.
• Report, record and cooperate in the investigation of all accidents or near miss incidents that have led or may have led to injury or
  damage.
• Notify and consult with relevant Quality, Health, Safety & Environment staff if taking any form of prescribed drugs or medication to the extent that the health, safety or welfare of the employee or any other person is put at risk.
• Be accountable for the effective implementation and compliance of QHSE.

QHSE Managers and Nominated QHSE Persons

QHSE Managers and Nominated QHSE Persons shall:

• Provide QHSE guidance and leadership to management and team leaders.
• Develop, implement and maintain Quality, Health, Safety & Environment arrangements and management Systems.
• Establish and maintain a Quality, Health, Safety & Environment audit and/or inspection programme based on the risk
  profile of site activities and supply partners.
• Monitor that legal registers, certificates and other related statutory documents are properly maintained by the responsible person.
• Regularly monitor and report on Quality, Health, Safety & Environment performance to management so that corrective actions can be effectively implemented.
• Investigate and report to management on Quality, Health, Safety & Environment incidents and facilitate implementation of corrective actions.
• Maintain close liaison with local regulators.
• Generate an awareness of safety at the workplace by promoting the safe conduct of work generally.
• Be accountable for the effective leadership and management of QHSE.

Company Quality, Health, Safety & Environment Department

The Company Quality, Health, Safety & Environment Department shall:

• Establish and maintain the Company Quality, Health, Safety & Environment Strategy, Policy and Standards guided by international standards and trends.
• Regularly report on Quality, Health, Safety & Environment performance and progress to the CEO and Management Committee, QHSE Committee and Project Heads.
• Make recommendations to the CEO, Management Committee and appropriate Project Heads, and Departmental Managers on matters relating to health, safety and welfare and provide guidance and advice for continuous improvement.
• Implement a company riskbased Quality, Health, Safety & Environment management audit program.
• Review Head Office/ Project Quality, Health, Safety & Environment arrangements and procedures to assess adequacy and compliance with the appropriate legislation, guidance documents and company practices prior to implementation.
• Regularly prepare and distribute Quality, Health, Safety & Environment information in response to circumstances and to proactively engender an awareness of safety as an integral part of good management.
• Establish, manage and deliver Quality, Health, Safety & Environment training to meet Kele’s and our supply chain and partners’ needs.
• Coordinate Quality, Health, Safety & Environment events and forums for Quality, Health, Safety & Environment Managers, and third party Quality, Health, Safety & Environment Consultants

Kele Quality, Health, Safety & Environment Committee

The Kele Quality, Health, Safety & Environment Committee shall:

• Meet periodically and at least quarterly to review Quality, Health, Safety & Environment performance and progress.
• Undertake an annual management, performance and strategy review and, where necessary, proposing revisions to the CEO and Management Committee.
• Review and endorse changes in policy and standards in response to new regulations, standards, and codes of practice, identified
  technologies, products and/or new work practices.
• Review and endorse the Quality, Health, Safety & Environment performance improvement programme.
• Review Quality, Health, Safety & Environment incident reports (both reportable and nonreportable) and where necessary, providing solutions to prevent repetition.

The preceding Health, Safety & Environment Policy covers the majority of the Kele project activities.

However, it may be necessary for Directors and Managers of workplaces to redefine certain occupational duties contained in “Main Responsibilities” to suit either their particular requirement or any new operation being undertaken, in coordination and consultation with the Kele Quality, Health, Safety & Environment Department.