Morpol Engineering Services Limited

COMMUNITY AFFAIRS, SAFETY, HEALTH, ENVIRONMENT AND SECURITY

POLICY STATEMENT

Company Policy Statement

The following CASHES Policy Statement is issued in accordance with the

requirements of relevant sections on statutory laws and regulations issued
through the Health, Environmental and Safety Commissions and authorities.

Policy of the Employer

It is the policy of the Company to do everything that is reasonably

practicable to prevent personal injury and to maintain a healthy and safe
working environment for its employees and any persons not employed by the
company that may be affected by its undertaking through the effective
management of all Health and Safety matters.

It is in particular, the Company’s policy to comply with its statutory duties

under current Acts, Regulations, Approved Codes of Practice and Guidance
Notes issued through the Health, Environmental and Safety Commission and
their appointed authorities in the execution of the Company’s duties.

In order to fulfil the Company’s obligations to its employees, host communities

and clients under statute, it has defined an organisation with named
individuals being designated responsibilities for the management of CASHES
at work.

The Company will assess, monitor and record all significant risks to health,
safety and welfare of its employees, Sub-Contractors and persons not
employed by the Company as a result of its undertaking and advise all
persons of the risks to their health and all preventive measures devised by the
Company.

Where identified by risk assessment, employees will be given additional

instruction, supervision, training, information and free health surveillance as
deemed necessary. All records of risk assessments will be available for
inspection by the Company’s employees upon request.

The company will, from time to time, revise the contents of this Policy
Statement, risk assessments and safe systems of work, then bring any changes
to the attention of its employees.

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CASHES Arrangements

Safe systems of work are issued by the Engineering Manager in consultation

with the Safety Adviser and revised in line with the risk assessments for all
operations involving hazardous substances, machinery and processes for on
site activities. These systems are outlined in the CASHES Procedural Manual
which is issued to the Client or Principal Contractor, dependent upon the
Company’s defined role, along with the Foremen of the respective Sub-
Contractors involved with the project. The Company shall appoint a Certified
Safety Officer to audit site operations and report on the effective working of
the Company’s policy throughout the project.

Safety equipment and clothing are provided free of charge to Company

employees as identified by risk assessment. Equipment and clothing for Sub-
Contractor employees shall be provided by the respective Companies under
recommendations of the Company and as detailed in the Project Method
Statement.

Permit to Work systems shall be issued or obtained for all operations involving
chemicals, electricity, machinery, maintenance and entry into confined
spaces. The respective project supervisor in consultation with the Safety
Officer and the client personnel shall administer these systems.

Safety inspections and audits of Company premises and site operations shall
be arranged at regular intervals with the co-operation of the Engineering
Manager and the Safety Adviser. Reports of the findings of the audits shall be
addressed to the Managing Director with recommendations.

Community Affairs

In all operations of the company, efforts to ensure good relationship with the
host community must be observed. Community development programmes
will be followed depending on the local needs and the value of project
being executed. Wherever required, local labour will be given priority while
executing projects.
Company staff must not be allowed to enter into disputes with the members
of the community or portray any sign of superiority to them, which will lead to
jealousy. All the customs and homages applicable to the community must
be observed.

Security

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All company personnel must adhere to all existing statutory security
requirements of both the company and the clients. An identification card
from the company and as

provided by the client in the course of executing their project must be worn
at all times. Necessary and applicable security gadgets and personnel
would be provided within the company and client’s premises.

Environment

The operations of the company shall be carried out in a manner that should
impact minimally on the environment. The company will always comply with
the Statutory Acts, Regulations, Approved Codes of Practice and Guidance
Notes issued by Environment Agencies and the client.

The Duties of all Employees

It is the duty of all employees to co-operate in the implementation of the

Company CASHES policy by:-

Acting in the course of their employment with all due regard to the health,
safety and welfare of themselves, their co-workers and any other persons that
may be affected by their acts or omissions.

Complying with the instructions and procedures issued to them by the

Company for safe working practice.

Wearing and correctly using protective clothing and equipment provided.

Immediately reporting to their superiors, any defects in plants, structures,

machinery, and equipment or safety procedures, which come to their notice.

Reporting to their superiors, any incidents which results, or may have resulted
in injury, or damage, and assist with any written incident report procedure.

Co-operating with any accident or incident investigations, which are carried

out with the objective of preventing future incidents.

Keeping each workplace clean and tidy and reduce to the barest minimum
impacts of their operations on the environment and community.

Observing the charts and manufacturer’s instructions on CASHES when using

machines, tools, equipment, plant and chemicals.

Ensuring that the best available methods, techniques and equipment are
used when lifting by hand or machine.

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Keeping access to fire fighting equipment and escape routes free from
obstruction.

Ensuring good waste management of by-products of their activities.

Special Responsibilities

Directors

Ensure that all levels of employees receive adequate and appropriate

information, instructions, supervision and training for their job specific tasks.

Ensure that all levels of employees receive appropriate clothing and

equipment and ensure that it is used correctly.

Project Manager

Ensure that, during the design, planning, tendering and installation of plant,
machinery and structures that all aspects of health and safety are
considered and due resources are allocated to the project to include the
management of CASHES.

Co-ordinate all aspects of CASHES matters with regard to the activities of

clients and Sub-Contractors.

Always set an example to others by wearing the appropriate protective

clothing and using correct equipment and procedures.

Site Foremen

Ensure that all employees, Sub-Contractors and persons invited onto

Company sites wear the protective clothing and equipment that is required
and provided for the particular circumstances.
Set example to others by always wearing the appropriate protective clothing
and using the correct equipment.

Organisation for Safety

The Board of Directors have appointed the Managing Director/Chief

Executive Officer, Chief S. S. Sanusi, as having particular responsibility for
Community Affairs, Safety, Health, Environment, Security and Welfare matters.
It is the responsibility of the Managing Director to implement revisions to this
policy as and when it is deemed necessary.

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The Company has appointed the Executive Director (Operations), MR. M. E.

TAWFIK, as having particular responsibility for the monitoring of the operation
of this policy. To assist him in this respect, the Company has appointed MR.
BOLA OMOLE, as Safety Adviser to assess the effectiveness of this policy and
to give advice on the requirements of the relevant Statutory Provisions and
safety matters generally. It is to the Engineering Manager that reference
should be made in the event of any difficulties arising in the implementation
of this policy.

Reports of community problems, health, security, environmental issues and

safety hazards, accidents and incidents must be given to the relevant level in
the organisation for CASHES in order that appropriate corrective measures
can be implemented.

This statement of Company policy will be displayed prominently at all sites

and workplaces and brought to the attention of all Company employees
and Sub-Contractors.

Signed:
Chief S. S. Sanusi
Position: Managing Director/Chief Executive Officer

Dated 02-10-2009

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COMMUNITY AFFAIRS, SAFETY, HEALTH, ENVIRONMENT AND SECURITY

PROCEDURAL MANUAL

The CASHES policy means in practice that:-

- Every activity must be planned and performed in accordance with the

CASHES policy.

- Activities identified as unhealthy, unsafe, environmentally destructive or

unsecured will not be started, or will be suspended until acceptable
solutions are found.

- Morpol will continually work within the Nigeria CASHES legislation and
see ways to improve on it.

- We will ensure that all our sub-contractors meet these standards and/or
will help to improve on their CASHES management ability if found
deficient.

- Staff at all levels will be trained to recognise, for all their work;

a) The implications for their own health and for that of others.

b) The potential safety hazards.

c) The impact activities may have on the community and

environment.

S. S. Sanusi
Chief Executive Officer

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