Environmental Policy. JRI Orthopaedics Limited

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1 JRI Orthopaedics Limited October 2014

2 Contents Clause 1. Policy Statement 1 2. Who is covered by the policy? 2 3. Organisation and Responsibilities 2 4. Training and Communication 3 5. Suppliers and Customers 3 6. Energy Management 3 7. Monitoring and review 4 Appendix 1 Amendment Record 5

3 1. Policy Statement 1.1 As a part of the Company's corporate social responsibility, it is JRI's policy to minimise its impact upon the environment. We do this by ensuring that all reasonable measures are taken to manage environmental aspects during the design, manufacture and distribution of orthopaedic products. These aspects include but are not limited to the careful use of raw materials, the prevention of pollution, the reduction of energy usage, the reduction of waste and the careful disposal of waste. We take care not to damage our surroundings or to have an adverse visual effect upon them. 1.2 JRI will comply with all applicable legal and other requirements and all relevant codes of practice. Furthermore, the Company will demonstrate continuous improvement in environmental controls through compliance with the international standard for environmental management systems ISO that includes the setting of measurable objectives. 1.3 The purpose of this policy is to: (a) (b) set out our responsibilities, and of those working for the Company, in observing and upholding the Company's position on the environment; and provide information and guidance to those working for the Company on how to prevent, recognise and deal with any potential impact JRI may have on the environment. 1.4 We have identified that the following are particular risks for our business: Suppliers that do not manage and seek to reduce their environmental impact Use of certain machinery in production with high energy consumption Heating, cooling and lighting our premises The use of noisy equipment The use of potentially hazardous materials to produce and clean our products The packaging materials for our products The disposal of waste materials and obsolete products Travel, particularly high mileage car use by our sales executives Transporting our goods to and from customers To address those risks we have: Conducted environmental impact assessments, involving employees Developed standard operating procedures, methods statements and efficient systems of work Developed waste reduction programmes and effective waste management streams Reviewed our packaging regimes to reduce the material used Identified ways to recycle waste materials Trained employees on any potentially hazardous equipment, materials or tasks Trained employees on energy conservation measures Conducted regular environmental audits with corrective and preventative actions October

4 2 Who is covered by the policy? This policy applies to all individuals working at all levels and grades, including all directors, managers, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, or any other person visiting our premises, wherever located (collectively referred to as workers in this policy). 3 Organisation and Responsibilities 3.1 The arrangements made to implement this policy are defined and documented in the Company Environmental and Energy Management Procedure PM022 and in Departmental Work Instructions. The allocation of duties and responsibilities for environmental matters and lines of reporting are defined in the Company Integrated Management System (IMS) Manual sections 2 and 3. Company personnel competent in environmental matters have been appointed in Sheffield and London. 3.2 JRI management will do everything that is reasonably practicable to: (a) (b) (c) (d) (e) provide and maintain plant, equipment, and systems of work, that are efficient minimise risk to the environment in connection with the use, handling, storage and transport of articles and substances provide information, instruction, training and supervision to safeguard the environment provide safe means of controlling and handling all types of waste control the place of work, maintaining it in a sound condition 3.3 You must ensure that you read, understand and comply with this policy. 3.4 Every employee has a clear duty to take all reasonable steps to safeguard the environment by their acts or omissions during the course of their work. 3.5 It is the responsibility of all those working for us or under our control to prevent, detect and report environmental issues. Every worker must maintain good housekeeping practices, keeping their working area clean and tidy. They must carefully consider their use of energy and materials and report any environmental risks in the work place as soon as possible to their immediate superior. 3.6 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve the right to terminate our contractual relationship with other workers if they breach this policy. October

5 4. Training and Communication 4.1 This policy is on view on notice boards in all Company locations and on the Company website Management will ensure that all information, instruction, training and leadership necessary to ensure environmental management at work are provided for all employees. Training on environmental issues is an essential part of employee induction for new employees and for employees that are moving to a new work place or role. Regular training on environmental impact controls will be provided to all employees. 4.3 Managers and Team Leaders will encourage and promote the cooperation of employees by consultation and discussion with them on a regular basis. 5. Suppliers and Customers 5.1 JRI considers its relationships with suppliers to be one of partnership. We will encourage them to adopt more environmentally beneficial practices in the supply of materials and services. Moreover, we prefer to work with suppliers that have active environmental management programmes, demonstrate continuous improvement in that regard and are accredited to ISO Where possible, JRI seeks to develop partnerships with its customers. We will encourage them to adopt more environmentally beneficial practices in the use and disposal of materials. Moreover, where practical, we will support our customers in their efforts to reduce environmental impact when using our products. 6. Energy Management 6.1 JRI acknowledges the importance of energy as a necessary resource for successfully meeting the organisation's operational objectives. The company is committed to the responsible use of energy and will seek energy efficiency throughout all of its premises; utilising its plant and equipment in the most cost effective manner to minimise waste, reducing its Carbon Footprint and minimising JRI's impact upon the environment. October

6 6.2 To achieve this JRI will: (a) (b) (c) (d) (e) (f) (g) (h) consider alternative and emerging technologies, in all new and refurbished facilities use best practice in energy efficient design select energy efficient plant and equipment, systems and other energy infrastructure maintain all plant and equipment so that it operates efficiently control and manage systems and energy infrastructure in such a way as to minimise energy wastage monitor and report on the Company's energy consumption and identify and implement opportunities for improved energy efficiency pursue the use of renewable and alternative energy sources to supplement conventional energy sources procure, distribute and maintain energy resources at the lowest cost whilst addressing the items above 7. Monitoring and Review This policy will be reviewed for continued suitability at the annual Management Review Meeting and any recommendations for changes made to the Audit, Risk and Policy Committee of the Board. Mr K R Jackson Managing Director JRI Orthopaedics Ltd October

7 Appendix 1 Amendment Record New issue Date Section Amendment date 09/09/14 All Changed date to October 2014 throughout the document October 2014 October

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