MANAGEMENT SYSTEMS PROCEDURE. Procedure 06: Non-Conformance, Incidents and Complaints

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1 WAPRES P06 Non-Conformance, Incidents and Complaints Page 1 of 8 MANAGEMENT SYSTEMS PROCEDURE Procedure 06: Non-Conformance, Incidents and Complaints OBJECTIVE: To outline the reporting and processing of non-conformance, incidents and complaints. DESCRIPTION: Accident and incident reporting allows for the identification of contributing factors and establishes a framework for the implementation of strategies and actions aimed at preventing the recurrence of similar events. The type and extent of any non-conformity, complaint or incident is documented using the 2.0 WAPRES Incident Note. This form is available at all Company locations and carried in each Company vehicle. All employees are encouraged to use the Incident Note to suggest improvements in methods, materials, suppliers, and contractors to further reduce the likelihood of incidents, non-conformances or complaints occurring, and/or improve the efficiency of an operation or process. Preventative and corrective action is taken to eliminate potential or existing non-conformances, incidents and hazards to a degree appropriate to the magnitude of the problems and appropriate with to risks encountered to eliminate or minimize the impact on health and safety, the environment, performance, dependability, processing cost, quality-related cost, and customer and stakeholder satisfaction. SCOPE: This procedure applies to all WAPRES employees, contractors and visitors, and includes compliance to the following procedures and standards: WAPRES Management System ISO EMS (2004) The Australian Forestry Standard AS The Occupational Safety and Health Act (1984) The Occupational Safety and Health Regulations (1996) Occupational Health and Safety Management Systems AS 4801 (2001) Australian Forestry Standard AS 4707 Australian Forestry Standard Chain of Custody for Certified Wood and Forest Products (2014) Forest Stewardship Council Chain of Custody FSC-STD (2004) Forest Stewardship Council Controlled Wood FSC-STD (2006) FSC Controlled Wood Standard for Forest Management Enterprises FSC-STD-010 (2006) SCS Guide to FSC Controlled Wood (2011)

2 WAPRES P06 Non-Conformance, Incidents and Complaints Page 2 of 8 SCS Interim Standard for Natural Forest and Plantation Forest Management Certification in Australia under the Forest Stewardship Council DEFINITIONS AND ACRONYMS: Non-conformance - An activity, product (incoming or outgoing), service that does not meet the specified requirements of a contract, license, permit, legislation or regulations, WAPRES operational controls, objectives, targets or policy and management system requirements. This includes audit findings (internal or external) recorded as non-conformances (NC, M) or corrective action requests (CARs). Serious - Incidents that are potentially costly to fix, litigious, or of a significant or extreme risk to safety, quality or the environment. If the WAPRES Risk Reckoner is used, these show up as Red or Orange (any rating equal to or between one to 15). PROCEDURE: 1. NON-CONFORMANCES 1.1. Non-conformances arising from internal and external audits are raised as Incident Notes and processed as per this procedure Internal auditors are to raise incidents from audits conducted HSE Supervisor / Management Systems Officer is to raise incidents from external audits See sections 7 and 8 for specific processes regarding non-conformances in relation to Chain of Custody and Controlled Wood. 2. COMPLAINTS 2.1. All personnel receiving a complaint must advise their immediate Supervisor or Manager. Collect contact details of the complainant if possible The immediate Supervisor or Manager of the operation receiving the complaint must: Confirm details of the issue with the complainant Conduct a discretionary evaluation of the issue and categorize as: Category Evaluation Action Trivial (T) Can be resolved immediately. Resolve the issue using appropriate personnel and communication. Minor (m) Can be resolved with resolution endorsed by Senior Manager. Discuss with Senior Manager and complete Incident Note for future reference. Ensure communication with Complainant to advise of actions being taken. Serious (S) Requires a meeting of all parties with Chief Executive Officer involvement to For these two categories, an Incident Note is to be completed and the Senior Manager is to

3 WAPRES P06 Non-Conformance, Incidents and Complaints Page 3 of 8 Major (M) decide resolution. Requires a meeting of all parties with Managing Director involvement to decide resolution. provide the Complainant with a timeframe and course of action. A comprehensive written report and investigation of the issues to be filed on the Incident Register for consideration by all WAPRES management All complaints of a litigious nature are deemed serious and are to be reported to the Chief Executive Officer as soon as possible All non-trivial complaints are processed as Incident Notes. Complaints are also duplicated on the Incident Register on a separate Complaints worksheet. 3. INCIDENTS 3.1. Incident reporting should be seen as a positive initiative to document and identify areas for improvement or good performance in the company Damage, hazards, near misses, fires, oil or chemical spills, quality issues, improvement opportunities, environmental or heritage issues, and positive observations are encouraged to be reported with an Incident Note All workplace injuries must be recorded with an Incident Note. In these cases, a copy must also be forwarded to the HR Administrator If there is uncertainty as to if an injury has occurred, the Incident Note should still be raised in case of any future related claims All WAPRES personnel may raise an Incident by filling out the first page of an Incident Note Each Incident Note must be signed by the relevant Manager before processing. 4. COMPLETING INCIDENT NOTES 4.1. Incident Notes are available at all site offices or from download on the portal under Management Systems Forms A digital pdf version is also available, however note this cannot be saved once filled out and must be printed The person affected by or reporting the incident is to complete the Incident Note cover page. All general details must be included and any additional information such as photographs, diagrams and contact details should be attached. The following tasks must be completed: Select and tick the appropriate boxes for the incident category and type. In some instances it may be necessary to select more than one category Provide a brief description of the incident. Where additional space is required ensure all information is attached to the original Incident Note The second page of the Incident Note is to be completed by the WAPRES Supervisor / Manager with the person affected by or reporting the incident. Managers and Supervisors are required to ensure the following information is provided: A thorough description of the incident. This will include details of who, when, where, and what happened, any damage resulting. Any additional information such as maps and photographs must be attached to the Incident Note.

4 WAPRES P06 Non-Conformance, Incidents and Complaints Page 4 of A detailed description of what the Supervisor / Manager and person reporting the incident believe to be the underlying (root) cause of the incident. Attempt to answer the 5 Why questions this is a method found to assist in arriving at root cause A description of the immediate corrective actions that were taken Consideration of further preventative actions to try and prevent this incident from happening again An assessment of the risk (risk rating) to determine the severity of the incident, from A1 Extreme to E5 Lower. This rating is based on frequency and consequence as below: Mark the appropriate boxes to indicate: if the WAPRES Crisis Management Plan was evoked if there is a repeated history of the type of incident occurring if the incident could have resulted in serious damage, injury or death Record how the incident was documented and reviewed. The appropriate boxes should be ticked to indicate where copies of the Incident Note will be sent to. This includes: any contractor or company other than WAPRES any persons involved / affected by in the incident

5 WAPRES P06 Non-Conformance, Incidents and Complaints Page 5 of 8 the WAPRES HSE Supervisor the Chief Executive Officer (if rated as serious) 4.4. NOTE: All Serious incidents (assessed as Extreme or Significant) must be referred to the Chief Executive Officer. Should the incident be defined as a Crisis the WAPRES Crisis Management Procedure must be evoked The table below lists the maximum time available to respond and identify corrective action according to how the incident has been rated (risk rating). RISK RATING EXTREME SIGNIFICANT MODERATE LOWER CORRECTIVE / PREVENTATIVE ACTION Immediate action required Within three working days Within ten working days As appropriate / acceptable risk / continue to monitor 4.6. For incidents rated as serious (Extreme or Significant), the Chief Executive Officer will be advised of the incident and will sign the Incident Note as a record of having been notified of the incident. The Chief Executive Officer may suggest additional corrective or preventative actions Employees/contractors are requested to complete the Incident Note as soon as practicable after the incident to ensure any potential issues can be dealt with in accordance with the Corrective/Preventative Action timeframes listed above Copies of Incident Notes should be lodged with the HSE Supervisor / Management Systems Officer within a couple of days of the incident occurring Not all information may have been collected in the initial timeframe and subsequent updates to the incident will need to be advised to the HSE Supervisor / Management Systems Officer within the close out period as determined by the severity of the incident If there may be a delay in collecting all the required information, the first page of the Incident Note may be submitted to the HSE Supervisor / Management Systems Officer, with the second page completed at a later date. 5. PROCESSING INCIDENT NOTES 5.1. SITES AND SECTION MANAGERS: The original Incident Note plus any associated documentation, is to be recorded in the work area Incident file with a copy sent to the HSE Supervisor / Management Systems Officer The responsible Supervisor / Manager is required to report all incidents, nonconformances and complaints in their monthly report Discussion of Incidents are tabled at the next section Operations / Toolbox meeting.

6 WAPRES P06 Non-Conformance, Incidents and Complaints Page 6 of During this meeting, the corrective / preventative control measures are to be recorded on the meeting Action Planner highlighting dates for completion and persons responsible for actions The corrective and preventative actions are to remain on the Operations / Toolbox meeting Action Planner until they are complete When all action items are completed the Manager / Supervisor is required to contact the HSE Supervisor / Management Systmes Officer informing them of what follow up / preventative actions have taken place and so the incident can be recorded as complete on the Incident Register All incidents are to be addressed within 3 months of being reported. Follow up / preventative actions may not be fully complete in this time frame, however an update of further actions needs to be provided to the HSE Supervisor/Management Systems Officer for recording on the Incident Register Managers are required to periodically check the Incident Register to review the status of Incidents and advise the HSE Supervisor / Management Systems Officer of any changes / updates MANAGEMENT SYSTEMS: A copy of the completed Incident Note with any associated documentation is forwarded to the HSE Supervisor / Management Systems Officer to be filed in the WAPRES Incident File and entered into the R04 Incident Register Incidents may also be entered to the Incident Reporting Information System (IRIS) administered by Forest and Wood Products Australia ( ) For all employee injuries, a copy of the Incident Note is forwarded to the HR Administrator for storing on personnel files and using with any workers compensation documentation A monthly Incident Review meeting with Senior Management is scheduled by the HSE Supervisor to review all incidents recorded during the previous month A key objective of this meeting is to identify and address incidents that have the potential to impact on areas of the organisation outside of where the incident was originally reported This review involves the Managing Director, Chief Executive Officer, Compliance and Systems Manager, HSE Supervisor and/or Management Systems Officer. 6. INVESTIGATIONS 6.1. Investigations are required by legislation for serious injuries, accidents and life threatening near miss incidents. Investigations may also be requested by Senior Management into any other significant incidents or in the event of a Crisis A procedure for accident investigations is available from Guidelines for the Investigation of Accidents Summaries of investigations are recorded on R04: Incident Register Investigation reports are stored in the Management Systems area. 7. NON-CONFORMING PRODUCT CHAIN OF CUSTODY 7.1. In the case that non-conforming products are detected, WAPRES shall:

7 WAPRES P06 Non-Conformance, Incidents and Complaints Page 7 of Immediately notify the Compliance and Systems Manager and relevant Senior Management and raise an Incident Note Endeavor to immediately cease to sell any non-conforming products held in stock Identify all relevant customers, and notify those customers in writing within three business days of the non-conforming product and maintain records of this advice Analyse causes for occurrence of non-conforming products and implement measures to prevent its re-occurrence Compliance and Systems Manager is to notify the certification bodies Cooperate with the certification bodies in order to allow the certification body to confirm that appropriate action is taken to correct this non-compliance Maintain records of all actions taken. 8. NON-CONFORMING PRODUCT DUE DILIGENCE AND CONTROLLED MATERIAL 8.1. Where complaints or non-conformances are received relating to controlled wood categories or controversial sources, the following applies Personnel receiving the complaint are to immediately notify Compliance and Systems Manager and Senior Management and raise an Incident Note Dialogue is initiated with the complainant with the aim of addressing the issue before further action is taken The Compliance and Systems Manager is to advise the complainant, the relevant Certification Body and the National FSC Initiative within 2 weeks of receiving the complaint.an assessment of the evidence provided will take place within 2 weeks of receiving the complaint WAPRES will endeavor to immediately rectify the incident, isolate product should that be required, and await direction from the appropriate body to continue business. A precautionary approach will be used for any continued sourcing of material from the supplier while the complaint is pending Field verification will take place where evidence is considered relevant within 2 months after receiving the complaint If the complaint is verified, the supplier will be excluded from WAPRES certified wood category until it can prove it complies with certification requirements The Compliance and Systems Manager is to inform the complainant, FSC Australia and the relevant certifying body of the outcome of the complaint and any actions taken towards its resolution The Compliance and Systems Manager is to inform FSC Australia and/or AFS and the certification bodies when there is a non-compliance in an area considered low risk Maintain records of all actions taken If concerns are validated, the relevant Risk Assessments shall be reviewed in light of the new information. DOCUMENT REVIEW As required or within a 3 year period by the HSE Supervisor / Management Systems Officer.

8 WAPRES P06 Non-Conformance, Incidents and Complaints Page 8 of 8 REFERENCES WAPRES F2.0 Incident Note WAPRES P16 Due Diligence System (Controlled Material) WAPRES Guidelines for the Investigation of Accidents MANUAL 1.7 Crisis Management Procedure FSC-DIR FSC Directive of Chain of Custody Certification FSC-STD V3 Requirements for Sourcing Controlled Wood Standards and Legislation recorded in Scope REVISION HISTORY REVISION DATE DESCRIPTION PREPARED BY REVIEWED BY APPROVED BY 00 Aug 2004 Initial Issue M. Campbell 01 Mar 2005 Revision 01 M. Campbell 02 Mar 2006 Revision 02 J. Hales 03 Jun 2007 Revision 03 J. Hales 04 Dec 2007 Revision 04 J. Hales 05 Nov 2009 Revision 05 A. Archer Jan 2010 Mar 2011 Jul 2011 Reviewed regarding incorporation of FSC CoC Incident Registration Timeframe Review regarding FSC FM and incident reporting procedures A. Archer W Hammond W Hammond W Hammond A. Archer A. Archer Mar 2012 Changes to scope A. Archer A. Archer 09 S. Martyn 10 Nov 2012 Position Titles D. Rumenos D. Rumenos 11 May 2013 Add SCS FSC FM standard D. Rumenos D. Rumenos 12 April 2014 Add sections 1, 2, 3, 5, 6, 7 8, update format D. Rumenos 13 Jul 2014 Position title changes A. Kiely Sep 2014 Addition of , changes to A. Kiely D. Rumenos Oct 2014 Changes to section 8 D. Rumenos A. Kiely V. Beurle