Quality, Health & Safety, Clean seas. Your choice. Our mission. Environmental and Social. Principles. are possible. by nature. are possible by Nature

Transcription

1 Quality, Health & Safety, Environmental and Social Principles Clean seas. Your choice. Our mission. by nature are possible are possible by Nature

2 Nature is the leading maritime and offshore waste collection and treatment company. Nature s port reception facilities treat all Marpol waste from Annex I-V. Our Compact Treatment Units can treat your waste at any location, both on and offshore. 2 Nature Group PLC Nature Group PLC 3

3 Table of Content Foreword 7 Code of Business Conduct 8 Strategy and Principles 13 Policy 14 Organisational Boundaries and Scope 20 Hierarchy of Documents 22 Process and Management Model 24 Leadership and Accountability 26 Planning, Goals and Targets 32 Legislation, Requirements and Commitment 34 Document Control and Record Management 36 Risk Management/Management of Change 40 Business Development 42 Awareness, Competence and Attitude 44 Communication and Participation 46 Corperate Sustainability 50 Operations and Maintenance 54 Contract Management 56 Emergency, Incident and Improvement 58 Monitoring, Reporting and Reviewing 62 Contact 64 Notes 66 4 Nature Group PLC Nature Group PLC 5

4 6 Nature Group PLC Foreword It is with great pride that I present to you the Nature Group Principles. These principles communicate our core values and define what we stand for as an organisation, they also provide a foundation for achieving our goals. Our principles aim to ensure that work is carried out in a safe way and that healthy working conditions are provided, both for our own employees and for others e.g. external contractors, customers etc. These principles attempt to mitigate risks and incidents, but should they occur, our assessment and reporting procedures shall ensure that lessons are learned for the future and openness and transparency is maintained throughout. As we fulfil our specific roles and conduct Nature activities and operations, our principles encourage us to care for the environment and to respect social and cultural norms when interacting with others. Our principles define our goal: to be a world-class, motivated and responsible operator. Both leadership and internal expertise require development and enhancement, but by embedding these principles in the Group s culture we will endure the test of time. It is my vision that Nature Group will exist in the year 2100 and be considered one of the world s most predominant maritime and offshore waste service providers, in a world which has inevitably become more sustainable, with cleaner air and oceans. It is possible with Nature... Andreas Drenthen, CEO

5 Code of Business Conduct This chapter, together with the other chapters of this guidance form Nature s code of conduct. The code clarifies the expectations and responsibilities that Nature Group and we, as employees, have to each other, our partners, stakeholders and to our communities. It supports our understanding of the responsibilities we share, and will help us to anticipate and protect against all kinds of issues that may occur. Although we are a multi-national corporation with integrated standards and policies across the Group, we recognise the importance of following local laws and the established in-house policies at each location (e.g. drug and smoking policy, social media policy, lease car policy etc.). These are not the focus of this document, but can be found at each of our regional bases. Business Ethics As a Group, individual companies and as individuals we have responsibilities to the communities in which we live and operate, responsibility and commitments to legal and other regulations (e.g. ILO Conventions) plus Group documents and procedures to abide by. Anchored in our principles are our commitments towards specific areas (see policy). Gifts and Hospitality We will not give or accept any gifts or other benefits, which may be perceived as influencing our impartiality or business behaviour. We consider the offer or receipt of gifts, hospitality or expenses that are intended to affect the outcome of specific business transactions as most inappropriate. The offer or receipt of gifts, hospitality or expenses shall be modest and in-line with acceptable legal, local and cultural practices. 8 Nature Group PLC Nature Group PLC 9

6 International Labour Standards (ILO Conventions) Nature respects the eight fundamental ILO (International Labour Organization) conventions, which stimulate and contribute to: Freedom of Association No. 87 Freedom of Association and Protection of the Right to Organize Convention, 1948 No. 98 Right to Organize and Collective Bargaining Convention, 1949 The Abolition of Forced Labour No. 29 Forced Labour Convention, 1930 No. 105 Abolition of Forced Labour Convention, 1957 Equality No. 111 Discrimination (Employment and Occupation) Convention, 1958 No. 100 Equal Remuneration Convention, 1951 The Elimination of Child Labour No. 138 Minimum Age Convention, 1973 No. 182 Worst Forms of Child Labour Convention, Nature Group PLC

7 Strategy and Principles Nature s ambition is to be a sustainable frontrunner in the worldwide maritime, oil and gas business. We realise that this is only possible in cooperation with our stakeholders, by focusing on our strategy and by creating a shared value. We aspire to be the leading maritime and oil & gas waste service provider, that leads through its corporate principles and offers sustainable, solution focused, innovative treatment methods to its clients worldwide. By communicating our positive impacts, sharing knowledge and engaging and inspiring our stakeholders, we would like to create a CSR (corporate social responsibility) wave motion. A wave moving people, planet and performance forward to a more sustainable world with cleaner seas. Nature Group PLC 13

8 Policy Introduction Since the start of our operations, we have been making a valuable contribution to a more sustainable world with cleaner seas by collecting, treating and creating energy out of wastewater. Nevertheless, in our opinion, CSR is more. CSR is about having a positive impact on people, planet and performance; a positive impact for our stakeholders - our employees, clients, suppliers, communities and society at large. CSR affects all our activities, everything we do day after day. Our focus is on the people, planet and performance related aspects where we can and do make a difference. Established in our principles is a commitment to: Health and safety Business (quality) assurance, customer relations and customer confidence Compliance and transparency Innovation and sustainable solutions Communication of our performance to all stakeholders Leadership, personal responsibility and development Clean seas Society and the environment Nature s Policies and Commitment Health and safety for all and environmental protection are top priorities in the guidelines of Nature Group. These guidelines are binding for all employees and, most importantly, entail a commitment from the senior management to quality, health, safety, and the environment. Nature is committed to providing healthy workplaces, thus reducing illness and absence of employees and striving for zero incidents and accidents. Nature also aims to reduce the use of natural resources and minimize environmental pollution in all its forms. Management programmes will be used to address and to follow-up issues identified by our stakeholders and by Nature itself, to make positive impacts in the widest sense (from people to society to environment to stakeholders and vice versa). Legal and Other Regulations Nature complies with both local and international law plus other applicable legal regulations, customer requirements and recognised (international) social guidelines, (e.g. with regard to child labour, equality of human rights as stated in the ILO Conventions etc.) Where possible we actively support and endorse better regulations and anticipate future regulations, locally and globally to improve our standards, procedures and performance. 14 Nature Group PLC Nature Group PLC 15

9 Competences and Experiences Having a long history in the transportation and handling of dangerous waste, we have always recognised our responsibility in matters of quality, health and safety and the environment. Nature s training programme for hazardous goods is used for training the staff of several customers as well as our own. Considering our activities at port facilities we establish, implement and maintain tailor made policies and procedures for the prevention of (major accident) hazards. Monitoring and Reporting Nature uses advanced information technologies to record, monitor and analyse incidents, maintenance activities, legal compliance and our performance in general. We will periodically publish our relevant quality, health and safety and environmental performances (e.g. carbon footprint) in-line with legal, CSR and financial parameters and/or guidelines and rules. Business Assurance Nature will have and maintain the clear requirement of implementing the same environmental, health and safety and sustainability standards as those applied by our customers and/or our stakeholders. 16 Nature Group PLC The strictest quality, health, safety, environmental and (major accident) hazard / emergency response standards are an integral part of world-class performance in Nature Group services. Therefore we will establish, implement and maintain a group-wide management system according to recognised standards. grou

10 Taking care of people and planet are essential pillars in our policy, which means that sustainability is at the core of our business.

11 Organisational Boundaries and Scope Organisational Boundaries This booklet (which is publicly available) interprets and supports Nature s policies and principles, and applies to all Nature sites and operations worldwide. These include: Sites and/or activities where Nature has the majority financial and/or operational. Acquisitions, divestments, mergers and/or (business) development projects. Activities by (sub) contractors and/or 3rd parties on Nature facilities or under Nature management. Scope The scope of the principles given in this booklet is to cover all operational aspects and activities which can be influenced and/or controlled and have the potential to have an impact on quality, health, safety, environment, sustainability and society at large. The purpose of this booklet is to: Support the implementation of Nature s Policy and to succeed in its Strategy Realise a risk-based management system framework, in accordance with: o ISO 9001 o ISO o ISO / Global Reporting Initiatives o OHSAS o Stakeholder interests o International policies and standards to which Nature Group is committed including: United Nations Universal Declaration of Human Rights US-UK Voluntary Principles on Security and Human Rights AIM rules Application This booklet has been issued on the authority of the Executive Management Team of Nature Group PLC as guidance of all staff, subcontractors, clients and/or regulatory bodies to whom Nature Group PLC or its subsidiaries may be required to provide such information to. Review and Document Control This booklet and its content will be reviewed at least every three years or as required by other regulations to which Nature subscribes. 20 Nature Group PLC Nature Group PLC 21

12 Hierachy of Documents Nature has chosen to build a hierarchical structure, where documents and procedures must meet and support the requirements and expectations of documentation at higher levels. Status and Application The strategy, policy and guidance given in this booklet are mandatory to all Nature facilities and activities. Nature procedures are mandatory to all Nature facilities and Nature controlled activities. These documents address specific topics (often required by international standards) where it is important that the process flow is carried out consistently and records kept to demonstrate conformity to the requirements. These procedures are to be written in UK English at all times. Work instructions, forms etc. provide preferred work methods and/or registrations and are advisory not mandatory. Work instructions, forms etc. are preferably made and controlled locally (in the local language). Included in this guidance document Strategy & Policy Nature Group Guidelines Procedures Work Instructions Forms etc. Availability to the Public This booklet is available in PDF format on request and can be found on the Nature Group website, 22 Nature Group PLC Nature Group PLC 23

13 Process and Management Model Nature s management model is based on the Plan-Do-Check-Act methodology. The figure below illustrates how our guidelines fit into this model and ensure continual improvement. - Leadership and Accountability - Risk Assessment - Legislation, Requirements and Commitments - Planning, Goals and Targets - Risk Management - Business Development and Change Management - Document Control and Record Management - Awareness, Competence and Attitude - Communication and Participation - Operational Control and Maintenance - Contract Management - Emergency, Incident and Improvement Plans - Corporate Sustanability - Management Review Planning Reviewing Implementation and Operation Monitoring and Checking - Auditing and Legal Compliance - Monitoring and Reporting Share, inspire, guide, motivate and assign. 24 Nature Group PLC

14 Leadership and Accountability It is Nature s intention that Board Members, Directors, line managers, employees and (sub) contractor staff are aware of their own role, responsibilities and accountabilities. They will demonstrate leadership (where relevant) and commitment to Nature s policies and corporate sustainability strategy, through an effective management system. Commitments 1. Nature establish, implement and maintain Group strategies and policies that are appropriate to the nature and scale of the Group s health, safety, environmental and social impacts. 2. The policy will be available to the public and stakeholders. 3. The Group s strategy and policy are approved by the Executive Management Team and Board. 4. The principles in this booklet are approved by the Executive Management Team. 5. The Executive Management Team and Nature staff will seek conformity to the principles and management system. 6. Top management will regularly review performance of all aspects and at all levels. 7. Nature s management system is certified in accordance with recognised management system standards. 8. Local management will establish and document the scope of their activities which are relevant for certification. 9. Line managers are accountable for both the performance of their business and also for implementing and maintaining Nature s policy, procedures and work instructions. 10. Line managers will provide their staff with necessary and sufficient resourses to support the implementation and maintenance of an efficient and effective (integrated) management system, incorporating the implementation and maintenance of an appraisal system for all employees. 11. Managers will demonstrate visible, available leadership and pro-active commitment to Nature s strategy and policy by personal example. They will promote initiative and encourage cooperation and teamwork at all levels. 12. Specific, measureable goals and targets will be included in improvement plans. 13. Line managers will support and participate in (periodical) site inspections, audits and (safety related) observations 26 Nature Group PLC Nature Group PLC 27

15 14. Roles, competences and responsibilities will be documented in-line with the importance of conformity with the strategy, policy and potential impact they could have. These will be communicated, kept up-to-date and understood by personnel. 15. Programmes are in place to ensure awareness and expectations towards employees behaviours and attitudes in general. Rights and Obligations 16. Employees and (sub) contractors understand that they have the right and responsibility to stop work (temporarily) or refuse to work in situations that are conflicting with their own safety or the safety of others and/or Nature s policy. Such situations will be immediately brought to the attention of those at risk and reported at all times to the responsible (line) management. grou 28 Nature Group PLC

16 by nature are possible are possible by Nature

17 Planning, Goals and Targets 3. Responsibilities, resources and time frames are designated and documented to achieve the set goals and targets. 4. Periodical performance information is gathered and used for defining improvement plans, goals and targets. It is Nature s intention to achieve sustainable development as an integrated part of our planning and control cycle. The planning and control cycle is crucial for our goal and target setting process and in order to ensure continuous improvement. Commitments 1. A management system is established, implemented and maintained to ensure successful business planning based on identified risks, stakeholder interests and legal compliance. 2. Nature sets measurable goals, targets and performance indicators for the Group as a whole and its specific business areas. These are documented, communicated, periodically monitored and annually reviewed and are consistent with Group policy and stakeholder interests. Improve 32 Nature Group PLC Nature Group PLC 33

18 Legislation, Requirements and Commitment Legal, regulatory and other requirements to which Nature Group subscribes are identified, available, understood, monitored and complied with. Commitments 1. Systems are implemented to identify and access all relevant laws, regulations, legal correspondences, licences, permits, approvals/ permissions and other requirements (codes, acts, decrees, policies, standards, covenants etc.) They are documented (or linked) in a compliance register that is reviewed and kept up-to-date. 2. Periodical evaluation of compliance with relevant requirements is implemented. Procedures are put in place to ensure communication of specific requirements, periodic evaluation and reporting. 3. If local legislation does not require an adequate level of control and/or is lacking in detail, Nature will conduct activities and operations in a manner that is consistent with relevant international standards and legislation, taking into account local social and cultural sensitivities. 4. If specific knowledge is lacking and/or in-depth knowledge is not available within Nature, experts will be consulted to address and meet legal requirements. Up-to-date Permit 34 Nature Group PLC Nature Group PLC 35

19 Document Control and Record Management Documents are produced consistently and records are kept to demonstrate conformity to Nature s policy and other (legal) requirements. Commitments 1. An integrated management system, in accordance with the requirements is implemented to: a. Establish and document the interaction of processes. b. Ensure consistency in the way we operate. c. Ensure that documents and records are controlled. 2. Actual documents and records are available at the workplace and are understandable to the user. 3. A Group procedure is implemented to ensure that records are established, maintained, accurate, legible and traceable to the source. 4. Documents and records are uniquely identifiable, stored securely, retrievable and have established retention times based on legal or other requirements (if applicable). 5. Documents and records are preferably stored digitally. A procedure is implemented to ensure the availability and safe storage of digital data at all times (back-up procedure). 6. A Group procedure for withdrawal and/or disposal of documents and records is implemented. Privacy 7. Medical records and other records with private information are kept confidential and in accordance with (local) legal requirements. 36 Nature Group PLC Nature Group PLC 37

20 roup

21 Risk Management/ Management of Change Hazards and risks are identified and assessed systematically in order to prioritise those which are significant and to manage and control these hazards and risks. Commitments 1. The risk management procedures are applicable to all facilities and activities that can be controlled and/or influenced by Nature. 2. Risk assessments are conducted only by those with the relevant knowledge and expertise. 3. Procedures are implemented to: a. Identify financial, quality, health and safety, environmental, image and other related risks. b. Ensure a standardised methodology, which includes identification of: I. Occupational health hazards and risks in normal and abnormal situations. II. Environmental effects in normal, abnormal and emergency situations. 4. Procedures are implemented (where relevant) to identify major hazard risks for new facilities and newly controlled facilities. 5. Hazards and risks are documented and maintained in a risk register. 6. The risks are reviewed and updated (if necessary) at least annually and/or after a significant change, incident or as often as deemed necessary depending on the nature of the risk. Management of Change 7. Procedures are implemented to identify the hazards and risks associated with both planned and unplanned changes (e.g. organisational, technical, facilities, process, technology, procedures, (legal) requirements, design etc.). 8. Change management procedures ensure that: a. Competent and authorised employees and/ or contractors or consultants approve temporary or permanent changes. b. Changes are communicated to all involved (internal and/or external). c. Changes are understood by all involved (internal and/or external). d. Identified actions have been completed. e. Documentation will be kept up-to-date and reflect the change(s) (including documentation, drawings, training needs etc.) and outcome (impact, result). together 40 Nature Group PLC Nature Group PLC 41

22 Business Development Managing risks is integrated in all processes of Nature Group. From the beginning (design, acquisitions) during approval, procurement and construction, right through to the end (start-up, commissioning). Commitments 1. Due diligence and/or dedicated project management (e.g. PRINCE2) processes are implemented to ensure the quality of risk assessments and project management as a whole. 2. Learning and experience from previous projects, current projects and other sources is taken into account in new business development and project definition. 3. Standards for design, project management, construction, risk assessment and commissioning follow legal requirements (if applicable), industrial codes and standards and ensure a sound and accurate business development process. 4. The design and selection of new facility locations, equipment and/or processes takes into account financial considerations, technical possibilities, stakeholder interests, life of asset requirements, (de)commissioning conditions, disposal and closure (end of life cycle). 5. Project management is managed and documented to ensure: a. Identification and documentation of critical equipment, systems, procedures, activities and milestones. b. Incorporation of risk management processes. c. Definition of responsibilities and competences. d. Project organisation. e. Pre and post start-up reviews and validation/verification reviews where needed. Ideas! 42 Nature Group PLC Nature Group PLC 43

23 Awareness, Competence and Attitude Employees, (sub) contractors and suppliers are aware of all possible hazards and risks, are competent and have the right attitude to act appropriately, safely and in-line with Nature s strategy, policies and stakeholder concerns. Commitments 1. Employees and (sub) contractors receive training and/or instructions appropriate to their responsibilities and roles. 2. When visiting a Nature facility or location for the first time, the relevant hazards, risks and related controls to eliminate and/or reduce such hazards and risks are presented, as appropriate to the nature of the proposed activities. 3. Procedures and systems are in place to identify, plan and monitor training needs. 4. Data from behavioural observations are recorded and analysed to identify, plan and implement op portunities for improvement. 44 Nature Group PLC Nature Group PLC 45

24 Communication and Participation Effectiveness, openness and transparency are the success factors of communication and interaction with employees, contractors and stakeholders. Nature encourages all involved parties to participate and contribute towards the common goal of a sustainable future with cleaner seas. by nature Commitments are possible are possible by Nature 1. A procedure and methodology is established and implemented to identify stakeholders, their concerns and expectations. 2. The corporate and departmental strategies and relevant information are communicated throughout the entire organisation. 3. Nature s policy and these principles are published both locally and on the internet and are communicated to employees, (sub) contractors and (relevant) stakeholders. 4. Employees, (sub) contractors and stakeholders are encouraged to participate in the development, implementation and review of business risks in general and to participate in specific improvement initiatives. 5. An open and pro-active communication and consultation process with employees, (local) governmental organisations, authorities and stakeholders is maintained. 6. Complaints, opportunities for improvement and relevant (external) communications related to Nature s integrated management system and/ or operational performance are recorded, investigated, reported back to relevant parties, analysed and monitored for continual improvement purposes and in consistency with the policy. 7. An annual, integrated corporate sustainability report is produced to communicate Nature s annual financial, quality, environmental, health and safety and other relevant performances. Communicate enabled by Nature 46 Nature Group PLC Nature Group PLC 47

25 by nature are possible are possible by Nature

26 Corporate Sustainability Clean seas are possible. Management of hazards, risks, activities and operations is conducted in a sustainable way, with respect for human rights and traditional rights, values and cultural heritage. Sustainability wheel Community CSR Health and safety Energy Energy Compliance Waste Transparency Continuity Commitments 1. Managers are committed to corporate social responsibility principles. 2. Records and registrations are kept to demonstrate and ensure that all disposed and collected waste can be tracked from source to disposal. 3. Nature complies with the Articles of the United Nations Universal Declaration of Human Rights. 4. A philosophy is established, implemented and continually refreshed to identify sustainable initiatives. Potential future initiatives are recorded in a register and discussed and reviewed periodically. 5. Nature forms partnerships with organisations who actively promote and encourage implementation and realisation of sustainable initiatives. Where possible, Nature or its (local) subsidiary work with local communities or organisations to support sustainable initiatives. 6. An annual integrated corporate sustainability report is produced to communicate Nature s annual financial, quality, environmental, health and safety and other relevant performances. This integrated CSR report will take the sustainability performance indicators (GRI Global Reporting Initiative) into account. 7. Monitoring and reporting are built on the principles: relevance, completeness, consistency, accuracy and transparency. Clean seas 50 Nature Group PLC Nature Group PLC 51

27 8. Employees have the possibility to get regular health checks. 9. Employees have the possibility to participate in beneficial company agreements which have higher standards / conditions (e.g. corporate health insurance agreement etc.). 10. Procedures are in place to ensure that natural resourses will be used efficiently and in a sustainable manner. 11. Research and development takes place to identify and implement new techniques to collect and/or reuse, recycle, treat or properly dispose of (collected or produced) waste. 52 Nature Group PLC

28 Operations and Maintenance All Nature fleet and equipment relating to Nature s activities (whether on site, remote and/or offshore) are operated, maintained and inspected in a sustainable way, in-line with legal requirements and Nature systems and procedures. Commitments 1. Systems and procedures are established, implemented and maintained and will be modified as necessary to ensure that our design, development, operations and maintenance activities are managed in such a way as to control and/or reduce our hazards, risks and impacts. 2. Documented procedures, work instructions and/or forms are in place to control situations where their absence could lead to deviation from our policies, legal requirements or this guidance. 3. Such procedures etc. will be reviewed periodically to ensure that they are kept up-to-date and maintain effectiveness of our processes. 4. Performance indicators are communicated, measured, monitored and evaluated periodically and are in-line with goals and targets. 5. Procedures are in place to ensure identification, control and review of the hazards, risks and impacts of our operations and maintenance activities (executed by own staff and/or contractors). 6. Programmes and plans are in place to plan, identify and monitor maintenance activities and related instructions and/or simultaneous operations and their impacts. 7. Modification of operating or design limits are subject to management of change. Operations with Major Hazard Risks 8. For relevant sites, dedicated studies (e.g. HAZOP, Impact Assessments) are undertaken to identify major hazard risks, associated mitigation and the necessary emergency response protocol. 9. (Major Accident Prevention) Policies, procedures, programmes and instructions are established, implemented and maintained to control operations with major hazard risks in accordance with international legislation. 10. Site management will communicate and cooperate with local authorities to reduce and control possible major hazard risks in all operational situations (normal, abnormal, emergency etc.) 11. Periodical emergency response drills will be executed (in cooperation with local authorities if applicable). 54 Nature Group PLC Nature Group PLC 55

29 Contract Management Contracting of services (purchasing, hiring, leasing of vessels/ships, equipment, materials, employees) are carried out in a sustainable way to reduce and/or control their impact where possible. Commitments 1. Hazards and risks related to contracted services are identified, analysed and reviewed periodically as part of the overall risk assessment procedure. 2. Contracts and agreements with relevant parties include appropriate obligations, specifically requiring: a. Commitment to Nature s policy b. Commitment to Nature s principles c. Compliance with legal and other relevant requirements 3. Commitment to Nature s CSR philosophy to achieve cleaner seas. 4. A system is implemented to monitor and evaluate contractors performance. 5. Suppliers are encouraged to establish and maintain (certified) systems and/or procedures consistent with international standards. 6. Suppliers and contractors shall provide information on the hazards, risks and impacts associated with all aspects (delivery, assembly, start-up, operations, maintenance, inspection, emergency, shut-down) of their services prior to delivery. 56 Nature Group PLC Nature Group PLC 57

30 Emergency, Incident and Improvement All incidents, accidents and near misses are recorded, investigated and analysed. Non-conformity to the system, procedures, legal and other requirements are reported. Appropriate corrections and corrective actions are taken and the lessons learned are shared. Commitments 1. A system and procedures are established, implemented and maintained for timely reporting and appropriate follow-up of both positive findings and (all) incidents, accidents, near misses and opportunities for improvement. 2. Timely reporting is promoted by and a responsibility of all line managers and their staff. 3. Incident and accident reporting includes all relevant information, fact and underlying causes. 4. The information gathered following analysis, is used to identify lessons to be learned and shall be shared across the Group and its subsidiaries. These outcomes will also be shared with stakeholders and others as appropriate. Emergency Preparedness 5. A system is in place to identify the impact and effects of potential emergency situations associated with Nature s operations and services, including assessment of neighbouring activities also. 6. Procedures which define responses to foreseeable scenarios are established, documented, maintained, periodically reviewed and tested. Procedures and/or plans define the emergency response organisation, roles and responsibilities. 7. Periodical emergency response drills are planned and conducted (in cooperation with local authorities as appropriate). 8. Emergency response maps and or instructions are published in clear, visible locations. 9. Emergency response plans and procedures are easy to read and to understand and are accessible at all times. 10. Equipment and tools dedicated to emergency response are easy to recognise, visible and accessible at all times and will not been used for any other purpose or unnecessarily moved from their dedicated location. 11. Employees, contractors and any other relevant parties visiting a Nature site or operation are instructed and/or trained in and understand the need and content of emergency plans, procedures etc. 58 Nature Group PLC Nature Group PLC 59

31 Major Hazard Risk Operations (additionally to above) 12. For relevant sites, dedicated studies are undertaken to identify the major hazard risks, the mitigation measure in place and the necessary emergency response organisation. 13. In accordance with international legislation, policies, procedures, programmes and instructions are established, implemented and maintained to control operations with major hazard risks. 14. Site management will communicate and cooperate with local authorities to reduce and control possible major hazard risks in all operational situations (normal, emergency etc.). 60 Nature Group PLC

32 Monitoring, Reporting and Reviewing Performance and systems are monitored, analysed, assessed and reviewed to ensure compliance, identify trends and progress and to achieve continuous improvement. Commitments 1. Operational, health, safety, environmental, quality and sustainable performances are regularly measured, monitored, analysed and reviewed to report to the organisation and stakeholders as appropriate. 2. Inspections, audits, assessments and/or reviews are conducted at frequencies appropriate to the identified level of risk, hazard and/or impact and reported in accordance with legal requirements and/or other standards as applicable. Audits are conducted objectively and impartiality is ensured. 3. Annual in-house assessments are executed to demonstrate accordance with this guidance. 4. Periodical audits are planned and executed in accordance with international standards. All sites, locations and organisational levels are audited every three years to establish the level of conformance with this guidance and the standards to which Nature subscribes. 5. Management reviews (top level) are conducted annually to determine the suitability, adequacy and effectiveness of the management systems and procedures. The management review requires mandatory input and output. Emergency Response 6. Emergency response plans, HAZOP (hazard and operability) studies and risks assessment reports will be reviewed at frequencies appropriate to the level of importance and/or at least annually or after each change/modification or incident. 62 Nature Group PLC Nature Group PLC 63

33 Contact Nature Group plc Ordnance House 31 Pier Road St. Helier / Jersey JE4 8PW info@naturegroup.co.uk Nature Port Reception Facilities Limited Gibraltar 1A, North Mole Road, Western Arm, PO Box 393, Gibraltar Nature Shipping Agency Limited Gibraltar Unit 4/5, The Boardwalk, Tradewinds, PO Box 393, Gibraltar Nature International Slop Disposal BV Netherlands Torontostraat 20, 3197 KN Botlek-Rotterdam Nature Ecoscrub Solutions BV Netherlands Torontostraat 20, 3197 KN Botlek-Rotterdam Nature Oil & Gas AS. - Norway Slettestrandveien 17, 4032 Stavanger, Norway Nature Environmental Technologies Ltd South Unit, Hawksfield A39 St Breock Wadebridge Cornwall Crystalwater Navigation Ltd Malta 10, Timber Wharf, MRS 1443 Marsa, Malta 64 Nature Group PLC Nature Group PLC 65

34 Notes 66 Nature Group PLC Nature Group PLC 67

35 Notes 68 Nature Group PLC Nature Group PLC 69

36 Clean seas. Your choice. Our mission.

37 Clean seas. Your choice. Our mission.