Human Resources SHELL CANADA LIMITED ALCOHOL AND DRUG POLICY

Human Resources SHELL CANADA LIMITED ALCOHOL AND DRUG POLICY October 2012

OVERVIEW Objective and Scope The objective of Shell Canada Limited s Alcohol and Drug Policy is to provide a framework for dealing with alcohol and drug related problems in the workplace based upon the following premises: n Shell strives to eliminate or minimize health and safety risks associated with its business activities. n The misuse of alcohol or prescribed or over the counter drugs ( medications ) and the use of illegal drugs jeopardize job safety and performance, the well being of employees and the public, the environment, and Shell s corporate reputation. n As appropriate measures are necessary to ensure the safe and sustainable conduct of Shell business, the use of alcohol or illegal drugs and the misuse of medications by Shell employees in the workplace are strictly prohibited and subject to disciplinary action up to and including dismissal for cause. n Shell recognizes that education, deterrence, and early intervention may help prevent alcohol and drug problems and dependencies in Shell employees or assist them with rehabilitation. Employees are encouraged to seek assistance from Shell s Occupational Health department respecting any drug or alcohol related problem or dependency they may have. This policy applies to all employees working for Shell in all work circumstances. Standards and Prohibitions Shell employees must perform their work duties without limitation due to the use or after effects of alcohol, illegal drugs, or medications (see section on Fitness for Duty). The following are strictly prohibited for employees: n While on duty, to use alcohol or illegal drugs or misuse medications. For employees in Safety Sensitive Positions this prohibition covers meals and other breaks. In addition, employees in Safety Sensitive Positions must not be found, while on duty, to have a detectable blood, or breath equivalent, alcohol content of 40 milligrams per 100 millilitres (0.04 %) or greater. n To possess, distribute, or offer for sale alcohol, illegal drugs, or drug paraphernalia or to illegally possess, distribute, or offer for sale medications on Shell premises, in Shell assigned vehicles, or on premises where Shell work is being performed. n To use alcohol or illegal drugs following a work related incident, before receiving post incident tests or being advised that tests will not be required. n To fail to submit to tests required pursuant to this policy. n To attempt to tamper with any obtained alcohol or drug test samples. Consequences of Non-Compliance Employees failing to comply with any of the above standards or prohibitions may be subject to: n Formal supervisory referral to Shell s Occupational Health department for assessment. n Disciplinary measures up to and including dismissal for cause. 2 Alcohol and Drug Policy

FITNESS FOR DUTY Standards Fitness for Duty is a requirement of all Shell employees during the time they are at work. To establish Fitness for Duty, a medical and/or other professional determination is made of the physical and psychological capability of an employee to safely and acceptably perform assigned duties without limitations ( Fitness for Duty ). This determination is made considering job demands and potential job exposures. To establish their fitness to perform Safety Sensitive duties, employees entering or re-entering Safety Sensitive Positions will be required to complete a medical assessment and to test for alcohol and specified drugs as part of a certification process ( Certification, as described in the first paragraph of the Certification section, below). Procedures In any work situation where a Shell employee is suspected of being under the influence of alcohol or illegal drugs or the performance disabling effects of medications, the employee may be required to attend for a Fitness for Duty assessment, which may include testing for alcohol and specified drugs. If, during the assessment, the employee is found to be impaired, or if an assessment cannot be performed, the employee will be provided with transportation to their place of residence. Consequences of Non-Compliance The employee may be temporarily suspended with pay and be removed from the worksite pending one or more of the following: n Assessment of a drug or alcohol problem and/or dependency or the misuse of medications. n The approval of site management, after considering the job functions to be performed, the safety of the work environment, and any appropriate conditions governing the employee s return to work. n A determination of whether a breach of this policy has occurred and, if so, the appropriate disciplinary action to be taken. Safety Sensitive Positions Scope Identified Safety Sensitive Positions will include: n Any position having a direct role in operations or construction where impaired performance could reasonably be expected to result in an incident having significant negative effects upon the health and/or safety of Shell employees, contractors, customers, or the public, or a significant negative impact to the environment. n Positions without direct involvement at the operational level but in which decisions, failures to act, or inappropriate action could reasonably be expected to result in an incident having significant negative effects upon the health and/or safety of Shell employees, contractors, customers, or the public, or a significant negative impact to the environment. n The temporary performance of any of the above roles. Alcohol and Drug Policy 3

Safety Sensitive Positions continued Identification Safety Sensitive Positions will be identified by each Shell business unit from time to time and will include, but may not be limited to, positions involving: n The operation, maintenance, or control of equipment for the production, processing, or transportation of hydrocarbons, chemicals, hydrocarbon by-products, or any other hazardous material. n The operation of or performance of maintenance upon aircraft. n The supervision of drilling or service rig activities. n The operation of heavy equipment. n Direct operational responsibilities for emergency incident response that could reasonably be expected to affect the safety of operations. n Direct responsibilities for field operations. Certification Certification will include completing a medical assessment to verify fitness to perform Safety Sensitive duties and testing for alcohol and specified drugs. Prior to entering or re-entering Safety Sensitive Positions, employees will be required to fulfill Certification requirements. Employees occupying Safety Sensitive Positions upon the effective date of this policy will be required to fulfill Certification requirements within six months following the fifth anniversary of such effective date, in accordance with scheduling as established by Shell management. Employees continuing to occupy Safety Sensitive Positions must re-fulfill Certification requirements within six months following the fifth anniversary of each of their previous Certifications. Alcohol and Drug Testing Certification Certification requirements for employees in, or hired or transferred into, Safety Sensitive Positions will include the administration of tests for alcohol and specified drugs. Reasonable Cause Testing for alcohol and/or specified drugs will be performed when there are reasonable grounds to believe that the conduct of an employee while on duty in a Safety Sensitive Position is indicative of the use or after effects of alcohol or drugs, or the misuse of medications. The decision to test may be made by a supervisor (if possible, with the concurrence of a second supervisor or manager) and will be based upon specific observations about an employee, which could include, but are not limited to, the following: n Observed use of drugs or alcohol n The smell of alcohol n Slurred speech patterns n Unsteadiness in walking or standing n Repeated errors or other unexplained changes in job performance such as patterns of absenteeism or lateness n Disoriented behaviour or drowsiness n Erratic or unusual behavior n Unsafe conduct. 4 Alcohol and Drug Policy

ALCOHOL AND DRUG TESTING continued In addition, testing for alcohol and/or specified drugs may be required of employees in non-safety Sensitive Positions at the discretion of Shell s Occupational Health department if the employee has been referred to Occupational Health in connection with performance issues and there are reasonable grounds to believe that the work performance of the employee is indicative of the use or after effects of alcohol or drugs, or the misuse of medications. Post Incident Testing for alcohol and specified drugs will be performed as part of an internal investigation for all employees whose acts, omissions, or decisions could have been a contributing factor in the cause of any work related incident having actual consequences with a severity rating of 4 or 5 on the Shell Canada Limited Risk Assessment Matrix ( RAM ), with respect to people, assets, environment, or reputation. 1 At Shell management discretion, as part of an internal investigation, alcohol and drug testing may be required of employees whose acts, omissions, or decisions could have been a contributing factor in the cause of any other work related incident. Testing will not be performed when there is clear evidence that the acts or omissions of employees could not have been contributing factors in causing a work related incident (e.g. structural failure from inherent defects). Reintegration Unannounced drug or alcohol testing may be performed as part of a recovery support program for any employee and will be a condition of return to or entering work in any Safety Sensitive Position following rehabilitative treatment or the admission or diagnosis of an employee s alcohol or drug dependency. Monitoring programs of this nature will be developed on a case-by-case basis by Shell s Occupational Health department. Return to Duty In circumstances of continued employment following a breach of this policy, any employee may be subject to unannounced testing as part of a return to work program, to be developed on a case-by-case basis by Shell s Occupational Health department. Procedures The following procedures will apply in all circumstances where alcohol or drug testing is required: n Employees who are required to take an alcohol or drug test will be provided with information describing the procedures and must sign forms consenting to testing, verifying samples and authorizing the report of results to a health professional designated by Shell, Shell s Occupational Health department, and/or Shell management. n Reasonable cause and post incident testing must be completed as soon as reasonably practicable once the determination has been made to test. In remote locations a collection service must be contacted as soon as possible to arrange for prompt testing. n The grounds upon which a decision to test is based must be documented by the manager or supervisor as soon as reasonably practicable once the request for testing has been submitted. n If a required alcohol test cannot be conducted within 8 hours of the initial request or a required drug test cannot be conducted within 32 hours of the initial request, the employee must be referred by the supervisor to Shell s Occupational Health department for an assessment of Fitness for Duty and the supervisor must provide their manager with written reasons as to why the tests could not be conducted. 1 The RAM can be found on ShellNet, Corporate, Corporate HSE, Corporate HSE M.S., Section IV Standards and Guidelines, 4.6 Incident Management Classification, Investigation, and Reporting Explanatory Notes - RAM - Figure 4.6.2 Alcohol and Drug Policy 5

SEARCHES Standard If there are reasonable grounds to believe that alcohol, drugs, or drug paraphernalia may be present on premises where Shell work is being conducted, or in Shell assigned vehicles, and that there has been a breach of this policy, Shell may conduct an unannounced search and seizure. Any attempt by an employee to impede or prevent a search and seizure of alcohol, drugs, or drug paraphernalia carried out pursuant to this policy will be considered a breach of this policy and may result in disciplinary action up to and including dismissal for cause. Impaired Driving Charges Any employee charged with an impaired driving offence while operating a vehicle on Shell business must immediately report the charge to their supervisor. In addition, any employee whose operator s licence is suspended as a result of the administration of a breathalyzer test for alcohol must immediately report such suspension to their supervisor if within the period of suspension they are required to drive on Shell business, operate mobile equipment in their work duties for Shell, or drive a Shell assigned vehicle. The supervisor will contact Shell s Occupational Health department for the determination of whether a Fitness for Duty assessment should be arranged. Interim Measures Provided that the employee retains a valid operator s licence, and considering the circumstances and any assessment performed by Shell s Occupational Health department, a determination will be made as to whether the employee is in need of a structured assistance program and whether the employee should be allowed to continue to operate mobile equipment or Shell assigned vehicles pending the outcome of the charge. Any safety concerns may result in medical work restrictions being issued for the employee. Convictions and Suspensions Any employee convicted of impaired driving must immediately report to their supervisor, the conviction, and any imposed suspension or limitations affecting their operator s licence, if their work duties for Shell require a valid operator s licence or the conviction resulted from a charge which occurred while operating a vehicle on Shell business or while driving a vehicle assigned by Shell. Accommodation If reasonable and possible, employees who have had their operator s licence suspended, but require a valid operator s licence to perform their job duties, may be accommodated in an alternative position until their operator s licence is restored. Any such accommodation should not be considered absolute or indefinite. If driving is an essential part of the employee s work duties and an alternative placement is not feasible, the employment contract may be treated as terminated. Failure to Report Failure to immediately report an impaired driving charge or conviction, or resulting effect upon the employee s operator s licence, as required herein, may result in discipline up to and including dismissal for cause. 6 Alcohol and Drug Policy

Contractor Compliance Standard A contractor s preparation for managing risks with respect to the use by workers of drugs, alcohol, or medications that could affect the performance of the contracted work must be addressed prior to Shell retaining the services of the contractor. Contractors Obligations At a minimum, Shell contractors performing work equivalent to that performed in Safety Sensitive Positions must have rules to prohibit, and procedures to deal with, the use (and after effects) of alcohol and illegal drugs and the misuse (and potential disabling effects) of medications by their employees and sub-contractors while on duty. Additional measures, comparable to those provided for herein, may be required of contractors in certain circumstances. All contractor obligations in this respect must be clearly set out in the written agreement between the contractor and Shell. Responsibility for Implementation Shell s Role Shell will provide appropriate assistance to employees with alcohol or drug problems and/or dependencies through its Occupational Health/Employee Assistance Program ( EAP ) in a manner that places priority on confidentiality, fairness, and respect for the individual. Shell s Occupational Health department will: n Create an awareness of the problems and safety risks associated with alcohol and drug use and the performance disabling effects of medications by making available appropriate educational materials, including those addressing EAP accessibility. n Provide training and guidance to managers and supervisors in recognizing and dealing with alcohol or drug related performance problems. n Consult on the application of and decisions to conduct alcohol and drug tests. n Arrange for the performance of Fitness for Duty assessments as required pursuant to this policy. Employees Responsibilities The responsibility of each Shell employee is to: n Be personally responsible for compliance with this policy and for their personal safety in this respect. n Assume ownership of any alcohol or drug problem and/or dependency by seeking professional assistance and making full use of the counseling and treatment services made available by Shell or through Shell s arrangements with outside sources. n Cooperate fully during investigations of work related incidents. n Comply with any treatment or rehabilitation program aimed at improving job performance, eliminating safety risks, or reintegration into the Shell workforce. n Notify their supervisor if aware that another Shell employee s use of alcohol or illegal drugs or misuse of medications presents a safety or security risk. n Use prescribed and over-the-counter medications responsibly and manage potential impairment during work hours due to the legitimate use of medications. Alcohol and Drug Policy 7

Responsibility for Implementation continued n If in a Safety Sensitive Position, obtain advice from a physician as to whether any prescribed medication will affect their ability to safely perform their job duties, and report any concerns in this respect to their supervisor or Shell s Occupational Health department to assist with decisions regarding modification of duties or temporary re-assignment. n Require that responsibilities be assigned to another Shell employee if under the influence of alcohol or drugs or the performance disabling effects of medications when asked to report for duty in a Safety Sensitive Position. n Report to their supervisor any impaired driving charge, conviction, or suspension of operator s licence in accordance with the requirements of this policy. Responsibilities of Supervisors and Managers The responsibility of each Shell manager and supervisor is to: n Ensure that this policy is communicated to Shell employees who report to them and the principles of this policy are addressed with contractors working within their area of responsibility. n Identify and monitor employee behaviour and performance problems that may be linked to the use of alcohol or drugs or the misuse of medications and notify Shell s Occupational Health department when there is a drug or alcohol related personnel concern or if aware of an employee s limited ability to perform their duties due to the use of medications. n Ensure that an employee is removed from the workplace and that Shell s Occupational Health department has arranged a Fitness for Duty assessment if there are concerns about the employee s immediate ability to safely perform assigned duties without limitations due to the use or after-effects of alcohol, drugs, or medications. n Ensure that investigations of work related incidents are carried out in accordance with corporate incident investigative procedures in Shell s Health, Safety and Environment Management System Standard 4.6, including the referral of employees for drug and alcohol tests when required pursuant to this policy. n Assist Shell s Occupational Health department with the periodic verification of an employee s compliance with a reintegration or return to work program. n Ensure that Safety Sensitive Positions are identified within the business unit for which they are responsible and that Certification for employees occupying, entering, or re-entering into Safety Sensitive Positions has been performed in accordance with the requirements of this policy. n Ensure that testing for alcohol and/or drugs is performed when there are reasonable grounds to believe that the conduct of an employee while on duty (including meals and other breaks) in a Safety Sensitive Position is indicative of the use or after effects of alcohol or drugs. n Ensure that sufficient contact information respecting facilities that can perform drug and alcohol testing and Fitness for Duty assessments is readily available at field locations within their area of responsibility. n Notify Shell s security department if they reasonably suspect the presence of unauthorized alcohol, drugs, or drug paraphernalia on premises where Shell work is being conducted or in Shell assigned vehicles. Consequences of Non-Compliance Failure to comply with any of the above listed responsibilities by an employee, supervisor, or manager may result in disciplinary action up to and including dismissal for cause. 2012/10 8 Alcohol and Drug Policy