Global Health & Safety Policy and Management Standards February 2009 Introduction Jones Lang LaSalle is dedicated to avoiding accidents, injuries and work-related illnesses in the properties we occupy and operate. To achieve this target, a series of policies and standards have been adopted that define a framework for the management of health and safety. The model for our health and safety management system is based on the internationally recognized OHSAS 18001 Standard and the Plan-Do-Check-Act methodology. Scope and application This Global Policy, and the supporting Health and Safety Management Standards, apply to the following business units/ divisions within Jones Lang LaSalle: Integrated Facilities Management Property Management Asset Management Consequently, this Global Policy and the supporting Health and Safety Management Standards apply to all activities, in all regions and countries where these business units/divisions operate. Management commitment The Global Executive Committee sets the values and beliefs for the firm. We are therefore committed at the highest levels to providing a safe and healthy working environment as it relates to our operational activities. Each employee and contractor also has a defined role to help us achieve this commitment. We are therefore committed to: Seeking to achieve zero harm to people through our business activities Promoting a culture in which each employee acts proactively to improve the safety, health and well-being of all colleagues, clients, contractors and partners Complying with occupational health and safety obligations that relate to our operations Complying with clients health and safety policies and programs that apply to our services Seeking continuous improvement to our safety, health and well-being performance Maintaining a culture that encourages the reporting, analysis and effective management of health and safety issues Additional business units/divisions within Jones Lang LaSalle may adopt this Policy and supporting Management Standards subject to their own appropriate executive/senior management endorsement and implementation strategies. Each global and regional leadership committee, as affected by this Policy, will evaluate and ultimately approve the recommendations of the Global Health and Safety Board.
Systems and processes To achieve these commitments we will develop, implement and maintain health and safety management systems and processes that enable us to: Set, achieve and report against objectives to demonstrate continual performance improvement Identify, assess and manage hazards, impacts and risks from our activities Deploy people who have knowledge and understanding of health and safety issues. Review the health and safety implications of our activities Learn and benefit from our experiences and the experiences of others. in compliance with the client s health and safety policies and procedures, in addition to the Jones Lang LaSalle national and regional health and safety policies and procedures. As a minimum these Standards will be applied. Jones Lang LaSalle will perform its work in accordance with relevant health and safety laws and regulations for the country and location in which the activities are occurring. Where occupational injuries and incidents are required to be reported, they must be reported using both Jones Lang LaSalle and client systems/processes, where applicable. Approach This commitment creates the cornerstone of our Health and Safety Program. The program creates the overarching principles and standards by which our global occupational health and safety activities are managed. The effectiveness of the health and safety program is reliant on individuals at the property level for ensuring that all relevant health and safety issues are identified and satisfactorily managed. It is the responsibility of every employee to adhere to this Policy in the performance of their operational activities. Governance The Global Health and Safety Board will review annual health and safety program reports from regional management and approve changes to our Health and Safety Program objectives, policies and governance. Acknowledging the diversity of the regions and businesses we operate in, the program requires that each region and business unit/ division establishes policies, procedures and tools necessary to comply with this Policy and Management Standards (see Figure 1). The Global Health and Safety Board creates and monitors: Health and Safety Strategy Health and Safety Policy Health and Safety Management Standards and Metrics Jones Lang LaSalle provides varying services to customers with specific work hazards and their own health and safety policies and procedures. Jones Lang LaSalle client teams must be Where material changes are made to existing global policies or procedures, or when new global policies and procedures are developed, the Global Health and Safety Board will seek Figure 1 Vision Global Requirements Global H&S Policy Global H&S Management Standards Business Unite Designed and Managed Regional and National Policies, Procedures and Tools Client-specific Health and Safety Requirements
endorsement of these by the Regional Business Unit/Division Heads. Consequently, each global and regional leadership committee, as affected by this Policy, will evaluate and ultimately approve the recommendations of the Global Health and Safety Board. Regional Business Unit/Division Heads are responsible for: Ensuring regional and national health and safety policies and procedures, consistent with the Global Health and Safety Policy and Management Standards are implemented Monitoring, evaluating and reporting the region s health and safety performance Ensuring emergency response planning is integral to business operations Health and Safety Management Standards Our Health and Safety Management Standards (hereafter referred to as these Standards ) form the basis for the development and application of relevant health and safety management systems. Definitions The definitions set out in OHSAS 18001 Occupational Health and Safety Management Systems Specification have been used in this document. Application These Standards interpret and support the Health and Safety Policy and apply, wherever practicable, to all activities, in all regions and countries where the affected business units/divisions operate. Scope The scope of these Standards covers operational aspects and activities that have the potential to affect health and safety either positively or negatively. To the extent of Jones Lang LaSalle s contractual responsibilities, the objectives of these Standards are to: a) Support the implementation of a Health and Safety Policy. b) Provide a risk-based health and safety management system framework, consistent with OHSAS 18001, or equivalent regional standards (see Figure 2). c) Progressively develop and implement health and safety management systems across the business units/divisions d) Provide criteria towards which health and safety management efforts across the business units/divisions can be targeted. e) Drive continual improvement towards leading industry practice.
Figure 2 H&S Management Standards OHSAS 18001 Model Elements 1. Leadership and 2. Legal and Client Requirements 3. Risk Management 4. Objectives and Performance Management 5. Awareness, Training and Competence 6. Health and Well-being 7. Communication, Consultation and Participation 8. Document and Data Control 9. Design, Engineering and Commissioning 10. Operations and Maintenance 11. Contractors, Suppliers and Partners 12. Incident Reporting and Investigation 13. Emergency Preparedess and Response 14. Monitoring and Review Policy Planning Implementation and operation Checking, corrective action and review Continuous improvement The remainder of this section contains the health and safety commitments identified by each of the 14 Health and Safety Management Standards. Standard 1 Leadership and Standard 2 - Legal and Client Requirements Standard 3 - Risk Management Standard 4 - Objectives and Performance Management Standard 5 - Awareness, Training and Competence Standard 6 - Health and Well-being Standard 7 - Communication, Consultation and Participation Standard 8 - Document and Data Control Standard 9 - Design, Engineering and Commissioning Standard 10 - Operations and Maintenance Standard 11 - Contractors, Suppliers and Partners Standard 12 - Incident Reporting and Investigation Standard 13 - Emergency Preparedness and Response Standard 14 - Monitoring and Review Standard 1 Leadership and Management and employees will promote our goal of zero harm through the adoption of the following performance requirements. 1. Regional Business Unit/Division Heads will direct and instruct alignment with these Standards from all regions and relevant business divisions 2. Business divisions and regional executives have the responsibility for the implementation of health and safety processes relevant to their business 3. Managers will promote a culture which encourages and recognizes behavior consistent with the corporate Health and Safety Policy and Management Standards, as well as regional, national, and client-specific health and safety policies and requirements. Managers will have procedures in place to advise employees of expected health and safety behaviors and consequences of inappropriate conduct 4. Health and safety data will be reported in a timely manner 5. Managers are responsible for incorporating Jones Lang LaSalle, client and contractual responsibilities into service delivery models 6. Employees are empowered to stop work in situations that may cause harm, and to immediately bring these situations to the attention of those at imminent risk and to management 7. Resources (e.g. human, financial or technical) will be made available and deployed to support the achievement of the Health and Safety Policy objectives
Standard 2 - Legal and Client Requirements The affected business unit/divisions, management and each employee will perform their work in accordance with relevant laws and regulations related to the health and safety requirements for the country and location in which they are working. 1. Business units/divisions are empowered to seek support from competent resources, where necessary, for the identification, interpretation and application of relevant legal, regulatory and client requirements 2. Legal and client requirements will be supported through the implementation of programs or procedures that encourage communication of specific requirements and evaluation 3. As a minimum these Standards will be applied. Where clients have alternative policies and requirements Jones Lang LaSalle has the flexibility to adopt these following review and agreement Standard 3 - Risk Management The identification, assessment and appropriate management of health and safety hazards will be performed. 1. Health and safety policies and procedures will guide the development of processes for the identification of foreseeable hazards, the assessment of risks and the implementation of control measures to ensure risks are managed 2. Site-specific risk assessments will be conducted, documented where necessary, and management processes developed appropriate to the nature of the work 3. The management of workplace health and safety risks will follow the standard hierarchy of control matrix (see Figure 3) 4. Risk assessments should be reviewed and updated periodically 5. Management will ensure that the results of the risk assessment process are communicated to employees and other appropriate parties Figure 3 Risk Management: Heirarchy of Control Preferred Order of Control (most effective to least effective) 1. Elimination (e.g., look to avoid, or prevent, the risk altogether) 2. Substitution (e.g., change the way the work is done, taking care not to introduce new risks) 3. Isolation (e.g., combat risks at the source and prevent access to the hazard) 4. Reduction / Engineering Controls (e.g., reduce the number of employees at risk to reduce the extent of exposure) 5. Information / Administrative Controls (e.g., written procedures, safe systems of work, training and supervision) 6. Personal Protective Equipment (e.g., eye protection, breathing apparatus should only be used as the last resort)
Standard 4 - Objectives and Performance Management Health and safety will form an integral part of each business unit s business plan. Health and safety objectives will be set to improve performance. 1. Business units will establish health and safety objectives and goals appropriate to the services provided. Objectives will be quantifiable, measured and tracked 2. The normal business planning and review process will incorporate health and safety as an integral component 3. Data related to the following items will be accurately captured by each assignment and transmitted to the regional health and safety data management system (database and/or individual), in accordance with the reporting format established by the respective region a. Number of employee fatalities occurring as a result of a work-related incident, illness or injury b. Number of contractor or vendor employee fatalities occurring as a result of work-related incident, illness or injury while performing work under contract, or management, by Jones Lang LaSalle c. Number of employee injury or illness cases involving medical attention in excess of first-aid (per OSHA definition) d. Number of cases where employee work-related injury or illness involved lost time from work and the amount of actual days lost for each of these cases e. Number of cases where employee work-related injury or illness involved restrictions to work and the amount of actual days on restricted duty for each of these cases f. Estimated total hours worked for Jones Lang LaSalle employees g. Number of occupational health and safety legislative breaches that involve formal notification Standard 5 - Awareness, Training and Competence Employees and contractors will be alerted to relevant health and safety requirements, hazards, risks and controls. 1. The knowledge, skills and experience of employees and contractors to perform their activities safely will be taken into consideration in their selection and appointment 2. To the extent of Jones Lang LaSalle s contractual and legal responsibilities, employees and other relevant workers acting on behalf of the firm will receive relevant health and safety induction and, where considered necessary, further training 3. Training needs, including refresher training, will be identified and delivered to support adequate levels of competency. Training records for employees will be maintained 4. Training programs will consider the cultural and educational diversity of employees, varying levels of responsibility, ability and workplace risk 5. Training programs will be periodically reviewed to ensure they remain relevant and appropriate to the nature and extent of the associated risks Standard 6 - Health and Well-being Health hazards associated with the firm s activities or workplaces will be evaluated and appropriate controls implemented. 1. Occupational health and hygiene and the working environment will be considered in the planning and scheduling of employees to perform their required tasks 2. Prevalence of work-related injury and illness will be assessed and reviewed where necessary, using data available from a range of sources including incident reports 3. The management of workplace health and hygiene risks will follow the standard hierarchy of control matrix (see Figure 3)
Standard 7 - Communication, Consultation and Participation Health and safety communication will be maintained with relevant individuals and groups associated with the firm s activities. Key parties will be encouraged to participate in, and contribute to, the continual improvement in health and safety. 1. The communication and participation in health and safety improvements will be an interactive process allowing for two-way dialogue. It will involve all appropriate parties (e.g. client representatives, contractors or regulatory authorities) 2. Processes will be developed and maintained to allow for the communication of health and safety information. The processes will include sharing of lessons learned, good practices and improvement opportunities. The processes will also strive to achieve the sharing of information across business divisions/units within the firm Standard 8 - Document and Data Control All relevant health and safety information will be reasonably identifiable and available. 1. Processes will ensure that relevant health and safety information and data are available, maintained and periodically reviewed for adequacy, format and accuracy 2. Processes will be designed so that accurate health and safety records can be established and maintained 3. Health and safety documents and records will be stored and retained in accordance with legal requirements and/or knowledge preservation 4. Health and safety documents and records will be periodically reviewed 5. Obsolete documents and data will be periodically removed or, otherwise, identified and protected from unintended use 6. Confidential records will be maintained securely Standard 9 - Design, Engineering and Commissioning To the extent of Jones Lang LaSalle s responsibilities the management of health and safety risks will be considered as an objective of all projects/activities. 1. Management processes will promote the adoption of suitable health and safety risk assessment strategies as part of project programs 2. The design and selection of new plant, equipment and processes, that Jones Lang LaSalle can control or influence, will take into account health and safety requirements 3. To the extent of Jones Lang LaSalle s responsibilities, where specialist services are engaged, health and safety criteria will comply with legislation, relevant industry codes and standards 4. Commissioning and operating will, where necessary, incorporate health and safety risk management and ensure conformity to required mandatory standards and regulations
Standard 10 - Operations and Maintenance Appropriate control measures will be established for the effective management of hazards and risks arising from operational and maintenance activities, and building or facilities management. 1. Plant and equipment will be operated, maintained, inspected and tested using processes and procedures that adequately address health and safety risks. 2. Control measures will be consistent with the nature and extent of the associated risks. The control measures may include documented systems and procedures and will, where practicable, be implemented following the principles of the hierarchy of control (see Figure 3). 3. Where available, design data and operating limits will be reviewed throughout the life of the building, plant or equipment. 4. Employees will be made aware of the controls, operational parameters and procedures, and if appropriate, maintenance requirements that are in place to manage safety risks. 5. Programs will be established and documented to ensure the on-going integrity of managed buildings/sites, work equipment and protective systems and devices. For example, the programs may include maintenance, inspection, testing, calibration and certification at intervals determined by the level and nature of the risk, statutory or manufacturers requirements. Standard 11 - Contractors, Suppliers and Partners Management of health and safety risk will be one objective when contracting services, purchasing, hiring or leasing of equipment and materials, and conducting activities with business partners. 1. Contracts and service agreements will include appropriate health and safety obligations specifically requiring contractors to effectively manage their health and safety risks and ensure compliance with relevant health and safety legislation, and any Jones Lang LaSalle or client specific requirements 2. Reporting relationships, lines of communication, accountabilities and interfaces for health and safety responsibilities will be established between contractors, suppliers, partners and Jones Lang LaSalle 3. As part of each site managements broader contractor management system, processes will be put in place with the objective of maintaining acceptable health and safety performance of contractors, suppliers and partners 4. Prior to purchase, hire or lease, the health and safety specifications of equipment or materials that have potential health and safety impacts will be considered for the intended use and to limit the potential introduction of significant health and safety risks Standard 12 - Incident Reporting and Investigation All reportable health and safety incidents will be documented and depending upon their severity may be investigated. Corrective and preventative actions will be taken and the learnings shared where relevant and practical. 1. Processes will be in place for the timely reporting, reasonable investigation, mitigation and appropriate communication of all reportable health and safety incidents 2. Incident investigation processes will include the identification of significant factors and underlying causes that contributed to the incident, the controls that were intended to prevent it and analysis of any failures in the controls
3. Incident investigations will aim to manage the risk and recurrence of incidents in accordance with the hierarchy of controls. Processes will be in place to ensure that recommended changes are communicated, followed up and completed 4. In the event of a significant incident, control systems will be reassessed before work resumes and reasonable actions taken to reduce the risk of recurrence 5. Information gathered from incident investigations will be used to identify lessons, discover trends and improve standards, systems and practices. Significant learnings will be shared with others as appropriate Standard 13 - Emergency Preparedness and Response Processes will be developed and implemented to protect the health and safety of people in emergency situations. 1. Plans that define responses (including the mitigation of health and safety impacts) to foreseeable emergency scenarios will be developed and communicated. The plans will clarify roles and responsibilities. Such plans will be developed in consideration of client arrangements and other relevant parties or building occupiers 2. To the extent of Jones Lang LaSalle s responsibilities, resources (including equipment and warning devices) provided for emergency response and ongoing recovery activities, will be maintained in accordance with the relevant standards 3. Training will be provided in emergency response plans relevant to the workplace, including roles and responsibilities 4. To the extent of Jones Lang LaSalle s responsibilities, emergency response drills and exercises will be scheduled and conducted regularly 5. Learnings from emergency response drills, exercises and incidents will be incorporated into plans and resources, and shared with relevant parties as appropriate 6. Emergency response plans will be reviewed periodically and updated as appropriate Standard 14 - Monitoring and Review Health and safety performance and these Standards will be monitored and reviewed to identify trends, measure progress and strive for continual improvement. 1. Health and safety performance and compliance with the firm s Health and Safety Policy and Management Standards will be monitored, recorded and analyzed 2. Health and safety reviews will be conducted as necessary 3. Findings from health and safety reviews will be reported to key parties as appropriate 4. An appropriate management plan will be established and reviewed for non-conformances identified during health and safety reviews 5. The Health and Safety Policy and these Standards will be reviewed at least every three years and revised as required
Date Revision Remarks Status Approved 2007-08-31 1.0 Initial issuance from Global H&S Board Draft D. Wigley 2008-04-10 1.1 Minor, non-material, amendments made Draft D. Wigley 2008-05-05 1.2 Revisions based on regional consultations Draft D. Wigley 2008-08-07 1.3 Revisions based of US Legal Counsel input Draft D. Wigley 2008-08-07 1.4 Revisions based of AP Legal Counsel input Draft D. Wigley 2008-08-13 1.5 Minor amendments after AP EHS review Draft D. Wigley 2009-02-19 1.6 Final approved version Final D. Wigley Approved: Dominic Wigley 19th February 2009 Chair, Global Health and Safety Board, IFM Date