Guzil NatGas Ltd.

HEALTH, SAFETY AND ENVIRONMENT (HSE) POLICY

REF: GIL – HSE-O1

Updated 02 October 2019

1. STATEMENT OF POLICY

GUZIL (Guz International Limited), subsidiaries and affiliates (GUZIL FORTE) adopt a proactive safety culture, that protects the health of all employees and other person who may be affected and the environment in which operations are carried out. GUZIL (Guz International Limited), subsidiaries and affiliates (GUZIL FORTE) are each referred hereinafter as “Company”. The policy statements are:

  1. All employees of COMPANY should comply with the Health, Safety, Environment and Policies, and adopt same as an integral part of the employees’ way of life.
  2. The COMPANY’S Health, Safety, and Environment Policies be open and applicable to All employees, clients, suppliers and others who may have some of association with the company, which shall provide training to all employees to enable them to protect their health, to work safely and to protect the environment.
  3. It is the policy of the company that working safely and protecting the environment is a condition of employment.
  4. It is the responsibility of everyone to ensure compliance with the company’s Health, Safety Environment procedures, and to conduct himself in a manner that protects himself, the environment and all others who may be affected by his actions.
  5. Clients, suppliers and third-party personnel working on our work sites or facilities are required to conduct themselves in a manner which complies with the company’s HSE Policy.
  6. We will help the employees to care for their own health. In addition to regular health advice, the medical support provided may include vaccinations and physical check-ups. However, the ultimate responsibility for personnel health lies with each employee.
  7. The company will review the policies and procedures on Health, Safety, Environment whenever necessary.
  8. The ultimate responsibility for Health, Safety, Environment in the company rests with the Chief Executive Officer of COMPANY

GUIDELINES FOR HEALTH, SAFETY, AND ENVIRONMENT PRACTICES (REF:GIL-HSE-04)

GUZIL LIMITED (hereinafter called Company) performing work as Service Provider to an Employer (Say oil and/or Gas Company) (hereinafter called ‘Client’) shall unless a different action, rule or standard that provides a higher degree of safety of environmental protection is required by any law, decree, administrative rule or regulation, or other legally binding policy, interpretation or pronouncement of a domestic or foreign legal jurisdiction or authority, shall apply, the requirements of the following guidelines.

As used in these Guidelines, the term “applicable laws and regulations”. Shall mean all Acts, statutes, restrictions, requirements, rules, regulations and laws imposed by governmental bodies or agencies having jurisdiction over this Contract, its performance, or the activities GUZIL or its Subcontractors thereunder, governing safety, occupational health or environmental protection as the same may be from time to time enacted, passed, issued or enforced, and any licensing or permitting requirements with respect or work of any type covered by this Contract, including all amendments and revisions thereof. The term “applicable safety and environmental standards” shall mean these Guide lines and all other requirements, precautions, procedures, and accepted industry practices regarding safety, occupational health or environmental protection whether required by COMPANY, by the provision of this Contract, or any other agreement between COMPANY and CLIENT.

2.A RESPONSIBILITY FOR COMPLIANCE

  1. COMPANY shall ensure that all of the COMPANY employees are made aware of the content of these Guidelines prior to beginning work. COMPANY shall be responsible for ensuring compliance with these Guidelines during the performance of work for CLIENT.
  2. CLIENT shall have the right to stop work under this contract at any time if the work procedure or work environment is identified by CLIENT as imminently hazardous to persons, property or the environment, or is in violation of any applicable laws and regulations or any applicable safety and environmental standards
  3. COMPANY shall provide its subcontractors, if any, with copies of and shall required and ensure their compliance with these Guidelines. All agreements between COMPANY and Subcontractors, if any, shall incorporate these Guidelines.
  4. COMPANY shall provide CLIENT with the name of COMPANY’S representative who shall have responsibility for safety, environmental protection, and enforcement of these Guidelines at each work site.

2.B ENTRANCE TO WORKSITE

  1. CLIENT shall designate the entrance area and/or parking facilities, if any, to be used by COMPANY/CONTRACTOR and its subcontractors, and the employees and agents of each CONTRACTOR, all Subcontractors and their employees and agents shall use only such entrance area and/or parking facilities as are designated by CLIENT for their use.
  2. OMPANY shall ensure that only those persons having authorized business in connection with the contract are allowed on the work site.

2.C TRAFFIC AND VEHICLES

  1. All traffic on CLIENT property shall observe safety signs, and the posted speed limit, or if not posted, a reasonable, safe speed in light of existing conditions.
  2. COMPANY shall ensure that operators of all vehicles, vessels and equipment are properly licensed and/or certified.

2.D SMOKING

  1. CLIENT shall have the right to order persons observed smoking in unauthorized areas to cease, and to remove such persons from CLIENT’S premises if deemed appropriate.
  2. COMPANY shall enforce and report to CLIENT representative all violations of Smoking restriction by COMPANY’S and Subcontractor’s employees.

2.E MATCHES AND LIGHTERS

  1. a. ‘Strike anywhere’ matches and plastic disposable lighters shall not be carried or used in those areas designated by CLIENT as hazardous or which area an unreasonable risk of combustion or ignition of flammable or explosive substances are stored and/or used. CLIENT’s facility of work site rules, if any, shall govern in case of conflict.

2.F WORK PERMITS

  1. Hot Work Permit
    Without first obtaining from CLIENT its written authorization for use of a valid ‘Hot Work’ permit, and without complying with all provision of the permit, COMPANY shall nether commence nor allow to be commenced any work on CLIENT premises that could introduce to a Class 1, Division 1 or Division 2, area as defined by APIRP 500 (including tank dike area) burning, welding, or heating, the use of torches, low heat devices such as fire pots and salamanders, or open flame of any kind, or the use of ramset guns, motor vehicles, or any unclassified electrical equipment.
  2. Confined Space Entry Permit
    Without complying with all provisions of a valid ‘Confined Space Entry’ permit. COMPANY shall nether commence nor allow to be commenced any work which involve entry of persons into confined spaces such as (but not limited to) limited access tanks or vessels, open-top spaces (pits, vaults, valve boxes, etc.) More that 4 feet (11.2 meters) deep, utility tunnels and pipelines, COMPANY shall obtain a written authorization for CLIENT before implementing a confined space entry producer on CLIENT’S premises.
  3. Lockout/Tagout
    Where there is possibility of injury to persons or damage to property if certain machinery were to start inadvertently or move while being worked on, COMPANY shall not commence or allow to be commenced and work on such equipment or machinery without first ensuring that a total energy deactivation system (lockout/ tagout) is in use with respect to the equipment of machinery during such work COMPANY shall obtain a written authorization from CLIENT before implementing a lockout/tagout procedure on CLIENT before implementing a lockout/tagout procedure on CLIENT’S premises.

2.G PRESSURE TESTING

  1. COMPANY shall not test piping or vessel using compressed air, gas, or service fluid without prior written authorization from CLIENT.

2.H EQUIPMENT

  1. Unless directly associated with COMPANY, COMPANY shall neither operate equipment nor open or close any valves, switches, or electric circuits on CLIENT’S premises without written CLIENT authorization.

2.I EXPLOSIVES

  1. Prior to the submission to CLIENT of written procedures for COMPANY’S safe and secure storage, handling and use of explosives, COMPANY shall ensure that all Subcontractors and agents and employees of COMPANY and sub-contractors storing, handling or using of explosives are qualified for the type of work being done. COMPANY shall ensure compliance with the written procedures, all applicable laws and regulations, and all applicable safety and environmental standards regarding the storage, handling, and use of explosives.

2.J FIRE PROTECTION EMERGENCY EVACUATION

  1. Paper, rags, trash and other combustible materials shall be properly disposed of, in safe containers.
  2. Flammable liquids, including but not limited to gasoline, kerosene, fuel oil, LPG, etc shall be transported and stored in industry approved metal containers designed specifically for handling these liquids and meeting the requirements of NFPA 30 or other similar authority and all applicable laws and regulations regarding the use, transportation and storage of flammable liquids. Flammable Liquids shall not be stored near possible sources of heat ignition, combustion, or Explosion hazards.
  3. Fire protection and detection equipment shall not be deactivated bypassed, Altered tampered with or rendered inaccessible or inoperable.
  4. Hydrants or main water valves shall not be opened or closed except in the case of emergency or properly scheduled tests.
  5. The finding of a leak or indication of a release of gas or any other flammable Substances shall be reported at once to CLIENT’s representative. All ‘Hot work’ in the area shall cease immediately on the discovery of such a hazard.
  6. Only non-chlorinated, non-toxic cleaning solvents that have a high flesh point exceeding 130 degrees Fahrenheit (54 degrees Celsius) TCC may be used for cleaning purposes, All solvents, fuels and other chemicals supplied by or used by COMPANY or any subcontractors shall be accompanied by the manufacturers detailed and most current Material Safety Data sheet (or comparable document) satisfactory to CLIENT. COMPANY is responsible for ensuring that all provisions of such Material Safety Data Sheets pertaining to safety. Occupational health, and environmental protection are properly followed at all times.
  7. Notwithstanding CLIENT’S responsibility to notify COMPANY of known or reasonably expected hazards in work areas on CLIENT’S premises to which COMPANY employees may be exposed, COMPANY shall be responsible for the safety (including fire protection), occupational health and environmental training of its employees. This training should include (but not be limited to): a disclosure of hazards and potentially dangerous conditions and materials in the workplace, proper notification and response procedures in the event of accidents, injuries, spills, or other emergencies: and an orientation to CLIENT’s applicable safety and environmental standards.
  8. COMPANY shall shut down all internal combustion engines before they are refueled, except where the fueling point is sufficiently remote from the engine to allow safe refueling in accordance with all applicable laws and regulations and all applicable safety and environmental standards.
  9. In case of fire, personnel in the area of the fire shall:
    • Immediately take all possible measures to firstly protect the safety of personnel.
    • If possible, without creating an unreasonable risk of harm to themselves or to others, make reasonable and practical efforts, where appropriate to immediately extinguish the fire or limit the source of fuel to the fire.
    • Clear access routes to the fire and Shut down and remove equipment in the fire area.
    • Clear all travel and access routes in and around the work area, at all times

2.K MEDICAL AID

  1. Unless otherwise agreed to in writing by CLIENT, COMPANY shall provide at sole risk, cost and expense, own first aid personnel, equipment and supplies which satisfy all applicable laws and regulations and all applicable safety and environmental standards.

2.L PERSONAL PROTECTIVE EQUIPMENT

  1. Appropriate personal protective equipment shall be worn by all personnel of COMPANY and Subcontractor on the job sites in accordance with all applicable laws and regulations and all applicable safety and environmental standards COMPANY shall pay for and provide such equipment unless otherwise agreed by COMPANY and CLIENT in writing.
  2. Appropriate Personal protection Equipment includes (but not limited to):
    • Safety shoes meeting AMSI Standard Z41 or comparable specifications shall be worn at all field or yard work sites other than in offices or similar environments.
    • Non-metallic safety hard hats meeting ANSI Standard Z891. 1 or comparable specifications shall be worn while performing work that poses a recognized or reasonably anticipated hazard to the head.
    • Appropriate eye protection meeting ANSI Standard Z87.1 or comparable specification shall be worn while performing work that poses a recognized reasonably anticipated hazard to the eyes, such as (but not limited to) : Grinding, buffing, hammering, chipping, wire brushing, welding, or handling chemicals.
    • Hearing protection shall be worn in all recognized or designated high noise level areas.
    • When handling chemicals, chemical gloves and goggles face shields, and other appropriate personal protection equipment recommended by the chemical manufacturer’s current Material Safety Data Sheet (or comparable document) shall be worn.
    • Appropriate respiratory protection apparatus shall be worn whenever it is necessary to enter or work in an atmosphere known or suspected to contain harmful concentrations of gas, vapor, dust, or other inhalable substances or when there is an oxygen deficiency (Oxygen concentration is less than 19.5%), or where required by applicable laws and regulations or applicable safety and environmental standards shall be worn:
      1. When working at over-water locations without suitable protection such as a handrail enclosure on all sides.
      2. When transferring to and from any watercraft.
      3. When below the main deck of an offshore structure.
      4. When over-water emergency drills are held.

2.M HOUSE KEEPING

  1. Good housekeeping shall be maintained at all times. All walking and working areas shall be kept clean and free from obstructions.
  2. Access to emergency exists shall be kept clear at all times.
  3. All ditches holes. Excavations, overhead work etc, shall be properly barricaded and where necessary provided with warning lights.

2.N ACCIDENT REPORTING

  1. COMPANY assumes the responsibility of promptly and accurately reporting in writing all on-the-job accidents, injuries, spills, and accidental releases to CLIENT within 24 hours of their occurrence, and to the proper government authorities.
  2. Serious incidents as listed below shall be verbally reported immediately to the CLIENT representative and confirmed in writing by COMPANY within 24 hours of their occurrence:
    1. All fires regardless of size or damage;
    2. All incidents that result in COMPANY or Subcontractor employee or agent fatalities or multiple hospitalization (for purposes other than observation);
    3. All occupational injuries to COMPANY or subcontractor employees or agents involving dismemberment, loss of limb or expected to disable the employee for more than 72 hours
    4. Property damage exceeding the equivalent of NGN 500,000;
    5. All spills or accidental releases of oil fuel, chemicals saltwater, natural gas, or other hazardous substances, or any other materials which when released are required to be reported to governmental authorities under applicable laws and regulations.
    COMPANY shall maintain and file incident/accident records required by CLIENT or in accordance with applicable laws and regulations.
    1. Copies of all governmental safety occupational health or environmental citations against COMPANY or its Subcontractor while performing under this contract shall be sent to CLIENT within 24 hours following the issuance of each citation COMPANY shall immediately act to remedy all situations and circumstances that gave rise to such citations, and shall notify CLIENT in writing when the remedy is complete.
    2. A summary report of all incidents affecting safety, occupational health and environmental matters shall be submitted quarterly in writing by COMPANY.