Attachment 4.2 - Company HSE Policy Documents

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HDD THAILAND–ENIKKOM LIMITED

COMPANY HSE POLICY

Document Revision Status


Revision Date Designation Originator Reviewer Approver
R0 11th July 2023 Issued for Information J.P. Okoye Chukwudi U. E.I. Amene

This document contains proprietary information and may not be partly or wholly reproduced without prior written
permission from HDDTHAILAND-ENIKKOM LIMITED
COMPANY HSE POLICIES

TABLE OF CONTENT

1. Community Affairs, Safety, Health, Environment and Security (CASHES) Policy


2. Occupational Health Policy Statement
3. Health Policy Statement
4. Environmental Policy Statement
5. Security Policy Statement
6. Quality, Health, Safety, and Environment Policy Statement
7. Personnel Empowerment, Commitment and Responsibilities Policy Statement
8. Drug and Alcohol Policy Statement
9. Testing For “Cause” Policy Statement
10. Challenge to Fitness Policy Statement
11. Firearm and Search Policy statement
12. Surveillances / Audit Policy Statement
13. Disciplinary Action Policy Statement
14. Smoking Policy Statement
15. Personnel Protective Equipment (PPE) Policy
16. Journey Management & safe Driving / Sailing Policy Statements
17. Seat Belt and Life Vest Policy Statement
18. Speed Limit Policy Statement
19. Night Driving / Night Sailing Policy Statement
20. Waste Management Policy Statement
21. Information Security Policy Statement
22. Community Relation Policy
23. HEALTH SAFETY AND ENVIRONMENT POLICY

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COMPANY HSE POLICIES

Community Affairs, Safety, Health, Environment And Security (CASHES) Policy


Statement
Community Affairs, Safety, Health, Environment And Security (CASHES) Policy
Statement
ECL/HDDTEC Policy has been planned to conform with the law and regulations of the
FEDERIAL REPUBLIC OF NIGERIA AND INTERNATIONAL STANDARDS, to meet the
COMMUNITY AFFAIRS, SAFETY, HEALTH, ENVIRONMENT AND SECURITY requirements
of all its project / clients. To give clear guidance towards safeguarding the Health,
Safety and Security of all its employees, the clients company and sub-contractor
personnel in all its operations.

THIS CASHES POLICY SHALL BE APPLIED TO:


• Give accountability and respect for environmental concerns and all applicable
legislations as well as the maintenance of good relationships with the Principal
Host Communities.
• Set objectives and target; measure, appraise and publicly report HSE
performance
• Include HSE performance in the appraisal of all employees and reward
accordingly
• Create a culture in which ECL/HDDTEC and contractor employees share our
commitment to HSE at work and home
• Play a leading role in promoting best HSE practice within the business
community of the world.
• Reduce potential long-term liabilities and achieve efficient use of materials and
energy
• Empower employees to start work ONLY when conditions are safe and to stop
work when it is unsafe

IMPLEMENTATION OF THE CASHES POLICY MEANS:


• Management of the Company accepts the responsibility for providing resources
and guidance for the development and implementation of the CASHES Programs.
• CASHES Awareness is a personal responsibility of all Company employees.
• Maximization of Loss Prevention or loss arising from accidents and the
preservation of the integrity and security of ENIKKOM CONSTRUCTION LIMITED
and Client assets.

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COMPANY HSE POLICIES

• Hazards associated with project activities are identified and safety measures to
eliminate these hazards and/or reduce inherent risk to ALARP level, are
implemented.
• The CASHES implementation is made an inseparable part of the overall business
management targets of the Company.
• Achieve unperturbed platform for training of personnel for continuous HSE
performance improvement in line with Corporate Company and Project goals.
• Environmental pollution is minimized / eliminated during ECL/HDDTEC
operations.
• Continuously assess and abate the health, social and economic impact of all
business activities and take needed preventive or mitigating measures.
• Establish and maintain close relationships with all segments of the local
population to better understand their concerns, needs and aspirations and to
ensure harmony peaceful co-existence.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

OCCUPATIONAL HEALTH AND SAFETY POLICY

The Occupational Health and Safety (OHS) Policy supports HDDTEC's Mission, Vision
and Values Statement. It demonstrates our commitment to having zero incidents and
to eliminating injuries, dangerous occurrences and ill health in all our operations.
To achieve this, we will:
• Make OHS the highest priority for all of our operations
• Make senior management accountable for company OHS performance,
ensuring they demonstrate leadership in this area by leading by example in all
their duties, at all times
• Implement safe systems of work to reduce risks
• Provide suitable facilities, plant and equipment, and maintain them in a safe
and secure condition to protect the employees and people who will use them
• Provide suitable and sufficient training for all employees and selected
contractors, as appropriate
• Maintain a transparent reporting system that allows the analysis of incidents,
potential incidents, and unsafe acts and conditions
• Provide an open communications channel, encouraging employees to
participate in OHS and actively look for improvements to eliminate risks
• Set objectives and targets for the continuous improvement of OHS
• Maintain OHS standards that meet legal and other requirements, always
aiming for industrial best practice

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

HEALTH POLICY STATEMENTS

ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM LIMITED attaches


greatest importance to the prevention of any loss, in particular to the health and
safety of all employees and public at large. This policy is formulated to ensure that all
its operations and activities are planned and executed in a manner, which safeguards
the Health of all Company employees, Client companies and Sub-Contractor
personnel.

ECL /HDDTEC is committed to achieving the highest level of HEALTH policy


performance through:

• Managers, Supervisors and Employees taking responsibility for Health and


Welfare within their respective areas.
• Line Management and staff openly committing themselves to active
participation in the implementation of this policy.
• Management consider no area of its operation or administration as being of
greater importance than the “Health Incident “prevention.
• The attitude and co-operation of each employee ensures that healthy
conditions are achieved and losses minimized.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

ENVIRONMENTAL PROTECTION POLICY

It is ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM LIMITED Policy to:


• Carry out environmental impact assessment and environmental evaluation
reviews in relation to all aspects of the natural and social environment that may
affect, or be affected by its activities.
• Enhance positive effects and prevent intolerable impacts from occurring, thereby,
limit the nature and extent of any residual negative impacts, however caused,
such that they are as low as practicable.
• Manage all wastes generated in our operations as well as spillage / discharges,
sewage and chemicals in a responsible manner and with due regard to applicable
Environmental Statutory Laws and the Client’s / companies’ requirements.
• Leave the environment at the end of the useful life of any operation in a condition
suitable for future use.
• Routinely monitor the environment status of each operation and take corrective
action as necessary.

Every employee shall be encouraged to perform his/her work in an environmentally


friendly manner in order to preserve air, water, soil, plant and animal lives.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

SECURITY POLICY

The Management of ECL/HDDTEC is committed to the security of its personnel and


properties. The damage or loss of any material, equipment and possible breakdown
of law and order has a great impact on costs to the Client and Contractor.

ECL/HDDTEC shall identify, evaluate and manage the risk to personnel arising from
malicious practices, crime, civil disorder or armed conflict.

THIS POLICY IMPLIES THAT:

• In the unforeseen occurrence of violence or threats to life and property we would


expect the forces of law and order of the state to give us appropriate protection.
The right to use force rests with the state. In pursuance of the mission and
objectives of the security management system, line management will draw on the
services of ECL/HDDTEC Security Department and, through the Nigerian Police
Force and other Nigerian Security Organizations as required subject to conditions
(ii) and (iii) below.

• ECL will not operate in an environment where the continuous deployment of


military or Para-military forces is required to comply with the above policy, except
where deployment is at the instance of Government for protection of key national
facilities.

• Where the lives of personnel are at risk, ECL/HDDTEC recognizes that the
deployment of military or Para-military forces by the government, in support of
the police and civil authorities, may be necessary for as long as is required to
restore law and order, if protection cannot be achieved by other means

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

Quality, Health, Safety and Environment (QHSE) Policy Statement

Management of ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM


LIMITED recognizes that its employee is the most valued assets. It is the outmost
commitment of ECL/HDDTEC to provide and maintain a safe working environment for
its employees. All activities must be planned and executed in such a way that will
minimize adverse effects on the environment.
IT IS THE POLICY OF THE COMPANY TO:
• Operate a Management System which satisfies ISO 9001:2015(QMS)
Specifications;
• Fully satisfy applicable statutory requirements and the agreed requirements of its
clients.
• Empower and encourage staff at all levels to take personal responsibility for and
take a leadership role in HSE issues relevant to their professional work, their
environment, and our host communities.
• Seek to meet, exceed or develop some or all of the concerns of others relevant to
our operations;
• Perform work safely, high level health & safety performance being an integral part
of business performance;
• Continually improve the Company’s reputation;
• Continually improve environmental performance;
• Set and publish objectives;
• Maximize long-term profits.
• Ensure no work MUST START unless considered SAFE and must be SUSPENDED
when there is every reason to believe that essential Safety Systems are not in
place or available HSE Systems are not being followed.
The Company undertakes to provide appropriate resources to enable
implementation of this policy. All company staff and line management must openly
commit themselves to active participation in the implementation and realization of
this policy in all Company operations.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

PERSONNEL EMPOWERMENT, COMMITMENT AND RESPONSIBILITIES POLICY:

Management of ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM


LIMITED is wholly committed to the protection of its resources, employees and
physical assets, against human distress and financial loss resulting from accidental
occurrences. ECL/HDDTEC recognizes that the success of any company-wide
endeavor is largely dependent upon the involvement of the entire workforce.

IN FULFILLING THIS COMMITMENT:

• All ECL/HDDTEC and Sub-Contractor employees are required to plan and to


perform their work safely in accordance with this Policy.

• This Policy must be communicated openly and at every opportunity to Clients,


Vendors and Sub -Contractors in their business with ECL/HDDTEC

• It is binding on all employees, Vendors, Subcontractors and Clients to abide by,


operate within, and adhere to, the Company CASHES Programs and to be
committed to the implementation /realization of project CASHES goals.

In the performance of all ECL/HDDTEC Project activities, the Health, Safety and
Security of the people involved, and the protection of Assets / the Local Environment
as well as securing harmonious relationship with Host Communities shall remain the
primary concern for ENIKKOM CONSTRUCTION CONSTRUCTIION LIMITED.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

DRUG AND ALCOHOL, POLICY

ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM LIMITED is dedicated


to maintaining a safe work environment and seeks to protect its employees from
unsafe conditions. Being under the influence of a drug or alcohol on the job poses
serious safety and health risks not only to the user but to all those who work with the
user. The possession or use of an illegal drug or alcohol in the work place also poses
unacceptable risks for safe, healthful and efficient operations. In addition, the
possession, use or sale of illegal drugs is a criminal offence and cannot be tolerated.
ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM LIMITED Drug
&Alcohol Policy strictly prohibits:
Possession, use or sale of illegal drug in any of its project location.
Any of its employee to be at work whilst impaired by drugs or alcohol
Any of its employees to possess, use, distribute or sell alcohol or illegal drugs,
intoxicating beverages and/or controlled substances on Company business or work
locations.
Controlled substances are any illegal drugs or prescription drugs not obtained by a
valid prescription. Illegal drugs will not be allowed anywhere on land, in buildings,
structures, installations, vehicles, aircraft, or watercraft owned, leased or used by
ECL/HDDTEC.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

TESTING FOR “CAUSE”, POLICY

This policy is to provide a safe work environment and empower a Manager or


Supervisor in charge of ECL project to request for a “cause testing” to be conducted
on any employee involved in a significant accident or incident or who may have
contributed to that accident or incident.

Significant may include (but not be limited to): vehicle accidents, injuries treated by a
medical practitioner, property damage or reportable (to legislative bodies) near
misses.

Refusal by employee to submit to, or cooperate with the administration of a testing


for cause, should be treated in the same manner as any other refusal / violation to
comply with ENIKKOM CONSTRUCTION LIMITED policies.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

CHALLENGE TO FITNESS POLICY

The identification of persons affected by alcohol and/or other substances is a


complex process, a challenge “as to fitness to perform duties safely” shall be made in
any of the company project site where a fellow employee, supervisor or manager,
suspects a person is not fit to perform his duties because of alcohol and/or other
substance induced impairment.

If any employee is of the opinion that any person is affected by alcohol and/or other
drugs then they should notify their supervisor immediately.

ECL/HDDTEC designated person who approach workers shall be properly trained in


substance abuse identification and the use of the most effective style of
identification.

The company managers and supervisors not trained in this area shall seek expert
assistance.

In pursuance of this policy, the company will continue to respect the right of
individuals and will minimize intrusion into the private lives of its employee.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

FIREARM AND SEARCH POLICY

ENIKKOM CONSTRUCTION LIMITED recognizes the existence of security threats


arising from lawlessness and civil unrest and therefore is committed to ensuring a
safe and secure working environment for all operations carried out in the its projects.

This document therefore covers all activities, subcontractors, projects, groups and
individual within the Facility on a round-the-clock basis.
The subcontractor shall ensure that all tools and materials are kept under lock and
key. ENIKKOM CONSTRUCTION is not responsible for the loss of the subcontractor’s
equipment as a result of any act of omission, notwithstanding cause arising.
Crimes and related incidents which occur on site must immediately be reported to
the security department for further investigation.
To enforce this Policy, the Company reserves the right to inspect any personnel,
place or thing on all its premises and intends to exercise that right without prior
announcement other than this Policy Statement.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

SURVEILLANCES / AUDITS POLICY

ENIKKOM CONSTRUCTION LIMITED is committed to ensuring that regular Health,


Safety, & Environment surveillances / audits are carried out in all its project areas
where personnel are engaged in project construction activities and ensure
compliance with the legal, client company and project requirements.

IN FULFILLING THIS COMMITMENT:


Site Management will conduct Management Monthly HES&S Audit; Reports should
be forwarded to the HSE&S department no later than 4th of the following month.

Check reports for action items that require immediate attention. Ensure that all
unsafe conditions are attended to immediately and signed off by responsible
person(s).
If unsafe acts are committed the ECL/HDDTEC disciplinary code system will apply. All
reports shall be tabled at the monthly HES Committee Meeting.

All reports will be filed for inspection purposes.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

DISCIPLINARY ACTION POLICY

ENIKKOM CONSTRUCTION management has the responsibility to provide a safe


working environment for all employees and to protect the company from avoidable
expense in order that it can continue to offer the job security consistent with market
conditions.

To enfore this policy, ECL/HDDTEC management reserves the right to opt for prompt,
decisive and remedial action against those whose actions detracts from a safe
working environment. Such actions, depending on the circumstances, could
appropriately range from oral admonition to termination.
The latter is appropriate when an individual has demonstrated through flagrant
disregard for the rights of others that his or her continued employment would
constitute a threat to the well being of fellow employees.
Although each case should and will be decided on its own merits, to preclude
injustice, appreciable consistency is necessary. Due to the wider dispersal of
company operations and decentralized management, appreciable consistency shall
be achieved through the use of same guidelines throughout the organisation.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

SMOKING POLICY

ENIKKOM CONSTRUCTION LIMITED policy on smoking has been formulated to


safeguard the Health of all its employees, our client’s company and contractor
personnel in all its operations.
Employees have the duty to take reasonable care and be responsibility for their own
Health and safety and the safety of other workers who may be affected by their
activity.

All company contractors, vendors, clients and subcontractors are required to comply
with this policy.

In pursuit of this policy ECL/HDDTEC;

• Recognized smoking as being injurious to health and is actively discouraged in


all its project
.
• Smoking of cigarettes, cigars, or pipes are strictly prohibited in Company
project site client project site and facilities, and other designated no-smoking
areas, which includes, public areas, and Company restaurants, but is not
limited to offices.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

PERSONAL PROTECTIVE EQUIPMENT (PPE) POLICY

ENIKKOM CONSTRUCTION LIMITED Policy is to provide and ensure the use of


relevant high quality Personal Protective Equipment (PPE) in the proper attitude for
the right job.
This policy is planned to ensure adequate protective measures are established to
protect employees from recognzed hazards in work places. The provisions of this
policy apply to all ECL/HDDTEC project site where hazards are present or likely to be
present that would necessaitate the use of PPE.

The policy is applicabe to all employees including clients, vendors, and contractor
empolyees who work with or whose job responsibility require them to be familiar
with the content of this policy.

Work Supervisors shall ensure that recommended protective equipment for any
activity to be carried out within its project area or potentially hazardous activities
outskirts of ECL/HDDTEC facilities by Company employees, Client company’s or
Subcontractor personnel shall only be authorised with a SAFE WORK PERMIT
completed and necessary protective equipment for the specified activities inspected.
Toolbox or other communication meetings shall be held between supervisors,
workforce and Subcontractors to identify appropriate tools, hazards and their
barriers before embarking on any job.
Management shall enforce the effective use and maintenance of the PPE, which also
entails regular condition audits and replacement of any defective ones.

Continual compliance to this Policy shall be monitored and any violations shall
attract disciplinary action.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

JOURNEY MANAGEMENT & SAFE DRIVING /SAILING POLICY STATEMENTS

Management of the ENIKKOM CONSTRUCTION LIMITED shall implement this policy


and support initiatives, which further enhance performance in all its operations.
• ECL/HDDTEC as activity owner for Logistics Operations shall maintain Company
standard for land; water and air transport, and provide guidance on their
implementation.
• All ECL/HDDTEC staff and contractors shall ensure that, Transport activities are
managed as an integrated part of day-to-day activities and within a framework of
controls that varies compliance with company standards.
• All forms of land, marine, air transport, and materials handling equipment are
registered and inspected by ECL/HDDTEC prior to being used on company
business and thereafter on periodic basis.
• ECL/HDDTEC and Contract Personnel that are authorized to operate all forms of
land, marine, air transport, and materials handling equipment are registered and
accredited by ECL/HDDTEC.
• Personnel at all levels shall be inducted on programs and other initiatives aimed
to raise the awareness of Operations to the full range of transportation hazards
that exist and how they may be controlled using approached such as Journey
Management.
• All ECL/HDDTEC drivers / boat captain shall possess valid Nigerian license for the
class of vehicle/boat he intends to drive, and shall have been subjected to Porto
clinic glare tests to check blurred visions.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

SEAT BELT /LIFE VEST POLICY

This policy demands strict compliance; any violation and/or alteration shall be dealt
with according to the ENIKKOM CONSTRUCTION LIMITED Disciplinary Procedure.

The driver or operator of any vehicle or craft is responsible for enforcing the use of
seat belts or life vest as the case may be. The vehicle or craft SHALL REMAIN
STATIONARY until the driver and his passengers have fastened their seat belts.

Wearing of seat belts shall be mandatory for the driver and passengers in moving
vehicles used on ECL/HDDTEC operations. It is equally obligatory that life vest be
used in all Air and Water borne operations relevant to the Company and its projects.

Security personnel at the gates shall check the use of seat belts, stop and report any
driver or occupants of the vehicle not wearing seat belts. On same note, Logistics
Officers shall brief all passengers travelling crafts on mandatory safety standards for
journeys and shall enforce compliance prior to craft movement.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

SPEED LIMIT POLICY

All ECL/HDDTEC company drivers and other company personnel who drive must
ensure that their vehicles are well equipped to conform to National Safety
Regulations and that speed limits are known and followed.

All drivers on the project shall strictly adhere to the following speed limits:

Express Way - 100km/hr


Major Roads - 80km/hr
Side Roads - 60km/h
Project Area / site posted speed limit

During adverse weather conditions such as during periods of heavy rain, speed shall
be reduced accordingly as dictated by the prevailing conditions.

Offenders may be required to attend a further defensive driving course or may be


dismissed from the project. Remember: You could lose your life trying to get there 5
minutes earlier with increased speed.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

Night Driving /Night Sailing Policy

This policy implies that operations must be planned and carried out under safe
conditions. Management shall continually implement measures aimed to curb
excessive exposure of personnel to transport hazards.

It is the policy of ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM


LIMITED to prohibit all night driving or night sailing in all its land and sea/water
operations. However, exceptions are allowed, but strictly for life threatening
emergency or medical evacuation (MEDEVAC) circumstances only.

Night Sailing is prohibited in ECL/HDDTEC sea/water operations from the hours of


1800hrs to 0600hrs.
It should be clear to all drivers, and boat operators, that authorization for Night
Driving or Night Sailing must come from the Responsible project /Line Management
Representative only.
Night security patrols on land where necessary are excluded from this Policy.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

WASTE MANAGEMENT POLICY

ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM LIMITED is committed


to safeguarding public health and protecting the physical environment of Nigeria. In
line with this, ECL/HDDTEC shall:
• Take all practical and reasonable measures to minimize the generation of solid
and liquid waste, and other waste.
• ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM LIMITED will be
guided by the principles of Reduce, Reuse, Recycle and Recovery, in the
management of waste.
• Manage and dispose of such wastes in a statutory and environmentally
responsible manner
• Track and maintain records of the full life cycle of waste streams and provide
an auditable trail as to its management and disposal.
• Abide by all Environmental Regulations ISO 45001 (EMS) and shall strive to
reduce environmental degradation and encourage pollution prevention in our
operation wherever possible.
Awareness programs shall be initiated and our staff and subcontractors at all project
locations shall be cultured and made to direct their practices away from every form
of environmental unfriendliness.
Compliance with this policy and efficiency shall be monitored stringently and
continuously.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

INFORMATION SECURITY POLICY

It is the policy of ENIKKOM CONSTRUCTION LIMITED that all information used and
generated in carrying out business activities, shall be managed as a corporate asset
and is safeguarded accordingly so as to stimulate continuous business improvement
and innovation;
Information security and access rights shall be defined and documented. Data
Custodians and asset holders shall enforce information security standards, ensure
the integrity of data within their area of responsibility and comply with all statutory
requirements for code of Practice for Information Security Management.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

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COMPANY HSE POLICIES

COMMUNITY RELATION POLICY


ENIKKOM CONSTRUCTION LIMITED recognizes that impacts on both neighboring
residents, businesses and the broader Community will arise during project execution
and regards managing environmental and community issues as integral components
of its business.
This policy is designed to anticipate, understand and respond more efficiently to
community relations issues by implementing communications processes that will
adapt to changing needs.

This policy is to provide framework to move towards establishing collaborative


relationships with the community and stakeholders. Collaboration typically involves
sharing information, arriving at a common definition of a problem or opportunity,
committing to working together, and suspending preconceptions to find and
implement new solutions.
Community Objective
To facilitate delivery of project on time and within budget by integrating community
relations into all facets of the project. This will be achieved by:
Community Interaction – interacting with community in a way that is, and is seen to
be, accessible, transparent and responsive.
Company Approach – demonstrably treating the community with sensitivity and
respect in relation to its issues, views and suggestions.
Mutual Trust and Respect – achieving a level of mutual trust and respect that leads
to problem-solving and solutions which improve the overall project.
Shared Recognition – achieving shared community recognition of the ENIKKOM
CONSTRUCTION best practice performance in project delivery.
Management Systems – using innovative, people-focused management systems to
achieve the above

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

25
COMPANY HSE POLICIES

HEALTH SAFETY AND ENVIRONMENT POLICY

The Management of ENIKKOM CONSTRUCTION LIMITED / HDDTHAILAND ENIKKOM


LIMITED is committed to occupational, health, safety and protection of the
environment, for both, employee and work locations, and ultimately achieve the goal
of preventing all accidents and injuries.

ECL/HDDTEC corporate management considers HSE to be the primary duty of an


employer.

This HSE Corporate Policy is to clearly and concisely communicate ECL/HDDTEC


Corporate Management commitment to HSE to all ENIKKOM CONSTRUCTION
personnel, subcontractors and vendors.

The company Corporate Management recognizes its responsibility for creating and
sustaining a culture that supports the implementation of high standards of HSE. And
therefore, provides the necessary leadership and commitment to ensure that the
necessary resources to develop, operate and maintain the HSE Management
Program and to achieve the HSE Corporate Policy and objectives are available.

The Policy also provides the basis for establishing the HSE Objectives which set the
limits within which ECL/HDDTEC shall operate and the basis for the establishment of
departmental and project plans and objectives.

The HSE Corporate Policy and objectives are communicated to all employees through
Corporate Management messages, newsletters, awareness programs and
campaigns, and training.

EDDY AMENE
(Managing Director)
ENIKKOM CONSTRUCTION LIMITED/HDDTHAILAND ENIKKOM LIMITED
August, 2022

26

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