MARINE & OFFSHORE HSSE MANAGEMENT SYSTEM

SCOPE AND ENFORCEMENT

This procedure aims to set in place the Marine & Offshore HSSE Management System in order M&O be compliant with Recognised Organisation (RO) Group HSSE certifications against ISO 14001:2015 Environmental Management System and ISO 45001:2018 Occupational Health & Safety Management System standards.

Health, Safety, Security and Environment Management System within Recognised Organisation (RO) M&O includes the services indicated below;

• Classification of ships, offshore units and marine & offshore equipment,

• Conformity assessment of marine & offshore equipment,

• In-Service surveys and verifications,

• R&D, Consulting and HSE Management,

• Project & Asset Integrity Management,

• Certification, Training,

• Risk and Safety Assessments.

REFERENCES

External documents referred in this document are indicated below;

• ISO 45001:2018 Occupational Health and Safety Management System – Requirements,

• ISO 14001:2015 Environmental Management System – Requirements with guidance for use,

• IMO RO Code.

TERMS AND DEFINITIONS

HSSE Management System

Health, Safety, Security and Environment Management System

Occupational Health and Safety

Conditions and factors that affect, or could affect, the health and safety of employees or other workers, visitors, or any other person in the workplace.

Environment

Surroundings in which Recognised Organisation (RO) performs its activities including air, water, land, natural resources, flora, fauna, humans and their interrelationships.

Workplace

Place under the control of Recognised Organisation (RO) where a person needs to be or to go for work purposes. Recognised Organisation (RO)’s responsibilities under HSSE management system for the workplace depend on the degree of control over the workplace.

Categories of Employees

Operational Staff

Operational staff are field surveyors/auditors/inspectors for job on client’s site.

Administrative Staff

• Managerial and Support functions managers (Top Management, Directors, Head of Sections, MOs,ITs etc.)

• Technical staff (Plan approval, R&D, DEV etc.)

Continual Improvement

Recurring process of enhancing the HSSE management system in order to achieve improvements in overall HSSE performance consistent with the M&O HSSE Policy.

Injury and Ill Health

Identifiable, adverse effect on the physical, mental or cognitive condition of a person arising from and/or made worse by a work activity and/ or work related situation.

Note 1: These adverse effects include occupational disease, illness and death.

Note 2: The term “injury and ill health” implies the presence of injury or ill health, either on their own or in combination.

Incident

Work related event in which an injury or ill health (regardless of severity) or fatality occurred or could have occurred.

Note 1: An accident is an incident which has given rise to injury, ill health or fatality.

Note 2: An incident where no injury, ill health or fatality occurs but has the potential to do so may also be referred to as a “near hit”.

Note 3: An emergency situation is a particular type of incident.

Hazard

Source, situation or act with a potential for harm in terms of human injury or ill health or a combination of these.

Environmental Aspects

Element of Recognised Organisation (RO)’s activities or products or services that interacts or can interact with the environment.

Environmental Impact

Change to the environment, whether adverse or beneficial, wholly or partially resulting from Recognised Organisation (RO)’s environmental aspects.

Risk

Effect of uncertainty (i.e. deficiency of information related to, understanding or knowledge of, an event, its consequence, or likelihood).

HSSE Risk

Combination of the likelihood of an occurrence of a work-related hazardous event or exposure and the severity of injury or ill health that can be caused by the event or exposure.

HSSE Opportunity

Circumstance or set of circumstances that can lead to improvement of HSSE performance.

Risk Assessment

Process of evaluating the risk(s) arising from a hazard(s), taking into account the adequacy of any existing controls and deciding whether or not the risk(s) is acceptable.

Audits, Site Inspections and Safety Walks

Audits

An audit is a systematic independent and documented process for assessing compliance with a standard, obtaining evidence and evaluating it objectively to determine the extent to which requirements are fulfilled.

External audits are carried out by bodies the aim of which is to grant a license to operate (certification, accreditation).

Internal audits may be performed by several interested parties within Recognised Organisation (RO) Group, M&O management, Local Management.

Site Inspections

Site inspections are carried on client’s site like shipyard, manufacturer, terminal, port,. The aim of site inspection is to assess the HSSE environment where Recognised Organisation (RO) staff perform M&O services.

Following activities are also considered as site inspections as they are way to assess how employees and sites where they operate are compliant with safety and work environment conditions requirements: activity monitoring, vertical contract audits (VCA).

An M&O specific guidance details how site inspections should be managed (Annex A2, see attached file). A specific checklist is used for this purpose.

Safety Walk Field

A Safety Walk Field is a visit to Recognised Organisation (RO) site/client site by the Local Manager or the HSSE Manager together with the Recognised Organisation (RO) staff in order to assess the HSSE performance of them against Recognised Organisation (RO) HSSE rule requirements.

Activity monitorings, vertical contract audits (VCA) also include the assessment of surveyor/auditor performance, hence can be done jointly with Safety Walk Field checklist, where specific criteria for assessment for HSSE are explicitly identified.

An M&O specific guidance details how Safety Walk - Field should be managed (Annex A2, see attached file). A specific checklist is used for this purpose.

Safety Walk Office

A Safety Walk Office is a tour/visit within a Recognised Organisation (RO) Office performed by the Local Manager or the HSSE Leader and focused on Safety aspects of work environment, work place.

A M&O specific guidance details how Safety Walk - Office should be managed (Annex A2, see attached file). A specific checklist is used for this purpose.

Subcontractors/ Service Suppliers

A subcontractor is an external provider, an entity which performs for Recognised Organisation (RO) part of the services that Recognised Organisation (RO) has contracted to perform with its client. When performing this part, the employee of this subcontractor acts on behalf of the company he belongs to; he appears to the client as an employee of that company; he is duly trained, qualified, authorized and directly controlled by that company; he follows the methodology of this company and issues deliverables of that company (ref: Group QHSSE 011-PO External Workers -Vendors Suppliers, Subcontractors, Non-Exclusives and Temporary Workers (Annex A1, see attached file), M&O the related management procedure procedure).

A subcontractor is a person working for an external company which has signed a contract for specific tasks in Recognised Organisation (RO) offices (maintenance of the building, printers, housekeepers...) to provide services to Recognised Organisation (RO) and to which Recognised Organisation (RO) policies, procedures and requirements apply too. A subcontractor is under Recognised Organisation (RO) responsibility so if an incident occurs it shall be reported.

Refer to Recognised Organisation (RO) Group HSSE Requirements Handbook for subcontractors and non-exclusives (Annex A1, see attached file).

Note: Non-exclusive surveyors are not considered as service suppliers. For this category of person, refer to Group QHSSE 011-PO External Workers -Vendors Suppliers, Subcontractors, Non-Exclusives and Temporary Workers (Annex A1, see attached file) and M&O the related management procedure procedure.

Performance

Measurable Result

Participation

Involvement in decision-making including engaging health and safety committees and workers’ representatives, where they exist.

Consultation

Seeking views before making a decision including engaging health and safety committees and workers’ representatives, where they exist.

Life cycle

Consecutive and interlinked stages of a product (or service) system, from raw material acquisition or generation from natural resources to final disposal.

Prevention of Pollution

Use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts.

CONTEXT OF ORGANIZATION

Understanding the organization and its context

Recognised Organisation (RO) M&O Internal Issues and External Issues that are relevant to its purpose and that affect its ability to achieve the intended outcome(s) of its HSSE Management System include but not limited to the below indicated table and the changes thereof;

These identifications are reviewed at the annual management review meetings.

Understanding the needs and expectations of interested parties

At Head Office Level

The Recognised Organisation (RO) M&O’s key stakeholders include;

• Employees, exclusive and non-exclusive ones, at HO and within M&O entities, operating countries and M&O subsidiaries who all are direct internal stakeholders,

• Shareholders who are indirect internal stakeholders as Recognised Organisation (RO) Group employees,

• Clients, suppliers, subcontractors, certification bodies and all national authorities who are direct external shareholders,

• Civil society in a broad sense as indirect external stakeholders as Recognised Organisation (RO) M&O provides services with a positive impact on health & safety, safety at sea and prevention of maritime pollution as well as protection of society and the environment.

More information is available in the ‘Recognised Organisation (RO) Registration Document’ published by Recognised Organisation (RO) Group on a yearly basis on the website, section ‘stakeholders’, relationships between Recognised Organisation (RO) and its stakeholders

The below template should be contemplated also with its homologue one regarding Quality and which is set in procedure M&O the related general procedure.

At local level

Based on the template set in section 4.2.1, local M&O offices must determine the interested parties that are relevant locally to this management system in order to take into account local specificities.

Once determined, their relevant needs and expectations may be identified to select the ones that will become compliance obligations.

List of interested parties are reviewed at the time of the management review.

Determining the scope of HSSE Management System

Recognised Organisation (RO) M&O’s HSSE Management System scope is determined by taking into account internal and external issues, relevant parties and expectations, compliance obligations, activities, products and services.

The scope of application of this procedure covers the whole M&O Division portfolio of services.

This procedure applies to ALL M&O employees (full time, exclusive or non-exclusive staff, Technical, Administrative, Managerial) and to subcontractors. As such, subcontractors may use their own Safety Management System subject to compliance with Recognised Organisation (RO) requirements; they however must hold evidences of this compliance.

This procedure is compliant with the Recognised Organisation (RO) Group Health, Safety, Security & Well-being (HSW) Environmental Statements from CEO as well as the Group QHSSE Policies which are available in attached files.

Provisions related to Well-being are detailed in specific Recognised Organisation (RO) Group policies uploaded in the M&O Documentation Database as part of Recognised Organisation (RO) Corporate Social Responsibility (CSR) domain and then not of this M&O HSSE management system.

Health, Safety and Environment for M&O employees is coordinated within the Division at HO level by LC&R Department. Well-being is coordinated by HR Department.

HSSE Management System

Recognised Organisation (RO) M&O HSSE Management System has been established, implemented, maintained and the efficiency is continuously improved as shown below. (see also section 4.4 of Recognised Organisation (RO) M&O procedure).

LEADERSHIP AND WORKER PARTICIPATION

Leadership and Commitment

The organization of Recognised Organisation (RO) M&O is detailed in the procedure “Organisation & Operation of M&O Division.”

Mission is to protect Recognised Organisation (RO) employees in order they work in safe conditions to come back home safely after the performance of services. Therefore Recognised Organisation (RO) HSSE principles are as follows:

• Safety is an absolute

• Health and Safety at work is Recognised Organisation (RO) responsibility:

  • Line management is accountable for compliance

  • Each employee, sub-contractor and visitor must comply and be alert.

Priorities are:

• to ensure employees/non-exclusive and subcontractor safe behavior

• to ensure a safe workplace for all employees/non-exclusive

• to enhance management accountability

HSSE Leaders must deliver value to the business:

• setting in place key training programs on main identified risks

• developing HSSE culture with the implementation of initiatives in a consistent manner and with added value for the business to reduce all work related accidents.

The leadership at various levels is executed as detailed below;

1. The Executive Committee (EXCOM) is held at HO level on a monthly basis in order to monitor Recognised Organisation (RO) M&O operations. It is attended by M&O Top Management. EXCOM tasks are also to:

   • defining M&O strategy including HSSE,

   • ensuring that M&O HSSE policy and objectives are established and are compatible with the strategic direction defined,

   • following HSSE KPIs trends as reported by Recognised Organisation (RO) M&O Offices for all activities,

   • taking accountability for the effectiveness of the HSSE management system,

   • ensuring that statements and objectives are established and compatible with risks faced by staff and the context of the organization,

   • ensuring the integration of the HSSE management system requirements into the organization’s business processes,

   • ensuring the resources needed for the HSSE management system are available,

   • communicating the importance of effective HSSE management system and of conforming to its requirements,

   • ensuring the HSSE management system achieves its intended outcome(s),

   • ensuring and promoting continual improvement,

   • supporting persons to contribute to the effectiveness of the HSSE management system,

   • protecting employees from reprisals when reporting incidents, hazards, risks and opportunities,

   • ensuring that arrangements done for effective consultation and participation of employees in the HSSE program,

   • supporting other relevant management roles to demonstrate its leadership as it applies to its areas of responsibility,

   • ensuring the organization establishes and implements a process(es) for consultation and participation of workers,

   • supporting the establishment and functioning of health and safety committees.

   As part of the commitment for HSSE, all EXCOM meeting start with a Safety and Quality review which is documented.

2. M&O HSSE Leader Committee is held at monthly basis by the chairmanship of M&O Compliance Director and secretary and animation of M&O HSSE Manager, including Zone HSSE Leaders, assigned Regional HSSE Leaders and Recognised Organisation (RO) representative at the IACS Safety Experts Group to tackle the below tasks;

   • Direct and coordinate overall HSSE effort for each level of the organization,

   • Review all serious accident RCA and ensure appropriate corrective and preventive actions are developed,

   • Review HSSE Internal & External audits completion, non-conformances and assess the need to develop appropriate corrective and preventive actions at Division level to address properly findings,

   • Review status of on-going HSSE programs and progress to goals/targets (Safety Walk plan v.s. executed; Training plan v.s. executed),

   • Review analysis of trends for causes of First Aids, Near hit, unsafe conditions, unsafe acts reported; deficiencies identified from safety walks and inspections; and evaluate effectiveness of existing controls implemented such as programs, procedures, policies, etc.,

   • Review the implementation status of HSSE alerts and communications plan,

   • Review the deployment status of Special initiatives from Group or M&O.

3. Safety Committee is held at local level (country/region) where more than 50 employees are present or based on the local legislative requirement. The meeting must be held at periodical intervals, quarterly in minimum, to discuss upon key HSSE matters in line with Recognised Organisation (RO) Group QHSSE Priorities. The meeting shall be chaired by Country/Regional HSSE Leader and the most senior operations manager together with key QHSSE staff including the participation of employees. For roles and responsibilities of this committee, refer to Recognised Organisation (RO) Group QHSSE Priorities (Annex A1, see attached file).

4. In addition, as part of the management review process (see the related management procedure), leadership and commitment consist of:

   • a ‘bottom-up’ process: it is specified at country level, it is consolidated and may be completed at zone/region level, it is consolidated and may be completed at HO level,

   • a ’top-down’ process: once consolidated and/or completed, M&O Division management review is cascaded at zone/region/country level.

   It includes:

   • a review of the results achieved previous year,

   • a re-assessment of risks and opportunities,

   • improvement needs (system, resources, action etc.),

   • the setting of the objectives for the year to come if there are local specificities otherwise M&O division ones are the sole to be achieved.

5. Similarly as EXCOM proceeds, all management meetings should start with a HSSE moment dedicated to the subject activities and M&O staff. Agenda of these meetings should be documented.

6. Leadership and commitment are also formalized through the Recognised Organisation (RO) M&O HSSE policies set in attached files to this procedure and so communicated to all Recognised Organisation (RO) M&O employees thanks to the working process of the M&O documentation database.

HSSE Policy/ Statement

M&O Division HSSE vision is an accident free workplace, with no harm to people and continuously decreasing environmental impacts of business activities.

For Recognised Organisation (RO) M&O, safety is an absolute, a non-negotiable priority without which the business could not be sustainable. Safety and Security and Protection of M&O employees is an overriding priority of all business activities. The M&O safety culture is driven by the goal of being a zero-accident division of Recognised Organisation (RO) Group.

M&O HSSE Policy is signed by the M&O Division President for the whole scope of M&O services and by Recognised Organisation (RO) Group CEO and M&O Division President for recognized organization scope of M&O services (Annex A2, see attached files). It is established and communicated as indicated here below. It is in line with the Recognised Organisation (RO) Group CEO Health, Safety, Security and Wellbeing and Environmental Statements (Annex A1, see attached files) and any pertinent relevant statement set by the main bodies of the maritime and offshore sectors including IACS Joint Safety Statement (Annex A2, see attached file) which Recognised Organisation (RO) M&O is a co-signatory of.

Organizational roles, responsibilities and authorities

Roles and responsibilities of all personnel are defined as follows and are in line with the provisions set in procedures “Organisation & Operating of M&O Division” and PCR_001 “Organisation & responsibilities of Legal, Compliance & Risks Management (LC&R)”. M&O HSSE Executive Chart is also presented in the attachment.The entire line of management is responsible for establishing, implementing and over viewing M&O HSSE statement and requirements.

HSSE responsibilities and tasks of the entire line of management are detailed and summarized in the Recognised Organisation (RO) Group Managing Safely Booklet (Annex A1, see attached file).

Managers are committed to managing HSSE in accordance with M&O Policy and monitoring the performance of their entity with respect to its implementation. They are responsible for ensuring that adequate resources are available (human, specialized skill, infrastructure, technology, financial etc.), and that local procedure(s) is (are) documented, if needed, to ensure a safe work environment to their staff.

Managers are responsible of the safety and work conditions of:

• the employees which they are the N+1 as per the reporting line (RL) where ever these employees are located,

• the employees who are on secondment in their teams; secondment agreement should detail the related specific conditions and requirements, if any. The manager of the RL is then informed of completion of training, safety campaign and any safety event impacting his/her staff on secondment,

• non exclusives, subcontractors and interns who may be within their teams.

M&O employees shall comply with all applicable requirements which include but are not limited to Recognised Organisation (RO) Group PO/PR requirements, IACS Procedural requirements, the national laws and regulation and Clients’ requirements. They also shall adopt a Safety behaviour at all times (Group QHSSE 111–PO Behavioral safety (Annex A1, see attached file)). They are responsible of their own health and safety and of the one of others who may be affected by their acts or omissions at the workplace.

The responsibilities with respect to processes (i.e. safety, environment etc.) are identified in item 5.3.1.

The responsibilities according to roles are identified in items 5.3.2, 5.3.3 and 5.3.4.

General

Health & Safety

Health & Safety requirements are managed by and are under supervision of the M&O HSSE management at HO (LC&R_CPL Department).

Environment

M&O procedure regarding environment requirements are those issued by Recognised Organisation (RO) Group QHSSE in particular M&O entities should be guided by Group QHSSE 200-PO Eco Efficiency (Annex A1, see attached file) and the subsequent ones at local level to which M&O employees have to comply with.

All entities are committed to report in accordance with Group instructions and requirements as well as Group QHSSE 112-PO Environment (Annex A1, see attached file).

Security

The commitment of Recognised Organisation (RO) for security is based on the implementation of appropriate ways of watching, warning and responding to ensure the security of its travellers, expatriates and subcontractors (essentially abroad in high or extreme risk countries) and to protect its assets.

Priorities & objectives are to continue to focus on:

• Travellers to high or extreme risks countries,

• Expatriates,

• Facilities (offices).

The Group Security team ensures the Security watch to identify the high risk situations in order to implement with anticipation the corresponding preventive measures.

A Travel Security Officer (TSO) is nominated in each Recognised Organisation (RO) Operating Group. The M&O HSSE Manager is the M&O TSO who is member of the Group Security Team.

M&O requirements regarding the security of employees during business travel are detailed in the related health and safety procedure Travel Health & Security Procedure.

At Head Office

M&O HSSE Management (L-C&R) is responsible for documenting, implementing and maintaining the HSSE Management System to ensure the commitments made in M&O HSSE Policy are being met.

M&O HSSE Manager

The HSSE Manager reports to the LC&R_CPL Department Director.

The scope of responsibilities and activities of this manager applies to the whole M&O Division.

Relevant tasks are to:

• Proposing the M&O HSSE Policy,

• Developing, implementing and maintaining the M&O Division HSSE management system compliant with requirements to be fulfilled,

• Proposing yearly HSSE KPIs and objectives in line with Recognised Organisation (RO) Group ones and with M&O strategy, and following their achievement,

• Identifying training needs and building them,

• Supporting the M&O network,

• Review, analyze and validate serious accident reports, work related illnesses and significant incidents,

• Supervise the review, the analysis and the validation of accident reports,

• Ensuring the validation of safety incidents in Nexus,

• Building the Safety, Security and Environment review to be presented at the monthly EXCOM,

• Animating the M&O Division through the HSSE Leaders network to emphasize a HSSE culture based on the prevention of incidents and a strong and effective analysis of accidents,

• Organize and monitor HSSE campaigns,

• Chair the monthly M&O HSSE Leader Committee meetings,

• Participating to quarterly meetings organized by the Group HSSE team to evaluate M&O benchmark,

• Organizing the relevant annual management review and drafting the subject report,

• In liaison with Group define and monitor external and internal audits programmes required by the certifications granted to Recognised Organisation (RO) Group (ISO14001:2015 & ISO 45001:2018).

HO Departments’ Managers

HO Departments Managers have the same responsibilities as M&O Country managers as set in item 5.3.3.1.

In addition, they support the M&O HSSE Manager in the identification and the assessment of the risks that can be faced by the employees who perform the activities they are responsible.

Recognised Organisation (RO) Representative at the IACS Safety Experts Group

To participate in IACS Safety Expert Groups in order to;

• Develop and update relevant IACS Resolutions,

• Identify issues and propose action to IACS Expert Group,

• Conclude tasks by correspondence,

• Attend relevant periodical meetings

In Countries

M&O Country Manager and Marine Chief Executive

M&O Country Managers and Marine Chief Executives are responsible of the safety and health of their staff.They so are responsible for identifying and assessing the risks that can be faced depending on the activity their staff have to perform, the relevant environments where they act and the conditions of work.

They are responsible to ensure their staff performing field activities are medically fit by undergoing medical surveillance.

They are responsible to providing their staff the right information relative to the HSSE national legislation and regulation, and the Recognised Organisation (RO) HSSE requirements in order their employees understand and comply with these requirements.

They are responsible to set in place, when needed, the procedures and instructions in order that all HSSE requirements will be fulfilled.

They are responsible of the organization and the human resources they set in place in order to fulfil the above requirements and to achieve HSSE objectives and KPIs.

Their tasks are among others to:

• Ensuring the delivery of HSSE training to all employees including awareness sessions as part of the induction for newcomers,

• Ensuring enough personal protective equipment (PPEs) are provided to staff to protect them,against the risks they have to face during the performance of services,

• Supervising the local HSSE Leader or shoulder the relevant responsibilities if they have not nominated anybody,

• Ensuring that staff understand:

  • the HSSE organization and their specific role within the latter,

  • the local HSSE management system and their own contribution in its implementation,

  • the risks they may face when they perform services,

• Set in place, communicate and implement an emergency response procedure,

• Chair the yearly HSSE management review meeting.

Zone HSSE Leader

Zone HSSE Leader, where exists implements, maintains and continually improves (as needed) Zone HSSE system, in line with M&O Division policy.

His/her main tasks are to:

• Support the local HSSE Leaders,

• Investigate and validate all HSSE incidents in the Zone and analyze,

• Be the Zone correspondent of HO on HSSE matters (LC&R_ CPL, M&O division HSSE manager),

• Animate and monitor the HSSE matters at Zone Level,

• Animate the Zone HSSE meetings,

• Cascade the information coming from HO,

• Maintain the relationship with Local HSSE Leaders on HSSE matters,

• Supervise the implementation of the HSSE management system at Zone Level,

• Attend the monthly HSSE Leader Committee meeting chaired by HO,

Local HSSE Leader

The HSSE Leader develops, implements, maintains and continually improves (as needed) local HSSE system, local safety, health and environment policies, programs, and procedures in line with M&O Division policy.

His/her main tasks are to:

• Support the local management on HSSE matters,

• Be the local correspondent of HO on HSSE matters (LC&R_ CPL, M&O division HSSE manager),

• Animate and monitor locally the HSSE matters,

• Cascade the information coming from HO,

• Maintain the relationship with managers on HSSE matters and is their referent on these matters,

• Supervise the implementation of the HSSE management system,

• Follow the achievement of HSSE KPIs and propose relevant action plans, if needed,

• Manage personal protective equipment (PPEs) and their availability,

• In terms of trainings, identify local needs, if needed in liaison with the M&O HSSE Manager, draw the yearly HSSE program, organize its implementation, its follow-up and the subsequent records,

• Investigate and if assigned as a validator validate all HSSE incidents and analyze (Root, cause analysis, action plans) serious accidents, work related illnesses, and significant incidents,

• Attend the monthly HSSE meeting chaired by HO, if assigned as HSSE Leader Committee member,

• Contribute to the performance of all HSSE audits and ensure their closing on time,

• Review quality and effectiveness of internal HSSE audits executed,

• Organize the HSSE management review and draw the relevant report.

Local HSSE Leader are nominated by the M&O Country manager or the Marine Chief Executive in liaison with HO department (LC&R_CPL).

Note: When no local HSSE Leader is appointed, the M&O country manager is also responsible for the above.

Employees (including the Head Office)

All Recognised Organisation (RO) employees are responsible for their own personal safety and must make sure before undertaking any task that all conditions related to their safety are met and that the risk is nil according to their best judgment.

All Recognised Organisation (RO) employees are required to comply with the requirements of the HSSE management system and thus to follow the safety, health and environmental policies and procedures established by the Group & the Division as well as the local entity:

• Apply and respect safety, health and environment requirements in daily activities, including those imposed by the client in their site (if more stringent than those imposed by Recognised Organisation (RO)),

• Work in compliance with the Recognised Organisation (RO) Cardinal Safety Rules and have a safe behavior; this includes they are duly trained and qualified, attend safety programs, safety trainings, maintain their qualification and ensure that they are medically fit to perform the job they are assigned to,

• Use required personal protective equipment (PPEs) as instructed,

• Watch for potentially hazardous working conditions or work practices and report them to his/ her management as soon as possible.

Consultation and Participation of Employees

Recognised Organisation (RO) has established, implements and maintains processes for consultation and participation of workers at all applicable levels and functions, and, when it’s mandatory as per local regulations, workers’ representatives, in the development, planning, implementation, performance evaluation and actions for improvement of the HSSE management system.

All Recognised Organisation (RO) Employees are encouraged to report hazardous situations; i.e. unsafe conditions, unsafe acts, near hits so that preventive measures can be put in place and corrective action can be taken.

Also employees as worker representatives are invited to safety committee, as per item 5.1.c when it’s mandatory as per local regulations, to provide their relevant feedback.

PLANNING

Actions to address HSSE risks and opportunities

General

Recognised Organisation (RO) considers the issues referred to in 4.1 (context), the requirements referred to in 4.2 (interested parties) and 4.3 (the scope of its HSSE management system) and determine the risks and opportunities in order to achieve the intended outcome(s), prevent or reduce the undesired effects and achieve continual improvement. When determining risks and opportunities; hazards, HSSE risks and opportunities, legal and other requirements are taken into account.

Risks management is under the responsibility of LC&R at Head Office. The OG’s risks are identified according to the methodology and the frequency set in place by Recognised Organisation (RO) Group Legal & Risk team by Group QHSSE 109-PR QHSSE Risks & Opportunities (Annex A1, see attached file).

Hazard identification and assessment of risks and opportunities

LC&R-CPL Department at HO is in charge of:

• the determination and the maintenance of the M&O HSSE SWOT matrix (Annex A2, see attached file), and

• the identification of the risks and opportunities relevant to the activities carried out by the M&O division, and the measures to mitigate the identified risks. This task is performed in liaison with the HO Departments in charge of the relevant activities, documented within M&O Global Risk Assessment Matrix Baseline (Annex A2, see attached file).

Local entities must determine their own HSSE SWOT matrix and the risks matrix relevant to the services they perform. Both elements are reviewed at least once a year at the time of the management review.

Risks and Opportunities are identified as per the Group QHSSE 109-PR QHSSE Risks and Opportunities (Annex A1, see attached file).

Health and Safety risks at work (at site and in office) and measures to be taken to keep these at tolerable level in other words the rule requirements are described in M&O the related health and safety procedure Personal Safety Instructions. Please observe specific Standard Operating Procedures presented for each M&O field risk to be informed in full for the scope, the definition, the responsibilities, Do’s and Don’ts, required trainings, required PPEs and all other additional information for guidance.

The travel health and security risks and rule requirements are described in M&O the related health and safety procedure Travel Health and Security Instruction.

Environmental aspects

Entities must identify their environmental aspects and associated environmental impacts considering a life cycle perspective in normal and abnormal operating conditions including the emergency situations by covering their own personnel, suppliers and all persons visiting their premises according to Group QHSSE 109-PR QHSSE Risks and Opportunities (Annex A1, see attached file).

Determination of legal requirements and other requirements

At HO level, LC&R_CPL is in charge of the compliance of the M&O HSSE management system with the ISO certifications standard requirements, as indicated by Recognised Organisation (RO) Group (holder of the relevant certifications) and with those of the interested parties (IMO, IACS, CESNI, Flag administrations,), if any.

At local level, Recognised Organisation (RO) offices must set in place a process to identify and follow-up the local legislation, legal requirements and other requirements of the interested parties they must comply with. In case of such requirements exist, specific relevant local instructions should document the relevant processes.

When no instruction exist in M&O HSSE procedures, the Group HSSE procedures PO and PRs apply to M&O employees who have to comply with.

Where this procedure, local legislation and client requirements differ, the more stringent requirements apply and M&O employees must comply with.

Contract managers are responsible of the compliance with clients’ requirements, if any.

M&O HSSE requirements are composed of:

• Recognised Organisation (RO) Group QHSSE Manual & Statements,

• Recognised Organisation (RO) M&O HSSE Policies,

• Recognised Organisation (RO) M&O HSSE procedures and instructions,

All the documents are available in the respective sharepoint community and M&O documentation database.

HSSE Objectives and planning to achieve them

For Recognised Organisation (RO) M&O, safety is an absolute, a non-negotiable priority without which the business could not be sustainable. Safety and Security and Protection of M&O employees is an overriding priority of all business activities. The M&O safety culture is driven by the goal of being a zero-accident division of Recognised Organisation (RO) Group. Similarly for Environment, Recognised Organisation (RO) M&O stands has the one of the lowest emission values within Recognised Organisation (RO) Group entities and is committed to continual improvement of its environmental performance.

Within that frame, the M&O HSSE objectives are proposed each year by LC&R Management to M&O EXCOM. They are established taking into account:

• Recognised Organisation (RO) Group and M&O Policies,

• the objectives set at Recognised Organisation (RO) Group level,

• the level of achievement of the previously set objectives,

• the analysis of risks and opportunities.

They are communicated via the management review process in order to be then cascaded to all staff.

To achieve these objectives, LC&R_CPL Department set in place actions the efficiency of which is evaluated at least on a quarterly basis or on a more appropriate period of implementation.

SUPPORT

Resources

Managers are committed to managing HSSE in accordance with M&O Policy and monitoring the performance of their entity with respect to its implementation. They are responsible for ensuring that adequate resources are available with respect to human, natural, infrastructure, technology and financial.

Competence

At HO level, roles, responsibilities and required competences of HSSE managers are set up as per Group QHSSE 101-PO Roles & Responsibilities. The relevant generic job descriptions are used as guidance to identify potential HSSE managers within M&O.

Competences are tackled through dedicated trainings which all must be platform in Employee’s success factor. These records help to set and feed key performance indicators (KPIs) at local level as well as HO one which are used for assessing and reporting on behavioural safety (e.g. number of completed safety talks, number of supervisions conducted, number of new employees inducted, number of Stop Work Authority used).

Training is essential in the provision of safe working practices. LC&R_CPL Department is in charge of designing the HSSE Trainings matrix of all M&O staff and of supervising and/or doing the set up of relevant training materials.

At local level, each M&O Recognised Organisation (RO) Office shall develop an annual training plan based on the M&O HSSE Trainings matrix set in place by M&O HO (Annex A2, see attached file). The training plan is validated at the time of the management review meeting and is part of the relevant report.

The volume of HSSE training for each staff is defined within the annual Safety objectives.

Training needs may be identified at the time of the yearly individual appraisal.

Safety competences of all operational staff are assessed at the time of their supervision/activity monitoring.

Safety Trainings

HSE Induction for all M&O Employees

All new employees have to attend an Induction Safety module as part of the induction training organized by the HR support function.

The content of the HSSE induction is based on the M&O induction module available on Sharepoint M&O HSSE community. It should be conducted within 1 month after joining Recognised Organisation (RO) or before field assignment, whichever comes first, by the local HSSE Leader and/or M&O HSSE manager. As a minimum the content should be:

• Recognised Organisation (RO) M&O HSSE organization and objectives,

• Recognised Organisation (RO) Cardinal Safety Rules,

• 2 Minutes for My Safety,

• Unsafe Condition / Near Hit Reporting,

• Stop Work Authority

The ‘’2 minutes for my Safety’’ booklet available in this procedure and on M&O HSSE Community Sharepoint.

No employee is allowed to perform any task in a yard, a manufacturer premise or on board a ship without having completed the M&O HSE induction module.

The number of new employees who received the HSE induction shall be reported as part of the HR indicators in the Group tool.

M&O field surveyors/auditors/inspectors

M&O field surveyors/auditors/inspectors have to take and pass a specific Health & Safety induction training course as identified in M&O Basic Common and HSSE Trainings Matrix (Annex A2, see attached file). This is a requisite for any new surveyor in order to obtain a qualification.

This module can also be used for qualified surveyor as refresher course. It is available in My-Learning platform.

Health and Safety and Environment Campaign

Health and Safety and Environment campaigns (Group or M&O Division ones) are part of the annual training program for the whole M&O employees and participation is mandatory.

Previous/former campaigns can be used during safety talks/moments to focus on some specific risks but are not mandatory for new comers to attend.

These are recorded in M&O Qualif Database.

Awareness

Employees are made aware of HSSE policies and objectives, the importance of their contribution to the HSSE management system, implications and potential consequences of not conforming to HSSE management system requirements, incidents and their outcomes, hazards and risks and opportunities relevant to them and their ability to remove themselves from work situations by Stop Work Authority where needed by the aid of awareness sessions in addition to the formal trainings held.

These awareness sessions (i.e.safety tool box talks, safety moments) are held to raise awareness of the employee which must be recorded in M&O Qualif database. These records help to set and feed key performance indicators (KPIs) at local level as well as HO one which are used for assessing and reporting on behavioral safety (e.g. number of completed safety talks, number of supervisions conducted, number of new employees inducted, number of Stop Work Authority used).

Managers shall ensure that regular HSE safety toolbox talks (STBT) and field discussions (Safety moments) are conducted and documented as per Recognised Organisation (RO) M&O HSSE annual objectives.

Safety Tool Box Talks (STBT)

Management meetings/toolbox talks shall be organized as per Recognised Organisation (RO) Group requirements. STBT shall address one specific HSE topic per meeting, present applicable requirements and allow time for discussion. The minimum topics to be considered are (if applicable):

• Confined space entry,

• Safe boarding,

• Driving,

• PPE,

• Working at height.

During safety talks, it is required by M&O HSSE Management to focus on main hazards.

Field discussions (safety moments)

Field discussions (safety moments) shall address the same minimum topics than safety talks and review field applicable requirements (the “2 minutes for MY safety” can be used).

Behavioral Safety

The goal of Behavioral Safety is to make the work environment as safe as possible. Behavioral safety is the application of behavior to occupational safety. This involves a set of principles, practices, processes that are used to improve safety under management responsibility.

The main benefits are:

• to reduce number of accidents, increase safety awareness,

• to ensure consistent behavioral safety in the Group, demonstrated it to clients.

Audits, supervision, safety walks, site inspections carried out in Recognised Organisation (RO) offices or client’s sites are opportunities / activities to assess if staff behave safely, if applicable safety rules are well understood and if work conditions are compliant with requirements.

If some safety behaviors are identified as not as required, management meeting should be scheduled in order to remind those rules.

If work conditions on clients’ sites are not as required, managers should liaise with clients in order to make improve these conditions.

Safety behavior is also required during Group sponsored events and for all events organised by the M&O Division. Points of contact are the organization team and local HSE managers.

Stop Work Authority

Stop Work Authority (SWA) is one of Recognised Organisation (RO) Cardinal Safety Rules (CSR) and designed to provide employees, non-exclusives and contractors with the responsibility and obligation to stop their work when a perceived unsafe condition or behavior may result in an unwanted event / an accident.

A process to activate the SWA must be defined locally as per Group QHSSE 111-G1 Guideline for SWA (Annex A1, see attached file).

This process must cover responsibilities of management and employees, and the process steps for implementation of SWA Process. It must be clearly defined in the process for resolving the SWA is Management Responsibility. All employees and managers must be trained on SWA process.

Each employee must be made aware of this process, must know how to implement it and must be empowered by the management to use it appropriately.

Safety Stand Down

In the unfortunate case of a fatality or a serious accident (whether in M&O or in Recognised Organisation (RO) Group) Safety Stand Down may be prompted by M&O HO or Group to freeze all work and take a moment to concentrate on the safety aspects, to ensure lessons are learned to avoid recurrence and to underline that Safety is an Absolute.

Communication

Internal Communication

Communication on HSSE topics is ensured via M&O Top Management messages, e-mail alerts and regular information meetings by Recognised Organisation (RO) M&O HO LC&R_CPL Department.

Local HSSE Leaders are in charge of cascading this information in liaison with their N+1 to find the most appropriate way.

Subcontractors and interns, if any, and non-exclusive must be appropriately integrated by managers into the internal communication means.

Health and Safety Alerts

Health & Safety Alerts are issued within M&O division to inform about incidents which are related to Health or Safety, which occurred and whose information is important for M&O employees.Description of the incident, main causes, lessons learnt, action plan are summarized in such Alerts. The following Safety Alerts may be issued.

1. Group Health & Safety Alerts

   Group Health & Safety Alerts are communicated within M&O division when the nature of the incident is of some interest for M&O employees.

   There are Alerts related to Safety events and others related to Health ones.

   These alerts are communicated by LC&R_CPL email to managers and HSSE Leaders who shall communicate and discuss the information during STBT and/or Safety talks with their staff.

   All Group Safety Alerts are posted on the M&O HSSE Sharepoint community.

2. M&O Safety Alerts

   Safety Incident felt as significant and whose lessons learnt seem to be shared may also be subject to be detailed in a M&O Safety Alert.

   Any serious accident occurring within M&O Division needs to be shared with all M&O employees and are subject to be detailed in a specific M&O Safety Alert with the same topics as the Group Safety ones.

   The communication is organized like the one described in 7.4.1.1.a.

3. Local Safety Alerts

   Local lost time accidents shall be detailed in local “Safety Alerts”.

   These alerts are locally communicated with LC&R_CPL in copy. They may be distributed to the whole M&O network upon decision of LC&R_CPL.

   Their format and structure are the same as detailed in section 7.4.1.1.

M&O Safety Newsletter

A Safety Newsletter is distributed three to four times a year within M&O division in order to animate and reinforce the Safety culture within the whole M&O division with Top managers commitments and provision of information, facts, data, testimonies.

The M&O HSSE Manager is the owner of the process from the design to the distribution of this newsletter.

All M&O Safety Newsletters are posted on the M&O HSSE Sharepoint community.

HSSE Communities

HSSE Communities may be created in Sharepoint communities tool in order to share information within authorized staff.

Two such communities are managed by LC&R_CPL:

• the M&O HSSE Sharepoint community where a lot of information is shared with the whole division

• the M&O HSSE Leader community which is restricted to M&O HSSE Leaders to share the information they need.

The M&O HSSE Manager is the webmasters of these both Sharepoint communities.

External Communication

Recognised Organisation (RO) M&O External Website

The Recognised Organisation (RO) external website is managed by the HO Department in charge of the Communication. The relevant HSSE external communication is then designed in liaison with LC&R_CPL Department.

Interested Parties’ concerns

In order to ensure the robustness and the coherence of the HSSE communication to interested parties LC&R_CPL Department is the designated M&O focus point for all questions/requests coming from all interested parties.

Any meeting with stakeholders should be the opportunity to promote Recognised Organisation (RO) HSSE ambition and performance and to take their concerns into account. LC&R_CPL Department collects all information got in such meetings.

Visitors and Contractors

All M&O entities should set up their own local HSSE communication process, for visitors to the workplace and contractors.

This process is based on the identification of their compliance obligations.

Documented Information

M&O Procedures include the documented information for the effectiveness of its HSSE management system. M&O procedures are updated and/or revised if a significant change occurs.

Validation and communication are ensured according to the M&O documents management process as per the quality documentary system procedure.

OPERATION

Operational planning and control

General

Local HSSE Leaders and managers plan and control the processes needed to meet the requirements for:

• the M&O HSSE management system,

• provision of services,

• actions relevant to HSSE objectives and achievement of KPIs,

• change in management,

• eliminate the hazards and reducing the HSSE risks according to the risk hierarchy.

They shall use and implement the provisions set in M&O HSSE procedures which details safety requirements, competency ones and equipment ones.

Local HSSE Leaders and managers should inform and report to M&O HO LC&R_CPL Department (M&O HSSE manager) when operational control measures as set in HSSE procedures are not appropriate or missing.

Where a new activity is on design, change management process should be applied including HSSE matters to ensure this service will be carried out in safe conditions and to mitigate its environmental impact.

This task is in hands of the HSSE Leaders at local level or in those of any competent staff designated by LC&R_CPL Department at HO level.

The M&O HSSE manager should be solicited when a new production tool is on design at HO level in order to integrate the safety process. HSSE Coordinators have this role when such tool is locally designed.

Eliminating hazards and reducing HSE risks

HSE risks as defined globally in M&O Global Risk Assessment Matrix Baseline (Annex A2, see attached file) and then more specifically in Local entity’s risk matrix (as indicated in item 6.1.2) shall be managed in a process in line with hierarchy of controls for HSE risks, as follows;

• eliminate hazard,

• substitute with less hazardous processes, operations, materials or equipment,

• use engineering controls and reorganization of work,

• use administrative controls, including training,

• use adequate personal protective equipment.

Using of PPE (as included in our Cardinal Safety Rules) shall be strictly followed, but it shall not be taken as a protection barrier in a hazardous environment and hierarchy of controls shall be implemented from top to bottom as far as practicable.

Management of Change

Change process should be driven, managed and followed according to provisions set in M&O procedure (section 6.3).

In addition to above, and to better address the HSSE matters, change management process should also cover the following subjects:

• New products, services and processes or changes to existing ones:

  • Workplace locations and surroundings,

  • Work organizations,

  • Working conditions,

  • Equipment,

  • Workforce

• Change to legal requirements and/or other requirements,

• Changes in knowledge or information about hazards and HSSE risks,

• Developments in knowledge and technology.

Procurement

Control of externally provided processes, products and services control is organized locally by Recognised Organisation (RO) Country Chief Executives nominated by Recognised Organisation (RO) Group CEO and as per Recognised Organisation (RO) Group procedures. Specific attention shall be paid for Group QHSSE 200-PO Eco-Efficiency Policy (Annex A1, see attached file).

Emergency Preparedness and Response

Based on identified potential emergencies, M&O offices shall set appropriate procedures in order to establish how to respond to them. Plans should cover information to communicate to contractors and visitors.

Regular tests of the local emergency procedure should be scheduled and proceeded to prevent such situations.

Visitors should be informed on safety measures which would be applied in case of emergency in Recognised Organisation (RO) office they visit. This safety moment must be the first item of meeting

In case there is a risk to be confronted with a potential crisis (such as an earthquake, tsunami, terrorist attack etc.) Recognised Organisation (RO) Country Chief Executives can find immediate support at the Recognised Organisation (RO) Group HO level to start organizing the adequate response to the crisis. The HSSE Leader may provide support to the local crisis management team; he or his direct manager should liaise with M&O HO (LC&R_CPL Department).

PERFORMANCE EVALUATION

Monitoring, measurement, analysis and evaluation

General

At entity level, HSSE Leaders are responsible for evaluating the local HSSE performance through:

• identifying what needs to be monitored,

• define how and when to monitor it,

• set up when results must be analyzed.

Local/Zone HSSE Leaders are responsible for monitoring on monthly basis.

Recognised Organisation (RO) M&O HO overviews this data with a view to follow-up the focus area KPIs as specified in the beginning of each year (Annex A2, see attached scorecard) and records realization on quarterly basis.

M&O HO LC&R_CPL Department reports on Safety rates and serious accidents to EXCOM on a monthly basis.

HSSE data are recorded in relevant Recognised Organisation (RO) Group tools as per Recognised Organisation (RO) Group QHSSE requirements.

Environmental data are recorded on GreenHub on quarterly bases as described Group QHSSE-112-PO Environment (Annex A1, see attached file).

The results from monitoring and measurement is analysed and evaluated at the end of the year and presented to management review as an input.

The conformity and effectiveness of the process are verified by the periodical internal audits.

Evaluation of compliance

Entities must regularly assess their compliance with their obligations or upon significant changes of these obligations, and maintain documented information of its compliance evaluation results against all requirements.

As per Recognised Organisation (RO) Group requirements, M&O HO monitors the processes which aim to design a global overview of the Group compliance through:

• regular reporting from local level to M&O HO,

• management reviews as per M&O procedure,

• internal audits.

Internal Audit

General

Internal audits are used to measure the level of compliance and identify opportunities for improvement.

The annual M&O HSSE Internal audit programme is designed as per Recognised Organisation (RO) Group QHSSE Manual requirements and implemented as per M&O procedure the internal and external audits procedure.

Internal audits records in Recognised Organisation (RO) Group Nexus tool is mandatory.

Three types of internal audits are implemented:

• HSSE Management system audits which are assessment of the documentation, the practices and the measurement of compliance of the audited office

• Operational audits are field assessment (site inspections) carried out on clients’ sites or part of M&O specialized internal audits carried out at the office or on site / on board (vertical contract audits) in order to evaluate Recognised Organisation (RO)’s employees and the environment where Recognised Organisation (RO) staff perform services; refer to the M&O Guidance for Safety Walks and Site Inspections (see attached files) where details are provided

• Individual audits which are part of the supervision/activity monitoring of staff.

M&O HSSE Internal audit checklists are used for Management systems audits and Operational audits. They include at minimum the Group HSSE requirements and IACS requirements regarding Safety matters to be checked.

Group Internal Auditors perform internal audits against ISO14001 & ISO45001 standards.

Local internal audits can be planned and performed under the responsibility of HSSE Leader/Zone HSSE Leader if he/she is duly qualified and competent. Audit plan has to be addressed and included in the annual Management review.

Management Review

At local level; M&O Country Managers and Marine Chief Executives review their entity’s HSSE management system at yearly intervals as per M&O Procedure, to ensure its continuing suitability, adequacy and effectiveness.

At HO level; M&O HSSE Manager reviews on behalf of HO with a view to provide additional support for continuous improvement for entities and to ensure harmonisation within the M&O Network. And additionally facilitates HO Management Review with M&O Top Management and HO Department managers.

IMPROVEMENT

General

Recognised Organisation (RO) determines opportunities for improvement and implements any necessary actions to achieve intended outcomes of its HSSE management system.

Incident, nonconformity and corrective action

Recognised Organisation (RO) has established, implements and maintains a process(es), including reporting, investigating and taking action, to determine and manage incidents and nonconformities. When a nonconformity occurs Recognised Organisation (RO) acts timely to take action for correction, evaluates with the participation of workers the need for corrective action to eliminate the root cause(s) and to prevent recurrence and later on reviews the effectiveness of its action taken. The records of which can be followed up via Nexus tool.

Continual improvement

Recognised Organisation (RO) continually improves the suitability, adequacy and effectiveness of HSSE management system and its processes with respect to new technology, good practices, recommendations from interested parties, new knowledge and understanding of HSSE issues, achieving improved performance with fewer resources etc. Information obtained from areas including but not limited to customer complaints, nonconformities, management review outputs, objective and KPI results, experiences related to services etc. form the inputs for continual improvement process.

Appendix — LIST OF CORRESPONDING Recognised Organisation (RO) GROUP DOCUMENTS (see attachment)

List

Recognised Organisation (RO) Group HSSW Statement

Recognised Organisation (RO) Group Environmental Statement

Recognised Organisation (RO) Group Managing Safely Booklet

Recognised Organisation (RO) Group QHSE Priorities

Group QHSSE 100-PR HSSE Incident Reporting

Group QHSSE 006-PO Preventive and Corrective Actions

Group QHSSE 011-PO External Workers -Vendors Suppliers, Subcontractors, Non-Exclusives and Temporary Workers

Group QHSSE 107-PR Root Cause Analysis

Group QHSSE 108-PO Medical Surveillance

Group QHSSE 109-PR QHSSE Risks and Opportunities

Group QHSSE 111-PO Behavioural Safety

Group QHSSE 112-PO Environment

Group QHSSE 113-PO Offshore Safety

Group QHSSE 111-G1 Guideline for Defining Stop Work Authority Process

Group QHSSE 116-PO HSSE Plan for Client Project

Group QHSSE 121-PO HSSE Competencies and Training

Group QHSSE 126-PO Waste Management

Group QHSSE 200-PO Eco-Efficiency

Recognised Organisation (RO) HSSE Requirements Handbook for Subcontractors and Non Exclusives

Package for tenders Group level

Appendix — OTHER RELATED DOCUMENTS (see attachment)

List

Recognised Organisation (RO) M&O HSSE Policies as follows;

• Recognised Organisation (RO) M&O HSSE Policy (EN, FR)

• Recognised Organisation (RO) SA HSSE Policy_as RO (EN, FR)

M&O HSSE Executive Chart

2016 IACS Joint Safety Statement

M&O Local Safety Review

M&O HSSE SWOT Matrix

M&O Global Risk Assessment Matrix Baseline

M&O Basic Common and HSSE Trainings Matrix

M&O Guidance for Safety Walks and Site Inspections

Appendix — SAFETY TRAININGS MATRIX FOR HSSE MANAGERS

HSSE Leaders and M&O Managers having direct HSSE responsibilities as detailed in section 5.3 have to complete HSSE trainings as indicated in the attached file ‘M&O Basic Common and HSSE Training Matrix’.