Health & Safety Policy

59825264_1054390124950901_63274368651839

Company Safety, Health and Environmental Philosophy

In the Company’s search for excellence in all of its operations, it is recognised by the Directors that they must aim:

to achieve and maintain the best and the safest working environment for all affected by the Company’s operations, and
to reduce the environmental impact of its operations to a minimum.

This will be done through:

constant training and dissemination of information in matters of safety, health and environmental responsibility,
the planning, management & monitoring of safe and environmentally responsible working practices which also safeguard the health of those affected, and
the engineering in of safe methods of work and environmentally friendly materials.

It is the Directors’ aim that this Safety, Health and Environmental Policy:

provides a Statement of Intent of the Company's safety health and environmental culture
supports the development of the Company's human resource
minimises the financial losses which arise from avoidable unplanned events
provides a systematic approach to, and to set out the responsibilities involved in, the identification, assessment and control of risk
defines the safety organisation and the Directors' responsibilities for safety, health and the environment
establishes the arrangements to be made for safety and health within the Company
identifies the Impact made on the Company's business by the stated approach to safety, health and the environment.

Statement of Intent on Safety and Health

The Directors of the Company, through the implementation of the safety, health and environmental Policy, will encourage the Company's employees and subcontractors to constantly aim for the best safety and health management practices that can be achieved and will provide a commitment to continual improvement in the health, safety and environmental performance of the company, ensuring that health and safety is never compromised for other objectives.

The Directors recognise that the needs of its employees, and of others for whom the Company provides employment, and the prosperity of the Company, are inextricably linked.

A major aim of the Directors is to ensure, through example and encouragement, that the Company and its employees and others working on behalf of the Company, behave ethically and responsibly, particularly in the fields of safety and health.

The Company, fully accepting its responsibilities for the health, safety and welfare of its employees, subcontractors and others affected by its operations will, so far as is reasonably practicable, act to provide and maintain:

Arrangements to plan, organise and control those preventive and protective measures found to be necessary by design and risk assessments.
Arrangements to monitor, measure and review compliance with this policy, and statutory obligations & responsibilities,
Safe plant and equipment, safe systems of work, and safe working places with safe access and egress for all operations

undertaken
Sufficient information, instruction, training, and supervision,
Arrangements for the safe use, handling and storage of all materials.
Adequate design and risk assessments that identify the risks to which employees, subcontractors and others affected by its operations are exposed.

The Company will advise, and co-operate with, those whose designs and operations impinge on the Company's own work.

The Company will ensure, so far as is reasonably practicable, that persons not directly in its employment shall not be exposed to risks to their safety and health when they are:

On the Company's premises
Within areas of work for which the Company is responsible
Affected by materials or components for which the Company has accepted design responsibility.

The Company recognises that no policy can be effective without the full co-operation of its employees and subcontractors. They are reminded, through this policy, that they have a statutory duty to take reasonable care of their own safety and health, and that of others with whom they work or come into contact.

The Company will provide, so far as is reasonably practicable, competent technical advice on safety and health matters to its employees and subcontractors. This provision does not relieve any individual of his/her own, stated, responsibilities.

Employees and subcontractors are required to co-operate with the Company in the implementation of this policy.

The Company will only employ subcontractors, on any of its operations, whose safety and health management competency has been checked and approved.

The Company will only employ, on any of its operations, operatives, supervisors and managers whose competency meets those standards set by the Director responsible for Safety.

The Company will issue a copy of this policy to all employees and subcontractors.

This policy will be reviewed annually or as and when changes are required and modified as necessary. Such modifications will be issued to all employees and appropriate subcontractors.

This statement of intent will form part of all safety method statements prepared and issued by the Company.

The Company, whilst not absolving itself from its statutory responsibilities, will use - where appropriate - the services of external health, safety, and environmental, advisers to assist in the implementation of this policy.

*Original document signed by TC Millichap (SHEQ Director) - December 2018

Statement of Intent on Environmental Policy

The Directors of the Company, through the implementation of the safety, health and environmental policy, will encourage the Company's employees and subcontractors to constantly aim for the best safety, health and environmental management practices that can be achieved and will provide a commitment to continual improvement in the Environmental performance of the company.

The Company, fully accepting its responsibilities for matters within its control that affect the Environment will, so far as is reasonably practicable, take action to provide and maintain:

Measures, found to be necessary by assessment, to use materials and methods of work that minimise any detrimental effect on the environment.
Arrangements to monitor, measure and review compliance with this policy, and statutory obligations & responsibilities,
Minimise the production of wastage
Minimise the production of disposal packaging through active involvement with major suppliers
Minimise energy wastage
Promote the use of recyclable and renewable materials
Control noise emissions
Plant and equipment that minimises any detrimental effect on the environment.
Sufficient information, training, instruction and supervision on matters affecting the environment
Adequate environmental impact assessments which identify the effect on the environment of all materials and methods of work that could have a detrimental effect on the environment.

The Company will advise, and co-operate with, those whose designs and operations impinge on the Company's own work.

The Company will ensure, so far as is reasonably practicable, that persons not directly in its employment shall not be exposed to environmental risks when they are:

On the Company's premises
Within areas of work for which the Company is responsible
Affected by materials or components for which the Company has accepted design responsibility

The Company recognises that no policy can be effective without the full co-operation of its employees and subcontractors. They are reminded, through this Policy, that they have a duty to consider the environmental impact of their actions.

The Company will provide, so far as is reasonably practicable, competent technical advice on environmental matters to its employees and subcontractors. This provision does not relieve any individual of his/her own, stated, responsibilities.

Employees and subcontractors are required to co-operate with the Company in the implementation of this policy.

The Company will only employ subcontractors, on any of its operations, whose competency has been checked and approved.

The Company will issue a copy of this Policy to all employees and subcontractors.

This policy will be reviewed annually or as and when changes are required and modified as necessary. Such modifications will be issued to all employees and appropriate subcontractors.

*Original document signed by TC Millichap (SHEQ Director) - December 2018

Safety Organisation and Management Responsibilities

The Management Structure of the Company, with regard to Safety, Health and the Environment (SHE), is shown below.

The management structure for individual contracts undertaken by the Company is provided in the safety method statement prepared for each contract.

The SHE responsibilities for the Managing Director, Directors and SHE Advisors are included in this SHE Policy.

The SHE responsibilities for all other employees, and for the SHE Committee are included in the Company SHE manuals.

Directors Responsibilities

In defining the responsibilities of the Directors of the Company, cognisance has been given to the Health and Safety Commission document: Directors’ Responsibility for Health and Safety.

The Directors accept and adopt the concept that:

In the context of effective corporate governance, managing corporate risk is a key issue for all directors and senior managers.

Effective management of health and safety risks will help:

maximise the well being and productivity of all people working for an organisation;

stop people getting injured, ill or killed through work activities;

improve the organisation’s reputation in the eyes of customers, competitors, suppliers, other stakeholders and the wider community;

avoid damaging effects on turnover and profitability;
encourage better relationships with contractors and more effective contracted activities; and minimise the likelihood of prosecution and consequent penalties.

In following the recommendations of the HSC document, a Director responsible for Health and Safety is nominated annually by the Chairman.

The following Directors' responsibilities are defined, to ensure that the Safety, Health and Environmental Policy (SHE Policy) of the Company is implemented:

Managing Director

shall ensure, through encouragement, example and the provision of sufficient resources, that the Directors of the Company are able to implement the Company's SHE philosophy and SHE policy within their areas of responsibilities.

Shall, each year – on the review of this Policy – nominate one of the Directors to be the Director responsible for Safety.
Shall each year – on the review of this Policy – approve the appointment of the Company’s SHE Advisors.

Shall ensure, through encouragement and example, and the provision of any necessary facilities, that the Directors of the Company are able to implement the Company's SHE philosophy and SHE policy within their areas of responsibilities; and that they are able to ensure that the requirements of these are communicated to and understood by all employees and subcontractors.

He shall ensure, in particular, that:

An organisation for safety, health and environmental management is established, maintained and understood by the Directors of the Company.
The Company's SHE policy is established and maintained by the SHE advisors, and is reviewed by the Directors of the Company at least annually
He monitors and reviews the effectiveness of the SHE policy.
Suitable, sufficient and appropriate training in health, safety, welfare and environmental issues is made available to all

employees, on recruitment and at appropriate times thereafter.

He, at all times, sets a good personal example in matters of safety and health, and in matters affecting the environment.

He shall also ensure that a SHE management system and procedures are established, issued and maintained.

SHEQ Director

Shall ensure, in addition to the above, that:

A safety method statement and risk assessments are prepared and issued for each project on which the Company is employed.
Safe systems of work, and suitable procedures for carrying them out, are included in all safety method statements and risk assessments.
Any plant and equipment needing to be designed for a specific task is designed by a competent person able to accept legal responsibility for such design; that a design assessment is carried out by that person, and that all instructions for use are prepared by that person.
Responsible for ensuring that the company complies fully with its duties under the Construction (Design and Management) Regulations
He arranges safety inspection visits to each site at least once each month, and arranges for a written safety report to be issued.
A site safety induction talk is given to all employees and subcontractors on each site on which the Company is employed, at the commencement of work
Site safety toolbox talks are given at a reasonable frequency on each site on which the Company is employed.

Technical Director

Shall ensure, in addition to the above, that:

A design assessment is carried out for each project on which the Company is employed as a designer, or for which the Company tenders and prepares a design.

Director Responsible for Safety

Shall ensure, in addition to his other responsibilities as a Director, that:

All accidents, and dangerous incidents, are investigated and reported, and that their causes are established with a view to eliminate recurrence.
A report is prepared and issued to the board of Directors on every fatal, or potentially fatal, accident or dangerous occurrence.
The ‘arrangements’ outlined later in this document, are in place.
Using advice from the Company’s SHE Advisors, he ensures that senior managers are aware of the implications of all

current and new SHE Legislation.

Department Managers

Shall ensure, in addition to their other responsibilities that:

Implement and comply with Company safety policy and ensure that responsibility allocated to each level of employee is discharged.
Be aware of the Health and Safety at Work Act, and other regulations relevant to the company’s activities.
Take note of accident investigation procedure and act to prevent similar occurrence.
Take disciplinary action against any employees failing in their responsibilities to Health and Safety, after ensuring that

no employee is penalised for refusing to work on the grounds of Health and Safety.

Ensure all new employees receive company induction and it is recorded on the record of training.
Ensure that safe working practices are always observed.

Contracts Managers/Site Managers

Shall ensure, in addition to their other responsibilities, that:

They implement and comply with Company safety policy and legal requirements within their area of operation.
Prepare and submit method statements for contracts under their control. In addition they will be responsible for ensuring

that the company complies fully with its duties under Construction (Design and Management) Regulations 2015

Carry out comprehensive risk assessments using the company format for risk assessment.
Ensure that working methods and conditions are in accordance with Company safety policy and statutory

requirements.

Instruct site operatives in their responsibilities and ensure they are understood and encourage suggestions for

improvement of Health and Safety for discussion and contracts management meetings.

Ensure all registers and records are maintained and reports are submitted as necessary.
Ensure all plant and equipment is properly checked and maintained.
Ensure operatives receive adequate Health and Safety training to fulfil their responsibilities including the duty to stop

work if they consider their or others health and safety may be at risk.

Ensure all new employees receive company induction.
Ensure all site operatives attend site specific inductions to inform them of emergency procedures by the Main Contractor
Ensure that adequate PPE is issued and signed for and used.
Investigate all accidents and injuries and provide a report to the Director Responsible for Health and Safety.

Operatives

Shall ensure, in addition to their other responsibilities, that:

They comply with Contracts/Site Managers instructions, Company safety policy and current legal requirements.
Use correct tools and equipment and where necessary wear the correct PPE.
Take care of tools, equipment and PPE and report any defects to site management.
Do not take unnecessary risk and avoid unsafe actions.
Develop a personal concern for your health and safety and that of others.
Refrain from irresponsible behaviour on site.
Report all accidents and incidents to site management.
Do not misuse anything provided for your health, safety and welfare.
Co-operate with management on all matters relating to health and safety.

Operatives are expected to fulfil certain duties and responsibilities under the Health and Safety at Work Act 1974 and all other regulations relevant to the company’s activities.

Operatives are therefore obliged to:

Take reasonable care for their own Health and Safety and that of others.
Co-operate with the employer and competent persons.
Not misuse safety devices and equipment.
Make correct use of work equipment, machinery, substances and PPE.
Report safety short comings and hazardous conditions to the employer.
Stop work if they consider that their or others Health and Safety may be at risk if they continue and report the same to
Site Management.

Staff

Shall ensure, in addition to their other responsibilities, that:-

Comply with Company Safety Policy and other legal requirements.
Be aware of the requirements of Health and Safety under the Health and Safety at Work Act 1974 and all other

regulations relevant to the company’s activities.

Develop a personal concern for your Health and Safety and that of others.
Stop work if you consider your Health and Safety or that of others may be at risk and report to your Manager.
Do not take unnecessary risks and avoid unsafe behaviour.
Refrain from irresponsible behaviour.
Report all accidents and incidents.
Do not misuse anything provided for Health, Safety and Welfare.
Understand the fire regulations and the action to take in the event of a fire.
Use PPE where necessary.

Employees are expected to fulfil certain duties and responsibilities under the Health and Safety at Work Act 1974 and all other regulations relevant to the company’s activities.

Staff are therefore obliged to:

Take reasonable care of their own Health and Safety and that of others.
Co-operate with the employer and competent persons.
Not misuse any safety devices and equipment.
Make correct use of work equipment, machinery, substances and PPE.
Report safety short comings and hazardous conditions to the employer.
Stop work if they consider that their or others Health and Safety may be at risk if they continue and report the same to

Management.

Assistance provided to the Directors

To assist the Directors in the implementation of the SHE Policy:

Safety, Health and Environmental Manuals

SHE procedures and manual are provided which define the responsibilities of:

Contract Managers etc.
Supervisory Management
All Employees
Subcontractors

SHE Advisors including Company Health, Safety and Quality Manager

SHE Advisors’ Responsibilities

The SHE Advisors shall ensure that, through their experience and the proper use of the resources provided by the Company, they are able to influence and improve the Company's SHE philosophy and SHE policy within their areas of responsibility.

They shall ensure in particular that:

They are familiar with all Statutory Regulations and Legislation relevant to the work for which they are responsible
They establish, maintain, monitor and review, and update as necessary, within the limits of their remit from the Company,

the Company’s SHE management system.

They similarly establish, maintain and update as necessary all Company SHE documents and publications.
They advise and co-operate with any Director of the Company in achieving the Company's required level of safe

working.

They assist the Director responsible for Safety in the execution of his duties and responsibilities
They carry out competently, and only within their area of competence, any task entrusted to them by the Company. Theyshall not undertake any task that is outside their area of competence.

Arrangements

The following arrangements shall always be in place to ensure that the Company's SHE Policy is carried out; and that the statements of intent and the SHE policy itself are brought to the attention of all employees and subcontractors.

The Director responsible for Safety shall be responsible for ensuring that these arrangements are in place.

Systems and Documentation

The Company SHE Policy, incorporating statements of intent, shall be issued to all employees.

A Safe Working Practice Manual shall be prepared covering each area of the Company's operations determined by the Director responsible for Safety in conjunction with the Company’s SHE Advisors, and shall be issued to all employees.

The Company's SHE policy, together with the relevant SHE manuals / procedures and code of safe working practice, shall be issued to all Subcontractors as a part of the order documentation for each specific Contract.

The Company's SHE Policy, or the Statements of Intent, shall be issued to any Third Party on request.

The Company's SHE Advisors shall provide an ongoing support, information dissemination and advisory service, and training, on all SHE matters relating to the Company's normal activities, within the limits of their remit from the Company.

General Duties

The following matters are brought specifically to the attention of all concerned with the implementation of the Company's SHE Policy.

Each employee has a Statutory Duty while at work:

To take reasonable care of the safety and health of himself and of other persons who may be affected by his acts or omissions at work.
As regards any duty or requirement imposed on his employer or any other person, to co-operate with them so far as is necessary to enable that duty or requirement to be performed or complied with.
Not to intentionally or recklessly interfere with or misuse anything provided in the interests of Health, Safety or Welfare.
To undergo any health checks, eye and hearing tests required by the Company.

General Arrangements

The following arrangements shall be in place at all times to ensure that the requirements of the appropriate Regulations are met:

The methods of providing health surveillance as required by Regulation 6 of the Management of Health and Safety at Work (MHSW) Regulations - 1999 shall be included in the SHE Manuals and shall also be considered in the preparation of Risk Assessments.
The competent help required to be available by Regulation 7 of the MHSW Regulations - 1999 shall be provided by the Company's SHE advisors.
The Procedures for danger required to be provided by Regulation 8 of the MHSW Regulations - 1999, relevant to each area of operation, shall be included in the SHE Manuals; or, in the case of construction sites, in the site safety induction.
The information for employees required to be provided by Regulation 10, and the Information for temporary workers as

required by Regulation 15, of the MHSW Regulations - 1999 shall be included in the Company SHE policy, SHE manuals /

procedures and safety instruction manuals.

The methods of providing the co-operation and co-ordination between employers required by Regulation 11 of the

MHSW Regulations - 1999 shall be included in the SHE manual.

The methods of ensuring that information is provided to visiting employees, as required by Regulation 12 of the MHSW

Regulations - 1999 shall be included in the SHE manual.

The methods of assessing the capabilities of employees and Training to be provided, as required by Regulation 13 of the

MHSW Regulations - 1999, shall be included in the Company SHE policy.

Employee's duties, as established in Regulation 14 of the MHSW Regulations – 1999 shall be set out in the relevant SHE

manual.

The duties imposed on the Company by the Construction (Design and Management) Regulations - 2015 and the means

of satisfying those duties, shall be set out in the SHE Management System and Procedures, and in the Company's

statement of intent on the CDM Regulations.

The duties imposed on the Company by the Workplace (Health, Safety & Welfare) Regulations - 1992 or workplaces

involving construction work on Construction Sites, these are amended by the Quarries Regulations 1999, the Health and Safety (Miscellaneous Amendments) Regulations 2009, the Work at Height Regulations 2005 and Work at Height (Amendment) Regulations 2007, and the Construction (Design and Management) Regulations 2015, and the means of satisfying those duties shall be set out in the SHE Management System and Procedures, and in each Safety Method Statement issued.

Statutory Regulations

A List of current Regulations, applicable to the Company's main construction operations, is maintained in specific registers.

All current Regulations, applicable to all of the Company’s operations are kept and maintained by the Director responsible for Safety.

It is the responsibility of the Director responsible for Safety, using advice from the Company’s SHE Advisors, to ensure that Senior Managers are aware of the implications of all current and new SHE Legislation.

Planning for Safety and Health

The preparation of a SHE Safe Working Practice Manual ensures that a systematic approach is made to planning preventive and protective measures. Risks are identified and methods of work established which minimise them.

The establishment of, and compliance with, a SHE Management System including the necessary Procedures ensures that a systematic approach is made to all aspects of the management of SHE matters on each Construction Project in which the Company has an involvement.

The preparation of a Safe Working Practice Manual, ensures that the Company’s safe methods of work on site are established and made known. This code of Practice will be referred to during the preparation of each Safety Method Statement.

The preparation of Design Assessments ensures that, on projects for which the Company is responsible for any design element, all risks which the designed component impose on those affected by its erection, use or dismantling are identified. Methods of work to minimise such risks shall be established.

The preparation of Safety Method Statements for each Construction Project on which the Company works, similarly ensures that a systematic approach is made, identifying all risks and setting out methods of work to minimise them. Reference is made to the Safe Working Practice Manual and to Specific Risk Assessments during preparation. The provision of Safe Methods of Working, Safe Places of Work and of Safe Access and Egress is given priority.

Organisation

The management structure and organisation to ensure a satisfactory implementation of the Company's SHE policy is identified in this Document.

Control, Monitoring and Review

Systems to ensure the satisfactory control, monitoring and review of SHE matters are identified in this SHE Policy.

The Company may retain external SHE advisors to assist the Director responsible for safety in carrying out these duties.

Other systems and procedures to ensure the satisfactory control, monitoring and review of safety, health and environmental matters are identified in the SHE manuals and procedures.

This policy will be reviewed at least annually and after every incident or change in legislation which causes rise to review.

Accident Reporting and Recording Procedures

The reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) apply and is a requirement under the law and failure to comply with that law is an offence.

All employees should be made aware that these regulations require the reporting of such accidents, incidents and dangerous occurrences irrespective of injury.

The following procedures must be adopted:

A full page per incident accident book is kept at the company offices and all accidents are reported and recorded in this book.

Where injury occurs to an employee or sub-contractor, or if there is a dangerous occurrence such as structural collapse, fire, explosion, acts of violence to or by personnel or incident which may threaten life or health the details must be entered into the accident book.

The person responsible for health and safety will check the RIDDOR requirement and notify the Health and Safety Executive if the incident is notifiable or dangerous.

Reporting allows trends to be identified by the Company and the Health and Safety Executive.

All accidents have to be reported to the Company’s insurers in order that appropriate and timely action can be taken in accordance with the civil liability rules.

The company has a procedure in place for investigating accidents which is carried out by the Contracts Manager and the report details remedial steps required. Recommendations arising from the report should be reviewed by Senior Management and implemented as soon as possible.

All accidents and incidents are noted and statistics kept for record purposes.

Management of Asbestos

It is the intention of the company to ensure that neither its employees, sub-contractors nor unconnected personnel are exposed to asbestos in any form, and thus eliminate the possibility that such persons will contract any terminal and debilitating cancers and other diseases that are associated with the inhalation of the fibres given off by asbestos containing materials if they are inadvertently disturbed.

The company restricts its involvement with asbestos to ensuring it finds out if asbestos containing materials are present on site, its operatives and sub-contractors are familiar with the areas where asbestos containing materials may be found and what to do if they are.

If the building being works upon is existing as opposed to new build the Contracts Manager will approach the client and enquire if there is an asbestos register prior to producing risk assessments.

Assuming the ACM’s are removed or can be avoided, there remains a small residual risk that hitherto undetected examples may still be present. The company as part of its commitment to training will progressively educate its frontline employees on techniques of how to recognise ACM’s, where they might be found, and what to do if a suspect material is encountered.

If a suspect material is encountered, operatives must notify their supervisor immediately. Work in the area is to be stopped immediately and Directors alerted. The company will, in liason with the client, arrange for samples to be removed and sent away for analysis by competent personnel. If ACM’s are present then a way forward will be agreed with the client prior to any work recommencing.

Should operatives ever be engaged in low level ACM removal, they must undergo regular professional health surveillance and screening to ensure they remain unaffected by the material and can safely continue to carry out such works.

Risk Assessments

In accordance with Regulation 3 of the Management of Health and Safety at Work Regulations - 1999, assessments are carried out of the risks to the Safety and Health of Employees whilst at work, and of other persons who may be affected by work carried out by the Company.

Model Risk Assessments*, or Specific Risk Assessments, are carried out for use on each Project on which the Company works in order to identify Risks encountered on all sites and peculiar to that particular project or site. These Risk Assessments are issued to all employees, or others, identified to be at risk.

All Risk Assessments are referred to in Safety Method Statements.

Model and/or Special Risk Assessments shall be carried out, and issued to all employees, or others, identified to be at risk, in accordance with the appropriate Regulations, which cover those risks presented by:

Noise - Manual Handling - Substances Hazardous to Health.

Special Risk Assessments and Safe Working Procedures shall be prepared for any abnormal and particularly hazardous operation, which employees or others may be required to carry out, and are issued, to all employees, or others, identified to be at risk. Such activities will typically include:

Working with Lead - Working with Asbestos - Exposure to Weill's disease.

Impact on the Company's Business

The Directors recognise that the Company's SHE policy impacts on all areas of the Company's operations, performance and results. The table below sets out some of the areas in which this impact is anticipated to be beneficial.

Record of Changes to this Policy

Metclad Contracts