CONTRACTOR HSEC INCIDENT REPORTING & …

1 CONTR ACTOR HSEC INCIDENT R EPORTING & INVESTIG ATION GUIDE L INE STRAFIGURA TRADING DIVISION & SHIPPING AND CHARTERING DESK1. P U R P O S WHO REGULATORY REPORTABLE WHEN TO WHAT TO REPORT REPORTING HOURS WORKED AND KILOMETERS HOW TO REPORT2. INCIDENT INCIDENT INVESTIGATION RECOMMENDED PROCESS1. PURPOSET rafigura requires that serious Health, Safety, Environmental and Community (HSEC) work-related incidents associated with our business are reported and appropriately investigated. By building a clear view of the HSEC risks faced by our employees and by contractors engaged in support of Trafigura s business we will be better placed to manage our shared document aims to provide Trafigura s partners involved in the storage and transportation of Trafigura owned product with clear guidance on how to:i) Report to Trafigura an INCIDENT or near miss;ii) Report monthly HSEC performance;iii) Carry-out INCIDENT investigations with a view to mitigating future incidents and.

2 Iv) Implement required corrective and preventive measures to avoid are required to report incidents that occur when working for Trafigura, either on a Trafigura facility or outside of a Trafigura facility. Data obtained from incidents and investigations will be used to inform and manage Trafigura s HSEC risks on a global basis and help prevent future you have any questions about the approach presented in this document please contact your existing contact point at Trafigura or email For further information on Trafigura s HSEC Policy and Business Principles please refer to SCOPEAll contractors engaged directly or indirectly by Trafigura s Oil and Petroleum Products Trading Division.

3 Metals and Minerals Trading Division and Shipping and Chartering desk are required to report against these defines an INCIDENT as a single event or continuous/repetitive series of events that results in, or could have resulted in, one or more of the following impacts: Injury or illness; Damage to the environment; Damage to physical assets ( product, buildings, plant and equipment); Disruption to a community; Exposure to legal liability; Security are to report incidents and near misses associated with the work they are doing for Trafigura. Incidents are classified by severity using the matrix in Section WHO CONTRACTOR Work Related ActivitiesIndustry practice is to record CONTRACTOR HSEC incidents that occur when Company ( Trafigura) has control over the work being performed.

4 Three types of CONTRACTOR are identified here referred to a Mode 1, 2 and of incidents is required for all work performed by CONTRACTOR personnel under the contractual Modes 1 and 2. REPORTING of incidents is encouraged from Mode 3 contractors. Mode 1 This is when the CONTRACTOR provides people, processes and tools for the execution of the contract under the supervision, instructions and HSE Management System of Trafigura or other Trafigura company. The CONTRACTOR has a management system to provide assurance that the personnel for whom it is responsible are qualified and fit for the work and that the processes, tools, materials and equipment they provide are properly maintained and suitable.

5 If a CONTRACTOR is working on a Trafigura facility, they are Mode 2 This is when the CONTRACTOR executes all aspects of the contract under its own HSE Management System, providing the necessary instructions and supervision and verifying the proper functioning of its HSE Management System. Trafigura is responsible for verifying the overall effectiveness of the HSE management controls put in place by the CONTRACTOR , including its interface with subcontractors, and assuring that both the client s and the CONTRACTOR s HSE Management System are contractors who transport Trafigura commodities from one Trafigura location to another are Mode 2 contractors as Trafigura has control over the type of vehicle used, routes, drug and alcohol testing, etc.

6 Time charter vessels where we have a time charter for more than one year are also considered Mode 2 contractors (less than one year are considered Mode 3).Mode 3 This is when the CONTRACTOR operates within its own HSE Management System that has no interfaces with the client HSE Management System and is not required to report HSE performance data including incidents to the client, however they are strongly encouraged to do so. This does not exclude the possibility that the client may wish to guide and influence HSE performance under this type of contractors delivering commodities to a Trafigura site from a non-Trafigura location are usually considered Mode 3 as Trafigura have little control over.

7 For recording purposes, Subcontractor personnel are to be treated as if they were CONTRACTOR personnel and work hours and work-related events reported as CONTRACTOR REGULATORY REPORTABLE INCIDENTST rafigura s REPORTING guidelines do not supersede local or national regulatory INCIDENT REPORTING requirements or absolve contractors associated with our business from REPORTING within designated WHEN TO REPORTT rafigura requires that third-parties provide an initial alert to their nominated contact within Trafigura within 4 hours of a serious (Level 3,4,5) INCIDENT occurring. Contractors are not expected to submit a formal INCIDENT investigation as part of this 1 and 2 incidents should be reported in monthly WHAT TO REPORT The following guidelines are designed to enable contractors to assess the seriousness of HSEC incidents.

8 While Mode 1 and 2 contractors are required to report Level 1 to 5 incidents and near misses, the company also welcomes the REPORTING of incidents and near misses from Mode 3 in any doubt as to the seriousness of an INCIDENT , contractors are encouraged to contact Trafigura immediately. Mode 1 and 2 contractors should report hours worked and kilometers driven on Trafigura activities each REPORTING HOURS WORKED AND KILOMETERS DRIVENIn order to understand the frequency at which incidents are occuring, Mode 1 and 2 contractors are required to report the hours they have worked on Trafigura business and the kilometers they have driven on Trafigura business. This should be provided monthly by the 10th working day of the following HOW TO REPORTL evel 3, 4 and 5 incidents should be reported within 4 hours to your Company contact.

9 All incidents, near misses and hours worked should be reported in summarised form within 10 working days from the last day of each month. Appendix B contains a template for this monthly INTRODUCTIONC ATEGO RYLEVEL 1 LOWLEVEL 2 MINORLEVEL 3 MODERATELEVEL 4 MAJORLEVEL 5 CRITICALI njury and Illness (to employees, CONTRACTOR or subcontractor, third parties/members of the public)First aid treatmentShort-term subjective treatment case or restricted work duties Objective but reversible disability / impairment. Illness or injury results in restricted / modified duties. Potential breach of health and safety Time INCIDENT injury Moderate irreversible disability or impairment to 1 or more persons.

10 Clear breach of health and safety irreversible disability or impairment to 1 or more hospitalization equal to or more than 3 people and equal to or less than 9 persons).Multiple irreversible human health effects or hospitalization of more than or equal to 10 people. Environmental EffectsHydrocarbon spill* of less than 1 barrel (BBL). Volume of metal, metal concentrate or bulk material spilled less than 1 damage to minimal area of low significance hydrocarbon spill largely contained on deck of vessel or at loading rack. No permanent impact on biological or physical environment.*NB. Gross volume spilled not residual or effective volume remaining in environment following recovery spill of more than 1 BBL less than 7 BBLs (1 tonne).