Policy Policy on OHS non compliance consequence management

Owner Human Resources, India

Issue date 12th March 2014

Version 1.1

Approved by Country Management Team, India

Version Control

Version Date Changes / Action

1.0 12th March 14 Policy rolled out
1.1 1st August 2014 Rebranding

Human Resource Policy

OHS Consequence management matrix
Version 1.0
For internal use © Nokia Solutions and Networks 2014
 CONTENTS

Serial No. Content Page Numbers

1 Objective 3

2 Scope 3

3 Definition 3

4 Process 4

5 Consequence of non-reporting 5

6 Deviation/Exception 5

7 Policy Owner 5

8 Policy Status 5

9 Annexure 1(a, b, c, d) 6

10 Annexure 2 10

Human Resource Policy

OHS Consequence management matrix
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1 Objective

1.1 Objective of the policy is to define and provide guidelines for dealing with OHS non compliance
consequence management.

1.2 Raise level of awareness amongst all employees in CO India Delivery organization and
consequently encourage highest levels of compliance to OHS standards.

2 Scope

2.1 The policy applies to all regular employees of Nokia Solution and Networks Private Limited,
hereinafter referred to as a “Company” including fulltime, fixed term and part-time employees
involved in employment or other activities on behalf of the company in CO India Delivery
Organization.

2.2 It applies to the work place or activities in any way connected with workplace including
customer work site.

3 Definition

3.1 OHS mean Organization Health and Safety policy, processes and guidelines to ensure highest
levels of health and safety for all the people working for or associated directly or indirectly with
Nokia Solutions and Networks.

3.2 OHS non compliance disciplinary committee – This committee will consist of CO India Delivery
Head, relvant COM/BL Head, India Delivery HR Head, India Region Legal Head and India
Delivery OHS Lead.

3.3 Investigating committee – This committee will consist of relevant CH/Function Head, Second
Level Manager/s of employee/s against whom non compliance has been reported, Circle HR
Manager and Circle OHS Lead.

3.4 “Severity Level” indicates the risk involved in activity/ies not in compliance with OHS
processes, policy and guidelines.

3.5 Severity level 1 implies low risk associated with activity/ies which is not in compliance with
OHS processes, policy and guidelines.
Human Resource Policy
OHS Consequence management matrix
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3.6 Severity level 2 implies moderate risk associated with activity/ies which is not in compliance
with OHS processes, policy and guidelines.

3.7 Severity level 3 implies high risk associated with activity/ies which is not in compliance with
OHS processes, policy and guidelines

4 Process

4.1 It is the responsibility of everyone working with or associated directly or indirectly with Nokia
Solutions and Networks to report any work or activities which is not as per Nokia Solutions and
Networks OHS policy, processes or guidelines.

4.2 Any work or activity which is not adhering to Nokia Solutions and Networks OHS policy,
processes or guidelines needs to be immediately reported to location Circle Head & CO India
Delivery OHS Lead. This can be done through mail, phone call of f2f meeting.

4.3 CO India Delivery OHS Lead would nominate the Investigating committee as defined above.
The Investigation committee would investigate such reported incidence/s and submit its report
within stipulated time frame to CO India Delivery OHS Lead.

4.4 On receipt of the report from the investigating team, CO India Delivery OHS Lead will
recommend action/s to be taken basis the non compliance severity level matrix illustrated in
annexure 1 and submit this recommendation to OHS non compliance disciplinary committee.
The CO India Delivery OHS Lead, on agreement with the OHS non compliance disciplinary
committee, can institute an alternate investigation team depending on nature of OHS non
compliance.

4.5 OHS non compliance disciplinary committee will decide on action/s to be taken basis
recommendation of the CO India Delivery OHS Lead and the Consequence management
matrix illustrated in annexure 2.

However, the Committee may, as its own discretion decide to impose a lesser punitive
measure after considering all circumstances of any incidence of non-compliance.

Human Resource Policy

OHS Consequence management matrix
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4.6 A monthly dashboard capturing status of OHS non compliance incidences and consequent
actions would be published by CO India Delivery OHS Lead on or before 10th of every
subsequent month.

5 Consequence of non reporting of OHS non compliance

5.1 It is expected that all OHS non compliance incidents are reported as per the reporting matrix.
However, in case of incidences where it is established that non-reporting of OHS non
compliance has happened, consequences of not reporting will be dealt with through
appropriate action as recommended by India Delivery OHS Lead and finalized by OHS non
compliance disciplinary committee.

6 Deviation / Exception

6.1 While the Consequence management matrix will serve as a guideline for determining nature
and quantum of non-compliance and punitive action thereof, the OHS non compliance
disciplinary Committee may, at its own discretion decide to impose a lesser punitive measure
after considering all circumstances of any incidence of non-compliance.

6.2 Management reserves the right to amend, modify or change the policy from time to time
without any prior notice thereof. Any deviation/exception needs to be approved by OHS Non
Compliance disciplinary committee.

7 Policy owner

Human Resources function owns this policy. In case of any dispute on the policy Head Human
Resource IMEA should be contacted and the decision taken will be final and binding.

8 Policy Status

The policy is in effect from 12th March 2014.

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OHS Consequence management matrix
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Annexure 1(a)
OHS non compliance severity level matrix

Severity
Work/Action NON Compliance
Level
Supervisor did not restrict the W@H while dangerous insects (honey bees),
birds or animals (snakes, monkeys, etc.) available at tower, which could put Level 1
the climber at risk.

Id card and proper clothes not available with the

Rigger/Climber/Technician/Engineer at site. Level 1

Engineer/Rigger/Technician not aware of what to do in-case of emergency

and list of emergency contact numbers not available Level 1

Nokia Solutions and Networks approved (EN Standard) PEE not used for
W@H. Level 2

W@H carried out during poor weather condition. Level 2

Prior to each climb, risk assessment not carried out at the site. Level 2
First Aid kit not available with the team while work in Progress. Level 2
Toolbox talk not carried out at site before starting the W@H Level 2
Work at Woking at height without Training (work at height) Level 3
Height
Working at height carried without Full body harness (EN Standard). Level 3
Personnel who W@H not certified medically fit by a medical practitioner. Level 3
A work permit not issued, on sire, prior to work commencing. Level 3
Engineer/Rigger/Technician not having appropriate age, qualification and
experience. (Defined in Health & Safety Requirements for Supplier) Level 3

W@H not restricted by Supervisor/Team Leader during hours of darkness.

(Working on towers during hours of darkness is permitted only if it is not
possible to re-schedule the work to daylight hours AND the following
measures are taken; all climbers shall maintain contact with each other at all Level 3
times;
the climbing path and the working environment and sufficiently illuminated.)

Rigger/Climber not attached to the structure through full body harness/fall

arrester while W@H Level 3

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OHS Consequence management matrix
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Annexure 1(b)
OHS non compliance severity level matrix

Severity
Work/Action NON Compliance
Level
Emergency contact no. not available in the vehicle or with the driver/rider
(4W/2W) Level 1

More than two pillion on a two wheeler. Level 2

Not using side indicators while taking a turn. Level 2

Driving/Rider not aware on Nokia Solutions and Networks Road Safety

Rules. Level 2

Driver not undergone the safe/defensive driving training program. Level 2

Vehicle not fit to drive. Level 2
Not wearing seat belt in rear (4W). Level 2
Rider / pillion or either or person not wearing ISI approved helmet. Level 2

Driving without driving license. Level 3

Road Safety Driver not medically fit to drive. Level 3
Driving under the influence of alcohol or illegal issues. Level 3
Not wearing seat belt in front (4W). Level 3

Driving more than 12 hours in a day Level 3

Use of Mobile Phone while driving Level 3
Driver not having appropriate age, qualification and experience
th
(Age – 23 yrs, Qualification-Min 10 Pass, Exp – 5 yrs after obtaining the Level 3
license)

Over speeding/Rash Driving. Level 3

Rider / pillion or either or person not wearing helmet. Level 3

Rider / pillion or either or person not wearing chin strap on helmet. Level 3

Human Resource Policy

OHS Consequence management matrix
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Annexure 1(c)
OHS non compliance severity level matrix

Severity
Work/Action NON Compliance
Level

ID card and proper clothes not available with the Technician/Engineer at

site. Level 1

Toolbox talk not carried out at site before starting the Electrical Work. Level 1

Engineer/Rigger/Technician not aware of what to do in-case of emergency

and list of emergency contact numbers not available. Level 1

Electrical equipment’s not fit for intended purpose/environment. Level 2

First Aid kit not available with the team while work in Progress. Level 2

Working on electrical equipment without authority Level 2

Electrical Engineer/Technician not having appropriate qualification and experience.

(Defined in Health & Safety Requirements for Supplier) Level 2
Safety
Personnel who is working on electrical equipment not certified medically fit
by a medical practitioner Level 2

Prior to start of work, risk assessment not carried out at the site. Level 2

Working on electrical equipment without training. Level 3

Working on ‘live’ electrical equipment without approval. Level 3

Working on electrical equipment without work permit. Level 3

Electrical equipment not isolated from all sources of power and formal lock
out/tag out system not followed. Level 3

Human Resource Policy

OHS Consequence management matrix
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Annexure 1(d)
OHS non compliance severity level matrix

Severity
Work/Action NON Compliance
Level

Internal H&S Inspection of site not carried out in 1:10 ratio. Level 1

Monthly H&S review not conducted with contractors. Level 1

Initiation of Project without conducting the project level risk assessment.

Level 2

Initiation of Project without H&S Plan.

Level 2
New Project
H&S documentation not filled up & kept at site while WIP.
Level 2

H&S V5 Checklist not followed during handover and takeover of site. Level 3

Contractor H&S evaluation not conducted before project start-up.

Level 3

Work performed by untrained & Incompetent person.

Level 3

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Annexure 2
OHS non compliance consequence management matrix
Action to be taken 1st Non 2nd Non
Severity 3rd Non Compliance
against Compliance Compliance
Warning letter + PIP
to be initiated. PE
rating needs to be IR
Level 1

Employees Verbal warning Warning letter for the year

Team Lead/Line Warning Letter to be
manager NA Verbal Warning issued.
Circle head/SBM NA NA Verbal Warning.

Warning Letter + PIP

Written Warning Warning Letter + Initiation + PE rating
Employees Letter. PIP to be initiated. will be IR.
Level 2

Team Lead/ Line Warning letter + PIP

manager Verbal Warning Warning Letter to be initiated.
Circle head/SBM NA Verbal warning Warning Letter

Warning Letter+
PIP Initiation + PE Services may be
Employees rating will be IR. terminated. NA
Level 3

Warning Letter +
Team Lea/Line PIP Initiation + PE Services may be
manager Warning Letter. rating will be IR. terminated.
Warning Letter + PIP
Warning Letter + Initiation + PE rating
Circle head/SBM Verbal warning. PIP Initiation. will be IR.

Employees NA NA NA
Fatalities/Grave

Team Lead/Line Services may be

manager terminated NA NA
Injuries

Warning letter.PIP
will be initiated. Services may be
Circle head/SBM Rating will be IR. terminated. NA

Human Resource Policy

OHS Consequence management matrix
Version 1.0
For internal use © Nokia Solutions and Networks 2014