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21.0 ENVIRONMENTAL MANAGEMENT PROGRAM

21.1 PURPOSE

The purpose of this document is to outline responsibilities and provide guidance on the use,
storage, maintenance, and disposal of wastes in the Project Sites to have a safe & green
Environment.

These guidelines describe the principal precautions required to be taken by all personnel
and apply to all company work sites.

21.2 MANAGEMENT COMMITMENT

Al- Amara International is committed to be a leader in the industry in maintaining the
environment through:

 Minimizing waste and maximizing recycling.

 Meeting or exceeding all the environmental legislation that relates to the Company.
 Promoting greener and cleaner environment for all.
 Promoting to improve environmental performance and limiting impacts from our
operations, through awareness programs, trainings, surveillance audits, etc.
Management Review is an essential tool to ensure the continual improvement of the
Environmental Management. The management review process ensures that the necessary
information is collected to allow the management to carry out this evaluation. These reviews
enable the management to have necessary information for carrying out the evaluation. A
Management Review includes all environmental potentialities for organizational activities,
products, and services. This also includes the financial impacts of these potentialities and addresses
the environmental concerns related to business opportunity.

21.3 MANAGEMENT REVIEW MEETING

The MR plans for conducting the review meeting. The review team consists of all in the top
management including staff with relevant information, and staff who have direct
responsibilities to discharge in fulfilling the EMS requirements. The management review
should take place minimum twice a year. MR will facilitate the meeting supported by the
Corporate HSE Advisor.

Main objectives

The main objective of the review is to ensure that:

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 Top management is involved in the process.

 Results are being documented.
 There is a follow-up procedure for actions resulted by the review.
 There is an effectiveness of the EMS in meeting targets and objectives of the System.
 Corrective measures are in place to solve identified problems.
 The need for changes in policy, objectives, and other elements of the EMS.
 The extent of compliance or non-compliance to the EMS standard.
 There is a financial efficacy of the EMS implementation.

Procedure

The agenda should include review of instances of non-conformance, corrective actions,

continuous improvements associated with the EMS, results of compliance and EMS Audits,
complaints, results of any pollution prevention programs, waste minimization programs, etc.

Review should include the overall effectiveness of the EMS in meeting targets and objectives
of the system

The results of the review shall be used to determine modifications to the EMS required for
continuous improvement

Review process should include:

 The assessment of company personnel`s compliance with policy and procedures
using audits reports.
 Checking the status of implementation of the recommendations concerning the EMS
in Audits and other reviews and their implementation.
 Assessing the achievement of targets, objectives, and environmental performance
indicators, to establish their continued suitability.
 To verify the regulatory compliance and determine root causes of systematic non-
conformance

21.4 ENVIRONMENTAL AUDIT

An Environmental Audit, in general, is a management tool comprising a systematic, documented,

periodic, and objective evaluation of how well the environmental management system [EMS] is
performing. Industrial activities are usually subjects to regulations and permits intended to limit
their impact on the environment, for example, consent levels for effluent discharges, emissions to
air and waste disposal. Environmental audit, thus, includes a comprehensive review of all the
elements included in the EMS. Internal or external resources may conduct the environmental audit.
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Based on the company environmental audit program, internal and external audits are carried out

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according to an appropriate time schedule. Generally, the internal audits are conducted at a higher
frequency.

Objectives

 Ascertain whether company operations are in compliance with its policy and meet the
requirements of laws, regulations, permits and self-imposed standards
 Assess the quality and effectiveness of the implementation of the Environmental
Management System [EMS].
 Ascertain whether the environmental policies and procedures are clearly defined and
the roles and responsibilities of individual staff are assigned throughout the
organization
 Recognize in a proper time the potential liabilities resulting from the company’s
environmental performance to place effective control measures to avoid or minimize
such liabilities

 Identify gaps in the implementation of EMS with respect to ISO 14001 certification for
the top management review for taking necessary measures

Pre-Audit Requirements

The Minimum number of internal audit shall be once in six-month time preferably prior to a
Management Review.

Formation of Audit Team

The number of team members will vary depending on the scope, complexity, and size of the
facility to be audited and typically ranges from 2 to 5. The team members shall be
technically qualified, appropriately experienced, and trained in auditing to provide a
balanced and realistic appraisal.

Provision of a Site Representative

It is advisable to nominate a site representative for co-coordinating the preparation of the

pre-visit information package, and setting up of meetings, interviews, and visits throughout
the audit period. The site representative can be very valuable in identifying problems and
providing explanations of situations not always obvious to outsiders.
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Visit Program

Once the Project Site has provided the information package, the team reviews the
information, identifies the concern areas, and develops the visit program. The program
outlines the necessary steps; by whom and what sequence and the way in which these will
be accomplished. The visit program identifies the key employees to be interviewed, the
facilities to be inspected and the documents to be referred. Based on expertise and
experience, tasks will be allocated to specific audit team members.

Inspection of Facilities

The audit team visits the relevant operational sites and facilities including discharge
locations, the receiving environments. The team will cover, along with other matters, the
operational practice and procedures, the quality of effluent, the emission monitoring and
analysis, the facilities and the quality of waste disposal, housekeeping, performance of
equipment, etc.

Evaluation of audit findings

At regular intervals, between and after, interviews and inspections the full audit team will
meet and discuss the findings. The team will evaluate and verify the findings were
considered necessary and assess the significance of each deficiency or pattern of
deficiencies. Such a rating should be based on the observed level of environmental
management control. For each finding requiring change or improvement, the team will
develop a recommendation.

Draft Audit Report

The audit report provides a survey of observations of areas for improvement. The
recommendations will be grouped and ranked in order of priority. The audit team should
normally complete a draft audit report during their visit.

Audit Report

Following the site visit, the audit reports shall be prepared as soon as possible, taking into
account comments made during the debriefing meeting. The audit report will be sent to
Company management.
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Follow-Up

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After the audit report is sent to the Project site, it is their responsibility to implement the
recommendations. Clearly, the value of the audit depends on active and purposeful follow-
up.

Implementation of Recommendations

A suitable manner to implement the audit recommendations is the development of a

specific audit follow-up plan with timetable, which reflects the priority, indicated by the
audit team. In addition, the audit recommendations may require the development or
updating of the company environmental action plan. Defining yearly targets and the
preparation of a quarterly progress report are considered valuable to achieve and monitor
the necessary progress. The Company management shall monitor the progress.

21.5 WASTE MANAGEMENT

The major waste streams are identified as follows:

 Construction Wastes (Non-Hazardous Wastes): Wastes generated at project sites shall

be collected and dumped at Municipality approved dumping areas.

 Contaminated wastes (Hazardous Wastes): Contaminated wastes at project sites shall

be delivered to treatment plants.

21.6 SPILL PREVENTING PROGRAM

Spill Prevention Program shall be prepared according to the site specific conditions,
depending on the nature and conditions of the project.

Normal procedures to avoid spillage are:

 Transfer / filling of paints / chemicals / fuel / oil are restricted at work sites and shall
be done at designated areas only.
 Separate area shall be identified for these types of activities, especially for
maintenance of equipments.
 Under unavoidable circumstances, (equipment breakdowns etc.) proper precautions
such as pans shall be provided to prevent spillage.

Material Safety Data Sheets shall be available and displayed at the project site.
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