Confidential

Health and Safety

Consequence Management
for Sub-contractor

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Introduction
Nokia Networks Health and Safety (H&S) Consequence Management is a policy for Sub-contractor/sub-
contractors supplying equipment and /or rendering services. Sub-contractor understands that Sub-contractor
failing to demonstrate robust safety management during the duration of their contract will face adverse
consequences to business relationship with Nokia and might lead to termination of Sub-contractor contract.
Aim
In addition to the requirement stipulated in the contract, this policy aims to address Sub-contractor’s
noncompliance to H&S requirements, H&S incidents, unsafe acts or conditions and provide a visible
approach, through the usage of CMM, to encourage and reinforce safe and ethical behavior among the supply
chain.

Scope
The CMM is applicable to all Sub-contractor, service providers, consultants, and / or vendors who are
engaged by Nokia, CO India, with effect from 1st April 2017.

Responsibilities
The Management of the Sub-contractor shall ensure that resources are in place for the implementation of the
Nokia H&S related requirements.
Nokia DO is responsible for communication of Nokia Health and Safety Requirements to the Sub-contractor.
Sub-contractor to ensure :
 Communication of the Nokia H&S requirement to all Sub-contractor employees and its staff in their
respective functions working on Nokia projects;
 Understanding of the CMM actions by Sub-contractor employees and staff working on Nokia projects,
as applicable.
 Compliance with H&S Requirement in line with the requirement stated herein and the contract.
 Appropriate actions are taken as per this policy if cases of violation are observed;
 Participation in the OHS Compliance committee when required;
Sub-contractor needs to ensure its employees and associates are complying to Nokia H&S requirements
herein and in the contract with Nokia during their delivery of services on Nokia projects. It is therefore very
important that the Sub-contractor has to be proactive in identifying situations where the rules could be violated
and takes appropriate corrective action.
In case the Sub-contractor fails in their duties then he / she would be liable to be taken action on as per this
policy and their contract with Nokia.
In case of any alleged violation of Nokia H&S requirements by any Sub-contractor and/or their employee,
Sub-contractor shall immediately investigate such incident and promptly provide Nokia with report of such
investigation
OHS Compliance Committee shall consist of the MN GS India Head, India DO Head, relevant COM / BL
Head, India region Legal Head and India GS OHS Head, or their authorized representatives. India GS OHS
Head shall be the convener of this committee.
Guideline and Requirements
The violation of Nokia Health and Safety Requirements have been categorized as follows: -

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Annexure 1(a)
OHS Non-compliance severity level matrix
Work/
NON-Compliance Severity Level
Action
Supervisor of the Sub-contractor did not restrict the W@H while
dangerous insects (honey bees), birds or animals (snakes, monkeys, Level 1
etc.) available at tower, which could put the climber at risk.
Minimum of two trained individual not available on site for all W@H to
Level 1
issue work permit, monitor the job and support in case of emergencies.
Nokia approved (EN Standard) PPE not used for W@H. Level 1
First Aid kit not available with the team while work in Progress. Level 1
Risk assessment not carried out before start the work Level 1
Toolbox talk not carried out at site before starting the W@H. Level 1
Personnel who W@H not certified medically fit by a medical
Level 1
Work at practitioner.
Height
Engineer/Rigger/Technician not having appropriate age, qualification
and experience. (Defined in Health & Safety Requirements for Sub- Level 1
contractor)
W@H carried out during poor weather condition or restricted hours of
Level 1
darkness
Working at height carried without approved Full body harness (EN
Level 2
Standard)
Rigger/Climber not attached to the structure through full body
Level 3
harness/fall arrester while W@H
Proper barricading / cordoning and access control not done Level 1
Lifting operation not done by trained, competent and qualified persons
Level 1
(Defined in Health & Safety Requirements for Sub-contractor)
Lifting Lifting activity not supervised by competent person Level 1
Operation
Work permit process not followed Level 1
Nokia approved (EN Standard) PPE’s not used Level 1

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Annexure 1(b)
OHS noncompliance severity level matrix
Work/
NON-Compliance Severity Level
Action
Emergency contact no. not available in the vehicle or with the
Level 1
driver/rider (4W/2W)
Level 1
Pre-use inspection of vehicle not done
Drivers carrying unauthorized passengers Level 1
Head rest not available for all the seats Level 1
Driver not take 20-minute break after 3 hours of continuous driving. Level 1
SUV vehicle not used for Highway and Night Travel Level 1
Driver/Rider not aware on Nokia Road Safety Rules. Level 1
Four Wheelers Vehicles hired for Nokia requirements are not less than
Level 1
6 years
Vehicles not fitted with appropriate level of safety equipment, in
Level 1
particular retractable seat belt for every passenger

Bulky object transported in 2 wheeler vehicle Level 1

Carrying of passengers in the back of pick-up trucks. Level 1
Road Driver not medically fit to drive. Level 1
Safety
Driving for more than 8 hours (4 wheelers), or 6 hours (2 wheelers) in
Level 1
any 24-hour period.
Driving for Nokia business purposes in restricted hours (times after 10
Level 1
pm and before 05 am) without approval from Nokia Circle Head.
Transport vehicle carry unauthorized goods (other than goods
designated by Nokia) or unauthorized person till the completion of their Level 1
entire journey
Transport vehicle driver not followed applicable law for the respective
Level 1
location
Transport service provider/agency not trained in handling emergency
Level 1
situations arising during the journey.
Rider / pillion not wearing ISI marked/full faced helmet Level 2
Not wearing seat belt while in four wheelers. (any seat) Level 2
Rider / pillion rider not wearing reflective wear while travelling for work on Level 2
a two wheeler

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Use of mobile phone i.e. hands free / texting / listening music /

Level 2
speaker phone / blue tooth while riding / driving

Over speeding/Rash Driving. (Speed limit will depend on the road

Level 2
rules as applicable)

Rider / pillion or either-or person not wearing chin strap on helmet. Level 2

Riding without a valid driving license / with learner’s license. Level 3

Driving without appropriate grade of license Level 3

Driving under the influence of alcohol or illegal issues. Level 3

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

Annexure 1(c)
OHS Non-compliance severity level matrix
Work/
NON-Compliance Severity Level
Action

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 Level 1

emergency and list of emergency contact numbers not available.
Electrical equipment’s not fit for intended purpose/environment. Level 1
First Aid kit not available Level 1
Working on electrical equipment without authority. Level 1
Electrical Personnel who is working on electrical equipment not certified
Level 1
Safety medically fit by a medical practitioner
Prior to start of work, risk assessment not carried out at the site. Level 1
Working on 'live' electrical equipment without approval. Level 1
Working on electrical equipment without required competency
(qualification/experience) (Defined in Health & Safety Requirements Level 3
for Sub-contractor)

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Annexure 1(d)
OHS Non-compliance severity level matrix

Work/ Action NON-Compliance Severity Level

Initiation of work at site without conducting the risk assessment. Level 1

Initiation of Project without H&S Plan. Level 1

H&S documentation not filled up & kept at site while WIP. Level 1
WFM tool not followed to work at site Level 1

H&S Audit Checklist not followed during handover and takeover of

Level 1
site.

RF Safety policy not followed Level 1

Product/Equipment safety policy not followed Level 1

H&S assessment of Sub-con not done Level 1

Communication of Nokia OHS requirements and contractual Level 1

agreement to sub-contractor not done (with appropriate contractual
New
performance management mechanism)
Project/MS
Regular monitoring and review of OHS performance of Sub-con not Level 1
done
PPE’s are not re-checked by authorized personal at an optimum
Level 1
frequency.
Id card and proper clothes not available with the
Level 1
Rigger/Climber/Technician/Engineer at site.

OHS Induction training program not conducted before start the work Level 1

Untrained & Incompetent person personnel work on heights, electric

Level 3
systems, RF energy installations and underground / cabling work

Child Labour was found on site Level 3

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Annexure 2
Additional High Potential issues where CMM would
be applied for suppliers / vendors in case of any
violations

Sl. No Management system / Policy failure

1 Subcontracting beyond approved tiers and non-communication of Nokia standards and expectations
2 Failure to ensure adequate risk controls and Nokia requirements in the safety plan
3 Failing to ensure supervision of high-risk job as per set standards and safety plan
4 Non-adherence to Permit to Work process for high risk jobs
5 No back to back contract with subcontractors on HSW
6 Failure to comply to Nokia design standards and processes - e.g. Electrical, Civil
7 Not reporting a Hi Po / Major / Fatal incident within timelines
Key Risk areas:
A. Road
1 Unsafe/non-compliant /inappropriate vehicle as per set Nokia standards
2 Untrained driver as per Nokia approved standards
3 Failure to follow road travel rules and all emergency response procedure
4 2W usage during restricted hours on highways (exception commuting, patroller and city limit travels)
5 Unauthorized journey – Route deviation, Vehicle/Driver change/ night travel without approval /
permit
6 Picking up unauthorized passengers or travelling using unauthorized mode of transport.
7 No Telematics in vehicle used for Nokia projects and operations
B. Height & Lifting
1 Usage of damaged PPE e.g. Harness, lanyards, karabiners etc.
2 Failure to ensure trained Rigger & Supervisor
3 Mismatch between Permit to Work and risk or person working at site
4 Use of lifting devices without a valid certification / damaged tools
C. Electrical
1 Failure to comply on lock out tag out or isolate
2 Rendering Fire prevention and other safety devices defunct – e.g. SPD, ELCB, FASH, DLAFSS etc.
(not applicable on IP sites)
3 Working without Personal Protective Equipment, damaged or non-Nokia approved PPE
4 Failure to ensure trained person as per Nokia standard
D. Cables in the ground
1 Failure to ensure warning, barricading & cordoning off endangering team & public safety
2 Work without requisite Right of Way / permissions from relevant authorities
3 Damage to utility/buried utility services like gas pipe line, High tension electrical cable while
trenching

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OHS Non-compliance Consequence Management Matrix
for action to be taken on the Sub-contractor
Severity 1st Non-Compliance
Sub-contractor will submit a
declaration on Corrective Action issued by Nokia
& Preventive Action in 3 days and
demonstrate Action within 7 days.
Level 1
# Sub-contractor will submit a
declaration on Corrective Action
& Preventive Action in 3 days and
demonstrate Action within 7 days.
Level 2
# Written warning shall be
issued.
# Sub-contractor will submit a
declaration on Corrective Action
& Preventive Action in 3 days
and demonstrate Action within 7
days.
Level 3 # Sub-contractor to be
suspended till they are cleared
by OHS Compliance Committee
after due scrutiny.
# Written warning shall be
issued.
High # Written warning shall be
Potential issued, and Nokia procurement
will issue show cause notice for
Hipo violation and conduct
meeting with supplier.
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Annexure 3
2nd Non-Compliance
Written warning shall be
# 4% PO value of previous
quarter business in the
respective Circle shall be
deducted.
# Sub-contractor may not be
given any further business
for upto next 30 days in the
respective Circle.
# 8% PO value of previous
quarter business in the
respective Circle shall be
deducted.
# Sub-contractor may not be
given any further business
for upto 90 days in the
respective Circle.
# 4% PO value of previous
quarter business in the
respective Circle shall be
deducted.
# Sub-contractor may not
be given any further
business for upto next 90
days in the respective
Circle.
3rd Non-
Compliance
# 4% PO value of previous
quarter business in the
respective Circle shall be
deducted.
# Sub-contractor may not be
given any further business
for upto next 30 days in the
respective Circle.
# Additional 4% PO value of
previous quarter business in
the respective Circle shall be
deducted.
# Sub-contractor may not be
given any further business for
up to next 90 days in the
respective Circle.
# OHS Compliance
Committee to decide on
terminating the Sub-
contractor contract and
blacklisting for up to 1 year.
# 8% PO value of previous
quarter business in the
respective Circle shall be
deducted.
# OHS Compliance
Committee to decide on
terminating the Sub-
contractor contract and
blacklisting for up to 6
months.
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CRITICAL INCIDENT FATALITY

# OHS Compliance Committee to decide on
# OHS Compliance Committee to decide on
terminating the services and blacklist for upto 2
terminating the services and blacklist for upto
years.
Accident 01 years
# Additional penalty of INR 10 lacs per instance
# INR 05 lacs per instance on the Sub-
on the insurance covers and the statutory
contractor, on top of the insurance covers
benefit that are due to the kin of the deceased /
and the statutory benefit that are due to the
incapacitated employee from the Sub-
kin of the deceased / incapacitated employee
contractor.
from the Sub- contractor.

Notes: -

 Supplier CMM - will be applicable to the Supplier in individual circle. Termination of unique supplier in
any of the circles may lead to India level blacklisting for the Supplier.
 For Suppliers the CMM violations would be accumulated & carried forward for a period of 3 months.

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