HES POLICY

HEALTH, SAFETY & ENVIRONMENT POLICY

SHROMB GEOTECHNICAL LTD consider health, safety, respect for the environment
and safeguarding of assets as essential to efficient operation and the welfare of our
employees, contractors and other stakeholders. We are committed to having an HSE
management system in place which recognizes the fact that safe operation depend not only
on technically sound facilities and equipment, but also on competent and a pro-active HSE
culture.

It is our policy to.

 Maintain safe operations as regard our activities and services in all forms. Providing
Project and Engineering support services covering Mechanical and civil engineering
/construction services, pipeline construction, marine transportation and supply etc.
 Comply with all legal requirements, international standard as well as adopting safe
approach toward incident prevention.
 Implementing a pro-active risk management process and monitoring effective
programs/plans to protect our employees, clients, host community on a regular
basis to ensure they are not adversely affected by our operations.
 To provide all the needed information, instruction and training for employees,
contractors and stakeholders on our HSE requirement and abide by them.
 Conduct internal audits and periodic reviews, backed by third party audits to
identify shortfalls and possible areas of improvement.
 Pursue continuous improvement in the measures taken to protect the health, safety
of employees, clients and stakeholders through hazards identification and risk
assessment and management review process.
 Recognize and rewards those who contribute to improved HSE performance.
 Minimize our Impart on the environment through pollution prevention and proper
management of our waste.

With the continuous dedication of all personnel, we will achieve these objectives. I will personally
ensure that these objective are met

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 1 of 17
 HES POLICY

OCCUPATIONAL HEALTH POLICY

It is SHROMB GEOTECHNICAL LTD belief that workforce is an employer’s greatest asset,

and a healthy workforce is a pre-requisite for industrial efficiency.
SHROMB GEOTECHNICAL LTD shall maintain an insurance against any liability that may
result in the event of any personnel suffering occupational hazard or any impairment of
health.
Company’s retained Clinic shall handle all routine medicals and medical emergencies.
SHROMB GEOTECHNICAL LTD shall ensure that workers attain and maintain high level
of well being and work collaboratively with fellow workers, their families, regulatory
agencies, community agencies and other occupational safety and health professionals.
First-Aid Box manned by a competent FIRST AIDER must be provided for field operations.
Records of medication or injuries treated MUST be document

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 2 of 17
 HES POLICY

ALCOHOL, DRUGS AND WEAPONS POLICY

The following is company policy concerning alcohol, illegal drugs and dangerous weapons.
No alcohol, illegal drugs and possession of dangerous weapons is allowed in any of our
locations.
Without prior notice, SHROMB GEOTECHNICAL LTD will conduct periodic searches and
screening of employees’ effects and lockers to ensure that no one is in possession of such
illegal or unauthorized items.
Employees will be required to submit to periodic alcohol and drug test (URINALYSIS OR
BLOOD TEST) or when specific circumstances warrant, workers will be tested according to
DOT regulations for alcohol.
Any violation of this policy will result in appropriate disciplinary action, which may include
termination

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 3 of 17
 HES POLICY

NO SMOKING POLICY

Smoking is not only injurious to health but also a potential safety hazard. Smoking

in public places exposes non-smokers to health related hazards. It is the duty of

SHROMB GEOTECHNICAL LTD to protect employees from unnecessary exposure

to such hazards.

The smoking of cigarettes or pipes is prohibited at all oil installation and

construction sites.

This ban also includes all conference/meeting rooms, corridors and public areas

and shared offices, unless otherwise agreed between all occupants of such offices.

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 4 of 17
 HES POLICY

HSE AUDIT POLICY

Due to the sophistication of our equipment, work tools and the nature of operations coupled

with man’s imperfection, unsafe acts and conditions are inevitable. These acts and

conditions, if not observed, checked and controlled or completely eliminated, can result in

accidents.

SHROMB GEOTECHNICAL LTD recognizes this fact and therefore has it as a policy to

carry out monthly HSE AUDITS on all its work sites and operations.

For every project, quarterly HSE AUDIT shall be performed jointly by SHROMB

GEOTECHNICAL LTD Project Manager and the client’s representative.

It is the responsibility of all the safety officers to carry out HSE AUDITS both inside and

outside their department’s area of operation and report to their immediate supervisor.

All workforces are required to read, understand and abide by this policy.

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 5 of 17
 HES POLICY

SEAT BELT POLICY

In SHROMB GEOTECHNICAL LIMITED Safety Belt is an employee’s (Drivers and

Operators) best chance of surviving an automobile collision or accidents, and can reduce
the risk of moderate, serious or fatal injuries in a crash as much as 60%.
It is therefore mandatory by this policy that every worker whose work demands the use of
Safety Belts wear them especially while on company’s business and must be properly
buckled always, as safeguard against any unwanted event.

All light crafts and heavy-duty crafts such as trucks, tractors, forklifts etc must have seat
belts fitted in them for use by the drivers or operators. The back seats of all lights crafts
shall additionally be fitted with seat belts.
The “NO SEAT BELTS, NO EXIT” rule shall be enforced at the gate or point of entry into
the company premises or facilities by Security Officers. They should carry out visual
inspections on any company / other vehicles entering or leaving the premises to ensure all
occupants comply with the directive.

Safety Officers are empowered to stop any operation wherein there is an obvious breach of
this policy.
Foremen, Supervisors and indeed other members of line management shall monitor and
ensure that everyone in company owned vehicles fastens his/her seat belt as required.
Appropriate disciplinary action may be taken against any staff that violates this policy
directive.

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 6 of 17
 HES POLICY
EQUIPMENT MAINTENANCE POLICY
SHROMB GEOTECHNICAL LTD will regularly maintain all equipment required for her
operations. All unserviceable equipment shall be locked out and tagged as thus.
Routine maintenance and minor repairs shall be undertaken at work site, while serious
maintenance of completely broken down equipment shall be done at the base.
Turn around maintenance shall be planned and executed twice a year; the aim being to put
all equipment in serviceable order for hitch-free operation.
It is mandatory that operators report and log immediately any breakdown or faults observed
in their equipment.
Toolbox meeting on proposed equipment maintenance MUST precede the maintenance
work plan for each day.
Repairs/Modification/Maintenance/Servicing shall be restricted to those who must have
received adequate training.
All maintenance shall be carried out in accordance with company’s safety maintenance
procedures. The maintenance crew must be briefed before each maintenance episode.
The implementation of the maintenance policy shall be the responsibility of the
Workshop/Maintenance Supervisor, who should report to the Operations Manager

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 7 of 17
 HES POLICY

SECURITY POLICY

SHROMB GEOTECHNICAL LTD has it as a policy and function to manage Security Affairs
as an integral part of overall HSE program are indeed part of the company business so as
to minimize the number of security related incidents for all staff, clients and third party
personnel involved in her operations.
In order to ensure the security of personnel, equipment and material in all our operations,
SHROMB GEOTECHNICAL LTD maintains a combined team of locally trained security
guards.
This security provision is not limited to project sites alone but also extended to all
equipment, personnel and materials in transit.
Essential work gadgets such as walkie-talkie, torches, and uniforms shall be provided to
enhance their services.
Independent security training shall be organized from time to time to update the workers in
security measures.
Adequate security devices such as demobilizer and radio equipment shall be provided in
project vehicle and other equipment.
All security defaults shall be reported, investigated and action taken to prevent re-Signed

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 8 of 17
 HES POLICY

ENVIRONMENTAL PROTECTION POLICY

SHROMB GEOTECHNICAL LTD shall carry out her activities in such a way as to minimize
any adverse effects or impact on the environment in which she carries out her operations.
SHROMB GEOTECHNICAL LTD shall promote and encourage plans; activities and
programs aimed at environmental preservations and protection.

SHROMB GEOTECHNICAL LTD Staff shall be trained and encouraged to perform their
work in an environmentally sound manner.
i The employee shall not knowingly discharge oil into the environment. The wastes
generated in course of our operations must be collected, handled, treated and
disposed of, in an environmentally sound manner.
ii ALL spills regardless of volume spilled shall be contained and reported to your
supervisor.
iii NO sanitary waste shall be discharged on land or in swamp locations unless properly
treated.
In order to improve the quality of life in host communities, SHROMB GEOTECHNICAL LTD
shall establish community development assistance on activities having high impact and
broad benefits for the host communities.
Encourage the full participation of host communities in execution of works.
Maintain communication with all social segments of host communities in order to address
their needs.
Have a systematic approach to HSE management designed to ensure compliance with the
law and to achieve continuous performance improvement
Set targets for improvement and measures, appraisals and report performance
Includes HSE performance in the appraisal of all staff and rewards accordingly.

“THE ENVIRONMENT IS OUR COMMON HOME”

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 9 of 17
 HES POLICY

PROCEDURES POLICY

It is the policy of SHROMB GEOTECHNICAL LTD to have in place for all her operation,

documented, structured and up-to-date procedures which give simple but effective

instruction to staff on “TECHNICAL KNOW HOW” of their tasks following best practices

embodied in company policies.

It is the responsibility of line supervisor and staff to identify the need for procedure

documentation and/or review in our own business area and to liaise with the HSE

Department to carry out same.

It is the responsibility of each staff to adhere strictly to company approved procedure

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 10 of 17
 HES POLICY

ACCESS POLICY
It is the policy of SHROMB GEOTECHNICAL LTD that all visitors to any location (including
the base) where the company carries out its activities must adhere to the guidelines
stipulated at points of entry so as to safeguard life and property.

To ensure the implementation of this policy, access will be granted at entry points to
company facilities only when:

i Seat Belts are worn at the point of entry/exit. The “NO seat belt, No
Entry/Exit” rule shall be enforced at gates leading to company’s premises.

ii Valid Swimming Passes are presented at points of entry into any

swamp/off-shore location.

iii Proper logging and issuance of visitors/contractors passes is done at the gate

iv Appropriate Personal Protective Equipment (PPE) is worn before entry.

v Identification is shown by either employees or client’s representatives.

vi Properties are declared at entry points to company facilities (including spreads) and
personnel submit themselves for proper indoctrination.
Access will be denied in the event that there is non-compliance with any of the above.

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 11 of 17
 HES POLICY

STOP WORK POLICY

ALL OPERATIONS OF SHROMB GEOTECHNICAL LTD SHALL BE PLANNED AND
EXECUTED IN SUCH A WAY AS TO:

i PREVENT INJURY
ii ENSURE SAFETY AND SECURITY OF EMPLOYEES’ LIVES AND PROPERTY
iii MINIMIZE ANY ADVERSE EFFECTS ON THE ENVIRONMENT.

EVERY EMPLOYEE OF SHROMB GEOTECHNICAL LTD SHALL THEREFORE

PERFORM HIS/HER WORK IN ACCORDANCE WITH THIS POLICY.

WORK MUST NOT START OR MUST BE SUSPENDED WHEN IT IS BELIEVED THAT

ESSENTIAL SAFETY SYSTEMS ARE NOT IN PLACE

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 12 of 17
 HES POLICY

TRANSPORTATION POLICY
SHROMB GEOTECHNICAL LTD has it as a Policy to provide and manage transportation
services in such a manner as to minimize exposure of personnel, assets and environment
to risk.

All transportation facilities such as vehicles and boats shall be maintained in line suitable to
provide safe and efficient services for company and third party personnel at all time.

Journey management plans are prepared for all transportation while the use of seat belt in
vehicles and life jackets in our boats are mandatory practice from the management down
below to the least crew member of our organization.

All form of flagrant disregard or omission and commission by driver are consequently frown
upon by the management .Drivers are made to understand that the safe practices in the
discharge of their business is the reason why they are been paid. The management frame-
up these action through annual reward to safe practices drivers and penalize those who
neglect lay downs rules. We shall continue to accord transportation issue with its deserved
priorities.

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 13 of 17
 HES POLICY

POLICY ON USE OF SEAT BELT

Seat belts are provided for the safety of drivers and also for the passengers in all vehicles.
It is mandatory for all employees to put on seat belts at all times while on company business.
It is our policy that:
NO SEAT BELT NO ENTRY NO TAKES OFF.
To ensure compliance to this policy directive, all drivers should prior to take off have their seat belts
fastened at all times and remind their passengers to do same by simply announcing: fasten your
seat belts.
The security officers at both the site and company premises gates should carry out visual
inspections of any company or other vehicles entering or leaving the premises to ensure all
occupants comply to this directive.
The security officers should bar any vehicle from leaving or entering the premises until all
occupants of the vehicle have complied with the directive
While in the premises or work sites, it is the responsibility of the safety officer, foreman, supervisor
ad indeed any member of line management present to monitor and ensure that every one in
company owned vehicle fastens his/her seat belts.
Appropriate disciplinary action may be taken against any staff that violates this policy directive.

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 14 of 17
 HES POLICY

PROCEDURES POLICY

It is the policy of SHROMB GEOTECHNICAL LTD to have in place for all her
operation a documented, structured and up-to-date procedures which give simple
but effective instruction to staff on “TECHNICAL KNOW HOW” of their tasks
following best practices as embodied in company policies.

It is the responsibility of line supervisor and staff to identify the need for procedure
documentation and/or review in our own business area and to liaise with the HSE
Department to carry out same.
It is the responsibility of each staff to adhere strictly to company approved
procedure

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 15 of 17
 HES POLICY
EMERGENCY RESPONSE POLICY
SHROMB GEOTECHNICAL LTD believes that ‘Safety is everybody’s businesses. Thus
all reasonable measures are taken to prevent the occurrence of an unwanted event. All
such measures form part of the company’s safety policy and operations guidelines, which
are already being propagated in our operations.
However, after all efforts to prevent the occurrence of an unwanted event, accidents may
still happen. Primarily, first aid and medical evacuation procedures are in place in our
company’s safety policy manual. But accidents occur in varying forms and are of varying
magnitude. Some could even result in sudden change in the condition of either the human
or material resources of an organization, and apart from disrupting normal operation, could
result in more damage to the human and material resources of an organization. This could
be identified as crises or an emergency situation.
In order to avoid more damage resulting from confusion and stampede, also to prevent
the crises situation from escalating, it is wise to identify specific emergencies for crises
situations for which specific plan of action could be drawn.
All such plans must be practicable within the limits of human and material resources, and
must be aimed at:
1. Saving life
2. Minimizing pain and suffering
3. Minimize waste on normal operation
4. Restore normal operation

All the emergency plans are directed towards realizing maximum assistance at the
shortest possible time, and ensure that all services likely to be involved or affected are
informed within the shortest possible time. An orderly and effective response to the
measure in place is of vital importance for achieving desired results.

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 16 of 17
 HES POLICY
ENFORCEMENT OF DISCIPLINE POLICY

VERBAL WARNING: Any worker who VIOLATES HSES rules knowingly or unknowing shall
be called to order and verbally warned.

STEP II.
QUERY: Any worker who breaks company HSES rules despite the previous warning shall be
written to explain why a disciplinary action should not be carried out against him/her. The query
should be answered in black and white and must be received within 24 hours.

STEP III.
SUSPENSION: If the explanations given were not satisfactory, the worker shall be made to
proceed on a given period of suspension as defined in the suspension letter. He shall lose all his
entitlement within the period of suspension. After the suspension period, his entitlement shall be
restored.

STEP IV.
DISMISSAL: The worker shall be dismissed if he continues to flout company HSES rules (after he
might have been suspended). Any worker dismissed in this regard shall not be entitled to any
benefit.

REV-01
Signed and Authorized by

KOLAWALE ONI
General Manager
Issue Date 20TH August 2021

Page 17 of 17