Health, Safety and Environment Policy Manual

Sharda Centre, Off Karve Road, Erandwane, Pune, Maharashtra, India 411004

www.techmahindra.com

Copyright © 2013, Tech Mahindra. All rights reserved.

Company-Confidential

HSE Policy Manual

Table of Contents 1 1.1 2

GENERAL .................................................................................................................................................... 3 SCOPE ............................................................................................................................................................ 3

REFERENCE............................................................................................................................................... 3

2.1

STANDARDS ............................................................................................................................................

4

2.2

GUIDELINES ............................................................................................................................................

4

2.3

MANUALS ................................................................................................................................................

4

3

DEFINITIONS AND ABBREVIATIONS .................................................................................................. 4

4

HSE MANAGEMENT SYSTEM................................................................................................................ 6

4.1

GENERAL REQUIREMENTS ..................................................................................................................... 6

4.2

HSE POLICY........................................................................................................................................... 6

4.3

PLANNING .............................................................................................................................................. 7

4.3.1 PLANNING FOR ASPECTS/HAZARDS IDENTIFICATION IMPACT/RISK ASSESSMENT AND CONTROL .............. 7 4.3.2 LEGAL AND OTHER REQUIREMENTS ............................................................................................................ 8 4.3.3 HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT PROGRAMME(S) ................................................... 8 4.4 HSE R&R ....................................................................................................................................................... 9 4.4.1 TRAINING AND AWARENESS ............................................................................................................................. 10 4.4.2 COMMUNICATION ....................................................................................................................................... 11 4.4.3 EMERGENCY PREPAREDNESS AND RESPONSE ............................................................................................. 11 4.5 MONITORING AND MEASUREMENT ................................................................................................................ 12 4.5.1 EVALUATION OF COMPLIANCE ................................................................................................................... 12 4.5.2 ACCIDENTS, INCIDENTS, NON-CONFORMANCE’S AND CORRECTIVE AND PREVENTIVE ACTIONS ............. 12 4.5.3 CONTROL OF RECORDS ............................................................................................................................. 13 4.5.4 HSE INTERNAL AUDIT................................................................................................................................ 13 4.4

MANAGEMENT REVIEW .............................................................................................................................. 14

4.5

MANAGEMENT OF CHANGE .................................................................................................................. 14

4.6

APPENDIX............................................................................................................................................. 14

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Company-Confidential 1

HSE Policy Manual

GENERAL

This manual describes the HSE Policy of Tech Mahindra and is designed to ensure that all the requirements relating to HSE management system ISO 14001:2004 and OHSAS 18001:2007 are recognized. Purpose With the concern to protect the Environment and maintain the Health and Safety of our Associates, Investors, Customers and Society, Tech Mahindra has initiated a journey to be in compliance with international standards like ISO 14001 and OHSAS 18001 Compliance to HSE (Health, Safety and Environment) at Tech Mahindra is viewed as its responsibility for the future condition of our Environment and Health and Safety of AICS 1.1

SCOPE

The HSE Management System applies to operations related to Corporate Services & Human Resources, to facilitate software project execution at HSE certified locations. This has been designed to comply with the requirements of ISO 14001 and OHSAS 18001. Areas covered under Corporate Services are provided below: 1) Buildings and Surroundings 2) DG 3) HT/LT Panels 4) UPS 5) Transportation 6) Transformer 7) Cafeteria 8) RO Plant 9) STP 10) TIM Server Room 11) AHU Room 12) Lifts 13) Chiller Yard 14) Housekeeping 15) Stores 16) Solid Waste yard 17) HR

2

REFERENCE

Following is the list of references, which includes Standard, Manuals, plans and applicable legal requirements and other requirements used in developing and implementing the HSE system.

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2.1

STANDARDS

  2.2

ISO 14001:2004 Environmental Management Systems (Requirements with Guidance for Use) OHSAS 18001:2007 Occupation Health and Safety Assessment Series GUIDELINES

 

2.3

ISO 19011:2002 Guidelines for HSE Management Systems Auditing ISO 14004:2004 Environmental Management Systems (General Guidelines on Principles, System and support techniques) MANUALS



3

Quality Policy Manual

DEFINITIONS AND ABBREVIATIONS

Abbreviation / Acronym

Description

GH

Group Head

AICS

Associates, Investors, Customers and Society

ERT

Emergency Response Team

HSE

Health, Safety and Environment

IQA

Integrated Quality Audit

RPN Number

Risk Priority Number(Number obtained by the product of Severity, Occurrence and Detection)

TECH MAHINDRA

Tech Mahindra

MR

Management Representative

SEA

Significant Environmental Aspects

SEI

Significant Environmental Impacts

SOA

Statement of Applicability

QMS

Quality Management System

NC

Non Conformity

Acceptabl e Risk

Risk that has been controlled through meeting legal obligations, establishing and implementing appropriate control mechanisms and procedures to a level that it can be tolerated and does not offer severe hazard to health, safety and Environment Undesired event giving rise to death, ill health or injury

Accident Audit

Continual

A systematic examination to determine whether activities and related results conform to planned arrangements and whether these arrangements are implemented effectively and are suitable for archiving the organization’s policy and objectives Process of enhancing the HSE Management System, to achieve improvements in Business Management System

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Improvement

Environment, Occupational Health and Safety Performances ,in line with the Organization’s HSE Policy

Correctiv e Action

Action to eliminate the cause of a detected the non-conformity or action to reduce the severity, occurrence or improve the detection of any risk/impact

Danger

A state or condition in which the personal injury is reasonably foreseeable

Emergency

A serious situation or occurrence that happens unexpectedly and demands immediate action as it has the potential to seriously harm the health, safety of a group of associates or has the potential of large environmental impact.

Environment

Surroundings in which the organization operates including the air, water, land, natural resources, flora, fauna, humans and their interrelation

Environment al Aspect

Element of the organization’s activities or products or services that can interact with the environment

Environment al Impact

Any change to the environment ,whether adverse or beneficial ,wholly or partially resulting from the organization’s environmental aspects

Environment al Targets

Detailed performance requirement, applicable to the organization or parts thereof, that arises from the HSE objectives and that needs to be set and met in order to achieve those objectives Source or situation with a potential for harm and cause injury or ill health, impact the environment or a combination of these.

Hazard Health, Safety and Environment( HSE)

HSE Management System refers to policies, guidelines and practices followed by Tech Mahindra that focus on 1)Preventing harm to and promoting the health of employees and other stakeholders ;2)preventing any injuries at work both for our own employees and our contractors; and 3)protecting the environment by preventing or minimizing the environmental impact of our operations and activities.

HSE Objectives

HSE goals that are set at relevant functional areas consistent with the HSE Policy and review by the HSE Forum

HSE Performance

Measurement of the Environmental aspects and Impacts identified as part of the risk assessment and indicator of effectiveness of controls established

HSE Policy

Overall intentions and directions related to Health, Safety & Environmental performance at Tech Mahindra, formally expressed by top management

Instruction

Any verbal or written policy, procedure, safe system of work, code of practice or guidance relating to Health and Safety. Verbal instruction should normally be followed by in writing. Individual or groups outside Tech Mahindra concerned with or affected by the Health, Safety and Environment Management Systems performance of Tech Mahindra

Intereste d Parties Integrated Quality Audit

Systematic, independent and document process for obtaining audit evidence and evaluating it objectively to determine the extent to which the HSE Management System is complaint with the OHSAS 18001 and ISO 14001 standards

Mistake

A human action that can produce an unintended result

Non Conformity (NC)

Non-fulfillment of a requirement of the ISO 14001 and OHSAS 18001 standards

Occupationa l Health/Healt Occupation h al Risk

The overall condition of body or mind; freedom from disease or abnormality Combination of likelihood and consequence(s) of a specified event occurring which can be hazardous to Health of associates at work or in work related activities Business Management System

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Significan t Risk

A risk (Health, Safety and Environment) that can cause significant damage to the environment and has the potential to cause severe illness or injury

Preventiv e Action

Action to eliminate the cause of a potential nonconformity to HSE Policy

Qualifie d Worker

One who is accepted as having the necessary physical attributes and possesses the required intelligence, training and education, and has acquired the necessary skill and knowledge to carry out the work in hand to satisfy standards of safety, quantity and quality A risk is a combination of occurrence and severity of an abnormal event or failure and the consequences of that event or failure to an employee’s health, employee’s safety and the environment

Risk

Risk Acceptabl e Risk Control/Ris k Manageme Routine nt activitie s Nonroutine activities Normal operatin g conditio Abnorma n l operatin g BMS condition

4

4.1

Overall process of estimating the magnitude of the risk/Impact and deciding whether or not the risk /Impact is acceptable. Process of initiating action to eliminate or reduce the risk/Impact identified through risk assessment Routine Activities which are cyclic / repetitive in nature and are part of the regular schedule / job requirements that are non-cyclic / adhoc in nature and are performed on need basis basis only condition which prevails in the work area in general i.e. unexpected / extraneous factors are not in effect conditions which are not witnessed/perceived in the work place in general i.e. unprecedented s present in the work environment Business Management System

HSE MANAGEMENT SYSTEM

GENERAL REQUIREMENTS

Tech Mahindra has established, implemented and maintains the HSE Management System .HSE Management System has been designed to continuously assist in achieving the HSE objectives and ensures compliance to legal and other requirements within the scope given. The systematic approach to HSE promotes the efficient use of resources. Tech Mahindra commits to continually improve the effectiveness of HSE parameters, through and inflow of observations, surveys and results into the Risk Register. 4.2

HSE POLICY

Tech Mahindra is committed to provide healthy and safe working conditions to all its associates and is focused on minimizing damage to the environment, wherever it operates. This will be accomplished Business Management System

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HSE Policy Manual

through training, communication & performance measurement of identified HSE parameters and there by facilitating the continual improvement. Tech Mahindra shall strive to conduct its business in compliance with Legal regulations & other requirements and in line with interested party concerns. Tech Mahindra will systematically manage the occupational risks and environmental impact(s) identified and reported. To live up the HSE mindset, we shall work towards: •

Providing and maintaining a healthy workplace and lifestyle



Providing and maintaining safe equipment with appropriate safety training



Facilitating arrangements for associate safety while working



Minimize damage to the environment and complying with legal and other requirements.



Conducting operations to ensure efficient use of resources.

4.3

PLANNING

The following block diagram represents the planning function pertaining to HSE:

4.3.1 PLANNING FOR ASPECTS/HAZARDS IDENTIFICATION IMPACT/RISK ASSESSMENT AND CONTROL Tech Mahindra has established and maintains a Risk Assessment procedure that identifies potential hazardous activities as Risk that need to be monitored for HSE compliance. The procedure determines the significance of the Impacts and Risks identified, taking into account normal / abnormal operating conditions or routine and non-routine activities, as applicable to Tech Mahindra. It also ensures that the aspects/ hazards relating to these significant Impacts and Risks are considered in setting HSE objectives. (Ref SOA for Significance Evaluation of Environmental Aspect/Occupational health, Safety Hazards and Impacts/ Risk for details).

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Risk analysis is carried out to identify the Impacts/Hazards proactively by performing risk assessment of new activities, processes, equipment use or installations that are undertaken. Significant Impacts/Risks are prioritized and select improvement is initiated through management programs. Risk arising out of unsafe and/or human behavior and other human factors are identified as part of risk assessment and are addressed through Behavior Based safety and Health program. Identifying controls to reduce the risks will be carried out on the basis of the hierarchy of controls defined based on the severity of the risk. In case, any such hazard originating outside the workplace, capable of adversely affecting health and safety of associates (within TECH MAHINDRA premises) is identified, the same would be brought to the notice of the authorities concerned to address and rectify. If the same is not addressed within reasonable timelines, then the issue will be highlighted to the relevant stakeholders 4.3.2 LEGAL AND OTHER REQUIREMENTS Tech Mahindra has established and maintains a procedure to identify and have access to legal and other requirements which are applicable. (Ref SOA) These legal requirement and other requirements are considered while establishing, implementing and maintaining HSE. The Objectives and Targets are set in line with applicable legal and other requirements. 4.3.3 HEALTH, SAFETY AND ENVIRONMENTAL M ANAGEMENT PROGRAMME(S) Objectives and targets for the HSEMP’s are derived from significant environmental aspects, such as water, power, air, noise, transport, Safety and Health.; and the views of interested parties. Objectives and Targets are consistent with the HSE Policy and reflect our commitment to Control/Mitigate risks. The reports are analyzed internally by the designated HSE leaders, and where required RCA is done to ensure corrective action is planned and implemented. The HSE Objectives and Targets are defined, documented as applicable are reviewed yearly for continual improvement and compliance to legal and other requirements by the HSE Forum and HSE Core Team. Composition of HSE Forum AIC- Corporate Services, HSE Manager, Head – Maintenance, Location Manager, Location – Maintenance Head, Location – HR and AIC – Quality Composition of HSE Core Team: HSE Manager, Head – Maintenance, Location Manager, Location – Maintenance Head, Location – HR, Quality Representative Health, Safety and Environmental Management Programme(s) (HSEMP’s) are developed to achieve the set objectives and targets for HSE. They address the delegation of responsibility to relevant functions of the organization, detailing specific resources and timelines to complete the task and for reviewing the programs. (Refer SOA). The HSE Forum meets annually to review the effectiveness of the implementation of the HSE Management system and performance against set targets. The forum can recommend suitable changes to the HSE Management system and the objectives and targets after the review

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4.4 HSE R&R

Tech Mahindra has formed an “HSE Management Forum” with a forum head for implementation and maintenance of the HSE Management System. The Forum determines and ensures the availability of resources like competent personnel, proper working conditions and adequate infrastructure. HSE Management Forum also provides timely resources to comply with legal requirement and other requirements. Task level responsibility to manage, perform and verify HSE work is detailed in relevant functional procedures, including for Vendors and contract associates. Responsibilities of HSE Forum •

To ensures the availability of resources for implementing and maintaining HSE Management Systems.



Review the HSE policy personnel.



Conduct periodic performances review



Review progress on HSE objectives and Programs



Provide strategic guidelines to the HSE initiative



Nominate HSE core team members and team members.

Responsibilities of HSE Core Team •

Ensure planning for HSE implementation



Undertake periodic Risk Assessment



Define control procedures and Implement the HSE Management programs



Communicate significant changes, updates and other information to AICS



Consult AICS on a periodic basis to ensure AICS involvement in HSE.

Responsibilities of HSE Manager •

To lead & facilitate implementation of Health, Safety and Environment management systems (OHSAS 18001 and ISO 14001)



Organizing, implementing and monitoring various HSE systems



Facilitate communication about HSE systems to Senior Leaders and Associates.



Undertake Incident study and root cause analysis for HSE related incidents and submit the findings to HSE forum.



Mentor the HSE core team in implementing HSEMS



Review and support the Risk assessments activities.

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Identify training requirements and conduct training for HSE core team members.

Responsibilities of Group Head •

Ensure that all the resources are made available in timely manner for effective implementation and maintaining of HSE Forum



To ensure that HSE Policy and Procedures are followed for the HSE scoped locations



To ensure that all the authorities and responsibilities of the associate in respective circles are Communicated as relevant



Ensure that appropriate communication takes place in respective circles.



Create culture that promotes compliance, encourage associates to raise any incidents related to HSE,



Ensure Education, counseling and awareness programs to assist associates in practicing sound HSE principles

Responsibilities of Associates •

Comply with HSE Policy and Procedures



Participate in initiative in protect Environment and to reduce adverse impact on environment



Participate in Health Initiatives, Health Check Ups and Organizational Safety initiatives



Raise incidents if come across practices which impact on Environment or have a risk related to Health and Safety at location



Co-operate and participate in all the Emergency response exercises carried out at the location

4.4.1 TRAINING AND AWARENESS HSE Core Team member defines the competence required for performing any activity. Training needs are identified in each function and responsibilities are assigned for carrying out trainings. Trainings will be focused on conformance to HSE Policy, pertinent risks in respective work areas and operational controls to be followed and potential consequences of departure from specified operating procedures. Tech Mahindra ensures that any associate(s) performing activities are aware of the potential risks associated with Health, Safety and Environment and are competent on basis of education and/or training or experience to Control/Mitigate them. The Stakeholders, i.e. AICS have a role and responsibility in meeting Tech Mahindra objectives and targets pertaining to HSE. The HSE roles and responsibilities in minimizing adverse environmental impacts/Occupational Health, Safety Hazards and achieving conformity with requirement of the HSE have been defined. HSE-PO001 I2.2

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Emergency Response Team is formed to take care of the emergency arising out of Health, Safety and Environment. The ERT Members are trained on emergency response, First Aid etc. The effectiveness of the training is assessed by the respective Functional Leader for their function

4.4.2 COMMUNICATION The objective of HSE communication is to work closely with all interested parties and AICS to develop and implement agreed HSE initiatives. At Tech Mahindra internal and external communication shall be done effectively. All internal communication is done by the HSE core team members within the organization. Relevant information would be shared to the external community through Annual reports. Participation of AICS and Interested parties is be ensured through various programs including but not limited to the Behavior Based Safety and Health program, HSE related events, Incident reporting procedure. HSE core team takes into account the feedbacks received as part of the consultations with AICS and interested parties when conducting the Risk Assessment. The result of the participation and consultations is presented to HSE Forum while considering the changes to the HSE Policy. Significant environmental risks would be addressed internally and will not be communicated to the external community unless there is a written communication received from any interested party, in which case, the communication pertaining to the issue would be shared with the respective party only. Track of all relevant incoming and outgoing communication records on interested party concerns would be maintained

4.4.3 EMERGENCY PREPAREDNESS AND RESPONSE

Tech Mahindra has the ability to respond promptly and appropriately to potential accidents or emergency situations and prevent or mitigate associated adverse HSE related impact(s)/risk(s). A documented procedure has been established, implemented and maintained to identify the potential for, and responses to, emergency situations and potential accidents that can have an impact(s) on the environment and health & Safety. (Ref. SOA) Periodic mock drills are conducted to check the emergency preparedness of the team. An ERT is formed at each floor to co-ordinate during the emergency situations/accidents. The Emergency Preparedness and response procedure is reviewed annually and/or when standards specification need to be revised as per the HSE standard and updated as necessary Whenever any drills are conducted with the help of external agencies, which can be potential trigger for panic situation in the neighborhood, nearby companies are kept informed on the same, to avoid any type of panic at their end. For other types of mock drills, which are conducted internally, no proactive communication is sent to external entities.

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4.5 MONITORING AND MEASUREMENT We monitor on a daily/monthly basis the activities defined in the Risk assessment register. Basis the RPN we prioritize and re-review the parameters and revise/re-test the targets and objective measures.. HSE Management Programs are monitored as per the schedule prepared and measured for performance. Guidelines of HSEMP are used in conjunction with internal inspections and audits to monitor relevant operation controls, track compliance with legal and other HSE requirements and record associated information. (Ref. Quality Policy Manual) 4.5.1 EVALUATION OF COMPLIANCE Tech Mahindra has established the Periodical evaluation and compliance with relevant environmental/ Occupational Health, Safety legislation and regulations and other requirements and are documented. (Ref. SOA) Tech Mahindra has established and maintains a procedure to identify and to have access to legal and other requirements that are applicable to the environmental aspects and occupational health and safety of the activities, products, equipment’s or services. Legal and other requirements are identified and updated through regular interactions with concerned authorities and/or by subscribing to the Central and State Government gazettes and Cll. Copies of the updated legal and other requirements and a Register of these requirements are maintained in the Legal register. 4.5.2 ACCIDENTS, INCIDENTS, NON-CONFORMANCE’S AND CORRECTIVE AND PREVENTIVE ACTIONS Tech Mahindra has established and maintains procedures, and defined responsibility and authority, for handling and investigating non conformance, taking action to mitigate any impacts caused and for initiating and completing corrective and preventive actions. These procedures make provisions for taking corrective or preventive actions as necessary to eliminate the causes of actual and potential non conformance’s to the degree appropriate to the magnitude of the problems and commensurate with the environmental impact encountered. Tech Mahindra implements and record changes in the documented procedure resulting from corrective and preventive action Procedures for corrective action include: a)

The effective handling of HSE related complaints and nonconformities;

b)

Investigation of the root cause of non conformities relating to accidents, incidents, property damage, permit excursions, spills, beneficial occupancy inspections, annual inspections, external audits, associate concerns/ near misses, complaints and trends identified by the management review process

c)

Determination of the corrective action needed to eliminate the cause of nonconformity

d)

Application of controls to ensure that the corrective action is taken and that it is effective;

e)

Classification of non-conformities based on severity to ensure the corrective actions is Business Management System

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commensurate with the impact to the associates, facility, public and environment

Procedures for preventive action include; a)

The use of appropriate sources of information as needed to detect, analyze and eliminate potential causes of non-conformities.

e)

The proposed corrective actions are reviewed through the risk assessment prior to the Implementation.

Post the successful implementation of the corrective action, the steps are standardized in the relevant operational control procedure to ensure prevention. Associated non-conformance and corrective and preventive action records are maintained. (Ref. SOA) 4.5.3 CONTROL OF RECORDS Tech Mahindra maintains records of the results achieved to demonstrate conformity to the requirements of the HSE Management System. These are maintained in legible, identifiable and traceable form with the respective stakeholders.

Identification and maintenance of records are as per Quality Policy Manual. The records include •

Training Records,



Inspection, maintenance and calibration records if any



Incident Reports,



Record of tests for emergency preparedness,



Audit results,



Management view results,



External Communications,



Records of applicable legal and other requirements,



Records of significant environmental aspects/hazards related to health and safety,



Environmental performance information,



Legal compliance records, and



Communications with interested parties if any.

4.5.4 HSE INTERNAL AUDIT Internal Quality Audits are carried out bi-annually, to ensure that HSE compliance as required by ISO14001 and OHSAS18001. The Controls are verified to ensure HSE activities and related results comply with the Objectives and targets in the risk assessment register.

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A detailed IQA procedure is established and maintained. The IQA’s are carried out as per Annual Audit plan. IQA training is conducted to qualify the Internal Quality Auditors. Trained and qualified internal auditors independent of the function being audited, conduct audits The audits findings are logged for tracking and corrective action. 4.4

MANAGEMENT REVIEW

The senior management reviews the HSE Management System, review its continuity, suitability, adequacy and effectiveness. The management review process involves the dissemination of information from the annual HSE Forum meeting. The management review addresses the possible need for changes to the policy, objectives and elements of the HSE Management System Agenda for HSE Forum Meeting: a)

HSE @ TECH MAHINDRA

b)

Results of Internal Audits. Corrective and Preventive Actions

c)

Communication from external interested parties, including complaints

d)

HSE performance

e)

Objectives and targets

f)

Action items from previous management reviews

g)

Changing circumstances, legal and other requirements

h)

Recommendations and improvement (including changes)

i)

BBSH Data Analysis

j)

Results of participation and consultation

k)

Incident Investigations, corrective & preventive actions

4.5

MANAGEMENT OF CHANGE

Tech Mahindra re-assesses HSE and other Risks when planned or unplanned changes occur. The HSE forum and core team comprises of associates trained on the HSE standard to ensure correctness and completeness and requirements of the standard is maintained. 4.6

APPENDIX

Statement of Applicability ISO 14001:2004 Clause

Particulars

1

Scope Normative references

2

OSHAS 18001:2007 References Clause 1 2

Particulars Scope Reference publication

Documents/ Records

HSE Manual

HSE Manual

HSE Manual

HSE Manual

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HSE Manual, Respective Procedures

3

Terms and definitions

3

Terms and definitions

4

Environmental management system requirements

4

OH&S management system elements

4.1

General requirements

HSE Manual

4.2

OH&S policy

Quality Policy manual; HSE Manual

HSE Manual

4.3

Planning Planning for hazard identification, risk assessment and risk control

HSE Risk Management Procedure

Risk Assessment sheet

HSE Manual; Risk Assessment procedure, Procedure for identification of Legal & Other Requirements

Legal Register

4.3

General requirements Environmental policy Planning

4.3.1

Environmental aspects

4.3.2

Legal and other requirements

4.1 4.2

4.3.1

4.3.2

Legal and other requirements

HSE Manual

1. HSE

4.3.3

4.4 4.4.1

4.4.2

4.4.3

Objectives, targets and programme(s)

Implementation and operation Resources, roles, responsibility and authority Competence, training and awareness

Communication

1. HSE Manual. 2. HSE Risk

Management Procedure 3. Procedure for HSE M Programs

4.3.3

Objectives

4.3.4

OH&S Management programme (s)

4.4

Implementation and operation

4.4.1

Structure and responsibility

HSE Manual; Quality Policy Manual

4.4.2

Training, awareness and competence

Quality Policy manual; HSE Manual; SLC Processes - Induction and QMS Training Respective Procedures

4.4.3

Consultation and communication

HSE Manual Internal & External Communication Procedure

1. HSE Manual. 2. HSE Risk

Management Procedure 3. Procedure for HSE M Programs

Business Management System

Management Programs planned and conducted 2. Six Sigma Projects Ongoing and closed (Records 1. HSE of Management the same) Programs planned and conducted 2. Six Sigma Projects Ongoing and closed (Records of the same) Procedural documents for respective areas 1. Records of

HSE trainings done 2. Calendar of training planned 1. Records of various communications

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1. DG and its distribution

Systems 2. UPS and its distribution Systems 3. AC and its distribution Systems 4. Waste Management Procedure 5. Cafeteria Management Procedure 6. Transport Management Procedure 7. Incident Management Procedure HSE Manual; Document and Data control HSE Risk Management Procedure - Noise pollution Procedure - Soil pollution Operational Control procedure for Transport

4.4.4

Documentation

4.4.4

Documentation

4.4.5

Control of documents

4.4.5

Document and Data control

4.4.6

Operational control

4.4.6

Operational control

4.4.7

Emergency preparedness and response

4.4.7

4.5

Checking

4.5

Checking and corrective action

4.5.1

Monitoring and measurement

4.5.1

Performance measurement and monitoring

Quality Policy Manual; HSE Manual, Individual Procedures for key performance measures

4.5.2

Accidents, incidents, nonconformances and corrective and preventive action

HSE Manual; Corrective and preventive action procedure

4.5.2

4.5.2.1

4.5.2.2

4.5.3

4.5.4

Evaluation of compliance

Emergency preparedness and response

Evaluate compliance with applicable legal requirements periodically Evaluate compliance to other subscribed requirements

Aid

BMS

Risk Management Checklist 1. Records of

ERT drills carried out 2. Reports of Incidents happened 1. QMR's 2. IQA 3. Periodic Risk Assessment

IQA

Legal Compliance Procedure

Nonconformity, corrective action and preventive action Control of records

1. ERT Procedure 2. Guidelines for First

Records and evidences for the list mentioned in the previous column (E20)

Corrective and Preventive Action Procedure

4.5.3

Records and records management

Document And Data Control Procedure

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Internal audit Management Review

4.5.4

Audit

Internal quality audits procedure

4.6

Management review

Management Review procedure

Business Management System

MOMs of the review with tracking

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