HEALTH, SAFETY & ENVIRONMENT MANAGEMENT SYSTEM MANUAL AJM-HSEMS-MAN NOVEMBER 2016

Transcription

1 ALTURA LITHIUM OPERATIONS PTY LTD HEALTH, SAFETY & ENVIRONMENT MANAGEMENT SYSTEM MANUAL AJM-HSEMS-MAN NOVEMBER 2016 Altura Lithium Operations Pty Ltd ABN PO Box 1386, Subiaco WA 6904 Telephone: Facsimile:

2 DISCLAIMER This document has been prepared for the exclusive use of Altura Lithium Operations Pty Ltd. Copying this document without the permission of Altura Lithium Operations Pty Ltd is not permitted.

3 Table of Contents 1.0 Summary Purpose Objective Scope References Definitions and Abbreviations Accountabilities & Responsibilities Leadership & Commitment Policy Health Safety and Environment Management System Structure HSEMS Description Organisation Structure Altura Lithium Operations Pty Ltd Health, Safety & Environment Support Leadership & Commitment The Altura Management Team Resources Altura HSE Resources Operational HSE Resources Other HSE Resources Planning Hazard Identification, Risk Assessment & Control Hazard Identification Studies: HAZID Hazard & Operability Studies: HAZOP Construction Hazard Assessment Implication Reviews: CHAIR Construction Risk Assessment Workshop: CRAW Job Hazard Analysis & Safe Work Method Statements: JHA / SWMS Take Legislative & Other Compliance Management Plans Objectives, Targets & Performance Standards Objectives, Targets & Performance Standards Site Objectives, Targets & Performance Standards Reward & Recognition Programs Training, Competency & Awareness Training Needs Analysis Inductions Licencing & Certificates Verification of Competency... 18

4 12.0 Consultation & Communication General Processes Issue Resolution Documentation, Data Control & Information Management General Provisions Document Control & Review HSE Records & Records Management Hazard & Risk Management Requirements for Hazard Identification, Risk Assessment & Control HSE Standards & Site Specific HSE Documents Emergency Preparedness & Response Emergency Response Plans First Aid & Medical Facilities Emergency Drills Critical Incident Response Measurement & Evaluation General Requirements Pre-Placement Medical Examinations Fitness for Work Health Surveillance Workplace Inspection Hygiene Monitoring Plant & Equipment Inspection Test Evaluation of Compliance Reporting & Investigation General Requirements Hazards Behaviour HSE Performance Corrective & Preventative Actions Incident Reporting and Investigation Statutory Reportable Events Injury Management Workers Compensation Environment Dust Monitoring Waste Management Sewage and Waste Water Management Hazardous Material Management Topsoil / Vegetation Management... 25

5 18.6 Ground Disturbance and Clearing Flora and Fauna Management Noise and Vibration Management Weed and Feral Animal Management HSEMS Audits & Corrective Actions Audits Non-Conformance Management Review Appendices... 28

6 1.0 Summary Altura Lithium Operations Pty Ltd is building a leading position in the independent supply of lithium raw materials, with a world class lithium project at Pilgangoora ready to set the platform and be the first new hard rock supplier in The Altura team has a track record of delivering mining projects with Pilgangoora the most advanced stage, near term producing lithium project; solid offtake partners and a market providing substantial growth opportunities to ensure positive shareholder returns. 2.0 Purpose Altura places the protection of people above all other business considerations. No person should suffer any ill effects arising from work undertaken for Altura. In support of this objective, Altura recognises its responsibility for maintaining the workplace through the implementation and maintenance of an appropriate HSE Management System. The Altura Health, Safety and Environmental Management System (HSEMS) comprises of the: Health, Safety and Environment (HSE) Policy Risk Management Policy Code of Conduct Policy (This document) HSE Contractor Requirements Manual HSE Management System Standards The HSEMS is an integral part of the overall management system at Altura. It is designed to complement other systems used within the organisation and provides a systematic management approach to assist in both leading to sustained improvements in HSE performance and meeting legal requirements. The HSEMS includes safety goals and performance targets, risk assessments, responsibilities and authorities, rules and standards, and monitoring and evaluation processes. The purpose of this manual is to provide a detailed description of the HSEMS Standards and to document their application within Altura. The standards provide a framework for the management of HSE related risks, consistent with legislative requirements and recognised standards listed below: AS / NZS 4801 Occupational Health & Safety Management System ISO Environmental Management System Western Australian Mines Safety and Inspection Regulations 1995 Western Australian Mines Safety and Inspection Act Objective Environmental Protection Act 1986 (WA) Mining Act 1978 Dangerous Goods Safety Act 2004 The HSEMS has been developed to provide an over-arching framework for HSE. This will assist in the management of risks associated with all activities undertaken by / for Altura. The system provides a structure for creating, developing, managing and reporting HSE issues on a continuous improvement basis. The Health, Safety Management System Manual is to ensure that: The HSE requirements of Altura are detailed to all personnel This manual is for use by all personnel who will use the HSEMS documents so as to comply with the system Document and communicate the framework of the Altura HSEMS AJM-HSEMS-MAN-001_1 Page 6 of November-2016

7 Demonstrate Altura `s commitment to Health, Safety and Environment Incorporate Australian Standard 4801:2001 Occupational Health and Safety Management Systems Demonstrate compliance with the applicable legislation 4.0 Scope This HSEMS Manual is applicable to all activities conducted by personnel working for or at the direction of Altura, including contractors and (where applicable) joint venture partners. 5.0 References AJM-GOV-POL-001 AS/NZS 31000:2009 HB AS / NZS 4801 Health, Safety & Environment Policy Risk Management Principles & Guidelines OHS Risk Management Handbook, Standards Australia OHS Management Systems Western Australia Mines Health and Safety Regulations 1995 Western Australia Mines Health and Safety Act 1994 Western Australia Occupational Safety and Health Regulations 1996 Western Australia Occupational Safety and Health Act Definitions and Abbreviations Altura ALARP AS ASNZS CHAIR CRAW EAP EMP Employee ERMP FAI FFW HAZID HAZOB Altura Lithium Operations Pty Ltd As Low as Reasonably Practicable Australian Standard Australian & New Zealand Standard Construction Hazard Assessment Implication Review Construction Risk Assessment Workshop Employee Assistance Program Environmental Management Plan Any person at a Altura workplace (direct employee, contractor, sub-contractor or visitor) Emergency Response Management Plan First Aid Injury Fitness for Work Hazard Identification Study Hazard Observation AJM-HSEMS-MAN-001_1 Page 7 of November-2016

8 HAZOP HIRAC HSE HSMP HSEMS ISO IDLH JHA KPI LTI MSDS MTI NOHSC OH&S OSHA PPE Personnel RWI SAO SWMS Work scope Hazard & Operability Study Hazard Identification, Risk Assessment & Control Health Safety and Environment Health and Safety Management Plan Health Safety and Environment Management System International Standards Organisation Immediately Dangerous to Life & Health Job Hazard Analysis. Has same meaning as JSA / JSEA etc Key Performance Indicator Lost Time Injury Material Safety Data Sheet Medical Treatment Injury National Occupational Health & Safety Commission (Australia) Occupational Health & Safety Occupational Safety & Health Administration (US) Personal Protective Equipment Any person at a Altura workplace (direct employee, contractor, sub-contractor or visitor) Restricted Work Injury Safe Act Observation Safe Work Method Statement The area in an agreement where the work to be performed is described AJM-HSEMS-MAN-001_1 Page 8 of November-2016

9 7.0 Accountabilities & Responsibilities To ensure all directors, managers, and other personnel understand their responsibilities and authorities with respect to the management of health safety and the environment, Altura will ensure: All personnel have position descriptions All personnel have signed their position descriptions to acknowledge their commitment to Altura s HSE Policy All personnel conform to their position description Records of statutory appointments including appointment letters will be maintained on site. Statutory positions include: Registered and Exploration Manager and their Alternates/Deputies Quarry Manager and their Alternates/Deputies Ventilation Officer Radiation Safety Officer A summary of following key positions, responsibilities and accountabilities is included as Appendix 1 of this document. Managing Director General Manager Registered and Exploration Managers Health and Safety Manager Site, Project and Construction Managers Supervisors HSE Advisors All Employees 8.0 Leadership & Commitment 8.1 Policy Altura policies are issued under the signature of the Altura Managing Director, and include: Health, Safety and Environmental Policy Risk Management Policy Code of Conduct Policy Altura policies apply to all of the Altura activities including those contracted companies. Copies are available via the company web site, and are on display throughout workplaces. Altura policies are communicated to all employees and contractors during company inductions, and will be periodically reviewed and if necessary, revised, by the Altura Management Team, to reflect any change in conditions or standards applicable to Altura. The above policies are supported and given effect by the implementation of this Health Safety and Environment Management System. A copy of the Altura Health Safety and Environment Policy is included as an appendix of this HSEMS Manual. AJM-HSEMS-MAN-001_1 Page 9 of November-2016

10 8.2 Health Safety and Environment Management System Structure The HSEMS model encompasses seven (7) elements which drive the continuous improvement cycle. Continuous improvement in Health, Safety and Environment is core to the duty of care provisions contained within relevant legislative requirements. Altura ensures that continuous improvement is achieved by documenting, implementing and abiding by Health Safety and Environment Management System Standards (HSEMS) which are aligned with these principles. Altura will periodically review its HSEMS to identify and implement opportunities for improvement. Figure 1: HSEMS Structure 8.3 HSEMS Description Altura Lithium Operations Pty Ltd Health Safety and Environment Management System, is comprised of seven (7) key elements as follows; ELEMENT HSE Policy HSEMS Manual ~this document~ DETAIL The HSE Policy establishes the overall direction for Altura `s approach to Health Safety and Environment Management and provides tangible evidence of management s commitment to the achievement of its aims. The policy is authorised by the Altura Managing Director, and is applicable to all of the Altura operations, including those of its contractors whilst engaged at an Altura operation. The HSEMS Manual defines and provides the framework within which Altura policy is given effect. The manual is authorised and approved by the Altura`s General Manager, and is applicable to all of the Altura operations, including those of its contractors whilst engaged at an Altura operation. AJM-HSEMS-MAN-001_1 Page 10 of November-2016

11 ELEMENT HSEMS Standards HIRAC Site Specific HSE Plans Site Specific HSE Documents DETAIL The HSEMS Manual details a systematic approach to the management and continual improvement of HSE performance in accordance with ASNZS 4801, WA Mines Health Safety Act & Regulations Altura HSEMS Standards provide detailed requirements on the steps to be taken to identify hazards, assess risks, implement safe work practice, investigate incidents and achieve continual improvement. Altura HSEMS Standards are authorised and approved by the Altura General Manager and is applicable to all of the Altura operations, including those of its contractors whilst engaged at an Altura`s operation. Compliance with Altura`s HSEMS Standards is required across all of the Altura operations. In accordance with Altura`s HSE Policy all operations are required to Wherever we operate we will develop and implement risk assessments and maintain a HSE Management System that is consistent with internationally reconised standards and practices so as to establish, monitor and maintain a safe workplace. Hazard Identification, Risk Assessment and Control are achieved by use of HAZOP s, CHAIR s, HAZID s, CRAW s, JHA & Take 5. These fundamental risk assessment tools are utilised in order to identify hazards, assess risks and establish appropriate controls so as to provide and maintain safe workplaces. Registered / Exploration, Site, Project and Construction Managers are responsible for ensuring that the appropriate risk assessments have been completed for their project, workplace or work scope, and for authorising the implementation of identified controls. Each work scope is required to develop Site Specific HSE Management Plan which documents the manner in which the company undertaking the work scope will comply with Altura`s HSE Policy & HSEMS Standards, in accordance with the systematic approach outlined in this HSEMS Manual. HSE Management Plans are required to document the manner in which hazards identified as part of the HIRAC processes are to be eliminated or managed. Site specific HSE Management Plans shall be authorised and approved by the Manager who has overall control and responsibility for the personnel for the work scope. In all cases, HSE Management Plans should be approved for use by a Altura representative before commencement of that work scope. Site specific HSE Documents will be supplied as required or deemed necessary to meet Altura`s HSEMS requirements by each company entity engaged at a Altura work place. Site specific documents may not over-ride or conflict with Altura HSEMS Manual and Standards and may only provide for an equivalent or higher level of hazard control, or for the creation of systems beyond those provided for by the Altura HSEMS Manual and Standards. Site specific documents shall be reviewed by Altura`s Management and shall only apply to the company entity for which they are AJM-HSEMS-MAN-001_1 Page 11 of November-2016

12 ELEMENT Measurement and Evaluation DETAIL developed and shall at all times be regarded as supplemental to Altura`s HSEMS Standards. Fundamental to the measurement, evaluation and continual improvement of any HSEMS is the development of records which document, support and report on the manner in which the system is implemented. Inspection reports, audits and other records will be recorded and retained in accordance with defined Altura HSEMS Standards. Altura will conduct planned audits and inspections of all company entities engaged at Altura`s work places to ensure compliance with the Altura HSE Management System. 8.4 Organisation Structure Altura Lithium Operations Pty Ltd The organisational structure of Altura, including operational and functional reporting structures, is outlined within organisation charts, available from Altura Health, Safety & Environment Support HSE support for Altura`s activities shall be provided by qualified HSE professionals, reporting to the Altura General Manager. 8.5 Leadership & Commitment The Altura Policy outlines management s commitment as follows: The Altura Board of Directors commits to ensuring the organisation operates in a safe, efficient manner and will take all reasonable steps to ensure the health and wellbeing of the workforce by providing a safe working environment throughout its operations at all times. The Board of Directors includes the Managing Director of the company. 8.6 The Altura Management Team The Altura Management team members have the authority to monitor and review HS performance, approve and support HSE improvement initiatives, and provide leadership and direction across their areas of direct authority. 8.7 Resources Responsibility for ensuring that adequate human, financial and physical resources are available to implement HSE policy is shared between Altura`s Corporate Functions and Altura Operational Functions with the following general guidelines applying: Altura HSE Resources Altura HSE resources are those which report within the corporate structure and include the Altura HSE Manager. Altura resources provide services as and when required across all areas of the company. The required level of HSE resources shall be as determined by Altura`s Management Team AJM-HSEMS-MAN-001_1 Page 12 of November-2016

13 8.7.2 Operational HSE Resources Operational HSE resources are those which report within a specific operational structure and include; HSE Advisors HSE Trainers, and HSE Administrators Operational HSE resources provide direct support to the site to which they are assigned, and have direct reporting lines to the Project, Site or Registered Manager. Minimum HSE resource levels for operational activities will be assessed and established during the HAZID risk assessment phase. The outcome shall be documented within the HSE Management Plan for the prescribed work scope. Operational HSE Resources additional to the above minimum requirements (eg: Site HSE Manager, HSE Trainer, HSE / Training Administrator) shall be determined on a case by case basis and shall be subject to any legislative, contractor or other requirement. * For part time HSE Advisor allocation, a resourcing level of 0.3FTE per 10 persons should be considered as a guide Other HSE Resources Where specialised skills, equipment, technology, financial or other resources are identified as necessary for the implementation of Altura`s Policy, an appropriate business case shall be submitted to the General Manager for consideration and determination. AJM-HSEMS-MAN-001_1 Page 13 of November-2016

14 9.0 Planning 9.1 Hazard Identification, Risk Assessment & Control Altura have documented standards for hazard identification, risk assessment and control. All work scopes are required to complete a HAZID study prior to commencement in order to identify significant hazards and develop appropriate controls. The HAZID process is high level and wide ranging, and should inform and feed into the development of the Site HSE Management Plan. Where work involves the design of either process plant & equipment or infrastructure, a Hazard & Operability Study (HAZOP) or Construction Hazard Assessment Implication Review (CHAIR) shall also be required. Once mobilised to site and prior to the commencement of new phases of construction, a Construction Risk Assessment Workshop (CRAW) shall be conducted on site with those personnel directly involved in construction work, to review and as necessary refine, the original HAZID. The above processes may be illustrated as follows 9.2 Hazard Identification Studies: HAZID All work scopes shall be subject to a preliminary Hazard Identification Study (HAZID) at tender. The purpose of the HAZID is to identify overarching hazards applicable to the scope of work, assess the level risk associated with those hazards, and identify appropriate control measures based upon the level of risk. Should the tender proceed to contract execution, the preliminary HAZID shall be refined, based upon the agreed and contracted scope of work. Refer to: AJM-HSEMS-STD-002 HIRAC AJM-HSEMS-MAN-001_1 Page 14 of November-2016

15 9.3 Hazard & Operability Studies: HAZOP Where the work scope involves the design of process plant and equipment, a Hazard & Operability Study shall be performed to identify operational & maintenance hazards. Outcomes from the HAZOP shall be utilised as necessary to refine the design such that risks are reduced to ALARP. Refer to: AJM-HSEMS-STD-002 HIRAC 9.4 Construction Hazard Assessment Implication Reviews: CHAIR Where the work scope involves the design of buildings or similar infrastructure, a Construction Hazard Assessment Implication Review (CHAIR) shall be performed to identify constructability and occupancy hazards. Hazards associated with construction, occupancy, repair, cleaning, maintenance or demolition shall be identified and to the extent possible, eliminated or mitigated at the design stage. Constructability hazards which cannot be eliminated at the design stage shall be reflected and treated as part of the HAZID / CRAW process. Refer to: AJM-HSEMS-STD-002 HIRAC 9.5 Construction Risk Assessment Workshop: CRAW Upon mobilisation to site, Construction Teams shall review the HAZID against actual site conditions during a Construction Risk Assessment Workshop. The purpose of the CRAW is twofold: a) to confirm the applicability of the HAZID based upon actual site conditions b) to involve the workforce in reviewing the known hazards and their controls, and seek such further input as may be appropriate Refer to: AJM-HSEMS-STD-002 HIRAC 9.6 Job Hazard Analysis & Safe Work Method Statements: JHA / SWMS Routine, low risk, or repeatable activities for which a Altura HSEMS Standard or Site Specific HSE Document has been developed are considered to be covered by a Safe Work Method Statement providing that the actual activity and conditions under which it occurs are the same as those described by the Standard or Document. Where a work activity is neither routine, low risk nor repeatable or where no Altura HSEMS Standard or Site Specific Document is available to detail the manner in which the activity is to be completed safely, the supervisor in charge of the work activity shall direct that a JHA be performed and a SWMS developed. Refer to: AJM-HSEMS-STD-003 Job Hazard Analysis & Safe Work Method Statements 9.7 Take 5 The Take 5 process forms the final link in the HIRAC process, requiring personnel to perform a final check and confirmation that their work area and / or the activity they are about to perform is safe and without risk to their health and safety, or the health and safety of any person who may be impacted upon by their activities. If any Health, Safety control required by the Altura HSMS Standard, Site Specific HS Document, or JHA/SWMS applicable to the work activity is not in place, work may not commence until the control is implemented. AJM-HSEMS-MAN-001_1 Page 15 of November-2016

16 Refer to: AJM-HSEMS-STD-005 Take Legislative & Other Compliance Altura personnel are required to comply with applicable legislation and other requirements related to Health and Safety. In order to assist site and ensure that all personnel have access to applicable legislation, the Altura HSE Manager shall maintain a master register of Acts, Regulations, Codes of Practice, Guidance Notes, and Australian, National & Other Standards appropriate to the Altura operations, and shall ensure that such information is kept up to date and communicated to personnel as required. Legislative and other requirements applicable to each specific project must be identified as part of the initial HAZID, and documented within project HSEMP s. Refer to: AJM-HSEMS-STD-007 Legal Compliance 9.9 Management Plans Each work scope is required to develop and maintain a HSE Management Plan (HSEMP) specific to its operation and scope of work. Additional plans may also be developed or incorporated in the main document, to address matters such as Environment, Emergency Response, Health Management, Cyclone Management, Traffic Management and so forth, dependent upon the nature of the work scope and contractor requirements. The development of HSE Management Plans should be informed by the outcomes of the HAZID, provide detail on how the Altura HSEMS shall be implemented and integrated into the work scope, and address the significant hazards and hazard control measures applicable to the work scope. Refer to: AJM-HSEMS-STD-009 HSE Management Plans & Site HS Documents 10.0 Objectives, Targets & Performance Standards 10.1 Objectives, Targets & Performance Standards The Altura Management Team shall establish detailed objectives and measurable targets on an annual basis. In developing objectives and establishing targets, the Altura Management Team shall be guided by industry and previous performance, the necessity of implementing Altura`s HSE Policy, and the requirements of this HSEMS Manual. The Altura Management Team shall meet and decide upon the annual objectives and targets and shall ensure that they are communicated to all personnel. Objectives, Targets and Performance Standards shall be published as an appendix to the Altura HSEMS - AJM-HSEMS-STD-008 HS Objectives and Targets and provide the following level of detail: Objective: Target: Standard: KPI: The desired outcome Description of the metric which will signify achievement of the outcome. The standard to be achieved in order to be measured The quantitative metric Refer to: AJM-HSEMS-STD-008 HSE Objectives & Targets AJM-HSEMS-MAN-001_1 Page 16 of November-2016

17 10.2 Site Objectives, Targets & Performance Standards Objectives, Targets and Performance Standards are established for all work scopes, and documented within the Work Scope HSEMP. Site Objectives, Targets and Performance Standards must reference those set by the Altura Management Team, in addition to any work scope specific requirements Reward & Recognition Programs Reward & Recognition Programs which compliment site objectives may be developed and implemented at the discretion of individual site / project managers Training, Competency & Awareness 11.1 Training Needs Analysis Training and competency requirements for all positions are identified within position descriptions maintained by each company and based upon an overall training needs analysis conducted for each work scope. As a minimum, the training needs analysis and position descriptions include details of required trade qualifications, mandatory (statutory) licences & certifications applicable to the position classification, as well as skills training & education relevant to occupational health & safety, and environmental awareness. In addition, each work scope is responsible for developing and maintaining: a) a site training matrix identifying the specific qualifications, licences, certifications and other training requirements applicable to that work location; b) a training plan which identifies how ongoing training is to be provided across the life of the work scope Personnel training and competency will be included in audit and inspection compliance requirements Inductions All personnel shall have received a comprehensive induction prior to commencing work. The induction provides an overall awareness of: HSE Policy, Objectives and Targets Company & workplace organisation including key contact personnel Hazard & incident reporting requirements Workplace Hazards, Controls and Emergency procedures Records are maintained onsite to confirm attendance Licencing & Certificates All personnel will be in possession of the licences & certifications identified on their position description or identified as required within the site training matrix, prior to undertaking any work for which that licence or certification is required. No person shall undertake or be permitted to undertake any task or operate any plant or equipment for which a statutory licence, certification or qualification is required, unless they hold the necessary qualification or are under the direct instruction of an authorised trainer. Records of qualifications, licences, certifications and other training relevant to occupational health & safety awareness are maintained on site for evidence purposes. AJM-HSEMS-MAN-001_1 Page 17 of November-2016

18 11.4 Verification of Competency The competency of personnel to undertake tasks for which a High Risk Work Licence is required, or for which another defined Licence or Certificate of Competency is available or required, shall be verified in a controlled environment, prior to their being authorised to work. This verification of competency (VoC) shall be performed in accordance with defined procedures, utilising approved instruments of assessment, by personnel who are qualified under the national training framework to conduct such training. Refer to: AJM-HSEMS-STD-010 Competency & Training 12.0 Consultation & Communication 12.1 General Processes Altura recognises the importance of accurate and open communication with all personnel on matters related to health, safety and the environment. The Altura HSEMS standard for consultation and communication requires that personnel; Are involved in the development, implementation and review of policies and procedures for hazard identification, hazard/risk assessment and control of hazards/risks; Are consulted where there are any changes related to the management of HSE Select those who will represent them on matters pertaining to HSE Are informed as to the identity of their HSE representative(s) and specified management representative(s). Receive appropriate training to undertake effectively their involvement in the development, implementation and review of HSE arrangements. A range of media and forums shall be utilised to communicate HSE information internally including; Inductions; Pre-Start Meetings; Toolbox Talks; Company Alerts; Noticeboards; Newsletters; HSE Committee Meeting Minutes; External communication in relation HSE occurs primarily via Contractor Meetings and Annual Company Reports. Refer to: AJM-HSEMS-STD-011 Consultation & Communication 12.2 Issue Resolution HSE issues or disputes are to be addressed in the first instance with the Site Supervisor who will consult with site personnel including the elected HSE Representative. If no resolution is possible within 2 hours, the matter shall be referred to the Supervisors Manager who can consult with The Altura Site Manager and other site specialists for advice. During this process, all efforts will be made to minimise interruption to work in progress, however the health and safety of personnel and impact to the environment will not be compromised. AJM-HSEMS-MAN-001_1 Page 18 of November-2016

19 Any personnel who has reasonable grounds to believe that continuing to work would expose them or others to injury or harm or impact to the environment, shall stop work and discuss the issue with their direct supervisor immediately. Refer to: AJM-HSEMS-STD-012 Issue Resolution 13.0 Documentation, Data Control & Information Management 13.1 General Provisions A general description of the core elements of Altura`s HSEMS are contained within this manual. Detailed requirements are contained within Altura`s HSEMS Standards. Current revisions of the above documents are maintained on Altura`s intranet; printed copies exist for information only and are not updated Document Control & Review This Altura HSEMS Manual & its associated standards provide the overall framework within which all work scopes are required to operate so as to ensure compliance with Altura`s HSE Policy. Work scope specific HSE Management Plans and associated Site Specific HSE documents outline the operational controls to be implemented for that work scope. The control and review of HSE documents that are Altura Lithium Operations Pty Ltd specific, is governed by and shall be in accordance with Altura`s Quality Management. Work scope specific HSE Management Plans and associated Site Specific HSE documents shall fall under the owners Quality Management requirements HSE Records & Records Management HSE records shall be collected, indexed, filed, maintained and archived in accordance with defined procedures. HSE Records shall be retained for work scope completion plus 7 years. Personnel and employment records, including Medical, Workers Compensation and Training records, shall be retained for 30 years. Refer to: AJM-HSEMS-STD-013 Control of HSE Documents and Records 14.0 Hazard & Risk Management 14.1 Requirements for Hazard Identification, Risk Assessment & Control The Altura standards for Hazard Identification, Risk Assessment and Control (HIRAC) are integral to and embedded within the HSE Management System. Six tools or processes are available and required to be used, dependent upon the nature of the activity: HAZID: For all work scopes HAZOP: Where the work scope involves the design of plant, equipment or processing facilities CHAIR: Where the work scope involves the design of buildings and infrastructure CRAW: For all work scopes, to review the HAZID at site prior to commencement JHA: For all work scopes. For the development of Safe Work Method Statements at task level Take 5: For all work scopes. For all tasks as a final check & confirm AJM-HSEMS-MAN-001_1 Page 19 of November-2016

20 Full details regarding these processes are contained within the relevant Altura standards. The HAZID process includes an assessment of all HSE Hazards and Risks, including those hazards and risks associated with the procurement of materials and services, and the management of sub-contractors. Refer to: AJM-HSEMS-STD-002 HIRAC AJM-HSEMS-STD-003 Job Hazard Analysis & Safe Work Method Statements AJM-HSEMS-STD-005 Take HSE Standards & Site Specific HSE Documents In support of the HIRAC process, Altura has a range of HSEMS Standards which outline the minimum HSE requirements to control various site hazards. These standards provide a baseline for safe operations and apply to all personnel across all work scopes and may be referenced as control measures for hazards identified during any of the HIRAC processes. They may be utilised on sites on a standalone basis, or incorporated into or referenced by work scope specific HSE documents. The Altura HSEMS Standards are issued under the signature of the General Manager on the advice of Altura`s Management Team and are available to all personnel via the company intranet. Refer to: AJM-HSEMS-STD-009 HSE Management Plans & Site HSE Documents 15.0 Emergency Preparedness & Response 15.1 Emergency Response Plans All work scopes are required to evaluate potential emergency situations as part of their overall HIRAC process, and develop appropriate emergency response plans. The scope and complexity of emergency response plans will vary from work scope to work scope, based on the particular circumstances and hazards applicable to the location First Aid & Medical Facilities In conjunction with the evaluation of potential emergency situations an evaluation of First Aid and Medical Facilities is required. This shall include consideration of all foreseeable requirements for first aid and medical services, the distance and available modes of transport to both internal and external medical services, and the adequacy of such services. Refer to: AJM-HSEMS-STD-014 Emergency Preparedness and Response 15.3 Emergency Drills The adequacy of all emergency response plans developed for emergency preparedness and response shall be evaluated on a bi-annual basis by way of an Emergency Drill or Exercise. Subject to the scope and level of complexity of the emergency response plan, drills or exercises may evaluate the entire plan or a part thereof and involve either practical response or desktop scenario. An outline of the drills or exercises required to be conducted shall be contained within the plan itself, and records shall be maintained of all drills or exercises held Critical Incident Response Nominated EAP providers shall be used in the event of a critical incident. AJM-HSEMS-MAN-001_1 Page 20 of November-2016

21 As soon as practically possible, the EAP provider will be informed and placed on standby to assist with professional debriefing for incidents such as assaults, fatalities, serious accidents and suicides/deaths. Refer to: AJM-HSEMS-STD-025 Employee Assistance & Critical Incident Response 16.0 Measurement & Evaluation 16.1 General Requirements Key characteristics of Altura`s operations relevant to HSE Performance are monitored and measured in accordance with Altura HSEMS Standards. This includes measurements relevant to the monitoring and control of employee health, workplace hazards and environmental impacts, as well as measurements of HSE performance. The objective of all measurement is to ensure that Altura`s HSEMS is implemented and is effective in controlling hazards to a level which is ALARP. The following sections outline specific situations in which monitoring & measurement is conducted Pre-Placement Medical Examinations In order to provide baseline information against which the health of personnel can be monitored, and to provide assurance that candidates are physically matched to task demands of their position, applicants for employment, transferees between work locations, and contract personnel, are subject to pre-placement medical examinations. Refer to: AJM-HSEMS-STD-019 Pre-Placement Medical Examinations 16.3 Fitness for Work The Altura HSEMS Standard Fitness for Work requires that employees present for work unimpaired in their ability to safely carry out their work duties. Factors which may impact upon an individual s fitness for work include mental health issues, fatigue, heat stress, personal issues, and the misuse of alcohol and other drugs. A range of monitoring and measurement strategies designed to ensure that personnel are fit for work at all times are to be implimented across Altura`s operations, including random and for-cause testing for the presence of alcohol or other drugs. Refer to: AJM-HSEMS-STD-020 Fitness for Work 16.4 Health Surveillance AJM-HSEMS-STD-021 Management of Alcohol & Other Drugs Where legally required, identified as necessary by the HIRAC process or otherwise identified during the course of work, Altura shall undertake surveillance of employee s health. Situations which may require health surveillance include, but are not limited to: Potential for exposure to noise beyond the statutory limit Potential for exposure to Lead Potential for exposure to Asbestos Potential exposure to hazardous substances or energies Potential exposure to communicable or vector borne disease For detailed requirements and guidance in all cases where a need for personnel health surveillance is identified, Refer to: AJM-HSEMS-STD-022 Health Surveillance & Exposure Monitoring AJM-HSEMS-MAN-001_1 Page 21 of November-2016

22 16.5 Workplace Inspection Regular inspection of all work areas is essential to ensure that activities are conforming to planned requirements, Altura`s HSEMS Standards. Refer to: AJM-HSEMS-STD-017 Workplace Inspection 16.6 Hygiene Monitoring In addition to the monitoring of employee health as outlined above, industrial hygiene monitoring may be identified as necessary by legislation, HIRAC processes or other circumstance, to ensure that levels of workplace contaminants are known and managed. Situations which may require industrial hygiene monitoring include but are not limited to: Noise emission / exposure. Lead emission / exposure. Asbestos emission / exposure Emission / exposure to hazardous substances or energies Emissions with potential to impact upon air, ground or water quality Refer to: AJM-HSEMS-STD-022 Health Surveillance & Exposure Monitoring 16.7 Plant & Equipment Inspection Test Plant & Equipment shall be subject to regular inspection in order to ensure continued safe operation and compliance with Altura`s requirements. For detailed requirements and guidance on the inspection and test requirements for vehicles, plant, mobile equipment and electrical equipment, Refer to: AJM-HSEMS-STD-018 Vehicles, Plant & Mobile Equipment AJM-HSEMS-STD-027 Portable Electrical Equipment 16.8 Evaluation of Compliance The effectiveness of Altura`s HSEMS Standards for monitoring and controlling those characteristics of its operations which could give rise to injury, ill health is regularly evaluated via review of individual work scope monthly HSE Data Reports and the Altura Monthly HSE Performance Report. Refer to: AJM-HSEMS-STD-015 HSE Performance Reporting 17.0 Reporting & Investigation 17.1 General Requirements AJM-HSEMS-STD-016 HSE Performance Measurement Altura has established detailed standards applicable to all work scopes for the reporting of HSE Information. These standards include the reporting of: Hazards Behavioural Observations Incidents & Injuries HSE Performance Corrective & Preventative actions AJM-HSEMS-MAN-001_1 Page 22 of November-2016

23 Statutory reportable events The following subsections provide additional detail Hazards Altura recognises the importance of identifying and reporting hazards as a key driver in their elimination. The Altura HSEMS Standards for Hazard Observation Reporting and Workplace Inspection apply across all work scopes. These processes are communicated to all personnel during inductions, stewarded by the responsible Site, Project Construction manager, and reported and monitored in accordance Altura`s HSEMS Standard for HSE Performance Reporting. Where contractor specific requirements dictate the use of differing but equivalent processes, those processes can be utilised and reported on as though they were the Altura processes. Refer to: AJM-HSEMS-STD-004 Hazard Reporting 17.3 Behaviour AJM-HSEMS-STD-017 Workplace Inspection Altura is committed to continual improvement and recognises the role of behavioural factors in influencing HSE performance and outcomes and demonstrating management commitment. A structured Safe Act Observation program (SAO) operates across all sites and is reported on and monitored in accordance Altura`s HSEMS Standards for HSE Performance Reporting. Refer to: AJM-HSEMS-STD-006 Safe Act Observation 17.4 HSE Performance All work scopes are required to submit HSE Data Reports to Altura`s HSE Manager on a monthly basis, for compilation into a Altura HSE Performance Report. The monthly performance reports allow for the effectiveness of operational controls to be monitored by Altura`s Management Team and evaluated against Altura`s objectives and targets. The Monthly Altura HSE Performance Report is circulated and made available to all personnel in compliance with the commitment to communicate HSE information across the organisation. Refer to: AJM-HSEMS-STD-015 HSE Performance Reporting 17.5 Corrective & Preventative Actions The process of Hazard Identification, Risk Assessment and Control is fundamental to the establishment and maintenance of safe workplaces, and may be instigated in a number of ways including Incident Reports HIRAC processes, Hazard Observation Process Safe Act Observation Processes Workplace Inspections Where any of the above processes identify a need for corrective or preventative action, the status of the action is reported in the Corrective Action Register which is regularly updated and published. AJM-HSEMS-MAN-001_1 Page 23 of November-2016

24 For detailed requirements and guidance on any of these processes, Refer to: AJM-HSEMS-STD-001 Incident Reporting & Investigation AJM-HSEMS-STD-002 Hazard Identification Risk Assessment & Control AJM-HSEMS-STD-004 Hazard Observation Reporting AJM-HSEMS-STD-006 Safe Act Observation AJM-HSEMS-STD-017 Workplace Inspection AJM-HSEMS-STD-018 Auditing 17.6 Incident Reporting and Investigation The reporting and investigation of all accidents, injuries, near-misses and other events which Altura`s HSEMS seeks to prevent (collectively referred to as incidents ), is a fundamental and mandatory cornerstone of Altura`s continuous improvement process. The Altura HSEMS standard for Incident Reporting & Investigation applies to all work scopes, and must be utilised in addition to any other legislative, contractor or work scope requirement. The Incident Reporting & Investigation process is designed to: Communicate, in a timely and appropriate manner, the details of the event and any subsequent learnings Evaluate the actual and potential severity of events in a consistent manner to ensure that appropriate resources are allocated to investigations Investigate the event to establish the facts and identify contributing factors Develop corrective and preventative actions which address the contributing factors Monitor the implementation of corrective actions Record information Refer to: AJM-HSEMS-STD-001 Incident Reporting & Investigation 17.7 Statutory Reportable Events Certain events related to HSE may require reporting to statutory authorities. The Altura Incident Reporting process ensures that all reports are reviewed by qualified HSE personnel, who are able to advise management of statutory reporting requirements Injury Management In accordance with Altura`s HSEMS Standard for Injury Management and Rehabilitation, the status of any person injured during the course of their employment will be continually monitored and evaluated with the aim of responsibly returning the employee to full and unrestricted duties at the earliest opportunity. Refer to: AJM-HSEMS-STD-023 Injury Management and Rehabilitation 17.9 Workers Compensation Altura shall maintain Workers Compensation Insurance policies in accordance with legislation, and shall ensure that Claims for Compensation are managed in accordance with the applicable Legislation Refer to: AJM-HSEMS-STD-024 Workers Compensation Claims Management AJM-HSEMS-MAN-001_1 Page 24 of November-2016

25 18.0 Environment 18.1 Dust Monitoring The Pilbara naturally experiences high dust levels at certain times of the year. Dust generated by exploration, construction, mining, processing, and transport activities can have a significant impact on local air quality and vegetation. Airborne dust can reduce local amenity for personnel and others. Dust accumulating on plants can interfere with photosynthesis and respiration and can lead to plant mortalities, usually when other stresses such as drought are also present. Altura is committed to minimising the environmental impacts of dust with the objectives of: Minimise dust generation from construction, mining, processing and transport activities. Minimise impacts on local air quality and vegetation 18.2 Waste Management Altura generates a range of waste products during its exploration, construction, and operation phases. It is important that the production of waste is minimised and that opportunities for recycling and re-use of materials are recognised and adopted wherever feasible. Where disposal of waste is necessary, it must be done in a manner that minimises the environmental impact and is compliant with all licence conditions. Altura is committed to minimising the environmental impacts of waste with the objectives of: To operate with no putrescible (Class II) landfills to ensure minimal environmental impact. To maximise recycling and re-use. To comply with all legislation and codes of practice in relation to waste management. Remove all waste from site 18.3 Sewage and Waste Water Management Sewage and wastewater will be generated from constructions camps, crib rooms and ablutions within the projects areas. Sewage and wastewater has the potential to infiltrate surface waters and ground waters, cause odours and pollute soil if not adequately controlled. Management Action for Sewage and Wastewater as per following: All personnel informed of the importance of sewage and waste water management Any spills from portable toilets will be reported as an incident 18.4 Hazardous Material Management Altura is committed to minimising the potential for hazardous substances and dangerous goods to pose a risk to health safety and the environment. Altura are committed to having a hazardous material management process to: Maximise compliance with the requirements for the use, storage and handling of chemicals, hazardous materials Maximise and encourage the use of chemicals that present a lower risk Minimise the total number of chemicals Minimise the potential for environmental issues from the use of chemicals and hazardous materials 18.5 Topsoil / Vegetation Management Altura is committed to managing and minimising environmental impacts resulting from its exploration, construction, and operations phases. The identification and recovery of topsoil must be planned at the beginning of all land disturbance works irrespective of size. AJM-HSEMS-MAN-001_1 Page 25 of November-2016

26 The planning shall incorporate Mine Infrastructure or Construction Infrastructure requirements for topsoil and subsoil. Suitable topsoil and subsoil stockpile locations shall be identified for storage. The site selected for storage should ideally be flat, safe from floods and future mining activities. The areas to be cleared shall be demarcated and included in the Ground Disturbance Permit Minimising vegetation clearing required for Altura is vital to manage and reduce potential impacts on native flora. Furthermore, the efficient reuse of cleared vegetation and topsoil will help to control erosion, provide a source of seed and organic matter for progressive rehabilitation activities and promote re-colonisation of fauna in disturbed areas. The aim of Altura is to ensure that only essential vegetation clearing is undertaken, no unauthorised clearing occurs, and that valuable vegetation and topsoil material is reused to effectively rehabilitate disturbed areas Ground Disturbance and Clearing The Ground Disturbance Permit (GDP) manages Altura`s environmental commitments and responsibilities. The GDP process is the final internal review and authorisation of proposed ground disturbing works prior to the commencement of any ground disturbing activities. Under various legislation there are penalties for unauthorised clearing. For example, under the Environmental Protection Act 1986, penalties extend up to a maximum of $500,000 and 5 years gaol for individuals and $1 million for companies. There are also penalties under the Aboriginal Heritage Act 1972 for non-authorised disturbance of Aboriginal sites. Altura is committed to minimising the environmental impacts of unauthorised ground clearing by: Outlining the process and the steps required prior to conducting ground disturbing activities Outlining the conditions for conducting ground disturbing activities on site Minimising adverse impacts from clearing Ensuring compliance with regulatory requirements Preventing the unauthorised clearing or disturbance of land Ensuring due diligence in the management of ground disturbing activities by Altura or its contractors. An approved Ground Disturbance Permit (GDP) is required for any mechanical work or construction activities by Altura or its contractors that will in any way change or disturb the ground surface. Without limitation, this includes grading, excavating, blasting, digging, quarrying, drilling, top soil stripping, land levelling, trenching, native vegetation clearing Flora and Fauna Management Altura is committed to mitigate or prevent impacts on native flora and fauna. The objective is to minimise impact on native flora and fauna and their habitat, particularly species of conservation significance. To ensure that native flora and fauna species are not adversely affected by site works Altura will provide guidance through dedicated: Flora and fauna standards, plans and procedures. Altura`s operations may result in loss of fauna habitat from direct impacts, such as collisions with vehicles, are likely. Where fauna of significance is at risk of impact from the works, specific management plans will be written. No species of Priority Flora have been recorded during flora and vegetation surveys within Altura`s site. No species declared rare (and threatened) under State legislation have been recorded. Altura aims to ensure that impacts on all flora are minimised and that special consideration is given to all species when planning revegetation work. The objective is not to decrease the abundance of flora within the site area AJM-HSEMS-MAN-001_1 Page 26 of November-2016