ENVIRONMENT, HEALTH & SAFETY MANAGEMENT SYSTEM MANUAL

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ENVIRONMENT, HEALTH & SAFETY MANAGEMENT SYSTEM MANUAL Revision No: 00 Issued On: 1-02-2016 Written By: EHS Management Representative Sign:.. Approved By: Commercial & Sales Manager Sign:.

ISO 14001:2004, OHSAS 18001:2007 Contents 1. INTRODUCTION... 3 2. SCOPE... 3 3. TERMS AND DEFINITIONS... 3 4. MANAGEMENT SYSTEM REQUIREMENTS... 5 4.1 General Requirements... 5 4.2 Management System Policies... 6 4.3 Planning... 6 4.3.1 Hazard identification, Risk/Impact Assessment and Determining Controls... 6 4.3.2 Legal and Other Requirements... 9 4.3.3 Objectives and Program(s)... 10 4.4 Implementation and Operation... 10 4.4.1 Resources, Roles, Responsibility, Accountability and Authority... 10 4.4. 2 ComUALence, Training and Awareness... 11 4.4.3 Communication, Participation and Consultation... 11 4.4.4 Documentation... 12 4.4.5 Control of Documents... 12 4.4.6 Operational Control... 12 4.4.7 Emergency Preparedness and Response... 13 4.5 Checking... 13 4.5.1 Performance Measurement and Monitoring... 13 4.5.2 Evaluation of Compliance... 13 4.5.3 Incident Investigation, Nonconformity, Corrective Action and Preventive Action... 13 4.5.4 Control of Records... 15 4.5.5 Internal Audit... 15 4.5.6 Management Review... 15 D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 2 of 17

INTRODUCTION This manual describes the Management System of Unicorn Arabia Limited and is the controlling document for all aspects of Occupational Health and Safety and the Environment. The Management System is based on Integration of Occupational Health and Safety and Environmental Management Systems. It carries out the activities in an effective way, combining two standards. The first of these is OHSAS 18001:2007 for obtaining the satisfaction of employees, clients and any other interested party with a safe work environment provided. The second is ISO 14001:2004 for corporate social responsibility and obtaining satisfaction of all interested parties. This Manual serves as a high level road map to Unicorn Arabia Limited and to house the procedures which Unicorn Arabia Limited follows in implementing its. 1. SCOPE This Management System manual is based on the requirements of OHSAS 18001:2007 and ISO 14001:2004 and details the specific controls established, documented and maintained at UAL in the execution of its operations as mentioned in the Part-I of this manual. This manual demonstrates the methodology adopted at Unicorn Arabia Limited to meet the requirements specified in these standards and refers to documented procedures, established and maintained at Unicorn Arabia Limited under the scope of activities as follows Engineering/mechanical/industrial works Leasing Plants and Equipment s Trade in building construction (such as: residential building-shops-marketsfactories-hotels) 2. TERMS AND DEFINITIONS Terms Definitions Acceptable Risk Audit Auditor Continual Improvement Risk that has been reduced to a level that can be tolerated by the organization having regard to its legal obligations and its own. Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which audit criteria are fulfilled. person with the competence to conduct an audit Recurring process of enhancing the Management System in order to achieve improvements in overall. D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 3 of 17

EHS Performance Corrective Action Preventive action Document Hazard hazard identification Ill Health Incident Interested Party Nonconformity Occupational health and safety (O&HS) EHS Management System EHS objective EHS performance EHS Policy Organization Procedure Risk Risk Assessment Environment Environmental Aspect Environmental Impact consistent with the UAL Policies Action to eliminate the cause of a detected nonconformity or other undesirable situation Action to eliminate the cause of a potential nonconformity or other undesirable potential situation. Information and its supporting documents. Source, situation, or act with a potential for harm in terms of human injury or ill health or a combination of these. Process of recognizing that a hazard exists and defining its characteristics Identifiable, adverse physical or mental condition arising from and/or made worse by a work activity and/or work-related situation Work-related event(s) in which an injury or ill health (regardless of severity) or fatality occurred, or could have occurred Person or group, inside or outside the workplace concerned with or affected by the EHS& E performance of an organization Non-fulfillment of a requirement conditions and factors that affect, or could affect, the health and safety of employees or other workers (including temporary workers and contractor personnel), visitors, or any other person in the workplace Part of an organization s management system used to develop and implement its EHS policy and manage its EHS risks EHS goal, in terms of EHS performance, that an organization sets itself to achieve Measurable results of an organization s management of its EHS risks Overall intentions and direction of an organization related to its EHSE performance as formally expressed by top management Company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether incorporated or not, public or private, that has its own functions and administration Specified way to carry out an activity or a process Combination of the likelihood of an occurrence of a hazardous event or exposure(s) and the severity of injury or ill health that can be caused by the event or exposure(s) Process of evaluating the risk(s) arising from a hazard(s), taking into account the adequacy of any existing controls, and deciding whether or not the risk(s) is acceptable surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation element of an organization's activities or products or services that can interact with the environment any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization's environmental aspects D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 4 of 17

Environmental Management System Environmental Objective Environmental Performance Environmental Target Prevention of Pollution part of an organization's management system used to develop and implement its environmental policy and manage its environmental aspects overall environmental goal, consistent with the environmental policy, that an organization sets itself to achieve measurable results of an organization's management of its environmental aspects detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts. 3. MANAGEMENT SYSTEM REQUIREMENTS 3.1 General Requirements Unicorn Arabia Limited has established documented, implemented, maintained and continually improve Management System in accordance with the requirements of OHSAS 18001:2007 and ISO 14001:2004 Standards and has determined controls to demonstrate its ability to meet these requirements. D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 5 of 17

4.2 Management System Policies Management System Policies based on the requirements of OHSAS 18001:2007 and ISO 14001:2004 integrated with ISO 9001 are established, documented and implemented and attached to this manual as under: ENVIRONMENT, HEALTH & SAFETY POLICY Unicorn Arabia Limited shall commit and ensure the; Health and Safety of its employees, visitors and the community at large and protect the physical environment in which the company s recruitment process is carried out. The Management and Staff of Unicorn Arabia Limited shall: Implement a EHS management system conforming to OHSAS 18001:2007 & ISO 14001:2004 and strive to its continual improvement Identify and control the process and product effectively. Ensure the safety and welfare of our staff and the protection of our assets. Ensure the prevention of any impact on the environment resulting from our actions. Comply with all relevant Environmental, Health & Safety legal laws and other requirements. Identify the hazards assess the and manage those risks Periodically review the suitability, adequacy and effectiveness of the (EHS) management system. Make every effort to protect the environment and prevent pollution, to minimize consumption of materials, to promote reuse and recycling of wastes and adopt best practice on waste management. Prevent accidents and cases of work-related ill-health. Ensure that the company s EHS policy is well communicated to all quarters concerned. 4.3 Planning 4.3.1 Hazard identification, Risk/Impact Assessment and Determining Controls Unicorn Arabia Limited has established, implemented and maintains a procedure for the ongoing hazard identification, risk/impact assessment, and determination of necessary controls. D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 6 of 17

PLANNING OF HAZARD IDENTIFICATION, RISK ASSESSMENT & RISK CONTROL STEP 1 IDENTIFY THE HAZARD STEP 2 ASSESS THE RISK STEP 3 ANALYSE RISK CONTROL MEASURES STEP 4 MAKE CONTROL DECISIONS STEP IMPLEMENT RISK CONTROL Each of the identified Hazards events is assessed for risks based on a Combination of the likelihood and consequence(s) of its occurrence. Risk assessment, risk level and ranking of each hazard is identified and recorded in Safety Risk Assessment. The three key aspects of risks are considered during the assessment process Likelihood the estimate of the likelihood that a hazard will cause a loss (Categories High, Medium and low) Severity the estimate of the extent of loss that is likely. (Categories Major, Severe and Slight) Exposure group of personnel or resources affected by a given event or overtime by repeated events. The Risk Assessment Matrix is used for the each hazard identified (see below).the Risk Assessment process is conducted individually and then compared with the team conducting the same assessment in order to identify the appropriate risk level. Each risk is labeled with its significance (Extremely High, High, Medium, Low etc.) to see the level and priority of the risk and their individual significance. The risk level is considered as high if there is a legal requirement any other related requirement by the customer. D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 7 of 17

SEVERITY MAJOR Fatality / severe injury SERIOUS More than 3 days off work SLIGHT None or less than 3 days off work LIKELIHOOD HIGH Likely to occur frequently MEDIUM Likely to occur occasionally LOW Unlikely to occur Risk control measures are taken for the identified potential hazards in Safety Risk Assessment. Action is taken to investigate specific strategies and tools that reduce, mitigate or eliminate risk. Areas such as effective control measures for reduction and elimination of one of the three components (Likelihood, severity or exposure) of risk and risk control costs and how various risk control options work together are considered during this process. The following are the risk control methods Elimination Substitution Engineering controls Signage, warnings, administrative controls Personal protective equipment s D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 8 of 17

OH&S and ENVIRONMENTAL MANAGEMENT PROGRAMMES In order to achieve its OH&S / Environment Objectives, Management Programs are identified; upon Significant Aspects and concerns are initiated identifying designations, responsibility and authority for achievement of the objective and a clear description of the means and time frame by which the objectives are achieved. Status of Action Plan is updated periodically by Management Representative and review during Management Review. In case of any changes to the activity, product, services or operating conditions the same is updated and communicated accordingly by Management Representative. OH&S and ENVIRONMENTAL MANAGEMENT PROCEDURE The Environmental Impact & Occupational Health & Safety Risk Management procedure provides a detailed methodology for identifying the environmental aspects of the Unicorn Arabia Limited business and develops control measures to its significant impacts that have or can have on environment in full compliance with the Legal and Other Requirements (LOR), to carry out an Occupational Health and Safety (OH&S) Hazard Identification, Risk Assessment and determine the Risk Control measures in full compliance with the Legal and Other Requirements (LOR). For the management of change, Unicorn Arabia Limited has identified the environmental aspects of its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence taking into account planned or new developments, or new or modified activities, products and services, and the OH&S hazards and OH&S risks associated with changes in Unicorn Arabia Limited the EHS management system, or its activities, prior to the introduction of such changes. Unicorn Arabia Limited ensures that the results of these assessments are considered when determining controls. When determining controls, or considering changes to existing controls, consideration shall be given to reducing the risks according to the following hierarchy: elimination; substitution; engineering controls; signage/warnings and/or administrative controls; Personal protective equipment. UAL documents and keeps the results and information of aspects that have or can have significant impact(s) on the environment (i.e. significant environmental aspects) and identification of hazards, risk assessments and determined controls up-to-date. UAL shall ensure that the OH&S risks and Environmental Aspects and determined controls are taken into account when establishing, implementing and maintaining its EHS management system. REFERENCE: Environmental Review, UAL-ER-PR-012 4.3.2 Legal and Other Requirements D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 9 of 17

UAL has established, implemented and maintains Legal & Other Requirements to identify and have access to the applicable legal requirements and other requirements to which UAL subscribes, related to Occupational Health & Safety and environmental aspects of its activities, and to determine how these requirements apply to UAL. UAL keeps this information up-to-date. These requirements are communicated to employees working under the control of UAL, and other relevant interested parties. 4.3.3 Objectives and Program(s) Unicorn Arabia Limited has established, implemented and maintains documented environmental objectives and targets, and OH&S objectives at relevant functions and levels within the organization. The objectives shall be measurable, where practicable, and consistent with the Environmental and OH&S policies, including the commitments to prevention of pollution, to the prevention of injury and ill health, to compliance with applicable legal requirements and with other requirements to which the organization subscribes, and to continual improvement. UAL takes into account legal and other requirements, environmental impact and OH&S risks, parties while establishing and reviewing its objectives. UAL also considers its technological options, its financial, operational and business requirements, and the views of relevant interested parties. UAL has established, implemented and maintain programs for achieving its objectives. These programs include as a minimum: designation of responsibility and authority for achieving objectives at relevant functions and levels of UAL; and The means and time-frame by which the objectives are to be achieved. These Programs are reviewed at regular and planned intervals, and adjusted as necessary, to ensure that the objectives are achieved. REFERENCE: Objectives & Targets Procedure, UAL-OT-PR-010. 4.4 Implementation and Operation 4.4.1 Resources, Roles, Responsibility, Accountability and Authority Top management of UAL is overall responsible for the implementation Environmental Management System the OH&S Management System. For the project specific roles, responsibilities, authorities & accountabilities refer to project specific Quality & HSE Plans. Top Management has appointed a Management Representative, (refer to letter of appointment) he is responsible for: D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 10 of 17

Ensuring that the EHS Management System is established, implemented and maintained in accordance with ISO 14001:2004 and OHSAS 18001:2007 Standards. Ensuring that reports on the performance of EHS management system are presented to top management for review during the management review meetings and used as a basis for improvement of the EHS management system. Management Representative is responsible to carry out the above functions with the help of the management, HSE Staff & all employees. 4.4. 2 Competence, Training and Awareness UAL has ensured by establishing a procedure for training that employees under its control performing tasks are competent on the basis of appropriate education, training or experience, and shall retain associated records. UAL identify training needs associated with its Environmental impacts and OH&S risks to make persons working under its control aware of: The Environmental impacts and OH&S consequences, actual or potential, of their work activities, their behavior, and the EHS benefits of improved personal performance; Their roles and responsibilities and importance in achieving conformity to the EHS policy and procedures and to the requirements of the EHS Management System, including emergency preparedness and response requirements. The potential consequences of departure from specified MS procedures. As per the Training procedure, trainings are provided to differing levels of responsibility, ability, language skills and literacy; and impacts/risks of activities. REFERENCE: Training Procedure, UAL-TAC-PR-14 4.4.3 Communication, Participation and Consultation UAL has established, implemented and maintains, Procedure for Communication and participation, with regard to its environmental aspects OH&S hazards and EHS Management System for: Internal communication among the various levels and functions of the organization; communication with contractors and other visitors to the workplace; Receiving, documenting and responding to relevant communications from external interested parties. Participation and consultation: Unicorn Arabia Limited has established, Implemented and maintains a procedure for Communication and participation, for the participation of workers by their: appropriate involvement in hazard identification, risk assessments and determination of controls; appropriate involvement in incident investigation; D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 11 of 17

involvement in the development and review of EHS policies and objectives; consultation where there are any changes that affect their EHS Management System; Representation on EHS matters. Nominated person(s) among workers, subcontractor s EHS representatives should attend EHS meetings, held on regular basis to discuss matters relevant to Management System. UAL ensures to attend meetings with its clients, consultants on regular basis to discuss pertinent EHS matters. 4.4.4 Documentation UAL has documented its EHS management system, documentation includes: the EHS policy and objectives; description of the scope of the EHS management system (this manual) description of the main elements of the EHS management system and their interaction, and reference to related documents; Documented Records established for EHS Management System. (As per List of Forms) 4.4.5 Control of Documents Unicorn Arabia Limited has established a documented procedure for the issuance, review, approval, revision, distribution, identification and irretrievability of documents as required by Management System. The procedure for documents and data control also defines the methodology of updating and amending the documents related to Management System. REFERENCE: Documents Control Procedure, UAL-CDR-PR-01 4.4.6 Operational Control UAL has established a procedure to determine those operations and activities that are associated with the identified hazard(s)/ environmental aspects where the implementation of controls is necessary to manage the OH&S risk(s) and environmental impact. These controls include: operational controls, as applicable to UAL and its activities; UAL has integrated those operational controls into its overall Management System; controls related to purchased goods, equipment and services; controls related to contractors and other visitors to the workplace; documented procedures, to cover situations where their absence could lead to deviations from the EHS policy and the objectives; Stipulated operating criteria where their absence could lead to deviations from the Environmental and OH&S policies and objectives. REFERENCE: Operational Control Procedure, UAL-OPC-PR-011 D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 12 of 17

4.4.7 Emergency Preparedness and Response Unicorn Arabia Limited has established, implemented and maintains a procedure for Emergency Preparedness and Response to identify the potential for emergency situations and to respond to such emergency situations. UAL responds to actual emergency situations and prevent or mitigate associated adverse Environmental and OH&S consequences. In planning its emergency response UAL has taken into account the needs of relevant interested parties, e.g. emergency services and neighbors. UAL periodically tests its procedure to respond to emergency situations, where practicable, involving relevant interested parties as appropriate. UAL periodically reviews and, where necessary, revise its emergency preparedness and response procedure, in particular, after periodical testing and after the occurrence of emergency situations. REFERENCE: Emergency Response and Preparedness Procedure, UAL-EPR-PR-07 4.5 Checking 4.5.1 Performance Measurement and Monitoring Unicorn Arabia Limited has established, implemented and maintains Measurement & Analysis to monitor and measure performance of Management System on a regular basis. This procedure provides for: both qualitative and quantitative measures, appropriate to the needs of UAL; monitoring of the extent to which UAL s Environmental and OH&S objectives are met; monitoring the effectiveness of controls for EHS; proactive measures of performance that monitor conformance with the EHS programs, controls and operational criteria; reactive measures of performance that monitor environmental impact, ill health, incidents (including accidents, near-misses, etc.), and other historical evidence of deficient Environmental and OH&S performance; Recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective action and preventive action analysis. 4.5.2 Evaluation of Compliance Consistent with its commitment to compliance UAL has established, implemented and maintains a procedure for Measurement & Analysis, UAL-EHS-PR-09 for periodically evaluating compliance with applicable legal requirements. UAL evaluates compliance with other requirements to which it subscribes; UAL has combined this evaluation with the evaluation of legal compliance. 4.5.3 Incident Investigation, Nonconformity, Corrective Action and Preventive Action Incident Investigation D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 13 of 17

UAL has established, implemented and maintains Procedure for Incident Investigation and Reporting, UAL-HNI-PR-09, to record, investigate and analyze incidents in order to: determine underlying Environmental and OH&S deficiencies and other factors that might be causing or contributing to the occurrence of incidents; Communicate the results of such investigations. The investigations are performed in a timely manner. Any identified need for corrective action or opportunities for preventive action shall be dealt with in accordance with the Procedure for Corrective, Preventive Actions and Nonconformance. The Procedure for Corrective, Preventive Actions and Nonconformance provides measures to: identify the need for corrective action; identify opportunities for preventive action; identify opportunities for continual improvement; The results of incident investigations shall be documented and maintained as per Procedure for Records Control. REFERENCE: Investigation & Reporting Procedure, UAL-NCR-PR-04 Nonconformity, Corrective Action and Preventive Action Unicorn Arabia Limited established, implemented and maintains Procedure for Corrective, Preventive Actions and Nonconformance, for dealing with actual and potential nonconformities and for taking corrective action and preventive action. The procedure defines requirements for: identifying and correcting nonconformities and taking actions to mitigate their Environmental and OH&S consequences; investigating nonconformities, determining their causes and taking actions in order to avoid their recurrence; evaluating the need for actions to prevent nonconformities and implementing appropriate actions designed to avoid their occurrence; recording and communicating the results of corrective actions and preventive actions taken; and Reviewing the effectiveness of corrective actions and preventive actions taken. Where the corrective action and preventive action identifies new or changed hazards/impact or the need for new or changed controls, the procedure requires that the proposed actions shall be taken through a risk/impact assessment prior to implementation. Any corrective action or preventive action taken to eliminate the causes of actual and potential nonconformities shall be appropriate to the magnitude of problems and commensurate with the Environmental impacts and OH&S risks encountered. D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 14 of 17

UAL ensures that any necessary changes arising from corrective action and preventive action are made to the Management System Documentation. REFERENCE: Procedure for Corrective, Preventive Actions and Nonconformance, UAL-CAR-PR-05 4.5.4 Control of Records UAL has established and maintains records as per Procedure for Records Control, as necessary to demonstrate conformity to the requirements of its Management System, and the results achieved. The Procedure for Records Control provides details for the identification, storage, protection, retrieval, retention and disposal of records. And that record shall remain legible, identifiable and traceable. REFERENCE: Procedure for Records Control, UAL-CDR-PR-01 4.5.5 Internal Audit Unicorn Arabia Limited has established, documented and maintains Procedure for Internal Auditing, MS-04. This procedure ensures that internal audits of Management System are conducted at planned intervals to determine whether the Management System: conforms to planned arrangements for Management System, including the requirements of ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007; Audit programs are planned, established, implemented and maintained by UAL, based on the results of risk/impact assessments of UAL s activities, and the results of previous audits. Internal Audit procedure addresses: The responsibilities, competencies, and requirements for planning and conducting audits, reporting results and retaining associated records; and The determination of audit criteria, scope, frequency and methods. Selection of auditors and conduct of audits shall ensure objectivity and the impartiality of the audit process. REFERENCE: Procedure for Internal Auditing, UAL-IA-PR-03 4.5.6 Management Review Unicorn Arabia Limited has established, documented and maintains Procedure for Management Review. This procedure details the methodology adopted at UAL for the review of Management System, at planned intervals, to ensure its continuing suitability, adequacy and effectiveness. Reviews shall include assessing opportunities for improvement and the need for changes to the Management System, including the QMS, EMS and OH&S policies and objectives. Records of the management reviews are retained. D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 15 of 17

Input to management reviews includes among other requirements: results of internal audits and evaluations of compliance with applicable legal requirements and with other requirements to which UAL subscribes; The results of participation and consultation. relevant communication(s) from external interested parties, including complaints; the MS performance of the organization; the extent to which MS objectives have been met; status of incident investigations, corrective actions and preventive actions; follow-up actions from previous management reviews; changing circumstances, including developments in legal and other requirements related MS; and Recommendations for improvement. The output from management reviews are consistent with UAL s commitment to continual improvement and includes any decisions and actions related to possible changes to: MS performance; MS policies and objectives; resources; and Other elements of the Management System. Relevant outputs from management review are made available for communication and consultation. REFERENCE: Procedure for Management Review, UAL-MR PR-07 D o c # U A L - H S E - MN- 0 0 1 R e v # 0 0 Page 16 of 17