ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) MANUAL

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) MANUAL

TABLE OF CONTENTS LIST OF TABLES... 3 LIST OF FIGURES... 3 APPENDICES... 3 LIST OF ABBREVIATIONS... 4 1. CLAUSE 4.1 GENERAL REQUIREMENTS... 5 1.1. Corporate Structure and Organisation Chart... 5 1.2. Overview of the SPA - PoB EMS... 7 1.3. Scope of the EMS... 8 2. CLAUSE 4.2 ENVIRONMENTAL POLICY... 8 3. CLAUSE 4.3 PLANNING... 8 3.1. CLAUSE 4.3.1 Environmental Aspects and Impacts... 8 3.2. CLAUSE 4.3.2 Legal and Other Requirements... 9 3.3. CLAUSE 4.3.3 Objectives and Targets... 9 4. CLAUSE 4.4 IMPLEMENTATION AND ORIENTATION... 11 4.1. CLAUSE 4.4.1 Resources Roles and Responsibilities... 11 4.2. CLAUSE 4.4.2 Competence, Training and Awareness... 11 4.3. CLAUSE 4.4.3 Communication... 12 4.4. CLAUSE 4.4.4 Documentation... 12 4.5. CLAUSE 4.4.5 Control of Documents... 12 4.6. CLAUSE 4.4.6 Operational Control... 14 4.7. CLAUSE 4.4.7 Emergency Preparedness and Response... 15 5. CLAUSE 4.5 CHECKING... 16 5.1. CLAUSE 4.5.1 Monitoring and Measurement... 16 5.2. CLAUSE 4.5.2 Evaluation of Compliance... 16 5.3. CLAUSE 4.5.3 Non-Conformity, Corrective Actions and Preventive Actions. 17 5.4. CLAUSE 4.5.4 Control of Records... 18 5.5. CLAUSE 4.5.5 Internal Audit... 18 6. CLAUSE 4.6 MANAGEMENT REVIEW... 18 7. Reference Documentation... 19 8. GLOSSARY OF TERMS... 24 APPENDIX A Environmental Policy... 25 Document Owner: HSE Manager Revision No: 02 Revision Date: 17/05/2017 UNCONTROLLED WHEN PRINTED Page 2 of 25

LIST OF TABLES Table 1 SPA-PoB Senior Management Positions... 6 Table 2 Description of Document Types... 14 Table 3 Risk Acceptance Criteria and Decision Base Table... 17 Table 4 Environmental Terms and Definitions... 24 LIST OF FIGURES Figure 1 Document Hierarchy System... 13 Figure 2 SPA-PoB Emergency Preparedness and Response Framework... 16 APPENDICES Appendix A Environmental Policy UNCONTROLLED WHEN PRINTED Page 3 of 25

LIST OF ABBREVIATIONS ARC BAU CFO GM - PORTS DDDP DER DoT EMS HSE IMS IMT ISO JSA KPI MOSCP MSIC NORM OEPA OHS PDF PoA PoB PoE PCLC RMPG RMS RTAP GM P & O SPA SOP WA Audit and Risk Committee Business as Usual Chief Finance Officer General Manger Port Development Due Diligence Proposal Department of Environment Regulation Department of Transport Environmental Management System Health, Safety and Environment Invasive Marine Species Incident Management Team International Organization for Standardisation Job Safety Analysis Key performance indicators Marine Oil Spill Contingency Plan Marine Security Identification Card Naturally Occurring Radioactive Materials Office of the Environmental Protection Authority Occupational Health and Safety Portable Document Format Port of Albany Port of Bunbury Port of Esperance Port Community Liaison Committee Risk Management Plan and Guidelines Records Management System Risk Treatment Action Plans General Manager People and Organsiation Southern Ports Authority Standard Operating Procedure Western Australia UNCONTROLLED WHEN PRINTED Page 4 of 25

1. CLAUSE 4.1 GENERAL REQUIREMENTS The Southern Ports Authority (SPA) was established on 1 October 2014 following the merger of the Albany Port Authority, Bunbury Port Authority and Esperance Ports Sea and Land. The legislation enabling the merger of the ports, The Ports Legislation Amendment Act 2013, was given Royal Assent on 21 May 2014. The Ports of Albany (PoA), Port of Bunbury (PoB) and Port of Esperance (PoE) continue to operate under local management, with supervision and governance under the SPA. The SPA is responsible to and reports to the Minister for Transport of the State of Western Australia (WA). It is committed to contribute to the economic growth and development of the State of WA by facilitating trade in a commercial, efficient and sustainable manner. To achieve this objective, the SPA-PoB is committed to implementation of Environmental Management System (EMS) principles throughout its day to day operations and future planning. This document provides information for understanding the structure of the EMS of the SPA-PoB. It identifies organisational structure, planning activities, roles and responsibilities within the organisation, development of staff and processes, and the procedures for continual improvement. 1.1. Corporate Structure and Organisation Chart The corporate structure comprises a SPA Board of Directors (Board) responsible for the governance of the three ports (PoA, PoB and PoE). The SPA Board is accountable to the Minister for Transport. The Accountable Officer for the SPA-PoB is the General Manager Bunbury/Albany Ports (GM - Port). Subject to the direction of the Board and the Chief Executive Officer (CEO), the GM - Port is responsible for and has all the powers needed to administer the day to day operations of PoB. More specifically, the GM - Port is responsible for policy implementation, achieving corporate objectives including those related to environmental performance, occupational health and safety, security, planning, marketing, port development, industrial relations and community liaison. The members of SPA-PoB s Senior Management report to the GM Port. The position descriptions for each member of the Senior Management Team are provided in Table 1. UNCONTROLLED WHEN PRINTED Page 5 of 25

Table 1 SPA-PoB Senior Management Positions Position Manager Operations & Maintenance Description The Manager Operations & Maintenance is responsible for landside port operations planning, infrastructure, port maintenance and protection of the environment and includes the Mine Manager role for certain port activities and locations. GM Health, Safety Environment and Security (GM-HSES) Deputy Harbour Master Health Safety and Environment (HSE) Manager Manager Engineering & Projects The GM-HSES is responsible for the implementation of the HSES systems across all Southern Ports sites. The Deputy Harbour Master is responsible for the control, safe movement and mooring of vessels in the port, hydrographic surveys and monitoring surveys, management and co-ordination of maintenance dredging and ocean disposal of dredged material, oil pollution control, emergency response planning and shipping information. The HSE Manager is responsible for the development and implementation of HSE plans, implementing environmental monitoring programs, liaising with industry regulators, provision of advice on HSE matters to the SPA-PoB and port user personnel, community liaison on HSE issues related to port operations and identification and management HSE risk. Manager Engineering & Projects - responsible for the development of plans from initial design and estimation through to completion in line with the defined objectives of the Port of Bunbury Inner Harbour Structure Plan 2009 and working with the Operations and Maintenance Manager to ensure that ongoing plans/schedules are developed to ensure all Port Infrastructure is in safe working order and in accordance with applicable Standards. The Manager Engineering & Project also ensures that the scope of a project is clearly defined, time managed, competitively priced and in accordance with civil and structural engineering standards and codes of safe and environmental practice. Port Senior Management are collectively responsible for ensuring that the strategies outlined in the SPA Environmental Policy are supported and implemented and to facilitate this, the Senior managers are supported by appropriately trained and qualified administration, technical, scientific, operational and maintenance personnel. In addition, external environmental consultancies are also engaged as required to undertake environmental monitoring and investigations and to provide advice. UNCONTROLLED WHEN PRINTED Page 6 of 25

1.2. Overview of the SPA - PoB EMS The SPA-PoB EMS has been established, documented and supported with the specific objective of ensuring that all port related activities under the direct day to day control of the SPA-PoB Senior Management achieve the environmental commitments set out in the Environmental Policy and meet ISO 14001 requirements. The EMS is designed to enable the SPA-PoB to address both environmental and compliance imperatives by creating a system of processes, plans and procedures that guide its performance against its environmental objectives and targets. The ISO 14001 standard emphasises continual improvement in the performance of the system and through this, improvements in the SPA-PoB s environmental performance are expected to result. The SPA-PoB believes that sound environmental management is a key component of its overall management responsibility both from a corporate and community responsibility perspective. The cornerstones of the EMS are: Development of an Environmental Policy; Development and implementation of Environmental Objectives and Targets; Identification of environmental risks in accordance with the SPA Risk Management Framework Ongoing monitoring and reviewing of environmental performance; and Continuous improvement of the EMS to further enhance the SPA-PoB s environmental performance. The SPA Board sets environmental policy and strategic direction and the EMS is implemented, managed and monitored by the SPA-PoB senior management team as part of the commitment to minimise operational impacts on the environment and community. The Environmental Policy, EMS manual, Risk Register, plans, other registers and procedures are the key EMS documents. They are found within the SPA-PoB s Synergy Records Management System (RMS), on the SPA-PoB s website and on the Intranet. This EMS manual describes how the SPA-PoB will implement its environmental management system and monitor its environmental performance. The format of the Plan will be consistent with the AS/NZS ISO 14001-2004 environmental system requirements and describe the systems and processes actioned by the SPA-PoB to meet the requirements of this International Standard. UNCONTROLLED WHEN PRINTED Page 7 of 25

1.3. Scope of the EMS The EMS applies to all SPA-PoB operations and administration functions under the direct day to day control of the SPA-PoB Senior Management, excluding those activities conducted by lease holders on leased sites within the port, their contractors, the licenced towage company, the lines boats and the licensed stevedores. In addition, the EMS includes all marine areas within the SPA-PoB limits including the shipping channel and at the spoil ground for the purposes of periodic maintenance dredging, dredge material disposal and periodic sediment, water chemistry and invasive marine species monitoring. 2. CLAUSE 4.2 ENVIRONMENTAL POLICY The SPA Environmental Policy document is provided in Appendix A. 3. CLAUSE 4.3 PLANNING 3.1. CLAUSE 4.3.1 Environmental Aspects and Impacts Environmental aspects (risks) and impacts are identified and recorded by the SPA- PoB within the Environmental Section of the Risk Register. The Risk Register is a live document and updated as soon as new risks are identified. Environmental risks may also be captured under other parts of the register that refer to operational, marine or administrative functions of the port that may result in environmental impacts. In addition, environmental risks and impacts may also be identified through the Development Due Diligence Proposal (DDDP) process (Synergy File Ref. No SMT1/11). The process for identifying aspects (risk) and impacts and assigning a risk rating is described in the Risk Management Plan and Guidelines or RMPG (Synergy File Ref. No. SMT1/11), which is consistent with the International Standard ISO 31000 Risk Management Principals and Guidelines. The SPA-PoB follows a risk calculation process which is detailed in the RMPG. Any new environmental risks and impacts are formally added to the Risk Register at monthly Risk Meetings that involve Senior Management and other SPA-PoB staff. The Risk Meetings are chaired by the Occupational Health, Safety (OHS), Risk and Security Officer. (Note: the structure of the risk management process within PoB is under review by the SPA Board). The decision base for rated risk is set out in the Risk Acceptance Criteria and Decision Base Table in the RMPG. Risk Treatment Action Plans (RTAPs) are prepared for medium, high and extreme risks. The RTAPS identify the risk and its possible impact, document the history and existing controls and identify actions to address the risks. UNCONTROLLED WHEN PRINTED Page 8 of 25

The RTAPs for medium, high and extreme risks are reviewed and approved either by the Audit and Risk Committee (ARC) which is chaired by a SPA Board representative. Recommendations from the ARC are then considered by the full Board. 3.2. CLAUSE 4.3.2 Legal and Other Requirements The SPA-PoB has access to applicable legal and other compliance requirements relating to its EMS through subscription to the on-line service Environment Essentials (www.enviroessentials.com.au). This service provides monthly advisories on changes to environmental legislation and is e-mailed to the HSE Manager and Environmental Officer. All SPA-PoB staff have access to this on-line service via the External Publications section of the Intranet. Changes to legislative and compliance requirements are noted in the register. Where significant changes to the legislation are noted and applicable to the SPA-PoB, these are communicated within the monthly Management Report that is part of the monthly Board meeting agenda. Pertinent changes are also discussed at the SPA- PoB weekly Morning Meeting and the weekly Trade and Infrastructure meeting. Changes are also discussed at the monthly HSE and General Staff meeting. HSE staff have internet access to the websites of the Western Australian Environmental Protection Authority (www.epa.wa.gov.au), the Department of Environment Regulation (www.der.wa.gov.au) and the Department of the Environment (www.environment.gov.au) and visit these periodically to check for notification of legislation changes. The SPA-PoB is also a member of Ports Australia (www.portsaustralia.com.au) and receives regular e-mail communications from this organisation with regard to proposed changes to environmental legislation as it directly affects ports and requests for input during comment periods for proposed legislative change. The SPA-PoB has also established a Legal Obligations Register which is maintained by the Environmental Officer. 3.3. CLAUSE 4.3.3 Objectives and Targets The SPA-PoB sets its objectives and targets such that they support the environmental commitments and strategies as set out in the Environmental Policy. Objectives and targets are also set with reference to the high and extreme rated environmental risks identified within the Risk Register. The SPA-PoB has developed an Objectives and Targets tracking spread-sheet which is updated by the HSE Manager or the Environmental Officer. The spreadsheet also sets out key performance indicators (KPI s) for each objective and target and monitors performance against the KPI s every six months. Objectives and targets are set for: UNCONTROLLED WHEN PRINTED Page 9 of 25

Air Quality Preston River water and sediment quality Marine Water and sediment quality Noise Heritage Invasive Marine Species (IMS) Naturally Occurring Radioactive Materials (NORM) Greenhouse Gases Odour Environmental Management Plans: Environmental Management Plans (EMPs) have been written to outline the processes for the various monitoring programs to achieve the objectives and targets as follows: Air Quality Management Plan Invasive Marine Species (IMS) Management Plan Long Term Dredge Materials Management Plan Noise Management Plan Waste Management Plan Risk Management Plan Odour Management Plan Environmental Management Program: The environmental management program has been developed to ensure legal compliance with but not limited to the requirements of the Ports Legislation Amendment Act 2014, the Environmental Protection Act 1986, the Environmental Protection (Sea Dumping) Act 1981 and subsequent amendments and the conditions set out in the SPA-PoB s Berth 8/5 Environmental Licences and its 10 Year Sea Dumping Permit. In addition, the program is also designed to achieve the objectives and targets described in the Environmental Objectives and Targets. The progress of the environmental management program is tracked on the Objectives and Targets tracking spread sheet maintained by the Environmental Officer. Senior Management and other staff are informed of progress of the environmental management program at the weekly Morning Meeting and the weekly Trade and Infrastructure meeting. Changes are also discussed at the monthly HSE and General Staff meeting.. The SPA Board is informed through the monthly Management Report that forms part of the monthly Board meeting agenda. In addition, monthly reports go to the Boards s Health, Safety and Environment Committee (HSEC) which in turn provided feedback to the full Board. Responses from the Board on the environmental management program are communicated to the relevant PoB senior manager by the GM - Port. UNCONTROLLED WHEN PRINTED Page 10 of 25

4. CLAUSE 4.4 IMPLEMENTATION AND ORIENTATION 4.1. CLAUSE 4.4.1 Resources Roles and Responsibilities Job descriptions have been developed for all SPA-PoB staff which set out responsibilities and authorities to facilitate effective environmental management. The SPA-PoB has provided adequate staff resources to implement and control the EMS through the employment of personnel with specific competencies and experience in environmental science and port operations, both marine and landbased. The SPA-PoB employs an HSE Manager and an Environmental Officer. The HSE Manager reports directly to the SPA-GM HSES (commence 8 May 2017) who reports directly to the SPA CEO. The GM HSES is a member of the SPA Executive Leadership Team (ELT). Sufficient budget allocations are made each financial year for environmental activities and adequate in-house monitoring equipment is available. External specialist environmental consultancies are engaged as required for environmental monitoring, survey and analysis work plus the provision of ad-hoc advice. Training needs are identified when circumstances dictate the need for new or further training and awareness. There is a specific process in place for staff to apply through their Manager or Supervisor to the GM PEOPLE & ORGANISATION with GM - Ports approval, for access to external training and development programs to maintain or increase skills in environmental management or environmental technical skills. The Operations and Maintenance Manager and the Marine Manager/Harbour Master positions have specific authorities and responsibilities for ensuring that the port is controlled to ensure that loading activities and shipping do not cause adverse environmental impacts. The Marine Manager/Harbour Master is the officer with specific responsibilities for emergency management, the most significant part of which is the prevention of and control of oil or chemical spills into the marine environment. The Operations and Maintenance Manager also assumes Mine Manager responsibilities under the Mines Safety and Inspection Act. 4.2. CLAUSE 4.4.2 Competence, Training and Awareness The GM People & Organisation maintains SPA PoB training records that relate to the EMS. Issues relating to the EMS and environmental compliance in general are included on the agenda for the monthly HSE and General Staff meeting, the weekly Trade and Infrastructure Meeting and the quarterly Port Operations Forum and Port User meetings. Environmental issues are also included in the Management Report for the monthly Board meeting and the monthly report to the HSEC. UNCONTROLLED WHEN PRINTED Page 11 of 25

Environmental management issues are also included in the bimonthly Port Community Liaison Committee agenda. A significant section of the SPA-PoB on-line induction video is devoted to environmental awareness and requirements for working within the port. The induction is linked to the Maritime Security Identification Card (MSIC) application process at the SPA-PoB. The induction video can be viewed at the SPA-PoB website (www.southerportsauthority.com.au). 4.3. CLAUSE 4.4.3 Communication Environmental aspects (risks) and impacts are recorded in the Risk Register. The Risk register is reviewed by the Senior Management Team and other staff at monthly Risk Team meetings. Further review of the medium, high and extreme ranked risks is undertaken at the Audit and Risk Committee (ARC) meetings and the Board meetings. External interested parties communicate through either hard copy, electronic (email or phone) or in-person at the SPA-PoB s Administration Office. Quarterly Port Operations Forum meetings at which environmental issues are an agenda item, include representatives from the SPA-PoB, lease holders, transport companies, emergency services, shipping agents, stevedores, towage companies, Boarder Force, and biosecurity. The HSE Manager is the key PoB contact for external regulatory agencies such as the Office of the Environmental Protection Authority (OEPA), Department of Environment Regulation (DER) and the Commonwealth Department of the Environment (DotE). An external contacts register is maintained within the Synergy System and with the Records Management System to record community or other interested party communications regarding port operations, in particular, environmental aspects (risk) and impacts such as noise or dust. The HSE Manager or delegate is the officer responsible for maintaining the contacts register and responding to external interested parties. 4.4. CLAUSE 4.4.4 Documentation The SPA-PoB has established a RMS within Synergy to electronically store all documents related to the EMS. The HSE Manager or delegate, through the Document Controller, ensures that electronic copies of approved EMS documents are forwarded to the Records Officer who then registers the document into the RMS with unique record number identifier. 4.5. CLAUSE 4.4.5 Control of Documents Approved EMS documents are registered within the RMS by the Document Controller or delegate. Documents retrieved from the RMS are in portable document format (PDF) and as such, are classified as a Read-only document. This is then UNCONTROLLED WHEN PRINTED Page 12 of 25

distributed to all SPA-PoB staff. The Document Controller maintains the Microsoft Word format of the document for revision or update by responsible SPA-PoB personnel. SPA-PoB staff has access to the EMS documents either in electronic form through the RMS and Intranet. Hard copy documents can be printed if required. Printed copies of EMS documents are identified with UNCONTROLLED WHEN PRINTED in the document footer. All EMS documentation is readily identifiable and dated and authorised. Retention, revision, suspension and archive of EMS documents are managed in accordance with SPA-PoB Record Keeping Plan 2012 (Synergy Ref. File No. SMT1/11). EMS Document review occurs on a biannual basis or when amendments are required due to changes in legislation or port operations. Document Hierarchy The SPA-PoB applies a document hierarchy system (Figure 1) as part of the documentation process. A document lower in the hierarchy must relate to, and be consistent with, documents higher in the hierarchy. Acts Guidelines Figure 1 Document Hierarchy System Details for each document type are described in Table 2. UNCONTROLLED WHEN PRINTED Page 13 of 25

Table 2 Description of Document Types Type Act Regulations and Referenced Standards Licence and Permits Policies Manuals Plans Procedures Guidelines Description An act means Australian common law, federal laws enacted by the Parliament of Australia, and laws enacted by the Parliaments of the Australian states and territories. The Ports Legislation Amendment Act 2014 has obvious and specific relevance to SPA-PoB operations. The Act specifies the requirements for; Annual Strategic Development Plan, Evidence of consideration of environmental management in strategic development of the port, the Authority s organisational structure, roles and responsibilities. Regulations and Referenced Standards means subsidiary regulations made under the Ports Legislation Amendment Act 2014 (the Act) governing specific internal affairs of the SPA. Licence and permits means a formal statement of the conditions which must apply to the conduct of key aspects of the port operations. These are usually issued by government regulators such as DMP, DER, EPA, Department of Transport (DoT) and the DotE. A Policy is a concise formal statement of principles which indicate how the Authority will act in a particular area of its operation, e.g. in relation to Human Resources, Health and Safety, Security or to Environment. A manual is a detailed overview of SPA PoB s Environmental Management System. It is a written account of existing and intended future courses of action (scheme) aimed at achieving compliance against relevant standards, i.e. ISO 14001 standard. A plan is a subsidiary document to Manual A Standard Operating Procedure (SOP) is a written document or instruction detailing all steps and activities of a process or procedure. Guideline means non-mandatory approaches to the implementation of licence/permit conditions, policies or procedures. Guidelines provide flexible "good practice" recommendations and advice to assist those responsible for implementing by-laws, rules, policies, or procedures and may include codes of conduct guiding behaviour. 4.6. CLAUSE 4.4.6 Operational Control The SPA-PoB has established a Risk Register that identifies normal operational activities and their associated environmental aspects (risk) and impacts. Risk UNCONTROLLED WHEN PRINTED Page 14 of 25

assessments are also conducted for new operations and for export proposals that have the potential for increased risk. The SPA-PoB requires all new proponents who wish to establish operations within the Port to complete a Development and Due Diligence Proposal (DDDP) form (Synergy Ref. File. No. SMT1/11). This form provides information regarding the nature of the proposed development, product characteristic, storage and loading methods and details of environmental impact issues such as air quality, water quality, noise, odour and visual impact. Standard Operating Procedures (SOPs) are written to manage day to day operational activities. Non-routine tasks may require a specific Job Safety Analysis (JSA) to be compiled that addresses environmental aspects (risk) and impacts and what controls are needed. Works undertaken at the Port by contractors are controlled through a Contractor Authorisation to Work process. Project tender conditions require the tenderer, during tender preparation, to take particular account of the requirements of Clause 14 of the General Conditions of Contract which includes reference to all relevant environmental laws. Inspections of loading equipment is undertaken prior to and during loading activities to ensure that plant and equipment controlling potential emissions to the environment such as dust control equipment, is in working condition. Maintenance of operational infrastructure is scheduled through the MEX Maintenance Software system and work is overseen by the Operations and Maintenance Manager or delegate. 4.7. CLAUSE 4.4.7 Emergency Preparedness and Response An Emergency Management Plan has been developed for the SPA-PoB. This Emergency Management Plan applies to all the SPA-PoB operations covering all emergencies involving the SPA-PoB and surrounding areas for which it has legal, ethical or community responsibilities. The plan is deliberately concise so that it actually assists the Incident Management Team (IMT) in a stressful situation. Business priorities in any emergency situation are firstly people, followed by environment and property including information. The Emergency Management Plan serves as the initial document to be consulted whenever a significant issue is encountered which falls outside the parameters of Business as Usual (BAU) at the PoB. These parameters are described in Section 1.6 of the Emergency Management Plan. This document forms part of and can be used in conjunction with a series of documents as detailed in Figure 2. UNCONTROLLED WHEN PRINTED Page 15 of 25

PREPARE Risk Management Plan RESPOND RECOVER Risk Register Standard Operating Procedures Emergency Management Plan Oil Spill Contingency Plan Business Continuity Plan Government Plans (Including WESTPLANS) Bunbury Emergency Management Arrangements (BEMA) Leaseholder Emergency Plans Maritime Security Plan IT Disaster Recovery Plan Pandemic Plan Figure 2 SPA-PoB Emergency Preparedness and Response Framework In addition, the Marine Oil and Chemical Spill Contingency Plan Action Plan (Synergy File Ref. No. SMT1/11) has been established to provide rapid access to essential information for personnel who are nominated for response roles or who may be required to report or respond to spills. The Action Plan contains key procedures from the SPA-PoB Marine Oil Spill Contingency Plan (MOSCP). The Marine Manager/Harbour Master is the officer responsible for the implementation and review of both of these plans. Emergency exercises are conducted periodically to test the SPA-PoB s preparedness for dealing with emergency events that may affect the Port and its environment. 5. CLAUSE 4.5 CHECKING 5.1. CLAUSE 4.5.1 Monitoring and Measurement The SPA-PoB has established a comprehensive program of environmental monitoring for the marine, terrestrial, riverine and estuarine areas of the port. Monitoring records are retained in the RMS. 5.2. CLAUSE 4.5.2 Evaluation of Compliance The SPA-PoB has established a Legal Obligations Register and monitors EMS compliance against the obligations set out in the Register. The HSE Manager or delegate is responsible for ensuring that compliance is evaluated and reviewed. Compliance is also monitored when reports from external consultants are submitted in relation to the SPA-PoB s environmental monitoring program as described in the Monitoring and Measurement element of this EMS Plan. UNCONTROLLED WHEN PRINTED Page 16 of 25

In addition, compliance is monitored during the SPA-PoB s mandatory Internal and External audit program. State regulatory agencies such as the DER and Department of Mines and Petroleum (DMP) undertake either ad hoc or planned audits of Authority operations for compliance against regulations or licences. Federal regulatory agencies such as the DotE also conduct audits. Compliance with respect to the conditions in licences issued by Western Australian regulatory agencies such as the DER is monitored and reported annually to the agency through Annual Audit Compliance Reports (AACR). Compliance with respect to permits issued by Federal regulatory Agencies such as the Department of the Environment (DotE) for sea dumping of dredged materials is monitored by the Marine Manager and reported through the HSE Manager or delegate as required by the Sea Dumping Permit conditions. 5.3. CLAUSE 4.5.3 Non-Conformity, Corrective Actions and Preventive Actions The Risk Management Plan sets outs a process for identifying actual and potential environmental risks that result in impacts that are non-compliant with legal and SPA-PoB s requirements. Corrective and preventative actions are discussed by senior management at risk meetings and Risk Treatment Action Plans (RTAPs) are developed to manage the risk or non-compliance. The extent to which the risk or non-compliance is treated is determined by the risk ranking. Depending on the risk ranking, the Risk Treatment Action Plan (RTAP) can be approved by the CEO, the GM - Ports, the ARC or the Board. Table 3 Risk Acceptance Criteria and Decision Base Table Risk Level Risk Criteria for Risk Management Decision Base 1-5 Low Monitor With adequate controls Chief Operating Officer 6-9 Medium Management Control Required 10-14 High Urgent Management Attention With adequate controls Only acceptable with excellent controls CEO/ARC to Board CEO/ARC to Board 15-25 Extreme Unacceptable Only acceptable with excellent controls ARC to Board In addition, inspections and audits of Port operations and administrative processes identify non-conformances that are corrected by line management. The nonconformance is recorded in the Action Register and usually communicated via UNCONTROLLED WHEN PRINTED Page 17 of 25

internal email and the records of corrective and preventative actions taken held on the RMS. Non-compliances identified by regulatory agencies are communicated to the SPA-PoB in either hard copy or electronic form. In the case of the DMP, environmental nonconformances are recorded in the Mines Record Book (and the DMP on-line SRS) which is held by the SPA-PoB s appointed Mine Manager. Non-conformances identified by the DER can be communicated either by a hard copy Environmental Field Notice (EFN), email or by letter. Actions taken by the SPA-PoB to correct the non-conformance are communicated to the Regulator by email or by letter. Copies are held in the SPA-PoB s RMS. 5.4. CLAUSE 4.5.4 Control of Records Environmental documents are held securely within the Synergy Records Management System (RMS). The system stores electronic copies of environmental records and HSE staff are required to file environmental records that they either create or receive. Retention and disposal of environmental records is determined in consultation with the Records Officer. Hard copies of environmental records received by the SPA-PoB are scanned electronically by the Records Officer and filed within the appropriate file location in RMS and distributed to the appropriate SPA-PoB staff member for action. 5.5. CLAUSE 4.5.5 Internal Audit An internal audit schedule (Synergy Ref. File. No. SMT1/8) has been developed and the audits are conducted by the HSE Department. The HSE Manager is responsible for ensuring the audit schedule is met. The audit focus will be informed by risk in that those activities that pose the most significant environmental risk as identified within the Risk Register will be audited most often. Outcome of the audits will be communicated to senior management and the Board via the weekly Morning Meeting,weekly Trade and Infrastructure meeting, the monthly Risk Team meeting, the monthly HSE Meeting, the HSEC Report and the monthly Management Report that forms part of the Board meeting agenda. 6. CLAUSE 4.6 MANAGEMENT REVIEW Elements of the EMS are discussed or reviewed at weekly Morning Meetings, weekly Trade and Infrastructure meetings, monthly Risk meetings, monthly ELT meetings, the ARC meeting and Board meetings. Management review will occur every 12-15 months unless a significant change or changes in the EMS occurs. UNCONTROLLED WHEN PRINTED Page 18 of 25

7. Reference Documentation Section Document 1.1. Introduction and Organisation Profile 1.3 ISO 4.1 Overview of the EMS Synergy Record File No (SRFN) NA NA File Location Within the EMS Manual (Section 1) Within the EMS Manual (Section 2) 2 Environmental Policy SRFN BRD1/3 SPA-PoB Intranet 3.1 Environmental Aspects and Impacts Risk Management Plan Development Due Diligence Proposals (DDDP) Process template copy only Risk Register Risk Treatment Action Plans H:\EHS\DocSys\Master\Risk -BCP\Risk Management\002 Risk Register H:\EHS\DocSys\Master\Risk -BCP\Risk Management\003 TAPs 3.2 Legal and Other Requirements Monthly Management Report Monthly Communication and Project Meeting Monthly HSE And General Staff Meeting Legal Obligation Register 3.3 Objectives and Targets Risk Register Objectives And Targets Tracking Spreadsheet SRFN A99 SMT1/2 SRFN EVM1/24 Refer to CEO/SPA Board Secretary H:\EHS\DocSys\Master\Env\ EVM003 Environmental Management EMS\BPA EMS\ISO14001\Legal register H:\EHS\DocSys\Master\Risk -BCP\Risk Management\002 Risk Register H:\EHS\DocSys\Master\Env\ EVM003 Environmental Management EMS\BPA UNCONTROLLED WHEN PRINTED Page 19 of 25

Section Document Air Quality Management Plan Invasive Marine Species Management Plan Long Term Dredge Materials Management Plan Noise Management Plan Waste Management Plan Odour Management Plan 3.3.2 Environmental Management Program Ports Legislation Amendment Act 2014 Synergy Record File No (SRFN) File Location EMS\ISO14001\Objectives and Targets H:\EHS\DocSys\Master\Env\ EVM003 Environmental Management EMS\BPA EMS\ISO14001\Legal register Environmental Protection Act 1986 Environmental Protection (Sea Dumping) Act 1981 BPA Berth 1 Licence BPA Berth 8 Licence 10 Year Sea Dumping Permit Objective And Targets Tracking Spread Sheet Monthly Communication Meeting Senior Officers Meeting SFRN EVM1/22 SFRN EVM1/22 SFRN EVM1/23 SFRN A99 SMT1/2 SFRN SMT1/14 H:\EHS\DocSys\Master\Env\ EVM003 Environmental Management EMS\BPA EMS\ISO14001\Legal register H:\EHS\DocSys\Master\Env\ EVM003 Environmental Management EMS\BPA EMS\ISO14001\Legal register H:\EHS\DocSys\Working\Lis sel\iso14001\objectives and Targets UNCONTROLLED WHEN PRINTED Page 20 of 25

Section Document Monthly Management Report 4.1 Resources, Roles and Responsibilities Organisation Chart 4.2 Competence and Awareness Training Matrix Monthly HSE And General Staff Meeting Monthly Communication Meeting Monthly Management Report Quarterly Port Operations Forum On-Line Induction 4.3 Communication Risk Register Monthly Risk Meetings ARC Meetings Board Meetings Quarterly Port User Meeting Community Contact Register/community meeting minutes 4.4 Documentation Risk Register Synergy Record File No (SRFN) SFRN EVM1/24 SFRN A99 SMT1/2 SFRN SRS1/5 SRFN 28/12 SRFN SRS1/6 SRFN SMT1/2 File Location Refer to CEO/SPA Board Secretary Refer to the Human Resources Refer to the Human Resources Refer to CEO/SPA Board Secretary SPA-PoB website H:\EHS\DocSys\Master\Risk -BCP\Risk Management\002 Risk Register H:\EHS\DocSys\Master\Risk -BCP\Risk Management\005 Risk Meeting Refer to SPA Board Secretary Refer to SPA Board Secretary H:\EHS\DocSys\Master\Risk -BCP\Risk Management\002 UNCONTROLLED WHEN PRINTED Page 21 of 25

Section Document Development Due Diligence Proposals (DDDP) Process JSA Contractor Authorisation To Work Maintenance Schedule 4.6 Emergency Preparedness and Response Emergency Management Plan Oil Spill Contingency Plan Business Continuity Plan Maritime Security Plan IT Disaster Recovery Plan Pandemic Plan Marine Oil & Chemical Spill Contingency Plan Action Plan 5.1 Monitoring and Measurement Synergy Record File No (SRFN) SRFNOHS1/1 SRFN 26/5 (Template) SRFN PES1/12 SFRN 26/5 (Template) SRFN COG1/9 File Location Risk Register MEX System Database Monitoring Program Within the EMS manual Section 5.1 5.2 Evaluation of Compliance Legal Obligation Register H:\EHS\DocSys\Master\Env\ EVM003 Environmental Management EMS\BPA EMS\ISO14001\Legal register Internal Audit Schedule SRFN SMT1/8 Regulatory Inspection Refer to Port Superintendent UNCONTROLLED WHEN PRINTED Page 22 of 25

Section Document Report Annual Audit Compliance Report Synergy Record File No (SRFN) SRFN EVM1/22 File Location 5.3 Non-Conformity, Corrective Actions And Preventative Actions Risk Treatment Action Plan Action Register 5.4 Record Control BPA Record Keeping Plan 2012 5.5 Internal Audit Internal Audit Reports Action Register Internal Audit Schedule 6 Management Review Board Meetings SRFN SMT1/8 H:\EHS\DocSys\Master\Risk -BCP\Risk Management\003 TAPs H:\EHS\DocSys\Working\Lis sel\action Register H:\EHS\DocSys\Working\Lis sel\iso14001\internal audits H:\EHS\DocSys\Working\Lis sel\action Register Refer to SPA Company Secretary ARC Meetings SRFN 28/12 Refer to SPA Company Secretary UNCONTROLLED WHEN PRINTED Page 23 of 25

8. GLOSSARY OF TERMS A glossary of terms used throughout this report is provided in Table 4. Table 4 Environmental Terms and Definitions Term Environmental Management System Risk (Environmental Aspect) Impact (Environmental Impact) Internal Audit Continual Improvement Environmental Objective Environmental Target Environmental Performance Indicator Definition The management system used by the SPA-PoB to develop and implement its environmental policy and manage its environmental risks. Activities or products or services that can interact with the environment or impact it. A change to the environment, whether adverse or beneficial, wholly or partially resulting from environmental aspects. Systematic and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the EMS audit criteria set are fulfilled. Recurring process of enhancing the EMS in order to achieve improvements in overall environmental performance consistent with the environmental policy. Overall environmental goal, consistent with the environmental policy, that the SPA-PoB sets itself to achieve. Detailed performance requirements, applicable to the organisation or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives. Specific expression that provides information about the SPA-PoB environmental performance UNCONTROLLED WHEN PRINTED Page 24 of 25

APPENDIX A Environmental Policy UNCONTROLLED WHEN PRINTED Page 25 of 25