National Beverage Company Gaza Plant

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Page 1 of 9 Environmental Program EP-Pg-01 1.0 Purpose NBC Gaza plant Environmental Impact Assessment 2.0 Scope This program is designed to identify the environmental aspects that take place during daily performance. Also to ensure pollution prevention by minimizing the discharge of waste into environmental and through effective pollution control practices The scope of this program will include the following: a. Water Efficiency. b. Wastewater Discharge. c. Solid and Hazardous Waste Generation and Management. d. Energy Efficiency. e. Chemical and Hazardous Material Use. f. Air Emission. 3.0 Responsibility 3.1 Management: NBC management is responsible of demonstrating its support and commitment to the development, implementation and continual improvement of the environmental program. This support and commitment to the environmental program is evidenced by communicating the EMS & by emphasize on the continuous improvement, efficiency, and effectiveness of the environmental program through the use of the business planning, objectives and audit results analysis of data, corrective and preventive actions, providing all necessary resources and by reviewing from time to time the over all program & the performance results. 3.2 Environmental Coordinator: The responsibility of the environmental coordinator is: Ensure compliance with the local (Palestinian Environmental Laws). Plan, oversee and participate in the implementation of Coca-Cola Environmental System (eko- System).

Page 2 of 9 Environmental Program EP-Pg-01 Has the overall responsibility for evaluating, implementing, monitoring and enforcing the environmental program of the company. Make policies & systems to ensure implementation of the eko system. Plan & coordinate the "Environmental & Safety Team" meetings to regulate and control various environmental & safety activities. Submit proposals & environmentally related data to higher managerial level. Submit various reports on programs progress and accomplishments. Develop and execute water and solid waste minimizing & recycling / reusing programs. Coordinate, handle and oversee the production out coming wastes. Develop and execute a wise & effective energy consumption procedure. Maintain & develop awareness to all plant employees in the field of environment. Plan & coordinate training programs. Plan and make a policy for a regular internal audit. 3.3 Departments Heads: Control the generation of waste by monitoring yields of all materials used in the plant; explore opportunities for minimizing or eliminating the generation of waste. Promote recycling of all recyclable waste and train the employees on hazardous material management. The department head is responsible about environmental program implementation within his department, each department head is responsible about carrying over all department activates with respect to the environmental program's needs. 3.4 Environmental Team "ET": The team is divided into three sections: water, solid waste & energy. The responsibility of each section depends on the section needs. a. Water Section: in charge person of the water has the following responsibilities: 1. Daily collection of all related data (over all water consumption, water reuse system). 2. Participate in environmental meetings. 3. Participate in corrective action plan. 4. Follow up the daily GMP of the same field. 5. Ensure proper operation and handling of the reused water. 6. Ensure proper consumption of the water. 7. Implement eko system in the respective field.

Page 3 of 9 Environmental Program EP-Pg-01 b. Solid Waste Section: in charge person of the solid waste has the following responsibilities: 1. Daily collection of all related data (generated solid waste). 2. Participate in environmental meetings. 3. Participate in corrective action plan. 4. Follow up the daily GMP of the same field. 5. Ensure proper collecting procedure and handling of waste. 6. Ensure waste minimization in daily performance. 7. Seek better recycling opportunity. 8. Implement eko system in the respective field. c. Energy Section: in charge person of the water has the following responsibilities: 1. Daily collection of all related data. 2. Participate in environmental meetings. 3. Participate in corrective action plan. 4. Follow up the daily GMP of the same field. 5. Ensure proper and efficient energy consumption. 6. Implement eko system in the respective field. 3.5 All Employees: To be aware of the followings: 1. The presence of hazardous material on site and ways of handling, storage area of hazardous material. 2. Methods of waste minimization as well as waste disposal. 3. Availability of the recycling / reusing system. 4.0 Definition: 4.1 Environmental Management System "EMS": EMS is a system that addresses all the environmental impacts and related corrective actions. The system contains establishment of programs / procedures, documentation, implementation and maintenance procedures. An EMS provides a structured, documented approach to managing a business's environmental performance and responsibilities. To be defined as an EMS the system has certain elements in place. The international standard ISO 14001 defines these elements.

Page 4 of 9 Environmental Program EP-Pg-01 4.2 Hazardous Material: A hazardous material is any substance, which posses a physical or health risk to people or environment, exposed to the substance by the virtue of its physical or chemical properties. These substances include, but are not limited to, substances that are corrosive, toxic, flammable, reactive, explosive, or are considered a health hazard. 4.3 Hazardous Chemical: Any chemical that is a health hazard or physical hazard. 4.4 Health Hazard: Any chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. 5.0 Method: 5.1 Local Environmental Laws: Local environmental laws are available without executive legislations which prevent the law implementation. The NBC environmental policies are followed up till the local environmental laws implementation. Wherever the TCCC standards are found to be stricter than the local law standards, then TCCC standards to be implemented. The identification of local law and legislation procedure considered different and regular visits as well as regular communications to the formal environmental institutions in order to identify the law implementation. 5.2 Environmental Commitment Statement: NBC Environmental Statement. (Ref. EP-M-5 & 6) 5.3 Communications: The EMS records are communicated with all staff in order to present the performance to all levels. The internal as well as external communication between various levels and/or different external parties, consumer, governments, contractors etc within the environmental management system is documented as general communication

Page 5 of 9 Environmental Program EP-Pg-01 procedure; this communication procedure applies to all levels, irrespective to the designated role of any employee. 5.4 Management Planning & Review: Management review to all environmental performance (team, objectives, implementation, improvement, results of audits, status of preventive and corrective actions, follow up actions form previous management reviews, changes that could affect the EMS performance, etc is carries out as per Management Planning & Leadership Program. 5.5 EMS Documentation & Records: 5.5.1 EMS Records: All EMS records are regularly obtained; the daily output data from various departments which are input data for the EMS records are evaluated, maintained in a daily basis and made ready in either hard or soft copy. 5.6 Packaging Material Suppliers: Packaging Materials are procured only from authorized suppliers and adhere to company's packaging policies and guidelines. Recyclable symbols and litter prevention message are printed on all possible material. 5.7 Operational Control: 5.7.1 Hazardous Material Management: Generation of hazardous material are limited and managed properly. Oil changed from machinery is collected in barrels properly marked & identified (FOR RECYCLING). All chemicals on site are identified and the employees who normally handle those chemicals are trained to handle correctly and the safety precautions associated with that. Chemicals stored in tanks have secondary containments to ensure spill prevention. Handling of any hazardous material is followed out as indicted in the Material Safety Data Sheets File. 5.7.2 Ozone Protection: (Ref. EP-Pr-04)

Page 6 of 9 Environmental Program EP-Pg-01 NBC will no longer purchase any equipment containing or made with CFCs or Halons. This is taken into account for the new line installations and any new modification; all the coolant and refrigerant gases were friendly to the environment. Currently No existing equipment that contains CFCs as per the conducted survey, It is the policy of NBC not to use CFCs in the manufacturing process. 5.7.3 Wastewater Management: (Ref. EP-Pr-03) All drainage system is properly identified and connected to waste water treatment unit. The wastewater is tested with full analysis according to KORE system to be done externally each 6 months. The samples are taken from the waste water treatment unit after treating process. 5.7.4 Reuse Water Management: The reused water system is a close system, designed internally to serve the house keeping activities. The collected water is usable by different taps distributed in the plant to cover all plant areas. The collected water is not drinkable and is used only for floor cleaning, bathrooms. Proper labeling for the reuse water system has been set wherever been used to differentiate between the raw and / or treated water. 5.7.5 Energy and Water Efficiency: Energy and water bills are monitored and if anomalies are noticed, the cause is investigated and corrective actions are taken, wherever possible. The plant is committed to use the most efficient equipment in term of energy consumption and using sunlight for day light and motion sensor where ever possible. The factory is designed to minimize water wastage. The water consumption control process briefs the analysis of reducing the water consumption. 5.7.6 Solid Waste Management: NBC believes that the best way to manage waste is to manage the waste source to eliminate or minimize waste. With this in mind the yields of all materials used are closely monitored and if at any time yields are higher than the set targets, the cause is investigated and corrective action taken.

Page 7 of 9 Environmental Program EP-Pg-01 a. Broken Wooden Pallets & Pieces: All broken wooden pallets that can not be repaired are collected in the carpentry shop. Also wooden pieces that generated by the pallets repairing process, is well arranged and collected in a way that facilitate transportation. The environmental coordinator is responsible of delivering the broken wooden pallets & pieces to contractor. b. Lubrication Drums: all lubrication drums are collected outside the lubrication store. All collected drums are properly arranged in a way that does not harm the GMP procedure. The environmental coordinator is responsible of delivering the collected drums to contractors or suppliers. c. Concentrate Drums: All concentrate drums are collected outside concentrate store in daily basis; all collected items are properly arranged in a way that does not harm the procedure of GMP store. Purchasing officer is responsible of delivering the collected drums to supplier. d. Chemical Drums: all lubrication drums are collected outside the lubrication store. All collected drums are properly arranged in a way that does not harm the GMP procedure. The purchasing officer and environmental coordinator is responsible of delivering the collected drums to contractors or suppliers e. Shrink Nylon: Shrink nylon waste is collected from product packaging activities. All collected nylon is properly arranged in a way that does not harm the GMP procedure. Environmental coordinator is responsible of delivering the collected nylon to contractor. f. Glass Bottles: broken glass material is collected from different places on the RB production line;. All collected material is handled in a way that does not conflict with the GMP procedure. Environmental coordinator is responsible of delivering the collected perform & bottles to contractor. 5.7.7Recycling Opportunity: a. Closures: Environmental coordinator is responsible for closure recycling process & agreement with a plastic contractor or company.

Page 8 of 9 Environmental Program EP-Pg-01 b. Carton & Paper: Environmental coordinator is responsible for finding carton & paper recycling contractor. c. Oil: Environmental Coordinator is responsible for finding oil recycling contractor. All used oil is collected in barrels to avoid contaminating the land. The collected oil sent to the recycling factory. All packaging material like pallets, cartons, layer pads and containers from different supplier is either returned to the supplier for re-use or recycled in case of reusing isn't possible. All non-recyclable materials are collected and dumped in to the skip provided by the municipality, and they manage the disposal of it. No waste will be disposed off or burnt on site. 6.0 Quality Records: Yields are monitored in daily, monthly & yearly basis and records are available with the Environment Coordinator. Water, fuel, electrical consumptions and solid waste generation values and rations are recorded in daily basis; these values are compared against the standards. A monthly summary report for the above mentioned consumption or generation with ratio and the detailed recycling report are submitted to the management. 7.0 Corrective Action: Any deviations to the procedure or practice need to be referred to the Environmental coordinator to initiate the corrective action plan. 8.0 Training: Task Responsible Person Competency Level Awareness of the Coca-Cola environmental system All employees Fully Competent (KORE-System) Awareness of the hazardous material on site, hazardous material usage, storage area and procedure and recycling opportunities. Environmental Team & Production Supervisors. Competent

Page 9 of 9 Environmental Program EP-Pg-01 Minimizing or eliminating the generation of waste. Monitoring of yields. Promote recycling of all recyclable waste. Local environmental laws and KORE system. Department Heads Environmental Team & Coordinator Fully Competent Fully Competent 9.0 Reference: