hse&w standard

Document Number: VGR-MAN-STD-0001 Version: 7 Owner: Kelvin Morgan

Title: Health, Safety and Environment Governance Standard C2 - Vodacom Restricted of 12

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VGR-MAN-STD-0001 Health, Safety and Environmental Governance Standard Revision 7

Applicable areas of business

All

Company/Division/Area

Refer scope

Approval Name Job Title/ Role Signature Date

Document Owner Kelvin Morgan Specialist: Health and Safety Kelvin Morgan 14/01/2019

Approved by Lance Louw EHOD: Group Health & Safety Lance Louw 16/01/2019

Approved by Matimba Mbungela Chief Human Resource Officer Matimba Mbungela 16/01/2019

Objective

This standard defines the control requirements in

fulfilling corporate governance in terms of Health,

Safety and Environment (HSE).

Owner Kelvin Morgan

Version Version 7

Scope

The content of this standard applies to Vodacom Local Markets and Vodacom wholly

owned subsidiaries within the respective Local Markets.

Referenced Standards

Country-related Regulations, ISO/SANS/ILO Standards

HSE&W Standard

Health, Safety and Environmental Governance

Standard

“Work Safe, Home Safe”



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1 Responsibilities, designation and specific duties or functions

Designation Responsibilities, Specific Duties or Functions Responsible

Chief Executive Officer (CEO) Appointment (Appointment not in writing, responsibilities and liabilities due to shareholders appointment as Chief Executive Officer [CEO])

Chief Executive Officer charged with certain duties.

Approve HSE Policies

Shall appoint All EXCO members as assistants to the CEO for their area of responsibility.

Approval of Country plans

Board Decision

All HSE Appointments as prescribed in the OSH ACT 85 of 1993

As prescribed in the appointment letter As prescribed

Contents

1 Responsibilities, designation and specific duties or functions .......................... 2

2 Definitions and abbreviations ................................................................................ 3

3 Standard .................................................................................................................. 4 3.1 Forms of Ownership and Compliance ................................................................ 4 3.2 Vodacom Health, Safety and Environment (HSE) Management ........................ 4 3.3 Vodacom HSE Strategic Intent .......................................................................... 5 3.4 Integrated HSE System ..................................................................................... 8 3.5 Vodacom HSE Standards .................................................................................. 8 3.6 Health, Safety and Environmental Governance Structure .................................. 9 3.7 Supplier Management (Supplier Vetting) ......................................................... 10 3.8 Governance and Assurance ............................................................................ 10 3.9 Supplier Governance ....................................................................................... 11 3.10 Communication ................................................................................................ 11 3.11 Review of Health & Safety Functionalities ........................................................ 11

4 Document History ................................................................................................. 11



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2 Definitions and abbreviations

Competent Person In relation to construction work, means any person having the knowledge, training, and experience specific to the work or task being performed.

Customer Means any person for whom construction work is performed.

DIFR Disabling Incident Frequency Rate

Employer Vodacom: Management F Band and above.

Emergency An event which may lead to danger of the public, to the health and safety of the personnel, or to the environment, or has occurred, or is to be expected, e.g. during the danger of an explosion, emission of hazardous substances, fire alarm, collapse of a building, etc.

Environmental

Incident This incident refers to an unexpected or sudden occurrence and/or uncontrolled release of a hazardous substance - including a major emission, fire or explosion - leading to serious danger to the public or potentially serious pollution detrimental to the environment, human life or property whether immediate or delayed.

EXCO Executive Committee

Hazard Source or situation with a potential for harm in terms of human injury or ill health, damage to property, damage to the environment, or a condition of these.

HSE Health, Safety and Environment (al).

HSE Country Plan An annual tactical plan that determines HSE activities and objectives.

Incident An unintentional event or unexpected reaction of a facility or process like: spillage, wastage, leakage, fire, explosion, personal injury, accident, fatally, on damaged materials.

KPA Key Performance Areas

KPI Key Performance Indicators

Local Market This is any Vodacom Operating Company; either local or international.

LTIR Lost Time Injury Rate

Project Manager any full-time competent employee entrusted with the duty of managing the project, which acts as a representative for Vodacom (client) and is appointed in writing.

Risk Product of probability of an occurrence of a hazardous event or exposure(s) and the severity of an injury or ill health that can be caused by the event or exposure(s).

Risk data base Is the risk management system to capture risks as identified through the risk assessment process?



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3 Standard

3.1 Forms of Ownership and Compliance

3.1.1 Operating Companies

Vodacom Group in terms of its shareholding has the following Operating Companies:

Vodacom South Africa

Vodacom Tanzania

Vodacom Mozambique

Vodacom Lesotho

Vodacom Democratic Republic of the Congo

It is Mandatory for all Vodacom Operating Companies to comply with the Vodafone and Vodacom Health Safety and Environmental Policies and Standards. Local health and safety policies and standards must only be developed if legally required or if local rules/priorities are significantly different to Vodacom Group.

3.1.2 Subsidiaries

Subsidiaries are separate and distinct legal entities that reflects in the independence of their liabilities, taxation and governance. There are two forms of Subsidiary ownership by Vodacom Group Subsidiaries e.g. Storetech, X-Link & Vodacom Business Africa. Subsidiaries are either where Vodacom Group has the Majority (>50%) shareholding or companies that are wholly owned (100%).

Subsidiaries must adopt, align or develop a Health Safety and Environmental Management System based on the Vodacom Group minimum on their Scope of Work, Market and Legal Environment.

3.1.3. Partner Markets

Partner Markets is where Vodacom Group collaborates with other organizations with the intent to gain a competitive advantage and to meet each of their respective business goals. Vodacom Group has no influence or liabilities in terms of the Partner Market Health Safety and Environmental performance and compliance. The current Partner Market within Vodacom Group is Safaricom who may adopt the Vodacom Group Health Safety and Environmental Policies and Standards or develop their own.

3.2 Vodacom Health, Safety and Environment (HSE) Management

Vodacom Group HSE determines and communicates the minimum HSE requirements in terms of the vision, leadership, integrated health safety and environmental systems, cultural guiding principles, HSE policies, HSE Strategy, HSE Risk Register, HSE standards and HSE guidelines.

Their objective is to govern HSE management on a strategic as well as tactical level and to establish accountability within all functions of the business.



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Vodacom’s Local Markets, contractors, suppliers and third parties working on Vodacom’s behalf interpret, implement and incorporate the above minimum requirements into their business specific HSE management programmes.

3.2.1 HSE Process Model

The HSE Policy, strategy, risk register and standards are mandatory to all Local Markets.

From the Legal Register downwards in the pyramid to workplace committees, items are applicable as per Local Market’s specification.

Risks are registered and managed on risk data base.

All Local Markets shall conform to Vodacom HSE Standards.

3.3 Vodacom HSE Strategic Intent

Through the Health, Safety and Environmental Policies, as incorporated in this document, Vodacom commits itself to excellence in health, safety and environment and to safeguard the environment against any harm and people against injury or occupational illness that may arise from Vodacom activities.

The Vodacom HSE Strategic Intent, underpinned by effective communication, is summarized in the illustration below:

3.3.1 Vodacom Leadership

Protecting the health, safety and environment of all stakeholders who may be affected by Vodacom’s activities, and protecting the environment in which we live and work in, is an essential part of risk management and must be led by the Vodacom Local Market Executive Committee (EXCO).

The following essential principles are intended to underpin the actions required by the EXCO in order to ensure an effective Health, Safety and Environmental Management System:

Policy

Strategy

Standards

HSE Country Plans

Risk Register

Legal Register

Appointments

Procedure, Guidelines, Forms, Checklists,Permits, Passports

Workplace Committees

Vodacom Markets

Applicable to all Local Markets

Local Market Specific Contextualized



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Strong and active leadership from the top management: o Visible leadership o Experience measures o Working in partnership to share knowledge, setting standards and improving

health, safety and environmental performance in the value chain where applicable;

o Commitment to continual health, safety and environmental improvement; o Adherence to applicable health, safety and environmental legal requirements

and other compliance obligation, codes of best practice and standards;

Employee involvement o Behaviour toward implementation of Vodacom Policies, Standards and

Procedures.

Assessment and review o Lagging Indicators

Incident statistics Monthly, quarterly and annual reports LTIR Number of disciplinary actions instituted Number of Contractors vetted Internal audits External audits Consequence management

o Leading Indicators Country HSE plan implementation progress Contractor vetting Maturity Matrix

3.3.2 Agenda: Planning and Organising

The EXCO should set the direction for effective health, safety and environmental management. The CEO needs to establish a health, safety and environmental policy that are much more than a document. It is an integral part of the Vodacom culture, its values, commitment to continual improvement and performance standards.

All EXCO members should take the lead in ensuring the communication of health, safety and environmental duties and benefits throughout the organisation.

Core Actions:

To agree to a policy, the EXCO will need to ensure that they are aware of the significant risks faced by Vodacom. The policy is a “living” document and should evolve over time, e.g. in the light of major organisational changes such as restructuring or a significant acquisition.

3.3.2.1 Agenda: Delivery

Delivery depends on an effective management system to ensure, so far as reasonably practicable, the health and safety of employees, stakeholders and other interested parties, as well as to protect the environment in which Vodacom operates

Core Actions:

To take responsibility and “ownership” of health, safety and environment, members of the EXCO must as a minimum ensure that:

Implement activities aligned to the annual approved by each Local Market Country Plan. The PD guideline can be used to capture your PD plans.



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Health, safety and environment arrangements are adequately resourced (As Required)

They obtain competent health, safety and environment advice

Explore opportunities to reduce greenhouse gases through the incorporation of energy efficient design criteria into new services, buildings and equipment.

Risk assessments are carried out

Health, safety and environment should be an integral part of all relevant business processes and should be governed as part of key business deliverables.

Provide a framework for continual environmental improvement which allows for the adoption of new ideas and innovation;

To conduct Leadership Engagement Tours and Leadership Inspection Tours as prescribed under the ‘Leadership Tour Management Guide Booklet’.

3.3.2.2 Monitoring Review

Core actions:

The EXCO should ensure that:

Appropriate weight is given to reporting both preventative information (such as progress of training and maintenance programmes) and incident data (such as accident and sickness absence rates)

Periodic audits of the effectiveness of management structures and risk controls for health, safety and environment are carried out. (ISO Audit Team)

The impact of changes such as the introduction of new procedures, work processes or products, or any major health, safety and environment failure, is reported as soon as possible to the EXCO.

There are procedures to implement new and changed legal requirements and other compliance obligations and to consider other external developments and events.

3.3.2.3 Agenda: Review

A formal review of health, safety and environmental performance is essential. It allows the OPCO to establish whether the essential health, safety and environmental principles are implemented.

Core Actions:

The OPCO should review health, safety and environmental performance at least once a year. The review process should:

Examine whether the health, safety and environmental policy reflects the organisation’s current priorities, plans and targets;

Examine whether risk management and other health, safety and environmental systems have been effectively reporting to the EXCO;

Report health, safety and environmental shortcomings, and the effect of all relevant EXCO and management decisions;

Decide on actions to address any weaknesses and a system to monitor their implementation; and

Consider immediate reviews in the light of major shortcomings or events.

3.3.3 Culture

The following can suggest an organisation with a positive health, safety and environmental culture:

Visible management commitment at all levels in the organisation (VFL);



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Good knowledge and understanding about health, safety and environment throughout the organisation;

Clear definition of the culture that is desired;

Lack of competing priorities with health, safety and the environment (e.g. production, quality, etc.);

A realistic idea of what is achievable whilst being challenging;

Visible evidence that investment is made into health, safety and environmental management System, including the quality of the working environment, equipment provided etc.;

Being proactive so opportunities for improvement are dealt with before problems arise;

Good communication up, down and across the organisation;

A fair and just discipline system; and

Meaningful involvement of the workforce in all elements of health, safety and environment.

3.3.4 Improving the HSE culture

Specific objectives to improve the health, safety and environmental culture within Vodacom must be included in the annual high-level HSE Plan for each OPCO and supported by each Local Market’s business specific HSE management programmes.

3.4 Integrated HSE System

To provide a good foundation for a positive HSE culture, it is necessary for the integrated HSE management system to go beyond the legal requirements and other compliance obligations to govern HSE requirements across all local markets, contractors, suppliers and third parties working on Vodacom’s behalf.

The Integrated HSE System will as a minimum include governance rules related to the following:

Policy – which set a clear direction for the Vodacom Group of Companies to follow;

Organising – which put a structure and arrangements in place to deliver the policy;

Planning and implementation – which allows the establishment, operation and maintenance of effective systems through speed, simplicity and trust;

Measuring performance – against agreed standards to reveal where improvement is needed;

Audit – planned assessment of arrangements; and

Review – taking into account all relevant experience and applying lessons learnt.

Information from key performance measurements and indicators will be reviewed, and then the findings from the review will be fed back into the appropriate elements of the system. This makes it a living system that adapts as required to ensure it makes a positive contribution to health, safety and environmental management system as stipulated in the Maturity Model below.

3.5 Vodacom HSE Standards

Document No. Standard Name Purpose

VGR-MAN-STD: 0002 TO 0017

As listed on the HSE standards

As stipulated on each standard



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3.6 Health, Safety and Environmental Governance Structure

HSE Committee

Key functions Frequency Records

Ethics and Compliance Committee

Review and monitor Vodacom’s policies to assess compliance with applicable HSE legislation and regulatory requirements.

To review and monitor the impact of Vodacom’s HSE practices on its products, services, employees, customers and communities in which it operates.

As determined by the Committee

Minutes of meeting

Group Risk Management Committee

Approve the list of high and critical strategic risks that are presented to the Group Board annually;

Quarterly Strategic Risk Register

Audit Reports

Approvals & Mandates

Executive Committee

Mandate HSE Strategy and Initiatives;

Approve & Mandate Annual HSE Plans per business function;

Allocate Human & Financial resources (Budget) necessary for HSE Strategy deployment & improvement;

Cascade HSE Strategy, Initiatives and Cultural drives and campaigns;

Review HSE performance.

As determined by the Committee

Approved HSE Strategy

HSE: KPA’s & KPI’s (Leading & Lagging)

Improved HSE Audits, Trends and System (including Suppliers and Contractors)

HSE tour report forms

HSE Strategic Planning

Consists of all full time HSE Specialists

Meets twice a year and is chaired by the Executive Head of Division: HSE.

Custodians and Responsible for developing HSE Management System, software applications, standards, specifications and guidelines;

Responsible for technical design of HSE Campaigns, training scope content and benchmarks;

Conduct technical HSE research and investigations with HSE system and standards;

Register and project Manage system enhancements, automations and amendments;

Ensure continuous competency training of HSE Consultants/Specialists aligned to business needs;

Dynamic/Emerging Risk discussed

Liaise with relevant authorities, Organisations and Suppliers on technical HSE requirements required by the system and legislation; and

6 Monthly HSE Plans

HSE Technical Roll-out Reports

Improved system designs

HSE Trends

HSE mandates /overrides/concession

HSE Standards

HSE Stats



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HSE Committee

Key functions Frequency Records

Technically interface with Vodafone HSE community and Global Head of Safety.

HSE Workplace Committees

As prescribed in the OSH ACT 85 of 1993 but not limited to

Quarterly or at increased intervals as determined by the Local Market

As prescribed in the OSH ACT 85 of 1993 but not limited to

3.7 Supplier Management (Supplier Vetting)

Suppliers are required to register into the Supply Chain Management (SCM) database after they have satisfied the HSE evaluation criteria, through the supplier vetting process, which is conducted by the local HSE Division. Suppliers complete and submit, with supporting documents, a questionnaire for evaluation as per VGR-MAN-STD-0004 Contractor Selection and Control Standard.

3.8 Governance and Assurance

Vodacom Group must review the performance of their HSE Framework on an annual basis. As a minimum the review should consider:

Legal, statutory and regulatory requirements

Annual HSE Plans

HSE risk profile

Feedback and learnings from the investigation of incidents

Risk assessments

3.7.1 If exemptions to Vodacom Group HSE Standards are required, a formal exemption request must be submitted to Vodacom Group HSE Head

As a minimum the request must include the following:

1) Element/s of the Standard which cannot be conformed with 2) Reason for non-conformance 3) Risk Mitigation – which may include but not limited to ; Alternative Designs, controls,

monitoring processes, process enhancements

3.7.2 If the exemption request impacts on Vodafone standards, a further request needs to be approved by the Vodafone Group HSW Director – (Refer to S01 HSE FRAMEWORK POLICY)

3.7.3 Each OPCO`s HRD and within VSA the applicable 16.2 legal appointees (EXCO

member or Regional ME), needs to provide on an annual basis, a formal attestation to the Group CHRO confirming compliance to Group HSE Standards and validity of HSE reports.



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3.9 Supplier Governance

Global Supplier Forums are to be facilitated by the Group Supplier Chain Management.

Local market forums must be scheduled with all main or principal contractors (High Risk).

Regional supplier forums may be held with the regional managing executive or executive head of division chairing such forum.

At the very least, each local market is to plan and host periodic supplier forums as per Country Plan.

All supplier forums must be aligned with the Global Supplier Forum (GSF) and tasks issued at this forum must be replicated within each of the companies or regions within the respective local markets.

It is mandatory for suppliers to attend these forums.

3.10 Communication

HSE internal and external communication processes shall be performed as prescribed in the

VGR-MAN-STD-0016 HSE Management System Standard.

3.11 Review of Health & Safety Functionalities

All HSE Legal and other requirements shall be aligned with the HSE Activity Plan, reviewed periodically. HSE Specialist should maintain compliance in accordance with this schedule.

Responsibilities in writing shall be assigned in terms of the following structure within each local market.

CEO/MD

Vodacom Local Market

Assistant to CEO/MD

Chief Officer / Regional

ME

Plant & machinery

Supervisor (SA only)

Employer Nominee

Divisional ME/HOD

(Defined area)

H&S Reps

Incident

Investigator

First Aider

Fire Marshal

Evacuation Officer

Chair person of

the HSE

Committee

Stacking

Supervisor

Employer Member

to HSE Committee

Scaffold Erector

Principal

Contractor

Construction

Supervisor

Environmental

Rep

Agent

Assistant to Plant

& machinery

Supervisor

RF Safety Officer

4 Document History

The applicable changes to the document

Change requested by:

Earl Kleinsmith

SUMMARY OF CHANGES

Paragraph Description Date



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Section 4.1 Added Country plans in the HSE Process Model pyramid.

18-10-2013

Section 6

Amended definition of Employer. Deleted Level 3 and inserted F Band. Deleted definitions: Health, Safety and Environmental Agreement, Personal company vehicle, Project Health and Safety Plan, VBA, VC, VCL and VTL.

18-10-2013

Section 4.1 Added: Standards and Country Plans to HSE Process model pyramid.

18-10-2013

Section 6

Amended definition: Employer referring to F Band. Deleted: BEC, CMS, Health and Safety Agreement, Personal Health and Safety Plan, Personal company vehicle, VBA, VC, VCL, VMZ, VSA and VTL

18-10-2013

Section 1 All designations definitions referred to in the appointment letters

21/02/2018

Section 3.6 Updated the risk classification – included Commercial activities in the high risk category

21/02/2018

Section 3.9 Global supplier forum managed by SCM -updated 21/02/2018

Section 3.11 Updated repository for appointment letters –HSE management system

21/02/2108

Policy Standard review and update including new VF logo

22/10/2018

Section 3.1 / 3.8 New section included for Governance and Assurance updates / Forms of Ownership and Compliance

17/01/2019

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