Ma’aden Safety, Security, Health and Environment Management (MSHEM) System Framework

SafeSTEPS

HSE MANAGEMENT
SYSTEM FRAMEWORK

Health, Safety and Environment

Table of
Contents

4 A Message from our CEO
6 Purpose
6 Scope
6 Context and Stakeholders
8 Organization of the framework
10 How to use this framework
12 Ma’aden Health, Safety and

Environmental Policy
14 Governance of the system
16 1. Leadership and Accountability
20 2. Health, Safety and Environment

Legal and Regulatory Compliance
22 3. Risk Assessment and Management
26 4. Communications
28 5. Competency and Training
32 6. Asset Lifecycle Integrity
36 7. Operational Integrity
38 8. Occupational Health and

Industrial Hygiene
40 9. Emergency Preparedness
42 10. Contractors
44 11. Incident Reporting, Investigation

and Analysis
46 12. Performance Evaluation and
48 Continuous Improvement

13. Off-Job Safety
50 14. System Administration
52 Glossary
54 HSE Management Related Documents

HSE Management System Framework

A Message from our CEO

We are implementing a comprehensive health, safety, and environment
(HSE) Management System to integrate all of our organization’s policies and
processes into one complete framework. This will ensure everyone working
with Ma’aden has not only a consistent understanding of our objectives but
also drives sustainable performance and is equipped with the knowledge and
resources to manage risks in the workplace proactively.
The new HSE Management System is in line with Ma’aden’s overarching
strategy of adopting a risk-based approach to health, safety and
environment , which means proactively identifying and mitigating risks
before they arise.
• It represents the shift from a ‘find and fix’ to a ‘predict and prevent’

approach.
• It applies the same HSE standards to the entire organization, including

our partners, contractors, and sub-contractors.

4

Ma’aden Safety Culture Transformation Program

‘‘The safety of everyone who works at and with Ma’aden is
at the very heart of our business, and we are committed
to ensuring ours is a workplace that allows all employees
and contractors to perform their duties safely every day.

Ma’aden’s leadership and I are committed to meet the objectives outlined
in this framework, which provides a reference to the best practices and
standardization that we will be utilizing in our journey towards health, safety,
and environmental excellence.

Implementing the system is the
best way to deliver sustainable
performance.

Mosaed Bin Suleiman Al Ohali
Chief Executive Officer

5

HSE Management System Framework

Purpose Scope

The purpose of this framework is to The HSE Management System
define the Ma’aden Health, Safety & is applicable to the HSE aspects
Environment management System across the full lifecycle of Ma’aden’s
and support the transformation operations, products and services,
to world class performance. It including the use of contractors, sub-
provides a framework that details contractors and contracted services
requirements and describes what at all Ma’aden owned, managed and
shall be implemented. leased sites, facilities and projects.

The framework is composed of an Context and Stakeholders
enterprise level set of requirements.
By addressing each expectation, Ma’aden is a leading mining and mineral
the site leaders can accomplish processing industrial organization listed
Ma’aden’s vision of achieving Health, on the Saudi Stock Exchange-Tadawul.
Safety and Environment excellence It is the largest multi-commodity mining
at their respective sites. and metals company in the Middle East
comprising three divisions; mining,
This framework is one of a set of risk- metals refining and processing focusing
based, integrated and interlinked presentlyongold,phosphate,aluminum
documents (Policy, Framework, industrial minerals and copper. Current
Standards and Code of Practices) operations are predominantly in the
that work together to define the Kingdom of Saudi Arabia with plans to
requirements of the system. expand internationally.

6

Ma’aden Safety Culture Transformation Program

Ma’aden’s primary, enterprise level, interested parties and stakeholders and
their expectations are as tabulated below:

Table 1 - Stakeholders - Expectations

Stakeholders Expectations

Employees and personnel • Healthy, safe, secure and environmentally responsible
working on behalf of the working environments
organization
• Awareness, training on and management of HSE issues
• Participation and engagement on HSE issues
• Compliance with local labor and HSE regulations

Local • Prevent uncontrolled emissions or the creation of nuisance (noise,
communities odor, vibration)

• Respect for and protection of the communities and the
surrounding environment

• Engagement on local community related HSE matters

Regulatory Authorities • Responsible and sustainable operations
– national, regional and • Compliance to HSE regulations and legal requirements
local • Timely reporting of HSE performance and incidents
• Coordination for the preparation and response to HSE incidents

and emergencies

Contractors and Service • Healthy, safe, secure and environmentally responsible
Providers working environments

• Support for HSE management and performance

Shareholders and joint • Conformance to good international HSE standards
venture partners • Responsible, profitable and sustainable operation of the business

Customers with a positive long-term return on investment
and End-users
• Safe and responsible transportation of materials and products to
our direct customers

• Provision of HSE information to :
• Enable legal compliance
• Safe and responsible transportation, storage and
use of products

7

HSE Management System Framework

Organization of
the framework

The system is organized into four focus areas: - Leadership, People, Process and Plants
& Assets. These are further elaborated in 14 elements. Each element contains a specific
objective, requirements and related documents that elaborate on these requirements. The
format of each element is as follows:

Objective: - What the element intends to achieve.
Expectations: - Statements of requirements which will fulfill the intent of the element.

Related documents: - Set of documents that provide the details on what is required to
accomplish the expectations. The documentation consists of normative (mandatory to
implement) standards, System Administration procedures and technical and operational
codes of practices.

Scope

The Ma’aden HSE Management System Framework is applicable to the HSE aspects and its
operations, products and services, including the use of contractors, sub-contractors and
contracted services at all Ma’aden owned, managed and leased sites and facilities. It is not
mandatory for joint ventures not managed by Ma’aden but is strongly recommended as
best practice to the managing agency.

Format of each element

Objective Related Documents Expectations
What the element Normative and informative Statements of
intends to achieve Standards/Guidelines requirements

Administration

Document Control Clarifications, Variance and Element
Procedure Exemptions Procedure Administrators
Procedures
8

Ma’aden Safety Culture Transformation Program

HSE Management
System Framework

9

HSE Management System Framework

HOW TO USE THIS
FRAMEWORK

The executive heads of each unit are accountable for ensuring the
implementation of the HSE management system, which includes
this framework, the HSE statement and the supporting standards,
and codes of practice, at their respective organizations.

Site leaders shall ensure that

1. The Policy statement and Management System framework are studied to
understand the objectives, expectations and related documents for each
element. If required, Affiliates can use the system administration procedure
to address the need for clarifications, exemptions and variances.

2. The status of existing local HSE systems is assessed and compared with
this framework and a detailed gap analysis report is prepared.

10

Ma’aden Safety Culture Transformation Program

3. Develop a comprehensive plan with specified target dates for fully
implementing all elements at their sites by:
Involving the stakeholders in the planning and
implementation process
Allocating resources and
Monitoring, supporting and reporting as required

11

HSE Management System Framework

MA’ADEN HEALTH, SAFETY
AND ENVIRONMENTAL
POLICY STATEMENT

Health, Safety and the Environment (HSE)
is at the heart of every decision we make.
We acknowledge that we operate in the
mining and mineral processing sector
which is hazardous and so HSE is a
pre-condition of everything we do. We
firmly believe all incidents are avoidable
if risk is managed proactively.

Our established HSE Policy and Management System Framework
contains the guiding principles that empower the following
undertakings:

12

Ma’aden Safety Culture Transformation Program ‘‘

We are committed to complying with all We recognize that our HSE culture,
applicable HSE laws, regulations, and management and performance is
obligations dependent on our leadership, line
We implement systems and provide management and the ownership of
equipment to prevent harm to people and each and every one of us.
the environment and enable a healthy,
safe and environmentally responsible Mosaed Bin Suleiman Al Ohali
workplace CEO
We integrate HSE factors throughout
the whole lifecycle of our assets and We have an ongoing commitment to
products spanning their development, providing training and ensuring the
procurement,operationandmaintenance, capability, competency and well-
decommissioning and rehabilitation being of everyone working at our
Our current HSE focus areas are the facilities and affiliates
prevention of major accidents, ensuring
workers’ fitness for duty, resource We enable and practice safe and
conservation and the minimization of healthy lifestyles and behaviors both
impacts related to effluent, waste and on and off the job
biodiversity
We actively consult, engage and listen Our HSE objectives and continual
to stakeholders including our employees, improvement plans are based on
investors, supply chain, local communities proactive risk management which
and customers to understand their HSE aims to progressively prevent and
concerns and each other’s views minimize impacts, losses and injuries;
and

We will continue to learn from
incidents, share information to drive
operational excellence and monitor,
review and report on our health,
safety, security and environmental
performance

13

HSE Management System Framework

Governance
of the system

Ma’aden’s leadership has established a comprehensive
governance framework to drive the implementation of
the HSE management system. This framework sets up
the structure to engage at all levels, ensuring all plans
are implemented effectively and consistently.

Leaders of change have been appointed at all
levels of the organization to ensure everyone
has a voice and a channel to communicate with
decision makers.

14

Ma’aden Safety Culture Transformation Program Strategy and plans will be developed and
Figure 2 - Ma’aden HSE Governance Model implemented through the collective efforts
of the Safety and Sustainability Board
Committee, Executive HSE Council,
Ma’aden Corporate HSE Council, Affiliate
HSE Committees and Affiliate Contractor
HSE Committee. The interaction of these
committees is illustrated below.

The HSE Policy, Governance and Leadership
standard contains the detailed roles and
responsibilities for the establishment and
operation of the Ma’aden’s HSE Governance
structure. The HSE Element Administration
Procedure details the governance for the
implementation of the management system
and it’s elements.

15

HSE Management System Framework

1.0.

Leadership and
Accountability

This element addresses the importance of
visible commitment of the leadership and
their role in supporting and driving the HSE
culture of the organization.

1.1. Objective

The top management and leadership at all levels of the
organization clearly demonstrates their commitment
and clearly establishes their accountability for the
implementation and the effectiveness of the system.

16

Ma’aden Safety Culture Transformation Program

1.2. Requirements

1.2.1. Establish and communicate that line management has primary accountability and
responsibility for HSE implementation and performance.

1.2.2. Assign clear HSE roles and responsibilities for the whole organization, including
employees and contractors.

1.2.3. Develop and document the organization’s HSE policy and ensure it is
communicated, maintained and reviewed periodically.

1.2.4. Ensure that a HSE management system, with the required supporting processes
and procedures, is developed and implemented at their affiliates to ensure the
implementation of all the elements and the requirements of the Ma’aden HSE
management system.

1.2.5. Develop, document and establish goals and objectives, including both leading
and lagging indicators at relevant functions and levels within the organization.
The objectives and targets shall be consistent with Ma’aden’s Corporate goals,
measurable where practicable, and consistent with the HSE Policy, including
commitments to improve HSE performance.

1.2.6. Develop, document and monitor the implementation plans to achieve the HSE goals
and targets.

1.2.7. Ensure that affected employees, individuals and stakeholders are engaged in
developing the policy, goals, and the HSE implementation plans.

1.2.8. Ensure that affected contractors, individuals and local communities receive timely
communications for the policy, goals, and the HSE implementation plans.

1.2.9. Regularly and systematically monitor and review the HSE management and
performance to take timely and appropriate actions to achieve the objectives and
improve the system.

1.2.10. Provide the necessary resources and consistent support to deliver the Ma’aden
HSE requirements. Resources include, but are not limited to, human resources and
specialized skills, organizational infrastructure, technology, facilities, equipment
and financial resources.

17

HSE Management System Framework

1.2.11. Visibly demonstrate the priority of HSE in
allbusiness activities,including integrating
HSEexpectations and targets intobusiness
planning.

1.2.12. Ensure HSE performance is considered
equallywith othercategories in all business
decisions including personal appraisals.

1.2.13. Ensure that a stakeholder’s participation
program is established and implemented
in the HSE Programs. Employees shall be
empowered to express their concerns on
unsafe act and unsafe conditions. Line
management shall be responsible to
address such concerns. Such concerns and
their response shall be documented.

1.2.14. Define, communicate and lead the Ma’aden
HSE culture and vision by being a personal
example, including off job activities, and
participating in the organization’s HSE
committees and other activities.

1.2.15. Review all class 1 and class 2 incidents,
including high potential incidents,
investigation and reports and ensure all
actions and recommendations from the
incident investigations are tracked and
closedontime.

1.2.16. Lead management reviews of the system
implementation and effectiveness at
regular planned intervals.

1.2.17. Ensure a HSE awards system is established
to reward HSE efforts and achievements.

18

Ma’aden Safety Culture Transformation Program
19

HSE Management System Framework

2.0.

Health, Safety and
Environment Legal and
Regulatory Compliance

HSE implementation efforts begin with the
identification of the legal and regulatory
requirements and establishing systems to
ensure compliance. This element addresses
the processes required to keep the
organization in compliance with all the HSE
regulations, legal and other requirements.

2.1. Objective

Systems are in place to proactively identify, comply
and document the compliance with applicable legal,
regulatory and other requirements.

20

Ma’aden Safety Culture Transformation Program

2.2. Requirements

2.2.1. Establish and maintain a systematic process to proactively identify applicable
legal, regulatory and other HSE requirements and determining how these apply
to the organization.

2.2.2. Identify and document HSE compliance tasks, assign responsibility for them, ensure
that these are a part of the HSE plan and verify their completion.

2.2.3. Identify, acquire and maintain all required legal, regulatory and other applicable
HSE permits and approvals.

2.2.4. Establish and maintain a process to identify applicable new or expected legal,
regulatory and other HSE requirements and use a Management of Change process
to implement and communicate them to those members of the workforce that
may be affected.

2.2.5. Establish and maintain a process to manage all HSE Notices of Violations and/or
Penalties issued by Regulatory Authorities, and Non-conformances identified by
third-party inspectors and auditors. Ensure the violations are investigated, root
causes identified, and corrective actions implemented to prevent recurrence.

2.2.6. Establish and maintain programs to comply with the regulatory monitoring,
reporting and record keeping requirements.

21

HSE Management System Framework

3.0.

Risk Assessment
and Management

Ma’aden uses a HSE risk based approach
to plan and manage all activities. This
element addresses the processes required
to proactively manage HSE risks.

3.1. Objective

To ensure that effective systems are in place for the
systematic identification, assessment, avoidance,
mitigation, stewardship and recording, of HSE Risks.
Appropriate approvals are obtained for continued
healthy, safe, secure and environmentally responsible
operations till HSE Risks are brought to a “low” level
or As Low as Reasonably Practicable (ALARP) level.

22

Ma’aden Safety Culture Transformation Program

3.2. Requirements

3.2.1. The organization shall establish and maintain a HSE risk identification, risk
assessment and risk management process.

3.2.2. Risk assessments shall be carried out by a team of competent, experienced and
knowledgeable personnel and involve stakeholders and affected parties as relevant.

3.2.3. The Risk assessment process shall be continuous, proactive and documented
covering the full life cycle of operations, products and services. HSE opportunities,
risks and impacts shall be assessed, as a minimum, during the strategy development,
feasibility, planning, procurement, design, construction, commissioning, operation,
decommissioning phases of assets, facilities and products.

3.2.4. Ma’aden’s approved risk assessment tools and techniques and the Ma’aden Risk
matrix shall be used to assess and record the risks.

3.2.5. Risk identification, assessment and management shall cover :

• Process safety hazards,

• Personal safety hazards,

• Transportation hazards (including vehicle & human interactions),

• Health and Hygiene hazards,

• Risks to the environment from operations until closure and rehabilitation,

• Processes, Products and Materials and

• Security Risks.

3.2.6. All documentation related to hazard identification and risk analysis, assessment
and management shall be kept complete, up-to date, and easily retrievable. All
units shall establish, maintain and, at least annually, review risk registers.

3.2.7. Risk management actions, based on the hierarchy of control, shall be identified,
recorded and implemented for identified hazards to minimize and control
foreseeable and residual risks.

3.2.8. As soon as the Risks are identified and assessed to be more than “low” on the
Ma’aden risk matrix, appropriate approvals shall be obtained before continuing
the plan, operation or activity for which the risks are identified.

3.2.9. Risk identification, assessment and management shall be performed for all routine

23

HSE Management System Framework

operations and be implemented through
detailed Job Safety Analyses (JSAs) for
all standard operating procedure for
operations and maintenance as detailed
in the JSA code of practice.

3.2.10. Risks of non-routine operations shall be
controlled through the implementation of
the Ma’aden work permit system.

3.2.11. Ma’aden’s Management of Change (MOC)
system shall be used to assess the risk
of, and manage changes safely and in
an environmentally compliant manner, to
plant, equipment, processes, technology,
materials,andorganization. TheMOCshall
be used to manage emergency, temporary
and permanent changes. Ensure that
details of the MOC are communicated to
those who may be affected by the changes.

3.2.12. MOC shall not be implemented if after
mitigation action the risk is still at a “Major
Risk” level. Major Risks items identified
in MOC shall be mitigated to “Low Risk”
level or ALARP (with approvals for the
level of Risk) before implementing or
commissioning such MOCs.

3.2.13. All actions for risk control shall be
documented and tracked to completion.

3.2.14. A formal process shall be established to
ensure that the risk studies and related
findings are communicated to the
concerned “affected parties” and all staff
understand the risks in their facilities,
the critical safeguards and their role in
maintaining ongoing safe operations.

3.2.15. A formal system to effectively and
continuously review the risk assessment
and management efforts shall be
established.

24

Ma’aden Safety Culture Transformation Program
25

HSE Management System Framework

4.0.

Communications

Communications, participation and
engagement plays a vital role in HSE
implementation both internally and
externally with all stakeholders.

26

Ma’aden Safety Culture Transformation Program

4.1. Objective

Effectively communicate HSE issues with all affected
parties and stakeholders.

4.2. Requirements

4.2.1. Develop an HSE communication, participation and engagement plan to identify
and provide avenues for the timely flow of information within the unit.

4.2.2. Establish, implement and maintain a process for:

• Internal communication among the various levels and functions of the

organization.

• Proactively communicating HSE information on risks, performance, HSE alerts

and lessons learned.

• Receiving, documenting and responding to relevant communication from

external interested parties.

4.2.3. Communication process shall include:

• Identification of relevant stakeholders and appropriate communication

program to promote and facilitate understanding.

• System to periodically evaluate the effectiveness of communications

programs with the stakeholders.

• Dialogue process with employees and other stakeholders about HSE

impacts, HSE performance, plans for improving organization performance
and management of relevant risks for products, processes and activities
associated with operations.

4.2.4. Conduct theme campaigns to reinforce HSE objectives and to address any
immediate or anticipated HSE concerns.

4.2.5. Any mass internal communication or external communication related to HSE,
shall be done in consultation with the Corporate Communication Department,
concerned HSE section head and the corporate HSE department.

27

HSE Management System Framework

5.0.

Competency
and Training

Employees and contractors need to
have the necessary knowledge and skills
(competency) to adequately perform their
assigned tasks. This element identifies how
to manage all the training activities and
provides details of specific training needs
that other elements may not have defined.

5.1. Objective

Ensure employees and contractors are competent
to perform their assigned tasks safely, securely,
environmentally responsibly and reliably.

28