Celtique Energie Hsec Policy1332848937

HEALTH, SAFETY, ENVIRONMENT AND COMMUNITY MANAGEMENT STANDARDS

OCTOBER 2011- ISSUE No 01

Doc No: HSEC MS 001

Introduction

Celtique Energie is in the business of exploring for oil and gas in proven basins in Europe. The aim is to create value to shareholders and local stakeholders through hydrocarbon exploration, development and production. We are committed to explore responsibly for oil and gas in Europe and to supporting the community by creating jobs and improving security of oil and gas supply.

To support the aims and aspirations documented in the HSEC policy, a number of management standards have been developed based on the plan - do - review - improve methodology outlined in UK Health and Safety Executive (HSE) guidance document HSG65. These standards are applicable to all operated sites and it is a requirement for our contractors and suppliers to follow them. The various standards are supported by procedures (including Celtique’s Fundamental Safety Rules – FSR), guidelines and toolkits. These are designed to aid implementation of HSEC performance requirements for our operations.

Hierarchy of HSEC Documentation

Celtique Energie’s HSEC management system is hierarchical where all documents and systems help to implement the HSEC policy as shown in diagram below.

Contractors working for Celtique Energie are expected to adopt and tailor their own HSEC management system to meet the requirements of Celtique Energie whenever they work at our sites.

HSECSTANDARD

1

LEADERSHIP ACCOUNTABILITY

Intent:

All staff and contractors at Celtique Energie understand their accountability for responsible development and effective HSEC management.

Performance RequirementsSupporting Procedures, Guidelines and Toolkits

1.1 Good HSEC performance is recognised as an

important business objective and job descriptions clearly define the Executive Management’s individual and collective responsibility.

1.1.1 Job Descriptions Template

1.2 Executive Managers will provide sufficient resources

and personnel to ensure effective management of all aspects of HSEC.

1.3 All staff and contractors will be informed of and

understand their role and responsibility for HSEC performance of the company.

1.3.1 Personal Protection Equipment

(PPE) Policy 1.3.2 Worksite Jewellery Policy

1.4 Executive Management take an active part in

implementation of the HSEC policy. Each Executive Manager will have an annual personal HSEC plan that includes at least one site visit/inspection with HSEC input and participation in HSEC management meetings.

1.4.1 Annual Management HSEC

Plan1.4.2 HSEC Management Meetings

HSECSTANDARD

2

PLANNING, GOALS & TARGETS

Intent:

HSEC and Responsible Development is an integral part of our business with realistic goals and targets set to drive continuous improvement in business performance.


2.1 Celtique Energie sets annual HSEC goals and targets

that are measurable, documented and communicated to stakeholders. These are an integral part of the annual business plan for the company.

2.1.1 Annual Goals and Targets

2.2 Goals and targets are realistic and consistent with the

business aims of Celtique Energie and contain both leading and lagging indicators.

2.2.1 Balanced HSEC Scorecard

2.3 Performance against set targets is measured and

information is used to improve business performance and drive continuous improvement

HSECSTANDARD

3

RISK MANAGEMENT

Intent:

Hazards to HSEC from all our operations are identified, evaluated and assessed to reduce risks to as low as reasonably practical (ALARP principle).


3.1 HSEC risks are assessed, prioritised and managed to reduce risk to people, environment and stakeholders. Risk assessments takes into account health, safety, community, ecological, social, cultural, biodiversity, legal and financial implications. The hierarchy of risk control is used to develop risk mitigation strategies.

3.1.1 Risk Assessment Procedure

3.2 A HSEC risk matrix is used to classify and ensure a consistent approach in risk evaluations.

3.2.1 HSEC Risk Matrix

3.3 The risk management process involves employees, contractors and other relevant stakeholders as appropriate.

3.4 Identified risks are recorded and maintained in a risk

register. The risk register is reviewed and updated regularly depending on business activities.

3.4.1 Site Risk Register Template

3.4.2 Companywide Risk Register

Template

3.5 Risk management decisions are documented and

reviewed by management at the appropriate level.

HSECSTANDARD

4

SUPPLIERS, CONTRACTORS & PARTNERS

Intent:

Contracts for services, purchasing of materials and activities with partners will be managed according to Celtique Energie’s HSEC policy to minimise risk and impact to the stakeholders and the community.


4.1 Contractors and suppliers will be evaluated for HSEC

performance as part of the contract award process.

4.1.1 Contractor HSEC Evaluation

Procedure

4.2 Partners, contractors and suppliers will be required to

comply and meet the intent of these HSEC standards.

4.3 Contractors and suppliers are expected to provide

information about hazards and risks associated with their services and equipment prior to delivery or commencement of work activities. Their participation in Celtique Energie’s risk management process is expected and required.

4.4 Contracts will contain clear HSEC obligations that

suppliers and contracts must meet and consequences for non-compliance stipulated.

4.5 Contractors HSEC performance will be reviewed

throughout the period of the contract. Corrective actions will be identified and implemented as appropriate.

HSECSTANDARD

5

DESIGN & CONSTRUCTION

Intent:

Celtique Energie will ensure that projects incorporate global international oil industry standards into their design. All new facilities will be designed and constructed in a manner that supports responsible development and reduces risk to people, the environment and neighbouring communities to as low as reasonably practical.


5.1 Wells and process facilities will be designed and

constructed to meet industry standards and comply with legal requirements. Sound engineering practice will be used taking into account risk management principles.

5.1.1 Well Planning, Design and

Operation Standard

5.2 Each well and production facility will prepare a legal

compliance document/register.

5.3 Design and construction will be carried out by staff and

contractors that are competent to perform their tasks. Risk to people, environment and communities will be reduced to as low as practical through good quality design and construction.

Ref 5.1.1

5.4 Design data and operating limits will be documented

and made available for all wells and production facilities.

Ref 5.1.1

5.5 A pre start-up review will be carried out for all production

plants (including early production systems).

5.6 Independent peer reviews will be carried out for all well

and process plant design as part of the design review process.

HSECSTANDARD

6

WELL & PRODUCTION OPERATIONS

Intent:

Celtique Energie will ensure that all operations are carried out to meet applicable legal requirements and good international oil industry practice. Operations will be conducted in a manner that supports responsible development and reduces risk to people, the environment and neighbouring communities to as low as reasonably practical.


6.1 Critical protection systems such as BOP’s, ESD systems, gas detection are tested and maintained to ensure availability and operation on demand.

Ref 5.1.1

6.2 All sites must implement safe systems of work taking

into account risk level at site. This could include Permit to Work (PtW), Gas Testing, Isolation Certificates, Entry Permits etc.

6.2.1 Process Isolation Philosophy

6.2.2 Lifting and Handling Procedure

Ref 5.1.1

6.3 All site operations (drilling and production) must be

carried out by competent staff and contractors that are medically fit for their duty.

6.3.1 Medical Requirement

6.4 Personnel working in company offices and operating

locations must not be under the influence of drugs or alcohol.

6.4.1 Drug and Alcohol Policy

6.5 Simultaneous operation (e.g. drilling and production)

must be reviewed and managed to reduce risks.

Ref 5.1.1

6.6 A management of change process is in place to

control modifications to drilling programs, equipment

and plant.

6.7 All operational sites must adopt and adhere to

Celtique’s Fundamental Safety Rules.

6.7.1 Celtique’s Fundamental Safety Rules

HSECSTANDARD

7

COMMUNICATION & CONSULTATION

Intent:

Celtique Energie will establish transparent and open communication with stakeholders affected by company activities. All stakeholders, especially major contractors, will be encouraged to contribute to improve HSEC performance and support responsible development.


7.1 An HSEC management meeting is held at least twice

annually to review HSEC performance of all operations and major contractors. Contractor management will be invited to these meetings as appropriate. Minutes of meeting will be prepared and shared with stakeholders as appropriate.

7.2 A stakeholder engagement plan will be prepared for

each operated site covering both drilling and production activities. Implementation of the plan will be monitored and reviewed regularly.

7.3 HSEC information is actively shared across all

operated sites, with contractors and other stakeholders as appropriate.

7.4 Annual HSEC report is prepared covering all

operations to document the company’s commitment to responsible development. This report is made available to the public.

HSECSTANDARD

8

INCIDENT INVESTIGATION

Intent:

All incidents are reported and investigated to identify corrective actions to prevent reoccurrence. Findings are widely communicated and shared to reduce the risk at other sites.


8.1 Systems are in place to report incidents that occur

within Celtique Energie operations. All incidents will be classified according to severity and reported to management as required within prescribed timeframes.

8.1.1 Incident Reporting and Investigation Procedure

8.2 In case of a serious incident work must not continue

until corrective actions have been implemented. Celtique Energie Executive Managers and Senior Contractor Management, as appropriate, will be responsible for making this decision.

8.3 Celtique Energie and all its contractors encourage

near miss reporting as corrective actions arising from a near miss investigation may prevent an accident.

8.4 Incidents will be investigated to identify all factors and

underlying causes to enable corrective actions to be put in place that prevent re-occurrence.

8.4.1 Incident Investigation Form

8.5 Findings from incident investigations will be shared in

a structured way companywide. This will include communication with stakeholders as appropriate.

HSECSTANDARD

9

EMERGENCY RESPONSE

Intent:

Arrangements are made to manage potential emergencies that may occur within our operations. The aim is to reduce the impact and disruption to people, environment and neighbouring communities to as low as reasonable practical.


9.1 A corporate emergency response plan will be

prepared to clarify roles and responsibilities between the company and its contractors. The plan includes clear definitions of roles and responsibilities for management of external communication with stakeholders, families, press and media etc.

9.1.1 Celtique Emergency Response Plan

9.2 Celtique Energie will work with contractors to establish

site specific response plans for dealing with potential emergency scenarios that could arise from our operations. These will be linked to the corporate emergency response plans.

9.3 Emergency response equipment is maintained and

tested to ensure availability.

9.4 Emergency response exercises are carried out

regularly involving external response organisations and other stakeholders as appropriate. Lessons learnt from exercise will be documented and used to improve emergency response plans.

9.5 Employees and contractors are trained and

understand their role and responsibility in emergency response for all our sites.

HSECSTANDARD

10

MONITORING & REVIEW

Intent:

Monitoring and review of HSEC performance of all aspects of our operations is carried out to enhance business performance and drive continuous improvement within Celtique Energie.


10.1 HSEC site inspections and audits will be carried out at

regular intervals according to risk level of the site.

10.1.1 Annual Audit Plan

10.1.2 Management HSEC Inspection

Template10.2 A system is in place to implement and follow-up

corrective actions identified in audits and site inspections. Actions are prioritised using the Celtique Energie’s HSEC risk matrix.

10.3 Lessons learnt from past contracts, site inspections,

emergency response exercises, audits and corrective actions from incident investigations are collected, documented, reviewed and actively shared across all sites (especially new operations).

10.4 Annual management reviews are conducted to

confirm the suitability and effectiveness of the HSEC management system. Improvements and observations are documented and actions for continuous improvement identified and followed-up.

10.5 Celtique Energie’s Heath, Safety, Environmental

Protection & Community (HSEC) Policy is reviewed at least every three years.

10.5.1 HSEC Policy

DEFINITIONS & ABBREVATIONS

TERM DEFNITIONS

ALARP As Low As Reasonably Practical. This is a well established methodology in the oil and gas industry to demonstrate that all risks associated with an operation is reduced to an acceptable level. The methodology includes taking safety, community, practical and financial implication into account before work can proceed.

Audit A systematic and documented process to review effectiveness of HSEC management standards.

Annual Goals & Targets These are performance requirements set annually to ensure and drive continuous improvement in HSEC management.

BOP A Blow Out Preventer is a device used during drilling activities to prevent oil and gas escaping from a well bore in an uncontrolled way.

Compliance Register A documented record of regulatory and other requirements applicable to an operation.

Continuous Improvement A process of enhancing performance in HSEC management using a: plan – do – review – improve methodology.

Emergency Response Actions carried out to manage and reduce the impact of an abnormal occurrence that can threaten people, environment or communities.

ESD Systems Description of equipment installed to close down and make safe a well or production facility in case of a drilling or production upset endangering the well, rig site or production plant.

Executive Management/ Managers

This covers the Leadership within Celtique Energie (e.g. CEO, Exploration Director, Chief Operations Officer and Chief Financial Officer).

Fundamental Safety Rules (FSR)

A set of simple and easy to follow basic safety rules for regular work activities developed by Celtique Energie to prevent serious injuries and fatalities within our operations.

HSEC Health, Safety, Environmental Protection and Community. Communities are included in the HSEC Policy and Management Standards as they may be affected by the company’s operation. Good and responsible management of health, safety and environmental protection is as essential to them as it is for Celtique Energie and this is clearly demonstrated in the company documents.

HSEC Management System This is a structured and systematic framework of policies, standards, rules, procedures and toolkits implemented within Celtique Energie to consistently and effectively ensure effective HSEC management.

HSEC Risk Matrix This is a matrix to assess risk considering consequence and likelihood of occurrence. This is used for all risk assessments to ensure a consistent approach in risk management.

Incident This is defined as an event that has or could have caused an adverse consequence (e.g. injury, spill etc.) to people, environment or communities.

Leading & Lagging Indicators

A leading indicator is used to define proactive measures taken as part of a structured HSEC management plan. An example could be HSE training, site HSE inductions, site inspection to identify and remove hazards. Lagging indicators are statistics or collection of data after an event or period. A typical example is injury frequency rates or number of pollution events (spills) per year.

Permit to Work (PtW) A formal document that is used to manage and control certain types of work which is hazardous.

Responsible Development Responsible Development describes the way the company conducts its business. This includes consulting with local communities, protecting the environment and reducing risk to personnel. It also concerns the ability to provide employment and energy in the communities and markets where we work.

Risk Management A structured and documented process to identify hazards, evaluate them and identify risk reduction measures reduce risks of an operation to as low as possible.

Risk Register A document where risks for an operational site are recorded and maintained. Celtique Energie maintains site specific risk registers and a companywide risk register.

Stakeholders A stakeholder is defined as any person, organisation or interested party that has or could have an impact on or could be impacted by Celtique Energie’s operation. Typical examples are: employees, shareholders, contractors, local communities, suppliers, government or regulatory agencies.

Toolkits Provides practical assistance in achieving a task of performance requirement in the HSEC management standards. Toolkits are not mandatory.

Documents

Celtique Energie Hsec Policy1332848937