HEALTH, SAFETY & ENVIRONMENT POLICY STATEMENT

It is the policy of Manas Constructions that the health and safety of its employees, contractors and all users of facilities shall be of primary importance at all times, while at the same time it shall operate to minimize any impact its operations may have on the environment.

It is our responsibility to establish, implement and maintain health and safety management systems to ensure compliance with the requirements of this policy and any applicable regulations.

Our objectives are to:

• Provide safe places of work and healthy working environments for our employees, contractors and users of our facilities.
• Reduce and ultimately prevent injuries at work places by developing safe working practices, training employees in the practices and monitoring the results in each department.
• Promote health, safety and environmental protection as an integral part of the duties of management along with the education of all employees.
• Supply appropriate information, instruction and training to promote a high degree of awareness of health, safety and environmental concerns and the responsibility of each employee to prevent injury to themselves and others.
• Comply with all laws and regulations covering occupational health and safety and the environment.
• Develop and implement policies and procedures designed to promote safe working practices and environmental protection and encourage healthy and safe operating conditions in all companies.
• Implement practices and procedures for the use, handling, storage and transportation of materials and substances and to eliminate discharges and omissions that could harm the environment.

HEALTH, SAFETY AND ENVIRONMENTAL (HSE) POLICY
HSE Management Program

The Company shall:

• Comply with local regulations.
• Ensure that all personnel understand their specific HSE responsibilities.
• Encourage all personnel to take an active part towards the improvement of the HSE program.
• Ensure that all managers and supervisors actively carry out the intent of the HSE policy.
• Work with and contribute constructively to HSE initiatives within the industry.
• Conduct HSE audits of the Company activities on an on-going basis and publish.
• Continue to comply with the governing environmental and health regulations.

The Company shall prepare and implement an HSE plan to facilitate the procedures listed above. This HSE Procedures Manual is a record of learning about how best to prevent accidents and injuries. Not every hazard that occurs in daily activity is included, but areas of greatest exposure are addressed.

MANAGEMENT RESPONSIBILITY

Management Responsibility
The Manager is ultimately responsible for the Company's HSE performance. He shall ensure that all personnel, who manage and are involved in operations, comply with the HSE aspects of the Program.

Supervisor Responsibility
Although the success of any safety program requires the combined efforts of management, supervisors, and the worker, the supervisor is the key man. It is the degree to which the supervisor applies the intent of the program and the principles of safety that governs the success of this program. Safety is an area of mutual interest between the supervisor and the worker, and the supervisor must lead the way in developing the HSE program. Some of the supervisor's responsibilities are:

• Always set a good example for safety.
• Give adequate safety instruction to each and every new employee.
• Ensure the understanding by all employees that the violation of established safe work practices is a violation of company rules.
• Promote the proper use and care of protective equipment on each job.
• Promptly report all injuries to the Operations Manager or designated Safety Officer.
• Conduct routine safety inspections of his area for unsafe conditions and procedures, and ensure the proper use and maintenance of protective equipment.
• Initialize and forward all necessary accident reports to the Operations Manager or designated Safety Officer, such as: Accident Report, Near Miss Reports, Unsafe Condition Reports, etc.

Security & Safety Manager
The coordination of the company's HSE program shall be the responsibility of the Security & Safety Manager. Duties include:

• Advising and making recommendations to all supervisory personnel in the company.
• Monitor the overall safety program and help identify critical areas.
• Manage and comply with local and industry specific safety and environmental reporting requirements.
• Keep management informed of the safety performance of the various divisions and recommend appropriate actions to improve performance.
• Develop and implement safety-training programs.
• Administer and report to management on the status of workers' compensation claims and property damage insurance claims.

Employee Responsibility
Management and supervisors expect the individual employee to cooperate in every respect with the company's safety program, so that the day-to-day operations may be carried on in such a manner, as to insure the safety of himself, his fellow employees, the client and company property. Therefore, each employee is charged with the following responsibilities:

• Observe all safety rules and regulations.
• Report any unsafe conditions or practices to your supervisor.
• Know how to perform jobs assigned and perform them properly.
• Do not undertake any job you do not understand. Ask your immediate supervisor if there are any questions or any doubt.
• Wear and use all safety equipment required by the job to be performed.
• Participate in safety meetings held by your supervisor.
• Report all injuries immediately to your supervisor.
• Cooperate with supervisor when injury and accident investigations are being made so that accident causes can be determined and corrective action taken.
• Report any and all defective tools or equipment immediately.

HSE DOCUMENTATION & RECORDS

HSE System Documentation
The HSE Program is comprised of the following documentation system:

• The HSE POLICY Manual which states the Company's policy and objectives, and which defines the method by which the Company shall comply with the overall intent of the HSE Program.
• The HSE Procedures manual, which has been developed for those activities posing the greatest risk to health and safety. These procedures define responsibilities and actions to be taken to minimize the risk.
• The Company records and forms (accident reports, Investigation report, Vehicle Accident Report) which support and document compliance with regulations and client requirements.

HEALTH, SAFETY AND ENVIRONMENTAL PROCEDURES

General
All company operations shall adhere to the HSE Procedures Manual. Health and safety guidelines, safety rules and client regulations must be taken into consideration. Where there is a conflict involving operational requirements, the more stringent of the two safety rules will take precedent. If a conflict involving an HSE practice cannot be resolved the appropriate manager must be notified immediately.

Health
It is a company policy that all employees pass a medical examination, work fitness evaluation, and random drug screening. Employees may be required to have a medical examination on other occasions when it is job-related and consistent with business activity.
Such occasions may arise when there is a potential for exposure to toxic or unhealthful situations, or when there is a question concerning an employee's ability to perform job duties.

Substance Abuse
Compliance with the Company's Drug & Alcohol Free Workplace Policy (HSE Procedures Manual) shall be a condition of employment. We are committed to a drug & alcohol free workplace. This is achieved by the maintenance of an active anti-drug and anti-alcohol plan.
Any on-duty employee with a detectable level of alcohol, drugs or controlled substances is prohibited from performing service for the Company and will not be permitted to remain at work.

Safe Work Practices
Field employees work in an environment of potential risk from dangerous machinery, materials, fire, weather and other conditions. Safe working practices must be followed at all times.

Personal Protective Equipment (PPE)
The use of PPE shall be in compliance with local and industry related regulations. Personnel shall be issued the necessary PPE for the operation to be performed Use of PPE will be mandatory and under the control of the on-site supervisor as outlined in the HSE procedures manual.

RISK CONTROL

Risk Assessment
The Company shall identify and document HSE risks in order to prevent and control the risk. As a minimum, the risk assessment will include consideration of the following:

• Nature of work
• Location of work
• Potential for exposure to worksite hazards
• Potential consequences of incident (environmental, legal, or delay in operations.

Risk Control
When risks or hazards have been analysed and assessed, decisions can be made about control measures, which must be taken into account. The following risk control principles shall apply:

• Eliminate or minimize the risk by substituting safer operational procedures.
• Use engineering controls.
• Minimize the risk by the use of personal protection and equipment.

Employees involved in these areas of operations will receive appropriate HSE training, participate in site-specific safety meetings.