Policies and Procedures

# Whirl the World - Health and Safety

The Company is keen that our offices and work practices do not cause harm to the environment. In addition to meeting legal health, safety and environmental policies we have adopted a number of measures to ensure that we contribute to a sustainable and healthy environment. These measures include but are not limited to:

- Recycling waste paper.

- Using re-usable plates, cups and suchlike instead of disposable items where practical.

- Donating surplus promotion items such as pads and pens to local charities or schools.

- Use of energy saving facilities on machines such as copiers and printers.

- Where possible trying to provide information electronically or though our website to save production of unnecessary waste.

## Policy

- The Company policy is to provide and maintain safe and healthy working conditions, equipment and systems of work for all employees, and to provide such information, training and supervision as they need for this purpose. Furthermore, it regards the promotion of health and safety matters as a mutual objective of every manager and employee.

- Consistent with the Company's commitment to safety, health and the environment it will ensure that arrangements will comply with legislation and best practice and involve all employees in the improvement.

- The Company also accepts responsibility for the health and safety of other people who are affected by its activities, and keeps under review the arrangements for health and safety of non-employees on its premises.

- This policy and the arrangements apply to all wholly owned companies; other associated companies are required to adopt this or an equivalent policy. It applies at all Company buildings, in accordance with the relevant local legal requirements.

- The Company will require contractors and suppliers to demonstrate an acceptable standard of performance.

- The Company will measure and review its safety, health and environment performance and audit arrangements as a means of planning continual improvements in performance.

- This policy will be reviewed annually.

## Procedure

### Health & safety

The Company has a legal duty to ensure, as far as is reasonably practicable, the health, safety and welfare of all its employees while at work. In general the Company must:

- Ensure that the working environment is maintained in a condition which is safe, free from risks to health and that adequate welfare facilities are provided.

- Ensure that Managers assess risk with the assistance of "competent persons" and devise systems of work where significant risks to health are identified and reduced to an acceptable level.

- Provide employees with information, instruction, training and supervision necessary to enable safe performance of work activities.

- Ensure that equipment and machinery used at work is suitable for its intended purpose and that any hazardous substances used or produced are assessed and adequately controlled.

A guide is displayed on notice boards throughout the Company's buildings.

### Environment

Implementation of an effective environmental policy to complement the Company’s health and safety activities is essential for the welfare of the community and employees. Consistent with this policy, the Company’s specific environmental policy is:

- To comply with environment protection laws and regulations.

- To conduct business according to recognized standards of the industry, including those relating to people.

- To market products without unreasonable risk to safety, health or the environment.

- To acknowledge that environmental, health and safety policies are of equal importance with other key operational objectives.

There are plans for continuous improvement in this area to support the various environmental initiatives already in place.

### Accountabilities

The CEO is ultimately responsible within the Company for health, safety and environment. Directors and Managers also have delegated responsibility for the implementation of the Company’s policy and have personal responsibility for safety, health and the environment within their functional or geographical responsibilities.

### CEO

The CEO is ultimately responsible for safety, health and the environment in the Company and must:

- Demonstrate commitment and leadership in all matters related to safety, health and the environment.

- Ensure that directors are aware of their obligations and carry them out in accordance with the Safety Health and Environment Policy.

- Ensure that adequate financial and other resources are made available to implement the Safety, Health and Environment Policy.

- Review policy implementation and performance annually and ensure improvement strategies are planned.

### Directors

Directors and in particular any specific Director designated with accountability for safety, health and the environment must:

- Demonstrate commitment and leadership in all matters of safety, health and the environment.

- Ensure the Safety Health and Environment Policy is communicated to all employees and implemented.

- Appoint a designated safety coordinator and ensure that all employees with delegated health and safety responsibilities have the necessary training and resources to fulfil their obligations.

### Location Manager

The Location Manager must:

- Ensure the premises, plant and equipment are maintained in a safe condition, in good repair and effective working order.

- Manage and monitor the building operational arrangements such evacuation procedures.

- Where designated, ensure requirements are incorporated into plans and local operating arrangements.

- Ensure that resources are provided for activities and that 4 fire evacuation drills are undertaken annually.

- Ensure all reported defects are rectified promptly.

- In addition to the Location manager’s responsibilities, the obligations of line managers may also be added.

### Line Managers

The responsibility of Line Managers is to:

- Ensure safety, health and environment risk assessment activities are carried out, documented and plans developed and implemented.

- Where designated, ensure safety, health and environment requirements are incorporated into plans and local operating arrangements.

- Ensure that resources are provided for safety, health and environment activities.

### Health & Safety Representatives

Health and Safety Representatives are to assist managers by:

- Undertaking assessments.

- Where required by law, reporting accidents to enforcing authorities.

- Assisting managers to carry out workplace safety inspections.

- Investigating complaints by employees relating to health, safety, or welfare at work and reporting findings to the Facilities Manager and Location Manager for appropriate action.

### Employees obligations

All employees have a duty to:

- Take reasonable care for their own safety, health and environment and for all persons they come into contact with at work.

- Cooperate with management to enable them to carry out their statutory duties in relation to safety, health and environment.

- Report all incidents that led, or may lead to injury.

- Not misuse anything provided for their safety, health and environment.

- Non-compliance with any safety, health and environment instruction will be considered a disciplinary offence and will be treated under the Company’s Disciplinary Procedures.

## Contacting Human Resources

Human Resources can be contacted at the following locations:

### Mail

First Avenue, Anytown, U.S.A.

### Email

hr.usa@whirltheworld.com