Health and Safety Procedure Rewriting

Shotton Paper Mill Project

1. Purpose

This procedure outlines Adana Construction Limited UK’s formal process for managing health and safety violations and administering disciplinary actions on the Shotton Paper Mill Project. It ensures a fair, transparent, and consistent approach to addressing breaches of health and safety policies, procedures, or legal requirements by Adana employees, subcontractors, and onsite personnel. The objective is to prevent unsafe behaviours, reinforce Adana’s zero-harm culture, promote compliance, and protect the wellbeing of all site personnel. This procedure supports Adana’s commitment to continuous improvement in health and safety performance through education, accountability, and when necessary, proportionate discipline.

2. Scope

This procedure applies to all individuals working under the control or supervision of Adana Construction Limited UK at the Shotton Paper Mill Project, including employees, subcontractors, temporary workers, and visitors. It covers all health and safety related violations, ranging from minor procedural non-compliances to severe breaches that compromise the safety of personnel or the environment. The disciplinary process outlined herein applies equally regardless of role or level and complements applicable legal frameworks, contractual duties, and Adana’s corporate policies.

3. Roles and Responsibilities

Project Manager The Project Manager holds ultimate responsibility for ensuring this procedure is implemented effectively across the project. They ensure that all health and safety violations are investigated thoroughly, disciplinary actions are applied fairly, and that leadership fosters a culture of accountability and safety leadership.

Health and Safety Manager/Advisor The HSE Manager leads investigations into reported or observed health and safety violations. They collaborate with management to assess the severity and context of breaches, advise on appropriate actions, and monitor the implementation of corrective and disciplinary measures. The HSE Manager contributes to training and awareness to prevent recurrence of violations.

Site Manager The Site Manager acts as the operational lead for enforcing health and safety standards on-site. They ensure immediate response to unsafe acts or conditions, coordinate violation investigations with the HSE Manager, and conduct frontline disciplinary discussions in line with this procedure. The Site Manager communicates outcomes and tracks resolution status.

Supervisors and Foremen Supervisory personnel are tasked with identifying, reporting, and addressing unsafe behaviours and conditions promptly. They provide coaching, issue warnings, and escalate more serious or repeated violations through formal channels as dictated by this procedure.

Human Resources / Disciplinary Coordinator The HR or designated Disciplinary Coordinator supports the consistent application of this procedure by advising on legal and procedural compliance, maintaining disciplinary records, facilitating hearings if required, and ensuring procedural fairness.

All Personnel and Subcontractors Every person on site is required to observe all health and safety policies and procedures, report violations, cooperate with investigations, and accept responsibility for the consequences of confirmed breaches.

4. Procedure

4.1 Identification and Reporting of Violations Any observed or reported health and safety violation — whether it be unsafe acts, neglect of safety controls, failure to follow procedures, or deliberate misconduct — must be reported immediately to the responsible supervisor or Site Manager. Observations can arise from routine inspections, safety audits, incident investigations, near miss reports, or peer reporting.

4.2 Initial Assessment and Immediate Actions Upon notification, the Site Manager or HSE Manager conducts an initial assessment to determine the validity and severity of the violation. Immediate measures are taken to mitigate any ongoing risk, which may include stopping work, isolating hazards, or temporary suspension of the individual involved pending further investigation.

4.3 Investigation A formal investigation team led by the HSE Manager or Site Manager conducts a structured assessment of the violation. The investigation considers the circumstances, intent, potential and actual consequences, prior history, contributory factors, and witness statements. The outcome establishes whether the violation was due to negligence, lack of understanding, procedural failure, or wilful disregard of safety.

4.4 Disciplinary Decision Making Based on investigation findings, a proportional disciplinary decision is made consistent with the nature and seriousness of the violation. Disciplinary measures may include:

· Verbal warning coupled with retraining.

· Written warning incorporated into personnel records.

· Temporary suspension from site pending further corrective action.

· Termination of employment or contract in cases of gross misconduct or repeated violations.

The decision is made collaboratively by the Site Manager, HSE Manager, and HR, following Adana’s disciplinary policy and ensuring procedural fairness. The affected individual is informed of the decision and right to appeal.

4.5 Communication and Documentation All investigations, decisions, warnings, and outcomes are documented in writing. Records are kept confidentially within Adana’s secure document management system and are retained in accordance with legal and contractual requirements. Communication about disciplinary outcomes is handled sensitively but clearly, reinforcing the zero-tolerance stance towards safety breaches.

4.6 Corrective Actions and Preventive Measures In addition to disciplinary actions, root causes of violations are addressed through corrective and preventive actions aimed at improving systems, controls, training, or supervision. These actions support continuous learning and risk reduction rather than solely punitive responses.

4.7 Appeal Process Individuals subject to disciplinary action have the right to appeal within a defined timeframe. Appeals are reviewed by senior management or designated impartial personnel who assess the procedural appropriateness and fairness of the original decision. Appeal outcomes are final and recorded appropriately.

5. Training and Competency

Adana ensures all personnel, especially supervisors and managers, receive comprehensive training on recognising safety violations, applying this disciplinary procedure consistently, and conducting fair and effective disciplinary discussions. Refresher training ensures ongoing awareness of behavioural expectations and procedural compliance.

6. Monitoring and Review

The HSE Manager and HR monitor health and safety violation trends to identify systemic issues, training gaps, or cultural concerns requiring strategic intervention. This data informs periodic reviews of the disciplinary procedure to ensure it remains effective, fair, and aligned with best practices and legislative changes.

7. References

· Health and Safety at Work etc. Act 1974

· Construction (Design and Management) Regulations 2015 (CDM 2015)

· Adana Corporate Health and Safety Policy

· Adana Employee Disciplinary Policy

· Shotton Paper Mill Project Safety Management Plan

· ISO 45001:2018 Occupational Health and Safety Management Systems