This plan applies to all Adana Construction Limited UK employees, subcontractors, suppliers, visitors, and any personnel operating on or connected to the Shotton Paper Mill Project under Adana’s jurisdiction. It governs conduct, operational controls, and management responsibilities relating to health, safety, and welfare matters during all phases of the project lifecycle, including mobilization, construction, maintenance, and demobilization activities.

3. Legal and Contractual Context

Adana acknowledges its duty under the Health and Safety at Work Act 1974, associated regulations (including CDM 2015), client contractual requirements, and relevant standards such as ISO 45001:2018. This plan integrates these obligations within Adana’s operational and management systems to ensure full compliance and proactive risk management throughout the project.

4. Health and Safety Management Rules

All personnel engaged by Adana on the Shotton Paper Mill Project must adhere strictly to the following management rules:

· Comply with all relevant health and safety legislation, client requirements, and Adana’s internal policies and risk control procedures without exception.

· Participate in all required health and safety training and induction programmes prior to commencing work on site.

· Always use the correct personal protective equipment (PPE) as specified for tasks and maintain it in good condition.

· Report all hazards, near misses, incidents, injuries, and unsafe conditions immediately to supervisors or the HSE team.

· Follow safe work methods and site-specific safety plans; never undertake work if risks are uncontrolled or beyond your competence.

· Cooperate fully with safety inspections, audits, and investigations to promote continuous improvement.

· Abstain from alcohol, drugs, or any substances that may impair safe behavior on site.

· Observe site traffic management, emergency procedures, and environmental controls as instructed.

· Maintain good housekeeping standards to prevent slips, trips, and falls.

· Support and engage positively with safety initiatives, toolbox talks, and behavioural safety programmes.

· No smoking except in designated areas in compliance with site rules and legislation.

Failure to comply with these rules may result in disciplinary action, including removal from site, consistent with Adana’s disciplinary policies.

5. Roles and Responsibilities

5.1 Senior Management (Project Director / Project Manager) Senior Management holds ultimate responsibility for health and safety leadership on the project. They must ensure health and safety policies are implemented effectively, sufficient resources are allocated, performance is monitored, and that a culture of safety excellence is championed. They oversee compliance with legal and contractual obligations and foster open communication and accountability relating to health and safety matters.

5.2 Health and Safety Manager (HSE Manager) The HSE Manager is responsible for developing, implementing, and maintaining the health and safety management system, ensuring risk assessments and control measures are current and effective. They coordinate audits, inspections, incident investigations, and drive health and safety training and awareness programmes. The HSE Manager serves as the principal advisor to project management on health and safety matters.

5.3 Site Manager The Site Manager ensures daily operational control of health and safety. Their duties include enforcing site rules, supervising safe working practices, coordinating with subcontractors to ensure compliance, and investigating any breaches or incidents. They act as the primary on-site leadership figure responsible for embedding the health and safety culture.

5.4 Supervisors and Foremen Supervisors and Foremen are responsible for implementing health and safety policies at the task level. They lead by example, conduct daily safety briefings, identify hazards, ensure workforce competence and adherence to safe systems, and report unsafe acts or conditions promptly. Their leadership in fostering safe behaviours is essential to project safety performance.

5.5 All Employees and Subcontractors Every individual working on the Shotton Paper Mill Project under Adana’s control must follow all health and safety instructions, attend required inductions and trainings, use PPE properly, report hazards, cooperate with investigations, and act responsibly to maintain their personal safety and that of others.

6. Communication and Consultation

Adana ensures continuous communication and consultation on health and safety through toolbox talks, safety committees, management meetings, posters, and digital communication tools. Everyone on site has the right and responsibility to raise safety concerns without fear of reprisal. Feedback from workforce engagement informs continual improvements to health and safety practices.

7. Training and Competency

All personnel must complete health and safety inductions before commencing work and participate in project-specific and role-specific training throughout the project. Adana maintains detailed training records and conducts competency assessments to ensure individuals are qualified and capable of performing their work safely.

8. Monitoring, Audit, and Review

Regular health and safety monitoring, including inspections, audits, and performance reviews, are conducted to measure compliance and effectiveness of controls. Non-conformances trigger corrective actions with lessons learned integrated into practice. This plan and related policies undergo formal review at least annually or following significant changes or incidents.

9. Incident Management and Reporting

All accidents, incidents, injuries, near misses, and unsafe conditions must be promptly reported, recorded, and investigated according to Adana’s incident management procedures. Root causes are identified, corrective actions implemented, and outcomes communicated to prevent recurrence.

10. Health, Safety and Environmental (HSE) Documentation

Adana operates a formal document control system ensuring that all health and safety documentation such as policies, risk assessments, method statements, training records, and audit reports are current, accessible, and securely stored to support compliance and continuous improvement.

11. References

· Health and Safety at Work etc. Act 1974

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

· ISO 45001:2018 Occupational Health and Safety Management Systems

· Adana Construction Limited Corporate HSE Policies

· Shotton Paper Mill Project Contractual Health and Safety Requirements