Safety and security guidelines for lone wolf mujahideen

Guidelines for the Assurance of Safety, Security, Health and guidelines for chemical transportation safety security and risk management
Dr.AshleyBurciaga Profile Pic
Dr.AshleyBurciaga,France,Researcher
Published Date:05-07-2017
Your Website URL(Optional)
Comment
 Guidelines for the Assurance of Safety, Security, Health and Environmental Protection in the Roche Group 2014 edition – supersedes the 2007 edition. Obligation to Society Excerpts from the Roche Corporate Principles: Mission Our aim as a leading healthcare company is to create, produce and market innovative solu- tions of high quality for unmet medical needs. Our products and services help to prevent, diagnose and treat diseases, thus enhancing people's health and quality of life. We do this in a responsible and ethical manner and with a commitment to sustainable development respecting the needs of the individual, the society and the environment. Respect for the individual, Commitment to society We want everyone in the organization to work under optimal conditions of health and safe- ty. We want to maintain high ethical and social standards in our efforts to protect the envi- ronment. Commitment to the Environment As part of our commitment towards sustainable development we proactively seek to em- ploy new, more sustainable technologies and processes and to minimize our impact on the environment. Therefore our mission for safety, security, health and environmental protection is: We ensure business continuity by managing Safety, Security, Health and Environ- mental matters with the same sense of responsibility, and just as methodically, as issues concerning quality, productivity and cost-efficiency. Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 2 / 48 Table of contents Obligation to Society ............................................................................................................................................. 2 Table of contents .................................................................................................................................................... 3 Abbreviations ........................................................................................................................................................... 5 1. Introduction .................................................................................................................................................. 6 1.1 Purpose of the Guidelines .................................................................................................................. 6 1.2 Scope ......................................................................................................................................................... 7 1.3 Management Cycle ............................................................................................................................... 9 1.4 Hierarchy of and Responsibility for SHE Documents ............................................................. 10 2. Strategic SHE Objectives and Operational Goals .................................................................. 12 3. Organization and Responsibilities ................................................................................................. 13 3.1 General Organization of SHE........................................................................................................... 13 3.2 Corporate Executive Committee ..................................................................................................... 13 3.3 Committee of the Board of Directors supervising SHE .......................................................... 13 3.4 Heads of Divisions, Business Units and Global Functions ................................................... 14 3.5 General Managers, Site Managers ............................................................................................... 14 3.6 Group Safety, Security, Health and Environmental Protection (Group SHE) ................. 15 3.7 Local SHE Organization, SHE Officers, Site Security Officers ............................................. 18 3.8 Line Managers, Supervisors ............................................................................................................ 20 3.9 Employees .............................................................................................................................................. 21 3.10 Additional Positions with Safety, Security, Health and Environmental Protection Responsibilities..................................................................................................................................... 21 3.11 Third Parties .......................................................................................................................................... 22 3.12 Further information ............................................................................................................................. 22 4. General SHE Standards ........................................................................................................................ 23 4.1 Training ................................................................................................................................................... 23 4.2 Communication .................................................................................................................................... 23 4.3 Goal Setting, Performance Monitoring and Key Data Collection ....................................... 24 4.4 Documentation and Document Distribution ............................................................................. 24 4.5 Legal Aspects ....................................................................................................................................... 25 Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 3 / 48 4.6 SHE Management System ................................................................................................................ 25 4.7 Prevention .............................................................................................................................................. 26 4.8 Risk Management ............................................................................................................................... 26 4.9 Emergency Management ................................................................................................................. 27 4.10 Auditing and Inspection .................................................................................................................... 28 4.10.1 Group SHE Auditing .................................................................................................................. 28 4.10.2 Site SHE Self-Audits .................................................................................................................. 28 4.10.3 Local Walk around Inspections ............................................................................................. 29 4.11 Product Stewardship .......................................................................................................................... 29 4.12 Due Diligence ....................................................................................................................................... 30 Annex: SHE Principles and Procedures .......................................................................................... 31 A.1 People .................................................................................................................................................... 31 A.1.1 Health Hazards and Occupational Risk Management.................................................. 31 A.1.2 Occupational Safety and Health Protection ...................................................................... 31 A.1.3 Mental Health .............................................................................................................................. 33 A.1.4 Health Promotion ....................................................................................................................... 33 A.1.5 Rehabilitation and Reintegration .......................................................................................... 33 A.1.6 SHE Knowledge .......................................................................................................................... 34 A.1.7 Personnel Security ..................................................................................................................... 34 A.1.8 Safe Driving .................................................................................................................................. 35 A.2 The Environment............................................................................................................................... 35 A.2.1 Safety of Chemicals ................................................................................................................... 35 A.2.2 Control of air emissions and water and soil contamination ....................................... 36 A.2.3 Clean Soil ...................................................................................................................................... 37 A.2.4 Nature Conservation ................................................................................................................. 37 A.2.5 Clean Water .................................................................................................................................. 38 A.2.6 Clean Air ........................................................................................................................................ 38 A.2.7 Environmental Risk Assessment ........................................................................................... 39 A.3 Resources ............................................................................................................................................ 39 A.3.1 Energy ............................................................................................................................................ 40 A.3.2 Chemicals, Dangerous Goods ............................................................................................... 40 A.3.3 Water .............................................................................................................................................. 41 Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 4 / 48 A.3.4 Packaging Materials ................................................................................................................. 41 A.3.5 Data on Materials ....................................................................................................................... 41 A.3.6 Eco-efficiency, Eco-balance ................................................................................................... 42 A.3.7 Suppliers, Service providers, Outsourcing partners, Contractors ............................. 42 A.4 Tangible and Intangible Assets ................................................................................................ 43 A.4.1 Buildings ........................................................................................................................................ 43 A.4.2 Plants and Installations, Infrastructure ............................................................................... 44 A.4.3 Raw Materials, Excipients, Products, and Packaging Material .................................. 45 A.4.4 Residual Materials, Waste ....................................................................................................... 45 A.4.5 Car fleet ......................................................................................................................................... 47 A.4.6 Knowledge, Know-how ............................................................................................................ 47 A.5 Processes ............................................................................................................................................. 48 Abbreviations  SHE = Safety, Security, Health and Environmental Protection. This is the abbreviation for the corresponding topics. See also chapter 1.2.  Group SHE = This is the abbreviation for the SHE organizational unit on the Roche Group level.  SEO = Safety, Health and Environmental Protection Officer = SHE Officer.  SSO = Site Security Officer. Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 5 / 48 1. Introduction Safety and health protection at all workplaces, together with protection of the surroundings and the environment are principal concerns of the Roche Group’s management. They are main elements of a sustainable development, as pursued by Roche. Safety, security, health and environmental matters are handled with the same sense of re- sponsibility, and just as methodically, as issues concerning quality, productivity and cost- efficiency. Safety, security, health and environmental protection concerns are an inseparable part of every activity. Department supervisors are responsible for ensuring that these issues are well managed. They are accountable for knowing what can be expected of employees in terms of know-how and skills and the technical and organizational measures that are required. Every supervisor and specialist must be familiar with the laws and regulations applicable to his or her area of responsibility, as well as with internal guidelines and directives, and with recognized technological codes and implement them accordingly. All employees have a personal responsibility, in accordance with their level of knowledge and ability, to ensure that safety, security, health and environmental protection regulations are observed. 1.1 Purpose of the Guidelines Based on the Roche Corporate Principles the Policy on Safety, Security, Health and Environ- mental Protection in the Roche Group was adopted by the Corporate Executive Committee. This policy document was revised and published in 2012; it builds on earlier editions (1980, 1991, 1996 and 2005). In addition to the principles stipulated in the Policy on Safety, Security, Health and Environ- mental Protection in the Roche Group, Roche also adheres to the guidelines of various inter- national bodies. For instance, Roche has signed the Charter for Sustainable Development of the International Chamber of Commerce (ICC principles on environmental management). Roche is committed to comply with all legal requirements and the pertinent international conventions in every country where we operate. The present Guidelines for the Assurance of Safety, Security, Health and Environmental Pro- tection in the Roche Group are oriented to the ISO 14000 ff standards. SHE is an integral part of the Roche Sustainability efforts (see http://we.intranet.roche.com/sites/roche/content/about- roche/sustainability/pages/default.aspx). The main purpose of these Guidelines is to define clearly the corporate provisions and re- quirements which are both necessary and suitable for practice-oriented implementation of the principles of the Policy on Safety, Security, Health and Environmental Protection in the Roche Group and the above-mentioned international programs. Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 6 / 48 As a supplement to these guidelines, Group SHE or local SHE organizations may issue spe- cial documents (e.g. guidance notes, directives, annexes) on specific topics. In carrying out their work, supervisors and specialists must therefore, in addition to meeting all legal re- quirements, observe not only the Guidelines for the assurance of Safety, Security, Health and Environmental Protection in the Roche Group and the local SHE handbook, but also such additional documents on specific issues. 1.2 Scope This publication has Group-wide validity. It is binding for all Roche Group Companies and Sites and must be followed by all managers and employees. Proposals for deviations from the provisions in this document can be discussed with Group SHE who can approve the devia- tions if the expected outcome is comparable to the provisions herein. SHE matters regarding third parties are covered by the Roche Guidelines on Dealing with Suppliers and Service Providers (part of the Roche Code of Conduct) and the Corporate SHE directives K13 (Dealing with Contractors) and K15 (Dealing with third party manufacturers and service providers). In order to account for the variety of businesses within the Group, the SHE provisions in this Guidelines document are formulated in a generalized manner. Companies and Sites must therefore regulate specific aspects in a local SHE handbook in line with their local organiza- tional form and particular circumstances. SHE stands for Safety, Security, Health and Environmental Protection, which comprises all issues and activities in these areas. It does not address safety issues in the intended use of our marketed products. Relevant topical areas are exemplified below, though the list is not exhaustive:  Safety o Operational safety  Employee safety  Accident prevention  Building and plant safety  Process safety  Risk management  Emergency management o Safety of chemicals and biological materials  Handling  Storage  Transport  Safety data, documentation Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 7 / 48  Security o Personnel o Physical assets o Products o Knowledge o Information (not covering core IT security like data access control, firewalls, vi- rus protection etc.)  Health o Health protection at the workplace  Industrial hygiene  Occupational toxicology  Occupational medicine  Accident prevention  Ergonomics  Stress, mental health  Biosafety  Radiation protection  Noise o Health promotion  Environmental Protection o Emissions  Into the air  Into the water  Into the soil o Waste  Avoidance  Re-use, recycling  Disposal o Resources, including energy  Efficient use  Change to best alternatives  Eco-balance o Noise o Remediation of existing contamination Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 8 / 48 1.3 Management Cycle The management of SHE issues should be structured and clearly communicated. For this reason we encourage the use of a framework that includes each of the basic steps in a man- agement cycle (e.g. according to ISO 14000). C Con ont tinu inual al I Im mpro prov vem emen ent t Re Rede def fiini niti tion on o of f Ob Objec ject tive ives s and and M Me eas asu ure res s A As ss ses ess sm men ent t a an nd d Man Managem agemen ent t Re Rev viiew ew Mon Monit itor oring ing a and nd C Con ontro troll I Im mp plem lemen enta tat tion ion Pla Plann nning ing Ob Objec ject tii- - v ve es s and and Me Mea as su ure res s C Com omm mitme itment nt and and Po Pollic icy y Ne Need eds s a and nd V Va alu lues es Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 9 / 48 1.4 Hierarchy of and Responsibility for SHE Documents Corporate Group Group SHE Executive Committee Companies / Sites Corporate Principles Proposal Group SHE Policy SHE Guidelines SHE Handbook SHE Guidance Notes SHE Directives Local SHE Directives Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 10 / 48 Guidance notes provide specific instructions valid only for certain parts of the organization (e.g. specific guidance for research). Directives are explicit instructions on selected topics (e.g. on energy management). They are binding for all Roche and must be followed in detail (except if provisions are prohibited by local laws). Directives do not cover all SHE topics. In accordance with the Policy on Safety, Security, Health and Environmental Protection in the Roche Group, all Group Companies and Sites are required to prepare and maintain local SHE handbooks, which form the basis for the SHE management at the Site (note: SHE handbooks are typically made available electronically). These handbooks must describe in detail the implementation of the Guidelines for the Assurance of Safety, Security, Health and Environmental Protection in the Roche Group at the local level. In particular, the handbooks should indicate where additions or modifications must be included based on local conditions (see following list). The following elements should be included in the local SHE handbook (existing documents can be referenced). These elements constitute the minimum necessary corporate require- ments. Additional formal requirements are necessary if you strive for certification (e.g. ISO 14000, EMAS, OHSAS 18001), and they also may be necessary for local legal reasons. Addi- tional documentation requirements are described in the SHE directives. Introduction - Glossary: definitions, abbreviations, terms Site description - Description of activities - Site organization - Site plans SHE Organization - Name of manager responsible for the Site - Determination of Site-specific responsibilities for SHE (job descriptions, duties) - SHE organization charts - Organization of emergency response service Legal aspects - Catalogue of legal SHE regulations (laws, ordinances, provisions, training), including reference to specific regulatory applicability to Site operations, as well as local compliance assurance documentation - Catalogue of SHE related building and operating licenses - Catalogue of SHE related agreements with authorities (exemptions, extension of deadlines, etc.) Communication - Determination of rules for internal and external SHE communication Measurements, data - Catalogue of compulsory and voluntary data registration (e.g. emission and immission monitoring) - Processes for key data collection and reporting Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 11 / 48 Documentation - Rules on documentation of SHE related data - Regulations on distribution, updating and filing of SHE related documentation (document control and retention) - Catalogue of valid SHE documents - Cross references to other SHE related documents Processes - Description of all relevant SHE processes of the Site (sequence of activities, controls, responsibilities, documentation, etc.) 2. Strategic SHE Objectives and Operational Goals The Policy on Safety, Security, Health and Environmental Protection in the Roche Group es- tablishes the following strategic SHE objectives. Roche strives to:  establish itself as one of the leading companies in the healthcare industry  continuously improve upon our high standards for safety, security, health and environ- mental protection  promote SHE awareness among all employees and create the conditions for SHE to be- come a matter of course in their daily work  support active SHE communication including training  maintain good relations on SHE issues with neighbors, authorities, customers, suppliers, shareholders and the public  continually reduce the ongoing and episodic environmental impact from our operations  actively manage the entire SHE risk portfolio  identify and resolve unacceptable risks at an early stage  continue efforts to further prevent occupational injuries and illnesses  optimize the use of all materials and energies to improve the eco-efficiency and continu- ally reduce environmental pollution and conserve resources  provide security for our employees, workplaces, knowledge and products Roche has established operational SHE goals on the Group level (see http://rochenet.roche.com/cse/she_goals_for_the_roche_group.htm). The goals and the per- formance against these goals are published yearly on the Roche Internet (http://www.roche.com/sustainability/for_communities_and_environment/environment/our_s he_goals_and_performance.htm). All Sites must make sufficient efforts to contribute to these goals according to their abilities. Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 12 / 48 3. Organization and Responsibilities 3.1 General Organization of SHE 3.2 Corporate Executive Committee The Corporate Executive Committee (CEC) determines the SHE policy on the basis of the Roche Corporate Principles and the Roche Sustainability Charter. The CEC defines the main organizational structures and designates the functional responsibilities necessary for imple- menting the SHE policy. In addition it supervises compliance of the entire organization with this policy. Safety, security, health and environmental protection are principal parts of a sustainable de- velopment and therefore main topics handled in the Corporate Sustainability Committee (see http://www.roche.com/home/sustainability.htm). 3.3 Committee of the Board of Directors supervising SHE The assigned sub-committee of the Board of Directors is regularly informed about the status of SHE in the Roche Group, the SHE goals, the trends of the corresponding key performance indicators, the main SHE issues (past and foreseen), the SHE risk situation and the exposure of the Roche Group to new SHE issues and trends. This Committee provides general guid- ance regarding SHE and actively engages itself if the SHE status, trends or risks are deemed unsatisfactory. Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 13 / 48 3.4 Heads of Divisions, Business Units and Global Functions The heads of divisions, business units and global functions must consider economic, envi- ronmental and social (including worker) impacts when taking business decisions. They sup- port their organizations in their SHE tasks and duties, in particular by  delegating the necessary powers and authority to them  approving the necessary budgets  ensuring that SHE due diligence is conducted on all property transactions including acquisitions, joint ventures, leases and sales of property  involving and cooperating with the SHE organizations 3.5 General Managers, Site Managers The General Managers (GM) of Roche’s Group Companies and the Site Managers (SM) (managers responsible for a Site) are responsible for all aspects of safety, security, health and environmental protection in the areas under their control. Where certain SHE issues cannot be assigned to a single Site, but span multiple Sites, the managers responsible for the corresponding activities take this responsibility. In these cases the delineation of SHE re- sponsibilities must be carefully coordinated. On the basis of the Policy on Safety, Security, Health and Environmental Protection in the Roche Group, these Guidelines and the Group SHE Directives, the GM/SM adopts the local SHE and security handbooks, establishes the local SHE organization and assigns responsi- bilities. The name of the manager responsible for a particular Site and of the persons in charge of SHE must be provided in the local SHE and security handbooks and reported to the headquarters to be documented in the Roche Corporate Addresses database. The SHE tasks and duties of the managers responsible for a Site are listed below. The Gen- eral Manager or Site Manager, while remaining responsible for SHE, may delegate certain tasks to the line managers and certain tasks to the local SHE officer and SSO.  implementing the corporate SHE Policy and Guidelines  defining the local SHE organization and assigning relevant tasks and responsibilities  establishing accountability for SHE performance and goal attainment with direct reports  promoting SHE awareness among employees at all levels, especially regarding the rele- vant legal regulations and in-house SHE provisions  ensuring compliance with local legal regulations and with Roche SHE provisions  allocating sufficient resources to support effective SHE training  defining local SHE objectives and goals, based on the Group SHE objectives and goals  defining and implementing action plans to address SHE objectives and goals  ensuring that a risk analysis process is established and that identified risks for all rele- vant assets, workplaces and processes are adequately communicated and managed  compiling the corresponding risk inventory (risk register) Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 14 / 48  ensuring and implementing an adequate and consistent security strategy for the Compa- ny or Site  setting up and training of an appropriate emergency management organization in line with local risks, clearly defining responsibilities, powers and procedures  establishing an external communication process to ensure good relations with neighbors, stakeholders and the public regarding SHE issues  establishing a process to ensure that SHE due diligence is conducted on all property transactions including acquisitions, joint ventures, leases and sales of property  ensuring that SHE-relevant incidents as well as situations where assistance is needed are reported to Group SHE and – where necessary – to the authorities  preparing and updating a local SHE handbook  ensuring that all employees are informed about and have access to the local SHE hand- book and other relevant SHE information in line with their level of competence and re- sponsibility  periodically reviewing the local SHE management system  ensuring that business decisions are sustainable and include consideration of economic, environmental and social (including worker) impacts  implementing a system for management of change and for the review of capital and maintenance projects for SHE impacts  ensuring that the SHE Officer and SSO are notified and involved early in the design phase of new projects  ensuring that contracted service providers and suppliers are carefully selected regarding their SHE performance  determining Site-related SHE key figures and reporting them to Group SHE 3.6 Group Safety, Security, Health and Environmental Protection (Group SHE) Group SHE is a specialized Group function which supports the Corporate Executive Commit- tee in SHE matters. It has the following mission: Set standards and regulate SHE matters. Support implementation by  Building awareness  Motivating  Educating, Informing, Consulting and Supporting  Auditing, Checking  Reporting Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 15 / 48 ②②② Loc Local S al SHE HE Mo Mo Motivat tivat tivate e e In In Info fo form rm rm ①①① Edu Edu Edu- - - c c cate ate ate Loc Local al Bu Bu Buil il ild d d Con Con Consul sul sult t t Ma Manag nageme ement nt Awa Awa Awa- - - ③③③ re re re- - - ne ne ness ss ss Do it Do it Aud Aud Audiiit t t ⑤⑤⑤ Re Re Repo po port rt rt ④④④ Tasks and duties include:  formulating the corporate SHE policy on behalf of the Corporate Executive Committee o including periodic review and amendment as necessary  issuing Group-wide SHE documents (guidelines, guidance notes, directives) in support of the corporate SHE policy  identifying, monitoring and assessing the general developments in SHE worldwide and initiating necessary actions in response to emerging trends or specific SHE problems  protecting Roche interests in governmental and non-governmental organizations, busi- ness organizations and scientific bodies while providing support in developing favorable solutions  representing all SHE affairs in the Roche Sustainability Committee  supporting the Group Companies and Sites in all SHE matters o training local SHE officers o discussing and assessing proposals from the Sites o identifying and communicating possible SHE solutions by providing the ad- vantages and disadvantages of possible options (best practices) o arranging contacts with experts and colleagues o facilitating know-how exchange and benchmarking  preparing relevant safety documents for chemical and pharmaceutical substances hand- led within the Roche Group (e.g. material safety data sheets, environmental risk assess- ments, classifications, registrations, etc.) Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 16 / 48  conducting SHE audits at Group Companies and Sites to review the status of SHE and local SHE management systems and ensuring follow-up o assessing the corresponding corrective action plans o monitoring implementation of the corrective actions  performing due diligence to identify SHE risks and liabilities associated with property transactions (e.g. acquisitions, joint ventures, leases, sale of parts of our business etc.) in support of, and upon request from General and / or Site Management  preparing a Group SHE risk inventory based on the local risk inventories and overall global risks  collecting SHE key figures and other relevant information from the Group Companies and Sites o conducting plausibility checks o consolidating of the numbers on different levels  coordinating corporate security programs and addressing security issues that cannot be resolved at a local level  informing the Corporate Executive Committee and the Committee of the Board of Direc- tors supervising SHE of the SHE status and the relevant SHE risks in the Group  preparing the SHE section of the annual Roche Business Report  maintaining Corporate SHE Internet and Intranet pages  issuing Corporate position papers on important SHE topics, and SHE bulletins on critical issues Group SHE consists of two groups, one located at Roche Group headquarters in Basel and one located in the USA (CESA = Corporate Environmental and Safety Affairs). The U.S. group is responsible for coordinating SHE, with a special focus on ensuring legal compliance, for all North American Sites on behalf of the Basel group and conducts other SHE tasks for the Roche Group wherever necessary. The Basel group coordinates SHE for the rest of the world. The head of Group SHE has the global responsibility for the described SHE tasks. Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 17 / 48 = functional reporting = functional and administrative reporting 3.7 Local SHE Organization, SHE Officers, Site Security Officers Every Roche Site must designate a SHE officer (SEO) and a Site Security Officer (SSO) who are located at the Site. Group SHE must be involved in the selection process (information on and interview with final candidate); they have a right of refusal, but the General Manager / Site Manager is finally deciding on who will be the SHE Officer / SSO. The tasks and competences must be given to them by the General Manager / Site Manager in writing (e.g. in a job description). In small Sites the two roles may be taken by the same person. The SEO and the SSO may be supported by a specialist SHE organization. Since the Site SEO and SSO need to  be as independent as possible,  have direct, unfiltered access to the top management of the Site,  have real oversight over the Site, and  have influence on the whole organization, they typically report directly to the head of the Site (exceptions to be discussed with and ap- proved by Group SHE). Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 18 / 48 In respect of technical matters, the SEO reports to the head of Group SHE and the SSO re- ports to the Chief Security Officer at Group SHE. Depending on a Company’s size and the complexity of its operations, the local SHE organization may be expanded. At small Company Sites these tasks can be conducted by single employees as part of or in addition to their reg- ular responsibilities. The tasks and duties of the local SHE organization and the local SHE officer include:  supporting and advising Site senior and line management in SHE matters  promoting SHE in the Company based on the local and global Roche SHE objectives and goals  supporting the organization for compliance with local legal regulations and with Roche SHE provisions  supporting line management in SHE training for employees  developing and maintaining a system for receiving, documenting and responding to SHE related reports and complaints  ensuring that a risk analysis process is implemented and documented  timely and actively representing and defending SHE requirements in projects and ensur- ing their implementation  conducting periodic SHE inspections  reporting critical SHE situations  monitoring and documenting o the implementation of SHE programs and action plans, especially SHE measures planned in order to close identified gaps o accidents and incidents, o occupational injuries and illnesses, o emissions due to the activities of the Company, especially related to soil, water and air pollution o the use of energy and raw materials and specifically regulated items o the status and progress of actions related to SHE goals and targets  compiling and documenting the SHE KPIs o used for monitoring the trend towards the SHE goals o used by the management as a basis for their SHE plans o for SHE reporting  reviewing and supporting the communication of SHE related information and documen- tation  advising local (Roche external) emergency response teams in the event of incidents, in- cluding transport accidents involving Roche products  establishing and maintaining the local (Roche internal) emergency management (LEM) system  managing financial provisions for legacy health and environmental liabilities, together with the finance department  establishing and maintaining contacts with the local SHE authorities, professional organi- zations, scientific bodies and the public Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 19 / 48 The tasks and duties of the local security organization and the Site Security Officer include assessing and assuring that adequate security programs are in effect to address  the security of Roche employees (on Site and outside the Roche premises), including, among others, travel security, evacuation planning and kidnap plans, etc.  the physical protection of the buildings, plants and properties, including, among others, fences, doors, closing systems, reception desks, security guards and patrols, detection and alarm systems, etc.  the control of contractors and visitors  the protection of intellectual property and proprietary information  the transportation of high value shipments The Company and Site management respectively are accountable for the security concept and the defined protection levels. Operational elements of Site security (e.g. security patrols, guards, etc.) may be outsourced to reliable companies if there is a clear business case (not just head-count). For more details see the Group SHE Directive K19. Safety and security programs often overlap and the two functions must work closely and ef- fectively together. Therefore the safety, security, health and environmental protection func- tions should form a common department (while historical exceptions having security as a separate local function are allowed). The specialist SHE organization, the SHE officer and the SSO may assume certain additional tasks delegated by the General Manager or the Site Manager. Each SHE Officer and SSO must have a deputy. In case the SHE Officer or SSO function is taken over by another person, a smooth hand over of the SHE and security documentation and affairs to the new job holder must be ensured by the line management. 3.8 Line Managers, Supervisors Roche places direct responsibility for initiating, implementing, monitoring and supervising SHE with the line managers of the various areas and departments - within the scope of their decision-making powers. The tasks and duties of line managers / supervisors include:  developing and maintaining knowledge of and ensuring compliance with company poli- cies, guidelines and directives as well as local SHE regulations  implementing SHE programs  defining SHE goals and objectives in support of Group and Site targets  preparing and maintaining area-specific documents for the operation and maintenance of plants, installations, equipment and buildings as well as for production and other work processes; ensuring inclusion of safety, security, health and environmental instructions into work instructions and standard operating procedures (SOP)  assuring that SHE training processes are in place, that employees are attending training, and that training is adequate for employees to conduct their job responsibilities  providing all necessary SHE information to the employees Roche Guidelines for the Assurance of Safety, Security, Health and Environmental Protection, 2014 Page 20 / 48