Introduction
Transition Industries (the “Company”), including its subsidiary Pacifico Mexinol (“Mexinol”), understands the ethical and sustainability responsibilities required of business to protect the ecosystems in which we operate. As such, the Company is committed to conducting our business in a manner that is protective of the environment, the health and safety of our employees, our partners, our community and wider society. Furthermore, the security of the Company’s people, facilities, assets, and information is imperative to the ongoing success of our operations and aligns with our commitment to uphold Human Rights.
With operations in different geographical locations, robust policies and procedures are critical to the Company’s approach to risk mitigation and management. The Company promotes the highest standards in health, safety, security, environmental and social performance (HSSE&SP) by establishing, implementing and maintaining a company HSSE&SP management system (referred to as the Good Neighbor Framework) that includes: HSSE&SP standards, practices and work processes; an HSSE&SP training program; and HSSE&SP performance measurement and improvement goals.
The Company recognizes the value of engaging with civil society and host and home governments to contribute to the welfare of the local community while mitigating any potential for conflict where possible. As such, the Company understands that robust stakeholder engagement often serves as the foundation for effective implementation of good HSSE&SP management and we are committed to engaging with relevant stakeholders as part of our Stakeholder Engagement Program.
The long-term business success of the Company, including our social license to operate, depends on our ability to continually train on the implementation of the HSSE&SP management systems.
Good Neighbor Framework
The Good Neighbor Framework establishes common expectations used by the Company for addressing risks. It is guided by the concepts of integrity and transparency, and is used to systematically manage workforce safety and health, process safety, reliability and integrity, environment, efficiency, security, and stakeholders in order to meet the following core objectives:
- Leading, managing and driving HSSE&SP performance so that it is a part of Company culture and is embedded across all teams and disciplines
- Using a risk-based systematic approach to identify, assess, prioritize and manage risk to prevent occupational health and safety (fatalities, serious injuries and illnesses), environmental and socioeconomic impacts
- Designing, constructing and preparing for start-up by eliminating high-consequence process safety incidents, environmental and socioeconomic risk and operating with industry-leading reliability
- Selecting, training, engaging and enabling people, including within the Company and with all third parties
- Leading the industry on energy and resources efficiency
- Proactively engaging with stakeholders and communities and conducting issues management to address business risks
- Managing changes and learning from experience
Figure 1 presents a high-level description of the Good Neighbor Framework and its essential elements. Implementation of the Good Neighbor Framework will be consistent with the risks associated with Project activities being planned and performed.
Figure 1: Good Neighbor Framework elements
The HSSE&SP system incorporates the “Plan, Do, Check and Act” elements to drive continuous improvement in our HSSE&SP performance. Such performance follows the principles of ISO 14001: Environmental Management Systems (2015), and ISO 45001: Occupational Health and Safety Management Systems (2018) and other relevant international environmental management system standards
Figure 2: Plan-do-check-act continuous improvement principles (IFC, 2014)
Purpose
The purpose of this policy is to outline, inform and uphold our commitment to:
- Transitioning the world to a net-zero carbon future;
- Respecting nature and our neighbors;
- Training and holding every employee accountable to work safely and in an environmentally and socially responsible manner;
- Complying with all applicable national, state and local HSSE&SP regulations, and with our company’s HSSE&SP management systems;
- Eliminate HSSE&SP incidents and injuries with the conviction that all are preventable and stive for continuous improvement;
- Requiring contractors to implement HSSE&SP policies and management systems consistent with the Company’s policies, management plans, and values;
- Working constructively and creatively with neighbors, local community organizations, local governments, shareholders, and partners, to effectively identify, minimize, and mitigate adverse environmental, social, security and safety impacts related to our operations and product use;
- Implementing actions in all phases of a Project lifecycle aimed at improving sustainability performance;
- Promoting pollution prevention, including the conservation of energy, water, and raw materials resources, and ensuring that all waste is handled and disposed of responsibly;
- Protecting and conserving biodiversity, ecosystems, and ecosystem services;
- Supporting the communities in which we operate through employment and supplier opportunities including development and training, strategic community investment initiatives, and robust stakeholder engagement;
- Ensuring all security activities are undertaken in a manner that complies the Voluntary Principles on Security and Human Rights (VPHSR);
- Conducting Security Risk Assessments to understand threats and risks;
- Conducting business responsibly and having zero tolerance for abuses of human rights in our workplace, in our communities, or across our supply chain;
- Ensuring all workforce and community grievance procedures are made publicly available;
- Monitoring and evaluation of all HSSE&SP plans and processes; and
- Conducting business practices in accordance with the local laws, international standards, and the Company Codes of Business and Ethical Conduct.
Legal Frameworks
The policy is aligned with the following legislature and frameworks:
- National and Local Level Legislation in the area of operations
- IFC Performance Standard 1, Assessment and Management of E&S Risks and Impacts
- ISO 14001: Environmental Management Systems (2015)
- ISO 45001: Occupational Health and Safety Management Systems (2018)
- ILO. International Labour Standards on Occupational Safety and Health
- Voluntary Principles on Security and Human Rights (VPSHR) (http://www.voluntaryprinciples.org/)
Scope
This policy applies to personnel, including employees as well as temporary or contingent workers. We expect our suppliers, contractors, and business partners to adhere to this policy. It shall be signed by managers, employees, contractors and subcontractors, reflecting acknowledgement and commitment with the implementation.
Your responsibility
Employees and contractors must follow all applicable provisions and the spirit and intent of this corporate governance document and support others in doing so. Employees and contractors must promptly report any suspected or actual violation of this corporate governance document through available channels so that the Company can investigate and address it appropriately. Employees and Contractors who violate this corporate governance document or knowingly permit others under their supervision to violate it, may be subject to appropriate corrective action, up to and including termination of employment or contract, as applicable, in accordance with the Company’s corporate governance documents, employment practices, contracts, collective bargaining agreements and processes.
Interpretation and administration
The Company has sole discretion to interpret, administer and apply this corporate governance document and to change it at any time to address new or changed legal requirements or business circumstances.
Non-retaliation
The Company supports and encourages employees and contractors to report suspected violations of corporate governance documents, applicable laws, regulations, and authorizations, as well as hazards, potential hazards, incidents involving health, safety, security or the environment. Such reports can be made through available channels. The Company takes every report seriously and investigates it to identify facts and, when warranted, makes improvements to our corporate governance documents and practices. All employees and contractors making reports in good faith will be protected from retaliation. Good Faith Reporting will not protect employees and contractors who make intentionally false or malicious reports, or who seek to exempt their own negligence or willful misconduct by the act of making a report.
Policy Approval
This policy was reviewed and approved by the following Company leadership.