1.2.

1 Managing improvement
1.2.1.1 HSE leadership, management and resources
The AkzoNobel Safety, Health and Environment (HSE) policy shall apply throughout the
company. Subsidiary companies must establish HSE policies and standards as necessary to
comply with local laws and be consistent with the AkzoNobel HSE policy, directives and
standards.
Business unit managers, functional managers and all line management must demonstrate
leadership in, and commitment to, HSE. They must have in place the appropriate
organization, responsibilities, authority, competent resources, support services and other
arrangements required to implement the AkzoNobel HSE policy, directives and standards.
Employee and other records must be maintained in a retrievable form.

The HSE management system requires site managers to be held accountable for
environmental protection and for the safety, health and security of employees and
contractors at work. Active leadership in HSE is demonstrated by:
Setting clear expectations
Ensuring HSE system elements are considered in all management decisions;
Demonstrating consistent safe behavior (leading by example);
Creating a work culture in which employees and contractors feel comfortable to speak out
and act when encountering unsafe and unsustainable situations.
Personally addressing HSE as the first topic in all meetings with site personnel
Actively stimulating and facilitating a safety conscious work culture, for example by
making resources available as necessary and taking part in safety and sustainability
initiatives.
Site managers must liaise with local authorities on strategic HSE issues on a regular basis;
they must represent the site in community communication.
At least once a year, site managers and their superiors must discuss the site HSE
performance against the set goals, improvements and resources required. These
discussions must be documented and include the development of measurable goals and
objectives.
1.2.1.2 Management of change
Any modifications to facilities and the arrangements for operation, including changes to
personnel, must not compromise HSE performance and where possible improve
performance. Proposals for changes must be documented and assessed, and modifications
must be authorized by competent people. Necessary hazard studies and risk assessments
must be carried out, appropriate design considerations made and all changes properly
implemented and recorded. The HSE implications of changes to organization and service
provision must be assessed.
1.2.1.3 Continuous improvement
Line management must review HSE performance amongst others by carrying out an annual
self-assessment (following the AkzoNobel HSE corporate audit protocol) to define
improvement opportunities and programs. Improvement programs to deliver continuous
improvement of performance towards defined goals at AkzoNobel and business unit level
must be established and monitored. Management reviews must take into account the
outcome from audits and risk assessments, and learning from incidents.
1.2.1.4 HSE performance and reporting
All locations must monitor, record and report HSE performance in line with the procedures in
the AkzoNobel HSE manual:
Level of compliance with HSE directives and standards
Performance against AkzoNobel, business unit and local KPIs
Incidents and complaints must be investigated, root cause(s) identified, recorded and
action taken to prevent recurrence. Learnings must be shared within AkzoNobel.
1.2.1.5 Auditing and assurance
Formal internal auditing and assurance procedures, including specified accountabilities and
HSE competency requirements, must be defined and implemented to ensure that the
systems and behaviors adopted to meet AkzoNobel requirements are soundly established,
maintained and observed. These will include corporate HSE management audits and annual
self-assessments (following the AkzoNobel corporate HSE audit protocol), specialist audits,
and local audits. The self-assessment must be used to provide input to the non-financial letter of
representation (NFLOR). Deficiencies identified and opportunities for improvement
must be recorded and actions implemented.
1.2.1.6 Training, involvement and personal responsibility
The HSE behavior expected must be defined. HSE competency and expertise requirements
must be defined for line managers and all employees, HSE specialists and specified
competent roles defined by legislation and AkzoNobel directives and standards. These
requirements must be considered in the recruitment, selection and placement of all
permanent and temporary personnel. Competencies must be documented by all sites and
reflected in work- and third party contracts. The accountabilities of all employees for HSE
performance must be established and linked to the appraisal system.
All sites must have an HSE training program. This training program must always be related
to site specific required competencies, in line with operational risks and HSE goals.
Training needs must be identified, implemented, validated and recorded to ensure that all
employees and contractors have the necessary skills and awareness to behave with proper
regard for risks, safety and the protection of the health of themselves and others, the
environment and security. Training and refresher training, mentoring and validation
arrangements must be regularly reviewed. There must be regular consultation,
communication and dialogue with employees on HSE matters. Employees must be
encouraged to participate in improvement programs.
1.2.1.7 Acquisitions and divestments
An HSE assessment, including soil and groundwater conditions, must form part of any
proposal for acquisition or divestment. Potential liabilities due to proposed acquisitions must
be assessed. Post-acquisition, corporate HSE audits must be carried out within one year
after the acquisition takes place in order to review if the unit is operating in line with the
AkzoNobel HSE policy, directives and standards.
1.2.2 Health and safety of employees and contractors
1.2.2.1 Employees and supervised contractors
Risks to employees and supervised contractors from all hazards and security threats must
be assessed and reduced to acceptable levels by applying the hierarchy of controls:
elimination, substitution, engineering controls, procedural controls including signage, and
finally personal protective equipment. Appropriate risk control, training, communication and
monitoring programs must be put in place. Assessment should consider chemical, biological
and physical hazards.
Systems of work must be implemented and maintained to ensure the safety, health and
security of employees and supervised contractors, both in the workplace, and while traveling
on company business.
Employees contracted to work at non-AkzoNobel locations must take part in equivalent risk
assessment and control processes, and receive training on specific hazards and emergency
plans. They are empowered to stop work if they are concerned for the security, safety or
health of themselves, others or AkzoNobel assets.
A health assessment program must be established and maintained, covering preemployment
and routine assessment programs as well as return from extended sickness
absence and ill-health retirement assessments. Health promotion programs must be
implemented.

1.2.2.2 Independent contractors

The HSE implications of all aspects of work carried out by independent contractors on behalf
of AkzoNobel must be considered. Competent contractors must be selected, and their
performance monitored.
Independent contractors must be required to provide sufficient information about working
practices, materials and equipment and to operate in a manner, which does not compromise
the safety and health of their employees and other people, or AkzoNobel security and
environmental standards. Contractors must be supplied with sufficient information to ensure
that the safety and health of their employees is not placed at risk by AkzoNobel activities.
1.2.3 Security of people and assets
1.2.3.1 People
Risks to employees from security threats must be assessed, reduced, controlled and
monitored: in the workplace, while traveling on company business, and for expatriates.
Systems must be established to ensure that all contractors are aware of the need for security
and practice it. They will be required to provide sufficient information and to operate in a
manner which ensures that AkzoNobel security standards are not compromised.
1.2.3.2 Assets and information
All locations must be maintained and equipped to ensure the appropriate security of assets
and information (IT and intellectual property). Facilities and systems must be reviewed
periodically to take account of the current and perceived future security threats and
associated risks, using the AkzoNobel site security assessment tool. Product security must
be reviewed and maintained from raw material supply to product delivery.
1.2.4 Product stewardship
1.2.4.1 Product design and development
The HSE implications of new and modified products must be taken into account during
development and approval. Hazards and potential HSE impacts must be assessed
throughout the product life cycle and the consequent risks reduced to acceptable levels. The
assessment must include the requirement for full compliance with local regulation; the
potential for additional exposure to product liability and significant local and global
environmental issues.
1.2.4.2 Product management, distribution, use and disposal
All product HSE aspects, including distribution, storage, sale, use, reasonably foreseeable
misuse and disposal, must be managed in an ethical and responsible manner. Business
units must have organizational arrangements in place to ensure stewardship activities are
carried out in an integrated way across all business activities. Risk management programs,
including product liability must be implemented, and reviewed following internal or external
(e.g. regulation, public opinion) changes. Relevant HSE information must be provided to all
those who handle or use AkzoNobel products, recorded and updated as required, and a
dialogue encouraged.
1.2.4.3 Suppliers and other purchased services
HSE requirements for the purchase and supply of raw materials, products, toll conversion,
equipment and services must be specified and monitored to ensure that they are met.
Relevant information must be sought from suppliers concerning the effects of their products
and activities on the safety and health of people and the environment, and other social and
economic factors. Potential risks to AkzoNobel, including exposure to product liability and
reputation damage, must be managed.

As a minimum requirement, supplier support visits must be planned and executed for those
suppliers that have been defined as critical for the business for AkzoNobel and for which
inadequate relevant information is available to make an appropriate judgment about the
sustainability risks associated with their operations and products. These visits will be initiated
by the responsible purchasing/sourcing manager and executed together with qualified HSE
personnel. If unacceptable sustainability risks for AkzoNobel are identified, improvement
actions will be defined and agreed together with the supplier. Re-visits will be planned and
executed to follow up on improvement programs of the suppliers. The business relation may
be terminated in case inadequate/unsatisfactory follow-up occurs or if extreme cases of
potential sustainability risks are identified.
1.2.4.4 Material hazards
A complete and current inventory must be available of all materials used, transported,
produced or sold, including isolated intermediates and wastes. Their hazards must be
identified and assessed. Appropriate information must be maintained to enable the safe
handling, storage, transportation, use and disposal of all materials.
1.2.4.5 Resource and utility management
Natural resources and utilities must be conserved by efficient use, by minimizing their
consumption throughout the product life cycle and by reducing waste. Re-use and recycling
of materials must be promoted, having regard for safety, health, environmental, social and
economic factors.
1.2.5 Emergency response and community awareness
1.2.5.1 Emergency response and crisis management
The nature and scale of all reasonably foreseeable on-site and off-site emergencies
(including distribution) must be identified. Adequate formal arrangements, accountabilities
and training must be established to deal with these emergencies, appropriate to the hazards
and risks involved. The arrangements must include local, business unit and regional crisis
management plans with escalation to the AkzoNobel crisis management process, which
must be communicated, regularly rehearsed and reviewed. They must be made in
association with the public emergency services, other relevant organizations and appropriate
voluntary co-operative schemes.
1.2.5.2 External communication and consultation
Relevant safety, health and environmental information must be provided to interested parties.
Feedback and dialogue must be encouraged and external views must be considered during
the development of HSE improvement plans. Sites must operate community liaison
programs, consistent with local needs, The programs should include employee involvement
and be monitored for effectiveness.
1.2.6 Process safety
Process safety is a disciplined framework for managing the integrity of hazardous operating
systems by applying good design principles, engineering and operating practices. It deals
with the prevention and control of incidents that have the potential to release hazardous
materials or energy.
Process safety management must address the following topics:
Process safety information (substances, technology and equipment)
Hazard identification and operational risk evaluation
Operating procedures/maintenance procedures
Training and competence
Management of Change
Asset integrity, including management of safety critical elements

Safe Work practices

Contractor management
Incident investigation
Emergency response
Workforce involvement
Community awareness.
The requirements with regards to all of the above mentioned topics are described in the
Standards and Guidance Notes in this Manual. The Global Process Safety Management
Framework described in Guidance Note 34; explains how the process safety management
building blocks are linked together. Process safety management must be in compliance with
local legislation.
1.2.7 Site environmental protection & pollution prevention
1.2.7.1 Site environmental impact
The handling and disposal of wastes and emissions must be properly managed so there are
no unacceptable environmental impacts, local consents/permits are met and waste disposal
is responsible and legal. Significant waste and emission streams should be fully
characterized, quantified, controlled and monitored. Records must be maintained of all
wastes generated and their disposal. Opportunities for waste minimization must be identified
and implemented.
Each location must prepare and maintain a risk assessment (Environmental Impact
Assessment) of those activities that have potential for significant environmental impact and
implement improvement plans to remove or manage those risks. This assessment must
include audit trails for all claims and take into account, but not be limited to: hazards, risks
and impacts due to solid, liquid and gaseous wastes, including disposal measures;
unplanned releases or losses of any materials or energy and any issue which may cause
concern to the public (e.g. noise, traffic). Systems of work and monitoring programs must be
implemented to demonstrate effective protection of the environment. All locations that have
significant natural habitats within, or near to, their boundaries must have arrangements for
the protection and conservation of the flora and fauna.
1.2.7.2 Soil and groundwater protection
There must be arrangements to prevent contamination of land and groundwater arising from
site activities. Each location must identify, assess and at regular intervals review possible
hazards and risks, to human health or the environment, arising from land or groundwater
contamination, and the need for protective or remediation measures. Each location must
maintain records of the history and contamination of the site, a register of all leaks and spills
which may have potential for land or groundwater contamination, and a record of any
protective or remediation measures undertaken.