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abdul latif jameel company ltd support services division environment safety security risk environment policy domestic automobile operations dao eco toyota essr revision date january 2011 version no 2 page 1
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executive summary of alj dao environmental policy this policy aims at incorporating environmental protection responsibilities with other alj essr health and safety policies and procedures as well as meeting tmc s environmental requirements the scope of this policy covers the entire alj dao facilities service centers and dealers alj senior management associates shall implement and enforce the environmental policy at all alj facilities service centers and dealers essr shall provide recommendations solutions and best management practices to all alj facilities service centers and dealers based on periodical field risk assessments inspections and audits all alj associates have responsibilities to implement the recommendations and achieve environmental objectives and targets defined by essr essr shall not be held responsible of any negative consequences occur if a respective alj facility fails or rejects to implement such recommendations objectives and targets already provided in summary respective alj business units shall fully coordinate with essr to generate environmental management programs action plans to achieve the following objectives 1 cooperating with essr associates during the assessments and inspections of environmental health and safety risks existing in alj facilities service centers and dealers 2 obtaining essr environmental recommendations and requirements before during and after any construction project 3 giving priority to purchase tools equipments and items friendly to the environment green purchasing 4 complying with local and international legal requirements and best practices 5 implementing tmc environmental promotion guidelines for service centers and dealers 6 assigning window personnel health safety and environmental promotion staff within each facility or center to monitor environmental safety aspects and implement environmental action plans 7 cooperating with essr associates to implement of iso 14001 environmental management systems 8 disposing hazardous and non-hazardous wastes through authorized and competent waste management companies 9 improving facilities logistical and distribution system to reduce co2 emissions in line with tmc s environmental guidelines 10 reducing the consumption of water and energy 11 allocating segregated and adequately-ventilated storage areas for air bags and seat pretensioners at each relevant facility 12 segregating hazardous and non-hazardous wastes whether solid liquid or gas into designated labeled areas/containers 13 phasing out substances of concern cadmium lead mercury and hexavalent chromium and replace them with cleaner alternatives 14 recovering hfc/cfc and phasing out r-22 freon and replace it with r-131a or cleaner freon alternatives 15 constructing bunded walls to contain oil/chemical spills 16 purchasing spill kits absorbents and its associated equipments such as safety shoes gloves portable cabins and container to segregate used absorbents 17 arranging environmental awareness training and education at both organizational and community levels dr hany idreis general manager environmental safety affairs essr revision date january 2011 version no 2 page 2
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essr revision date january 2011 version no 2 page 3
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abdul latif jameel company ltd support services division organization and responsibilities the scope of this policy is all business activities facilities and centers that come under the umbrella of abdul latif jameel company s domestic automobile operations alj dao the organizational arrangements and responsibilities to maintain this policy cannot be separated from the ones arranged for health and safety occupational and environmental safety and health arrangements shall be incorporated together in order to avoid redundancy and conflict of interests within alj facilities at any time the notion of work and grieve should be discouraged and rejected in alj when irreversible environmental or occupational health and safety issues are observed in instead necessary support should be given for constructive communication and escalation of matters to top management if the issues cannot be resolved or are unreasonably delayed in accordance with toyota motor corporation s tmc earth charter and environmental guidelines all toyota distributors are required to establish environmental management system ems iso 14001 program within their facilities separate guidelines have been issued to toyota dealers to promoting environmental performance within service centers and dealers kingdom-wise the vice chairman is responsible for environmental safety and health across abdul latif jameel company limited each director and senior manager will be specifically responsible to him for environmental health safety within their respective operating business units each will ensure that the environmental targets and objectives mentioned in the policy are brought to the attention of all associates by distribution and are displayed on all company communication tools notice boards intranet etc additionally all directors and senior managers will ensure that it is fully implemented in their respective operating business units the head of the environment safety security risk department essr reports directly to the managing director of the shared services organization who in turn reports directly to the vice chairman the head of essr is responsible for providing an advisory service on all aspects of health safety throughout the company detail of specific responsibilities of management all associates contractors and visitors are set out below environmental health and safety arrangements the president requires the company to implement such arrangements as are appropriate having regard for the nature of the activities and size of undertaking for effective planning organization control monitoring and review of the preventive and protective measures this company s environmental policy outlines the policies objectives and targets applicable to all business units within abdul latif jameel company limited alj they will be added to as and when new work practices or assessments of environmental risk identify the need or when there are new projects and changes to the local legislation presidency of meteorology and environment and best international industry practice e.g european union commission s environmental standards and directives essr revision date january 2011 version no 2 page 4
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abdul latif jameel company ltd support services division as in the case of health and safety the management of essr will assume and assist to ensure that the basis of successful environmental management system is depending upon accurate and sufficient risk assessment at each location and within each work group these risk assessments will be under the responsibility of the senior manager for that location of work in conjunction with regular workplace inspections undertaken by essr supervisors and safety representatives these risk assessments will identify environmental hazards within the workplace any environmental hazard identified by any means will be reported to and be dealt with by the essr department and senior management team at the location all solid liquid gaseous hazardous and non-hazardous wastes generated by each facility shall be identified and regarded as environmental hazards as well which must be treated through legal and environment-friendly channels it is recognized that the environmental policy of the company may require revising from time to time necessary arrangements have been made to monitor the effectiveness of this policy by regular inspections in order that the appropriate action is taken where necessary by local management policy monitoring and review the operation of this policy will be reviewed at annual intervals clause 4.6 of iso 14001 standard mandates certifying facilities to conduct management review meetings on specified intervals to discuss the following aspects 1 results of internal audits and evaluations of compliance with legal requirements and tmc guidelines 2 communications from external interested parties including complaints 3 the environmental performance of alj 4 the extent to which alj environmental objectives and targets are achieved 5 status of corrective and preventive actions action plans 6 follow-up actions from pervious management reviews 7 changing circumstances including developments in legal or tmc requirements related to alj s environmental aspects 8 recommendations of future improvements dealers guidelines issued by tmc may require continuous revision and amendments to suit the current saudi working environment and infrastructure the person responsible for this review and updating of the environmental policy responsibilities guidelines and arrangements is the general manager environmental safety affairs empowered by the head of essr department clause 4.5.5 of iso 14001 mandates alj to conduct internal auditing for its certifying facilities at planned intervals to ensure the conformity and implementation of the environmental action plans objectives and targets and arrangements and legal tmc requirements and to provide necessary feedback and information to essr management general implementation of policy alj senior and operational management associates must communicate and enforce this policy in their relevant departments/facilities essr shall offer complete gap analysis through risk assessments inspections and interviews with workers in order to establish essr revision date january 2011 version no 2 page 5
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abdul latif jameel company ltd support services division baseline for full-fledged environmental management systems iso 14001 within each facility gap analysis gives the opportunity to establish environmental management programs action plans as per specific needs and requirements of each facility specific roles and responsibilities for shop floor associates can be determined clearly after risk assessments prior initiating any new project company directors top management and all other decision-makers shall put into their consideration the best environmental options available through in the market in order to achieve best cost-saving opportunities and reducing the excessive consumption of in energy water electricity paper and other natural resources environment-friendly technologies shall be utilized so far as reasonably practicable to achieve the targets and objectives of this policy coordination with essr management is recommended in order to consult specialized external parties on such issues environmental requirements shall be identified and examined prior initiating any company project also environmental impact assessment eia is legal requirement prescribed by the presidency of meteorology and environment pme to be conducted on specific projects eia shall be conducted by pme-authorized environmental consultancy offices and agencies the suppliers/service providing agencies responsible for performing the project for alj shall be challenged in their contracts to fulfill any requirement or recommendation made by eia final report alj shall ensure safe delivery and storage of fuel environmental standards shall be implemented with regards to underground and above-the-ground oil/fuel tanks spill contingency plan and procedures have been developed to address this aspect spill contingency kits shall be available in all service facilities in well-defined locations facility management shall coordinate with essr management to ensure adequate training for all associates to use spill contingency absorbents pollution prevention is an essential part of tmc environmental guidelines alj operational and senior management shall ensure to · prevent emissions to the environment and where that is not practicable then · minimize or reduce them to acceptable levels and · render harmless any emissions to the environment alj directors facility managers and top management shall enforce that all alj workplaces under their responsibility always clean and tidy the management of waste generation handling transporting and disposal shall occur professionally on each site the policy places a responsibility to ensure that waste 1 is not managed illegally 2 does not escape from control 3 is transferred only to an authorized company/agency and 4 is adequately described and documented type and content of waste and the amount generated the management of all types of wastes hazardous non-hazardous solid liquid or gaseous is an integral component of this policy senior operational management staff must consider the following hierarchy of waste management · · · reduce an emphasis on not producing waste in the first place or minimizing the quantities produced re-use for same purpose rather than dispose of recover/re-cycle materials and energy essr revision date january 2011 version no 2 page 6
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abdul latif jameel company ltd support services division · disposal through handling them to waste management companies as a final measure the disposal of any type of waste must be through pme-authorized companies if pme-authorized companies are not found then other companies shall be considered that are accredited and licensed by the relevant saudi government authorities e.g municipality effective liaison will be maintained through essr with external governmental e.g pme and non-governmental bodies environmental information training and instructions will be disseminated and promoted as appropriate in order to achieve high standards of personal awareness of environmental risks hazards and personal responsibilities facilities for joint consultation on matters of health safety and environment and welfare will be available through safety representatives and safety committees advice consultancy and external contacts an up to date contact list for key outside organizations should be maintained by the senior manager responsible at each location the required information is set out below a b c d e f g h i j k essr administration presidency of meteorology and environment local authorities e.g municipality tmc environmental affairs division local and international environmental agencies and groups other worldwide toyota distributors civil defense site essr health safety and environment hse coordinators associate-management joint hse committees local water sewage companies contact lists of companies close to facility mutual aid specific responsibilities departmental directors senior general managers to implement company policy by considering the best environmental programs and technologies available in their facilities and projects to be aware of saudi environmental legislations issued by pme especially with regards to waste management to be aware of and implement the tmc s dealer s environmental guideline for service centers to encourage good environmental practices essr revision date january 2011 version no 2 page 7
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abdul latif jameel company ltd support services division to establish a guideline for green purchasing at their relevant facilities through the following o buying environment-friendly tools equipments including office supplies and technologies green purchasing to purchase items from companies that have well-known contributions and action plans for environmental protection or at least those who have iso 14001 certification o to make resources human financial available to meet the requirement of the policy to assist general manager environmental safety affairs in acquiring iso 14001 certification for their respective facilities to assist general manager environmental safety affairs in achieving environmental objectives and targets and implementing actions plans to put necessary action plans in line with tmc environmental requirements to o reduce co2 emissions through assisting relevant facilities to improve logistical distribution systems phase out substances of concern cadmium lead mercury and hexavalent chromium from their respective operations and replace them with cleaner alternatives have proper hfc/cfc recovery and to phase out r-22 freon replace it with r-131a or cleaner freon alternatives o o to set targets to reduce tahseen water energy and natural resources e.g paper consumption at relevant facilities to make recommendations to the board for improving the environmental performance to support arrange environmental training to set a personal example head of environment safety security risk essr to ensure environmental safety is always incorporated with the general requirements of health and safety within alj facilities e.g functions of facility safety committees should include environmental safety responsibilities to support general manager environmental safety affairs in achieving specific targets and objectives through liaising with and advising the directors and top management essr revision date january 2011 version no 2 page 8
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abdul latif jameel company ltd support services division to assist management as necessary in the reporting and investigation of accidents incidents and dangerous occurrences and to monitor action taken to prevent a recurrence environmental safety affairs general manager to perform gap analysis hse risk assessments and environmental inspections for alj facilities in order to establish environmental management systems iso 14001 to periodically review the environmental policy procedures making recommendations to the head of essr and relevant facilities and business units for revisions to meet changes in legislation or company circumstances to assist departmental directors senior general managers operational managers in implementing dealers environmental guideline at service centers and to assist in making action plans to reduce co2 emissions and phasing out substances of concern r-22 freon to establish annual environmental action plans to meet the objectives and targets of the policy at facility level to be involved with the provision of environmental training to promote good working relations and to achieve compliance with current company codes of practice to represent the company at all environmental health and safety organization meetings to prepare the annual environmental budget to liaise with external environmental authorities pme and other environmental groups consultants universities etc to set a personal example to participate in establishing annual health safety environmental performance report to alj shareholders and tmc management to understand the company environmental policy and organize their associates to fully comply with the codes of practice or procedures to ensure that adequate supervision is available at all workplaces to ensure full implementation of spill contingency plan essr revision date january 2011 version no 2 page 9
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abdul latif jameel company ltd support services division to segregate and arrange adequate ventilation systems to store air bags and seat pretensioners at each relevant facility to implement the green purchasing guideline as established by the departmental directors and senior general managers of their facilities to ensure that all types of wastes solid liquid and gas are segregated in separate containers and handled by competent pme or government-authorized companies to ensure that all sub-contractors adopt safe and healthy systems of work to ensure that workplace is always clean and tidy to accompany any visiting external environmental auditor or essr personnel during regular inspections to promote good working relations and to achieve compliance with current company codes of practice and legislation to co-operate with essr in releasing associates for appropriate environmental health safety training to ensure all environmental safety accidents incidents near misses and dangerous occurrences are recorded reported and investigated and appropriate remedial measures are taken promptly to prevent a recurrence to set a personal example at the facility level operational management supervisors to understand the environmental policy and to co-operate with its implementation at all times to coordinate with relevant alj departments to construct bunded walls dykes to prevent oil/chemical spills from above-the-ground oil/diesel tanks after consulting with general manager environmental safety affairs to ensure that work operations are only carried out by trained and competent operatives to allocate special cabinets in each facility containing spill absorbents gloves safety shoes and visual spill control procedures to ensure the use of spill absorbent kits to control any spillage of oils or chemicals provided by the company in all circumstances where risk of spillage is likely to facilitate the visits paid by environmental companies and specialists to audit and collect samples to measure air emissions and water effluent discharges to be familiar with and to observe all regulations applicable to the work being undertaken essr revision date january 2011 version no 2 page 10
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abdul latif jameel company ltd support services division to ensure environmental training e.g spill contingency plan is taken place to undertake their work processes procedures in environmentally-safe manner to accompany any visiting external environmental auditor or essr general manager environmental safety affairs during regular inspections to implement targets to reduce tahseen water energy and natural resources consumption as set by departmental directors and senior general managers of the relevant facilities to wear appropriate personal protective clothing and use appropriate safety equipment at all times to keep tools and equipment in good condition to keep the workplace always clean tidy to report all accidents and incidents whether persons are injured or not and damage to their supervisors or manager as soon as possible to report all hazards to the senior manager including any defects in plant and equipment as soon as possible associates duties it is the duty of all associates to act responsibly in relation to all matters which may affect the environment safety and health of themselves and other persons whilst on company premises and to abide by the company s safety regulations at all times observe all safety procedures and instructions given by management and assist in maintaining a safe workplace wear appropriate protective equipment and use safety devices provided by the company where appropriate report to management any accidents spills hazards defects or damages to plant or equipment report any injuries sustained during working hours report conditions equipment or practices thought to be unsafe to a supervisor as soon as possible contractors visitors · alj operational managers responsibilities toward contractors essr revision date january 2011 version no 2 page 11
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abdul latif jameel company ltd support services division ensure full coordination and consultancy with essr to determine any special safety environmental or health requirements elaborate environmental policy to all contractors incorporating environmental requirements within the contracts regarding waste segregation storage and disposal providing clear instructions information and training to undertake projects or daily duties in healthful and environmentally safe manner ensuring adequate supervision by competent persons from alj management to implement environmental requirements and procedures · contractor/subcontractor responsibilities abiding by the environmental safety and health requirements mentioned in their contracts or requested by relevant alj business units implementing company standard operating procedures or contractor s own procedures when found acceptable disposing wastes shall in accordance through government-approved agencies and procedures as per pme s or other authorities guidelines segregating all types of wastes solid liquid hazardous and non-hazardous in separate containers/areas the containers/areas must be labeled and all workers involved in that area shall be informed as well pre-planning work effectively to identify potential environmental aspects or safety hazards and take appropriate steps to control/mitigate/eliminate these hazards allocating proper resources necessary to execute all safety-related tasks discussing work methods adequately with all concerned company representatives including essr to identify potential hazards and risks to the health and safety of the contractor employees or to company associates due to the work being undertaken informing the company of all environmental aspects or safety deficiencies that will result from their work coordinating with essr at the start during and on completion of the work unless otherwise agreed working on premises only when the relevant safety rules are understood and accepted providing suitably skilled supervision to ensure the work is carried out correctly and in compliance with company rules and the above mentioned legal requirements contractors should adhere to all relevant alj requirements applying to the work they are carrying out and in particular the contractors safe working policy essr revision date january 2011 version no 2 page 12
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abdul latif jameel company ltd support services division organizational chart the attached organizational chart indicates the basic environmental safety and health organizational structure of abdul latif jameel company limited example at center level dr saad attiah al ghamdi senior vice chairman faisal abdalla vice president dao george shaw managing director shared services business units managing directors note essr cooperates directly with internal audit to conduct annual internal audits against iso 14001 standards for facilities predetermined by essr center facility general senior manager environment safety security risk dept financial controller service manager parts manager body shop manager sales manager supervisors representatives of environment safety security associates essr revision date january 2011 version no 2 page 13
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abdul latif jameel company ltd support services division arrangements and procedures the following arrangements and procedures shall be put in place to ensure the safe and healthy environment for all associates and others whilst at work and as affected by working activities gap analysis risk assessments gap analysis is to be conducted to determine actual status of a facility baseline gap analysis could be conducted by series of risk assessments inspections interviews and audits a final report could be generated and released to the relevant facility along with action plans for kaizen all premises and activities subject to risk assessments must be addressed in accordance with the relevant legislation using company documentation provided such assessments will be repeated whenever any of the following factors occur but not limited to 1 change in legislation 2 new tmc environmental requirements 3 change in control measures 4 significant change in the work carried out 5 transfer to new technology 6 original assessment is no longer valid assessments will be recorded and records maintained by the essr administration the results of such assessments will be communicated to and be available for inspection by all associates all assessments will identify necessary protective and preventive measures the company shall make and give effect to any appropriate arrangements for the effective planning implementation monitoring and review of any preventive or protective measures identified as a result of risk assessments specific operational policies and procedures implementing environmental management system iso 14001 is a tmc requirement iso 14001 standard requires each facility to establish the following procedures note iso-certified alj facilities have already established them in accordance with their operational activities 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 spill contingency policy and procedure sludge removal policy and procedure environmental aspect risk significant aspect determination procedure legal requirement procedure monitoring measurement and records procedure non-conformance procedure internal audit procedure environmental emergency procedure environmental training and awareness procedure environmental communication procedure waste management procedure environmental management review meeting procedure work instructions for objectives targets compliance evaluation procedure control of records procedure document control procedure essr revision date january 2011 version no 2 page 14
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abdul latif jameel company ltd support services division 17 facility overview and environmental management system summary document 18 pdc maintenance procedures 19 toyota motor corporation guidelines for dealer s environmental promotion in addition specific roles and responsibilities were given to the following departments/personnel depending on the scope of iso certification for instance when alj parts distribution center at jeddah was to acquire iso 14001 the following staff/departments received specific environmental responsibilities 1 warehouse management 2 warehouse maintenance safety coordination team 3 essr maintenance team 4 oil warehouse management 5 internal audit team 6 administration management 7 projects department 8 security and safety teams and 9 contractors and subcontractors reporting and investigating of accidents incidents and dangerous occurrences all environmental incidents accidents and dangerous occurrences no matter how minor will be reported on the company accident report form with copies being sent to the essr administration examples of such reportable environmental situations includes but not limited to spills leakages emission of harmful gases drainage of harmful liquids noise all accidents dangerous occurrences and near misses will be reported immediately to the manager responsible for the site as soon as possible after the event when an associate from another company is involved in an accident on the company premises a copy of the accident report will be sent to their company essr shall allocate one designated accident report form for all environmental safety and health issues each facility management is responsible to report and send a copy on monthly basis even of there is no accident training to comply with a general duty to provide such information instruction training and supervision as is necessary to ensure so far as is reasonably practicable the health safety and welfare of staff health and safety training will be provided whenever there is a plan to implement iso 14001 system in a facility need for refresh training at facilities need to introduce new technology change in the systems of work spill contingency plan new tmc environmental requirement new employees and contractors essr revision date january 2011 version no 2 page 15
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