Policy

Introduction

Policy

The personal safety and health of each employee of this company is of primary importance. Rango Construction recognizes the paramount importance of ensuring a healthy, safe and accident free workplace for all our employees and visitors, and to comply with Occupational Safety and Health Administration (OSHA) regulations, Association of Building and Civil Engineering Contractors of Ghana (ABCECG) regulations, the Labour Law and Trade Union regulations as well as local safety requirements of where the business operates.

The prevention of occupationally induced injuries and illnesses is a management priority and will be given precedence in all operational matters. Rango Construction will not knowingly allow unsafe conditions to exist, or permit employees to participate in unsafe activities.

Purpose of Document

To provide methods for the evaluation and maintenance of a safe working environment and to outline procedures for handling injuries and subsequent reporting requirements.

Scope

This Policy/Procedure applies to all employees, visitors’ contractors and projects of the company.

Definitions

Material Safety Data Sheet (MSDS) is a detailed information bulletin prepared by the manufacturer or importer of a chemical that describes the physical and chemical properties, physical and health hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures, and control measures.

Worksite Safety Analysis

A safe work environment must be everyone's goal. Accordingly, all employees are encouraged to evaluate their work methods and areas for potential safety hazards and/or ideas for improving safety in their work environment. Employees with ideas for accident prevention should complete a Safety Suggestion Sheet and review with their project/line manager and forward to the company's Health and Safety Coordinator for follow-up.

The Occupational Safety and Health Administration (OSHA) Job Safety & Health Protection poster will be displayed at designated locations within the firm as a reminder to all employees, guest and contractors of the importance of workplace safety.

Within thirty days after the end of each calendar year, the Safety Coordinator should work in conjunction with each line/project manager to conduct a thorough self-inspection in order to identify any potential safety hazards. The Safety Coordinator, in conjunction with each line/project manager, should complete the Safety Self-Inspection Checklist.

In addition to the checklist, the Safety Coordinator and each project manager should review OSHA's General Industry Standards for additional items or areas that may not be addressed by the checklist.

• Any safety concerns or hazards discovered should be documented using Worksite Safety Action Plan and forwarded to the Safety Coordinator.
• The Safety Coordinator is responsible for overseeing completion of all action plans, and must also review and evaluate the company's safety programs, and complete the annual summary of occupational injuries and illnesses (See 6.0 OSHA Reporting and Record Keeping).
• The Safety Coordinator should arrange individual Project Safety Committee Meetings, at least monthly, that are attended by subcontractor, supervisors, foremen and other designated workers. The meetings should discuss safety issues among workers and supervisors. Any safety concerns or hazards discovered should be documented using Worksite Safety Action Plan

Agenda discussions should include but not limited to the following;

• Safety performance over the past month.
• Review of all accidents and incidents.
• Work planned for the coming month and any special concerns regarding the work.
• Resolution of outstanding Worksite Safety Action Plans.
• Policies and procedures should be updated to reflect changes and corrections that were made throughout the year.

Hazard Prevention and Control

Project managers should be responsible for creating and maintaining safe work procedures necessary to prevent and control hazards that have been identified through the worksite analysis.

Safe Work Procedures
Control procedures are the basic means for preventing accidents. Each manager should tailor their project’s safe work procedures to the job tasks being performed and the worksite environment. Further, these safe work procedures must include the company's worksite safety rules (WORKSITE SAFETY RULES).

NOTE: OSHA standards should be used to develop safe work procedures since they address controls in order of effectiveness and preference. Where no standard exists, creative problem solving by employees and managers should help create effective controls. The basic formula OSHA follows is, in order of preference:
• Eliminating the hazard from the machine, the method, the material or the plant structure.
• Abating the hazard by limiting exposure or controlling it at its source.
• Training personnel to be aware of the hazard and to follow safe work procedures to avoid it.
• Prescribing personal protective equipment for protecting employees against the hazard.
• Protective Equipment.

Employees are required to wear protective clothing and equipment as indicated by their project’s safe work procedures. These procedures should specifically indicate when, where and what types of equipment are to be worn. Evaluation of types of equipment and clothing should include protection against damage to eyesight or hearing, dust or chemical inhalation or ingestion, skin or bodily exposure to caustic or toxic chemicals, falling objects, cuts, burns, electrical shock, etc.

For example, a safe work procedure indicating hard hat protective headgear equipment in a worksite could read as follows: "The entire project worksite is deemed a potential hazard area. This area will be well defined and marked with prominent warning signs. All personnel entering or working in the project worksite during operations will be required to wear ANSI certified hard hat protective headgear to protect against falling debris from above. A sufficient number of hard hat protective headgear devices will be available for all personnel working in these areas and for those who must occasionally enter these areas."
Protective equipment and/or clothing shall be periodically inspected at regular intervals for wear, defects, and cleanliness and replaced as necessary. Contaminated equipment that cannot be decontaminated should be disposed of in a manner that protects employees from exposure to additional hazards.
Helmets for the protection of employees against impact and penetration of falling and flying objects shall meet the specifications contained in the ANSI Z98.1-1969 Standard. Helmets for the head protection of employees exposed to high voltage electrical shock and bums shall meet the specifications contained in the ANSI Z89.2-1971 Standards.

Safety shoes and boots should meet the ANSI Z41-1991 Standard to provide both impact and compression protection. Where necessary, safety shoes should be obtained that provide puncture protection also. In some work situations, metatarsal protection should be provided, and in other special situations electrical conductive or insulating safety shoes would be appropriate.

Fire Prevention

All employees are instructed to be continuously aware of fire prevention even though the Company does not engage in activities that present a high fire danger. Smoking by employees will be restricted to designated break areas only.
All flammable liquids will be stored in a storage cabinet that is specifically designed for these products. Flammable liquids should not be used for cleaning if a nonflammable product can be substituted. A sufficient number of fire extinguishers will be available throughout the facility, and will be clearly marked.
Fire extinguishers, exit paths, exit signs, passageways and other means of emergency exit shall be inspected periodically by the Safety Coordinator to insure that they are working properly and unobstructed.

Safety Violations

Violation of safety rules is a serious offense that puts the employee committing the offense in danger, as well as jeopardizing others and the success of the project. Rango will issue a written notice to the employee for violating safety rules. The gravity of the violation will bear heavily on the disciplinary action that is taken. Termination may result from the first offense if it is severe and places the well-being of others in peril; however, the second warning notice will include an automatic suspension from duties pending possible discharge.

Hazard Communication Program

In compliance with OSHA's Hazard Communication Standard, the Safety Coordinator will work in conjunction with project managers to implement and maintain a Hazard Communication Program for all work operations in The Company where employees may be exposed to hazardous substances under normal working conditions or during an emergency. The Hazard Communication Program should consist of compiling a hazardous chemicals list, using MSDS's, ensuring containers are properly labeled and providing employees with training (see 5.0 WORKSITE SAFETY TRAINING), training section below).

MSDS's will be filed in the corresponding part file in the master inventory parts file. The Safety Coordinator should ensure that an MSDS is available on every substance on the list of hazardous chemicals and should be open to review by employees at all times. The purchasing agent should be responsible for obtaining and updating MSDS's.

The Safety Coordinator should make a List of Hazardous Chemicals (see Index of Hazardous Chemicals & MSDS) with the operational areas they are used and the corresponding MSDS for each chemical. The Safety Coordinator will maintain and update the list as necessary and will post a separate list in each work area. The Safety Coordinator will work with each project manager to incorporate protective measures for hazardous chemicals used in their area into their safe work procedures.

The Safety Coordinator will ensure that all hazardous chemicals in the facility are properly labeled and updated, as necessary. Labels should list at least the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer or responsible party.

If there are a number of stationary containers within a worksite that have similar contents and hazards, signs will be posted on them to convey the hazard information. If chemicals are transferred from a labeled container to a portable container that is intended for immediate use, no labels are required on the portable container.

Medical Emergencies

A comprehensive first aid kit should be kept at the entrance of the production area. The purchasing agent should be responsible for replenishing supplies in the kit. Eyewash stations are located within the immediate vicinity of all operational areas that utilize hazardous or caustic chemical substances.

Emergencies or injuries that require medical care but are not life threatening and can be safely transported by automobile should be treated at the local health care facility. The local emergency rescue service should be called for any serious life-threatening injuries, and for transporting injured employees that cannot be safely transported by automobile.

A listing of all emergency phone numbers and the address of the local health care facility should be posted next to the OSHA safety poster in accordance with Federal Posting Requirements.

Worksite Safety Training

Each person must know and understand their job related activities, duties and responsibilities prior to commencement of work. If any worker is in doubt concerning their safety rules or responsibilities, they should contact their respective first line supervisor for clarification before commencing or continuing any work-related activities.

Safety orientation will be conducted for every new and transferred employee. Orientation will consist of written material, a series of videos and a comprehension quiz.

Safety Orientation Checklist will be utilized to ensure a complete training session. Orientation will be done before employees are sent out on site. Subcontractors will be required to provide safety orientation training for their new and transferred employees and provide the Company with documentation proving this has been completed.

Training should include review of this worksite safety policy and procedures. Further, each person should be informed that no employee is expected to undertake a job until he or she has received job instructions on how to do it properly and has been authorized to perform that job and no employee should undertake a job that appears unsafe.

The training plan should also include the Hazard Communication Program, which will emphasize:

• Summary of the Hazard Communication Standard.
• Chemical and physical properties of hazardous materials (e.g., flash point, reactivity) and methods that can be used to detect the presence or release of chemicals.
• Physical hazards of chemicals (e.g., potential for fire, explosion, etc.). • Health hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical.
• Procedures to protect against hazards (e.g., personal protective equipment required, proper use, and maintenance; work practices or methods to assure proper use and handling of chemicals; and procedures for emergency response).
• Work procedures to follow to assure protection when cleaning hazardous chemical spills and leaks.
• Where MSDS's are located, how to read and interpret the information on both labels and MSDS's, and how employees may obtain additional hazard information.
• The Safety Coordinator should arrange periodic employee safety meetings with the project managers, as necessary, but no less than once a year. These meetings should include review of any additions, changes or corrections to the worksite safety program and procedures and the hazard communication program. Specific topic only items may also be held (e.g. Fire or natural disaster drills, proper use of fire extinguishers, administering first-aid, etc.) and may include use of outside consultants, speakers, audiovisual aids, etc.

Reporting and Record Keeping

Tall injuries, illnesses and non-injury accidents that require medical attention other than first-aid and is the result of a work accident or from an exposure in the work environment must be reported to the project manager and the Safety Coordinator.

Further, any incident including fire, explosion, water damage, spill, collapse and any similar event that results or could result in significant personal injury or damage to the building and equipment will be reported as above.

For every injury or illness entered on the above log, it is necessary to record additional information on the supplementary record, OSHA Form 301 - Injury and Illness Incident Report - within seven (7) days of a reported incident. As an alternate, if a worker's compensation claim is prepared, this form can be used as a substitute for OSHA Form 301.

Every calendar year, OSHA Form 300A - Summary of Work-Related Injuries and Illnesses - should be prepared by the Safety Coordinator and certified by the President, CFO or a Company Officer before being posted next to the OSHA worksite poster no later than February 1, and will remain posted until March 1 of that year.

The Safety Coordinator should be responsible for maintaining a designated area for filing all of the above records, reports and documentation of the company's worksite safety program. All records and documentation unless otherwise required will be retained for a period of not less than five years.

Confidentiality - Information relating to employee health must be used in a manner that protects the confidentiality of employees as much as possible while the information is being used for OSHA purposes in accordance with Federal and State requirements.

Health and Safety Responsibilities of Key Stakeholders

Chief Executive Officer

The Chief Executive Officer is committed to developing and implementing the Environmental Management System. Resources requirements are reviewed to ensure that adequate resources are provided to plan, do, check and act for continually improving its effectiveness General Manager is responsible for:
• endorsing the health and safety policy
• ensuring appropriate resource allocation to enable the effective operation and continual improvement of the company’s health and safety system

Enterprise Risk Management
The Enterprise Risk Management will have the responsibility and authority for:
• Ensuring that Health and Safety requirements are established, implemented and maintained in accordance with the Labour Act, 2003 and the Factories, Offices and Shops Act, 1970 including the following tasks;
• Ensuring that sufficient resources are allocated for the proper implementation of the health and safety policy
• Regularly reviewing the policy and ensuring that the necessary changes are made.
• Coordinating internal Health and Safety audits to ensure the Health and Safety Systems are being properly implemented and maintained;
• Handling and investigating nonconformity and ensuring corrective and preventive action are taken to mitigate any impacts caused;
• Reporting on the performance of the Health and Safety System implemented to the General Manager for review and as a basis for improvement of the system.

Health and Safety Committee (HS Committee)

This committee is responsible for:
• the establishment and implementation of the Health and Safety Systems;
• the establishment and review of objectives, targets, and programs;
• ensuring the effective implementation of health and safety related operational controls and programs;
• the internal communication of health matters between management and employees;
• the review of complaint records, nonconformity, corrective action and preventive action reports and the adoption of preventive actions as necessary;
• providing leadership in the pursuit of health issues;
• any other EMS activities that are assigned by the Enterprise Risk Management
• The Committee comprises of the Environmental Health and Safety Officer, compliance Officer and selected members from the Technical Office

Management Review Committee

The Committee systematically examines the Health and Safety System implemented to ensure the suitability, adequacy and effectiveness. The Committee comprises of the Chief Executive Officer, Enterprise Risk Manager, Human Resource Manager and Chief Finance Officer.

Human Resource Manager (HRM)
The Human Resource Manager shall consolidate the training needs and prepare an annual training plan for all employees. The HRM shall also arrange or coordinate training and keep training records accordingly.

All Employees

All employees are responsible for:
• Working in accordance with the documented health and safety procedures and instructions, and with specific responsibilities as defined in individual procedures and instructions;
• Reporting problems or deviations associated with health and safety issues to the HR Committee.

Health and Safety Responsibilities of Key Stakeholders

Board of Directors

• The Company’s Board of Directors has overall responsibility for ensuring this policy complies with the legal and ethical obligations, and that all those under the Company’s control comply with it.
• The Board shall approve AML/CFT policies that promote a culture of compliance.

Senior Management

The Senior Management of the company shall be responsible for managing the business effectively, in relation to AML/CFT systems. The senior management should;
• Be satisfied that the company’s AML/CFT systems are capable of addressing the ML/TF risks identified
• Appoint a director or senior manager as a compliance officer who has overall responsibility for the establishment and maintenance of the company’s AML/CFT systems
• Appoint a senior member of staff as the Money Laundering Reporting Officer (MLRO) who will be the central reference point for suspicious transaction reporting

Compliance Officer and Money Laundering Reporting Officer

The function of the Compliance Officer (CO) is to act as the focal point within the company for the oversight of all activities relating to the prevention and detection of ML/TF and providing support and guidance to the senior management to ensure that ML/TF risks are adequately managed. In particular, the CO assumes responsibility for:
• Developing and/or continuously review the company’s AML/CFT systems to ensure they remain up-to-date and meet current statutory and regulatory requirements.
• The oversight of all aspects of the AML/CFT systems, which include monitoring effectiveness and enhancing the controls and procedures where necessary.

Compliance and Audit Function

The independent compliance and audit function will have a direct line of communication to the senior management. The audit function either internal or outsourced shall;
• Regularly review the AML/CFT system to ensure effectiveness.
• Ensure important matters are escalated.
• Ensure proper compliance and implementation of AML/CFT policies.
• Shall have direct reporting line to the BOD.

Money Laundering Reporting Officer (MLRO)

The MLRO should play an active role in the identification and reporting of suspicious transactions. Principal functions performed are expected to include:
• Review all internal disclosures and exception reports and, in light of all available relevant information, determining whether or not it is necessary to make a report;
• Maintenance of all records related to such internal reviews;
• Act as the main point of contact with the fic, law enforcement, and any other competent authorities in relation to ml/tf prevention and detection, investigation or compliance.

Third Parties
Third Parties must ensure provision of timely, accurate and adequate information to enhance the due diligence checks performed.

Record Keeping

Employees are encouraged and mandated to immediately report all suspicious transactions to the MLRO for further investigation and report to the FIC. STRs must be filed when Customer:
• Presents fake documentation; or
• Is found to have been suspect in news publications egg. Wanted Persons etc.; or
• Is involved in identity theft, that is, presents fake Identity card to impersonate someone else in order to have access to a transaction; or
• Fails to complete the required Customer Relationship Form within the stipulated time.

Continuous Monitoring

Effective ongoing monitoring is vital for understanding of customers’ activities and an integral part of effective AML/CFT systems. It helps companies to know their customers and to detect unusual or suspicious activities.

Rango will continuously monitor its business relationship with customers by:
• Reviewing from time to time documents, data and information relating to the customer and obtained to ensure that they are up-to-date and relevant4;
• Monitoring the activities (including cash and non-cash transactions) of the customer to ensure that they are consistent with the nature of business, the risk profile and source of funds. An unusual transaction may be in the form of activity that is inconsistent with the expected pattern for that customer, or with the normal business activities for the type of product or service that is being delivered; and
• Identifying transactions that are complex, large or unusual or patterns of transactions that have no apparent economic or lawful purpose and which may indicate ML/TF.
Failure to conduct ongoing monitoring could expose Rango to potential abuse by criminals, and may call into question the adequacy of systems and controls, or the prudence and integrity or fitness and properness of Rango’s management.

How to Raise a Concern

• Employees, directors and all stakeholders are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage via designated whistle blowing channels.
• To guarantee the anonymity of employees and other persons who may want to report suspicious malpractices, management will from time to time deploy the services of an independent whistle blowing platform/firm.