Alturki HSE Guidelines

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Contents1. OVERVIEW 41.1 Letter of Commitment President & CEO 61.2 Purpose and Scope 71.3 Policy 81.4 Commitment and Accountability 81.5 Purpose of a Health, Safety and Environment (HSE) Program 81.6 Importance of a HSE 81.7 Alternative options to a HSE Program 91.8 Responsibility of Implementing an HSE Program 91.9 Document Control and Review 92. CORPORATE POLICIES 102.1 HSE Policy 112.2 Health, Medical and First Aid Policy 112.3 Compliance / Corrective Discipline Policy 122.4 Personal Protective Equipment (PPE) Policy 122.5 Material Safety Data Sheets (MSDS) Policy 132.6 Work Refusal Policy 142.7 HSE Training Policy 142.8 Incident Reporting Policy 152.9 Corporate HSE Goals and Objectives 163. ORGANIZATION AND RESPONSIBLITIES 173.1 HSE Organization and Responsibilities 183.2 Responsibilities 193.3 Corrective Disciplinary Process 253.4 Enforcement Procedures 263.5 First Aid 284. COMPETENCIES, TRAINING, AND DOCUMENTATION 294.1 Training Purpose 304.2 Worker Competency 304.3 Training 31

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5. HAZARD MANAGEMENT SYSTEMS 345.1 The Hazard and Effects Management Process 355.2 Personnel Protective Equipment (PPE) 435.3 Workers Right to Refuse 506. COMMUNICATION AND EMERGENCY RESPONSE 536.1 Communicating - Health Safety & Environment 546.2 Emergency Response Plan 556.3 Incident Reporting and Investigation 567. FACILITY or SITE SPECIFIC HSE PROGRAM 657.1 Generic Outline - Site Specific HSE Program 667.2 Generic Site Specific HSE PLAN 688. AUDITS and HSE MONITORING (KPIs) 758.1 Management HSE Role during Site Inspections 768.2 Tiered HSE Inspection/Audit Programs 768.3 HSE Audit Frequency 778.4 Auditor Competency 788.5 Alturki HSE Steering Committee Audit Program 788.6 Senior Management HSE Review Subsidiaries 788.7 Alturki Group Level - HSE Matrices 798.8 Safety Performance Accountability 80

OVERVIEW

5Alturki HSE Guidelines

Khalid Ali Alturki & Sons (Alturki) is a leading investment and development holding company that has been operating in Saudi Arabia since 1975. Its subsidiaries and joint venture companies are operating in the building materials, construction & infrastructure, ICT & distribution, energy & industrial, transportation and real-estate sectors in Saudi Arabia and Egypt.

Alturki is committed to the Health, Safety and Environment (HSE) and it has developed Alturki HSE Guidelines to ensure HSE policies, objectives, hazard management systems and communications are uniformly adopted by all of its subsidiaries. By virtue of the diverse business activities of each subsidiary, the Alturki HSE Guidelines prescribe key program requirements, while enabling each company flexibility to develop a HSE Management System that is specific to its needs. Although not a requirement, some companies may decide to pursue ISO Management System Certification in (Safety (ISO18001), Environment (ISO 14001) and Quality Management Systems (ISO 9001)) in order differentiate with existing competitors, requirement for Tenders or to motivate staff/goal setting. Alturkis development of the Alturki HSE Guidelines is driven by a sense of purpose and corporate values that are routed in the philosophy that in achieving excellence in HSE everyone wins - it is beneficial for our employees, contractors, the communities in which we operate, and we believe it is essential to maintaining a successful business. The Alturki HSE Guidelines harmonize with the Saudi Aramcos Safety Management System (SMS) as well as Occupational Safety and Health Administration (OSHA).

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1.1 Letter of Commitment President & CEO

Simply, we care about people!

It is one of my main responsibilities as a President & CEO of Alturki Holding to make sure our colleagues who choose to build their careers with us are safe and work in a healthy environment.

Alturki is committed to health, safety and the environment and it has developed guidelines (Alturki HSE Guidelines) to ensure policies, objectives and communications are uniformly adopted by all of its people. By virtue of the diverse business activities of each subsidiary, the Alturki HSE Guidelines Manual prescribes key program requirements, while allowing each company the flexibility to develop an HSE Management System that specific to its needs.

Building on our mission of accelerating the sustainable growth of Alturki businesses, HSE is part of Alturki Sustainability Model which is becoming a strategic differentiator for our business. It can be transformational if leveraged properly. Sustainability (The Triple Bottom Line) means companies should measure their long term success by considering their wide impact on the environment, the economy, and on the society in which they work. It is as much a mindset as it is an objective and needs to be integrated into our values and principles; then, translated to daily actions.

I expect total commitment, individual responsibility and accountability from each of our employees, contractors, and visitors to comply with our guidelines, policies, standards and procedures. It is important that we establish and support the HSE culture through a process of continuous improvement, striving for consistent performance across Alturki Holdings companies. It is the responsibility of each employee to motivate, to lead by example, and to monitor the performance of our work in this regard.

Rami AlturkiPresident & CEOOctober 2016

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1.2 Purpose and ScopeThis guidelines manual provides the HSE framework and expectations for Alturkis Corporate Office and its subsidiary companies (collectively referred to as the Alturki Holding), including all of its applicable employees, contractors, and visitors. The Alturki Holding strives to compliant with all applicable laws and regulations, to adopt industry recognized best practices, and to control risks that may impact health and safety at our worksite, or may have an impact to the environment or cause harm within the communities in which we operate.

This manual includes usage of the verbs SHALL and SHOULD. For the purpose of this publication, the following definitions apply:

f SHALL indicate that the rule has universal application to the specific activity, and implies that the rule is mandatory.

f SHOULD indicates that the rule is to be used unless there are practical or other sensible reasons to the contrary, and implies that the rule is to be used where good judgment and safety principles indicate it is appropriate

It is expected that all of our employees, contractors, and visitors are aware of our commitment to protect the health of our employees, providing a safe work environment and caring for the environment. We welcome employee participation and feedback to improve our HSE program and will forward these initiatives to our Sustainability General Manager.

1.2.1 ComplianceCompliance with the Alturki HSE Guidelines, Policies, and Programs & Procedures is mandatory. Once the HSE programs are fully implemented any contravention is considered a performance issue and may result in disciplinary action, up to and including termination with cause. Guidelines reflect the elements of policies or procedures that allow for discretionary action. Enforcement of the HSE Manual, Policies & Procedures is the responsibility of all management and employees.

If an Alturki employee knowingly contravenes or intends to contravene the HSE Policies & Procedures, or has knowledge of an individual who has contravened or intends to contravene any HSE Policy or Procedure, they shall immediately report the contravention or intended contravention to ones manager/supervisor. The manager will inform senior management following established reporting norms.

The safety program outlined in the Alturki HSE Manual does not take precedence over the applicable laws and regulations in the countries in which we operate.

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1.3 PolicyStaff and contractors employed by Alturki and any of its subsidiary companies are responsible for compliance to the HSE management program. Managers and supervisors are responsible for identifying safety needs, communicating safety hazards, investigating hazardous conditions and accidents, providing training, supplying appropriate safety and personal protective equipment, and ensuring all equipment is properly maintained.It is expected that worksite safety rules are followed, including compliance to approved safe work procedures, using, when required, personal protective equipment, participating in safety training programs and informing ones immediate supervisor of any unsafe working conditions. Everyone has the right and responsibility to refuse to do work when unsafe conditions exist. By fulfilling the Corporations safety responsibilities, everyone who works for Alturki and its subsidiary companies will share in the benefits of a safe and healthy workplace that minimizes impacts to the environment.

1.4 Commitment and AccountabilityThe Corporation and its subsidiary companies are committed to maintaining safe work practices and progressive environmental practices within the organization. These practices allow for: achievement of the quality of services and products, establishment of sound business practices, and provision of a safe and responsible work environment to allow for growth.

The Board of Directors, President & CEO, and Senior Management expect total commitment, individual responsibility and accountability from each employee and contractors to comply with the HSE policies, procedures, standards and guidelines. It is the responsibility of each of subsidiary company to incorporate the HSE management