qad016uk hse handbook issue 18 april 2019 · the hse handbook is applicable to all personnel...

HSE Handbook Atlas Professionals ---------------------------------------------------------------------------------------------------------------------------------------------

--------------------------------------------------------------------------------------------------------------------------------------------- This document forms part of the Atlas Integrated Management System. A master copy of this document is maintained for version updates internally on the Atlas Professionals

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QAD016UK • Issue 18 • April 2019 - 1 - Approved Director

HSE Handbook

April 2019





Introduction Atlas Professionals is a global provider of specialist recruitment and HR services to Energy and Marine industries.

Health, safety and environmental issues are of paramount importance in these industrial sectors. Atlas Professionals makes every effort to safeguard the health, safety and working environment of its employees, and the environment in general. Our clients also impose requirements on temporary personnel. In the event of gross negligence on your part, they could even hold you, as a temporary employee, legally responsible for any consequences. In order to prevent such situations, we, as your employer, intend to provide you with as much information as possible about health, safety and the environment.

Atlas Professionals employees work in extremely diverse areas. Consequently, most general health safety and environmental standards and procedures (HSE policy) in the oil & gas, maritime, hydrographic, submarine telecoms and seismic survey sectors are covered in this safety manual. Hereafter, you will find more specific information about working aboard vessels or on other floating structures and on onshore and offshore sites. Where available, you will also receive the safety information sent to us by the client. The instructions in this manual should be considered as complementary to the regulations laid down by our clients and applicable codes, guidelines and standards recommended by industry organisations and administrations. The client’s safety instructions always take precedence over the general instructions in this manual. Attendance of information sessions, alarm drills and the appropriate education and training courses organised by the client is mandatory. You also have to familiarise yourself with your working environment or ship, and the documentation you receive from the client.

Legally speaking, the employer, in this case the various divisions of Atlas Professionals, is responsible for the HSE policy and the implementation thereof by its employees. The employee, however, should also take responsibility for implementing the HSE guidelines laid down by Atlas Professionals and the client. All work carried out at different sites entails specific risks, and all employees at the site should be aware of these risks. Often, a client has established procedures to identify potential risks. In addition, there are many site-specific rules and regulations, depending on the project or vessel on which you are working. If no site-specific procedures have been put in place at your location, make sure that you are aware of any potential risks.

In the interest of your own safety and that of others, we urge you, politely but firmly, to read this manual thoroughly so that you are well prepared before reporting to your work location.

The HSE Handbook is applicable to all personnel engaged by Atlas, whether permanent or temporary employee, contractor, or consultant. For the purposes of the handbook, all personnel are referred to as employees, and Atlas is referred to as the employer. However, this does not necessarily constitute permanent employment.

Atlas Professionals





CONTENTS

1. Chapter 1: Before starting work

1.1. Passport / Identification 6

1.2. Medical examination 6

1.3. Travel Vaccination and Malarial Programs 6

1.4. Background Security Checks 6

1.5. Ready to Travel without detainments. 6

1.6. Personal Belongings 6

1.7. Electronic Cigarettes (& Vapers) 6

1.8. Maritime Labour Convention 2006, Required Documentation 7

1.9. Code of Conduct 7

2. Chapter 2: Safety at work

2.1. Worksite Behaviour

2.1.1. Forbidden Substances & Offensive Weapons 7

2.1.2. Smoking in Prohibited Areas 7

2.1.3. Punctuality 8

2.1.4. Duties 8

2.1.5. Safety and the 7 C’s 8

2.1.6. Behaviour towards others 9

2.1.7. Bringing unauthorized personnel onboard 9

2.1.8. Treatment of Workplace, Accommodation & Facilities 9

2.1.9. Conduct in Emergencies 9

2.1.9.1. Fire Safety Procedure 9

2.1.10. Working Environment 9

2.1.10.1. Personnel Protective Equipment 10

2.1.10.2. Lifting 11

2.1.10.3. Use of Hazardous Substances 11

2.1.10.4. Stair Safety 11

2.1.11. Waste Management 12

2.1.11.1. Non Hazardous Office Waste 12

2.1.11.2. Hazardous Office Waste 12

2.1.11.3. Broken Glass and Sharp Items 12

2.1.11.4. Non-Recyclable Waste 12

2.1.11.5. Activities at Sea 12

2.1.12. Confidential Records 12

2.1.12.1. Disposal 12

2.1.12.2. Destruction 12

2.1.13. Fatigue Management 12

3. Chapter 3: Accidents and dangerous situations 13

4. Chapter 4: Working at heights

4.1. Platforms and scaffolding 14

4.2. Ladders 14





4.3. Hoisting equipment 14

4.4. Fall prevention equipment 14

5. Chapter 5: Important addresses / telephone numbers

5.1. What to do in the case of illness /accident /return to work 15

5.2. Who to contact for work related health & safety issues 15

6. Chapter 6: Specific Maritime Safety

6.1. Seaman’s book 16

6.2. Service book 16

6.3. Certificates 16

6.4. Arrival and departure 16

6.5. Safety on board 16

6.6. Safety committee 16

6.7. Alerting the coastguard or local port authority 17

6.8. Lifeboat drill 17

6.9. Fire drill 17

6.10. Other drills on board ships may include 17

7. Chapter 7: Specific oil & gas safety

7.1. Personal Safety Logbook 17

7.2. Transport to offshore locations 18

7.3. Smoking 18

7.4. Emergency drills 18

7.5. Reporting accidents 18

7.6. Reporting illnesses 18

7.7. Tidiness and cleanliness 19

7.8. Other instructions 19

7.9. Work permit 19

7.10. Shutdown of machines 19

7.11. Radioactivity 19

7.12. Hoisting activities 19

7.13. Grating and Guard rails 20

7.14. Emergency procedures 20

7.15. Fire or other emergency situations 20

7.16. Abandon platform 20

7.17. Man overboard 20

8. Chapter 8: Complaints & Suggestions

8.1. Seafarer’s complaint handling procedure 21

8.2. Making a complaint onboard 22

8.3. On-Shore complaint handling procedure 23





APPENDICES

Appendix 1: Health & Safety Policy 24

Appendix 2: Social Media Policy 25

Appendix 3: Drug & Alcohol Policy 26

Appendix 4: Road Safety Management Policy 29

Appendix 5: Complaint Form 31

Appendix 6: Quality Policy 33

Appendix 7: Code of Conduct 34

Appendix 8: Whistleblower Policy 38

Appendix 9: Fraud Rules 41

Appendix 10: Environmental Policy 47

Appendix 11: Corporate Social Responsibility Policy 48





1. Chapter 1: Before starting work

The rules and regulations below apply to all employees, who work onshore or on offshore facilities, on board vessels or on other floating structures.

1.1. Passport / Identification

All employees should possess a valid passport or other form of identification that will allow them to travel.

Identification is necessary for checking in at airports or showing to security agents.

1.2. Medical examination

All employees should be in the possession of a valid medical certificate entered in the service book or in

the Personal Safety Logbook. Without this certificate, you will not be allowed to enter the site or join the

platform / vessel. In the event of a medical certificate being refused, you have the right to seek a 2nd

opinion by attending another independent medical examination with a duly qualified medical practitioner.

1.3. Travel Vaccination and Anti-Malarial Programs

Employees are required to follow international guidelines and recommendations on vaccinations and anti-

malarial advice which may be required to travel overseas, as recommended by the World Health

Organisation, registered medical advisors or travel clinics. Employees may be required to participate in

anti-malarial programs before, during and after deployment.

1.4. Background Security Checks

Employees may be asked to provide a “Declaration of Good Behaviour” (Netherlands), “Certificate of Non

Prosecution (UK), or similar background security check, depending on residency. Checks may be

requested for visa purposes, or for projects that require such checks to be carried out prior to deployment,

depending on the nature of work to be undertaken, and / or location.

1.5. Ready to Travel without detainments.

All employees should be ready and free to travel without detainments, and should declare, prior to

contract negotiations, any open fines, or criminal convictions that may prevent travel across international

borders and / or to an offshore vessel or installation.

1.6. Personal Belongings

Personal belongings and cash are the responsibility of the individual. Employees are advised not to carry

highly valuable items, or excessive amounts of cash to any work location, in order to minimize the risk of

theft, and to prevent possession which may inadvertently place them under suspicion. Any cash carried

should be in accordance with international entry requirements. Employees are advised to follow client

instructions on the possession of items which may be regarded as restricted in certain countries.

Valuables should be kept in a safe / secure place. Any theft should be reported to a supervisor

immediately.

1.7. Electronic Cigarettes (or Vapers)Electronic Cigarettes (or Vapers) and their associated refills are not permitted in the check in baggage of aeroplanes, or in helicopter baggage bay compartments. These items must be hand carried, in accordance with carrier policies. Since rules may differ per country for bringing an electronic cigarette on board an aircraft, it is recommended to always check the legal restrictions of the countries that are part of your journey.





1.8. Maritime Labour Convention 2006, Required Documentation

In accordance with the Maritime Labour Convention, 2006, all personnel who are deemed to be seafarers

and who are working in an offshore capacity on a vessel must carry the following original documentation

as a minimum to be able to board any client vessel.

Documents must be valid and available for the duration of deployment, and must be presented to port

state Authorities should they be requested:

(i) Valid passport (ii) Vaccination booklet (only for international trips where vaccinations are required) (iii) Current Employment or Consultancy Agreement with any applicable Agreement Addendum. (iv) Recent payslip i.e. within the last 12 months. (v) Signing On/Off booklet (Seaman’s book). (vi) Valid medical certificate. (vii) Valid survival certificate. (viii) Evidence of training, a copy of a current CV including list of pertinent training for current role will

be suitable. The above list is not exhaustive and additional documentation may be required by the Client on a project specific basis.

1.9. Code of Conduct

Employees are required to adhere to the Atlas Professionals Code of Conduct (See Appendix 7). The

Code of Conduct includes the Atlas Professionals Values and Principles that apply in all our decisions,

thereby ensuring that we make the right ethical choices in our daily business.

2. Chapter 2: Safety at work

2.1. Worksite Behaviour

The following guidelines apply to all employees, all of whom should be aware of them before starting work.

Action will be taken in cases where there is a breach of these guidelines. Actions will depend of the nature

of the breach, and may range from informal warnings for minor breaches, through to formal warnings and

dismissal for gross misconduct.

2.1.1. Forbidden Substances & Offensive Weapons

To carry or possess alcohol or drugs is forbidden. Work cannot be started or resumed if you are under the

influence of the aforementioned substances. It is also forbidden to carry weapons, knives, explosives or

caustic substances. Failure to comply with these restrictions can result in refusal of entry to or removal

from the work location. The costs incurred in the removal of persons from the work location will be

recovered from the person involved. Checks may take place before departure, on arrival, during your stay

or upon leaving the work location. Appendix 3 contains the Drug & Alcohol Policy for Atlas Professionals.

2.1.2 Smoking in Prohibited Areas

Smoking in prohibited areas is dangerous, but particularly on tankers, liquid gas carriers and vessels

carrying explosive or inflammable materials. Rules controlling smoking and the use of naked lights or

unapproved electric torches must be obeyed at all times.





2.1.3 Punctuality

All employees are expected to arrive at the work location on time. This is particularly important for joining

a vessel, returning from shore leave, and reporting for duty, where absence at the time of sailing may

seriously delay the ship or even prevent her sailing until a replacement is found.

2.1.4 DutiesAll employees shall carry out his/her duties efficiently, and to the best of their ability. Employees are entitled to be informed of their duties and to whom they are responsible for carrying them out. If in doubt, employees should ask. Within the scope of his/her duties, reasonable commands and instructions must be obeyed.

2.1.5 Safety and the 7 C’s All employees shall comply with safety policy, procedures and instructions, and shall always adopt safe work practices to prevent accidents, incidents and near misses. To help with this, Atlas professionals has produced a safe behaviour program. The 7 C’s. Following the 7C’s will help ensure safe and efficient work is conducted. No paperwork is required to follow the 7 C’s it’s all in the mindset.

Correct PrioritisationPlanning tasks prior to commencing and re-planning according to

new developments

ComplianceFollowing procedures

and using management of change when

required.

CommunicationTalking and

listening to each other.

.

Continuous Risk Assessment

Think What if? And having the correct mind set prior to conducting

any task.

Caring for each otherHaving the courage to intervene on an unsafe act or omission at any

given time.

Coaching / MentoringUsing your

competence to help and guide others.

CompetenceThe ability, skills and

knowledge to do something

successfully and efficiently.





2.1.6 Behaviour towards othersAll employees shall ensure that they conduct themselves in an orderly and respectful manner, which maintains a smooth working environment, conducive to effective company operations. Anti-social behavior will not be tolerated, and in extreme circumstances, can endanger the work location and crew. This can include excessive noise, abusive language, sexual harassment, aggressive attitudes and offensive personal habits. Employees should also bear in mind that fellow crew members may need to sleep whilst others are awake.

2.1.7 Bringing unauthorised persons onboardFor persons working onboard a ship or vessel, the ship’s rules or port authority’s restrictions on bringing unauthorised persons on board must be strictly observed.

2.1.8 Treatment of Workplace, Accommodation & Facilities All employees shall strive to maintain good working conditions, maintaining a pleasant and safe working environment for all. All areas should be kept clean, and clear of obstructions which could potentially cause a safety hazard. Accommodation and other facilities, whether provided for personal use, or to be shared with others, shall be treated with respect.

2.1.9 Conduct in Emergencies In any emergency or other situation in which the safety of the workplace is at stake, all employees are required to obey any instructions and orders given by those responsible for the emergency evacuation procedures.

2.1.9.1 Fire safety Procedure In the event of a fire, raise the alarm. If trained to do so, use an appropriate fire extinguisher to tackle the fire, but only if your exit is clear. Close doors and windows and switch off any heat generating equipment, if safe to do so. Leave the building by the nearest safe exit, following the instructions of fire marshals as applicable. Do not return to pick up personal belongings. Do not use lifts. Proceed to the assembly point. Alert the emergency services as required.

2.1.10 Working environment Employees shall comply with the following rules in order to create a safe working environment for all those concerned: - Use all personal protective equipment appropriately and store it after use in the proper place; - Use the proper means of access and egress to your bunk bed and to your place of work - Operate/handle machinery, appliances, tools etc. appropriately; and only the ones that you are trained to use. - Do not modify or remove protective devices from tools, machines, PPE etc; - Attend information and training sessions or toolbox / LMRA (last minute risk assessment sessions, organised for employees; - Only undertake duties for which you have received adequate training, and are familiar with applicable

regulations and working method; - Report any dangers to the employer and the direct supervisor; - If necessary, assist the experts who have been appointed by the employer to provide good working

conditions, but only after you have been included in a toolbox talk for that particular task. - When working in harsh environmental conditions, including heat / cold, be aware of any additional

risks associated with working in such conditions. Follow instructions on how to protect yourself from over exposure to these conditions, which may cause heat and cold stress, and can result in serious medical conditions.

The following guidelines clarify the above obligations:





Have you arrived at the workplace for the very first time? In that case, you should familiarise yourself with the escape routes;

The warning, safety and hazard signs are there for a reason! Follow the instructions on these signs; Keep all emergency exits, entrances, fire-fighting equipment and first-aid equipment free from

obstructions; Do not move fire-fighting equipment unnecessarily; If a fire-extinguisher is used, report this to your supervisor; Do not place any materials or tools in the marked passageways; Inform your contact person at Atlas Professionals and direct supervisor if you suffer from any of the

following: fear of heights, claustrophobia, epilepsy, medication side effects, allergies, diabetes or other physical or mental handicaps;

Park vehicles in the designated areas/spaces only.

Guidelines for your own workplace (and those of others): Keep your workplace clean and tidy, this will help prevent accidents; Ensure that there is sufficient space for you (and others) to complete tasks in a safe manner; If working in or around vehicles, always look in the direction of travel, and maintain eye contact with

others in close proximity; Maintain good levels of communication with those working with you, and around you;

Throw waste into the designated containers and clean up and report spillages appropriately;

Stow away any loose items in the correct location;

Never supply more material than strictly necessary;

Keep the workplace well-lit;

Maintain adequate ventilation in the workplace;

Always use the correct materials for the task and ensure that they are in good working condition – the

use of homemade tools is forbidden.

Remember: No work is so important or has to be finished so quickly that it must be done unsafely….USE STOP AUTHORITY IF REQUIRED.

2.1.10.1 Personal protective equipment It is important that employees use personal protective equipment during the performance of their duties. If stipulated by the applicable rules of the client, the client will supply the protective equipment. You should carry safety boots and work clothing/overalls with you at all times. Use the personal protective equipment appropriately and store it in the proper place after use.

The following personal protective equipment may be applicable, but is not limited to the following, when working: - Head protection; - Ear protection; - Eye protection; - Arm and hand protection; - Leg and foot protection; - Fall protection; - Face and respiratory protection; - Body protection; - Lifejacket. Your site supervisor will inform you of the personal protective equipment that you need. Pay attention to any possible safety signs. For time dependent PPE, users must ensure that any PPE with a shelf life, shows an issue date, expiry date, and is replaced before expiry date.





2.1.10.2 Lifting When lifting loads, it is very important to avoid any injuries. When lifting objects, observe the following rules: - Estimate the weight and volume of the object. If in doubt, use mechanical devices or ask for

assistance; - Check the load for sharp edges or corners, and sharp objects; - Bend your knees, take a firm hold of the object and keep your chin close to your chest; - Lift the load by stretching your legs so that your back does not take the strain; - Keep your back straight and keep the load as close to your body as possible; - Place your feet in a position that allows you to maintain your balance; - Make sure there are no obstacles in the lifting path; - Avoid twisting your back during lifting; - Carry angle bars, pipes etc. balanced evenly on your shoulder with the front end pointing downwards.

This avoids head, face or chest injuries of persons approaching from the other direction.

TILEO: When assessing the risk in lifting heavy objects, be mindful of the following: T – Task. Consider the manual handling task/activity itself, i.e. the lifting, lowering, carrying, pushing or pulling, and how it may affect your health and safety. For example, does the task involve repetitive movements, strenuous movements, long distances, or uneven weight distribution?

I – Individual. Consider the person who will be carrying out the manual handling activity, i.e. you or another colleague. For example, how strong, fit or able is the person? Are they capable of manual handling alone? Do they need assistance?

L – Load. Consider the object or person that is being moved, and assess how this may affect health and safety. For example, is the load particularly heavy, bulky, hard to grasp or unstable?

E – Environment. Consider the area in which the load is being moved, and assess how this could make the manual handling task unsafe. For example, are there any space constraints? Is the floor slippery or uneven? Is there sufficient lighting? Are there any trip hazards?

O – Other factors. Consider anything else, in addition to the task, individual, load and environment, which may impact on the safety of the manual handling activity. For example, will personal protective equipment (PPE) make movement difficult? Is additional / different PPE needed?

2.1.10.3 Use of Hazardous substances Workers shall read the labels, instructions for use and safety data sheets (SDS) to be able to identify the hazards of the substances they use and to take the appropriate measures. If in doubt, the work should be stopped and an expert or supervisor should be consulted. Take appropriate measures during work activities to maintain good standards of hygiene: - Adequate ventilation; - No smoking, no open flames, wash hands after working, no eating; - Make sure there is sufficient fire-fighting equipment in the vicinity or in the workplace

when working with flammable materials. When working with corrosive substances, the necessary precautions should be taken to prevent skin and eye contact. This can be achieved by wearing protective clothing, gloves or face shields. In case of accidents involving hazardous substances, call immediately for medical assistance. Inform first-aid workers as soon as possible of the substance(s) involved.

2.1.10.4 Stair Safety Stairs should be clear of obstructions, be well lit, have slip resistant stair treads, have visible stair edges, and should comply with prevailing regulations for dimensional geometry of the stairs. When using stairs, ensure that the “3 point of contact” rule is adhered to. Always maintain one hand and two feet, or two hands and one foot, when climbing or descending stairs, ladders, trucks and equipment.





2.1.11 Waste Management2.1.11.1 Non-Hazardous office waste.The majority of materials discarded from offices in which Atlas Professionals are present are non hazardous and many are recyclable. These materials include (but are not limited to): Paper, Cardboard, Drinks cans, Plastics, Small quantities of glass. These items should be separated and placed into bins provided for recyclable materials, as per local arrangements.

2.1.11.2 Hazardous office waste.Items such as fluorescent tubes, batteries and toner cartridges should be separated and recycled or disposed of as per local arrangements.

2.1.11.3 Broken Glass and Sharp Items.Small quantities of glass or sharp items (typically one or two items) should be separated and marked, and placed into suitable, designated containers. Quantities are limited to prevent the items causing injury to cleaners and others who may handle this waste.

2.1.11.4 Non-Recyclable Waste.Non-recyclable waste includes Food (if no facility exists to segregate for disposal as food waste); Heavily Food-contaminated packaging; Polystyrene. Food waste should be separated from recyclable materials so that they do not contaminate recyclable materials. Bins for non-recyclable wastes are available in offices and kitchens, and removed by cleaning or catering staff for disposal, as per local arrangements.

2.1.11.5 Activities at Sea.All items should be disposed of as per work site rules and regulations. Waste items should be disposed of in designated containers as per local arrangements. Items should not be thrown overboard.

2.1.12 Confidential Records2.1.12.1 Disposal: Records of a sensitive or confidential nature should be disposed of to ensure no possibility of reconstruction. For paper records, documents should be shredded, either onsite, or via a secure removal and off-site shredding service, as per local arrangements.2.1.12.2 Destruction: The destruction of official records must be authorised by the department head, with retention as per regulatory and operational requirements, where archiving is not possible, as per local arrangements.

2.1.12.3 Fatigue Management Fatigue is more than feeling tired and drowsy. In a work context, fatigue is a state of mental and/or physical exhaustion which reduces a person’s ability to perform work safely and effectively. Factors that may contribute to the risk of fatigue include work schedules, workload, work demands, sleep – length of sleep time, quality of sleep and time since last sleep, Environmental conditions, non-related work factors including lifestyle, health and extended travel periods to / from the work location. Fatigue presents a safety hazard to you and to those around you. Professionals should be well rested ahead of any period of deployment and must follow planned work and travel schedules. Should these schedules result in fatigue, consult your supervisor immediately to discuss all available options to ensure that you are rested before commencing or recommencing work.





3 Chapter 3: Accidents and dangerous situations Accidents can have considerable personal and financial consequences for the victim, the client and Atlas Professionals. All parties shall try to avoid accidents and are therefore instructed to report all accidents (and near-misses) and dangerous situations to their safety officer, supervisor, colleagues and Atlas Professionals. All events shall be reported to Atlas Professionals within 24 hours of the event occurring. The purpose of reporting accidents is to avoid any recurrence through investigation and registration.

In the event of an accident, all local procedures should be followed. If there are no local procedures in place at the site, the employee should act as follows: - Remedy the dangerous situation where possible. Stop the supply of hazardous substances and turn

off unnecessary machinery; - Serious accidents require immediate medical attention. Smaller wounds, no matter how small, should

always be examined, if necessary by the first-aid worker(s) on duty; - Alert the client's manager or his deputy, who will take further action (verify this if necessary!); - Mark the scene of the accident and write down the names of witnesses; - Do not move any materials that could be the cause of the accident. This is important for any subsequent investigation. When the employee is unable to take the steps mentioned above, he/she should alert a colleague. Only in emergencies may first aid be administered by anyone other than trained personnel.

Onboard ships, contingency plans may be consulted to alert the nearest port or coastal rescue centres and to avoid loss of life and damage to ship or environment.

After the injured person (IP) has been attended to, an accident report form should be filled in. Preferably, the form should be completed by the injured person but, if this is not possible, then the injured person’s supervisor will fill in the form together with the employee of Atlas Professionals. The report form should be sent, or handed over to the account manager of Atlas Professionals on the same day at the very latest. The employee shall, of course, inform the client management of the report.

If a near-accident / near miss has taken place or a dangerous situation has been detected, the locally established procedures should be followed. The near-accident/dangerous situation shall then be reported to Atlas Professionals' account manager in accordance with the accident reporting procedure.

Every employee of Atlas Professionals has the right, but also the duty, to take action and to remedy dangerous situations by stabilising, screening off, protecting or marking the accident site. If the employee is not authorised or unable to do this, he/she shall warn his/her supervisor or the competent person. The employee should then check whether the dangerous situation is being dealt with and, if necessary, contact Atlas Professionals.

If in doubt: SHOUT IT OUT!





4 Chapter 4: Working at heights

4.1 Platforms and scaffolding When working at heights or above water, a scaffold or platform should be used (where practical), as per local scaffolding regulations. If it is not practical to fit a guardrail, safety harnesses with lifelines shall be used. Scaffolding shall not block any passageways, exits or emergency equipment. A platform shall be easily and safely accessible, and workers shall be able to work safely on the platform with both hands free. When working above water, life buoys with attached life lines shall be available and a life vest (personal flotation device) shall be worn. The scaffold shall display the latest inspection date as per local legislation, and the connections, vertical supports, girders and floor boarding shall be strong and in good working condition. All scaffolding equipment shall be checked before use.

Please note: the erection and modification of scaffolding may only be carried out by certified personnel.

4.2 Ladders Moveable ladders should be checked regularly and be kept in good working order. Ladders should protrude at least 1 meter above the last point of support and, when scaling a height of more than 3 meters, a ladder should be secured to the top or the bottom. A ladder should be placed at an angle of 75 degrees, as smaller angles increase bending. When placing the ladder, any risk of sliding due to slippery conditions during or after rainfall should be taken into account. There should be sufficient room behind the ladder to place your feet on the ladder. Always use two hands when climbing a ladder, (with 3 points of contact at all times) and use mechanical aids to lift material to the top of the ladder. Only one person shall use a ladder at any one time and never horizontally. A metal ladder is prohibited to be used when carrying out electrical work. A wooden ladder may not be painted and should be stored in a dry, ventilated room. It is dangerous to extend your reach when standing on a ladder.

4.3 Hoisting equipment Hoisting equipment may only be used by certified or qualified personnel. The hoisting equipment has to be inspected before use. Hoisting equipment includes all equipment used to hoist materials, such as chains, slings etc. To prevent accidents while hoisting, employees shall follow the clients’ policies and procedures and use the STOP work authority for any safety related issue.

4.4 Fall prevention equipment When working at heights, where there is a risk of falling, workers are legally required to use a fall arrest or fall restraint system. While working above water, you shall always use fall protection such as (but not limited to) a safety harness, a fall-arrest system with full body harness or other approved fall protection equipment.





5 Chapter 5: Important addresses / telephone numbers

5.1 What to do in the case of illness/accident and return to work

When to contact Atlas.Absence due to illness / accident: Inform Atlas Professionals before 10am. Please state address, expected duration and any symptoms. Return to work: Inform Atlas Professionals before 10am. If you are working shifts: Please report the date you are returning to work as soon as possible so that this can be included in the planning.

Who to contact at Atlas. If employed by a Dutch entity, you should contact the Absence Co-ordinator in the first instance and your account manager thereafter. If employed by a non Dutch entity, you should contact your account manager in the first instance.

Absence Co-ordinator +31 (0)6 25 05 28 59 [email protected]

Aberdeen, UK +44 1224 628 555 Banbury, UK +44 (0) 1295 225 000 Bristol, UK + 44 (0) 117 929 5250 Capelle a/d IJssel, The Netherlands +31 (0) 10 266 9455 Dubai, UAE +971 4427 3203

Emmerich am Rhein, Germany + 44 (0) 117 929 5250 Hoofddorp, The Netherlands +31 (0) 23 556 0430 Houston, USA +1 832 485 4300 Limassol, Cyprus +357 25 822 056 Moscow, Russia +7 495 258 33 23 Newquay, UK +44 (0) 1726 86 22 00 Odessa, Ukraine +38 (0) 48 777 41 63 Riga, Latvia +371 733 15 03 Rio de Janeiro, Brasil + 55 21 3590 5101 Singapore + 65 6423 0749 Stavanger, Norway +47 40 00 44 77 Urk, The Netherlands +31 (0) 527 20 02 50 Vic, Spain + 34 619 48 1260 Vlissingen, The Netherlands + 31 118 22 54 66

5.2 Who to contact for work related health & safety issues

For work related health & safety issues, please contact your account manager and / or the Atlas Professionals QHSE Department.

QHSE Manager – Atlas Professionals Kate Knott +44 (0)1726 86 22 02

[email protected]

Senior HSEQ Advisor – Atlas Professionals Mark McDonald + 44 (0) 1224 62 85 55

[email protected]





For work related health or illness issues, please contact your account manager and / or the absence co-ordinator.

Absence Co-ordinator +31 (0) 6 25 05 28 59 [email protected]

In addition to mandatory medical examinations, the employee may come into contact with the Health and Safety Executive. This applies to those on secondment or staff personnel. This contact can take the form of a consultation following illness or an accident.

6 Chapter 6: Specific maritime safety

6.1 Seaman’s book Everyone who works on a seagoing vessel must have a valid seaman’s book with a valid medical certificate. The seaman’s book is handed over to the captain on arrival and will be returned upon departure.

6.2 Service book Everyone who works on inland vessels should have a service book with the corresponding medical certificate. The service book is handed over to the captain on arrival and should be returned on departure.

6.3 Certificates All personnel should carry original copies of valid certificates, required or necessary for the assigned duty or function. (For seafarers, as required by the STCW code).

6.4 Arrival and departure Depending on the place of embarking (signing on) or disembarking (signing off) of a vessel, transportation to and from the vessel will be arranged. You will be informed hereof by the captain or by your contact person at Atlas Professionals. In case of delay, please contact your Atlas Professionals contact person. Upon arrival on board the vessel, you should report to the captain or the second officer.

6.5 Safety on board On boarding, report immediately to the Captain/Master/Offshore installation Manager or the second officer. He will show you your cabin and familiarise you with the safety plan.

Many customers have quality ISO (International Organisation for Standards) and ISM (Integrated Safety Management) systems. You should familiarise yourself - within 24 hours - with the applicable ISO and ISM safety rules and regulations. Safety information that you receive from Atlas Professionals should be taken on board with you. Instructions that you receive on board always supersede instructions you receive from Atlas Professionals.

6.6 Safety committee Ocean-going vessels are, according to "International Maritime Law", required to have a safety committee on board. The captain will appoint the safety committee, preferably from volunteers. The task of the safety committee is to advise the captain on measures to prevent accidents on board vessels. This means: - Regular safety patrols on board; - Report dangerous situations, dangerous practices and unsafe materials; - Ensure the use of required personal protective equipment; - Investigate and report occupational accidents; - Advise and consult with the captain/ship owner;





6.7 Alerting the coastguard or local port authority In the case of an accident on board where outside assistance or advice is required, the coastguard or local port authority shall, with the permission of the captain, be informed of the situation. If this is not possible, the captain will send the general distress signal depending on the circumstances.

6.8 Lifeboat drill - It is the duty of the Captain/Master/Offshore installation Manager to ensure that life vests (PFD, or

‘personal floatation devices’) are worn correctly. - Lifeboats shall be regularly lowered overboard, as part of the client’s preventive maintenance scheme

and as per regulatory requirements. - Everyone on board should be involved in the lifeboat drill and report to a designated lifeboat station. - The Captain/Master/Offshore installation Manager should shall ensure that the crew is thoroughly

familiar with the assigned duties, as indicated in the boat drill procedure. - A mandatory lifeboat drill should be held once a month or within 24 hours of a 25% crew change.

6.9 Fire drill The appointed designated person is responsible for the organisation of the firefighting procedure. Everyone present at the workplace shall be involved in the fire drill (unless given special dispensation) and shall report to a designated safe area as per station bill. The responsible person or deputy shall check whether the crew is thoroughly familiar with their assigned duties. All designated fire stations will be marked above a berth or in the gangway, with a sign stating the specific duties. The fire drill shall be organised in such a way that when the Fire crew report to their fire stations, they do not know what type of fire it is and where the seat of the fire is located.

6.10 Other drills on board ships may include, but are not limited to: - MOB drill (Man Over board) - Security drill - First Aid drill - Emergency steering - Emergency operation of Main Propulsion system Specific duties during drills as per muster list/station bill and/or to be assigned by the officer in charge.

7 Chapter 7: Specific Oil & Gas safety The employee shall comply with the legal regulations and established safety standards of the client. Both onshore and offshore locations are considered hazardous zones with the exception of designated safe areas. These areas are indicated on the floor plan of the location.

The HMI (Mining Installation Manager) / OIM (Offshore Installation Manager) is responsible for your safety, but ultimately you are responsible for your own safety. Your safety and the safety of others strongly depends on good behaviour and the observance, and the following of company rules. You shall follow the rules faithfully. You are dependent on others and others are dependent on you.

7.1 Personal Safety Logbook (PSL) This document is mandatory for anyone working on a Dutch sector oil and gas installation. It contains the NOGEPA medical examination and also records the training sessions and courses that have been followed. Make sure you have this document with you at all times, otherwise you may be refused entry.

Atlas Professionals may issue Personal Safety Logbooks to field staff of ASG Energy BV, on request. Where PSLs are issued, Atlas takes no responsibility for the registration or update of the PSL. All updates remain the responsibility of the professional.





7.2 Transportation to offshore locations Transportation to an offshore location can be by boat or helicopter, whereby a number of rules apply.

• Boat: Professionals are required to follow the client’s policy and procedures when taking part in a boat transfer to and from an offshore location/vessel. This will include (but not limited to) taking part in a Tool Box Talk (prior to the task commencing) which shall have a suitable and sufficient Risk Assessment attached. If any Professional has doubts regarding anything within the process of the transfer, they shall use the STOP work authority (STOP the job).

• Helicopter: You should check in one hour before departure. Arriving less than one hour before departure can result in being refused to board the flight. Before take-off, a video will be shown with instructions that shall be followed before and during the flight: wearing a survival suit(dependent on work location), a life vest and how to act in emergencies (dependent on the type of helicopter).

On all helicopter flights, it is compulsory to wear three layers of clothing under the survival suit (depending on work location and season), comprising of sleeved shirts, long pants/trousers and closed toed footwear. Smoking during the flight is forbidden and mobile telephones must be turned off. You may take a maximum baggage weight of 9 kg in a soft (sports) bag. Any excess baggage must be declared before the flight, and may be refused. Some helicopter operators may allow higher weight limits for baggage, and these should be verified with Atlas prior to travel. A consignment note is required for medication, tools, laptops, cameras and video equipment etc. You should always follow the pilot's instructions in the case of emergencies during take-off, flight and landing.

On arrival at the location, you should report to the radio or control room or to the HMI / OIM, where you will be informed of the location's general safety regulations, and receive further instructions. These will cover the location of specific safety equipment, escape routes, muster stations and alarm signals. A safety video will be shown during the first visit.

7.3 Smoking There is a total ban on smoking at the location, both indoors and outdoors, with the exception of specially designated areas. This includes the smoking of E-cigarettes. It is not permitted to carry lighters, matches or other ignition sources outside this room without special permission from the HMI / OIM. This also applies to cameras and mobile telephones.

7.4 Emergency drills You must react during an exercise as you would in a real situation. These exercises take place regularly and are mandatory (unless given exemption by senior management) for all personnel. When the alarm sounds, all personnel should report as quickly as possible to their designated muster stations and follow the instructions of the supervisor/muster checker.

7.5 Reporting accidents Every accident/incident (or near-miss) and incident shall be reported to the HMI / OIM ASAP and to the Atlas Professionals office within 24 hours of occurring.

7.6 Reporting illness In a small environment such as an offshore location, infectious illnesses such as the flu can spread rapidly. It is therefore important that someone who feels unwell report to the medic. Cases of illness should also be reported to the Atlas Professionals office within 24 hours.





7.7 Tidiness and cleanliness Keep areas, floors and stairways clean. Dirt and discarded rubbish can cause incidents. Escape routes should always be kept clear. Always throw waste in the appropriate container, tidy away and store used materials in the proper place and leave the workplace clean and tidy. It is strictly forbidden to dump rubbish in the sea. In the event of leakage of gas, oil, condensation or other forms of pollution, the location's HMI / OIM should be informed. The wearing of jewellery is forbidden if there is a risk of injury. Long hair should be tied back or worn in a hairnet.

7.8 Other instructions Safety instructions can be found on the safety notice boards. Everyone on-site is expected to be familiar with and to follow these instructions.

7.9 Work permit This document is used on all oil & gas industry locations and states the duties to be carried out together with the appropriate control measures to minimise danger. This provides a centralised overview of who does what and when. The work permit will be issued by the HMI / OIM and should be discussed prior to the start, so that everyone is aware of the safe working procedures before starting their work.

There are work permits for a variety of activities, but not limited to: - a 'hot' work permit.

This is mandatory for welding, open flames, explosive-sensitive electrical devices and other sources of ignition;

- a permit for entry into confined spaces. This includes chambers, tanks, etc;

- a permit for other dangerous work. This includes diving activities, working above open sea, at great heights or with radioactive materials. Other activities requiring a work permit are wire line activities, working with scaffolding and using the personnel basket;

- a permit for duties for which the HMI / OIM considers a permit to be necessary.

7.10 Shutdown of machines An employee should shut down the machinery he / she is working on if: - the 'general' alarm sounds; - the 'abandon platform' alarm sounds; - there is a break; - the shift is over; - the machine / device will not be used for a long period; - refuelling takes place when the fuel tank is a part of the machine; - the supervisor gives the order to do so.

7.11 Radioactivity When working with radiation, a radiation expert should be present to supervise the work. In these cases, the HMI / OIM informs the HSE (Health, Safety and Environment) department and issues the work permit.

7.12 Hoisting activities Employees are required to follow the client’s policies and procedures when taking part in any hoisting /lifting operations. This will include (but not limited to) taking part in a Tool Box Talk (prior to the task commencing) which will have a suitable and sufficient Risk Assessment attached and lift plan. If any employee has any doubts regarding anything within the process, they shall use the STOP work authority (STOP the job). Good communication between all parties is vital to concluding a safe hoisting/lifting operation.





7.13 Grating and guardrails On offshore locations and on board, grating and guardrails can be removed during working thus increasing the risk of accidents. Where possible, these openings should be closed-off with temporary railings/hard barriers.

7.14 Emergency procedures It is important that you know how to (re)act in emergency situations. Therefore, further instructions are provided on arrival at a location as part of the workplace induction. Know where you are and where the life-saving appliances, muster stations and escape routes are located. Know who the first-aid workers are and follow instructions from the staff.

7.15 Fire or other emergency situations When discovering a fire or other emergency situation (gas or condensation leakage) you should immediately activate the nearest alarm. Report the information to the control room from a safe area. The emergency will be dealt with by the Emergency Response Team. Everyone who is not a part of this team should go to the designated muster station and await further instructions. A strict ban on smoking applies to emergency situations.

7.16 Abandon platform When the abandon platform/ship alarm sounds (a continuous alarm tone), everyone is expected to proceed as quickly as possible to the muster stations or lifeboats. On offshore locations, you should put on warm clothing, a survival suit and a life vest.

7.17 Man overboard When someone falls overboard, the following actions must be taken, but not limited to: - Throw the nearest lifebelt as close to the person in the water as possible; - Throw the nearest marker buoy as close to the person in the water as possible; - Keep the person in the water constantly in sight; - Press the nearest alarm without losing sight of the person in the water; - Repeatedly shout “man overboard”; - Instruct another person to inform the radio room or the Bridge of the location.





8 Chapter 8: Complaints & SuggestionsAt Atlas we care about your opinion. We are open for suggestions and always looking at ways to improve our organization. If you have any suggestions, issues or questions regarding the service provided by Atlas, please contact your account manager in the first instance.

Alternatively, please complete the complaints form (see appendix), and submit by email or post to your account manager, or to the contact details as stated on the form. Your complaint will be acknowledged within 2 working days, upon receipt, and you will be advised of the time limit for dealing with your complaint, depending on the nature of your complaint. Atlas aim to deal with all complaints in a fair, effective and timely manner. All complaints will remain confidential.

8.1 Seafarer’s Complaint Handling ProcedureYou have the right to make a complaint relating to matters occurring onboard ships, or on-shore. There is a complaints procedure onboard your ship to enable you to make a complaint about any matter, including breaches of the Maritime Labour Convention 2006, and your rights, including the right to live and work in decent conditions.

If you have any issues or concerns onboard your ship, we urge you to try and resolve problems at the lowest level possible, and suggest that you contact your Atlas Professionals Account Manager or direct supervisor or head of the department (HOD) onboard in the first instance. The Atlas Professionals Account Manager, Supervisor or Head of Department will then attempt to resolve the matter within prescribed time limits appropriate to the seriousness of the issues involved.

If the matter cannot be resolved by Atlas, or your supervisor or head of department onboard, you may refer the issue to the master, who should handle the matter personally.

If your complaint cannot be resolved by Atlas Professionals, or by the master, you may refer your complaint to external authorities. When you join the ship, it is the shipowner’s responsibility to issue you with a copy of the ship’s onboard complaints procedure. This will give you the contact details of the person responsible from the flag State and from your country’s administration (if different). It will also identify the person or people onboard to whom you can go to for advice and assistance in making a complaint. If you make a complaint, you should be made aware of the time limit for dealing with your complaint, especially if the matter is serious. The time limit for dealing with your complaint is governed by flag state rules.

During the complaints procedure, you have the right to be accompanied or represented by a fellow seafarer of your choice, and under no circumstances should you be victimised for making a complaint. Any such victimisation should be reported immediately.

All complaints and the decisions made on them should be recorded, a copy of which should be provided to you.





8.2 Making a complaint onboard.

If the complaint cannot be resolved on board, you should refer the matter ashore, either to the shipowner or to the authorities of the flag State, the port State visited by your ship or those in your own country.

COMPLAINT

1. Account Manager, Supervisor , HOD Onboard, HOD - HR

2. Master

3. External Authorities

Case closed Decision recorded

Copy provided to Seafarer

Attempt to resolve the matter to the seafarer’s satisfaction

Resolution

YES

If complaint was first made to Atlas HOD / Supervisor, Seafarers then refer complaint up to

Master

Complaint Recorded and copy provided to Seafarer

NO

Decision recorded Copy provided to Seafarer

Non-Resolution

Case closed Decision recorded

Copy provided to Seafarer

Matter to be referred to Shipowner or

Representative Flag State / Port State.





8.3 On-Shore Complaint Handling Procedure

Further steps to be taken should the onboard complaints procedure not address issues;

COMPLAINT

Port State Control Inspector to be contacted should onboard handling procedures not address issue(s)

Seafarer Informed of actions taken.

Decision recorded. Copy provided to

Seafarer. Case Closed

Tries to resolve deficiencies at ship-management level

Problem successfully resolved

Port State Control Inspector undertakes InvestigationCheck if on-board procedure followed

Problem not resolved, but not considered serious

enough to require detention of the vessel

Problems not resolved. Hazardous conditions

onboard, serious/repeated breach of the convention incl.

breach of seafarers’ rights

Inspector notifies flag state and requests a corrective

plan of action. Sets a prescribed deadline for

resolving problem

If problems are still not resolved, report sent to

Director or General of the ILOS seafarers’ and

shipowners’ organisations involved

Inspector can have ship detained until such time as

the deficiencies are resolved or he/she is satisfied that

there is an adequate plan for rectification

Flag state notified. Shipowners’ and seafarers’

organisations informed.

Follow onboard Complaint Handling Procedure in first instance





Appendix 1: Health & Safety Policy

Atlas Professionals, and the companies belonging to this group, provide specialist services and

consultancy to the hydrographic, seismic, maritime and oil & gas industries, operating worldwide.

It is the policy of the Atlas Professionals to provide safe and healthy working conditions for the prevention

of work-related injury and ill health, to seek to eliminate hazards and reduce OH&S risks, and to

continuously improve the Health & Safety of employees and professionals as well as the safety of

operations and equipment,. The safety of operations will be monitored and reviewed by senior

management on an at least quarterly basis.

Occupational Health & Safety objectives and targets are set and reviewed annually, to measure

performance and identify opportunities for improvement. Atlas Professionals aim to achieve OH&S

objectives to the full satisfaction of clients, employees and professionals.

The policy is based on the principle that each employee and professional is responsible for the quality and

safety of his/her own activities. By promoting an Integrated Management System, employees and

professionals are facilitated and encouraged to integrate Health & Safety management into their daily

work and to promote its application as a method of continual improvement within their area of

responsibility.

Atlas Professionals has agreements in place with clients to ensure that professionals have the means to

work safely. . In order to maintain a safe and healthy working environment, both the professionals working

at our Client’s sites and office staff are required to conduct their duties in a safe and sound manner,

abiding by all applicable rules and regulations.

Atlas Professionals maintain and encourage regular consultation and participation of clients, employees

and professionals, and where they exist, worker’s representatives.

Atlas Professionals recognises that due to its activities as a service provider, the safety regulations cannot

be limited to the Atlas Professionals’ Health & Safety Policy alone, but must include Client’s requirements

and instructions in the field of Health & Safety.

Atlas Professionals values the importance of employees being competent to carry out their tasks as

required by our Clients, in a safe manner. Atlas therefore aims to obtain and pass on to its employees,

any available information and instruction to assist its employees in achieving this.

The Health & Safety Policy is reviewed annually by senior management, for continued suitability.

René Neelissen Marcel Burghouwt Co-Chief Executive Officer Co-Chief Executive Officer

Peter Wit Luuk Kornelius Chief Operations Officer Chief Information Officer





Appendix 2: Social Media Policy

General This policy applies to all employees and professionals of Atlas Professionals, and relates to the use of social media, which should be broadly understood for the purposes of this policy to include blogs, wikis, microblogs, message boards, chat rooms, electronic newsletters, online forums, social networking sites, and other sites and services that permit users to share information with others.

Principles The following principles apply to professional use of social media on behalf of Atlas Professionals as well as personal use of social media when referencing Atlas Professionals, and its clients to whom professionals are deployed.

1. Employees and professionals are required to know and adhere to the Atlas Professionals Code of Conduct, HSE Handbook, and other company policies when using social media in reference to Atlas Professionals.

2. Employees and professionals should be aware of the effect their actions may have on their images, as well as Atlas Professionals image. The information that employees or professionals post or publish may be public information for a long time.

3. Employees and professionals should be aware that Atlas Professionals may observe content and information made available by employees and professionals through social media. Employees and professionals should use their best judgment in posting material that is neither inappropriate nor harmful to Atlas Professionals, its employees, professionals or clients.

4. Although not an exclusive list, some specific examples of prohibited social media conduct include posting commentary, content, or images that are defamatory, pornographic, proprietary, harassing, libelous, or that can create a hostile working environment.

5. Employees and professionals are not to publish, post or release any information that is considered confidential or not public. If there are questions about what is considered confidential, employees and professionals should check with the Human Resources Department and/or supervisor.

6. Social media networks, blogs and other types of online content sometimes generate press and media attention or legal questions. Employees and professionals should refer these inquiries to authorized Atlas Professionals spokespersons.

7. If employees or professionals encounter a situation while using social media that threatens to become antagonistic, employees and professionals should disengage from the dialogue in a polite manner and seek the advice of a supervisor.

8. Employees and professionals should obtain appropriate permission before referring to or posting images of current or former employees, professionals, clients, vendors or suppliers. Additionally, employees and professionals should obtain appropriate permission to use a third party's copyrights, copyrighted material, trademarks, service marks or other intellectual property.

9. The use of social media should not interfere with the professional responsibility of an employee. 10. Atlas Professionals computer systems are to be used for business purposes only. When using Atlas

Professionals computer systems, the use of social media for business purposes is allowed but personal use of social media networks or personal blogging of online content is discouraged and could result in disciplinary action.

11. Subject to applicable law, after‐hours online activity that violates Atlas Professionals Code of Conduct or any other company policy may subject an employee or professionals to disciplinary action or termination.

12. If employees or professionals publish content after‐hours that involves work or subjects associated with Atlas Professionals, a disclaimer should be used, such as this: “The postings on this site are my own and may not represent Atlas Professionals positions, strategies or opinions.”

13. It is highly recommended that employees or professionals keep Atlas Professionals related social media accounts separate from personal accounts, if practical.





Appendix 3: Drug & Alcohol Policy

1. General This policy applies to all employees and contractors of Atlas Professionals. Atlas Professionals recognizes and respects the employee's right to use alcohol whilst on leave and during vacations. However we also recognize that the abuse of alcohol and drugs can adversely affect job performance, the work environment and the safety of our employees, contractors and the general public.

Atlas Professionals is committed and contractually obliged by its clients to provide a safe working environment for its employees and contractors that is free from substance abuse. Substance abuse means the use of illegal drugs or the misuse of legal drugs or other substances and/or the abuse of alcohol.

The working site means all property owned, operated, leased by or otherwise under the control (in whole or in part) of Atlas Professionals’ client or related third parties, whether onboard, onshore or offshore including: designated check-in points for personnel travelling to and from offshore installations such as crew tenders, heliports and/or airports and any transportation provided from such heliports and/or airports, to and from any offshore location.

The use, possession, concealment, transportation, purchase, production and supply or offer to supply of prohibited substances on the working site shall not be tolerated in any form whatsoever. Substance abuse problems, as well as having major implications for the employees concerned, have the potential to impair safety and productivity of the operations.

Any employee who, during an assignment, including travel, is under the influence of a prohibited substance is in breach of this Policy. Violation of this Policy by an employee or contractor may result in that he/she will be immediately dismissed.

2. Alcohol The consumption of alcohol onboard or at the worksite during duty hours or working hours is strictly forbidden. Personnel are advised to exercise moderation in the consumption of alcoholic beverages during official company occasions (e.g. off duty hours, client meetings/ presentations, employee presentations etc.). Any violations or abuse may result in dismissal.

Employees and contractors of Atlas Professionals are reminded that in circumstances where they are representing Atlas Professionals, the image and reputation of the company must be upheld at all times and employees should conduct themselves accordingly. If at any time it is felt that the company's reputation is adversely affected, or that due to the consumption of alcohol the health or safety of any persons or property of Atlas Professionals is threatened, the employee or contractor may face dismissal.

Atlas Professionals and/or its client reserves the right to insist that employees submit to testing for alcohol in the following situations:

2.1. before coming on duty 2.2. when checking-in to travel offshore as part of the standard procedure; 2.3. when an employee is refused permission to a flight to or from embarkation or debarkation

destination. 2.4. when an employee is refused permission to board a vessel because he/she is suspected to be

under the influence of alcohol; 2.5. when an employee is refused permission to board a flight to or from an offshore installation,

because the employee is suspected to be under the influence of alcohol, or is suspected to have consumed alcohol prior to the departure of the flight;

2.6. immediately following an accident on working site;





2.7. Upon reasonable suspicion by Atlas Professionals or its client that an employee or contractor is under the influence of alcohol, and/or has consumed alcohol whilst on working site.

2.8. During random alcohol testing initiated onboard, or at working site.

Employees and contractors are advised that when travelling by any means of transportation, and specifically when travelling by helicopter to embarkation destination or working sites, they should abstain from consuming alcohol 24 hours prior to embarkation. Following this advice if any employee is refused transit by any means of transportation, and specifically refused transit on a helicopter due to failing a breath analysis test, they will be liable for the cost of the seat on the helicopter flight and may also face disciplinary action. In the event that an employee or contractor refuses to submit to breath analysis testing and/or search of person, possessions or immediate work area as detailed above, or are otherwise in breach on this Substance Abuse Policy, Atlas Professionals has the right to prevent such personnel from travelling to the worksite, or if already at the worksite, immediately remove such personnel from the work-site and send ashore, if applicable. The cost of removal will be paid by the employee.

3. Drugs 3.1. Illegal Substances

The production and supply, intention to supply, possession and use of illegal substances is a criminal offence, and any employee or contractor found in the course of their work and related travelling to be involved in the production, supply, possession of, or use of such substances will be subject to immediate dismissal. Atlas Professionals and/or its clients and related parties reserve the right to search the person, his/her personal possessions, and/or the immediate work area of any employee or contractor who work, visit or perform services on working site, for evidence of a prohibited substance or items associated therewith. Employees and contractors should be aware of the possibility of finding traces of use weeks after consumption.

3.2. Medically Prescribed DrugsSea going, offshore and onshore crew based personnel, contractors and employees who are using prescribed drugs while at work, must inform their operational contact within Atlas Professionals of type of medically prescribed medication they are using. Following evaluation, it may be deemed necessary to inform the Client’s Personnel Department in order to establish whether this particular medication is compatible with the Client’s standard duties. Failure to inform the relevant operations manager within Atlas Professionals may result in disciplinary action.

Atlas Professionals advises employees and contractors who are taking medically prescribed drugs to carry English written medical statements at all times to avoid possible misunderstandings during travelling and assignment. Personnel should carry sufficient essential medication to cover the duration of their expected deployment period, plus a further 50% as a minimum, to cover any unexpected delays. This should be carried as hand luggage, with the appropriate written medical statements as required, to avoid lack of medication should hold luggage be lost or mislaid during transit.

3.3. Barbiturates Barbiturates are drugs that can be used for a wide range of reasons, mainly for the treatment of epilepsy (e.g. phenobarbital) and anaesthesia. They are used to treat insomnia, anxiety or seizure activity, and have been known to be used recreationally. Although some barbiturates are freely available in some countries, in the UK, Europe and USA, barbiturates are a controlled drug, and are only available on prescription.

Barbiturates are central nervous system depressants with wide ranging effects from mild





sedation to general anaesthesia. They act in a similar manner to alcohol and slow down many areas of the brain. Barbiturates are known to cause drowsiness, or impairment to operate machinery. For this reason, they are not recommended when working in high risk areas, such as working at sea. The use of Barbiturates may result in a positive drug screening analysis, which will lead to appropriate disciplinary action being taken, up to and including dismissal.

4. Declaration of medicines taken onto the worksiteEmployees shall inform the Medic / Doctor of any medication, prescribed or non-medically prescribed , taken onto the worksite, on arrival. Failure to do so may result in disciplinary action.

5. Drug ScreeningAtlas Professionals and/or its client reserves the right to carry out urinary/blood drug screening on any employees and contractors at any time. If Atlas Professionals and/or its client suspects an individual to be under the influence of drugs, or if an individual's performance levels and behaviour have become inexplicably erratic, the individual may be required to undergo urinary/blood drug screening. The majority of oil- and shipping companies also have a policy of drug screening "for cause", at random or on suspicion, and may conduct drug screening onshore at airports/heliports prior to travelling offshore, or on offshore installations. Employees and contractors are expected to co-operate with such drug screening at all times. Failure to do so could lead to appropriate disciplinary action being taken up to and including summary dismissal. Positive results will lead to appropriate disciplinary action being taken, up to and including dismissal.





Appendix 4: Road Safety Management Policy

1. General This policy applies to all employees and contractors of Atlas Professionals (), who are required to drive motor vehicles in the course of their employment. This policy sets out guidelines which shall apply to all driving while on company business. Employees and contractors are also strongly advised to take heed of advice in relation to any kind of travel, including personal travel / commuting.

It is acknowledged that driving conditions can be dangerous, particularly when individuals are tired, where driving conditions are difficult, or in overseas countries where driving regulations are different , where local conditions may be far below those that we are familiar with in our county of residence, and where drivers will not be familiar with driving routes and environment.

This policy also applies to road users other than vehicle drivers, including cyclists and pedestrians.

In all instances, it is the company policy to minimise risk to its employees, contractors or others who may be affected. This shall include looking for alternative methods of transport where any of the following guidelines cannot be adhered to. In overseas countries in particular, the company shall consider provision of contracted private transport. Alternative transport may be public or private at the company’s sole discretion.

If the company decides that the employee is required to travel early or late to abide by these rules, then the company will provide suitable accommodation.

1.1 Minimum Requirements – Vehicles All vehicles shall be fit for purpose, have been maintained in a safe working condition, and properly insured. If these stipulations are not met, the driver shall not attempt to operate the vehicle, and shall use an alternative mode of transport.

It is strongly recommended that seat belts are installed and functional even where this is not a legal requirement in accordance with local legislation. Where local legislation requires the use of seat belts, this is mandatory.

The number of passengers shall not exceed the manufacturer’s specification and legal limits for the vehicle. Loads shall be secured and shall not exceed the manufacturer’s specification and legal limits for the vehicle.

1.2 Minimum Requirements - Drivers Drivers shall be competent, appropriately trained, hold a relevant and valid driving license, and be medically fit to operate the vehicle. Drivers shall not be under the influence of alcohol or drugs, or any other substance or medication that could impair their ability to drive.

Seat belts, where available (in accordance with local legislation), should be worn by all occupants at all times. While operating the vehicle, drivers are only permitted to use mobile phones or other two-way communication devices, via the use of hands free equipment. All employees and contractors shall comply with local traffic law requirements, and shall conduct themselves in a courteous manner to other road users.

1.3 Journey Requirements Journey planning is encouraged in advance of any unfamiliar journey. Drivers are encouraged to use satellite navigation devices where available, particularly when required to drive for company business in areas with which they are not familiar.





Journey risk assessment shall be carried out where and when appropriate and consider as a minimum the following; Road conditions, weather conditions and weather forecasts, risk from fatigue, safe loading and distribution of loads.

1.4 Vehicle Crash & Road Traffic Incident Reporting. Any vehicle crash, involving a company leased vehicle or hire car, whether major or minor, shall be reported to the employees Account Manager immediately, who will then inform Atlas’ Insurance and Claims Manager.

Any driver who has been involved in a road traffic incident, whilst driving a hire car, including but not limited to, speeding tickets/ fines, or parking tickets/ fines, should report any incidents to their Account Manager immediately, who will then liaise with the relevant car hire company. Costs related to such offences will be recharged to the individual concerned.

1.5 Fitness to Drive. The company will not tolerate individuals driving on company business whilst they are not fit to do so and any employee who does so will be subject to disciplinary action. Disciplinary action may also be taken against employees who, having been advised in advance of required journey, subsequently inform they are unfit to drive due to self-imposed conditions.

1.6 Maximum Driving Hours The company expects all drivers to assess their own capabilities, fitness to drive, driving route and conditions to determine how long they can safely drive for. It is essential however, that the limits set out in this policy are not exceeded

A minimum break of at least 15 minutes after every two hours of driving is recommended. The maximum period of continuous driving shall not exceed 4 hours without a break of at least 30 minutes. The maximum total driving time shall not exceed 12 hours (inclusive of breaks) without a period of at least 8 hours.

When an employee has just completed a night shift or has been travelling for more than 10 hours, that employee shall only be allowed to drive for a maximum of 2 hours. The employee shall then have a rest period of at least 6 hours before further driving.

No journey on company business that commences after 2200 hours or before 0500 hours will exceed 3 hours duration. Journeys of less than 3 hours shall only be permitted if individuals are competent and fit as described above.

1.7 Road users other than motor vehicle drivers. Road users other than motor vehicle drivers, including cyclists and pedestrians, are required to be alert when using the road for their own safety, and for the safety of others. This includes adhering to local road safety regulations, to remain attentive, to pay attention to the road environment and to have respect for other road users at all times.





Appendix 5: Complaint Form

COMPLAINT FORM / KLACHTENFORMULIER

Atlas Professionals, PO Box 444, The Netherlands, Tel + 31 23 556 04 20, Fax + 31 23 556 04 49 www.atlasprofessionals.com

Please enter as much information as possible and email the form to your account manager or to [email protected], or post to the address above. Vul het formulier zo volledig mogelijk in en stuur het per e-mail naar uw contactpersoon bij Atlas of naar [email protected] . Het formulier opsturen naar bovenstaand adres mag ook.

Date / Datum:

Name, Company / Naam, Bedrijfsnaam *:

Contact details / Contactgegevens*:

* Optional, but will need to be completed if you would like a reply / Velden zijn niet verplicht maar wel nodig indien u een reactie wenst.

Atlas Office / Kantoren Atlas Please check your office / Vink het betreffende kantoor aan aanvinken a.u.b.

Atlas Contact person / Contactpersoon Please fill out name / naam van uw contactpersoon bij Atlas

Aberdeen, UK

Banbury, UK

Bristol, UK

Capelle a/d IJssel, The Netherlands

Dubai, UAE

Emmerich am Rhein, Germany

Hoofddorp, The Netherlands

Houston, USA

Limassol, Cyprus

Moscow, Russia

Newquay, UK

Odessa, Ukraine

Riga, Latvia

Rio de Janeiro, Brasil

Singapore, Singapore City

Stavanger, Norway

Urk, The Netherlands

Vic, Spain

Vlissingen, The Netherlands





Complaint Category / Categorie van de klachtPlease indicate which category your complaint falls into / Vink de categorie van uw klacht aan

Service Content, Delivery or Quality

Inhoud dienstverlening, levering of kwaliteit

Documentation / Documentatie

Office based Personnel / Kantoorpersoneel Response Time / Reactie snelheid

Requests / Verzoeken Billing or Payment / Facturering of betaling

Communication / Communicatie Follow Up / Begeleiding

Other, please specify / Anders, namelijk:

Complaint Details / Omschrijving van de klacht Please enter the details of your complaint / Omschrijf hieronder uw klacht.





Appendix 6: Quality Policy



It is the policy of Atlas Professionals to ensure that customers have access to an efficient and well

regulated recruitment and placement system, and to continually improve the quality of its internal

organisation and of 3rd party related processes.

Quality objectives and targets are set and reviewed annually, to measure performance and identify

opportunities for improvement. Atlas Professionals aim to achieve quality objectives to the full

satisfaction of clients, employees and internal staff.

The policy is based on the principle that each employee is responsible for the quality and safety of his/her

own activities. By incorporating the Quality Management System into Atlas Professionals’ integrated

management system (IMS) and supporting systems, employees are facilitated and encouraged to

integrate quality management into their daily work and to promote its application as a method of continual

improvement within their area of responsibility.

The quality assurance system of Atlas Professionals is certified to ISO 9001:2015, attested to the Maritime

Labour Convention 2006 (as applicable), and is integrated in our core activities. The activities are

described in the Integrated Management System manual, supported by procedures and work

instructions. Upon employment, each staff member receives an extensive introduction to the IMS manual,

his/her job profile and all procedures and forms, to which they have ongoing access via the organisation’s

intranet.

Procedures are revised regularly, under strict supervisory control, and according to the wishes of all

parties involved. Atlas will provide adequate resources to continually review and improve business

processes.

Atlas Professionals’ Integrated Management System is independently audited annually to ensure the

effectiveness of the system, the level of compliance with the documented system, and to identify

opportunities for improvement.

Atlas Professionals actively seek performance feedback from customers and address opportunities for

improvement that are identified. Results and recommendations are dealt with between the Client and an

Atlas representative.

The Quality Policy is reviewed annually by senior management, for continued suitability.







Appendix 7: Code of Conduct

Introduction

With the increasing size of our company, both organically and through acquisitions, we recognized the need

to express our commitment for a high quality “brand” based on a combination of entrepreneurship and high

business ethics. This Code of Conduct (“Code”) includes the Atlas Professionals Values and Principles that

apply in all our decisions, thereby ensuring that we make the right ethical choices in our daily business. In

the Code we use the name ”Atlas Professionals” for Atlas Professionals B.V. and for each of the companies

in the Atlas Professionals group.

This Code helps us to foster trust within the company and among our staff members, professionals and

other stakeholders. In addition, the Code helps to foster trust in Atlas Professionals from our clients and

business partners.

We consider it of vital importance that all Atlas Professionals staff members and professionals thoroughly

understand and apply in practice the Atlas Professionals Values and Principles as set out in this Code and

conduct business consistent with these Values and Principles. This Code will provide you with sufficient

guidance to be able not only to understand the true meaning of the Values and Principles that define us,

and the underlying philosophy and intention, but also to apply these consistently.

We very much encourage an open and straightforward culture. Should you have questions about the right

behavior in certain specific situations, please do speak up and address these questions to your supervisor

or manager or, if this does not work, to one of the Management Board members . We refer to the separate

Fraud Rules and Whistleblower Policy and the reporting lines mentioned therein in case your question or

concern considers a suspected irregularity as described therein.

We hope the Code meets your expectations and we thank you for your continued entrepreneurship,

professionalism, integrity and excellence.

Management Board:

René Neelissen (CEO) Marcel Burghouwt (CEO) Peter Wit (COO)

Hoofddorp, April 2019





Our Values

Our mission is to offer a complete range of specialist recruitment & HR services in the Energy and Marine

industries. Atlas Professionals is a global player serving these markets worldwide and develops ongoing

relationships by carefully maintaining its Values and Principles.

In everything we do, we follow our carefully selected seven Values:

We know our business

We are experts. We know our clients, their businesses, our professionals and our businesses. We know

and understand the details, which count most.

We conduct business with integrity

We treat each other with respect. We adhere to and follow local laws and regulations. Health and safety,

whilst respecting the environment, has our highest priority.

We are pro-active

We take initiatives. We communicate with clients and candidates as much as possible. We listen and we

act.

We keep our promises

We honor our agreements. We do not promise things we cannot deliver.

We are responsible and accountable

We are ambitious. We take calculated risks and take responsibility for our actions and results.

We are open and straightforward

We encourage open communication. We are straight to the point. We listen to each other and are not afraid

to give our opinion.

We invest in people

We educate our professionals. We want to excel and stimulate them to improve their skills.

Our success flows from the trust we enjoy from our key stakeholders (staff members, clients, professionals,

shareholders, business partners and suppliers), governmental and regulatory bodies and the communities

within which we operate.





Our Principles

We operate worldwide, recognise the rule of law within all jurisdictions and support appropriate

internationally accepted standards. The following Business Principles reach beyond our legal obligations

and establish our relationship with society.

We all make decisions on a daily basis and hence make decisions in difficult situations. By making the most

appropriate decision in a given situation, you should always consider if the outcome of your decision may

affect Atlas Professional’s reputation and brand and if your decision is in line with this Code.

Staff members and professionals

We pursue equality of opportunity and treatment and diversity through our employment policies and we

encourage our staff members and professionals to reach their full potential through training and

development.

Impact of our decisions

We safeguard the continuity of Atlas Professionals and we pursue a healthy economic return on capital.

However, when making economic decisions, we regard the impact of these decisions on our stakeholders,

including society and the environment. We extend the same respect and courtesy to our clients.

Clients

We are driven to achieve superior results for our clients through exceptional service delivery and we

recognise that our clients' success depends upon employing the right people in their organisations. In

recognition of their reliance upon us, we strive to understand and respond to our clients' needs, to introduce

those professionals most likely to meet those needs and to enhance our clients' value to their own

stakeholders. In making introductions, we are committed to rewarding our clients' trust through the highest

achievable professional and ethical standards.

Professionals

We understand that finding jobs is an important task in society that carries with it duties of care and

professional behaviour. We will match each professional's needs and objectives with those of our clients

and we respect our obligations of confidentiality to professionals. We recruit, train, develop and retain the

best talent in our industry.

Communication

We expect our staff members and professionals to communicate transparently and honestly with our clients,

professionals, business partners, suppliers and governmental and regulatory bodies, within the legal

framework of privacy and confidentiality.





Human rights

Our relationships with staff members, clients, professionals, shareholders, business partners, suppliers and

the communities within which we operate are based upon respect for individuals and their human rights. We

do not discriminate on the grounds of religion, belief, political opinion, race or sex or any other grounds

whatsoever.

Personal conduct; integrity; no fraud or corruption; no conflicts of interest; anti-trust compliance

All our staff members and professionals are expected to act with honesty, integrity and fairness and not to

be involved in any fraudulent activity (reference is made to the Atlas Professionals Fraud Rules). The offer

or acceptance of any form of bribery is prohibited, including facilitation fees. Hospitality, gifts and improper

offers or payments to third parties or to government officials that seek to induce or reward improper

performance, or might appear to place any person under an obligation, are prohibited. All Atlas

Professionals staff members and professionals will adhere to the highest ethical and legal standards in

business dealings throughout the world. Conflicts of interest that interfere with proper performance or

independent judgment are prohibited. Each staff member or professional must report any potential conflict

of interest to his supervisor or manager or, where appropriate, to one of the Management Board members .

When dealing with our competitors, we are careful not to discuss topics that could violate competition laws.

The use of agreements and understandings, which have as their object or effect the elimination, prevention,

restriction or distortion of competition, is prohibited. All staff members and professionals are forbidden from

engaging in any practices that violate competition laws.

Community

We firmly believe that finding jobs is a vital benefit to society. In addition, we will invest in our communities,

including direct initiatives through charities to improve the employment prospects of the disadvantaged.

Health and safety

We will conduct our operations in a manner that strives to safeguard the safety of all staff members,

professionals and the public.

Public authorities

We will not make political donations or support party political interests.





Appendix 8: Whistleblower Policy

Introduction

Together with the introduction of the revised Atlas Professionals Code of Conduct (“Code”) and the new

Atlas Professionals Fraud Rules (“Fraud Rules”) we have again confirmed that we consider it of vital

importance that all Atlas Professionals staff members and professionals thoroughly understand and apply

in practice the Atlas Professionals Values and Principles as set out in the Code, the Fraud Rulesand conduct

business consistent with the Values and Principles of Atlas Professionals.

We very much encourage an open and straightforward culture. We consider it important that our staff

members and professionals may adequately and safely report any suspected irregularity at Atlas

Professionals. We can only grow and improve as an organization if we are open and honest with one

another. Therefore, you are encouraged to report any suspected irregularity. Doing so helps Atlas

Professionals to maintain a culture of transparency and integrity. It also helps us to address potential

problems before they can negatively affect Atlas Professionals or our valued stakeholders.

“Whistleblowing” means that any Atlas Professionals staff member or professional in good faith and on

reasonable grounds confidentially reports a suspicion of any irregularity relating to Atlas Professionals staff

members or professionals. This may include a criminal offence, including fraud, a violation of laws and

regulations, including safety and environmental regulations, an intentional provision of incorrect information

to public bodies, or an intentional suppression, destruction or manipulation of information regarding any of

the aforementioned, in each case if the public interest is at stake.

This policy does not apply to personal complaints of a staff member or a professional, for example, relating

to working conditions, conflicts with colleagues or other job related issues. Such complaints shall at all times

be dealt with by the individual’s supervisor or manager.

Management Board

René Neelissen (CEO) Marcel Burghouwt (CEO) Peter Wit (COO)

Hoofddorp, April 2019





How do you report a suspected irregularity?

If you have reason to believe that a suspected irregularity has occurred, you first have to follow the internal

reporting procedure and report the suspected irregularity to your supervisor or manager. In many cases,

they may be able to agree a way of resolving your concern quickly and effectively. In some more serious

cases, or if you feel your supervisor or manager has not addressed your concern completely or adequately,

or you prefer to raise it with someone other within Atlas Professionals than your supervisor or manager for

any other reason, you should contact the Whistleblower Officer or one the Management Board members .

In case a Management Board member is involved in the suspected irregularity, you should contact the

chairman of the Atlas Professionals Supervisory Board (details to be obtained from the Whistleblower

Officer). In all cases, you are entitled to consult with an external professional adviser, subject to a duty of

confidentiality. Only in very exceptional and serious situations, you may choose to report a suspected

irregularity externally.

We do not encourage staff members or professionals to make a report anonymously, so as to allow

appropriate follow-up questions and investigation. If, however, you nevertheless wish to report

anonymously, you can do so by sending an email to the confidential email account

[email protected], which is monitored by the Whistleblower Officer. Should you want

to report anonymously, you will be required to create a new external email account, such as a Gmail account.

This can be done through https://mail.google.com and following ‘create an account’.

What will happen when you report? Confidentiality, Investigation

Any report made in good faith will be treated as strictly confidential, subject to local law and regulations. The

report and all relevant information will be made available to the Whistleblower Officer and one of the

Management Board members , unless the report concerns a Management Board member . All reports made

in good faith will be investigated. All staff members and professionals are expected to cooperate fully with

an investigation or inquiry, within the limits of applicable law. The position of any staff member or

professional who has in good faith reported a suspected irregularity in accordance with this policy shall not

be affected in any way as a result of making the report.

How will your report be handled?

The immediate actions taken by Atlas Professionals in response to a report under this policy will depend on

the nature of the issue raised. Initial inquiries will be made to determine whether an investigation is

appropriate, and the form that it should take, if applicable. Some concerns may be resolved without the

need for investigation. The Whistleblower Officer will inform you about the outcome of the assessment.

In case a further investigation is needed, the investigator(s) may seek additional information from you. We

will aim to keep you informed of the progress of the investigation and its likely timeline for resolution,

however, sometimes the need for confidentiality may prevent us giving you specific details of the

investigation. All necessary precautions will be taken to ensure personal data is protected from unauthorized





access and processing. Where necessary, Atlas Professionals will take appropriate corrective or disciplinary

action.

If you are not happy with the way in which your report has been handled, you can raise this directly with one

of the Management Board members or, in case the report concerns a Management Board members , with

the chairman of the Atlas Professionals Supervisory Board.

External reporting

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any

suspected irregularity at Atlas Professionals, as defined in the Introduction. This includes any whistleblower

concerns that relate to the actions of a staff member, professional, client or supplier. In almost all cases, it

should not be necessary to alert anyone other than those within Atlas Professionals identified in this policy.

However, if you consider making a report externally, we strongly encourage you to seek external

professional advice before doing so. At all times, the interests of Atlas Professionals shall be taken into

account. Information about the possibility of external reporting in your country can be obtained from the

Whistleblower Officer (in the Netherlands: the act Wet Huis voor Klokkenluiders applies).

What will happen when you make a report in bad faith?

Atlas Professionals will not tolerate reports made in bad faith. Any staff member or professional making a

report, with the intention to be misleading or false, will be subject to disciplinary action as deemed

appropriate, including potential termination of employment.

Review and Contacts

The Management Board will review this policy regularly. Staff members and professionals are invited to

comment on this policy and suggest ways in which it might be improved. Comments, suggestions and

queries should be addressed to the following contacts:

Whistleblower Officer: [email protected]

CEO’s: [email protected] or [email protected] or

[email protected]





Appendix 9: Fraud Rules

RULES RELATING TO REPORTING OF SUSPECTED FRAUD

I. Introduction

1. These rules (“Fraud Rules”) are rules relating to the reporting of suspected fraud. These Fraud

Rules apply to staff members and professionals of Atlas Professionals, to the Management

Board and to the Supervisory Board (each as defined below).

2. Atlas Professionals is committed to conduct its affairs with integrity and honesty and to protect

the assets with which it has been entrusted. As evidenced by the Code of Conduct, Atlas

Professionals demands the highest standards of integrity and ethical behaviour of all staff

members and professionals.

3. Further to the general principles of the Code of Conduct, these Fraud Rules underline the

commitment of Atlas Professionals to maintain an anti-fraud culture and to adhere to the highest

ethical standards in all of its affairs. Atlas Professionals believes that the maintenance of a

culture of integrity and honesty is a key element in preventing fraud.

4. The Management Board considers it important that staff members and professionals may

adequately and safely report suspicions of fraud at Atlas Professionals or relating to Atlas

Professionals, whether generally on the basis of the Code of Conduct or pursuant to the

Whistleblower Policy.

5. The Management Board is responsible that the staff members and professionals are made aware

of these Fraud Rules. Each staff member or professional in turn has the responsibility to

familiarise himself/ herself with the content of these Fraud Rules.

6. Any staff member or professional who is unclear as to these Fraud Rules or what may constitute

fraud must seek guidance from the Compliance Officer (as defined below).

II. Definitions

In these Fraud Rules the following capitalised terms shall have the following meaning: - Code of Conduct: the Atlas Professionals Code of Conduct, as the same may apply from

time to time;

- Compliance Officer: the person designated by the Management Board pursuant to the

Code of Conduct to act in that capacity for Atlas Professionals (currently Mrs. Aimee

Kamphuis);

- Management Board: the Management Board of Atlas Professionals, currently being Rene

Neelissen, Marcel Burghouwt and Peter Wit;





- Manager: the person to whom a staff member or professional directly reports;

- Reporting Staff Member or Professional: any staff member or professional making or

having made a report of any suspected fraud under these Fraud Rules;

- Supervisory Board: the Supervisory Board of Atlas Professionals;

- Whistleblower Policy: the Atlas Professionals policy relating to Suspected Irregularities

(Whistleblower Policy), as the same may apply from time to time.

III. Fraud; Risk Areas; Prevention

1. Each staff member or professional must at all times be alert to the possibility of fraud within Atlas

Professionals. There is no legal definition of fraud which applies equally in all jurisdictions in

which Atlas Professionals is active. The term fraud generally encompasses different types of

irregularities.

2. Examples of fraud are embezzlement, theft, money laundering, forgery, misappropriation, false

representation, concealment of material facts, tax evasion, corruption, market abuse and

extortion, but also wrongful or improper use of the resources of Atlas Professionals or misuse of

rank, position or authority.

3. Areas of particular risk for Atlas Professionals and thus of particular vigilance on the part of each

staff member or professional are:

• financial reporting irregularities: any act or omission of a material nature that may lead to

inaccurate financial accounts and/or financial reporting,

• corruption: the offering or acceptance of a benefit that is not legally due for the commission

or omission of an act in connection with a position of employment,

• release of confidential information of or regarding Atlas Professionals, including price-

sensitive information, and

• Cybersecurity incidents, such as phishing mails or data leaks.

IV. Duty to report suspected fraud; Procedure

4. Subject to Article VII, any staff member or professional shall report a suspected fraud to his

Manager and/or in accordance with the procedures set out in the Whistleblower Policy. A

Manager shall immediately inform the Compliance Officer of each suspected fraud of which

he/she receives a report. The procedures set out in the Whistleblower Policy shall apply.

5. Any staff member or professional who suspects fraud may never start his/her own investigation

or make contact with the staff member or professional whom he/she suspects of fraud.





6. The report by any Reporting Staff Member or Professional shall provide a description of the

suspected fraud; the report may include:

• the names and locations of the persons or entities involved;

• the approximate dates and time frame of the relevant facts;

• the location and description of any potentially relevant documents, data or records;

• the names and locations of other persons who may have information regarding the

suspected fraud;

• the basis for the knowledge of the Reporting Staff Member or Professional;

• an estimate of the amount of funds at risk;

• any concern of the Reporting Staff Member or Professional regarding possible reprisals or

personal security.

7. In addition, any staff member or professional must immediately notify the Compliance Officer if

he/she has any suspicion about any actual or potential money laundering activity. Staff members

or professionals must look out for warning signs of money laundering, such as requests to:

• pay funds to a bank account in the name of a different third party or outside the country of

operation;

• make payments in a form outside the normal terms of business;

• split payments to several bank accounts;

• overpay.

Warning signs can also be payments to Atlas Professionals:

• from multiple bank accounts;

• from foreign bank accounts when not a foreign counterparty;

• received from other third parties; or

• made in advance when not part of normal terms of business.

V. Investigation process

8. Immediately after receiving a report of suspected fraud, the Management Board shall start - or

shall cause the Compliance Officer to start - an investigation into the suspected fraud. The

purpose of the investigation is to establish all relevant facts and circumstances related to the

suspected fraud.

9. Suspected fraud will be investigated in an independent, open-minded and professional manner,

with the aim of protecting where reasonably possible the interests of both Atlas Professionals

and the individual being investigated. Suspicion shall not imply or be considered as guilt to be

proven.

10. It is important to ensure that evidence is not contaminated, lost or destroyed. Atlas Professionals

may therefore take appropriate steps to secure physical assets, including computers, laptops





and mobile devices and any records therein, and all other potentially evidential documents. Atlas

Professionals will seek to ensure that appropriate controls are introduced to prevent (further)

loss.

11. The investigation may extend to the contents of files, desks, cabinets and other storage means

(digital and otherwise) and facilities on the premises of Atlas Professionals, without the prior

knowledge or consent of any staff member or professional who may use or have custody of any

such means or facilities, provided that such examination reasonably falls within the scope of the

investigation of the suspected fraud.

12. Where initial investigations reveal that there are reasonable grounds for suspicion, and to

facilitate the ongoing investigation, it may be necessary and appropriate for Atlas Professionals

to suspend, re-assign or transfer any staff member or professional against whom a report of

suspected fraud has been made. Suspension shall not imply or be considered as guilt. Where

initial investigations reveal that there are reasonable grounds for suspicion, Atlas Professionals

may notify law enforcement authorities and/or regulatory agencies, if this is considered

necessary or appropriate.

13. If Atlas Professionals considers it to be in its interest, it may grant confidentiality to the Reporting

Staff Member or Professional or to a witness. This may be necessary to facilitate cooperation

and/or to protect any such person against reprisals. Atlas Professionals will not pay a witness

for information. Atlas Professionals may, however, pay or reimburse reasonable expenses

incurred by a witness in connection with his or her cooperation to the investigation.

VI. Findings and action

14. The Compliance Officer will lay down the conclusions of the investigation in written findings (the

“Findings”). The Compliance Officer will submit the Findings to the Management Board. The

Findings may be based on various elements, including (but not limited to):

• the most reliable factual information available and reasonable inferences and conclusions

drawn from established facts;

• to the extent feasible, documents and (electronic) data;

• to the extent feasible, statements from witnesses;

• information that has been corroborated to the extent possible by other reliable sources,

including other witnesses, documents or data; and

• other credible information.

15. Having considered the Findings, the Management Board may conclude that there is not sufficient

credible information to substantiate the report of suspected fraud. In this situation, the





investigation will be closed. The Management Board may re-open any investigation if credible

new information is received or if it is warranted by other circumstances.

16. Having considered the Findings, the Management Board may conclude that there is sufficient

credible information to substantiate the report of suspected fraud. The Management Board may

then promptly take any appropriate action, utilising all disciplinary and/or legal options at its

disposal, including notifying law enforcement authorities and/or regulatory agencies and/or

(immediate) termination of the employment contract of any staff member or professional

involved.

17. The Management Board may also take appropriate action if the Findings indicate that the

Reporting Staff Member or Professional or any other staff member or professional involved in

the investigation made a knowingly false statement, or otherwise attempted to hinder, impede or

obstruct the investigation. Such action may include notifying law enforcement authorities and/or

regulatory agencies and/or (immediate) termination of the employment contract of any staff

member or professional involved.

18. Subject to the overall interests of Atlas Professionals, the Management Board may inform the

Reporting Staff Member or Professional of the position of Atlas Professionals with regard to the

suspected fraud and the action taken.

VII. Reporting to the Chairman of the Supervisory Board

19. The Reporting Staff Member or Professional may comply with his duty under Article IV.1 by

making a report of a suspected fraud to the chairman of the Supervisory Board rather than to the

Manager, the Compliance Officer, the Management Board or the Whistleblower Officer, if the

suspected fraud concerns:

• a member of the Management Board or the Compliance Officer;

• a situation which may give reasonable cause for the Reporting Staff Member or Professional

to fear that his/her report would lead to countermeasures directed at him/her; or

• an earlier report of suspected fraud substantially involving the same facts and

circumstances did not result in any action being taken.

20. Immediately after receiving a report of suspected fraud, the Supervisory Board shall start an

investigation into the suspected fraud. Articles V and VI will apply mutatis mutandis.

VIII. Confidentiality

21. The Reporting Staff Member or Professional will keep the report confidential.





22. All information provided in connection with the report will be considered confidential and will not

be disclosed to or discussed with any person other than for the purpose of conducting the

investigation, deciding upon the Findings, reporting to the appropriate authorities or taking

appropriate action.

23. Subject to applicable law, no information shall be provided, directly or indirectly, by the Reporting

Staff Member or Professional to persons outside Atlas Professionals without the prior written

consent of the Management Board or, as the case may be, the chairman of the Supervisory

Board.

IX. Losses

24. The recovery of losses is an important objective of the suspected fraud investigation. Atlas

Professionals will seek to quantify the amount of any loss and will seek recovery of any loss in

each relevant case. Atlas Professionals will also examine whether further loss can be prevented.

X. Management Reporting regarding Fraud; Informing the external auditor

25. The Management Board will periodically, at least twice per calendar year, make a report to the

Supervisory Board regarding all suspicions of fraud reported and all fraud investigations

conducted.

26. The Management Board will periodically, at least once each calendar year, discuss with the

Supervisory Board the Management Board’s assessment of specific fraud risks (including

possible control deficiency considerations) and the measures the Management Board has taken

and/or proposes to be taken in response to those fraud risks.

27. Atlas Professionals will make available to the external auditor all information referred to in

Articles X.1 and X.2.

28. Atlas Professionals will periodically, at least twice per calendar year, make available to HAL all

information referred to in Article X.1, in the format required by HAL.

XI. Effective date

These Fraud Rules took effect on 1 April 2019.





Appendix 10: Environmental Policy



It is the policy of Atlas Professionals to maintain care for the environment, including the prevention of

pollution, to continuously improve environmental management, to create environmental awareness and to

enhance environmental performance. It is the policy of Atlas Professionals to “Reduce, Reuse & Recycle”

wherever possible. Atlas Professionals is committed to fulfilling its compliance obligations in relation to the

Environment.

The safety of operations including environmental discharge, shall be monitored and reviewed by senior

management on a quarterly basis. Environmental impact shall be reviewed on an annual basis, with

objectives and targets tailored to address significant environmental aspects.

Environmental Health & Safety objectives and targets are set and reviewed annually, to measure

performance, and identify opportunities for improvement. Atlas Professionals aim to achieve its

Environmental objectives to the full satisfaction of clients, employees and professionals.

Atlas Professionals has agreements in place with clients to ensure that professionals have the means to

work in a manner that maintains care for the environment within their scope of operations. Atlas

Professionals aims to prevent accidents and cases resulting in environmental damage. . In order to

maintain a safe and healthy working environment, both the employees working at our Client’s sites and

office staff are required to conduct their duties in a safe and sound manner, maintaining respect for the

environment and abiding by all applicable rules and regulations.

Atlas Professionals recognises that due to its activities as a service provider, the environmental

regulations cannot be limited to the Atlas Environmental Policy alone, but must include Client’s

requirements and instructions in the field of Environmental management.

Atlas Professionals values the importance of employees being competent to carry out their tasks as

required by our Clients, in an environmentally friendly manner. Atlas therefore aims to obtain and pass on

to its employees, any available information and instruction to assist its employees in achieving this.

The Environmental Policy is reviewed annually by senior management, for continued suitability.







Appendix 11: Corporate & Social Responsibility Policy



Atlas Professionals aims to manage its social and economic impact on local stakeholders and

communities where it operates, by conducting assessments at the request of its clients, allowing full

participation by clients, making any results available to clients on request.

Atlas Professionals respects the Human Rights of individuals by not engaging personnel under the age of

18; by not using forced labour in any form (prison, indentured, bonded or otherwise); does not

discriminate against any employees on any ground (including race, age, political views, religion, disability

or gender); does not engage or support the use of corporal punishment, mental, physical, sexual or verbal

abuse and does not use cruel or abusive disciplinary practices in the workplace, does not retain original

identity papers and does not restrict the freedom of the individual; does not require personnel to deposit

money, and does not require personnel to pay fees for our services.

Atlas pays each employee at least the local minimum wage, and legally mandated benefits; complies with

laws on working hours and employment rights in the countries in which it operates; and is respectful of its

employees right to join and form independent trade unions and freedom of association.

Atlas Professionals conducts business with integrity, and is responsible and accountable for its actions.

The Atlas Professionals Code of Conduct ensures that employees make the right ethical choices which

reflect Atlas’ identified values and principles. Atlas prohibits bribes of any form, and ensures compliance

with anti-corruption principles. The Atlas Whistleblower policy enables employees to report any suspected

irregularities within Atlas, helping to maintain a culture of transparency and integrity.

The CSR Policy is reviewed annually by senior management, for continued suitability.

