BASIC PROGRAM ELEMENTS

I. Foundation: Establishing baseline for program
A. Site review by internal personnel, counsel and technical consultants

• Identify significant environmental aspects and impacts
• Assess status of existing program
• Identify areas that that need attention or inquiry

II. Policy

• Articulates company approach to environmental, health, safety and/or social accountability practices internal and external concerns it faces
• Includes elements required under relevant standards

III. Manual

• Policy
• Signed "charge" from top management
• Organization, roles and responsibilities for EH & S management
• Summary of regulatory context and applicable laws
• Institutional and Functional guidance
• Guidance on addressing common issues of concern
• Direction to other documentation
• Framework for defining and coordinating programs to implement policy and manage environmental impacts
• Framework for policy on document retention and document management

IV. Training

• Policy, technical and regulatory sessions on managing operations
  - Management personnel training
  - Train the trainers
  - Plant-level training
  - Continuing regulatory and technical training for internal technical   personnel
  
• Corporate library of training materials (written, videotaped, general, site-specific) including "lending library" function for similar plants

V. Technical support on implementation of program elements

• Internal technical resources
• External technical resources

VI. Self-assessment and validation processes

• Institutional assessment
• Functional assessment
• Internal auditing at local level
• Peer review process
• Database of responses, goals, follow-up needs, issues, highlights and approaches to transfer to other operations
• Processes provide tools for
  - Defining and coordinating controls and programs for implementing
    policy and managing environmental impacts
  - Setting and reviewing goals
  - Evaluating compliance posture
  - Identifying and tracking follow-up
  - Documenting diligence
  - Communicating to external parties
• Validation: Spot checks and peer review process
  - Reports reviewed by division engineers, division vice-presidents,
    general counsel and environmental counsel
  - Division engineers and operations managers visit plants and spot
    check operations
  - Selected follow-up on schedule with regulatory deadlines
  - Plants are peer reviewed on a rotating basis by team of internal
    personnel and external technical and regulatory consultants

VII. Reporting to management and corrective actions

• Management review
  - Quarterly environmental reports
  - National and international environmental compliance management
    committee meetings
  - Reports reviewed by division engineers, division vice-presidents,
    general Counsel and environmental counsel corrective action
    programs
  - Technology transfer of solutions between plants (supported by
    peer review process and periodical visits of division engineers)
  - Division engineers periodically visit to trouble shoot,
    advise and follow-up
  - Technical guidance / recommendations for routine issues
  - "Task force" approach to more significant issues
  - Use of external technical experts as appropriate

VIII. Outreach

• Work with reputable and reasonable environmental and social Non-government organization to identify concerns and provide responses concerning Company's environmental and social performance
• Response library for issues expressed by interested parties and answers developed for them