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Commitment

Management at all levels of J.S. West and Companies will be actively committed to the achievement of health, safety and environmental excellence in the conduct of our business. Every manager shall demonstrate commitment and provide adequate resources to achieve this goal and follow these principles. Through communication with our employees, it is our goal to ensure that the company’s commitment to health, safety, and environmental excellence is reflected in day to day operations.

Organization

We will maintain and enhance a companywide organizational structure and culture that recognizes and encourages the full and active participation of all employees in the systematic management of health, safety, and environmental issues. We will also enhance a culture that allows for the transfer of information and best practices across all levels of the company.

Achievement of health, safety, and environmental excellence depends heavily on the continuing participation and accountability of management. Responsibility for health and safety and the protection of the environment is a matter of corporate policy and is a matter of law, with potentially severe consequences for failure to comply. Management at all levels is responsible for ensuring that operations are conducted in accordance with this policy and that appropriate health, safety, and environmental programs, procedures and systems of work have been developed and implemented for each facility and operation under their supervision.

We will develop, implement and continuously improve effective health, safety, and environmental management systems and develop standards that reflect best industry practices. We will extend our knowledge by conducting or supporting research where practicable on the health, safety, and environmental effects of our products, work practices, processes, services, and waste materials.

We will ensure that potential health, safety, and environmental risks associated with all our activities are assessed as early as is practicable in order to minimize and manage adverse effects and to identify opportunities for improvement. J.S. West & Companies will strive to eliminate or manage any foreseeable hazards which may endanger health, safety or the environment.

We will operate to standards that will comply with the requirements of appropriate national and international legislation and codes of practice and will strive beyond compliance and recognize these principles as a valued way of life. We will participate with governments and others in creating responsible laws, regulations, and standards to help safeguard the workplace, community, and environment. Where no regulatory controls exist, we shall adopt and impose our own health, safety and environmental standards in accordance with relevant industry standards of practice.

Training is an essential element of HSE excellence. Health, safety, and environmental managers and staff will be qualified by reason of education or experience to discharge their responsibilities and will participate in a program of continuing professional development. In addition, the company is committed to provide training and development on health, safety, and environmental matters that are appropriate to each employee’s job duties and responsibilities. The management of each of the operating groups shall take steps to assure that appropriate training is conducted on a regular basis.

We will comply with applicable legal requirements and where the company’s standards are more stringent apply those standards to minimize the environmental impact of our activities including emissions to land, air, and water.

J.S. West & Companies believe that effective HSE management is good business. As in other areas of our business, the company is committed to continuous improvement of HSE management practices. We believe that adherence to these ten principles will assist us in achieving our objectives of HSE excellence. Each year we will identify specific goals against which we will measure our progress toward HSE excellence.

Effective management requires on-going assessment and review to determine whether the health, safety and environmental policy is being appropriately implemented. Accordingly, an on-going assessment, self-evaluation and audit program shall be implemented and maintained for operations throughout the company. The objective of this program is to provide management and the Board of Directors with verification that operations are in compliance with laws, regulations, company policies and standards and to facilitate the spread of best practices throughout the company’s operations.