Policy Statement

Our Commitment

The health, safety and well-being of our employees, contractors, clients, visitors and affected communities are fundamental priorities. We also recognise our responsibility to prevent pollution, use resources responsibly and consider environmental impacts across the sectors and activities in which we operate.

This Policy applies to directors, employees, contractors, consultants, project teams and visitors at Company locations and project sites in Uganda and, where applicable, internationally. HSE requirements should be adapted to the nature and risk profile of each activity.

Core Principles

Our HSE Approach

Prevention

Identify hazards and environmental aspects early and apply controls before work begins.

Leadership

Management provides visible commitment, resources and direction for HSE performance.

Competence

People receive information, instruction, training and supervision appropriate to their responsibilities.

Participation

Personnel are encouraged to report hazards, near-misses and concerns without fear of blame.

Compliance

Operations are conducted in accordance with applicable legal, regulatory, contractual and Company requirements.

Improvement

Incidents, inspections, reviews and lessons learned are used to strengthen controls and performance.

Health & Safety

Protecting People

  • Maintain workplaces, equipment, vehicles and facilities in a condition appropriate to safe operations.
  • Identify hazards and assess risks before and during work, particularly where conditions change.
  • Apply the hierarchy of controls, prioritising elimination and engineering or administrative controls before reliance on personal protective equipment.
  • Provide appropriate personal protective equipment (PPE) where risks cannot otherwise be adequately controlled.
  • Ensure personnel receive relevant induction, task-specific instruction, training and supervision.
  • Encourage prompt reporting of hazards, near-misses, injuries, occupational illnesses and unsafe conditions.
  • Investigate significant incidents and implement corrective and preventive actions.
  • Maintain appropriate emergency preparedness and response arrangements for foreseeable incidents.
  • Promote a culture in which every person takes reasonable responsibility for their own safety and that of others.
Environment

Responsible Environmental Management

  • Comply with applicable environmental laws, regulations, permits and project requirements.
  • Identify significant environmental aspects and consider them during planning and decision-making.
  • Prevent pollution and minimise waste, emissions and unnecessary resource consumption where practicable.
  • Promote efficient use of energy, water, fuel, materials and other resources.
  • Handle, store and dispose of materials and wastes responsibly and according to applicable requirements.
  • Encourage responsible environmental practices among suppliers, contractors and partners.
  • Respond promptly to environmental incidents and implement corrective measures.
  • Seek practical opportunities for continuous improvement in environmental performance.
Operational Controls

Risk-Based HSE Planning

The level of HSE planning should reflect the hazards, environmental aspects, scale and complexity of the activity. Higher-risk work may require documented risk assessments, method statements, permits, toolbox talks, competency checks, emergency arrangements, inspections and other controls before work proceeds.

Where an activity presents an unacceptable or uncontrolled risk, personnel are expected to escalate the concern and, where appropriate, stop or suspend work until effective controls are established.

Roles & Responsibilities

Shared Accountability

Leadership

Provide direction, resources and visible commitment and ensure HSE considerations are integrated into decisions.

Managers & Supervisors

Implement requirements, assess risks, communicate controls, provide supervision and monitor compliance.

Project Leads

Ensure project-specific HSE risks, emergency arrangements and environmental considerations are addressed.

All Personnel

Follow procedures, use PPE correctly, report concerns and act responsibly to protect people and the environment.

Contractors & Visitors

Follow applicable Company HSE requirements, site instructions and legal standards while on Company premises or projects.

Reporting & Response

Incidents, Hazards & Emergencies

Accidents, near-misses, occupational illnesses, environmental incidents and unsafe conditions must be reported promptly through the appropriate supervisory or management channel. Serious or potentially serious incidents should be escalated without delay.

Investigations should focus on understanding causes, strengthening controls and preventing recurrence rather than assigning blame. Emergency response arrangements should be communicated to relevant personnel and tested or reviewed as appropriate.

Governance

Responsibility, Review & Improvement

Overall responsibility for this Policy rests with the Managing Director, supported by relevant managers, supervisors and project leadership. The Policy will be reviewed periodically and may be updated earlier following significant incidents, regulatory changes, material changes in operations or lessons from reviews.

Effective date: September 2026  |  Version: 1.0  |  Approved by: Managing Director

Questions about health, safety or the environment?

We welcome concerns and feedback that help strengthen responsible operations.