EHS Roles and Responsibilities

Contents:

Introduction 3

Country EHS Policy 4

1.0 EHS Responsibilities 5

1.1 All Employees 5

1.2 CEO/Managing Director 6

1.3 Country Division Leads/Corporate Function Heads/SRE 7

1.4 BU Heads/Line Managers/Project Managers 8

1.5 Site Managers & Supervisors 9

1.6 Country Head of EHS 10

1.7 EHS Team(Division EHS/BU EHS/SRE EHS) 12

1.8 EHS Representatives(Project Site/Manufacturing Site EHS) 14

INTRODUCTION

Siemens AG establishes EHS principles and delegate’s responsibility for implementation of

environment, health and safety (EHS) and compliance with relevant legislation to Siemens Ltd.

It is the responsibility of Siemens Ltd, to meet local legal requirements and comply to the
EHS principles as established by Siemens AG. It is important that responsibility for EHS
across Siemens Ltd. is clearly set out. In this regard the following principles apply:

All Business Division Heads, Business Unit Heads, Corporate Department Heads,
Managers and Supervisors carry responsibility for full compliance in relation to country
specific legislation and are accountable for implementing the global and local EHS
standards for their respective functions. In case there is a conflict between global and local
legislation, then the local legislation will take precedence.

Management and implementation of EHS standards, processes, controls and regulations is

a prime responsibility of line management, from the most senior executive to supervisory
level and all employees.

This document explains the general EHS responsibilities delegated throughout Siemens
Ltd. management structure and includes all employees. This is not an exhaustive
document but is intended to serve as a general conceptual guideline. Related process
documents may be referred to for more details.

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Country EHS Policy

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1.0 EHS Responsibilities

1.1 All Employees

All Employees should be mindful of their responsibilities for ensuring a workplace where
EHS is the top priority. They should engage with both Line Managers and the EHS Team to
ensure that, they are familiar with the EHS management system, and:

a. Demonstrate visible, strong and active EHS leadership, acting as champions for Zero Harm,
Sustainable Future and Wellbeing.

b. Be attentive to working safely, taking reasonable care for the environment and the health and safety of
themselves and others who may be affected by their acts or omissions at work.

c. Co-operate with management to enable duties imposed on Siemens under any EHS law/guideline
to be performed or complied with.

d. Actively participate in the compilation of risk assessments and any other documentation.

e. Ensure housekeeping standards in the workplace are maintained at the highest level.

f. Undertake their work and use equipment safely and responsibly in accordance with training and/or
instructions provided, and immediately report any defects or deficiencies to supervisors/Line Managers.

g. Take personal responsibility to intervene when violations of EHS rules are noticed/occur that could
endanger people, the environment or assets.

h. Report to management any injuries, ill-health, incidents and near misses, and concerns arising out of
work activities, and assist and contribute in determining measures required to prevent recurrence.

i. Be available and transparently, truthfully and diligently participate in incident investigations.

j. At all times ensure that they are fit for the work they will undertake and also deploy people for work who
are qualified/authorized, skilled, experienced and medically fit to perform the assigned duties.

k. Personnel issued with tools/tackles, instruments, construction/installation/testing equipment and

personnel protective equipment (PPE) must use these as per norms/standards or as instructed,
maintain them in good condition and ensure that any defects/shortcomings are promptly reported to
their immediate supervisors so that replacement/repair can be arranged. Personnel should be
reminded that it is their individual responsibility to ensure that they report for work with the appropriate
PPE and equipment as issued/specified/instructed.

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1.2 Chief Executive Officer/Managing Director
The CEO/Managing Director has ultimate responsibility for ensuring, as far as is reasonably
practicable, the implementation of EHS Policy. The CEO/Managing Director will establish
and maintain an effective organisation through the senior management team, which should
ensure compliance to all relevant statutory EHS obligations. The CEO/Managing Director
recognises these obligations, and that EHS forms an integral part of the company’s values,
business and operations. The CEO/Managing Director will:

a. Formally and publicly accept the role to provide visible, strong and active EHS leadership within the
Business Unit, acting as a champion for Zero Harm, Sustainable Future and Wellbeing.

b. Ensure deployment of the management system for EHS, collectively with the Management Team,
putting in place an appropriate and effective organisation, and arrangements to plan, control, monitor
and review the effectiveness of the management of EHS and mitigation of risk to the environment and
people.

c. Endorse the EHS Policies and set specific objectives/ targets to drive continuous improvement in EHS
performance.

d. Allocate appropriate resources for the management of EHS and have competent advice available at all
times. Ensure involvement of all parties, and undertake/assign health and safety tours.

e. Engender a positive mindset & attitude towards EHS through communication, consultation, co-operation.

f. Ensure that employees are engaged in the promotion and achievement of safe and healthy conditions and
protection of the environment. Ensure that they are provided with high-quality training relevant to their role
and that effective monitoring mechanisms are implemented to verify that employees are competent to
undertake their tasks and responsibilities

g. Ensure that all decisions comply to the defined EHS guidelines and legislations

h. Consider EHS requirements when deciding senior management appointments

i. Ensure that all liability is covered by adequate controls and safeguards

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1. 3 Country Division Leads/Corporate Function Heads/SRE
All Senior Management members reporting directly to the CEO/Managing Director have the
responsibility to provide leadership and to promote responsible attitudes towards EHS. Collectively
with the CEO/Managing Director, they will put in place and maintain appropriate arrangements for
the effective planning, organisation, control, monitoring and review of the preventive and corrective
measures. In particular they will:

a. Formally and publicly accept the role to provide visible, strong and active EHS leadership within the
Business Division, acting as a champion for Zero Harm, Sustainable Future and Wellbeing.

b. Support the set up of an effective EHS management system based on a systematic approach to risk to
establish priorities and develop performance standards. This is both for the completion of the risk
assessment(s) and the implementation of preventive and corrective measures. Wherever possible, risks
are eliminated through selection and design of facilities, equipment and processes.

c. Involve employees and their representatives in carrying out risk assessments, deciding on preventive
and corrective measures and implementing those requirements in the workplace.

d. Establish effective means of communication and consultation in which a positive approach to EHS is
visible and clear. Effective communication will ensure that employees are provided with sufficient
information so that control measures can be implemented effectively.

e. Ensure employee competence in EHS by the provision of adequate information, instruction, and training
and its evaluation. Where necessary, this will be supported by the provision of adequate and competent
EHS support or advice.

f. Ensure everyone with EHS responsibilities, understand clearly what they must do to discharge their
responsibilities, and ensure they have the time and resources to discharge them effectively.

g. Implement defined standards to monitor and review EHS performance with respect to leading and
lagging indicators and ensure that EHS requirements and strategic roadmap are met at all times.

h. Monitor how effectively EHS risks are being controlled, and how well they are developing a positive EHS
culture. Such monitoring being undertaken through routine and planned safety tours, inspections/auditing
and adequate investigation of incidents/accidents to ensure that remedial action is taken promptly,
lessons are learnt and long term objectives as per the defined Strategic Roadmap are achieved.

i. Review the whole of the EHS management system including the elements of planning, organization,
control and monitoring (PDCA) to ensure that the whole system remains effective. Ensure necessary
changes are made, in consultation with EHS experts following an update or change in legislation/process.

j. Ensure that all employees, contractors/service providers and visitors follow safety rules where
necessary.

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1.4 Business Unit Heads/Line Managers/Project Managers
All BU Heads/Line Managers have the responsibility to promote responsible attitudes
towards EHS. They are integral to embedding a responsible culture that mitigates risks to
people and impacts on the environment. They must ensure the implementation of the EHS
management system within their area of responsibility. To this end, they must familiarise
themselves with the company EHS Policy and guidelines, integrate EHS into business and
enforce disciplinary action for any violation inappropriate and negligent behavior. They
must:

a. Formally and publicly accept the role to provide visible, strong and active EHS leadership within the
Business Unit, acting as a champion for Zero Harm, Sustainable Future and Wellbeing.

b. Ensure EHS risk assessments are undertaken and appropriate control measures (preventive and
corrective) are put in place to deliver Zero Harm and environment protection. Risk assessments should
be adequately communicated and recorded, and regularly reviewed and updated to take into account
routine, non-routine and new or changed situations.

c. Ensure the requirements of EHS policies and guidelines and any additional standards are fully
implemented and employees are competent, suitably trained and adequately resourced to undertake their
roles/duties by encouraging learning and sharing. Training and information provided will include issues
raised by the risk assessment process and be dependent on the degree of supervision the field
employees and contractors receive.

d. Ensure operational targets are achieved. Promote Zero Harm culture, sustainable practices and
health improvement. Drive and monitor agreed actions and improvement plans.

e. Communicate and review regularly with their team on EHS issues and ensure EHS standards and
consequences are clear to all.

f. Ensure processes are followed; allow their team to report EHS injuries, ill-health, unsafe acts/unsafe
conditions, incidents, near misses and concerns, fully closing out any required actions to prevent re-
occurrence.

g. Act as a proactive role model in EHS practices and devote personal time to EHS. Act decisively to
correct problems when concerns are raised by others.

h. Promote openness, transparency and accuracy in EHS reporting and reward good EHS behaviours (e.g.
Puraskar Scheme). Challenge poor behaviours and working environments and halt activities where there
are uncontrolled risks.

i. Ensure that all EHS considerations are an integral part of the strategic decision-making process,
particularly when initiating strategic, operational or organizational changes.

j. Ensure that the preceding points are equally applied to protect all other stakeholders e.g. contractors,
visitors, customers, temporary workers etc., while working in project sites, own premises or customer
sites.

k. Ensure that all employees, contractors and visitors observe safety rules where necessary. The
Project Manager is overall responsible for EHS compliance in his/her project.

l. Ensure all EHS performance data (including training records, PPE records and health surveillance
details), as required by legislation and internal guidelines are prepared, checked, published and
maintained as applicable.

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1.5 Site Managers & Supervisors
(Including other job roles with particular responsibility for providing supervision):

All Site Managers/Supervisors have the responsibility to provide first-line supervision and direction
to promote responsible attitudes towards EHS. To this end, they must read and understand relevant
company EHS Policy, guidelines, procedures, statutory requirements and consider disciplinary
action for any inappropriate behavior. They must:

a. Formally and publicly accept the role to provide visible, strong and active EHS leadership within their
respective projects/units, acting as a champion for Zero Harm, Sustainable Future and Wellbeing.

b. Promote, communicate and implement any EHS objectives, processes, and guidelines cascaded
by the business/EHS.

c. Ensure risk assessments are carried out, documented, recorded and reviewed periodically in line with
company procedures. Controls identified by Risk Assessment should be implemented, maintained and
monitored.

d. Ensure all personnel operating within their area of responsibility (including contractors & visitors) are
informed/instructed/trained regarding hazards, risks and all other safety-related information such as
emergency procedures, precautions to be taken, safe work procedures etc., as applicable.

e. Ensure all equipment (including those provided by customers, contractors, etc.)are maintained, tested
and used correctly and safely.

f. Ensure good housekeeping standards are maintained at all times and regular workplace inspections are
carried out, whilst taking an active role in the participation of daily walk-through, daily tool box talks, daily
safety briefings, inspections, evaluations and audits. Unsafe acts/unsafe conditions observed during walk-
through, inspections, evaluations and audits must be recorded and corrective/preventive actions taken
promptly. Similarly, Near-misses, if any, must be recorded and corrective/preventive measures
implemented on priority.

g. Ensure participation and involvement of all Employees in EHS issues are actively encouraged and all
feedback, complaints and or breaches are dealt with and documented promptly

h. Ensure all injuries, ill-health, incidents, near misses and concerns within their area are
recorded and investigated in accordance with the company procedures.

i. Ensure suitable EHS records (including training records) are kept and maintained up-to-date

j. Ensure that all employees, contractors and visitors observe and follow safety
rules and procedures at all times, as applicable.

k. Conduct regular EHS performance reviews at site during site progress reviews and ensure that corrective
and preventive actions are implemented expeditiously.
l. Interface with customers to ensure that collateral safety risks are mitigated. The Site Manager is
responsible for overall EHS compliance in his/her site.

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1.6 Country Head of EHS
The Country Head of EHS reports directly to the CEO/Managing Director and has responsibility for
providing strong EHS leadership and for supporting the MD and Senior Management Team to
deliver their collective EHS responsibilities. The Head of EHS will ensure appropriate processes for
the effective planning, organisation, control, monitoring, review and maintenance of the preventive
and corrective measures. The Head of EHS will also promote responsible culture and attitudes
towards EHS on all Siemens operational sites and premises and will:

a. Formally and publicly accept the role to provide visible, strong and active EHS leadership within the
company, acting as a champion for Zero Harm, Sustainable Future and Wellbeing.

b. Encourage and promote responsible culture and attitudes towards health, safety and the environment.

c. Formulate policy, strategies, guidelines, procedures and goals related to EHS. Provide governance &
expert support for implementation of the policy, strategies, guidelines and procedures. Report on the
effectiveness of the policy and ensure that necessary changes are made following a review or change in
legislation.

d. Provide guidance to management on the promotion and implementation of company and business unit
health, safety and environment objectives for continuous improvements, and ensure those objectives
are suitably resourced.

e. Manage the EHS Score Card and KPIs for health, safety and environment and ensure that they are
communicated, updated and reviewed.

f. Provide advice to management on implementation of current and forthcoming EHS legislation and other
EHS related obligations, thereby ensuring compliance of EHS requirements in the various business units
of the company.

g. Ensure that EHS records and reports are completed in a timely manner, communicated as required,
maintained and updated as and when necessary, and are available for scrutiny.

h. Ensure that adequate resources are available to carry out relevant EHS policy and procedures.

i. Provide competent health, safety and environment advice to all employees and customers whenever
required.

j. Ensure that regular safety inspections/evaluations of the premises, factories and/or project sites are
carried out and participate in such inspections/evaluations on a regular basis.

k. Provide assistance for those undertaking accident investigations ensuring the identification of immediate
and root causes, and the implementation of actions to prevent recurrence.

l. Attend Executive Management meetings and report on health, safety and environment performance as
necessary and provide periodic updates to the Company’s Board of Directors, as scheduled by the
CEO/Managing Director

m. Actively ensure participation and involvement of all employees in EHS issues and ensure all complaints
and/or breaches are dealt with firmly without delay

n. Where necessary, liaise and consult with relevant external authorities, customers and organizations.

o. Liaise with customers with respect to EHS performance and the continual improvement of the EHS
management of Siemens.

p. Ensure that internal and external health, safety and environment audits are scheduled and undertaken in
accordance with the business unit QMS and external accreditation bodies as required.

q. Ensure all accidents, incidents and near misses are recorded, reported and investigated in accordance
with the company accident and reporting procedures, and all corrective/preventive actions are identified,
implemented and reviewed.

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r. Ensure Reporting of accidents to relevant statutory bodies as per relevant local laws.

s. Ensure that responsibilities detailed for the EHS teams are fulfilled, and provide support in areas wherever
required.

t. Agree and set objectives/goals for all EHS team members in line with the country/divisional strategies and
goals. Monitor the progress against these goals, strategies and objectives through regular reviews and
staff dialogues.

u. Drive the continual professional and personal development of all EHS team members.

v. As part of the contractor/supplier management process involving qualification and evaluation,

prepare the EHS criteria and provide implementation support.

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1.7 EHS Team (Division EHS/BU EHS/SRE EHS)
The EHS Team provides support and guidance to respective Line Managers and employees
regarding the practical application of the EHS management system. They ensure the effective
planning, organisation, control, monitoring, review and maintenance of the preventive and
corrective measures in their area of responsibility.
They support the organization in embedding responsible culture and attitudes towards EHS, and:

a. Formally and publicly accept the role to provide visible, strong and active EHS leadership within the
Business Unit, acting as a champion for Zero Harm, Sustainable Future and Wellbeing.

b. Provide management and employees with competent EHS advice and action plans.

c. Provide guidance and support to management on the promotion and implementation of the EHS
strategies, procedures, guidelines and goals for continuous improvements.

d. Provide enabling support to management on the implementation of EHS strategies, procedures,

guidelines and legislation to achieve the goals and objectives of the company

e. Ensure that environment and health impacts and significant risks are identified and communicated and
provide active support in mitigating such risks/impacts.

f. Ensure that appropriate measuring and monitoring of EHS issues is undertaken and reported accurately
and transparently.

g. Provide advice and support to Division/BU management on EHS compliance.

h. Participate in the regularly scheduled Division/BU Business Review meetings, as applicable.

i. Provide assistance in the completion of risk assessments where required, and ensure that they are
regularly reviewed and mitigation measures are undertaken.

j. Ensure that all accidents, diseases, dangerous occurrences are reported to the relevant statutory bodies
as applicable within the defined legal framework and time lines

k. Ensure all accidents and near misses are recorded, reported and investigated in accordance with the
company accident and reporting procedures ,and all corrective/preventive actions are identified,
implemented and reviewed

l. Ensure defined KPIs, initiatives, measures and accident and incident statistics are compiled accurately
and reported to the Head of Country EHS and Division CEOs in a transparent and timely manner.

m. Ensure relevant EHS records (e.g. policy documentation, risk assessments, safety data sheets, registers,
fire drills and training records etc.) are maintained and updated as and when necessary.

n. Ensure provision is made for all employees, including temporary staff and contractors, to receive
effective and sufficient training and instruction by way of the company’s EHS competency development
program.

o. Ensure procedures exist in order that all contractors and visitors entering work premises are made aware
of any EHS rules and any other specific requirements and the same are followed.

p. Ensure fire fighting devices are inspected, tested and maintained at regular intervals, and fire
drills/emergency procedures are undertaken at regular intervals with records maintained and corrective
actions taken as necessary.

q. Ensure adequate supplies of effective PPE, as specified by risk assessments, are readily available for
those employees visiting clients’ premises

r. Provide advice and guidance on the usage of PPE, tools and tackles, equipment and devices appropriate
to the nature of work and application.

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s. Act on employee complaints relating to Health, Safety or Welfare, communicate through the relevant
company channels and bring to the attention of the concerned authorities as required.

t. Ensure updated information of legal requirements, hazards in the work place company EHS policy and
procedures

u. Encourage the participation and involvement of all employees in EHS issues and ensure that all
complaints and/EHS breaches are dealt with promptly and effectively.

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1.8 EHS Representatives (Project Site/Manufacturing Site EHS)
EHS Representatives represent their respective locations (Project Site/Manufacturing
Site/Office locations) in matters relating to EHS. They must ensure that they are
familiar with and undertake their functions with diligence, and are expected to:

a. Formally and publicly accept the role to provide visible, strong and active EHS leadership within
the location, acting as a champion for Zero Harm, Sustainable Future and Wellbeing.

b. Ensure that daily EHS inspections/safety walk & talks/tool box talks/specific work related safety
briefings at sites, as applicable, are jointly carried out by the location Heads (Site
Managers/Factory Heads/Location Managers, as applicable).

c. Conduct EHS committee meetings minimum once in a month or as required, to discuss

concerns, plan remedial actions and implement the same.

d. Update and maintain EHS database, KPIs and other related information as required by
BU/Division/Country on a monthly or weekly or daily basis.

e. Assume a lead role in driving the defined EHS objectives with contractors and site staff.

f. Be actively involved in promoting and generating sound EHS practices through feedbacks and
suggestion schemes.

g. Identify and mitigate potential hazards, risks and dangerous occurrences/near misses/unsafe
conditions/unsafe acts.

h. Investigate employee concerns relating to EHS and welfare issues.

i. Encourage employees to take a proactive attitude towards health, safety and the environment.

j. Promote and support health, safety and environment related LEAN project

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