Subject : Safety Starts at the TOP

Document no : 1 Date of effect : 15-Feburary-2015

Prepared by : Raul
McFaddin
Approved by : JD Nielsen Controlled by : Antonio Perez

SECTION 1 Objective and Scope

This document establishes the methods of planning, analysis and operations for
the health and safety of APM Terminals Lazaro Cardenas employees, contractors
and visitors. It also includes the commitment from the company to comply with
legal requirements, shareholder requirements and the values of the APMM
Group.

1.1 Introduction

APM Terminals Lazaro Cardenas health, safety and environmental guidelines are
based on a sincere desire to eliminate all incidents that result in personal injury to
our employees, occupational illness, equipment damage, property damage and
environmental damage or pollution. This commitment is based on a respect for
each employee and customer as well as sound business practices and regulatory
requirements. We will also strive to protect the general public insofar as they
come in contact with or are affected by our operations.

Accidents can be controlled through good management, active employee

involvement, intervention and a focus on process improvement. Toward this end,
terminal management and supervisors will be expected to understand, intervene
and seek to improve APM Terminals Lazaro Cardenas safety and environmental
program and requirements as they apply to the operation and maintenance of
facilities and equipment and work to achieve the terminal safety goals. All
employees will be required to perform their job properly in accordance with
established procedures. Trucking community customers, contractors and visitors
also have a responsibility to adhere to established rules and to promote safety and
environmental awareness while on this terminal. These guidelines, in conjunction
with the APM Terminals Corporate Safety, Health and Environmental Guidelines
and related legislation will provide a basis for APM Terminals Lazaro Cardenas
to establish and maintain a safe and environmentally responsible workplace.

The purposes of the HSE guidelines are to provide the answers to safety and
environmental questions. It will cover accident, injury and illness prevention,
accident investigation, accident and damage reporting, safety rules, safety
awareness, hazard identification, training, evacuation plans, emergency contacts,
record keeping, employee participation and leaking container procedures. All
terminal personnel are encouraged to make suggestions and recommendations for
improvement to this document to the APMTLZC Safety, Security and
Environmental staff.

JD Nielsen

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Subject : Safety Starts at the TOP
Document no : 1 Date of effect : 15-Feburary-2015
Prepared by : Raul
McFaddin
Approved by : JD Nielsen Controlled by : Antonio Perez

APM Terminals, Lazaro Cardenas.

1.1.1 APMT Global Safety Policy

This policy is based on the four core safety principles as defined by APM
Terminals Global Senior Management Team:

We do not accept that accidents and injuries are part of our business, and will not
compromise safety for profit or production.
We hold our leaders accountable for the safety in our business. We expect our
managers and supervisors to provide effective leadership in safety whilst
recognizing that good safety behaviour is the responsibility of all those who work
for us.
We strive for a no-blame culture but cannot accept intentional neglect or
disregard for our safety rules.
Our main focus is on prevention of accidents before they happen by proactive
risk assessment and mitigation through the hierarchy of controls.
All APMT companies, contractors and joint ventures must manage safety in line
with this policy irrespective of whether it concerns our own employees,
contractors or any other external parties working on or visiting any of our
facilities.
If a non-controlled APMT company is unable or unwilling to apply this policy
APMT Senior Management Team will decide on our continued involvement.

Page 2 of 3
Subject : Safety Starts at the TOP
Document no : 1 Date of effect : 15-Feburary-2015
Prepared by : Raul
McFaddin
Approved by : JD Nielsen Controlled by : Antonio Perez

As a consequence of this policy every APMT company must:

• Have a systematic approach to safety to ensure continuous performance
improvement
• Comply with local laws and regulations as well as APMT Global
Standards
• Ensure all employees are competent to do their tasks, and provide
adequate safety training as well as given freedom/obligation to intervene
in unsafe situations
• Set targets for continuous improvement and measure, appraise and report
on performance
• Report observations, near misses and incidents with a special focus on
high severity and high potential incidents
• Investigate incidents to determine root causes, identify learnings and
apply proper actions to prevent recurrence
• Share safety performance and learnings with staff, suppliers, and
customers so they can contribute to a safer work environment
• Require contractors to manage safety in line with this policy and ensure
proper supervision
• Ensure adequate resources are allocated to perform these tasks
• Include safety performance as part of employee appraisals

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