COMPANY POLICIES

November 2009

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ALAN POULSEN ENGINEERING LTD CODE OF BUSINESS ETHICS

Alan Poulsen Engineering Ltd requires its employees to conduct all activities they undertake on behalf of the company in compliance with all legal, statutory and regulatory requirements including the codes of conduct of any customer with which the company has formal or informal ties. Each employee has an obligation to behave at all times with honesty and propriety as Alan Poulsen Engineering Ltd depends for its business success on its reputation for integrity and on the trust and confidence of everyone with whom it deals. All employees of Alan Poulsen Engineering Ltd are required to: Comply with all Laws and Regulations All laws and regulations, conditions and terms of their Employment contract and those of any customer of Alan Poulsen Engineering Ltd whom we service are to be strictly adhered to at all times. Deal honestly with customers, suppliers, and consultants In negotiating contracts, be accurate and complete in all representations. In negotiating contracts we will comply with all contractual requirements in a fair, honest and ethical manner. Ensure product quality Deliver services which meet all contractual obligations and company quality standards. Providing business courtesies to customers or suppliers Our success in the marketplace results from providing superior products and services at competitive prices. Our company does not seek to gain improper advantage by offering business courtesies such as entertainment, meals, transportation, or lodging. As a gift employees may pay for a reasonable refreshment and/or entertainment expenses for customers and suppliers that are incurred only occasionally, and are not requested or solicited by the recipient. Keep accurate books and accounts All company payments and other transactions must be properly authorized by management and be accurately and completely recorded on the companys books and records in accordance with generally accepted accounting principles and established corporate accounting policies. Employees are not to make false, incomplete or misleading entries. Not misuse the e-mail and the Internet

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Alan Poulsen Engineering Ltd is committed to providing a professional work environment for its employees and has, therefore, introduced strict guidelines on the usage of certain company property. In the case of usage of the companys e-mail and internet systems strict guidelines have been established. The following is unacceptable usage of the e-mail and internet systems: Sending e-mail and Internet material All written material which has any reference of a sexual or offensive nature; All pictorial material which has any reference of a sexual or offensive nature; and All video/film material which has any reference of a sexual or offensive nature. Receiving e-mail and Internet material Storage of any of the above mentioned material on the companys system; and On-forwarding of any of the above-mentioned material to internal or external sources Any breach of these guidelines can lead to summary dismissal of an employee. Maintain a position of trust Outside Outside employment - Alan Poulsen Engineering Ltd employees may not have any employment, consulting, or other business relationship with a competitor, customer or supplier unless with the written permission of the Manager. Outside employment may also constitute a conflict of interest if it places an employee in the position of appearing to represent the company, involves providing goods or services substantially similar to those of the company, or lessens the efficiency, alertness or productivity normally expected of employees in their jobs. Acceptance of business courtesies Employees should never accept anything of value from someone doing business with the company whether or not the gratuity is offered or appears to be offered in exchange for any type of favourable treatment or advantage. To avoid even the appearance of impropriety, employees are not to accept any gifts of promotional items of more than nominal value. Employees may accept meals, drinks, or entertainment only if such courtesies are unsolicited, infrequently provided, and are reasonable in amount. Such courtesies should normally be connected with business discussions.

Created by: Created by Mark Stevens Position: Manager

Date: November 2009

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ALAN POULSEN ENGINEERING LTD DRUG & ALCOHOL POLICY

Alan Poulsen Engineering Ltd has a policy of absolutely no alcohol or drugs in the workplace. Any employee who believes they may be affected by drugs or alcohol in their system must advise Management immediately. A decision will be made that will see you removed from the workplace until you are deemed to be in a suitable condition to continue with work activities. Failure to notify your condition will result in disciplinary action being taken against you. Alan Poulsen Engineering Ltd staff who have access to company vehicles must not under any circumstances be in control of a vehicle at any time under the influence of alcoholic drink or any drug not prescribed by a registered physician for a lawful purpose. Failure to comply with this policy will see immediate disciplinary action taken against you by the Company. Should Alan Poulsen Engineering Ltd provide alcohol to staff as a reward after the completion of any work activity for that day, on the Company premises, staff need to be aware of the policy of Alan Poulsen Engineering Ltd and will be obliged to organize their own transport home. Under no circumstances shall staff drive any vehicle owned by Alan Poulsen Engineering Ltd after consuming any alcohol. Alan Poulsen Engineering Ltd staff are reminded that an accident in a work vehicle is treated as a work place accident, and depending on the severity of any such accident, is punishable by a fine up to and not exceeding $200,000 for the individual and up to and not exceeding $500,000 for the Company. Punishment may also include a prison term up to and not exceeding two years. Alan Poulsen Engineering Ltd staff is asked to work with Management to ensure there are no breaches of this policy, the Health & Safety Act 1992 and Amendments 2002. Your co-operation will ensure our target of an accident free work place is achieved. As you will appreciate, the risks are far too great to ignore.

by Created by: Mark Stevens Position: Manager

Date: November 2009

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DRUG & ALCOHOL POLICY

I have read or have had the Alan Poulsen Engineering Ltd Drug & Alcohol Policy fully explained to me and I acknowledge that I fully understand the contents and implications of the attached policy. I furthermore agree to abide by the contents of this policy. I further agree that should I be suspected of any breach I will be asked to undergo a drug or alcohol test by Alan Poulsen Engineering Ltd. I also understand that I may be subjected to a random drug or alcohol test at any time during working hours.

Staff Signatures: ______________________________ ______________________________ ______________________________ ______________________________ ______________________________ Dated this Day of 20____ _____________________________ _____________________________ _____________________________ _____________________________ _____________________________

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ALAN POULSEN ENGINEERING LTD MANAGEMENT ENVIRONMENTAL MANAGEMENT POLICY

Environmenta Environmental Statement Alan Poulsen Engineering Ltd is committed to environmental leadership, instilling the highest environmental values in all employees and subcontractors, utilizing the best environmental practices in all we do and ensuring the safe removal of waste and the regular health monitoring of employees within the organization. Objective No product to ground therefore there is no damage to the environment. Responsibility All Management and Employees are responsible for protecting the environment and helping reduce Alan Poulsen Engineering Ltds waste consumption. This policy will be regularly reviewed in the light of legislation and company changes. Procedure We will continue to drive down the environmental and health impact of our employees and operations by: Adhering to a no hydrocarbon product to ground philosophy Adhering to a clean and green philosophy Obeying the laws and regulations concerning the environment Consulting, listening and responding openly to our customers, employees, subcontractors and society Integrating environmental goals into our business strategy wherever possible

Waste Alan Poulsen Engineering Ltd has an ongoing policy to reduce waste by: Recycling paper/cardboard, glass and off cut materials wherever possible Returning toner cartridges to the supplier for recycling and/or proper disposal The ongoing monitoring of usage of vehicles, gas, electricity and water

by: Created by Mark Stevens Position: Manager

Date: November 2009

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ENGINEERING ALAN POULSEN ENGINEERING LTD SAFE DRIVING POLICY AND PROCEDURES

Preamble The safe operation of Alan Poulsen Engineering Ltd company vehicles and the security of product/services is the prime responsibility of the driver. It is also Alan Poulsen Engineering Ltds commitment to ensure that continuous compliance is maintained for all relevant regulation, risks and client specific requirements. Objectives To eliminate any potential damage or harm to company property, employees and the general public. Responsibilities Position: Administration Manager Maintain driving records and licence details of all employees who are required to drive vehicles for company purposes Vehicle maintenance is maintained Vehicles are operated within the manufacturers guidelines Regular inspections are carried out on the vehicles Monitoring the driving performance of drivers Maintains records of vehicle incident reports

Employees Follow procedures Maintain vehicle records as directed

Procedures Drivers Licence Relevant staff must hold a valid drivers licence of the appropriate type for the vehicles they drive and produce it on request Relevant staff must be medically fit to operate the vehicle Traffic Offences If relevant staff receive a Traffic Offence or other infringement notice in respect of the vehicle, the relevant staff must make a written report to the Manager as soon as is practicable The driver is responsible for the manner in which the vehicle is driven. As such the driver is responsible for any driver-responsible fines imposed as a result of any traffic offence committed while in charge of the vehicle

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Seat Belts Seat belts and traffic laws must be worn/followed at all times Alcohol and Drugs Alan Poulsen Engineering Ltd requires that relevant staff performance be unimpaired by substance misuse whilst on Alan Poulsen Engineering Ltds behalf. Substances such as alcohol, narcotics, and other drugs and medications chemically modify the bodys functions, reducing the ability to drive safely because they impair co-ordination, upset judgment and lengthen reaction time. It is Alan Poulsen Engineering Ltds policy that all drivers of company vehicles have a zero blood alcohol level Relevant staff are advised that as alcohol takes time to be cleared from the body a person may be under the influence of alcohol, not only immediately after drinking, but for some considerable number of hours afterwards It is the employees responsibility to ensure that they do not drive with a blood alcohol level above zero If relevant staff are required to take prescribed medication, they must inform their doctor of their occupation and ask whether any medication prescribed is likely to adversely affect their work duties If relevant staff are required at any time to take regular medication they should report this to their Supervisor/Manager If relevant staff are given prescribed drugs that may affect their ability to drive they must inform their Supervisor/Manager prior to commencing duty so that, if necessary nondriving duties (if available) can be allotted for the duration of the course of medication Care must be taken when consuming non-prescribed medication that this will not adversely affect the staff members ability to perform their work duties. If relevant staff is in any doubt, they should ask their Supervisor/Manager prior to commencing duty Reporting Of Accidents, Incidents and Vehicle Defects Incidents: must be reported to the Supervisor/Manager as soon as practicable. The Supervisor/Manager will advise of the correct forms for the completion and return Accidents: must be reported to the Supervisor/Manager as soon as practicable, with a full personal description given on return to work where the required paperwork is to be completed Vehicle Defects: must be reported to the Supervisor/Manager as soon as practicable

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Security Security of Alan Poulsen Engineering Ltds vehicles and their contents, particularly outside the premises itself, are of the utmost importance The use of company vehicles for other than company business is prohibited unless otherwise authorized by Management Mobile phones and other electrical equipment Mobile communication: The operation of mobile phones and radio telephones, in vehicles whilst the vehicle is in motion is not permitted (except where a hands free kit is used) Hand held radios, RTs and mobile phones must not be used within 8 meters of a Dangerous Goods vehicle. If staff is required to use this equipment they must move away from the vehicle. Care must be taken to ensure that if a phone is used outside the vehicle it is not used in any area that may be subject to vapours

Before entering a Dangerous Goods Terminal, all air conditioning units, radios, CBs, RTs and mobile phones must be turned off. The reason for this is that radio mobile transmitting devices generate electromagnetic fields when in use that can create electromagnetic static electricity sparks to earth

Created by: Mark Stevens Position: Manager

Dated: November 2009

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ALAN POULSEN ENGINEERING LTD PERSONAL PROTECTIVE EQUIPMENT POLICY & PROCEDURE.

Scope and Purpose This standard is applied wherever personal Protective Equipment (PPE) is supplied as a means of protection against hazards. It is also Alan Poulsen Engineering Ltds commitment to ensure that continuous compliance is maintained for all relevant regulations, risks and client specific requirements. Definition Personal protective equipment is where clothing and personal equipment is used to prevent personal injury. Alan Poulsen Engineering Ltd provides to employees personal protective equipment such as gloves, earmuffs or plugs, safety glasses, safety boots, hard hats and Hi-viz apparel as required for the particular work being undertaken. Responsilities Alan Poulsen Engineering Ltd Management must ensure: Appropriate personal protective equipment is provided Employees are appropriately instructed and trained in the use of personal protective equipment and where applicable, employees are certified The uniform and proper use of PPE is enforced Equipment is provided in a clean and hygienic condition Client specific requirements prior to staff and or subcontractors performing the task for the client is complied with The PPE is suitable for the task

Alan Poulsen Engineering Ltd Employees must: Not intentionally misuse or interfere with PPE Apply any training given and wear or use any personal protective equipment supplied Regularly inspect and maintain PPE Report defective equipment

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Equipment purchased All personal protective equipment purchased must comply with the appropriate New Zealand standard. Repairs/disposal PPE that is damaged or defective is to be repaired or discarded. In addition, contaminated PPE is to be disposed of appropriately and in accordance with regulatory requirements. Maintenance records The company is responsible for maintaining records relating to the distribution of PPE. This may include retaining manufacturers warranty information in the event of defective goods and as well all testing/inspection records for certified equipment.

by: Created by Mark Stevens Position: Manager

Date: November 2009

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ALAN POULSEN ENGINEERING LTD HOURS/FATIGUE WORKING EXTENDED HOURS/FATIGUE MANAGEMENT POLICY AND PROCEDURE
Objectives To assist supervisors to recognize work situations that may lead to employee fatigue and other detrimental effects To provide guidelines for minimizing the effects of working extended hours To provide guidelines for managing situations where fatigue may be an issue

Responsibilities

Manager
Establish procedures for recognising and managing work situations that may lead to employee fatigue Ensure all supervisors and employees receive training and instruction on minimization of fatigue in the workplace Monitor the work situation for early identification of fatigue indicators Take action to manage the situation where fatigue becomes an issue in the workplace Provide education and training where required to assist supervisors and employees to understand the issues related to working extended hours and workplace fatigue Assist supervisors to manage the situation where fatigue becomes an issue in the workplace

Supervisors
Monitor the work arrangements to identify situations that may lead to employee fatigue Implement recommended procedures for managing extended hours work and minimizing the occurrence of fatigue Report situations that are difficult to manage to the Manager to seek assistance Report situations where fatigue is becoming an issue Follow procedures that are implemented to reduce the effects of working extended hours

Employees

Situations with potential for fatigue Working extended hours is a major cause of fatigue in the workplace. The following situations can lead to employee fatigue if not managed effectively; Emergency call out of personnel Staff shortages

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Meeting rigorous production schedules Meeting deadlines for completing a job Demanding shift rosters

Potential impact of fatigue The following effects can be the result of working extended hours and fatigue when it occurs over a period of time. Ill health, e.g. gastrointestinal symptoms, sleep deprivation, depression, and aggravation of pre-existing diseases. This is exacerbated by disruption to healthy lifestyle habits such as regular exercise and well balanced diet Stress through demands to remain alert and trying to balance family life with work Increased potential for injury due to poor concentration Social disruption where a person is unable to fulfill family and other commitments due to the work load Increased exposure to workplace hazards as a result of longer work hours in contact with the hazard e.g. noise, fumes, chemicals Communication problems as a result of lack of normal contact with the workplace e.g. inability to attend meetings, loss of contact with fellow employees Training and instruction opportunities may be missed Involvement in activities such as Health & Safety meetings, tool box meetings and consultative meetings may be impossible Required actions

Risk assessment
The following situations should trigger an assessment of the work situation, as fatigue could be an issue: Where normal rostered breaks are not occurring Where demands are consistently high over a period of time Where the employees are regularly required to work over 12 hours

Training and education

Employees should receive training and education to ensure the issues relating to working extended hours and fatigue are understood. Training should cover the following topics; Recognition of situations likely to lead to fatigue Risk assessment procedures Procedures for managing jobs involving extended working hours

Supervision
Work involving situations likely to lead to fatigue must be adequately supervised by a person who understands how to manage the issues and who is authorised to make the necessary decisions.

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Emergency procedures
Risk assessments should take into account the potential for emergency situations and procedures implemented to respond in the event of an emergency occurring. Employees should be provided with the means to make contact in the event of emergency Emergency contact numbers, internal and external, should be readily available Supervisory staff must be able to respond to an emergency situation

Overtime On occasion staff will be required to work overtime. At Alan Poulsen Engineering Ltd staff shall not work any longer than 14 hours in any one 24 hour period. Following an extended work period there will be a minimum mandatory 9 hour stand down period prior to commencing the next working period. Created By: Mark Stevens Position: Manager Date: Revised August 2010

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ALAN POULSEN ENGINEERING LTD CONTRACTOR/SUBCONTRACTOR CONTRACTOR/SUBCONTRACTOR SUB POLICY MANAGEMENT POLICY
Definition The management

of

contractors/subcontractors

may be defined

as the

total

management of all companies providing contractors/subcontractors services to Alan Poulsen Engineering Ltd to ensure full and total compliance to high standards of Occupational Health, Safety and Environmental practices. It is a process which begins at the commencement of the selection process and continues until the completion of the project/job involved. Policy It is the Companys intent to provide a safe working environment and safe systems of work for all employees, persons, including visitors, contractors/subcontractors, and clients needs, regardless of location of work. We acknowledge the need to examine individual contracts to ensure that we have the equipment, environment, trained personnel, standard work procedures and appropriate personal protective equipment to complete the job safely. The Company has procedures in place to manage our legal and moral obligations concerning a safe and healthy working environment for external personnel and effectively controls the risks involved whilst working either on or off site. To ensure the safety of all persons performing work for or on behalf of Alan Poulsen Engineering Ltd, the following responsibilities will be undertaken. Responsibilities

Management
The Company includes appropriate OHS/HSE clauses in all contracts to remind personnel of their OHS/HSE obligations and legislative requirements as applied to the work under the contract The Company ensures particular risks associated with the work site are effectively communicated to all personnel performing work on behalf of Alan Poulsen Engineering Ltd The company provides information regarding site specific and standard work procedures which apply to Alan Poulsen Engineering Ltd personnel and communicates these to all personnel involved prior to the commencement of work under the contract

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The Manager and Supervisors are responsible for ensuring that employees are conversant and trained in this policy and follow the procedures outlined in the Contractors/Subcontractors Safety Procedure

The Manager ensures all responsible staff receives appropriate training to effectively implement the Contractors/Subcontractors Safety Procedure The Company ensures all contractors/subcontractors receive appropriate training to effectively and safely manage all tasks associated with each specific contract The Company ensures that Permitting Officers are responsible for providing advice and assistance to personnel in respect to all Health & Safety Injury Management matters

The Company must be informed of incidents and accidents occurring during the course of company business so that Health and Safety performances can be gauged accurately

Employees
Have a duty to take the care of which they are capable for their own health and safety and of others affected by their actions at work Should comply with the safety procedures and directions agreed between Management, contractors/subcontractors and employees with nominated or elected Health and Safety functions; Must, in accordance with agreed company procedures for accident and incident reporting, report potential and actual hazards to their Health and Safety representatives

Contractors/Subcontractors
Have a duty to take the care of which they are capable for their own health and safety and of others affected by their actions at work Alan Poulsen Engineering Ltd Management and contractors/subcontractors employees with nominated or elected Health and Safety functions Must not willfully interfere with or misuse items or facilities provide in the interests of health, safety and welfare Are to notify the Alan Poulsen Engineering Ltd Manager of any accident, incident, potential and or actual hazards to their health and injury or illness as soon as possible while on the nominated site Objectives To provide

and

promote

safe

working

environment

for

all

contractors/subcontractors To develop a mutually beneficial working relationship between all parties To ensure that the essential guidelines for the major client are always adhered to To establish commitment for the prevention of accidents and injuries at work, in accordance with the Alan Poulsen Engineering Ltd Health and Safety Policy

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To ensure all hazards and risks associated with the contractor/subcontractor are identified and effectively managed

This policy will be regularly reviewed in the light of legislation and company charges.

Created by: Mark Stevens Manager

Date: November 2009

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ALAN POULSEN ENGINEERING LTD SECURITY POLICY

Preamble This policy recognizes that the security of all employees, equipment and contractors/subcontractors within Alan Poulsen Engineering Ltd is the responsibility of the company Management. In fulfilling this responsibility, Management has a duty to provide and maintain so far as is practicable a safe working environment including: Staff and customers Property, particularly buildings Plant, machinery and vehicles Office equipment, particularly computers (software and hardware) Information or intellectual property

Objectives Objectives Alan Poulsen

Engineering

Ltd,

together

with

our

employees

and

contractors/subcontractors, will provide a secure working environment by protecting ourselves, our assets and our operations against risk of injury and loss or damage from criminal, hostile or malicious acts. Alan Poulsen Engineering Ltd will routinely assess security measures in place and act accordingly should we become aware of any situation that may compromise the safety or security of our employees, contractors/subcontractors and/ or clients health & safety or property. Responsibilities

Management
A key register is established for the issue of company keys to staff A PIN Number register for personnel that have access to the premises alarm system All unique paper documents that are no longer required, are to be destroyed via paper shredder or via a security document disposal service A document register is established for all company QA documents and controlled by the Project Manager The storage and archiving of company documents is controlled by the Administration Manager All relevant contractors/subcontractors sign an Alan Poulsen Engineering Ltd confidentiality agreement. This includes Cleaners, Software Technicians, and the Security Company

Supervisors
When planning major works, the security of the work site should be considered at the end of the working day when the site is unattended

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Factory windows, doors and gates to be secured, prior to departing the premises Dangerous Goods/Flammable storage areas to be secured prior to departure Security alarm system to be activated prior to departure

All staff
All Alan Poulsen Engineering Ltd staff have signed a confidentiality clause as set out in their respective Employment contracts The last person leaving the premises at the completion of the days work is to ensure all windows and doors are secured and that the alarm is set Company vehicles and toolboxes are to be locked when the vehicle is unattended (Refer Vehicle Safe Driving Policy) All non-essential electrical appliances are to be switched off at the socket All services should be turned off e.g. air conditioners and lights Do not give any unnecessary information to anyone. In particular any information relating to production, construction, manufacture, materials, technology, clients or work in progress. Refer all such requests to the Manager EMPLOYEES ARE OBLIGATED TO PROTECT COMPANY COMMERCIALLY SENSITIVE INFORMATION AT ALL TIMES CONFIDENTIAL AND

Visitors
All visitors must report to reception on arrival for a briefing of the site Health & Safety requirements, restricted access areas and the Emergency procedures All visitors will be escorted at all times

Personal belongings All staff is responsible for the security of their own property. Valuable items should not be brought to the workplace. All staff is to ensure that personal belongings are not left in view of the public and where possible locked away Parking of vehicles on Alan Poulsen Engineering Ltd land is at the owners own risk and Alan Poulsen Engineering Ltd takes no responsibility for any damage that may occur Computer security At Alan Poulsen Engineering Ltd there is a responsibility to maintain the highest level of security regarding access to unauthorized persons to the computer network, individual files, or other sensitive records. The server is backed up daily to a tape and stored off site. Commitment This policy will be regularly reviewed in the light of legislation and company changes. by: Created by Mark Stevens Position: Manager Date: November 2009

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