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CHAPTER 5

Environmental, Health and Safety Excellence

"Achieving EHS excellence is not easy, but it is essential for our survival and success. By EHS excellence we mean going beyond compliance to ensure that we’re keeping people safe and protecting the environment. The highest priority must be placed on risks that could cause the most serious harm to people, the environment or the business."

—Charles Koch

Environmental, Health and Safety Excellence

Our companies worldwide will act as proper stewards when managing all aspects of business. That means they will act with proper regard for the rights of others, put the safety of our employees and others as our highest priority, drive environmental excellence and comply with all laws and regulations.

Fundamental Expectations of Employees:

  • Place protection of health and safety and the environment first, no matter how urgent the job.
  • Never accept noncompliance, unsafe behaviors or unsound environmental practices for the sake of production or financial objectives.
  • Seek an understanding of the key EHS risks of his or her role, and the best knowledge regarding EHS issues.
  • Comply with applicable regulations, requirements and job procedures.
  • Report all incidents and near misses, raise concerns and challenge the status quo in order to prevent incidents and drive continuous improvement in EHS performance.
  • Report any EHS issue that he or she believes has not been appropriately resolved, even if it means raising it with another available resource as described in chapter one of this Code.
  • Responsibly manage your actions and the resources entrusted to your care in a manner that respects the rights of others.
  • Full commitment to these EHS expectations and engagement in achieving this level of performance, throughout the organization.

Any employee who knowingly violates applicable environmental, health and safety policies, laws or regulations will be subject to disciplinary action, up to and including dismissal.

Fundamental Expectations of our Companies:

  • Act with proper regard for the rights of others and place protection of health and safety and the environment first, and equip employees to work effectively in the workplace.
  • Require the same level of performance from contractors, vendors, visitors and other third-parties in our facilities as we do from our employees.
  • Identify and manage EHS risk, placing the highest priority on those which could cause the most serious harm to people, the environment or the business.
  • Integrate consideration of EHS performance into all business and product planning decisions.
  • Utilize materials, natural resources and energy efficiently to increase value and reduce environmental impact.
  • Respond in a timely and appropriate manner if an EHS incident does occur; learning from incidents and taking action to prevent such incidents in the future.
  • Audit and assess our performance and practices regularly, and take appropriate actions where needed to continuously improve our EHS performance.
  • Engage employees, customers and suppliers, government officials, communities, and non-government organizations to advance effective approaches to health and safety, and environmental protection.
  • Ensure all products are manufactured and placed on the market in a manner that is compliant with applicable laws, regulations and relevant standards of safety for customers, consumers, employees and the environment.

FAQs

    I am aware of a local law, applicable to the location where I work, that I do not believe we are complying with. I have talked to a few coworkers about my concern and their point of view is that the law is out of touch with today’s manufacturing process, other companies in the region do not comply with it either, and it is rarely enforced by the regulators so why bother complying with the law. Are my coworker’s views aligned with what the company expects?

    No. The company’s expectation is to comply with all applicable legal requirements. Our commitment to compliance does not rely on how other companies manage their compliance obligations or the extent of enforcement activity. You must raise your concern using one of the many options available to you so the appropriate resources can assist in evaluating the circumstances and help make a determination that meets the company’s expectation.

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    I work at a small facility and I am aware of a safety issue that may cost a lot of money to fix. I am afraid the plant will not be profitable if we have to spend the money. Should I still report the issue?

    Yes. Report the issue using one of the many reporting options available to you. Protection of health, safety and the environment must come first, no matter what. Safety is more important than profits.

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    I work in a high noise area and some of my coworkers refuse to wear their required hearing protection. I don’t want to be a trouble-maker, but I am concerned about them. What should I do?

    Share your concern with your coworkers and encourage them to wear the required hearing protection, if you feel comfortable doing so. Not wearing required hearing protection or any other required personal protection equipment is a violation of our policies and possibly the law. You should also use one of the many reporting options available to you so the company can understand the issue. Maybe the hearing protection is uncomfortable and needs to be redesigned, or maybe additional training is needed.

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    We just implemented some new safe work practices. I have been doing this kind of work for more than 20 years and have never been hurt. Why do I have to change the way I do things?

    The company values your safety. The company is not trying to make your job harder. The procedures are necessary to identify hazards and reduce risks so that you and your coworkers are protected, and to ensure compliance with regulations and our EHS Policy. Everyone must follow the procedures, however if you have concerns about them or if you think you can improve them, talk to your supervisor or your local safety professional.

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