Health, Safety and Environment

We aspire to achieve an HSE performance that is exemplary in the Turkish oil & gas manufacturing industry. Over the years, have worked to improve its HSE best practices and performance and create our HSE codes of practice.

Our HSE understanding prioritizes the following:

• Optimizing manufacturing practices while maximizing work safety, operational health and environmental compliance,

• Always meeting and exceeding the minimum required health and safety conditions in the work environment ,

• Ensuring sustained training-while-working for continued improvement of HSE understanding,

• Prioritizing “environmentally compliant” designs and materials

A comprehensive Health, Safety and Environment (HSE) policy governs our efforts to continuously better our health and safety performance and our environmental stewardship. The duty to comply with our policy extends to each and every Petrotek facility and employee, as well as the terms of our working agreements with our subcontractors and suppliers.

For sustainability of our HSE program, we employ a resident corporate HSE team, which is supported by nominated experts from staff as well as guest auditors from time to time. Tasks of the corporate HSE team are as follows:

• HSE compliance verification: We use a HSE compliance verification system in a number of situations including the design and commissioning of a new facility, startup of a new manufacturing line, implementation of a new process and hazard investigations. The process is utilized to research significant risks – including social and environmental concerns where applicable - identify action items, process risk assessments and determine possible corrective actions and remedial measures.

The same HSE compliance verification is carried onto our business managers’ conduct, where they are also required to certify the compliance of their departments with the HSE policy, and put forth adequate action plans for any identified deficiencies.

• HSE auditing of facilities: In order to ensure strict compliance with our HSE policies, we give significant importance to auditing. We audit our facilities once every year to ensure that they comply with our HSE policies and associated regulations. For this purpose, our resident corporate HSE auditing team also employs nominated experts from staff as well as guest auditors from time to time. This structure allows both a more comprehensive evaluation by team members (i.e. field experts across the company) that can pinpoint potential weaknesses, as well as introduce new and better perspectives on common applications.

All potential gap points are assessed during periodic audits, as well as additional cross examination of deficiency points identified in different departments. If and when performance deficiencies are determined, the relevant unit is given 30 days to develop a corrective plan, which is then put into action following approval of the board. These improvements to the existing system are then tracked by the corporate HSE team until the time of the next audit.

All findings and conclusions are reported to the associated business manager as well as to the board of directors.

• Internal HSE inspection: Periodic audits are further complemented by internal inspection processes that are also conducted by the corporate HSE team. Similar measures are taken as periodic audits upon discovery of deficiencies.