MAINTAIN GROUP

Health and Safety Policy

Maintain Industrial Access is committed, to ensuring all personnel within and under control of the organisation will always follow best-practice risk management techniques, including ensuring all employees, at all levels, participate in workplace and site assurance inspections, and by ensuring that all Maintain Industrial Access personnel including (Employees, Contractors, Sub-contractors and External Providers) have the training, skills, knowledge, competence and where applicable, license(s) required for the duties performed. All Maintain Industrial Access personnel will be recognisable by the diligence and attention to detail, and their commitment to ensuring that they will eliminate or control risks to a level which is tolerable and as low as reasonably practicable (ALARP).

The Maintain Industrial Access will achieve this by:

• At all times, engaging in consultative processes with employees, suppliers, customers and governmental authorities.
• Ensuring the provision and maintenance of equipment and providing safe systems of work that are, so far as is reasonably practicable, without risk to the health and safety of all personnel, stakeholders or interested parties.
• Ensuring that there are effective arrangements and practices in place and for ensuring the safe use, handling, storage and transport of equipment and substances.
• Ensuring strict compliance with all aspects of the Heavy Vehicle National Laws (HVNL) and the Chain of Responsibility (CoR) requirements and obligations, as they apply to all MIA activities, in the delivery of its products and services in Western Australia and all other interstate locations.
• Ensuring the provision of all instruction, training and supervision necessary to ensure the health and safety of all personnel, including Employees, Contractors, Sub-contractors and External Providers.
• Ensuring that the organisation maintains all places of work under its control in a safe condition and provides and maintains safe access to each workplace.
• Ensuring that the organisation makes available adequate information about any substances used at any workplace, including any additional information arising from research or product development or improvement.
• Ensuring that the processes developed for undertaking any workplace activities meet all applicable legislative, regulatory and other applicable requirements.

Quality Policy

Maintain Industrial Access is committed, to ensuring its primary obligation to meet the needs and expectations of its customers, which is achieved by the capable implementation of the Integrated Management System (IMS).

Maintain Industrial Access will ensure this by:

• Committing to maintaining a culture of continuous improvement within the organisation so as to:
• Developing and maintaining customer recognition of our quality progress.
• Developing and supporting an organisational culture in which all personnel, including Employees, Contractors, Sub-contractors and External Providers, continually strive for a complete understanding of our customers' changing needs and expectations.
• Developing and supporting an organisational culture in which all personnel, including Employees, Contractors, Sub-contractors and External Providers, consistently comply with all regulatory and legislative requirements and the contractual obligations of all contracts, and agreements in relation to quality.
• Only using selected, approved and preferred suppliers.
• Consulting with all employees, to develop and achieve identified Quality Improvement Goals which will be monitored and reviewed on a regular basis.
• Developing and supporting an organisational culture in which all personnel, including Employees, Contractors, Sub-contractors and External Providers, remain focused on the continual improvement of the Maintain Industrial Access business processes.
• Fully supporting and endorsing the management system as described in the Maintain Industrial Access's integrated management plan.

Environmental Policy

Maintain Industrial Access is committed, to ensuring all personnel within and under control of the organisation will be recognisable by their diligence and attention to detail during the provision of its services.

They will demonstrate this through the management of all work activities in a manner consistent with the principles of sound environmental management, supporting ecologically sustainable development, and by delivering continuous improvement in the organisation's environmental performance through:

• The integration of the organisation's environmental duty of care into all business planning and day-to-day activities.
• Ensuring the conduct of all operations, whether carried out by or on behalf of MIA, in accordance with all relevant legislation and government policy and agreements and those duties as may be identified in any contractual requirements.
• Ensuring the provision of the skills, awareness and leadership for all personnel, including Employees, Contractors, Sub-contractors and External Providers, to achieve MIA's environmental goals and objectives.
• Promoting a culture of respecting the rights and interest of the communities in which we operate, and consideration of the environmental and social impact of products and services we use or provide.

Indigenous Engagement Policy

Maintain Industrial Access respects the traditions and cultures of Indigenous people and believes that effective management of Indigenous participation is an integral component of a successful business.

This policy statement recognises the potential for the development of relationships and partnerships between resource companies and Indigenous communities and the role Maintain Industrial Access can play in the socioeconomic development of Indigenous people and their communities.

Our commitment is underpinned by recognising the need to demonstrate respect and an understanding of the cultural, social and economic issues which affect Indigenous people through industry activities within this country. To achieve this, Maintain Industrial Access shall:

• Consult with clients and stakeholders to fully understand their requirements and to meet or exceed their expectations;
• Recognise the traditional and cultural values that tie Indigenous people to the land, including the special significance of some areas in which we work;
• Work with individuals, Indigenous communities and businesses to maximise opportunities for Indigenous people to engage with and work for us;
• Ensure our recruitment and employment processes are inclusive of the needs of Indigenous applicants;
• Ensure that our workforce and subcontractors are made aware and support the employment and retention of Indigenous people;
• Provide a safe and culturally aware environment for all employees;
• Actively seek feedback from clients and stakeholders addressing opportunities or areas for improvement and levels of satisfaction; and
• Review and revise our Indigenous Engagement Policy periodically to maintain relevance, effectiveness and appropriateness to our business.

Risk Management Policy

Maintain Industrial Access Risk Management Policy objective is to ensure the implementation of an effective risk management framework that is consistent with achieving its policy and operating objectives. In doing so, it follows accepted standards and guidelines for managing and minimising risk. To achieve this, Maintain Industrial Access shall:

• Consulting with clients and stakeholders to fully understand their requirements and to meet or exceed their expectations;
• Recognising that Risk Management is fundamental in achieving excellence;
• Ensuring Maintain Industrial Access integrates Risk Management into all business activities;
• Using industry best practices to identify, eliminate and minimise project risks;
• Establishing and achieving measurable Risk Management objectives and targets;
• Investing in the most appropriate technology solutions;
• Ensuring our systems are flexible and to encourage new ideas, technologies and innovations;
• Ensuring all employees understand and take responsibility for their own work;
• Actively seeking feedback from clients and stakeholders and addressing opportunities or areas for improvement and levels of satisfaction; and
• Reviewing and revising our Risk Management Policy periodically to maintain relevance, effectiveness and appropriateness to our business.

Equal Opportunity Policy

Maintain Industrial Access recognises that honesty, integrity, respect, fairness, and embracing differences is fundamental to achieving success and there so strives, through continuous improvement, to integrate equal opportunity principles into all aspects of its activities.

Through this policy Maintain Industrial Access seeks to promote the principles of equal opportunity; equity, fairness and social justice and to act in accordance with relevant legislation.

To achieve this, Maintain Industrial Access shall:

• Consult with clients and stakeholders to understand their requirements and to meet or exceed their expectations;
• Empower employees to believe in a limitless potential;
• Provide a grievance procedure that is accessible by all and is fair, impartial, efficient and respectful;
• Ensure that all our procedures and processes comply with all relevant equal opportunity legislations and statutes;
• Provide a workplace free of all forms of unlawful discrimination, harassment, sexual harassment, vilification, victimisation and bullying;
• Ensure all employees respect cultural and social differences amongst each other and our clients and treat each other fairly;
• Recognise that Equal Opportunity is fundamental in achieving excellence;
• Provide training on our Equal Employment Opportunity commitment to employees through our induction process, internal management courses, and as required on site;
• Create a workplace which encourages participation from groups which may be under-represented in our workforce; and
• Actively seek feedback from clients and stakeholders and address opportunities or areas for improvement and levels of satisfaction.

Sustainability Policy

Maintain Industrial Access is committed to improving the sustainability performance of the organisation through promoting a culture of sustainability, managing our operations in a manner that minimises our environmental and social impacts and enabling the integration of sustainability principles and practices.

To achieve this, Maintain Industrial Access shall:

• Apply a reasoned balanced approach to the guiding principles of sustainability to achieve high performance, including:
• Integrated planning;
• Innovation and encouragement;
• Customer needs and expectations;
• Business partner engagement; and
• Performance measuring and reporting.
• Actively promote sustainability in our industry through the industry associations, partnerships and organisations we support;
• Offer career development, supporting our teams to be diverse, engaged, motivated and competent together working towards the sustainable success of our business;
• Engage with local communities in which we work, both through specific project engagement and through company-wide initiatives;
• Deliver sustainable profitable growth while satisfying our ethical, legal and contractual obligations;
• Encourage innovation internally, with our supply chain and stakeholders that benefit the organisation, our customers, society and environment;
• Improve resource efficiency, sustainable consumption, and production, throughout the whole supply chain from design through to operation;
• Communicate the Sustainability Policy to all personnel via the intranet and the wider community through publication on our website and on request; and
• Review and revise the Sustainability Policy periodically to maintain relevance, effectiveness and appropriateness to our business.

Injury Management Policy

Maintain Industrial Access recognises that the effective injury management within the workplace is a beneficial process that promotes the early return to work for injured or ill personnel.

Maintain Industrial Access is committed to implementing workplace principles and practices to enhance Injury Management.

Experience shows that injury management and rehabilitation assists in the healing process and aids in returning the worker to normal functioning capacity sooner. Injury management aims to provide early intervention of timely and adequate services, including alternate duties programs such as:

• Manage injured or ill workers;
• Facilitate the workers earliest possible return to work; or
• Maximise the workers independent function.

To ensure the success during the management process the full commitment of the injured personnel, support of co-workers and supervisors and effective injury management coordination is required.

Maintain Industrial Access shall ensure this by:

• Providing a safe and healthy work environment;
• Demonstrating the company’s commitment to assisting injured persons by arranging appropriate medical treatment and working with employees to encourage, develop and manage return-to-work programs in accordance with treating practitioner recommendations, and without disadvantaging employees;
• Ensuring workers are informed about their rights and obligations;
• Providing medically approved alternate duties for injured or ill workers, where appropriate;
• Return injured employees to the workplace as soon as possible, in accordance with professional medical advice, on modified duties if required;
• Ensuring confidentiality to all injury management information; and
• Complying with legislative obligation for injury management.

Fitness for Work Policy

Maintain Industrial Access recognises that an individual’s fitness for work may be affected for a variety of reasons including the adverse effects of fatigue, stress, alcohol and or other drugs. Maintain Industrial Access is committed to creating a healthy and safe workplace through effective risk management.

Maintain Industrial Access management shall provide a framework enabling practical steps to be taken to manage fitness for work concerns. To achieve this, Maintain Industrial Access shall:

• Maintain appropriate health and fitness standards to enter the workforce and sustain fitness for work;
• Maintain a zero tolerance to drugs and alcohol in the workplace. This equates to a prescribed limit of 0.00% BAC on all Dowell Mechanical Services and client worksites;
• Communicate and consult with personnel to increase awareness of their workplace health and safety obligations in relation to drugs and alcohol;
• Promote physical, mental and emotional health so that people can safely undertake and sustain work;
• Provide relevant training, education and awareness to employees and contractors to assist in fulfilling their roles and responsibilities under this policy;
• Ensure confidentiality is maintained at all times in respect of these matter;
• Monitor the health and wellbeing of personnel;
• Ensure personnel deemed unfit for work as a result of alcohol or other drug misuse, are disciplined in a manner that aligns to the principals of just culture; and
• Provide adequate resources to ensure the successful implementation of this policy; including access to an Employee Assistance Program.

Health and Safety Responsibilities

• Maintain Industrial Access personnel shall adhere to the policy and ensure that they are fit to perform their duties without risk to the safety and health of themselves and others; and
• Maintain Industrial Access Management is responsible for the implementation of Fitness for Work Policy.

Performance Management Policy

Maintain Industrial Access is committed to assisting its employees in the performance of their duties by creating a clear direction for employees and ensuring that all are aligned with the strategic efforts and directions of the Group.

Maintain will assist employees to improve performance by providing employees with:

• Clarity regarding roles, responsibilities, and performance expectations;
• Provide a framework for regular and constructive feedback (formal and informal) regarding performance related issues between supervisors and employees;
• Ensure policies and procedures are accessible to all employees;
• Where possible, attempt to resolve any issues through counselling, provide training if required and other suitable management practices;
• Conduct annual review and maintain accurate records of performance outcomes and achievements;
• Identifying the cause of poor performance and taking appropriate corrective action; and
• Eliminating inappropriate behaviours from the workplace.

In order to achieve this goal, Maintain Industrial Access requires its employees to:

• Comply with improvement plans and lawful instructions;
• Ensure awareness of Maintain’s policies and procedures;
• Attend any training sessions arranged and requested by the group; and
• All employees must participate in a formal Review and cooperate with any performance-based outcomes.

In circumstance where performance improvement has not been satisfactory, further disciplinary action may occur up to and including termination of employment.

Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Maintain Industrial Access is committed to limiting the risk of modern slavery occurring within its own business, infiltrating its supply chains or through any other business relationship. Maintain Industrial Access Management shall achieve this by:

• Conducting risk assessments to determine which parts of the business and supply chains are at most risk from modern slavery and implement controls to address these risks. The risks shall be evaluated annually as part of the management review process.
• Ensuring compliance and regular monitoring of the organisations legal and other requirements.
• Recruiting personnel from reputable employment agencies and ensure they have the right to work in Australia.
• Undertaking due diligence when considering using new suppliers, and regularly review its existing suppliers.
• Ensuring products and services are procured from approved suppliers.
• Ensuring this policy and information on modern slavery is communicated to all personnel and suppliers.
• Providing training to all personnel on the issue of modern slavery in supply chains.
• Encouraging personnel and suppliers to raise concerns about any issue or suspicion that they may have of modern slavery at the earliest possible stage. If anyone becomes aware of or suspects that modern slavery is taking place, they must immediately notify Maintain Industrial Access Management.

Breaches in this policy may result in the potential termination of individuals and contracts.

Sexual Harassment

Maintain Industrial Access (MIA) is committed to providing and maintaining an Equal Opportunity workplace that is free of harassment of any kind. Sexual Harassment is defined as “any unwelcome sexual advance or an unwelcome request for sexual favours or other unwelcome conduct of a sexual nature” (Sex Discrimination Act 1984). MIA will not tolerate Sexual Harassment of any nature. Sexual Harassment may be deliberate or unintentional and may include, but is not limited to:

sexually graphic displays of pinups, calendars, cartoons, graffiti and screen savers;

written messages left on boards, desks, in lockers or in emails;

staring or leering at a person or parts of their body;

smutty jokes or verbal remarks;

body contact such as rubbing, pinching, patting or massaging;

tales of sexual exploits;

repeated requests for dates/drinks; and

suggestive comments regarding a person’s appearance.

Sexual Harassment is unlawful under the Sex Discrimination Act 1984 and the W.A. Equal Opportunity Act 1984. MIA has the responsibility to ensure that the principles of equal opportunity are practiced and reflected in its policies and procedures.

Appropriate disciplinary action will be taken against any staff member who is found to have engaged in behaviour that contravenes this policy up to and including termination of employment.

“What may seem as reasonable by one person can be viewed differently by another”.

Any staff member who makes fraudulent or vexatious complaints shall be subject to disciplinary action and may face termination of employment if appropriate.

MIA will comply with all current legislation and this policy will be reviewed at regular intervals and revised where appropriate.

Intellectual Property, Conflict of Interest and Ethics

Maintain Industrial Access (MIA) is committed to providing and maintaining integrity and ethics in our operating standards, encouraging an honest and transparent working culture.

Intellectual Property

Work that you create during your employment, including an invention, design or copyright, is considered our intellectual property.

Conflict of Interest

A conflict of interest arises where your activities, financial interests, family relationships, personal relationships or loyalties jeopardise or could jeopardise your judgment or independence in relation to Maintain.

Examples may include:

Any work activity (paid and unpaid) which may impinge on your normal working hours;

A business interest in, or association with, any supplier, client, subcontractor or other service provider, including that of a friend or family member;

A personal relationship with someone under your supervision; and

A personal relationship with an applicant applying for a position with us.

If you become aware of any actual or potential conflict of interest you must:

Disclose the matter to the relevant member of management immediately as it arises; and

Follow any direction given by the member of management in relation to the matter.

Ethics

Ethical practice is behaving in a way which is moral, right, fair and just.

Examples of its application in our workplace include:

Ensuring that any instance of bullying, harassment or assault is reported;

Ensuring there is no improper use or unnecessary waste of company belongings or resources;

Act in accordance with the Code of Conduct;

Ensure information gained in employment is used for the purpose intended or for legitimate business purposes; and

Abiding by our Australian laws.

Employees, who become aware of an unethical practice, including a conflict of interest, must report it to their supervisor as soon as possible.