It is the policy of Six Alliance Co. Ltd. In connection with the use or operation, handling, storage, transport and disposal of chemicals safety in its business. This also applies to its employees, contractor and sub-contractors.
To achieving this policy, will endeavour to ensure that;

•    All chemicals are to conform to the appropriate Government statutory Regulations and Guidelines.
•    Each chemical shall be accompanied by its Material Safety Data Sheet and communicated.
•    Where feasible, chemicals chosen shall not to cause harm to people and minimize any negative impact on the environment.
•    Where use of a toxic or hazardous chemical is unavoidable, appropriate safety measures shall be taken to minimize the risk of injury, illness to people or harm to the environment.
•    Employees handling chemicals shall be briefed of the safety and its proper’s, are confirmed to be aware of its contents and due appropriately equipped with personal protective equipment.

Six Alliance Co. Ltd. Believes that a healthy and safe working environment is the greatest importance in all of its operations.

MAINTENANCE
The Management of Six Alliance Co. Ltd. (SACL) is committed to the maintenance of all company diving plant and equipment regardless of the location. All maintenance of diving equipment shall be implemented and carried out in accordance with the requirements of International Marine Contractors Association (IMCA) guidance for the initial and periodic examination, testing and certification (IMCA D018), manufacturer’s maintenance requirements and third party (Class or other inspection body). In order to comply with SACL Policy all equipment and plant used in manned underwater operations shall be designed, constructed and maintained in accordance with recognized standards. It is the ultimate responsibility of the Company to ensure that all plant and equipment is fit for purpose.

AUDITING
In order to establish compliance with all of the above, the IMCA D023 or IMCA D040 (Diving Equipment Systems Inspection Guidance Note) will be used as the audit pro-forma for all diving operations. It is the responsibility of the Offshore Project Manager (OPM) to ensure that the DESIGN audit is in place, in date and remains valid. NB: - This responsibility is irrespective of whether the dive system is managed by the SACL Workshop Department, Third Party Vessel or a Mobile System belonging to the external vendors.

PERSONAL DIVING EQUIPMENT
Personal diving equipment consists of diving helmet or mask, first stage regulator and connecting hoses and bailout cylinder. All maintenance actions whether planned or repair shall only be carried out in accordance with the manufacturers' requirements and guidance procedures. Only trained and certified Helmet Maintenance Technicians shall carryout maintenance of company diving helmets and masks. All records of maintenance carried out on such equipment shall be clearly documented with records maintained in a structured method and signed by the approved technician who carried out the work.

Six Alliance Co. Ltd. Is strongly committed aims to be drugs and alcohol free in all our business and operation premises. The principle is that no aspects of its business and operation are more important than the safety and health of employees and its premises towards the provisions of a safe working environment. 

Employees are expected to recognize that they have a clear duty to exercise self-discipline to ensure a culture of fit and healthy workforce and free from the bad influence of drugs and alcohol.

It is a serious offence for any employee caught under the influence of alcohol, or In possession of or under the any non-prescribed drug, such as cocaine, marijuana, heroin, hashish and other illegal substance, while working or residing on any job, office and site. That shall leads to termination of employment contract. 

In ensuring that such provisions are complied with, Six Alliance Co. Ltd. Shall not hesitate to take disciplinary action against any person discovered in possession of or under the influence of drugs and alcohol.

Six Alliance Co Ltd is committed to the protection, preservation and conservation of the natural environment and local amenities in all areas of its operations. To achieve this Six Alliance Co Ltd Will:
· Comply with all applicable standards and legislation on the environment, both national and state-ratified international conventions and protocols;
· Implement oil and gas industry’s best practices;
· Implement an environmental management system compliant with ISO 14001; and continually improve its environmental performance and reduce environmental impacts by implementation of environmental programmes;
· Set environmental objectives and targets aimed at achieving compliance with legislation and create a management framework for reviewing them;
· Ensure the effectiveness of the environmental management system through documentation, training, communication and feedback from employees. This environmental management system will be rigorously applied, implemented, reviewed and improved;
· Make this environmental policy and QP’s performance freely available to the workforce, contractors, government and the general public.

The Managing Director of Six Alliance Co Ltd. Hereby directs all Six Alliance Co Ltd personnel to implement this environmental Policy. All Six Alliance Co Ltd personnel are also directed to ensure that all contractors working in Six Alliance Co Ltd apply the same environmental policy.

SIX ALLIANCE CO.LTD Specializes in the management of Subsea contracts and totally committed to quality in the performance of all activities. It is the policy of Six Alliance Co.Ltd. That all employees and Sub –Contractor have the RIGHT TO STOP any work when there is an immediately threat to the health, safety and environment. 

The individual’s right to stop any work which is considered dangerous shall have the full support from the management of Six Alliance Co.Ltd. If there any doubt whether to stop work, employees including Sub –Contractor should immediately notify the hazardous situation to the Superior in charge for immediate action.

Prior to commencement of such work, the advice from the health, safety and environment Department is to be sought. All personnel are encouraged to contribute towards the effectiveness and continuous improvement of the health, safety and environment Management system and highlight to management any areas of improvement or where deviations identified.

Six Alliance Co. Ltd. is dedicated to providing the highest standard of health and safety and environment, providing and maintaining safe and healthy working conditions and equipment to all its employees.

We are committed to providing quality professional offshore equipment services, developing long-term relationships, adapting to the changing needs of our clients and the industry, meeting and exceeding client’s expectations and being a contributing member to the communities where we work and live.

Our commitment to business excellence is encapsulated in the following principles.

SERVICE STANDARDS

We shall deliver services that meet or exceed the requirements set out by our clients and the relevant regulatory authorities. We shall comply with all the established procedures, quality standards, safety standards and regulations.

COMMITMENT TO QUALITY, HEALTH AND SAFETY

We are accountable for the Quality, Health and Safety of our Work and will perform to the best of our capabilities at all times. We are committed to prevent/ eliminate/minimize/control risk/ill/health/pollution due to Occupational Health and Safety Hazards and comply with all applicable Occupational, Health and Safety, Legal and Other requirements.

COMMUNICATION

We communicate our QHS policy with our clients, employees, vendors, sub-contractors, and partners and solicit their input to enable us to meet their expectations. We actively promote our QHS policy across all levels of our organization and we encourage our employees to embrace Quality, Health and Safety as their personal commitment. We shall report reportable errors or incidents to the relevant parties and are committed to an open reporting culture. We encourage sharing of information on QHS.

CONTINUAL IMPROVEMENT

We shall consistently strive to improve our Quality, Health and Safety through learning, sharing, benchmarking, innovation and participation in continual improvement programs. Six Alliance Co. Ltd. aims to eliminate all causes of fatal and major incidents from its workplace and we target for continual improvement on incidence rate. We shall establish and maintain appropriate controls and conduct periodic reviews of our attainment of set goals.

Six Alliance Co Ltd recognises that an integral part of quality is the assignment of personnel with suitable qualifications. To facilitate this, a system has been developed which governs this process and ensures that only the best suited candidates become part of our team.

Personnel progress activities shall guarantee that the personnel requirements of the company with regard to qualifications are being met. With the help of training the employees are able to meet the present and future requirements of their tasks. Therefore training should be directed to meet specific needs.

Training of permanent personnel

The level of knowledge is never taken for granted at Six Alliance Co Ltd and training is run whenever improvement of skills, knowledge or career progression are identified by supervisors and managers. Six Alliance Co Ltd will ensure suitable support and resources to allow for effective training once a personnel’s needs have been identified.

This record of training is logged whereby management is guaranteed of continuous upliftment of our services, our safety, and good maintenance of our equipment.

Training of foreign personnel

Six Alliance Co Ltd policy is to train local employees in foreign countries to the high standard we have attained at our base.

Company Management Commitment

The Company Management is responsible for ensuring that sufficient resources are provided in order to guarantee this training is carried out.

The selection and subsequent employment of suitable candidates is of a high priority. The identification of requirements is the responsibility of the relevant department head and the process described in the Standard Operating Procedure is the responsibility of the Human Resource Manager.

The training has to be orientated and based on the requirements defined beforehand. Also employees will discover training needs during their daily work. Employees are urged to approach their supervisors, managers, or the Training Manager if they feel the need for training that would enhance their abilities within their particular job description. After careful deliberation Company Management will consider the Companies and the employees benefit of such training. Records of training’s completed are to be kept in the employees personnel file.

The following Policy demonstrates the ethical business conduct and compliance with all laws and regulations of Kingdom of Saudi Arabia on payments to any third party (in particular Government Official’s) which may be directly applicable to Six Alliance Co. Ltd. as well as compliance with the United States of America Foreign Corrupt Practices Act ("FCPA”) and/or the United Kingdom's Bribery Act which may apply to "Six Alliance Company" principals. This Policy strives to not only protect the interests of Six Alliance Company and its employees but to also protect the interests of Six Alliance Company’s business partners. Violations of this policy will be grounds for disciplinary action. Six Alliance Company gives itself strict rules on payments (including benefi­ts in money's worth) of any kind to any third party, in particular to Government Official’s, by Company rank in file employee and/or top management Official’s. The provision of a payment or anything of value to, for the benefi­ts of, or at the request of a third party: See Anti-Bribery and Anti-Corruption Manual

1. May only be made for a bona ­de and legitimate business purpose;

2. May not be made with an intent to influence the third party inappropriately;

3. May not be in exchange for the award of business or other unfair / improper advantage;

4. Must not be extravagant;

5. Must be provided openly and transparently;

6. Must be properly recorded and adequately documented.

Please note that Six Alliance Company may revise any part of this policy from time to time when necessary.

PREAMBLE
The purpose of this policy is to mitigate the risks associated with any act of modern slavery and human trafficking related to Six Alliance Co. Ltd (hereafter called as “Company”) business activities by clearly stating its position on the matter to ensure all human rights of its employees, supplier personnel are assured and the actions which might result due to any violation of the same.

MINIMUM AGE OF LABOUR
Company will not employ children below the age of fifteen (15) or the minimum age for employment according to applicable laws. Company ensure that persons under   the age of eighteen (18) do not perform any hazardous work.

FORCED  LABOUR
Company will not use any form of forced, bonded or prison labor. Personnel will not be required to lodge ‘deposits', identity papers or work permits as a condition of employment. We shall have no involvement in human trafficking in our business activities.

NON-DISCRIMINATION
Company  treats  our  employees and  hired  labour  equally and  fairly. Company will not tolerate any form of harassment or discrimination, including on  the grounds of race, colour, sex, religion, political opinion, national or  social  origin.  It shall promote equal  opportunity and  fair  treatment in employment and  occupation for our employees and  hired  labour, including migrant workers.

TERMS OF EMPLOYMENT
Company ensures that wages paid   to employees and   hired  labours are  in accordance with applicable law  and/ or agreements.

Employee and hired labour working hours shall not be excessive and  comply with  local law and  agreements regarding working hours.

Vacation time,  leave periods and  holidays consistent with applicable local  law  and/ or agreements will be provided to employees. We shall ensure that all employees are  free  to leave  their  employment/work after  giving reasonable notice.

All Company employees are provided with  written agreements of employment setting out  employment conditions in a language understandable to the employee and have access to effective grievance mechanisms.

MINORITIES AND INDIGENOUS PEOPLES RIGHTS
Company recognize and  will  respect the special  importance of the social,  cultural, religious and  spiritual values and  practices of  the  minorities, indigenous and  tribal  peoples and  their relationship with  the  land  or  territories. Subject to exigencies of  work for applicable employees and applicable laws and regulations; a process to minimize and manage such  impacts will be undertaken.

ACTIONS DUE TO VIOLATION OF POLICY
Company takes violations of this policy seriously, and strongly encourages its Employees and suppliers to comply with its terms. Where a non-compliance is identified and reported, Company expects its employees and suppliers to implement appropriate corrective actions promptly. Company reserves the right to take such action as it deems appropriate in relation to a breach of this Policy including, without limitation, reporting of the practice to the relevant authorities and exercising any contractual right of termination.

REPORTING
If any party subject to this policy at any time discovers or suspects the existence of modern slavery or human trafficking in any part of Company’s operations or its suppliers, the situation shall be reported to Chief Executive Officer of the Company.

PREAMBLE

Six Alliance Co. Ltd (hereafter called as “Company”) recognizes that gifts and hospitality can be an  important part  of  developing business relationships. However, caution should be taken in accepting or providing gifts or hospitality that could raise suggestions of impropriety or create a position of obligation on the part of the recipient.

The objective of this Gifts & Hospitality Policy (the “Policy")  is to  provide  a procedure to ensure  that  Company,  together   with  its  directors,  officers, employees,  consultants and contractors,   may  provide   or  receive  gifts  and/or  hospitality, in  compliance   with   high standards  of integrity and all relevant laws and regulations applicable.

STANDARDS IN PROVIDING OR ACCEPTING GIFTS OR HOSPITALITY

Directors, officers, employees, consultants and contractors, and their families will not give or accept gifts, gratuities or entertainment in relation to Company or  its  business that  may conflict with  the provisions of this Policy. For clarity, all directors, employees, consultants and contractors of Company must ensure that:

      i.         The   gift and/or hospitality is   not   given   or   accepted with   the   intention or expectation of influencing a party to obtain or retain business  or a business advantage,  or  as a reward for  the  provision or  retention of  business or  a business advantage, or in explicit or implicit exchange for favors or benefits;

     ii.         The gift and/or hospitality is customary to the industry;

   iii.         The gift and/or hospitality does not violate any local laws;

    iv.         Any gift and/or hospitality given is provided in the name of the Company and not in the name of the individual;

     v.         The gift   and/or hospitality does   not   include cash or a cash equivalent (e.g. vouchers, gifts certificates);

    vi.         The  gift  and/or  hospitality is  of  an  appropriate type  and  value   and  given  or accepted  at   an   appropriate  time,    taking  into    account  the    business relationship  with   the   counterparty, any   pending action   expected  of  the counterparty and the reason  for the gifts and/or hospitality;

  vii.         The  gift   or  hospitality  would  be  considered  as  being appropriate by  an independent third party bystander in all the circumstances and  in hindsight; and

 viii.         The gift and/or hospitality is given or accepted openly and not secretly.

GIFTS & HOSPITALITY TO PUBLIC OFFICIALS

a)     Company requires all directors, officers, employees, consultants and contractors to exercise great  care when  interacting with  public officials and  demands that  they act with  the highest level of Integrity.

b)     Prior approval must  be  obtained from the Chief  Executive  Officer for  the  making of  any  gift  or  the  provision of  any hospitality  to   a  public  official.  Gifts   or   hospitality of   an   insignificant value   such   as promotional items  (e.g.  pens, notepads, diaries and calendars) or refreshments offered during a meeting are not covered  by this rule.

APPROVAL  FOR OTHER GIFTS & HOSPITALITY

a)     Gifts  or  hospitality to  those  other  than  public officials should never  be offered or accepted without the  prior approval of the  Chief  Executive  Officer  where  the value  of the  gift  or the hospitality  per   person  is  more than   the   limits  notified  internally  and   available from Company's Chief  Operating Officer  at any time.  Gifts  or hospitality of an insignificant value such  as  promotional items  (e.g.  pens, notepads, diaries   and  calendars) or  refreshments offered during a meeting are not covered by this rule.

b)     Care  should also  be  taken  that  several  smaller  gifts  or  lower levels  of  hospitality are  not provided to  the  same  recipient thereby breaching the  overall limits notified internally and available  from Company's Chief Operating Officer at any time. Recovery of the reasonable cost of   a  gift   or   hospitality provided  may  be  claimed  in  accordance with Company's expenses policies. When providing hospitality, a host from Company should always be in attendance at the event.

c)     Where  a gift is received of a value in excess of the amount established by the Chief Executive Officer from time  to time, it is advised to return it in a polite manner. Should it be impractical or offensive to return it (e.g. due to local traditions) the Chief  Executive  Officer will  decide  whether it is appropriate to keep the gift or whether it should be donated to charity.

d)     Further, there   may   be  occasions   where   directors, officers, employees, consultants  and contractors of Company and their  families are provided with  more  generous hospitality and it will be necessary to  obtain approval from the  Chief Executive Officer  before accepting. If acceptance  of the hospitality would leave any director, officer, employee, consultant or  contractor of Company in a position of obligation, it should be politely declined. 

GIFTS & HOSPITALITY REGISTER

All gifts and hospitality provided, received or declined must be recorded in Company's Gifts Register   which   is maintained by the   Finance   Manager.

REPORTING VIOLATIONS OF THIS POLICY- WHISTLE BLOWER POLICY

Whistleblower policy and procedures apply.

PREAMBLE

This policy is created for the purpose of encouraging its Stakeholders to report in good faith of any suspected Reportable Conduct through the channels mentioned hereunder which maybe made with the confidence that Stakeholders making such reports will be treated fairly and to the extent possible, protected from reprisal.

DOING THE RIGHT THING

Everyone who works under Six Alliance Co. Ltd (hereafter called as “Company”) is mandated to comply with our Principles of Business Conduct, our policies and procedures, professional standards, laws and regulations. Stakeholders are encouraged to speak up within the firm when they suspect something that does not comply to company policies or regulations.

REPORTABLE CONDUCT

Reportable Conduct is anything that have reasonable grounds to suspect, such as, is:
·       misconduct, or an improper state of affairs or circumstances;
·       conduct that constitutes a contravention of laws specified in the Whistleblower Laws or other commonwealth laws that are punishable by imprisonment or fines; or
·       conduct that represents a danger to the public or the financial system.

Examples of Reportable Conduct include but are not limited to:
·       illegal conduct, such as theft, violence or threatened violence, and criminal damage against property;
·       fraud, money laundering or misappropriation of funds;
·       offering or accepting a bribe;
·       financial irregularities;
·       failure to comply with, or breach of, legal or regulatory requirements; and
·       engaging in or threatening to engage in Detrimental Conduct against a person who has made a disclosure or is believed or suspected to have made or be planning to make a disclosure.

WHEN TO MAKE A WHISTLE BLOWER REPORT

Before making whistleblower, report stake holder should satisfy themselves that they have reasonable grounds to suspect Reportable Conduct. ‘Reasonable grounds to suspect’ is based on objective reasonableness of the reasons for the suspicion. In practice, a mere allegation with no supporting information is unlikely to reach that standard.

However, a Whistleblower does not need to prove their allegations. In addition, the disclosure can still

qualify for protection even if the disclosure turns out to be incorrect.

·      Six Alliance Co. Ltd. Is adopting policy expressing “Divers should take no drugs that the company does not know about”

·      Six Alliance need to know what drugs have been prescribed for their divers (or have been self-selected by the divers) so that they can arrange for an informed medical assessment to be carried out.

·      Certain medical conditions controlled by drugs may not be a barrier to diving at work, some medications may be used by divers providing an assessment has been made by Six Alliance diving medical specialist(s). As emphasised previously, all drugs must be declared to those in control of the diving operations. 

·      Six Alliance diving medical specialist physician(s), are authorized to approve any non-prescription and prescription drugs to divers at company worksites.

Example of a list of medications/substances that Six Alliance considers should not normally be made available to divers at worksites unless approval has been given by the company diving medical specialist physician(s):

1. Amphetamines (including lisdexamfetamine dimesylate) and designer drugs (substituted methylenediosyphenethylamines including MDMA, MMDA, FLEA, EDMA, EFLEA, MDOH, EBDB, MDEA, 5-methyl-MDA and others);
2. Phencylidine (PCP);
3. Opioids, naturally occurring and synthetics;
4. Phosphodiesterase inhibitors such as erectile dysfunction medications;
5. Tramadol;
6. All antidepressants except low dose sertraline used for mild situational depression;
7. All antipsychotic medications;
8. Muscle relaxants;
9. All forms of insulin;
10. Oral hypoglycemic medication;
11. Anticoagulants or platelet inhibitors;
12. Benzodiazepines;
13. Barbiturates;
14. Anxiolytic and/or hypnotic medications;
15. Nicotine patches – must be removed while diving;
16. Varenicline;
17. Bupropion;
18. Beta blockers. 

Note
This is not an exhaustive list. It is indicative and only provides a basis for discussions with company Diving Medical Physicians.