Shell Petroleum Development Company of Nigeria

Classification Status: Restricted

OCTOBER, 2013 DOCUMENT NUMBER

SSG-NG01012401-GEN-AA-5880-00012

SOUTHERN SWAMP ASSOCIATED GAS SOLUTION (SSAGS) PROJECT

PRODUCTION FACILITIES EPC

Contract No. : NG01012401

NIGERIAN CONTENT PLAN

Proprietary Information: This document contains proprietary information and may not be partly or wholly reproduced without prior
written permission from Shell Petroleum Development Company

INTERNAL EXTERNAL
Revision Date Description NCDMB
Originator Checker Approver
Approval

C01 21-Oct-2013 Isued For Construction Lawrence C. Sule E. Liberatore M. NCDMB

Contractor:

Contractor Document Number: GEN-ZX-E-09125

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 ADDITIONAL AGREEMENT/APPROVAL RECORD

Party Ref Ind. Name Sign Date

Revision Philosophy
 Revisions for Review - First issue will be issued at R01, with reason of issue description - Issued
for Review, (with subsequent R02, R03, etc. as required to be used in dependence of review
status received by SPDC). Last issue: A01, A02… with reason of issue description - Issued for
approval, A02 might be reissued in case further modification occurred A02, with reason of issue
description – Re-Issued for approval. When document is considered closed by SPDC, the revision
must be changed to C01, C02….. with reason of issue description - Approved for Construction
 Revisions for Design Documentation - First issue will be issued at D01, with reason of issue
description - Issued for Review, (with subsequent D02, D03, etc as required to be used in
dependence of review status received by SPDC). Last issue: C01, with reason of issue description
- Issued for Construction (Final Design) (C02 might be reissued in case further modification
occurred). When document is considered closed by SPDC, the revision must be increased (with no
change on the document itself) and issued , with reason of issue description - Approved for
Construction (Final Design).
 Revisions for Purchase - First issue will be issued at P01, with reason of issue description -
Issued for Purchase, (P02, etc to be used in dependence of review status received by SPDC).
Last issue: P03, with reason of issue description - Approved for Purchase (Final Issue) (P0X
might be reissued in case further modification occurred).
 Revisions for Information - First issue will be issued at R01, with reason of issue description -
Issued for Information.
 Revisions for As built - Documents or drawings revised as “As built” will be issued as Z01, Z02 Z03
etc as required.
 Narrative sections revised from previous approved issues are to be noted in the table below and/or
highlighted in the RH margin (using the appropriate revision status).
 Previous revision highlighting to be removed at subsequent issues.
 Drawings/diagrams revised from previous approved issues are highlighted by 'clouding' the
affected areas and by the use of a triangle containing the revision status.
 If a document is cancelled the document will be issued at the next sequential number by adding the
suffixed with a X. For example if R02 is the current revision then 03X will be the Cancelled revision
 All revisions to this document must be approved by the relevant Technical authority.

Revision History

Revision No. Date of issue Document ID/Reason for change

C01 25-Oct-2013 Issued for Construction

A02 25-Jun-2012 Re-Issued for Approval

A01 22-Apr-2012 Issued for Approval

R01 03-Dec-2012 Issued for review and comment

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 CONTENTS

1. PURPOSE 4

1.1. INTRODUCTION 4

2. SCOPE 4

3. REFERENCES 5

4. DEFINITION AND ABBREVIATIONTIONS 6

5. RESPONSIBILITIES 6

5.1. CONTRACTOR ORGANISATION 6

5.2. INTERNAL INTERFACE 7

6. NIGERIAN CONTENT TARGETS AND OBJECTIVES 7

7. CONTRACTOR EXECUTION STRATEGY 8

7.1. PROJECT MANAGEMENT 8

7.2. ENGINEERING 9

7.3. PROCUREMENT ACTIVITY 9

7.4. CONSTRUCTION 12

8. PROJECT STAFFING 12

9. HUMAN CAPACITY TRAINING 13

10. NIGERIAN CONTENT REPORTING 14

10.1. MEASUREMENT 14

10.2. MONITORING AND REPORTING OF NIGERIAN CONTENT 14

10.3. DEVIATIONS AND WAIVERS 15

11. ATTACHMENTS 15

11.1 CONSORTIUM INTEGRATED ORGANIZATION CHART 15

11.2 ENGINEERING ORGANIZATION CHART 15

11.3 NIGERIAN CONTENT COMPLIANCE CERTIFICATE 15

11.4 TRAINING PLAN FOR CONSORTIUM STAFF 15

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1. PURPOSE
The purpose of this Plan is to ensure that the Nigerian content target set out in the CONTRACT for the
PROJECT are clearly defined, measured, monitored and reported in accordance with the contractual
provisions. CONTRACTOR is aware of Government aspiration for the Development of Nigerian Content in the
oil and gas sector, and is committed to the development of sustainable and achievable Nigerian Content in the
PROJECT. CONTRACTOR will strive to further improve the achievement of Nigerian Content and execute the
PROJECT in such manner that will add value to the Nigerian economy, develop human capabilities, improve
local capacity, and support Nigerian companies by transfer of knowledge.

Based on the CONTRACT and the NOGICD Act, this Nigerian Content Plan seeks to adhere to the following
Nigerian Content definition “Nigerian Content is the quantum of the composite value added to, or created in the
Nigerian economy through a deliberate utilization of Nigerian human and material resources and services, in
the exploration, development, exploitation, transportation and sale of Nigerian crude oil and gas resources, so
as to stimulate the development of indigenous capacity and encourage foreign investment and participation
without compromising quality, health, safety or environmental standards”.

1.1. Introduction
The Southern Swamp assets are located in OML-35 and OML-46, some 65 km South-East of Warri in the
Niger Delta area. The area includes four flow stations which handle production from the following currently
producing fields:

The four flowstations in the node are:

 Tunu Flowstation - A 3-Bank flowstation built on sand filled site.
 Benisede Flowstation - A 2-Bank flowstation built on a swamp piled site.
 Opukushi Flowstation - A 3-Bank flowstation built on a swamp piled site.
 Ogbotobo Flowstation - A single bank 45MBD concrete-barge-mounted flowstation.

2. SCOPE
The overall project scope is summarized below:

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  Construct a new Central Processing Facilities (CPF) at Tunu comprising but not limited to:

- 2 x 50% associated gas compression system (gas turbine driven centrifugal compressors)
- Twister hydrocarbon dew pointing and dehydration facilities
- 2 x 50% export compression system (gas turbine driven centrifugal compressors)
- Main (3x50%) and 1x100% blackstart /emergency (essential loads) Electrical power generation
system
- Electrical Power distribution System
- AC and DC UPS Systems complete with battery banks.
- Cathodic Protection System
- Earthing and Lighting Protection System
- Lighting and small power distribution system
- Allocation gas metering system
- CDM Ultrasonic meters.
- Instrument Air package

 Refurbish Tunu, Benisede, Opukushi and Ogbotobo flow stations through Brownfield upgrade with the
following scope:

- Install a gas engine driven booster compressor package in each of the flow stations at Tunu
3No.5MMSCFD (3 x 33%), Benisede 2No. 10MMSCFD (2 x 50%), Opukushi 3No.
10MMSCFD (3 x 33%)
- and Ogbotobo 2No. 5MMSCFD (2 x 50%), together with minor flowstation upgrades.
- Install a (2 x 100%) fixed speed electric motor driven surge vessel gas booster compressor at
Tunu flowstation
- Install a (1 x 100%) fixed speed electric motor driven surge vessel gas booster compressor at
Ogbotobo,Benisede and Opukushi flow stations
- Install main (3 x 50%) and blackstart/emergency (1x100%) Electrical power generation
systems at Ogbotobo, Benisede and Opukushi flow stations
- Decommission existing Electrical Power generation systems at Tunu, Ogbotobo, Benisede and
Opukushi flow stations
- Install Electrical Power Distribution Systems at Ogbotobo, Benisede and Opukushi flow
stations
- Decommission existing 3.3 kV HV Switchgear at Ogbotogbo flow station
- Install A.C and D.C UPS Systems complete with battery banks, at Ogbotobo, Benisede and
Opukushi flow stations
- Install Cathodic Protection System at Tunu, Ogbotobo, Benisede and Opukushi flow stations
- Install Earthing and lightning protection system at Ogbotobo, Benisede and Opukushi flow
stations for the AG Handling facilities
- Tie-in of the Tunu,Ogbotogbo,Benisede and Opukushi flowstations existing Earthing system to
the new Earthing and Lightning protection systems
- Install Lighting and small power distribution system at Ogbotobo, Benisede and Opukushi flow
stations for the AG handling facilities
- Install process, drain and utility pumps (various) at Tunu, Benisede, Opukushi and Ogbotobo
flow stations
- Install instrument air compression packages at Benisede, Opukushi and Ogbotobo flow
stations

3. REFERENCES
 NOGID Act 2010
 Nigerian Content Compliance Certificate
 NG01006306
 SSG-NG01012401-GEN-VA-6047-00001
 SSG-NG01012401-GEN-BA-7880-00018
 SSG-NG01012401-GEN-AA-5880-00002
 SSG-NG01012401-GEN-AA-5880-00013
EPC Contract SSAGS
PROCUREMENT MANAGEMENT PLAN
SUBCONTRACTING PLAN
COMMUNITY AFFAIRS PLAN
SSAGS NIGERIAN CONTENT TRAINING PLAN

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4. DEFINITION and ABBREVIATIONTIONS

COMPANY The Shell Petroleum Development Company of Nigeria Limited

Saipem Contracting Nigeria Ltd, Snamprogetti Engineering BV and

CONTRACTOR
Desicon Engineering Ltd (CONS)

CONTRACT No. NG01012401

SOUTHERN SWAMP ASSOCIATED GAS SOLUTION (SSAGS)

PROJECT PROJECT PRODUCTION FACILITIES EPC

Nigerian Content is defined as the quantum of composite value added

to or created in the Nigerian economy by a systematic development of
NIGERIAN CONTENT: capacity and capabilities through the deliberate utilisation of Nigerian
human, Material Resources and Services in the Nigeria Oil and Gas
Industry.
Engineering, Procurement and Construction
EPC
NC Nigerian Content
NCD Nigerian Content Development
NCCC Nigerian Content Compliance Certificate

HCD Human Capacity Development

NCDMB Nigerian Content Development Monitoring Board

AG Associated Gas

Mhrs Man-hours

MM Man-Months

5. RESPONSIBILITIES

5.1. CONTRACTOR ORGANISATION

CONTRACTOR REPRESENTATIVE;
 Coordinates the activities of the CONTRACTOR parties to ensure a smooth interface of the total scope
of WORK and NC obligation
 Manages all phases of the project; monitors resources, progress and schedule; assesses potential
risks; and takes action to resolve any problems that may arise in the course of execution
 Holds final authority on all project activities

PROJECT NIGERIAN CONTENT MANAGER;

 Responsible for the implementation of contractors Nigerian Content Plan and report
periodically on performance.
 Serves as primary contact with Client project NC team , NCDMB and maintains regular
channels of communication
 Continual overall project harmonization and monitoring of Nigerian Content levels achieved
throughout project life
 Supervises the creation, update and maintain all necessary documentation in close coordination with
other relevant departments
 Prepares the NCD Training Plan.

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 C01 CONTRACTOR REPRESENTATIVE
(PROJECT DIRECTOR)

PROJECT LOCAL CONTENT MANAGER

COMPANY NCD TEAM

 Manages the interface between NCDMB and Consortium
 COMPANY NCD Team will forward CONSORTIUM’s Nigerian Content Compliance
Certificate, Nigerian Content Plan and Nigerian Content training plan to the NCDMB for
approval.

5.2. INTERNAL INTERFACE

6. NIGERIAN CONTENT TARGETS AND OBJECTIVES

Nigerian Content Objectives:

The primary objectives of the Nigerian Content plan for the PROJECT include but are not limited to the
following:

Prioritising and maximising the use of Nigerian labour, goods and services and equipment

- Domicile Project Management and Engineering activities in Nigeria

- Maximise the Employment of Nigerians during the execution of the PROJECT
- To increase participation of Nigerians in key positions during the execution of the PROJECT
- Prioritise utilization of Nigerian labour, goods and services for engineering design.

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 - The proposed utilisation of Nigerian labour, goods and services for procurement elements of the
WORK;
- Prioritise the utilisation of Nigerian labour, goods and services for fabrication and assembly elements of
the WORK;
- Prioritise the utilisation of Nigerian labour, goods and services for construction, installation, pre-
commissioning and commissioning elements of the WORK;
- Prioritise the utilisation of competent Nigerian manufacturers and fabricators as appropriate in the
manufacturing, assembly and fabrication of component parts;
- The proposed utilisation of Nigerian representatives and/or agencies, to import those goods and
services and equipment originating from outside Nigeria;
- A comprehensive training and development plan covering accredited training programmes, for the
development of skills and competence amongst Nigerian labour hired for the WORK.
- The programmes shall cover all skills required for the WORK, specifically including engineeringdesign,
procurement, logistics, fabrication, construction, inspection, testing, commissioning and project
management;

7. CONTRACTOR EXECUTION STRATEGY

7.1.Project Management
The Project Management Team will be fully located in Nigeria

100% domiciliation of project management will be in Nigeria, to achieve this target CONTRACTOR will set up
Project Management Team in Saipem Operational Base Rumuolumeni in Port Harcourt and Warri logistics
base as support.

CONTRACTOR has demonstrated relentless effort in the development of the Nigerian Oil and Gas industry,
the Saipem credo “here to stay” have been proved in all its initiatives and strategies:

CONTRACTOR’s Nigerian Content target on PMT is as follows:

 Domicile all Project Management activities in Nigeria

 Maximising the Employment of Nigerians during the execution of the PROJECT

TABLE 1: PROJECT MANAGEMENT LOCATION

Project management and

procurement centres
Scope of specialist support to be
Scope of services to be provided
– location and address provided from home office

Saipem Operational Base PMT, fabrication and Logistics

NIL
Rumuolumeni Port Harcourt support.

Fabrication and Logistics

Warri Logistics Base NIL
activities

Fabrication and Installation

Project Sites
activities

* Key positions to be held by Nigerian are shown in the PROJECT organisation chart here attached and in
section 8.

TABLE 2: ESTIMATED PROJECT MANAGEMENT MAN HOURS

Total planned Target NC Mhrs % of Man-Hour spent

Mhrs in Nigeria

PMT 927,140 668,780 100%

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 Total 927,140 668,780 100%

7.2. Engineering

CONTRACTOR shall perform all FEED verification and engineering design necessary to support
procurement,construction, transportation and commissioning activities and in the development as built
documents.
CONTRACTOR shall execute all engineering man-hours in Nigeria with its TSD (Technical Service
Department) at the PROJECT office in SCNL base Port-Harcourt, with over 100 Nigerian engineers.
CONTRACTOR shall engage the engineering capability of the Nigerian Nationals who have already been
trained and used in similar projects for the execution of the engineering scope of the WORK.
The engineering review will be performed with due regard to the design criteria and inputs coming directly from
COMPANY.
CONTRACTOR will encourage transfer of knowlegde from Project Specialist lead in the different engineering
departments to Nigerian engineers, and will minimize the Non-Nigerian manpower in phases.
The Following Table Summarizes the Planned engineering design WORK and Target man-hours;

TABLE 3: ESTIMATE ENGINEERING MAN

C01 HOURS
Total planned Target Mhrs Target NC
ENGINEERING ACTIVITY Mhrs in Nigeria Mhrs
CIVIL AND STRUCTURAL 37,100 37,100
ELECTRICAL 74,200 74,200
ENGINEERING
MANAGEMENT 5,700 5,700
LOSPE 7,200 7,200
376,620
PACKAGES 57,520 57,520
PIPING 141,400 141,400
PROCESS 87,650 87,650
STATIC EQUIPMENT 27,600 27,600
TEL/INSTR/&AUTO 139,100 139,100
   
Grand Total 577,470 577,470 376,620

7.3.Procurement Activity

CONTRACTOR has an established procurement team, with good knowledge of the Nigerian market; with over
1000 approved vendors. First priority will be given to the Nigerian manufacturers and Suppliers.

Procurement centre will be based in the CONTRACTOR’s Project Office Port-Harcourt with a team of
experienced buyers and expeditors. A dedicated procurement plan that describes the process from
requisitioning to final delivery of materials and equipment will be in a separate document.

7.3.1 Goods

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For equipment and materials, CONTRACTOR will strive to procure the under listed construction consumables
from Nigerian suppliers;

 Rebars,
 Wire mesh,
 Cement,
 Cast iron,
 Paints,
 PVC Pipes,
 Low voltage cable etc.

For materials required for the execution of the WORK, CONTRACTOR has a deliberate policy of giving first
preference to utilize materials and services produced and provided in Nigeria that conforms to standards and
specification.

Where applicable as a means of increasing Nigerian Content, CONTRACTOR shall encourage out country
vendors to add Nigerian content value to the goods provided for the PROJECT, by entering into a sustainable
relationship with in-country vendors. All such value added shall be reported periodically in the monthly Nigerian
content Report.

CONTRACTOR plan is to ensure complete maximization of Nigerian resources and patronization of made in
Nigeria materials, goods etc.

Where CONTRACTOR needs to procure foreign produced equipment, materials and goods, as a result of
unavailability of cabable and qualified manufacturers in the Nigerian Market this will be done through a
COMPANY approved vendor provided the vendor can deliver on schedule. CONTRACTOR would make
considerable effort on value addition, by ensuring the utilization of Nigerian human resources and services in
the course of assembly, product finishing and delivery.
When CONTRACTOR needs to procure foreign goods, equipment, materials which will contravene the NC Act
as a result of unavailability of qualified manufacturer in Nigeria, CONTRACTOR will notify COMPANY to seek
for a waiver.
Summary of purchases planned for the project;

TABLE 4: IN COUNTRY PROCUREMENT

Nigerian content Target Suppliers

Electrodes 90%

Welding Consumables 100%

Fuels / Diesel 100%

Paints 100%

Insulation 100%

Low Voltage cables 100% To be confirm after

competitive tender
Various consumables for 90%
workshop

Civil consumables 100%

Medium Voltage Cables 45%

Valves 60%

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 TABLE 4: OUT COUNTRY PROCUREMENT
Suppliers
Biocide Injection Package

Coarse Diesel Inlet Filter

Corrosion Inhibitor Day Tank

Corrosion Inhibitor Package

Corrosion Inhibitor Storage/ Injection Package

Diesel Filter Coalescer Package

Hydrate Inhibition Package

Mobile Corrosion Inhibitor Package

Mobile Hydrate Inhibition Package

To be confirm after
competitive tender
Nitrogen Generation Package

Open Drains Plate Pack

Open Drains Return Filter

Oxygen Scavenger Injection Package

Fuel Gas Package

Fuel Gas Strainer

HP Fuel Gas Filters

Details of PO Issued to Nigerian Vendors shall form part of the Nigerian content monthly report.

7.3.2 Subcontracts & Services

CONTRACTOR will give first consideration to Nigerian Vendors in the execution of the WORK. Wherever
possible, CONTRACTOR shall strive to include more indigenous companies in COMPANY bidders list.

CONTRACTOR will work, as usual, towards promoting the development of the Nigerian companies in a
sustainable and ethical manner. Promote knowledge transfer from CONTRACTOR and international
SUBCONTRACTORS to Nigerian companies and community vendors.
CONTRACTOR will strive to ensure that fabrication facilities in-country where competence exists, are utilized in
the execution of the WORK.
CONTRACTOR will encourage out-country SUBCONTRACTORS to enter into sustainable and value adding
relationships with Nigerian companies.
The Community Subcontractor who meets specification, quality, reliable and meets the delivery time of the
CONTRACT will be given priority. Nigerian Content target for Subcontract is 100%.

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 Description NC Target (Spend)
Geotechnical Services 100%
Dredging 100%
Sandfiling & Sand filling 100%
Sand Search 100%
Piling Works 100%
Site Preparation 100%
Concrete and primary foundation works 100%
Mechanical Works at site 100%
Electrical and Instrumentation installation at site 100%
General Site services 100%

7.4.Construction

CONTRACTOR’s Nigerian content target includes construction/fabrication of all Works and appurtenances in
Nigeria in SCNL Fabrication Yard Rumuolumeni Port Harcourt and WORKSITES, which is composed of mostly
Nigerian nationals at the ratio 90:10.

The CONTRACTOR shall strive to maintain the existing ratio in all aspects of the Construction activities,
Construction Engineering, Quality Assurance/ Control, welding /fitting, Assembly, Coating and testing.
CONTRACTOR will provide classroom and on the job training for its personnel and Niger Delta workers, as
applicable, tailored to meet each individual need.

Activity Description Total MM on Target MMSpent Nigerian MM

Project. in Nigeria
Construction / Installation 5,612,329 5,612,329 4,770,480

8. PROJECT STAFFING

CONTRACTOR plan is to carryout the WORK in Nigeria and engage Nigerian personnel for the performance of
the WORK.

To achieve this primary Nigerian Content objective, where lack of capabilities has been identified,training
programs have plaaned to close the gaps(see Attachment 11.4). Nigerian personnel shall be introduced to
encourage knowledge transfer. Consequently CONTRACTOR shall maximize the Nigerian manpower and
minimize the Non-Nigerian manpower in phases.

CONTRACTOR shall ensure employment and utilization of Nigerians at all levels in project execution.
As Per the Attached Organization Chart (Attachment 11.1), the following key-positions will be covered by
Nationals:
 Deputy Project Manager (O & C)
 Deputy Project Manager (E & P)
 Deputy Technical Manager
 Deputy Procurement Manager
 Deputy Construction Managers (for Tunu, Benisede, Opukushi and Ogbotobo locations)
 Local Content Manager
 Community Affairs Manager

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  HR Coordinator
 Site HSE Manager
 Fabrication Quality Manager
 Site Security Coordinator
 Community Relations Coordinator
 Site Logistic Coordinator
 Warri Logistic Coordinator
 Deputy Site Engineering Manager
 Deputy Asset Manager
 Spread Superintendent
 DCC Coordinators

9. HUMAN CAPACITY TRAINING

A comprehensive training and development plan, for the development of competences amongst young
graduate engineers and crafts men; the training program will be for 12 months, which will comprise of
classroom and on the job training (post training attachment).

CONTRACTOR shall execute this training programs for non-Contractor personnel in accordance with the
Human Capacity Development Guideline issued to the industry in 2009.

Training program will be strictly linked with the development plans for the development of workmen hosted by
NIGERIAN CONTENT DEVELOPMENT MONITORING BOARD database. The proposed training program
aims at filling the gaps between career opportunities in the industry for projects similar to Southern Swamp
Associated Gas Solution Project on the one hand and the availability of skilled Nigerian human resources on
the other hand.

The program would provide specific classroom, on-the-job training and field experiences for selected Nigerian
workmen, which would be necessary to enhance competence and confidence in their chosen profession and
increase professional responsibility; consequently enhancing skill pool to achieve national goals.

A dedicated Training plan with details of courses and training schedule shall be submitted to COMPANY

Training Program will be mainly based on:

 Classroom training
 Globally recognized software certificate
 “On the Job” Training / Exposure to field situations

All training data will form part of the Nigerian content report.

C01
Training Summary
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 Description No. of Trainee Hours Target Audience
General training 117 15,536 NCDMB Nominated
Design/Engineering 28 66,808 NCDMB Nominated
Project Control 6 12,360 NCDMB Nominated
Quality 6 12,744 NCDMB Nominated
Crafts 77 76,572 NCDMB Nominated
TOTAL 117 184,020

Description 1st Year 2nd Year Target Audience

Design/Engineering 14 14 NCDMB Nominated
Project Control 3 3 NCDMB Nominated
Quality 3 3 NCDMB Nominated
Crafts 40 37 NCDMB Nominated
60 57  
Engineering/Project
Control/Quality
Classroom Training 3 Months 3 Months
On the Job Training 9 Months 9 Months

Crafts
Classroom Training 2 Weeks 2 Weeks
On the Job Training 18 Weeks 18 Weeks

10. NIGERIAN CONTENT REPORTING

10.1.Measurement
The Nigerian Content will be measured against the targets set above, in support of CONTRACTOR
commitment to Nigerian Content and in alignment with the aspirations of the Nigerian Government for
increased Nigerian participation in the nation’s oil and gas industry, CONTRACTOR will pursue the
maximization of Nigerian Content targets set above as far as is reasonably practical.

10.2.Monitoring And Reporting Of Nigerian Content

CONTRACTOR will continuously monitor the level of Nigerian Content achieved throughout the CONTRACT
duration.

The Nigerian Content Monitoring Report shall be updated and reported on monthly basis and shall be inline
with the project monthly cut off dates. The report shall show levels of Nigerian Content components (Human &
Material) including names of short listed Nigerian Companies who are considered for subcontracting
opportunities.

CONTRACTOR shall implement corrective measures in every case where the level of Nigerian Content
achieved is less than plan for a given scope.

10.2.1 Labour

All man hours spent by contractor or its subcontractor in direct performance of the work shall be reported.

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CONTRACTOR would maintain a record of roles and responsibilities of Nigerian nationals assigned to the
work.

10.2.2 Goods and services

CONTRACTOR shall provide periodic updates of the number of Nigerian Subcontractor or suppliers utilized
for the work.

10.2.3 Training

CONTRACTOR shall keep record of all training courses, professional certification and man hours spent for
training. All the man hours spent for formal training and on the job training shall be deemed 100% Nigerian
content.

10.2.4 Taxes, fees and dues

Statutory payments made to Nigerian govenmental organizations for permits,licences and levies in order to
execute the contract shall not be recorded as Nigerian content.

10.3.Deviations and Waivers

Deviations from the Nigerian Content Law 2010 as shown on the Nigerian Content Compliance Certificate will
be discussed with COMPANY, that will in turn apply for the waiver.

11. ATTACHMENTS

11.1 Consortium Integrated Organization Chart

11.2 Engineering Organization Chart

11.3 Nigerian Content Compliance Certificate

11.4 Training Plan for Consortium Staff

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 11.1.Consortium Integrated Organization Chart

N = Nigerian
E = Expatriate

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 11.2.Consortium Integrated Organization

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 11.3.Nigerian Content Compliance Certificate

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 11.4.Training Plan for Consortium Staff

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