ENVIRONMENTAL POLICY

BRAIN DEE TECHNIK NIGERIA LIMITED has a policy that its business will be organised, planned and

executed in such a manner;

 That commitsto providing quality service and ensures a safe and healthy workplace for our

employeeswhile minimizing our potential impact on the environment.

 That is in compliance with all relevant environmental legislations and ensures the implementation of

environmental best practices in all our activities to prevent pollution.

 That integrates the constitution of environmental concerns and impacts into our decision making

process.

 That minimizes our waste and reuse or recycles as much of it as possible.

 That minimizesusage of energy and water within our environment and processes in order to conserve

supplies and minimize the consumption of natural resources.

 That mandates the compulsory education of our employees about environmental issues that may affect

their work.

 That promotes environmental awareness among our employees and encourage them to work in an

environmentally responsible manner.

 That communicates our environmental policies to clients, sub-contractors and the public, encouraging

them to observe it.

 That where required by legislation or where significant health, safety or environmental hazard exists,

we will develop and maintain appropriate emergency response programmes.

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KINGSLEY AZUBUIKE Date
Managing Director

QUALITY MANAGEMENT SYSTEM (QMS) POLICY

At Brain Dee Technik Nig. Ltd we are committed to the following policies in organizing, planning and

execution of our business and projects;

  Constant improvement our quality management system which is the frame work for measuring and

improving our performance.

 Providing guidelines for planning the overall quality program and defining the actions to be taken in

situation for which such guidelines are required.

 Having systems and procedures in place to support our aim of total client’s satisfaction and continuous

improvement through our business operations.

Our quality management system inculcates the employees into becoming increasingly competent and creative.

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KINGSLEY AZUBUIKE Date
Managing Director

HSE POLICY AUDIT/INSPECTION

It is our policy at BRAIN DEE TECHNIK NIG. LTD. that audit/inspection program and procedure be

established, implemented and maintained for periodic occupational health and safety management system.

The program and procedure will facilitate the determination of occupational health and safety management

system to conform to planned arrangement for occupational health and safety management including system

components/criteria.
Audit/Inspection program and procedure will also facilitate the determination of occupational health and safety

management system to be effective in complying with the organization’s policy and occupational health and

safety objectives and targets.

The audit inspection procedure will cover scope, frequency, methodologies, competencies, responsibilities and

the requirements for conducting audit/inspections and reporting results.

Top management will undertake occupational health and safety management system reviews at intervals to

ensure continuous suitability, adequacy and effectiveness.

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KINGSLEY AZUBUIKE Date
Managing Director

PERSONAL PROTECTIVE EQUIPMENT (PPE) POLICY

It is the policy of BRAIN DEE TECHNIK NIG. LTD. to provide quality personal protective equipment (PPE)

for personnel according to their job demand.

We are committed to educatingour workers on the essentials of real application of the apparatus/equipment

provided for their safety through induction, toolbox briefing and HSE meetings/ workshops.

The site HSE Officer is to ensure that all workers on site put on their required PPE during official working hour,

any worker without his/her correct and complete PPE will not gain access to the worksite.
The management shall provide a stock of safety wears and they shall, at all times be maintained at the site for

sudden or immediate needs.

Workers that refuse to put on their required PPE after persistent warnings shall have their appointment

terminated.

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KINGSLEY AZUBUIKE Date
Managing Director

OCCUPATIONAL HEALTH POLICY

It is the policy of BRAIN DEE TECHNIK NIG. LTD. to recruit and maintain a well-articulated work-force that

is well equipped mentally, emotionally and physically. Much emphasis is laid on the medical fitness of

employees and we maintain a practice of medical certification of personnel to be recruited.

Weintend to maintain a high standard of health at the work via:

 An adequately stocked and appointed First Aid Box.Only Well-trained and qualified first aid personnel

shall administer first aid.

 Provision of clean and clear drinking water to all our personnel on site.

 Provision of Hygienic toilet facility at the work location for convenience.

A sound staff bus will be stationed at the site for the purpose of conveying worker to and from the project site.
Allmedical examination shall routinely be conducted for all staff at our recognized retainer clinic before

commencement of project.

The site nurse will be available always on site with a medical evacuation vehicle. We shall maintain a records of

all drugs administered on site.

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KINGSLEY AZUBUIKE Date
Managing Director

ALCOHOL & DRUGS POLICY

In BRAIN DEE TECHNIK NIG. LTD., we place much emphasis on the alcohol and drug control to go in line

with our health policy.

It is prohibited for any employee of BRAIN DEE TECHNIK NIG. LTD. to be under the influence of alcohol or

in possession of or under the influence of any non-prescription drugs such as; cocaine, amphetamine (speed),

marijuana or has any other illegal alcohol/drugs on job site.

Being under the influence of performance enhancing drugs such as alcohol violates the company’s policy and as

such may be seen as a misconduct which could lead to termination of appointment immediately.

The company will not allow the use, possession, exchange, distribution or sales of drugs/alcohol in the company

premises/sites.

Only qualified medical practitioners (Doctors and/or Nurses if need be) are authorised to administer drugs to

workers. Only First Aid andClients approved list of drugs shall be allowed onsite.

Records of administered rugs to whom and for what purpose including the date such drugs was given shall be

maintained onsite.
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KINGSLEY AZUBUIKE Date
Managing Director

COMMUNITY RELATIONS POLICY

Our operations/activities are mostly carried out in a remote environment and we have always been guests of the

inhabitants of these communities. In other to have a disturbance free environment, we shall institute a healthy

mutual relationship with our host communities. It is therefore the Policy of BRAIN DEE TECHNIK NIG. LTD. to:

 Respect the cultural, social and religious beliefs of the host communities.

 Involvethe communities where possible in the execution of the project by giving them the opportunity to

supply materials needed for the job.

 Honouring invitations to attend community’s festival ceremonies and being punctual in attending

meetings.

 In a case of any communal disturbances, as quickly as possible, BRAIN DEE TECHNIK community

relations officer and the project engineer will be informed of the situation by the site safety

officer/supervisor.The public relations officer (PRO) will proceed immediately to the location to

determine the grievance of the community. If the issue is beyond his authority to resolve, the PRO shall

contact the client’s Project Engineer and CLO to inform them of the development.

 Client’s CLO shall proceed to the site, joint with the PRO to hold a meeting with community. If PRO and

client’s CLO are able to resolve the issue, normal operations resume otherwise the procedure for

managing community disturbances shall be followed.

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KINGSLEY AZUBUIKE Date
Managing Director

SEAT BELT POLICY

It is the policy of BRAIN DEE TECHNIK NIG. LTD. that all company vehicles must be fitted with functional

seatbelts at every available seating position.

Seatbelts must be properly fastened on all personnel on board, including the driver before vehicle commences its

assignment.

The company is obliged to replace any worn out or damaged seatbelts.

We are committed to this policy to achieve a non-fatal impact of road traffic accidents on our drivers and crew.

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KINGSLEY AZUBUIKE Date
Managing Director
 STRATEGIC OBJECTIVES & POLICIES
BRAIN DEE TECHNIK NIG. LTD. has well defined HSE Policies which are in line with our clients’ policies. These

policies were drawn with the understanding of the nature of our business in engineering work/construction with

reference practices. In order to demonstrate our seriousness in matters relating to HSE issues in the running of our

business. The management of BRAIN DEE TECHNIK NIG. LTD. has put in place policies that show the

commitment of our company HSE implementation.

The policies are flexible and easy to read and understand by any category of workers in our operations. These policies

are drawn out for the understanding of the management and the workforce in order to perform their duties in such a

way that all operational risks associated with our daily activities can be reduced and all forms of safety, health and

environment exposure to hazard can be properly managed. Sample of our corporate HSE Policies are made available

on our information board accessible to all personnel. Copies of these policies are displayed at out project site/

location, workshop and other operational site.

These policies are consistent with client’s requirement and national law. The HSE policies are assigned by the

Managing Director and are reviewed at regular intervals.

The review does not necessarily result in a change except where necessary due to regulatory mandate.

The development of this is a continuous process based on:

 Nigeria legislation, guidelines from governmental agencies and the host communities feedback, non-

governmental organisations input and industry at large.

 Feedback and learning points from HSE management performance reviews, incident monitoring and audits.

 Evaluation of risks and treats to continued HSE improvement including aspects of the operations that impact

upon the environment.

 The corporate custodian of all corporate HSE Policies is the HSE Manager. Policies, whether HSE or

otherwise are owned by the respective line managers.

  In the execution of all jobs, it is the policy of our company that every reasonable effort will be made to

ensure that all employees have a safe and healthy workplace, adequate welfare facilities and surrounding

environment shall not be adversely affected by work activities.

 The prevention of all accidents, particularly those involving personnel injury or damage to properties are

recognized as being essential to efficient operation as well as to avoid hardship and suffering while the

overall policy responsible for safety rest at the highest management level. All individuals at every level will

have responsibility for carrying out the policy. With this in mind, employees should report potential hazards

and observe safety rules, procedures and code of work practices.

 The company retains the services of good clinics to carter for our employees and also ensure that adequate

medical services are provided to cover all our operations.

We encourage our employees to participate in voluntary first aid raining and other training programs.

 BRAIN DEE TECHNIK NIG. LTD. environment is a complete fulfilment of recent glamour for improved

living condition and sustainable development practices. The company is committed to ensuring clean and

healthy environment especially in the course of work.

Every effort will be concentrated towards minimization of noise, dust and other pollution agents released

during our jobs. It is expected of every of our employees to provide healthy, safe and environmentally

acceptable conditions both a work and at home.

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KINGSLEY AZUBUIKE Date
Managing Director

WASTE MANAGEMENT POLICY

BRAIN DEE TECHNIK NIG. LTD. has viewed responsible waste management as essential to reducing its

environmental footprint and providing a safe and healthy work environment for top managements, employees,

clients, students, volunteers and visitors.

A range of waste management strategies is undertaken by BRAIN DEE TECHNIK NIG. LTD. to create a safe,

secure and environmentally friendly workplace.

Separate waste at the point of generation and keep the types of waste separately during handling, accumulation,

interim storage and transportation.

BRAIN DEE TECHNIK NIG. LTD. uses additional waste reduction strategies including the reuse of products,

repairing broken items, using refillable cartridges or reusable products.

BRAIN DEE TECHNIK NIG. LTD. maximizes conservation of natural resources and minimizes environmental

harm through an effective waste management system of recycling and reusing waste products where ever is

possible.

We actively promote the use of effective waste management strategies and waste are disposed safely in a way

that least harms the environment.

All staffs are supported and encouraged to participate in waste management.

BRAIN DEE TECHNIK NIG. LTD. employees dispose waste in accordance with the waste management

procedure.

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KINGSLEY AZUBUIKE Date
Managing Director

ACCESS CONTROL POLICY

It is our policy that both logical and physical access to information and systems are controlled and procedures

are in place to ensure the protection of information, systems and data.

The policy includes all access to information, ICT Systems and physical access to areas and locations where

information and data is located. This applies throughout the information lifecycle from acquisition/creation,

utilisation, storage and disposal.

BRAIN DEE TECHNIK NIG. LTD. has an ongoing education featuring corporate induction programmes, E-

learning, Line Managers Training. Specific training and awareness programmes must be undertaken by staffs to

enable them be aware of their responsibilities towards systems and information security.

When a staff of BRAIN DEE TECHNIK NIG. LTD. changes role or his/her contract is terminated; the

management will ensure that a user’s access to the system/information has been reviewed.

All systems shall be accessed by the secure authentication of user validation.System logon data shall not be

copied, shared or written down.

All staffs of BRAIN DEE TECHNIK NIG. LTD must wear their ID card, including the visitors. Anyone who do

not have and ID card will not Gain access.

Any person not known in the location must be identified in order to establish who they are and whether

authorisation has been provided for them to be there. If there is any doubt about the identity of the individual,

appropriate security officers/manager will be contacted to confirm the individual’s identity.

Appropriate recording mechanisms are put in place to record the names, dates, times and signatures for the

signing in and out of visitors, including BRAIN DEE TECHNIK NIG. LTD personnel.

All visitors must be issued with an authorised BRAIN DEE TECHNIK NIG. LTD. visitor’s ID card or badge

when signing in.

Movement registers shall be maintained for staff and for visitors.

Logbook for movement of vehicles across the facilities shall be ensured at all times (Pre-mobbed vehicles only).

Company vehicles are fitted with appropriate security devices or appliances.

Cases of security defaults and/or lapses shall be thoroughly investigated and appropriate action taken.

Access to and knowledge of keys, doors lock codes or access to keys for locks are restricted to authorised

personnel only and must not be shared with any unauthorised person.

Breaches of this policy and/or security incidents can be defined as events which could have or have resulted in

loss or damage to BRAIN DEE TECHNIK NIG. LTD. assets or an event which is in breach of the company

security procedures and policies.

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KINGSLEY AZUBUIKE Date
Managing Director
 HSE POLICY STATEMENT

At Brain Dee Technik Ltd we take pride in organizing, planning and executing our businesses ina such a

manner as to:

 Protect and promote the health of the work force as well as to conduct all activities in such a way that

does not adversely affect any third party.

 Avoid injury to all workers, sub-contractors, and third parties that are either involved in or are affected

by Brain Dee Technik Ltd activities, minimize the impact on the environment in which we operate.

 Observe our client’s HSE rules and regulations and ensure that the client’s HSE objectives are

achieved.

 Ensure every Brain Dee Technik Ltd employee must perform his or her activities in accordance with

the HSE Policy. Any activities which the employee believes cannot perform in accordance with the

Policy must be suspended and reported immediately to his supervisor.

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KINGSLEY AZUBUIKE Date
Managing Director
 HSE TRAINING POLICY

AtBrain Dee Technik Ltdwe are dedicated to ensuring that:

 AllBrain Dee Technik Ltd workers requiring health and safety training in order to complete their duties

safely, will be provided with adequate training.

 All management and workers receive health and safety training required for their job position.

 The resources necessary for the development, implementation and maintenance of an effective health

and safety training program is put in place.

 Responsibilitiesfor training coordination are assigned to competent management.

 Selectedsupervisors and trainers are competent to perform the required training.

 Trainingneeds and assessment processes are in place to determine the health and safety training

required for management and workers annually.

 Develop and implement a department’s specific orientation program based on a health and safety risk

assessment of existing and potential workplace hazard.

 Review the training policy and program annually in consultation with stakeholders.

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KINGSLEY AZUBUIKE Date
Managing Director
 TRAINING POLICY

 We are committed to building a competent workforce in order to achieve strategic and operational

plans and is committed to providing an environment that is conducive performance and promotes

training and development opportunities for all staffs.

 Providing a framework for training and development that ensures staffs have necessary competencies

to deliver on Brain Dee Technik strategic and operational plans.

 Ensuring equality of opportunity for all Brain Dee Technik Ltd staffs to develop their knowledge,

skills and abilities through a blend of learning methods including mentoring & coaching on the job

learning, courses, conferences and seminars.

 The training needs of staffs will be identified through performance management and operational

planning in line with best practices and legislative guidelines.

 Brain Dee Technik Ltd will facilitate externally accredited training and development opportunities for

staffs, subject to the availabilities of funding.

 All training, i.e. courses, workshops, seminars and conferences will e coordinated through the Brain

Dee Technik Ltd training department.

 Brain Dee Technik staffs participating in training will satisfy all attendance, assessment and evaluation

requirement with the required time frame.

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KINGSLEY AZUBUIKE Date
Managing Director
 ENVIRONMENTAL IMPACT ASSESSMENT POLICY

It is our policy at Brain Dee Technik Ltdto perform the following prior to any project execution:

 Carry out an environmental impact assessment at the planning stages of the proposed project to ensure

that significant impacts on the environment are taken into consideration during the design, construction

operation and commissioning of the project.

 Identification of environmental hazard associated with the proposed development through literature

review, public participation in the project development, recognition of social and cultural principles

and polluters pays principle and the precautionary principle.

 Committed to leading the industry into minimizing the impact of its activities on the environment, by

improving our environment performance over time and to initiate projects and activities that will

further reduce our impacts on the environment.

 Our commitment to the environment extents to our customers, our staffs and our community in which

we operate.

 Compliance with all applicable environmental regulations.

 Train all of our staffs on our environmental program and empower them to contribute and participate.

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KINGSLEY AZUBUIKE Date
Managing Director

QUALITY POLICY
Brain Dee Technik Ltd has a policy that its business will be organized, planned and executed in such a manner

as:

 Not to sacrifice Quality in order to meet unreasonable time schedule or target.

 To supply accurate data and information for audit.

 To implement, operate and maintain a quality assurance system in compliance with the requirement of

BS5750 Pt ISO9001 and other international codes.

 For full implementation of Non-Conformance Report (NCR) and Corrective Actions Report (CAR) for

close out.

 Adhere to our client’s quality standards in executing all projects.

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KINGSLEY AZUBUIKE Date
Managing Director

FRAUD, CORRUPTION AND MALPRACTICE POLICY

BRAIN DEE TECHNIK NIGERIA LIMITED operates an anti-malpractice policy which encourages
employees and others working with the organisation to help tackle fraud, corruption or other malpractice within
the organisation. Likewise BRAIN DEE TECHNIK NIGERIA LIMITED is determined to maintain its
reputation as an organisation which will not tolerate fraud, corruption or abuse of position for personal gain,
where ever it may be found in any area of the organisation's operations.

The Management of BRAIN DEE TECHNIK NIGERIA LIMITED play a key role in counter-fraud
initiatives. This includes providing a corporate framework within which counter-fraud arrangements will
flourish, and the promotion of an anti-fraud culture across the whole of the organisation.

In the Event where an investigation provides proof that an employee of BRAIN DEE TECHNIK NIGERIA
LIMITED is guilty of an act of fraud, corruption or malpractice then the organisation's disciplinary procedures
will be invoked and subject to the findings of the investigation the matter may be referred to the police. Where
there is prima facie evidence of fraud, corruption or malpractice by an employee of BRAIN DEE TECHNIK
NIGERIA LIMITED and its deemed necessary to refer the matter to the police in the first instance, the
organisation's disciplinary action may be invoked after the police investigations are concluded.

At the same time BRAIN DEE TECHNIK NIGERIA LIMITEDexpects that individuals and organisations
(e.g. suppliers, contractors, and service providers) that it deals with will act with integrity and without thought or
actions involving fraud and corruption. Where relevant, BRAIN DEE TECHNIK NIGERIA LIMITED will
include appropriate clause in its contracts about the consequences of fraud, bribery and corruption; evidence of
such acts are most likely to lead to a termination of the particular contract and may lead to prosecution.

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KINGSLEY AZUBUIKE Date
Managing Director