TECNICAS REUNIDAS SAMSUNG ENGINEERING

Project N° Unit Document Code Serial N° Rev. Page

076551C 000D PP 559 0 2/11

Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

TABLE OF CONTENTS

1. OBJECTIVE 3
2. SCOPE 3
3. REFERENCE DOCUMENTS 3
4. DEFINITIONS 3
5. ACRONYMS 3
6. ROLES AND RESPONSIBILITIES 3
6.1. Site Operations JV Director / Project Manager 4
6.2. JV Site Social Assistant 4
6.3. JV Site Construction Manager 4
6.4. Camp Manager 4
6.5. Workforce 4
6.6. Grievances Committee 4
7. INTERESTED PARTIES 5
8. GRIEVANCE MECHANISM 5
8.1. Specific Targets 5
8.2. Implementation Steps 6
9. RECEPTION AND REGISTRATION OF GRIEVANCES 6
10. EVALUATION AND CLASSIFICATION OF GRIEVANCES 7
11. GRIEVANCES RESOLUTION AND RESPONSE 7
12. MONITORING 8
13. REPORTING 8
APPENDIX 1: STEP BY STEP GRIEVANCE MECHANISM FLOW DIAGRAM. 10
APPENDIX 2: GRIEVANCE FORM 11

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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076551C 000D PP 559 0 3/11

Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

1. OBJECTIVE

The objective of this procedure is to establish a guideline to collect, record and resolve the
grievances, complaints, concerns or questions of the Project Interested Parties (i.e. workers,
Contractors, Subcontractors, Owner).

2. SCOPE

This Grievance Procedure will be implemented during the Construction, Pre- Commissioning
Commissioning, Start Up, Operation up to the Performance Acceptance Test phases of BAPCO
Modernization Program, awarded by OWNER to TechnipFMC, Tecnicas Reunidas and
Samsung in the form of JV called here in after TTSJV. The Grievance Procedure complies with
IFC requirements.

3. REFERENCE DOCUMENTS

000-A-PRO-50041-001 Project HSSE Plan

000-A-PRO-50058-001 Site HSE Plan
000-A-PRO-50075-001 HSSE Training Plan
000-A-PRO-50043-001 Project Security Plan
000-A-PRO-50059-001 Site Hazard Identification Plan 000-
A-PRO-50093-001 Camp Management Plan

4. DEFINITIONS

OWNER THE BAHRAIN PETROLEUM COMPANY (BSC) (C), a

company organized and existing under the laws of the Kingdom of
Bahrain (hereinafter named also Owner and Bapco)

EPCC Contractor or TechnipFMC, Tecnicas Reunidas, Samsung in the form of Joint

JV Contractor or JV Venture named TTSJV

Subcontractor Authorized Enterprise to carry out Construction activities on

behalf of the Contractor

5. ACRONYMS

HSE Health Safety and Environment

JV/TTSJV Joint Venture among Technip, Samsung and Técnicas Reunidas (also
referred as Contractor)
PC/C Pre-Commissioning / Commissioning
SRT Stakeholders Relations Team
SU Start Up

6. ROLES AND RESPONSIBILITIES

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

6.1. Site Operations JV Director / Project Manager

The Site Operation JV Director has the primary responsibility in ensuring the implementation of
this plan. He shall ensure that all the resources required for applying such procedure will be
made available and will be the interface point for reporting and communications with Owner.

6.2. JV Site Social Assistant

The JV Social Assistant, in conjunction with the Site Operation JV Director, or his delegate, is
responsible for implementing and administering this plan on the site.
Ensure the required HSE records are generated and available for review by Site Management
and Authorities as appropriate.
The JV Social Assistant shall be responsible for the administration of the Grievances database,
recording of grievances and complaints and follow up the resolution of the grievances according
the process described in this procedure.

6.3. JV Site Construction Manager

The JV Site Construction Manager promotes and supports the implementation of this procedure
by allocating the necessary resources. He follows up the indicators in order to ensure that all
employees are informed about the Grievance Mechanism and are able to properly use it if
needed.

6.4. Camp Manager

The Camp Manager is responsible for the implementation of this procedure in the Camp. He
follows up the indicators to ensure that all employees are informed about the Grievance
Mechanism and are able to properly use it if needed. Monitors the indicators as defined in this
procedure

6.5. Workforce

Site Workforce must know what the Grievance Mechanism is, hereby described, and be aware
of its benefits and conditions of use. All workers shall receive instruction on the Grievance
Mechanism in the HR and Social Induction as foreseen in the HSSE Training Plan 000-A-PRO-
50075-001.

6.6. Grievances Committee

Grievances Committee is composed by the JV Program Director, JV Project Manager, Social

Assistant, Camp Manager.
Its function is to resolve particularly serious complaints that may require the intervention of the
Owner, local authorities or external means.
Grievances Committee meets periodically to check trends, resolutions and follow up of
grievances and to monitor the proper implementation of the Grievance Procedure.

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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076551C 000D PP 559 0 5/11

Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

7. INTERESTED PARTIES

The interested parties are people, groups of people or organizations that can be negatively affected
by the activities of the Project.
The Interested Parties identified for the BMP are the following:
 The Workers;
 The Subcontractors;
 Ethnic Groups living in the Camps;
 Workers associations, Unions.

All these parties have the opportunity to communicate and resolve their complaints through
the mechanism presented in this Grievance Procedure.

8. GRIEVANCE MECHANISM

This procedure seeks to establish a mechanism that allows the interested parties and / or parties
affected by the Project to present both positive and negative feedbacks. These feedbacks can be
complaints, grievances and even doubts, questions or improvement recommendations.

The interaction mechanism must be anonymous, free, diverse and culturally appropriate for
those who wish to use it. This mechanism should guarantee that the feedback received will be
addressed by the appropriate persons, that it will be given timely follow- up and that any
employee raising a complaint will not be subject to any reprisal.

The Grievance Mechanism will also prevent the following latent risks that could arise during
the implementation of the Project:

 Possibility of demonstrations, claims or blockades by protestors groups.

 Lack of communication and inadequate relationship with vulnerable or minority
groups.
 Discontents created by possible impacts on external local communities (noise, dust, etc).
 Discontents created by possible uncomfortable situations on Camps occupants.
 Increase in conflicts between different workers' ethnic groups living in Camps.
 Lack of communication and inadequate relationship with communities.
 Possibility of conflict in the acquisition of rights of way.

8.1. Specific Targets

 Establish a communication tool, based on a grievance resolution mechanism, which can

resolve issues of social interest in a systematic, transparent and monitored manner;

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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076551C 000D PP 559 0 6/11

Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

 Allow people interested in providing feedbacks on the Project performances an

anonymous, free and easily accessible way to show their disagreement or grievance;
 Resolve quickly the grievances submitted to generate confidence and acceptance of the
Project in the interested parties.
 Address the queries and complaints of the interested parties to minimize the social risks
that may arise from the timely non-attention, on behalf of the Main Contractor, to the
concerns and inconveniences that may arise from their construction activities.

8.2. Implementation Steps

The implementation of the Grievance Mechanism will go through the following steps:

 Establish and implement the communication means that allow the collection of the
grievances and complains in the more suitable places for establishing an easy contact with
the interested parties (i.e. places within the Site, in the Camps);
 Dissemination of the Grievance Mechanism, through communication campaigns and
Induction Training, in order inform the interested parties on how to use it;
 Define and deploy all resources and means necessary for the implementation of the
Grievance Mechanism.
 Collect, process and resolve the grievances and complaints.
 Monitor and report performances.

9. RECEPTION AND REGISTRATION OF GRIEVANCES

The people interested in providing feedback to the Project or issuing a complaint and / or
grievance can do it through the following mechanisms:

1. Use of anonymous mailboxes that will be installed in the Site/Camps;

2. Communication of the complaint via telephone to a cellular number assigned to a

representative of the Project who will attend the complaint in a schedule from 9 a.m. to 1
p.m. from Sunday to Thursday;

3. By email.

The comments will be recorded in a grievance database, organized and administered by a

Stakeholder Relations Team (SRT);

Each complaint shall be numbered and when it is solved formal confirmation shall be issued to
interested parties with resolution date.

A maximum period of 10 working days is established to confirm receipt of the complaint and/or
grievance. If by that time, the complaint and / or grievance has been closed, then the resolution
will also be provided. In case of not having resolution within 10 working days, the time in
which the resolution will be solved will be specified;

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

During the resolution of the complaint a follow up of the status shall be done and issued to the
interested parties.

10. EVALUATION AND CLASSIFICATION OF GRIEVANCES

All grievances shall be classified according the following criteria

Importance or criticality:
 High (group complaints, or involving third parties): seek support from senior management
or third-party expert groups;
 Medium (individual complaints, internal issues): seek internal and managerial support;
 Low (lack of information, not relevant): review information before proceeding with its
resolution.

Response Time:
 The grievances prioritized as “High” shall be resolved within a period not exceeding 20
working days from the date of registration of the grievance or complaint. If, for reasons
beyond the control of the Project, the grievance cannot be resolved within the established
period, the aggrieved party must be notified, and the response time will be restored to the
original time;
 The grievances prioritized as “Medium” must be resolved within a period no longer than 15
working days from the date of registration of the grievance or complaint. If, for reasons
beyond the control of the Project, the grievance cannot be resolved within the established
period, the aggrieved party must be notified, and the response time will be restored to the
original time;
 The grievances prioritized as “Low” should be resolved within a period of no more than 10
working days from the date of registration of the grievance or complaint. If, for reasons
beyond the control of the Project, the grievance cannot be resolved within the established
period, the aggrieved party must be notified, and the response time will be restored to the
original time.
 No complaint and/or grievance can be restored more than 3 times. This means that, only for
reasons of force majeure, the maximum that a grievance can take to resolve is 60 business
days. This provision applies to the same complaint and/or grievance by the same person or
interest group. That is to say the resources of the Grievance Mechanism will not be
available to give attention to the same complaint instance for more than 3 times (it is
considered that 3 times it is an appropriate number to give opportunity for the same
complaint to be resolved). In case the complaint is very recurrent for the same person or
group of interests and a satisfactory solution is not found, the case will be reviewed
individually, in which case the ordinary resolution scheme may change.

11. GRIEVANCES RESOLUTION AND RESPONSE

The grievances can be solved by means of the following approaches:

 Unilateral: direct resolution by the Social Assistant towards workers and / or contractors;

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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076551C 000D PP 559 0 8/11

Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

 Bilateral: Social Assistant and aggrieved reach joint resolution through transparent
negotiations and without coercion;
 Through a third party: as an impartial mediator (not excluded to raise the grievance through
a Union)
 If the employee is not satisfied by the resolution has the right to raise the complaint to an
higher level of the organization.
 If the grievance cannot be solved by Site the aggrieved party has the option to go through
legal action.

The type of response will be:

 Preliminary: inform stakeholders about the evaluation or progress of their complaint;

 Conclusion: report the final resolution and its justification, asking for acceptance to close
the claim in the registry.

All resolved complaints and/or grievances shall be supported by a written response such as:
agreements reached and signatures of parties.

A written record of the details of its resolution of all complaints and/or grievances will be kept for
internal control.

The list of closed cases will be published monthly and will be registered in the database.

12. MONITORING

There are different indicators that must be considered for the correct evaluation of the Grievance
Mechanism for all the stages of the Project:

 Number of registered complaints or grievances (per week, month, etc);

 Time of resolution of grievances or complaints;
 Proportion of positive feedback from stakeholders;
 Levels of recidivism of grievances or complaints after having been attended initially; All

the indicators will be evaluated and reported on a monthly basis.

13. REPORTING

The HR team must prepare and transmit to Owner a monthly report indicating:

 number by locality of origin of the query or claim;

 number by interest group;
 number by type of communication: consultation or claim;
 number of inquiries and complaints received by category (for example: environmental,
discrimination, perception of inequality in employment opportunities, supplies of goods
and services, social investment, lack of information, misinformation or misinformation,
damage to property or social infrastructure, poor treatment in communities by workers).

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

 proportion (%) of consultation or claim received that corresponds to the Social

Management, other managements of the Main Contractor, Subcontractors and suppliers.
 proportion (%) of the consultations, claims and complaints attended within the 10 days
foreseen in the response procedure;
 proportion (%) of recidivism in the claims and complaints already attended previously.
 new inquiries and complaints received during the month;
 the queries and complaints received during the month that reactivate old queries or claims;
 inquiries and claims pending response;
 the inquiries and claims pending response for which the holders of the complaint were
informed about the progress of their consultation or complaint;
 the answers/solutions that were considered satisfactory by the owner of the query or claim;
 the answers/solutions that were not considered satisfactory by the owner of the query or
claim;
 the suggestions and recommendations to solve the queries or claims that correspond to the
Social Affairs Management;
 the queries and claims that do not correspond to the Social Affairs Management indicating
who should be redirected (for example, other managements of the Main Contractor,
subcontractor or Owner);

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

Appendix 1: Step by Step Grievance Mechanism Flow Diagram.

1. Participation of Questions, doubts,- individual
groups of interests complaints, comments from stakeholders including the internal workers of TTSJV and Sub-contractors
or group
-withtheoptionof anonymity,freeand

Suggestion
Hours of visit / tours sheets (mailboxes)
Meetings / group forums Telephon e / email
2. Methods of
communication receiving the grievances or comments. They must have easy access and shall be previously announced.

Grievance and complaints registration system

3. Reception and registration of grievances. Confirmation of receipt, registration with folio and estimated resolution time.

Monitoring of time efficiency and transparency of allocation and use of resourc

Categorization by levels (I, II, III, IV and V) and possible redirection of comments to

4. Evaluation and
categorization of grievances by levels. Identify trends, and perform initial FAQ.

5. Priorization and hierarchy of grievances. Definition of priority scales and communication process based on each scale.

High Medium Low

10
15
20

6. Grievance resolution and response options. Unilateral or bilateral approach or by third parties. Type of response (preliminary and conclusion). Closure and public

Resolution, response and case closure approach

List of closed cases and monthly publication

7. Review and monitoring of the Mechanism. Compliance

with Reports
resolution times.
Internal and/or external publication of annual/ monthly sustainability reports

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain
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076551C 000D PP 559 0 11/11

Bapco Doc. No.: 000-A-PRO-50106-001 BAPCO

MODERNIZATION PROGRAM
TECNICAS REUNIDAS SAMSUNG ENGINEERING

GRIEVANCE PROCEDURE
The present document or drawing is property of THE BAHRAIN PETROLEUM COMPANY B.S.C. (CLOSED) (BAPCO) and shall not, under any circumstances, be totally or partially, directly or indirectly, transferred, reproduced, copied, disclosed or used, without its prior written consent, for any purpose and in any way other

Appendix 2: Grievance Form

Employee Name (grievant) Telephone Number

Place Date

Employer / Subcontractor Immediate Supervisor and title

Grievance Statement (write the nature and the facts of the grievance: who, what, where, when, why):

Remedy Sought (What employer action will resolve this grievance)

Signature of employee Date

Signature of Management Representative Date

TTSJV W.L.L. – Riffa AlHajiyat – Blk. 939, Rd. 3901, Bldg 98, Flt. 33 – Kingdom of Bahrain