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NOTE: THIS IS AN UNCONTROLLED COPY OF THE POLICY MANUAL No part of this document may be reproduced or disclosed to any other party without the prior permission of a Director of Häfele U.K. Ltd. Issue 45 25.05.2017 Page 1 of 24 Integrated Management System Manual Brownsover Road Swift Valley Industrial Estate Rugby Warwickshire CV21 1RD Authorised by: Craig Chambers, Managing Director Date: 25 th May 2017 Meeting the requirements of ISO9001:2015, ISO14001:2015, BS OHSAS 18001: 2007

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NOTE: THIS IS AN UNCONTROLLED COPY OF THE POLICY MANUAL

No part of this document may be reproduced or disclosed to any other party without the prior permission of a Director of Häfele U.K. Ltd.

Issue 45 – 25.05.2017 Page 1 of 24

Integrated Management System Manual

Brownsover Road Swift Valley Industrial Estate

Rugby Warwickshire

CV21 1RD

Authorised by: Craig Chambers, Managing Director

Date: 25th May 2017

Meeting the requirements of ISO9001:2015, ISO14001:2015, BS OHSAS 18001: 2007

NOTE: THIS IS AN UNCONTROLLED COPY OF THE POLICY MANUAL

No part of this document may be reproduced or disclosed to any other party without the prior permission of a Director of Häfele U.K. Ltd.

Issue 45 – 25.05.2017 Page 2 of 24

Revision History

Issue No

Date Amendments Who by

43 28.11.2016 Overall upgrade of manual to be complaint to ISO9001:2015 and ISO14001:2015

CC

44 01.03.2017 Amendment to Policy Statement CC

45 25.05.17 Amendment to Policy Statement JC

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Issue 45 – 25.05.2017 Page 3 of 24

CONTENTS

TITLE Page

Company Profile 4

Introduction 4

Objectives & Planning to Achieve Them 4

Internal Audit & Review 5

Regulations 5

Competence & Awareness 5

Resource – Infrastructure 5

Resources – Work Environment 5

Understanding the Context of the Organisation Internally & Externally 6

Requirements of Interested Parties 7

Determining the Scope of the Management System 8

Interaction of Processes 9

Leadership, Commitment, Organisational Roles, Responsibilities & Authorities 10

Management System Policy Statement 11/12

Health & Safety Policy Statement 13

Planning – Risks & Opportunities 14

Process 1 - Management system review 15

Process 2 - Competency, training and awareness 16

Process 3 - Monitoring and measurement including internal audit 17

Process 4 - Nonconformance reporting and corrective action 18

Process 5 - Performance measurement and monitoring 19

Process 6 - Consultation and communication 20

Process 7 - Document and record management 21

Process 8 - Identification and Assessment of H&S Risks and Environmental Aspects

22

Process 9 - Identification and maintenance of legislative and requirements register

23

Process 10 - Control of hazards/Identification of objectives 24

NOTE: THIS IS AN UNCONTROLLED COPY OF THE POLICY MANUAL

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Issue 45 – 25.05.2017 Page 4 of 24

TITLE Integrated Management System Manual

Approved By Craig Chambers – Managing Director of Häfele U.K. Ltd.

2.0 Company Profile Häfele U.K. Ltd is part of a long established German company founded in 1923. The U.K. subsidiary was founded in May 1980, and moved into their present purpose built premises in Rugby in 1984. These premises have since been expanded and state-of-the-art storage racking and conveyor equipment has been installed. The company is one of the largest furniture fittings and hardware distribution centres in the U.K. The U.K. Company presently employs approximately 402 staff. An organisation chart is available on the Intranet. Häfele U.K. (HUK) Ltd has a Management System which is in compliance with ISO9001:2015, ISO 14001:2015, SA8000 and OHSAS: 18001:2007. The company has also achieved FSC accreditation, covering the supply of wooden products. An overview of the key processes and support processes are shown below. Details of the organisational structure are available on the network. An overview of the key processes and support processes are shown below with the organisational structure.

2.1 Introduction

The Company has adopted an integrated management policy aimed at improving its performance in the areas of quality, environment and health & safety management and reducing the negative impacts of its own activities and operations.

HUK Ltd has also adopted this management system to support its policy. The system sets out the roles and responsibilities for managing, auditing, reviewing and updating its policies and procedures in support of its overall management policy.

2.2 Objectives and Planning to Achieve Them

The Company will adopt on an annual basis targets for quality, environmental and health & safety improvement. These will be specific, measurable, achievable and consistent with their stated policy continually improving their environmental and health and safety performance. Objectives and Targets will be monitored on an on-going basis by the individual given responsibility on the Improvement Programme. Overall the SMT will be responsible for achieving continual improvement throughout the management system.

The departments of HUK produce a business plan every year and KPI’s are introduced from the plans.

A full review of the Improvement Programmes will be carried out on at minimum an annual basis.

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Issue 45 – 25.05.2017 Page 5 of 24

2.3 Internal Audit and Review

The Company aims for continuous improvement in its quality, environmental and health & safety performance. To achieve this the organisation shall conduct internal audits at planned intervals to provide information on whether the IMS conforms to the organisations own requirements and the requirements of the standards. Audits shall be planned through an audit schedule that shall define the scope of the audit. Audits shall be carried out by impartial and objective auditors who shall report to management the results of the audits.

Performance will be monitored, along with progress towards any targets. Information shall be collated for an annual management review.

2.4 Regulations

The Company will review annually existing and impending legislation that impacts on its business activities.

2.5 Competence & Awareness

The senior management will arrange for training for managers and staff to assist them in their role. Training is in the form of internal, external and tool box talk format dependent on the nature of the training.

Bridge Consultants will also take steps, through visits, to improve awareness among staff generally of our aims in relation to the quality, environmental and health & safety performance of the company.

2.5 Resources - Infrastructure

Buildings – All buildings leased or owned by the company will be deemed to be a safe working environment. Internal inspections will be recorded and external reports on Asbestos and Fixed Mains Testing etc shall be conducted and retained at the site. Transport – All company fleet vehicles are serviced and maintained as per schedules through Arval. Communication – This is conducted through several avenues, Email, H&S Committee Meetings, Safety Inspections, Toolbox Talks, Training, Company Conferences, Weekly magazine – Team Focus & Policies.

2.6 Resources - Work Environment All staff shall be afforded a good working environment to conduct their business. Welfare arrangements will be available through toilets, rest areas, water and coffee machines etc. The working environment shall be deemed safe through internal inspections and external regulatory inspections such as Gas Boiler / Fire Alarm servicing, PAT testing and Fixed Electrical testing etc. Risk Assessments including COSHH Risk Assessments are completed by the company and are held at the site. PPE is issued to all HUK staff as required, and a master record of issued equipment is maintained and held by the H&S department.

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Issue 45 – 25.05.2017 Page 6 of 24

4.1 Understanding the Context of the Organisation Internally and Externally

Landlord – No Interest

HUK own their site at Rugby .

HafeleExternal

context

Suppliers – InterestedMain suppliers are numerous of which the company endeavour to

have at least 2 suppliers per category , thus minimising the loss of a supplier .

Customers – Significant Interest

Customers are varied and include B &Q, Wickes, KBB manufacturers /studios , shop fitters , independent trade distributors , but do not include members of the

public . The service provided by HUK enables its customers to meet their

needs and requirements .Markets/Trends – Significant Interest

HUK are extremely aware that changes in the market could significantly affect their business and the Senior staff are constantly looking out for indicators and trends . Expected sales for new product ranges

are forecast prior to purchase . The Company has broadened the products that they offer in order to reduce the potential impact of competitors and market changes .

Media - InterestedHUK have their own website and social media pages and use this to publish

information regarding their activities . Sometimes this information is picked up by the press and can result in wider good publicity . Otherwise It is unlikely that HUK or their

activities would be of great interest to the media .

Central and LG – Little Interest

Other than paying Business Rates and providing employment , their interest is low.

Public, Neighbours and local community - Little InterestHUK is based at an industrial estate in Rugby , Warwickshire, Neighbours

include business and houses . The company provides employment for

approximately 402 staff .

Regulators and legislation – Significant interestHUK themselves are subject to typical legislative requirements including those applying to

H&S, Environment , business and employment . Legislation is reviewed on an ongoing basis

through NQA In Touch subscription .

Shareholders /Board –Significant InterestHafele is a family ran Limited Company and the Directors of HUK are either current or former

employees . Any issues would therefore be an internal issue and would be dealt with by

Senior Management .

Environmental and Geographical – Little InterestHUK are located on an industrial estate in Rugby .. There are 2

watercourses , in the general area but no SSI or significant wildlife in the

vicinity. The impact of HUK’s operations on the local environment is negligible . It is extremely unlikely that HUK would be affected by flooding or

other natural disaster .

Trade Unions

Very few of HUK’s staff belong to a trade union (GMB).Unions would only get involved at the company on an as required basis . Unions

would look for the best outcome for its members .

Political – Little Interest

The nature of HUK’s work will result in little to no political interest .

Cultural /Social – Little InterestHUK fit well into the local scene , employing local people . It is unlikely that

they would have any significant impact or that cultural issues would greatly

affect HUK .

Competitors – Significant InterestHUK have numerous major competitors in the UK but any companies who offer office

furniture and fittings as well as ironmongery and architectural products of a nature that matches HUK are considered to be competitors .

Employees and staff

HUK has 402 FT Employees . Employees serve a probationary period . All staff are

responsible for ensuring customer

satisfaction , health safety and welfare , IMS requirements and all regulatory

requirements .

HafeleInternal context

Work culture

HUK has encouraged employees to feel they belong to a ‘family’ and to treat everyone and

everything associated with HUK with respect and to expect respect and loyalty in return . This

includes meeting customer needs and ensuring

health safety and welfare , and environmental compliance .

Internal practices and processes

These have been developed and implemented over many years and are ‘ 2nd’ nature to most staff .

Operating to consistent processes ensures that

HUK achieves its objectives including customer satisfaction and ensuring health safety and welfare ,

and environmental compliance .

Organisation /StructureHUK has a defined structure which allows staff to interact and

cooperate with one another and external sources , and which

ensures that information and data flows are effective and secure.

Policies

These have been developed in the light of experience , customer requirements , Env , H&S welfare and regulatory

requirements .

Objectives and strategy

HUK has a clear vision of what it wishes to achieve and this is detailed in the IMS policy & the improvement

programmes .

ResourcesHUK constantly reviews its resource requirements , both

human and other and ensures that as far as practicable

these are adequate to achieve the Policy , Strategy and Objectives .

Expertise and competence

Staff competence is reviewed for the offices by line managers on an annual basis via appraisals and for the

warehouse by quarterly performance reviews , and further development needs are identified and staff training

implemented . This competence includes meeting

customer requirements , ensuring EH &S and regulatory requirements where appropriate .

Premises

HUK occupy offices and warehouses at its Rugby site which are

modern and well kept and suitable for the activities performed there.

Business planning

Sales/Marketing

Contract Review

Availability

Purchasing

Production/

service

Accounts

Customer

Technology

The company utilises latest technology for office and warehouse based staff for company business .

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Issue 45 – 25.05.2017 Page 7 of 24

4.2 Requirements of Interested Parties

Interested parties include those shown above in the ‘Context’ diagrams.

The significant requirements of these parties include:

• Customers – these are defined in the “agreements or orders” agreed with each Customer but will generally include ‘The stockholding and distribution of fittings and accessories to the furniture manufacturing and architectural ironmongery industries’.

Customers’ needs and expectations shall be for the company to provide product(s) at an agreed price in a time frame that is acceptable. Environmentally needs and expectations are few but a good company name is essential to ensure continued business. HUK will be expected to continue to conduct good practises and not have its name linked to issues that portray the company in a bad light, be it of a H&S or environmental nature.

• Regulators – The Company is subject to a number of regulations including LOLER for the picking cranes compliance with further legal areas to be met such as manual handling regulations, these are further defined in the Compliance audits and in the IMS Manual. Legislation is considered implicitly during the risk assessment and if appropriate would affect the risk rating.

The needs and expectations of the regulators such as the HSE and the EA will be for the company to remain compliant with the regulations and as such the requirement for visits by the regulators not be required. The need to perform well from a H&S & Environmental prospective will keep our staff fit for work and environmental aspects controlled.

• Suppliers – these are controlled through the SAP systems and suppliers must be approved prior to use. HUK reviews its suppliers annually but considers the risk low.

The needs and expectations of our suppliers will be reciprocated. HUK will expect its suppliers and contractors to maintain high levels of service whilst ensuring a high standard of controls from an H&S and Environmental nature. The suppliers and HUK need to perform business with reputable companies and a poor reputation could affect business between HUK and a supplier/contractor.

• Competitors – Competitors in this market area are numerous and do pose risk to the continued success of the business and would be very interested in the work carried out by HUK. Protecting data is considered and conducted.

• Shareholders – As the investors in the Company, the needs of the Shareholders will include ensuring that the business is successful and gives them a return on their investment.

• Markets/trend – The Company have taken action to expand their product range through purchasing the latest products and equipment for the business requirements. The needs of the business are to stay at the forefront of market sector and ensure the most modern technology and equipment/products are sought out and added to the product range for sale or use by its staff. Customers expect to be able to buy the latest products or equipment from HUK and ensuring realisation for its customer base is paramount to continued and long term success.

• Employees and staff – employees are interested in being suitably rewarded for the work they perform. Risks to the Company are considered in the Business Continuity Plan.

The needs of the staff also include the continued success of the business in order to retain their employment within HUK. Staff are vital to this element as they provide the man power and expertise to ensure the company continues to thrive.

• Resources and premises – these are essential to the success of the business and their provision and maintenance is constantly under review. Staff will expect to work in an environment that safe, clean and maintained well. The company has in place contracts with various contractors for pre-planned maintenance of gas boilers and air conditioning for example. Senior Management review resources at meetings and resources are always on the agenda to ensure the most modern equipment is utilised by the company.

• Internal practices and processes – To help ensure that the business is managed effectively and is compliant with applicable health, safety and environmental legislation and requirements, HUK has implemented an Integrated Management System that conforms to ISO9001, ISO14001, OHSAS18001.

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No part of this document may be reproduced or disclosed to any other party without the prior permission of a Director of Häfele U.K. Ltd.

Issue 45 – 25.05.2017 Page 8 of 24

4.3 Determining the Scope of the Management System

HUK, offer the stockholding and distribution of fittings and accessories to the furniture manufacturing and architectural ironmongery industries. The head office is in Swift Valley Industrial Estate in Rugby, Warwickshire.

Full details of the organisational structure are available with individual responsibilities detailed in the IMS Manual & H&S Roles & Responsibilities and in job descriptions.

All personnel (employees, temporary staff and contractors) are responsible for ensuring that they work within the framework of the management system, irrespective of geographical location and contribute to its continual improvement. The company has considered its external and internal requirements on page 7 and is fully aware of its compliance obligations for the business including our compliance requirements when working as either a sub-contractor or main contractor for our customers. Potential environmental hazards – these are hazards which may have an impact on the environment. Those which arise as a result of HUK’s activities may include energy and raw material usage, waste (general waste, cardboard, paper, IT equipment, hazardous waste etc), emissions from heating boilers, etc.

This document describes the management system applicable to HUK. It includes the requirements of: ISO9001:2015; ISO14001:2015 and OHSAS18001:2007. The company is certificated with NQA to show that it complies with the above-named standards.

The scope of this system covers ‘The stockholding and distribution of fittings and accessories to the furniture manufacturing and architectural ironmongery industries’.

The company does not perform any design work or retain customer property and therefore Clauses 8.3 & 8.5.3 of ISO9001:2015 are determined not applicable to the scope of the management system.

There are no elements of the ISO14001 or OHSAS18001 standards that are deemed not applicable to the business.

Associated Documents Cross-references to the next level of documentation are specified herein.

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Issue 45 – 25.05.2017 Page 9 of 24

4.4 Integrated Management System

HUK has determined the processes needed for this IMS and where deemed appropriate and/or necessary these are documented. High level Process Maps are provided in this Manual which show the inputs and outputs, the sequence and interaction, control criteria, resources required, responsibility and authority. The risks and opportunities have been determined as detailed in 6.0 below. Monitoring and review of the processes encourages improvement of the processes and the associated procedures / records for the overall enhancement of the Management System. The determination of its internal and external requirements has been reflected in 4.1, 4.2 & 4.3.

Initial status review (Gap

analysis or PER) or

ongoing monitoring

Identify working practices,

hazards and

environmental aspects and

carry out risk assessments

Identify applicable

legislation and maintain

register

Ensure that risks are

controlled and/or subject

to an improvement

programme

Feedback into

management

review

Environmental and

H&S process

Support processes

include:

Monitoring and

review

Internal audit

Corrective action

Preventive action

Document control

Competency

Business planning at

Corporate and Site level

(Setting and review of

objectives)

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Issue 45 – 25.05.2017 Page 10 of 24

5.0 Leadership

5.1 Leadership Commitment, Organisational Roles, Responsibilities & Authorities

The Directors of HUK have overall responsibility for taking accountability for the Management System, ensuring the policy & objectives are established and in context with the strategic direction of the company, promoting the use of risk based thinking, ensuring resources are available, communicating the importance of the management systems and the requirement of conformance to it, ensuring the targets are met, ensuring the promotion of customer focus, engaging, directing and supporting the directors/managers and other staff to ensure the effectiveness of the IMS, promoting continual improvement and ensuring the integrity of the management system when changes are required.

The IMS Manager, John Callaghan & H&S Manager Rhiain Liquorish have responsibility for reporting to the other Directors on the performance of the management system, ensuring the processes deliver their intended outputs, planning and implementing changes aimed at achieving agreed targets, arranging audits and reviewing with the directors the company quality, environmental, H&S and sustainability performance. He is assisted in this role by managers and Bridge Consultants.

Managers working in locations across the company are responsible for promoting the IMS policy in their areas and providing reports on performance.

Staff and any contractors working on the premises are expected to follow the principles of the IMS policy statement and its supporting policies and procedures.

Bridge Consultants have been appointed by HUK to provide competent quality, health, safety and environmental guidance and support to the company as may be required.

The IMS Manager, H&S Manager & Bridge Consultants all have responsibility for maintaining and auditing the system.

For a full description of individual H&S responsibilities please refer to the H&S Roles & Responsibilities document.

- Has defined the roles,

responsibilities and authority

regarding this MS.

- Ensures that performance

reports regarding the MS are

reviewed by top management.

- Ensures that adequate

resources are provided for this

MS.

- Are responsible for the

implementation and

maintenance of this MS.

R Liquorish

Health & Safety

Manager

R Liquorish

Health & Safety

Manager

Craig Chambers

Managing Director

Craig Chambers

Managing Director

J Callaghan

Integrated

Management

Systems (IMS)

Manager

J Callaghan

Integrated

Management

Systems (IMS)

Manager

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Issue 45 – 25.05.2017 Page 11 of 24

5.2 Management System Policy Statement

The Häfele U.K. Ltd. IMS Policy is available in this manual below, on the network and on notice boards around the site. It is made available to interested parties upon written request, and is communicated throughout the Company.

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Issue 45 – 25.05.2017 Page 12 of 24

Integrated Management Systems Policy Statement Häfele U.K. Ltd. is committed to providing a service to our customers which ensures that they are provided with the best possible product and service, whilst endeavouring to protect the environment, our employees, visitors and all others who may be affected directly, or indirectly, by our activities.

In particular, we shall:

seek to establish, maintain and continually improve an Integrated Management System (IMS) addressing the requirements of ISO 9001 (Quality) / 14001 (Environmental) / 18001 (Health and Safety), FSC-STD-40-004 (V.02) EN and SA8000 (Social Accountability);

seek to ensure compliance with current and future environmental, social responsibility, and health and safety legislation as applicable, relating to our operation, and any other initiatives or requirements to which the company may subscribe;

commit to liaise with all relevant external bodies and work with our own staff to continually improve our quality, environmental, social responsibility, and health and safety performance, prevent accidents and cases of work related ill health, and maintain safe and healthy working conditions;

identify and seek to reduce significant environmental aspects, health and safety risks, and prevent any pollution which may arise from our processes, operations and work activities;

provide appropriate quality, environmental, social responsibility, and health and safety information and training for our employees, building on competencies and encouraging them to apply good practice, both at work and at home;

provide and maintain safe plant, premises and equipment and minimise, re-use and recycle all packaging materials wherever practicable;

notify our employees, vendors and customers about our Ethics, Anti-corruption and Gifts policies and enforce them accordingly.

discuss quality, environmental, social responsibility, and health and safety issues regularly at the highest levels of the company, consulting and communicating, where appropriate, with our employees on all issues affecting them;

liaise with vendors and customers to facilitate the best possible products, service, safety, social responsibility, and environmental practices and to promote recycling;

seek to ensure that the sustainability and recyclability of proposed new products is considered before they are accepted into our product range;

inform our vendors of and enforce the company’s Terms and Conditions policy, which insists that all wooden products provided by our vendors originate from controlled wood sources and, when specified by our customers, from approved Forestry Stewardship Council (F.S.C.) certified sources;

establish, implement and review environmental objectives and targets annually, which will be measurable where practical and linked to the company’s main environmental aspects, and these will be published in an annual Improvement Programme which the I.M.S. Manager is responsible for generating and monitoring.

review and revise this policy as necessary at regular intervals. Sound management principles and practices shall be documented, maintained and applied to realise these commitments, and to achieve demanding and publicly available performance objectives. Arrangements to review our objectives, scope, environmental aspects and performance reviews may be made by writing to: John Callaghan, I.M.S. Manager, who will also welcome any observations on the quality, environmental, social responsibility, or health and safety aspects of our activities.

Issue L

Mr. C. Chambers, Managing Director Circulation: Reception (Swift Valley) Häfele U.K. Ltd. Lobby (Haynes Way)

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Issue 45 – 25.05.2017 Page 13 of 24

Health and Safety Policy

Health and Safety Policy Statement

Häfele UK Limited will:

• establish and implement a health and safety management system to manage the risks associated with our premises and activities

• regularly monitor our performance and revise our health and safety management system as necessary, to ensure we achieve our objective of continuous improvement

• provide sufficient resources to meet the requirements of current health and safety legislation, and aim to achieve the standards of good practice applicable to our activities

• actively promote an open attitude to health and safety issues, encouraging staff to identify and report hazards so that we can all contribute to creating and maintaining a safe working environment

• communicate and consult with our staff on all issues affecting their health and safety and, in doing so, bring this policy to their attention

• provide adequate training for our staff to enable them to work safely and effectively, and to ensure they are competent and confident in the work they carry out

• carry out and regularly review risk assessments to identify hazards and existing control measures; we will prioritise, plan and complete any corrective actions required to reduce risk to an acceptable level

• maintain our premises and work equipment to a standard that ensures that risks are effectively managed

• ensure that responsibilities for health and safety are allocated, understood, monitored and fulfilled

• provide health surveillance for staff where appropriate, and maintain records

• co-operate with other organisations in these premises to ensure that they are aware of any risks to their staff and other people posed by our activities, that we are aware of any risks to our staff from their activities, and that we comply with the relevant requirements of fire legislation

• co-operate with other organisations on construction sites to ensure that they are aware of any risks to their employees and other people posed by our activities, that we are aware of any risks to our employees from their activities, and that we comply with the requirements of relevant legislation.

It is the duty of all of us when at work to:

• take reasonable care of our own safety

• take reasonable care of the safety of others who may be affected by what we do or fail to do

• co-operate so that we can all comply with our legal duties

• ensure we do not interfere with or misuse anything provided in the interests of health and safety.

Issue 2

Mr. Craig Chambers, Managing Director Circulation: Reception (Swift Valley) Häfele U.K. Ltd. Lobby (Haynes Way)

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Issue 45 – 25.05.2017 Page 14 of 24

6.0 – Planning – Risks & Opportunities

The Directors of Häfele U.K. Ltd. have overall responsibility for determining the Risks and Opportunities that are associated to the business. Risks and opportunities can be attributed to the specific type of business or through the needs and expectations of its interested parties. The company has produced a Risk & Opportunities spreadsheet that highlights these areas. This document is an open record that shall be reviewed annually.

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Issue 45 – 25.05.2017 Page 15 of 24

Key Processes

PROCESS 1 Management System Review Process owner

SCOPE To review the suitability and effectiveness of the management system, identify opportunities for improvement and, where appropriate, initiate corrective or preventive actions.

Managing Director

Inputs

• Company feedback

• Client feedback

• Stakeholder feedback

• Audit feedback

• Accident statistics

• QA, Env and H&S feedback

• Supplier feedback

• Health & Safety committee meetings

• Legislative & compliance review

• Health & Safety policies review

Note: Ensure that at least annually, the Management Review Meeting evaluates the continuing suitability, adequacy and effectiveness of the IMS and records the conclusion. In addition, the meeting should consider changes to the policy, objectives and the other elements of the MS as a result of audit findings, changing circumstances and the commitment to continual improvement.

Outputs

(EMS and QMS) Resource issues, People issues, Other issues, Prioritisation, Responsibilities, Review of policy, strategy and objectives, Legislative review, Environmental Initiatives, Environmental Issues. Audit feedback and review Preventive action Nonconformance review Resource review (Health & Safety) Accident review and statistical analysis, Preventive action, Corrective actions, Legislation review, Nonconformance review, Compliance review, Safety initiatives, Health & Safety Committee feedback and reporting, General Health & Safety root cause analysis, Contractor control issues, Safety training, Emergency preparedness review and feedback, Resources issues, Health & Safety business plans, improvement plans and progress developments, RIDDOR related accidents, MORR related issues Management Review ISO Inputs include; Results of internal audits & evaluation of compliance with legal requirements, Communication from external parties, Environmental performance of organisation, extent of which targets/objectives have been met, status of incident / corrective actions, follow up actions from previous MR’s, changing circumstances & recommendations for improvement, Customer Feedback, Process Performance, Opportunities for continual improvement, Performance of external providers, Adequacy of Resources, Risks & Opportunities.

Outputs

• See list beside flowchart.

• Preventive action is considered at all levels as can be seen from the various meeting minutes and outputs.

Minutes are retained indefinitely in electronic format.

Control elements

• Internal work instruction QA.10

• Legislation

• ISO9001, ISO14001 and OHSAS18001

• Policy

Responsibilities

• Managing Director

• IMS Manager

• Health & Safety Manager

Interfaces

• All processes

Process metrics

None are in place for this process although overall company performance (in terms of profitability, H & S and environment) can be taken as an indication of the effectiveness of the process to ensure that continual improvement takes place and that the company’s objectives are met.

Health & Safety KPI dashboard includes a number of relevant, measurable and comparable process metrics, these include the following, accident statistics, near miss statistics, audit Nonconformances, Risk assessments, DSE assessments, driving licence endorsements.

Environmentally energy usage & waste recycling information is monitored for improvement.

Interim IMS Management

Review Meetings

IMS Management Review Meeting

(Annual)

H & S meeting (Biannual)

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Issue 45 – 25.05.2017 Page 16 of 24

PROCESS 2 Competency, training and awareness Process owner

SCOPE To ensure that training and development needs are identified and that employees are competent

Managing Director

Inputs

• Competency records

• Job descriptions

• Training information

• Performance appraisal information

• Legislation

• Resources

Review requirements and identify the human

resource need

This may take place when objectives are reviewed or as the need arises (e.g to cover maternity leave, leavers etc)

Define the

competencies

required and draw

up a job

description if

appropriate

Ensure that the relevant quality, environmental and H & S issues are defined including any specific QA, Env. and/or H & S roles and responsibilities.

Induction training must include any relevant quality, environmental and H & S training. The development needs may include quality, environmental and H & S issues. Such as Env. aspects. This takes into a/c ability and the risks of the job.

Recruit the

appropriate

person

Provide induction

training and

assess

development

needs

Provide

appropriate

training

Review the

effectiveness of

the training

Carry out

appraisals

Conduct interview, assess, take references, evaluate skill levels.

This may include quality, environmental and H & S training including general awareness training.

Contractor Competence Where applicable copies of competence records shall be retained by the company for contractors conducting works at the site.

Outputs

• Competency records

• Performance appraisal Documentation

• Training needs

• Training plan

• Post course evaluations

• Policy Statement

• Environmental Aspects Records are retained by HR.

Control elements

• Internal work instruction MIS.02

• ISO 9001, ISO14001 and OHSAS18001 requirements

• Legislation

Responsibilities

• Managing Director

• HR & Development Director

• Managers

• Learning & Development Advisor

Interfaces

• All processes

Process metrics

Owned and maintained by the Managing Director & Representatives

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Issue 45 – 25.05.2017 Page 17 of 24

PROCESS 3 Monitoring and measurement including Internal audit Process owner

SCOPE To assess the effectiveness of the integrated management system and compliance with ISO 9001, ISO 14001 and OHSAS18001.

Managing Director

Inputs

• Previous findings

• Accident records and reports

• Criticality of process

• Internal auditor resources

• Inspection checklists

• ISO9001, ISO14001 and OHSAS18001

• Audit checklist

Compile an annual audit schedule

and agree inspection regime

This process will take into account the results of previous audits, inspections and other monitoring and the criticality of the process. In addition the available resource will be considered.

Plan and carry out

the audit

As part of the audit process ensure that compliance with legislative requirements is evaluated. The standard audit form defines the methodology of the audit process.

Consider the

findings and

implement

corrective action if

appropriate.

Follow up to

ensure that the

corrective action is

effective

Implement

inspection process

(see notes re

frequency)

Report inspection

findings and

implement

corrective action if

appropriate

Notes:

1. Auditors shall be independent of the process being audited.

2. The audit scope and frequency is defined in the audit schedule.

3. All internal auditors have undergone training and their competency

has been assessed and recorded.4. Inspections are carried out by nominated persons.5. Any nonconformity raised at an internal audit will be recorded on the audit report – a separate nonconformance report is not used.

Compile audit progress summaries for

quarterly Quality Reports and a full audit

summary report for senior management, as

part of the annual QMS/EMS review.

Outputs

• Audit/monitoring report (including corrective action requests)

• Approved audit programme

• Inspection results

• Monitoring programme (e.g. areas monitored by Occupational Health)

• Closure of corrective action(s) Records are retained on the network.

Control elements

• Internal work instruction PM.05

• ISO9001, ISO14001 and OHSAS18001 requirements

• Legislation

Responsibilities

• Managing Director

• IMS Manager

Interfaces

• All processes

Process metrics

Owned and maintained by the Managing Director.

Health & Safety KPI dashboard includes a number of relevant, measurable and comparable process metrics, these include the following, accident statistics, near miss statistics, audit Nonconformances, Risk assessments, DSE assessments, driving licence endorsements.

Environmentally energy usage & waste recycling information is monitored for improvement.

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Issue 45 – 25.05.2017 Page 18 of 24

PROCESS 4 Nonconformance Reporting & Corrective Action Process owner

SCOPE Identification and control of nonconforming materials and other entities and the subsequent corrective action taken to eliminate the cause of nonconformity and prevent recurrence. Includes complaints and accident and incidents.

Managing Director

Inputs

• Identification of nonconformity

• Risk assessments

• Accidents and Incident reports

• Complaints

• Nonconformance report

• Trend analysis (recurrences)

• Root cause analysis

• Results of actions taken

• Feedback on effectiveness of action taken

• Inspection and audit results

Feedback to

management

This includes accidents, incidents and nonconformances.Ensure that the H & S Arrangements Manual and RIDDOR reporting requirements are followed in the event of an accident or near miss.

Notes:1. Nonconformances include material defects, process errors, internal audit findings, environmental issues (spills etc) and H & S Issues (accidents, inspection results).2. NCs can be raised by any employee.3. Nonconformances raised at internal audits are recorded on the audit report. A separate nonconformance report is not used.

Investigate and review

the nonconformance

Agree corrective

action and implement

Follow up to ensure

that the corrective

action is effective

Where necessary take

immediate action to

limit or mitigate the

consequences of the

nonconformance

Identify and record environmental

non-conformance

Identify and record H & S

nonconformance

When this involves H & S ensure that a risk assessment is carried out prior to the implementation of corrective action.

Outputs

• Nonconformance report

• Identification of root cause

• Identification of corrective action(s)

• Implemented corrective action

• Elimination of recurrence All appropriate records are retained indefinitely on the network.

Control elements

• Internal work instructions Q.A.04 and PM.06

• H & S Arrangements Manual

• Legislation

• ISO9001, ISO14001 and OHSAS18001

Responsibilities

• Managing Director

• IMS Manager

• Health & Safety Manager

Interfaces

• All processes

Process metrics

Owned and maintained by the Managing Director & Representatives

NOTE: THIS IS AN UNCONTROLLED COPY OF THE POLICY MANUAL

No part of this document may be reproduced or disclosed to any other party without the prior permission of a Director of Häfele U.K. Ltd.

Issue 45 – 25.05.2017 Page 19 of 24

PROCESS 5 Performance measurement and monitoring Process owner

SCOPE To ensure that the performance of the firms integrated H & S and Environmental system is measured and monitored on a regular basis.

Managing Director

Inputs

• Accident and H&S records

• Inspection results

• Progress to achieving objectives and improvement programmes

• Analysis of historical data

• Corrective actions

• Results of actions taken

• Feedback on effectiveness of action taken

Monitor whether the

objectives and improvement

programmes are being met

This function is carried out mainly through the Management Review meetings.

This process ensures that the Integrated Management System is monitored and measured on a regular basis. See also Processes 1, 3 and 11.

Ensure that pro-active monitoring takes place via inspections, risk assessments, OH surveillance, and internal audits.

Ensure that re-active

measures of performance

are collated and considered

Ensure that sufficient data

is available to facilitate

corrective and preventive

action analysis

Ensure that monitoring

equipment is calibrated and

maintained where

appropriate and that

records are retained.

Ensure that monitoring takes

place to ensure compliance

with all applicable legislation

This is carried out in a number of ways e.g. accident reports and investigations, environmental incident reports.

This is usually carried out within the audit programme.

These re-active measures include accident and ill-health statistics, environmental incidents, and the results of OH monitoring.

Outputs

• An effectively monitored IMS

• Statistical analysis

• Process improvement All records are retained indefinitely on the network.

Control elements

• Internal work instructions Q.A.10 and PM.05

• Legislation

• ISO9001, ISO14001 and OHSAS18001

Responsibilities

• Managing Director

• IMS Manager

• Health & Safety Manager

Interfaces

• All processes

Process metrics

Improvements in the performance of the IMS including, energy review, waste statistics, customer feedback, accident statistics

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Issue 45 – 25.05.2017 Page 20 of 24

PROCESS 6 Consultation and communication Process owner

Scope To ensure that internal and external communications are dealt with and that internal communication takes place

Managing Director

Inputs

• Communication channels

• Compliance Obligations

• Employee awareness

• Internal and external communications

• Articles/items of interest

Ensure that all employees are aware

of the lines of communication

It will have been explained at induction briefings, who the relevant managers are and their roles. e.g. IMS Manager and Health & Safety Manager.

Distribute articles of

interest via the notice

boards and the

network

In particular where possible use the e-mail facility to raise awareness.

During audits and

inspections involve as

many employees as

possible in order to

heighten awareness

Ensure that external

requests and

communications are

directed to the

appropriate manager.

Ensure that a copy of

the IMS Policy is

available in strategic

locations e.g.

Reception

Ensure that a copy of

all communications

are dealt with and

records retained.

All employees are aware of the roles of the various managers and can direct enquiries to the appropriate location.

Audits should attempt to involve a broad range of employees over a period of time. They can be used as a form of ‘toolbox’ talk.

All communications are retained and dealt with by the appropriate manager and usually retained on the network. Supply details to the MR and meetings as appropriate.

Notes:1. It has been agreed that the aspects and the policy will not be communicated to outside parties except upon written request.2. A MR meeting is held at least annually and considers changes that may affect Quality, Env. and H & S. It also ensures that employees are represented.

Communicate IMS

and H&S

requirements to

contractors and others

working on behalf of

the firm

This is carried out as part of the supplier approval process or as part of the setting up of a maintenance project e.g. Site inductions

External Communications All external communications to the company regarding the IMS shall be made in writing to the IMS Manager. This can include the policy, aspects, objectives or performance of the organisation.

Outputs

• Increased employee awareness

• Communications dealt with

• Communications recorded

• IMS policy available All records are retained indefinitely on the network.

Control elements

• Legislation

• ISO9001, ISO14001 and OHSAS18001 requirements

Responsibilities

• Managing Director

• IMS Manager

• Health & Safety Manager

• All employees

Interfaces

• All processes

Process metrics

Owned and maintained by the Managing Director & Representatives

NOTE: THIS IS AN UNCONTROLLED COPY OF THE POLICY MANUAL

No part of this document may be reproduced or disclosed to any other party without the prior permission of a Director of Häfele U.K. Ltd.

Issue 45 – 25.05.2017 Page 21 of 24

PROCESS 7 Document and Record Management Process owner

SCOPE Control of documentation and records including the results of audits and reviews

Managing Director

Inputs

• Documents

• Records

• Legislation

• Resources

• IMS requirements

• Internal requirements

• Client requirements

Identify documents, data and records which

require control

Ensure that documents

are uniquely identified,

and stored safely

Documents are given a unique title and their revision status is usually denoted by a ‘Last revised date’. Storage is almost always on the network.

Although some documents and records are printed for easier access, these are deemed to be uncontrolled documents.

An archive of obsolete

documents is maintained

In future, virtually all

documentation will be

available on the network,

and will be the only

authorised version

available

Ensure that computer

backups are made, that

virus protection is in

place, and that access to

the network is via a

secure system

Ensure that only

authorised software is in

use

Periodically review

the adequacy of the

process via the audit

process

Ensure that documents

are reviewed as

necessary and approved

Documents are reviewed by the issuer prior to release. Release on to the network confirms that they have been reviewed and approved.

Define retention times

Retention times and storage locations are defined in the Master List although almost all documents and records are retained indefinitely via electronic backup on the network.

Obsolete documents and records are removed from the point of use and archived. This is almost always carried out electronically.

External Documents

External documents are identified by type, i.e Fire Alarm test certificates, PAT testing, Mains testing, waste transfer notes and air conditioning service records. These are retained by the H&S or Environmental Managers.

Outputs

• Master list

• Computer backups

• Identified documents

• Authorised documents

• Software licences

• Virus protection

• Up-to-date standards and manuals etc

Records are retained either on the network or locally in hard copy.

Control elements

• Internal work instruction PM.01

• Legislation

• ISO9001, ISO14001 and OHSAS18001 requirements

Responsibilities

• Managing Director

• IMS Manager

• IT Director

Interfaces

• All processes

Process metrics

None in place at present

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No part of this document may be reproduced or disclosed to any other party without the prior permission of a Director of Häfele U.K. Ltd.

Issue 45 – 25.05.2017 Page 22 of 24

PROCESS 8 ID & Assessment of Health & Safety Risks & Environmental Aspects Process owner

SCOPE To ensure that all H & S and environmental aspects are identified,

the risk assessed and appropriate controls implemented. Managing Director

Inputs

• Environmental review

• Up-to-date legislative register

• Monitoring reports/previous findings

• Competent assessors

• RA form for Env. and H & S

• Guidance re H & S RAs

• H & S Arrangements Manual

• Code of Practice for Contractors and visitors

• Equipment

• Resources

Identify and review processes

(including activities of all personnel, subcontractors,

visitors and facilities provided by others)

This was carried out in the first instance by means of a gap analysis for the environment and H&S. The documents are available in the file and will be retained indefinitely.

Consider various operating

conditions and identify

environmental aspects and

H & S hazards

Some aspects and hazards only occur under particular operating conditions or are non-routine. Where possible these conditions are taken into account during the identification and RA process.

Carry out a risk

assessment of the

identified aspects and

hazards

Draw up register of

significant

environmental aspects

The Environmental RAs are carried out by competent persons using the defined template. This results in all aspects being rated and allows them to be ranked in order of significance. In doing this any legislative or other requirements (e.g. Company Policy, other requirements etc) are taken into account.

The environmental aspects are then ranked. In this case all aspects having a rating higher than 18 are considered to be significant and would be included on the Register of Aspects.

Consider control

measures and/or

improvement

programmes

All environmental aspects and H & S hazards are then reviewed to determine whether further controls (e.g. training, operational control or facility requirements) are necessary or whether an improvement programme could be implemented.

The H&S RAs are carried out by competent persons using the defined process laid down by the standard RA sheet. This means that the hazards are reviewed w/o controls and then with necessary controls. This results in all hazards being rated. In doing this any legislative or other requirements (e.g. Company Policy, other requirements etc) are taken into account.The H&S controls or need for improvement are identified at this stage e.g. training, guards etc.

H & S

RAs

Review and re-assess

new controls prior to

implementation

Monitor required

actions to

ensure

effectiveness

(via audits,

inspections,

H&S and

other meetings)

Implement controls or

improvement

programme

Notes:

1. H&S RAs are carried out by persons who have been trained in H & S risk assessment techniques. Records of training are

retained.

2. Environmental RAs are carried out by persons who have been trained in Environmental risk assessment techniques. A record of

this training is retained.

3. Subcontractors visiting the site are required to identify both H&S and Environmental hazards or aspects likely to arise due to

their work on site. They must submit RAs and Method Statements if deemed appropriate by the Manager involved.

4. Pro-active reviews of the hazards and RAs take place at least annually as defined on the RA.

5. Re-active reviews take place after accidents or incidents, OH monitoring etc.

6. Risks are classified as defined in the RA templates for both H & S and Env.

7. Employees are involved in the ID of hazards and aspects and in the RA process.

New processes including projects, equipment etc are reviewed and if appropriate an RA carried out prior to the implementation of the process. Existing processes are reviewed annually or in the event of an accident or incident.

All environmental aspects and H & S hazards are then reviewed to determine whether further controls (e.g. training, operational control or facility requirements) are necessary or whether an improvement programme could be implemented.

Outputs

• Master list of aspects for environmental issues

• Completed risk assessments

• Required control measures

• Improvements (Objectives and action plans)

All records are retained indefinitely on

the network.

Control elements

• ISO9001, ISO14001 and1OHSAS8001 requirements

• Company requirements

• Legislation

Responsibilities

• Managing Director

• IMS Manager

• Health & Safety Manager

Interfaces

• All processes

Process metrics

• Reduction in accidents/incidents

• Reduction in environmental issues

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Issue 45 – 25.05.2017 Page 23 of 24

PROCESS 9 Identification and maintenance of legislative and requirements register Process owner

SCOPE To ensure that all legislation and requirements related to the

company’s operations and products are identified. Managing Director

Inputs

• In Touch legislation up-date service

• Croner Environment and H & S

• Master list of aspects and hazards

• Completed risk assessments

• Monitoring reports/previous findings

• Other requirements

• Equipment

• Resources

Identify and review applicable legislation

This was carried out in the first instance using NetRegs as a reference. Thereafter, a subscription to In Touch and Croner is maintained both of which issue frequent updates.

Consider other requirements

This includes customer requirements, and the objectives of the Company.

Prepare and

maintain a

legislative register

Ensure that

employees and

others are aware

of changes as

appropriate

This is a document which lists legislation which may be applicable to the Company. It is retained on the network and includes a brief description of the legislation or other requirement where appropriate.

The effectiveness of the process is monitored and compliance with legislation is checked

periodically via the audit process.

Legislative changes are generally identified by the IMS Consultant or Health & Safety Manager, who informs the appropriate persons. E-mails and notice boards are used to inform employees re important issues.

Outputs

• Applicable legislation and requirements identified in connection with an aspect or process

• Employees and stakeholders who are aware of appropriate legislation or its impact on the company’s processes

• Up-to-date register and risk assessments retained on the network

All records are retained indefinitely on the network.

Control elements

• ISO9001, ISO14001, OHSAS18001 requirements

• Legislation

Responsibilities

• Managing Director

• IMS Manager

• Health & Safety Manager

Interfaces

• All processes

Process metrics

• Improved awareness of legislative requirements

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Issue 45 – 25.05.2017 Page 24 of 24

PROCESS 10 Control of hazards/Identification of objectives Process owner

SCOPE To ensure that control measures are in place and to establish

objectives, targets and improvement programmes Managing Director

Inputs

• Company strategy and business plan

• Master list of aspects and hazards

• Completed risk assessments

• Monitoring reports/previous findings

• Equipment

• Resources All records are retained indefinitely either in hard copy or on the network.

Notes:

1. The setting of high level objectives takes place mainly within the Company Strategy meetings to ensure that the corporate objectives are understood and considered when the departmental business plans are being drafted. However lower level objectives or improvement programmes and the identification of controls result from the Risk Assessment or Aspect evaluation process.2. Where practicable objectives are quantifiable. 3. Responsibilities and timescales for objectives are documented.

ID and review objectives and/or control measures

as appropriate

Identify required control measures from the Risk Assessments, Inspection results, Audit results, accident records and any other monitoring carried out.

Take measures to

achieve the objective

including cascading to

the relevant function

and level

Where appropriate draw up an action plan to ensure that the objective is achieved and/or that the control measure is put in place

Review the

achievement of the

objective usually by

the appropriate

manager

Feedback review

information

When identifying and reviewing objectives, take into account statutory requirements, best practice, other requirements, mission statement, results of RAs and effects of controls.

ObjectivesControls Seek approval

Implement the agreed controls

Review the implemented

controls e.g. by audit, inspection,

monitoring

Outputs

• Agreed control measures

• Agreed objectives and targets

• Improvement programmes

Control elements

• ISO9001, ISO14001 and OHSAS18001 requirements

• Legislation

Responsibilities

• Managing Director

• IMS Manager

• Health & Safety Manager

Interfaces

• All processes

Process metrics

• Accident rate

• Number of environmental issues