the most important thing we build is trust - …...most important goals is to achieve an injury and...

Safety, Health and Environment (SHE)SHE Management Standards

FEBRUARY 2010 – ISSUE 2

The most important thing we build is trust

Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Safety, Health and Environment Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

SHE Performance Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

SHE Management Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

1 Leadership and Management Commitment . . . . . . . . . . . . . . . . . . . . . . . 4

2 Planning and Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3 Risk Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

4 Communication and Engagement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

5 Regulatory and Corporate Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

6 Monitoring and Assurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

7 Competency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

8 Incident Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

9 Emergency Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

10 Continuous Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

FiguresFigure 1 – Cobham’s SHE Management Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Contents

Safety, Health and Environment Management Standards SHE – Issue 2

Bob MurphyChief Executive OfficerSeptember 2013

As a growing, dynamic, international company we recognise the importance

of developing a business that is sustainable economically and environmentally,

which is why we place great emphasis on Safety, Health and Environment

(SHE). The Cobham Board of executives has very clearly stated that one of our

most important goals is to achieve an injury and incident free business, and to

minimise the impact our business has on the environment.

We will work towards these goals through leadership, fostering a positive

and proactive SHE culture, clearly articulating the standards we aim to

achieve. The SHE Management Standards in this document establish our

expectations and focus on the following areas in particular:-

1 Demonstrating commitment to SHE

2 Ensuring compliance, as a minimum, with the regulatory

requirements where our businesses operate

3 Driving continuous improvement to meet and ultimately

exceed leading SHE practices

For more than 75 years we have been proudly protecting

lives and livelihoods with our products and services. This

is a great base to work from, so I am confident that with

your support we can extend this to everyone affected by

our operations, activities, products and services.

We hope that you will find these Standards useful in

improving SHE management in your business and

we would appreciate your feedback.

Foreword

1


2

Introduction

Safety, Health and Environment Policy

The Company’s SHE policy is to strive to:

• Provide workplaces that are injury-free and

incident-free for all employees, visitors and

contractors.

• Enhance the well-being of its employees

and local communities.

• Where practicable, minimise its impact on

the local and global environment arising

from it operations, activities, products

and services.

To achieve this policy, the Group will

endeavour to provide the following:

• Demonstrated leadership and management

commitment to SHE.

• Appropriate leadership development and

training in SHE.

• Fostering and maintenance of a positive

SHE culture.

• Identification, assessment and elimination/

mitigation of all the risks associated with

SHE hazards in the Group’s operations,

activities, products and services.

• Continuous improvement towards meeting

and exceeding leading SHE practices.

• Elimination, mitigation or remediation

of the environmental impacts of the

Group’s activities.

• Continuous improvement on the efficiency

and use of raw materials, energy and

natural resources.

• Reduction in emissions of direct and

indirect greenhouse gases and assessment

of the need for adaptation of the Group in

relation to the significant adverse effects of

climate change.

• Reduction in the use of hazardous

substances.

• Reduction, reuse or recycling of wastes

wherever possible.

• Development and encouragement of a

just and equitable SHE reporting culture

that does not apportion blame such that

the Group can learn and share from SHE

accidents and high potential incidents.

• Preparation and effective response to SHE

emergencies and crises.

• Empowerment of the Group’s personnel

to take responsibility for SHE with respect

to their own, their colleagues and their

communities wellbeing.

• Active engagement with contractors,

suppliers and business partners, so that they

understand and respect the Company’s SHE

policies and Management Standards.

• Metrics for management at all levels to

continually review, assess and improve

performance.

SHE management globally will be driven

through the implementation of the

standardised SHE Management Approach and

the reader is referred to the SHE Management

Standards and associated guidance.

This document sets out the standardised management approach by

Cobham plc (the “Company”) to the management of safety, health

and environment (SHE) relating to its operations, activities, products

and services and forms part of the Corporate Framework. Words and

expressions defined in the Corporate Framework have the same meaning

when used in this CR&S Framework save that “Group” means corporate

functions, Divisions, SBUs and BUs.

Andy StevensFebruary 2010

3

The Company respects that its businesses have

varying levels of scale, resources, maturity and

risk associated with SHE. As such, the Company

has provided its businesses with three

increasing levels of performance to define their

behaviours and approach in relation to SHE.

SHE Performance Levels

SHE Management Standards

SHE management throughout the Company

will be driven through the implementation of

ten SHE Management Standards that define

the Company’s minimum expectations for

managing SHE (refer to Figure 1).

The SHE Management Standards define how

SHE risks and impacts are to be identified

and managed in accordance with a

continuous management and performance

improvement process.

Detailed information on compliance with the

Standards is provided in the accompanying

SHE Management Standards Guidance

document, Issue 1.

Further information is provided in the Corporate Framework and the Corporate Responsibility & Sustainability (CR&S) Framework.

Figure 1 – Cobham’s SHE Management Standards

LEVEL 1Foundation

LEVEL 2First Target

LEVEL 3World Class

Compliance/Risk Management DrivenThis level sets out the Company’s

foundation performance for a focus area.

Management will be required to meet this

performance level and correct any non-

compliance identified on an urgent priority

basis with regulatory non-compliances

addressed as the highest priority.

Continuous Improvement DrivenThis is the first target level of performance

for each focus area. On achieving the

foundation level of performance, the

Company requires management to

develop a defined action plan to meet

the First Target level of performance. The

action plan will require a defined timetable

that is appropriate to each corporate

function, division, SBU, BU and site.

Opportunity DrivenThis is a performance level that the

Company aspires to for the Group. It

is intended to develop competitive

advantage for the Company and raise

the bar for future performance level

setting. On achieving the First Target

level of performance, the Company

requires management to develop

a defined action plan to meet the

World Class level of performance.

The action plan will require a defined

timetable appropriate to each corporate

function, division, SBU, BU and site.

Leadership & Management Commitment

Continuous Improvement

Monitoring & Assurance

Communication & Engagement

Risk Management

Incident Management

Emergency Management

CompetencyPlanning & Resources

Regulatory & Corporate Compliance


4

1 Leadership and Management Commitment

IntentThe Group’s management will demonstrate

visible SHE leadership and management

commitment. They will address and pursue

SHE performance with the same priority as

other key areas of business performance,

and understand and execute their SHE

accountability.

7 Establish and document personal SHE

objectives and targets for themselves,

against which their performance will be

appraised. This should be cascaded to

staff in accordance with their key roles

and responsibilities.

8 Empower all employees to take

responsibility for SHE with respect to their

own, their colleagues’ and others’ (e.g.

contractors, community etc.) wellbeing.

9 Seek to drive improvements in SHE

performance using appropriate SHE

management techniques, including but

not limited to LEAN principles, processes

and tools.

10 When allocating resources, prioritise

resources for meeting the requirements

of these SHE Management Standards and

sustaining regulatory compliance.

11 Further their SHE leadership skills through

professional development in both technical

and managerial aspects of SHE.

12 Consult with key stakeholders of the

business to understand their SHE concerns

and aspirations, in a culturally sensitive and

appropriate manner.

1Minimum RequirementsAll leaders and managers across the Group will:

1 Embrace and champion Group-wide SHE

policies and communicate them across

the business.

2 Develop a SHE policy that complies

with the requirements of the Company’s

SHE policies.

3 Promote a proactive, just and equitable

SHE culture that rewards success and does

not apportion blame.

4 Treat SHE management as important as

other key areas of business performance.

5 Endorse plans to bring the business

promptly into full compliance with the

Company’s SHE Management Standards

at the performance level adopted from

the CR&S Framework (i.e. Foundation, First

Target or World Class).

6 Commit to continuous improvement by

driving the business towards the next SHE

performance level in the CR&S Framework

or continuing to seek competitive

advantage through SHE opportunities once

World Class has been achieved.

5

2 Planning and Resources

IntentThe Group will manage the impacts of its

operations, activities, products and services

at all levels of the organisation through

establishing effective SHE planning processes

that integrate with its other business planning

processes. SHE will be given equal priority

to all other business planning requirements.

The Group will identify and provide sufficient

human, financial and technical resources

to ensure regulatory compliance, manage

significant SHE risks and impacts, and deliver

on its continuous improvement goals.

drive local performance improvement.

The Company will collect performance

data from across the Group to enable

monitoring of performance and

programmes and to meet the Company’s

legal reporting obligations.

6 Review progress against the SHE plans

at least annually (see also Standard 6:

Monitoring and Assurance).

7 Allocate sufficient human, financial

and other resources (including external

specialist, competent advice) necessary

at all levels to implement the SHE Policy,

meet the requirements of the CR&S

Framework and the SHE Management

Standards to deliver sustained regulatory

compliance and deliver on SHE continuous

improvement plans

8 Ensure planned SHE requirements are

included and visible in budgeting requests.

The Group will consider requests for SHE

capital and operating expenditure with

equal priority to all other business

planning requirements.

2

Minimum RequirementsThe Group will:

1 Appoint a senior manager with overall

accountability for SHE management.

2 Develop and communicate annual SHE

plans, objectives and targets to deliver

identified improvements at all levels, in line

with the intent of the CR&S Framework,

Continuous Improvement standard (i.e.

Standard 10) and aligned to the Company’s

objectives and targets.

3 Define SHE roles, responsibilities and

accountabilities for developing and

delivering SHE plans and all other aspects

of SHE management described in the SHE

Management Standards.

4 Establish a SHE organisation to develop SHE

plans, champion continuous improvement

and promote a proactive, just and equitable

SHE culture.

5 Define leading and lagging SHE metrics

which, as a minimum, incorporate the

Group-wide SHE metrics and supplemented

with any locally applicable metrics to


6

3 Risk Management

IntentCobham will manage the SHE risks of its


at all levels of the organisation, through

systematic risk identification and elimination

(where practicable) or mitigation. Risks will

be identified and tracked and the potential

consequences understood, communicated

and addressed in business planning processes.

5 Develop a means of tracking SHE

control measures through to effective

implementation.

6 Develop a change management process

to identify SHE risks associated with

significant changes and put in place

appropriate controls to eliminate or

mitigate the associated risks.

7 Periodically review identified SHE risks to

ensure understanding and control of risks is

up-to-date.

8 Establish a means of communication to

employees, contractors and visitors on

identified risks and adopted risk controls.

9 Develop and implement contractor

management processes to identify, assess

and manage SHE risks as a minimum on

high risk contracts.

3

4 Communication and Engagement

IntentThe Group will communicate their SHE

expectations, risks and performance in

an effective and timely manner to their

employees, visitors and contractors and

will engage with employees, visitors and

contractors to continuously improve SHE

awareness, commitment and competency.

Cobham will identify and respond to its

key external stakeholder concerns and

needs in relation to the impacts of the

Group’s activities, operations, products and

services on society and the environment.

Communication will be conducted in an

equitable and culturally sensitive manner, to

promote engagement across all geographies

and cultures.

6 Communicate and engage with regulatory

bodies as appropriate to maintain SHE

regulatory compliance.

7 Establish, implement and maintain a

process to identify and periodically

review the business’ key external

stakeholders associated with SHE aspects

of their operations, activities, products

and services.

4


1 Establish and maintain procedures to

systematically identify and document

SHE hazards and impacts associated with

their operations, activities, products

and services.

2 Assess SHE risks arising from the identified

hazards by applying recognised analytical

and evaluation methodologies.

3 Select and implement effective control

measures consistent with the recognised

‘hierarchy of controls’ to prevent, eliminate

or reduce risks and impacts.

4 Identify particularly high risk activities

and develop and implement documented

procedures for managing such activities.


1 Ensure effective channels of

communication exist to:

i appropriately inform all employees, visitors

and contractors of the business’s SHE

policies and objectives, and

ii provide the Company with regular updates

on SHE performance.

2 Ensure senior managers communicate

and engage directly with employees (in

person) on a regular basis regarding SHE

management and performance.

3 Invite employee representatives to

participate in local SHE committees.

4 Regularly engage with employees to

understand their material concerns and

needs with regard to SHE and provide

feedback as to how the business is

addressing these concerns and needs.

5 Engage with contractors to assess their

ability to comply with the business’s SHE

policies and objectives.

7

5 Regulatory and Corporate Compliance

IntentThe Group will, at all times, meet the law as

it applies in each location that it operates in

and abide by the SHE requirements set out in

the Corporate Framework, Code of Business

Conduct, CR&S Framework, SHE Policies and SHE

Management Standards that might be revised,

developed or added to from time to time.

5 Assign accountability for implementing

those actions, and communicate to those

assigned what is needed to comply.

6 Document that the actions needed to

deliver compliance have been completed.

7 Report and investigate non-compliance and

take action to prevent reoccurrence.5


1 Identify all SHE legislation, recognized

voluntary standards (e.g., ISO and ANSI

standards) and codes of practice and

corporate requirements (hereinafter all

referred to as “the requirements”) that are

applicable to their operations, activities,

products and services.

2 Identify changes to the requirements

at a frequency appropriate to maintain

compliance.

3 Create and maintain a register of

applicable requirements.

4 Determine how identified new or amended

requirements apply to the business and

what action is needed to comply.

6 Monitoring and Assurance

IntentThe Group will monitor SHE performance

and undertake routine management reviews

to assess the adequacy and effectiveness of

their SHE policies, systems and performance.

Actions will be taken to address weaknesses

and share good performance across the

organisation. The Group will identify areas for

improvement in SHE performance as required

to progress the business to the next level in

the CR&S Framework.

In accordance with the requirements of the

Corporate Framework, the Company will seek

assurance of the Group’s SHE performance

and management effectiveness through a

combination of self-assessment, independent

internal audit and external audit.

5 Implement processes to control and

routinely audit contractors’ and key

suppliers’ SHE performance at frequencies

appropriate to their SHE risks and

performance, and act upon audit findings

to improve their SHE performance.

6 Establish and maintain an effective system

for tracking close-out of corrective and

preventative actions including for incidents.

7 Perform an annual self-assessment of SHE

performance against the requirements

of the performance level adopted from

the CR&S Framework and the SHE

Management Standards guidance.

8 Participate fully, when requested by the

Company, in an independent assurance

audit involving an independent Cobham or

external resource.

9 Conduct an annual management review

to assess all findings from the monitoring

& assurance programme & determine the

suitability and effectiveness of

SHE management.

6


1 Develop leading and lagging metrics for

management to continually review and

assess the adequacy of SHE management

and performance.

2 Develop a periodic monitoring and

assurance programme that provides

feedback to senior managers, at an

appropriate frequency, regarding their:

i regulatory compliance status;

ii conformance to the Company’s

SHE policies and SHE Management

Standards;

iii effectiveness and implementation of

risk controls; and

iv progress against objectives and targets.

3 Evaluate employees SHE behaviours and

culture and implement change, where

required, to deliver the desired SHE

behaviours and culture.

4 Establish and maintain auditable evidence

of SHE performance to meet the

requirements of the SHE Management

Standards and the Company’s SHE

reporting requirements.


8

7

7 Competency

IntentThe Group will ensure that all employees

(including senior management) are competent

to carry out their work activities and to

manage significant SHE risks and impacts and

provide the platform for achieving continuous

improvement. Employees will be provided with

the necessary experience, skills and training to

achieve the required level of competency for

their work activities.

5 Where necessary, implement a training

programme to deliver the required

competencies in a timely manner.

6 Assess contractors and suppliers (before

being appointed) to ensure they have the

required SHE competencies appropriate to

the scope of work being undertaken.

7 Ensure training and competency records

are documented and stored in a manner

appropriate to ensure accessibility by

relevant personnel whilst protecting

employee confidentiality.

8 Seek independent specialist, competent

advice (either from within or outside of

the Group) where internal resources are

insufficient to manage SHE risks and deliver

SHE plans, objectives and targets.

8

8 Incident Management

IntentCobham’s goal is to provide an injury-free

and incident-free working environment for

all employees, visitors and contractors. The

Group will develop a just and equitable SHE

reporting culture, routinely analyse the causes

of SHE accidents and high potential incidents,

implement corrective actions and track them

to completion. Investigations of high severity

and high potential incidents will include a

thorough understanding of the root cause

and lessons learnt will be shared throughout

the Group.

6 Invite a Divisional or Company manager to

lead incident investigation and reporting

into any accidents that have the potential

for severe injury, if they occur.

7 Maintain records of all SHE accidents and

high potential incidents.

8 Implement a process for the sharing of

lessons learnt from incident investigations

across the Group.


1 Actively manage and promote proactive

SHE behaviours amongst their employees,

particularly those with SHE related roles

and responsibilities.

2 Consider SHE competencies as key

selection criteria during the recruitment

process of new (or return to work)

employees who are primarily engaged in

SHE-related activities.

3 Conduct periodic SHE performance

evaluations for staff with SHE

responsibilities.

4 Identify competency needs necessary to

deliver regulatory compliance, identify and

manage risks, drive continual improvement

and establish a proactive, just and equitable

SHE culture.


1 Develop a just and equitable SHE reporting

culture such that employees report

accidents and near misses without fear

of reprisal.

2 Report SHE accidents and incidents to the

Company in accordance with Company’s

reporting requirements (i.e. quarterly H&S

metrics and annual CR&S returns).

3 Report SHE accidents through the

operational management structure as

appropriate to the severity of the incident.

4 Report all SHE accidents and incidents

to the local regulatory authority in

accordance with applicable regulatory

reporting requirements;

5 Investigate SHE accidents and high

potential incidents to identify underlying

causes and contributory factors towards

identifying and implementing corrective

and preventative actions.

9

9

9 Emergency Management

IntentCobham will ensure appropriate measures

are taken to prevent SHE emergencies. The

Group will prepare for, and provide, effective

resources and responses to SHE emergencies

impacting the Group’s operations, activities,

products and services.

4 Allocate sufficient human, financial and

other resources necessary to implement

the emergency response plan.

5 Ensure that emergency plans are consistent

with, and integrated with, the Group’s crisis

management and business continuity plans.

6 Conduct emergency response drills on a

periodic basis (at least annually) to review

the effectiveness of emergency response

arrangements and update the plan

accordingly.

7 Ensure the emergency response plan is

communicated and made available to

employees, visitors, contractors and other

interested parties (e.g. emergency services

and local communities) where relevant

and appropriate.

10

10 Continuous Improvement

IntentCobham will strive for continuous

improvement in SHE performance in all its


and apply all relevant and appropriate

SHE management techniques (including

application of LEAN techniques, tools and

processes) to optimise SHE performance and

key stakeholder value.

The Group will identify and implement areas

for improvement in SHE performance as

required to:

i ensure sustained compliance with

regulatory requirements; and

ii reduce impacts on people (including but

not limited to employees, visitors and

contractors) and the environment.

3 Assign accountability for achieving

improvements.

4 Periodically review SHE performance,

define improvement goals and visibly

commit, through leadership and providing

the necessary resources, to achieving

those goals.

5 Ensure that SHE is considered in all stages

of design, manufacture, use and disposal

of our products and services with a view to

continuously improving their performance

and impacts (e.g. energy consumption,

raw material and hazardous substance use,

waste generation etc).


1 Develop and document site-specific

emergency response plans at their

operating locations that includes

consideration of all potential SHE

emergency situations and their impact

on the business, the environment and

surrounding communities.

2 Consult with local communities, emergency

services and external regulatory authorities

as appropriate during the development of

an emergency response plan.

3 Define roles and responsibilities for

developing and implementing the

emergency response plan.


1 Identify improvements that will i) deliver

full conformance with their adopted level

of performance in the CR&S Framework

and ii) drive progress to the next level

of performance in the CR&S Framework

in accordance with an action plan and

timeline defined for each business.

2 Through implementing the Planning and

Resources Standard (i.e. Standard 2),

develop plans and measurable objectives

and targets to drive achievement of the

identified improvements.

Designed and produced in England by Generator (Creative Energy) Ltd – Telephone: +44 (0)1425 651951 e-mail: [email protected]

Whilst every effort is made to ensure the accuracy of the information contained in this brochure, no responsibility can be accepted for any errors or omissions.

All photography is copyright and is used with thanks to the respective owners.

For further information:

James Streater Director, Corporate Responsibility & SustainabilityE: james .streater@cobham .com

Cobham plcBrook RoadWimborneBH21 2BJ

This paper contains 50% recycled fibres and is bleached in a totally chlorine free process. The virgin fibre content of this paper is elemental chlorine free and comes from managed forests.

www .cobham .com

Leadership & Management Commitment

Continuous Improvement

Monitoring & Assurance

Communication & Engagement

Risk Management

Incident Management

Emergency Management

CompetencyPlanning & Resources

Regulatory & Corporate Compliance

the most important thing we build is trust - …...most important goals is to achieve an injury and...

Documents