Health and Safety

1. Purpose & Commitment
T30KT Energy Resources Limited (“T30KT”) is committed to conducting all its business operations in Nigeria in a manner that ensures the health, safety, and welfare of its employees, contractors, visitors, the public, and protection of the environment. Our goal is to prevent accidents, injuries, occupational illnesses, and environmental harm through proactive, systematic risk management, continuous improvement, compliance with legal and regulatory requirements, and promotion of a safety culture at all levels of the organization.

2. Scope
This policy applies to all T30KT operations across its areas of business in supply, trading, storage, transport, handling of petroleum and associated products, importing, exporting, logistical operations, and any contractor or third party acting on behalf of T30KT. It covers all personnel: permanent, temporary, contract, and visitors; onshore, offshore, terminals, yards, transport routes, and any operational site.

3. Regulatory Framework & Standards
T30KT will comply with all applicable Nigerian laws, regulations, and industry guidelines, including but not limited to:
Upstream Petroleum Safety Regulations (Nigeria) for occupational health, noise control, fitness for work assessments, emergency response etc. NURPC
Safety Case Guidelines for oil & gas facilities as issued by the Nigerian regulator NUPRC
Other national standards (e.g. environmental laws, oil spill, transport safety), local government requirements, and international best practices as relevant.

4. Key Principles & Responsibilities
Leadership & Accountability
Senior Management shall provide leadership, resources, and visible commitment to health & safety, and ensure HSE is integral to business planning and decision-making.
Line managers/supervisors are responsible for implementing this policy in their areas, ensuring compliance, and maintaining safe working conditions.
Every employee and contractor is responsible for their own safety and for cooperating with safety systems, reporting hazards, incidents, and following safe working procedures.
Risk Management
Identify, assess, and control hazards associated with all operations (e.g. handling of dangerous goods, transport, storage, working at height, electrical systems, noise, chemical exposure etc.).
Use risk assessments, safety audits/inspections, job safety analyses (JSAs), and formal safety reviews (e.g. process safety) to ensure hazards are mitigated.
Maintain the Integrity Operating Window (IOW) for equipment and systems, ensuring they are operated within safe and tested limits. NURPC
Training, Competence & Fitness to Work
Ensure all personnel receive appropriate HSE training before being assigned to duties, including emergency response, first aid, firefighting, handling hazardous materials, transport safety etc.
Conduct periodic refresher training.
Ensure pre-employment medical assessments & periodic health checks (e.g. every 1-2 years) to confirm fitness for work. NURPC
Personal Protective Equipment (PPE)
Provide and maintain appropriate PPE (helmets, goggles, hearing protection, flame resistant clothing, etc.), ensure its proper use, and train personnel in its correct usage.
Ensure specialist PPE for specific tasks (e.g. confined spaces, high risk chemical exposure) is selected and used.
Emergency Preparedness & Response
Develop, maintain, and test emergency response plans (fire, spill, explosion, transport accident etc.).
Put in place alarm systems, emergency shutdown procedures, evacuation routes, and muster points.
Conduct regular drills and reviews to validate preparedness.
Process & Operational Safety
Maintain safe design, installation, inspection and maintenance of equipment, storage facilities, pipelines, loading/offloading systems.
Ensure electrical equipment, flare systems, pumps, valves etc. meet national & international codes, especially those concerning intrinsically safe equipment. NURPC
Ensure proper controls over operations involving hazardous substances, confined space work, working at height.
Monitor noise exposure, conduct audiometric tests for personnel in high-noise areas. NURPC
Incident Reporting & Investigation
All incidents, near misses, unsafe acts or conditions must be reported promptly.
Investigate to determine root causes, implement corrective and preventive actions.
Maintain records & share lessons learned to avoid recurrence.
Monitoring, Audits & Continuous Improvement
Regular audits/inspections of facilities, operations and HSE systems.
Key performance indicators (KPIs) and regular reviews of HSE performance.
Use feedback, data, incident trends to drive improvement.
Contractors, Suppliers & Third Parties
Ensure contractors and suppliers adhere to T30KT’s HSE standards and policies.
Assess contractor HSE competence before engagement; monitor their performance during projects.

5. Health & Occupational Hygiene
Given the nature of oil & gas supply and trading (which may involve handling volatile chemicals, exposure to noise, vapors, dust etc.), T30KT will:
Carry out occupational hygiene surveys to identify chemical, physical, biological hazards.
Maintain exposure monitoring (e.g. for vapors, gases, noise, dust).
Implement control measures (e.g. ventilation, process controls, substitution where possible).
Provide medical surveillance programs for personnel exposed to health-risks.
Ensure proper hygiene, welfare facilities (sanitation, clean water, rest areas).

6. Environment & Oil Spill Management
Even though primary focus is health & safety, the environment is closely tied to safety. T30KT commits to:
Preventing oil spills, leaks and product losses by maintaining integrity of storage, transport, handling.
Preparedness for spill response, with containment, clean-up procedures, training and drills.
Proper waste management and disposal of hazardous substances.
Monitoring and controlling emissions, effluents, noise, etc., in accordance with environmental regulations and standards.

7. Health, Safety Culture & Behaviour
Foster a safety culture in which all employees and contractors are empowered and encouraged to stop work if unsafe.
Promote awareness, open communication, regular safety meetings, toolbox talks.
Lead by example – leadership shall demonstrate safe behaviors.
Reward safe performance; ensure no reprisals for reporting safety concerns.

8. Compliance & Review
Ensure compliance with all relevant Nigerian regulations (Upstream Petroleum Safety Regulations, Safety Case Guidelines, environmental laws, oil spill laws etc.), as well as international best practices as applicable.
This policy shall be reviewed annually or after major incidents or changes in operations, legal requirements, or hazards to ensure relevance and effectiveness.

9. Enforcement & Discipline
Non-compliance with this policy, safe working procedures, or standards will lead to disciplinary action.
Ensure fairness, transparency and consistency in enforcement.

10. Policy Oversight
The Managing Director / CEO of T30KT has overall responsibility for HSE performance.
An appointed HSE Manager / Officer shall coordinate implementation, monitoring, reporting, and continuous improvement.
HSE responsibilities shall be integrated into job descriptions and performance evaluations across all levels.

Conclusion
Safety is not optional; it is essential. By embedding this policy into our business operations, T30KT Energy Resources Limited will protect our people, assets, reputation, and ensure business continuity. Every person has a role to play. Together, we will achieve zero harm.