Brobags Limited Policies

ANTI-CORRUPTION/ FRAUD POLICY

Brobags Limited is highly determined to maintain its reputation as a state-owned Engineering, Procurement, construction and Logistics company operating in the oil and gas industry in Nigeria and will not tolerate fraud, bribery and corruption, abuse of position or office for personal gain in cash or in kind.

All staff are required to support and adhere strictly to the company’s values of honesty and high standards of performance. Management, auditors and accounting staff should play key roles in counter-fraud initiatives, which involves developing a corporate framework within which anti-fraud arrangements will flourish throughout the company’s operations.

Fraud may be said to be false representation, failure to disclose information where there is a legal duty and responsibility to do so, and abuse. Corruption entails offering, giving, soliciting or acceptance of an inducement or reward which may improperly influence the action of any person. While bribery is an inducement or reward offered, promised, or provided to gain personal, commercial, regulatory, or contractual advantage. A person shall be guilty of theft if he dishonestly appropriates property belonging to the company or another with the intention of permanently depriving the company or the other of it.

The anti-corruption strategy of Brobags Limited is to avoid the misuse of company funds both internally and externally. The due process of requesting for funds for any operational activity of the company is designed in such a way that it will be difficult for a single staff or even a group of staff to connive and commit acts of fraud. Requests for funds are made departmentally to line managers with copies relevant supervisory departments such as accounts, administration, and document control. Approval of funds request is done by designate top management staff before they are released by the Accounts and Finance Department.

Any staff of the company found wanting on fraud, theft, bribery, corruption, and other malpractices shall face a disciplinary committee which shall impose the necessary sanctions.

HEALTH SAFETY AND ENVIRONMENTAL POLICY (HSE)

PURPOSE:

This policy defines Brobags Limited's commitment to protecting the health and safety of its employees and others who are affected by the company’s business activities and to reduce the negative environmental impact of operations under its control policies. BROBAGS LIMITED does not compromise the health and safety of its employees and respects the environment. The company’s goal is to sustain an incident-free working environment. Every direct hire and contractual employee is accountable for working in a manner consistent with this goal. To this end, BROBAGSLIMITED will:

Foster a positive Health, safety and Environmental Management System•
Implement an effective Health, Safety and Environmental Management System•
Proactively manage Health, Safety and Environmental Performance

Brobags Limited Health, Safety and Environmental objectives are given equal priority with other business objectives Brobags Limited will comply with all applicable legislation and relevant industry standards consistent with the policy Brobags Limited will strive to be a good cooperating entity. We will work with our clients, contractors and suppliers to improve the efficiency of our operations conserve natural resources and reduce waste and emissions. We will seek sustainable solutions to our own and our client's business needs, balancing environmental, social and economic considerations.

We will make appropriate arrangements to protect the health of our people while at work. Brobags Limited would engage employees, clients, partners, contractors, suppliers and communities in which we work to achieve continual improvements in our health, safety and environmental performance.

Finally, our policy is an obligation that requires the complete cooperation of all personnel to ensure full compliance without reservation. Only in this way can we avoid the horror of accidents and ensure that all our personnel have the opportunity to enjoy safe working conditions

QUALITY CONTROL POLICY

It is the policy of the company to maintain a quality system process designed to meet the requirements of ISO 9001:2008 in pursuit of its primary objectives.

The board of Directors of Brobags Limited recognizes the importance of quality control in an efficient and profitable organization and thereby adheres strictly to its policy, clients and international quality policies which are an integral part of an effective organization that will render its clients with quality products and services.

The Company's aim will always be to provide a high standard of work in accordance with the project drawings and documentation on all projects undertaken.

To this end, Brobags shall operate its own Quality plan and Quality Management system with specific checklists and maintained records of quality checks.

The Quality Management System(QMS) will be operated on all projects regardless of size or complexity and will be subject to regular reviews by senior management in order to ensure its correct operations and effectiveness. These reviews will be based on a program of internal audits which will seek to constantly improve the documented and operational procedures.

The managing director is the Head of QA/QC and is responsible for the implementation of the Quality Management System.

Our Procedures ensure the regular training of personnel, and reporting to the Managing Director, to ensure awareness and understanding of quality and its impact on customer service. The requirement of the company’s quality system is mandatory and all companies have a responsibility and obligation to it.

SUSTAINABILITY POLICY STATEMENT

BROBAGSLIMITED aims to contribute to the quality of life of the environment it works in, and seeks to ensure that development meets the needs of the present without compromising the ability of future generations to meet their own needs. We understand that environmental issues are important, but we also recognize the wider social and economic impacts of sustainability and aim to run our organization deliver our projects and events and work with our supply chain in a way that seeks to minimize our social, environmental and economic sustainability impacts. A ‘green approach can bring direct benefits andBROBAGSis committed to improving its environmental performance by addressing the following objectives:

Energy Conservation
Resource Conservation
Reducing Pollution and the Use of Hazardous Substances
Waste Reduction and Recycling
Supply chain sustainability

We are committed to promoting Equality & Diversity values and will challenge any discrimination. To carry out this commitment, it is our policy to prevent pollution, reduce waste, reduce consumption of natural resources and CO2 emissions and continually improve our sustainability performance to ensure that all aspects of our business have the least detrimental effect on the local and global environment, whilst ensuring we continue to provide the highest quality service to our clients.

Our Sustainability Policy is based on the following principles:

To comply with, and exceed where practicable, all applicable legislation, regulations and codes of practice.
integrate sustainability considerations into all our business decisions.
We will promote an ethical approach to decision-making by ensuring that staff will make decisions in a fair, consistent and unbiased manner and ensure that all staff are fully aware of our Sustainability Policy and are committed to implementing and improving it.
To minimise the impact on the sustainability of all office and transportation activities.
To make clients and suppliers aware of our Sustainability Policy, and encourage them to
To review, annually report, and continually strive to improve our sustainability performance.
We will conduct ourselves with integrity and respect human rights wherever we operate.
We recognize our responsibility in the communities we operate in and will seek opportunities to engage local suppliers as well as the local workforce to increase skills levels
We will strive to publicly report on our progress to demonstrate our commitment to the Environment and the Communities we work in.
We will seek to work together with public and private sector organizations to develop and promote sound practices.
We publicly acknowledge our commitment to fulfil and address our Corporate Social Responsibilities.
To demonstrate our commitment to continuous improvement we aspire to certification of environmental as well as sustainable excellence (e.g. ISO14001).

BROBAGS NIGERIAN CONTENT DEVELOPMENT POLICY STATEMENT

Based on the targets set out by the Federal Government under the Nigerian Content Development Policy, a set of directives was issued to the industry by NNPC letter Ref: GMD. 144 dated 21st March 2005 and based on the feedback from the oil and gas industry and National Supplier Associations, the initial directives and guidelines are revised and allowed by the bill passed on 29th March 2010 Brobags hereby adopted the following policy statement.

All feed and detailed engineering designs for all projects will be done in Nigeria at our head office, Lekki, Lagos State.
Detailed engineering design, Procurement centre and project management team will be domiciled in Nigeria using our head office,atLekki, Lagos State.
All Fabrication work will be fabricated at the Brobags Limited Fabrication workshop.
Continuous training of Brobags staff (Engineers) both within and outside the country as our contribution to capacity building and enhancing our capability.
To employ more staff as the need arises based on the project and most especially our host community as a way of empowering Nigerian youths.
Investing continuously in facility upgrades.
To use all equipment and material manufactured in Nigeria to their fullness in all projects that required them, such as low voltage earthen cables of 450/750V grade, control, Power, lighting cables of 600/1000V grade and a host of others.
Establish the maximum degree of Nigerian content practicable without compromising company objectives concerning operational efficiency and technical integrity
Train Nigerian engineers, such that similar projects in the future might attain increasingly higher levels of Nigerian involvement.
Establish meaningful, long-term and sustainable relationships between Nigerian companies, Nigerian engineers and their counterparts in Europe and other Western countries for the express purpose of skill and technology transfer.
Develop CASHES policy for Brobags with the provision for continuous assessment and improvement so as to ensure safe systems of work, harmonious community relations and zero negative environmental impact.