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Golden Safety Rules

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TABLE OFCONTENTS

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1. Purpose ..............................................................................................................................................12

2. Application .......................................................................................................................................12

3. Procedure ....................................................................................................................................... 13

4. Responsabilities and Authorities ......................................................................................... 18

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1. PURPOSE

The program aims to discipline work safety behavior in order to ensure the

continuous enhancement and excellence in the operational safety, guiding

the Leaders on the adoption of administrative procedures, alignment of the

practices and improvement of the discipline culture to meet the Policies,

Guidelines, Principles, standards and procedures.

In addition to disciplining the safety behavior, this program also aims to improve

the quality of communication, investigation, identification and treatment

of the causes of incidents and deviations involving behavioral issues in

accidents with and without leave, operational incidents and violation of the

12 Golden Safety Rules.

2. APPLICATION

Within this context, Odebrecht Oil & Gas implements a structured, consolidated

and highly disclosed program throughout all projects, agreements and Business

Units of Odebrecht Oil & Gas, referred to as Odebrecht Oil & Gas 12 Golden

Safety Rules. The program will cover all Members and services providers, either

offshore or onshore, who are carrying out activities to Odebrecht Oil & Gas.

For the agreements in which we have Partners/Members, the program shall

be aligned with the Partner/Member, and the best strategy to be followed shall

be defined for its application or for the deployment of a similar program which

comply with the objective for which it was defined.

Odebrecht Oil & Gas is committed to ensure the reliability, keeping issues

confidential and being transparent throughout the whole process.

The proper administrative actions, which aim to discipline the correct behavior

with the rules set out herein are supported by Articles 158 and 482 of CLT

(Consolidation of the Labor’s Law).

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3. PROCEDURE

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1 Use the Permit to Work system and adopt all required safeguard for the performance of either routine or non-routine activities;

Ensure the insulation and block of hazardous sources of power;

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Apply the change management procedure for any temporary or permanent change in the organization;

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4 Adopt all work safety measures for work at high places (above 2.0 m).

Ensure the integrity of the compo-nents and accessories used for moving and handling loads.

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Perform every activity wearing all proper Personal Protective Equipment (PPE) and using the adequate tools.

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10 Investigate 100% of the incidents and near miss;

Comply with all applicable legisla-tion and with the procedures of the management system;

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Do not override critical safety systems, equipment or components.

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PROCESS OF IDENTIFICATION AND INVESTIGATION OF THE VIOLATION OF THE 12 GOLDEN SAFETY RULES

IDENTIFICATION AND INVESTIGATION PROCEDURE

ACCIDENT AND NEAR MISSIn case of occurrence of an accident (with or without leave) or near miss, it

shall be registered at Credit360 system, through the module of Investigation

of Accidents and the investigation procedure shall be started through the

Investigation Commission, and its standard shall be OD-SST-PR-006 –

Communication and Investigation of Incidents.

The conclusion of the accident investigation shall identify whether the violation

of any of the 12 Golden Safety Rules has or has not occurred. If no violation

has occurred, the investigation commission shall prepare the report which

will appoint the immediate and basic causes and will define the action plan to

effectively treat the found deviations, eliminating or reducing ALARP (as low

as reasonable possible) the possibility of events of this nature to happen again.

DEVIATIONS AND NON-COMPLIANCESDeviations and non-compliances shall be registered at Credit360 system,

through Action/Auditing module. As well as in the process for investigation of

incidents, for the deviations and non-compliances reported, the causes which

resulted in them shall also be investigated, as well as if their consequences result

in violation of one of the 12 Golden Safety Rules. As a reference, the following

procedures will be used: OD-SST-PR-005 – Treatment of Non-compliances,

Preventive and Corrective Actions and OD-SST-PR-010 - Auditing.

The process of investigation of deviation and/or non-compliance will be carried

out by the responsible person for the Auditing/Inspection, which shall identify

whether a violation of any of the 12 Golden Safety Rules has or has not occurred.

If there is no violation, the actions for treatment of the deviations and/or non-

compliances shall be carried out via Credit360, in order to eliminate or reduce

ALARP (as low as reasonable possible) the possibility of new occurrences.

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VIOLATION OF THE 12 GOLDEN SAFETY RULES

If a case of violation of any of the 12 Golden Safety Rules is detected, an

Administrative Procedure Commission will be created, which will involve the

Leadership related to the deviation and the Sustainability, Legal and P&O areas.

The Administrative Procedure Commission is called whenever the investigation

of the accident or near miss result from the violation of the 12 Golden Safety

Rules and shows the occurrence of either intentional or non-intentional human

failure action. The Administrative Procedure Commission shall analyze the

results obtained by the Investigation Commission regarding the deviation or

non-compliance and will forward it to the Leader of the Small Business and

to the Leader of the Member or service provider involved that will make the

possible administrative decision, communicating such fact to them.

BEHAVIOR FAILURE

The behavioral deviation or failure is divided into intentional and non-intentional

action.

The non-intentional action is directly associated to any sort of mistake or lapse

which result in imprudence or malpractice by the individual involved in the

activity.

The intentional action is result of negligence or sabotage. When there is a

violation with an intentional action, it is divided into routine, optimizer and

necessary.

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Routine. Routine deviations performed in a routine;. Carried out with approval of the Supervision or by request of the Leadership;. Result from the existence of improper procedures or “difficult to execute”

ones.

Optimizer. Not related to the service (E.g.: finishing the operation quickly to go out

earlier);. Tendency to optimize non-functional objectives as part of a performance

style of some individuals;. “Violating a rule for the pleasure of doing it” (adrenaline).

Necessary. Necessary for the performance of the task (within the deadline, in the

expected amount etc.);. Usually caused by organizational failures related to the site, to the equipment

or to the tools.

The causes may be attributed to an “absent” supervision or which allow the

non-compliance with rules or the conflict of priorities. It may also be associated

to the lack of Leadership by the example procedure (the leader’s practices are

different from what he says).

ADMINISTRATIVE ACTIONS

The Administrative Procedure Commission will assess the investigation report

and will conclude whether the violation of the 12 Golden Safety Rules has been

committed due to an intentional or by a non-intentional action. According to the

assessment of the gravity of the fault, the applicable administrative actions are:

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Warning – this is the lightest penalty, with a mostly teaching effect. It may

be oral or written. It is a notice to the Member so that he will be aware of his

behavior deviations and of the measures that may be taken in case he does

repeats such act. He must be aware that his work agreement may be terminated

by just cause if he does not change his behavior. It shall be applied in case of light

fault within the period of occurrence of such event.

Suspension – aims to discipline and rescue the Member’s good behavior. It shall

be applied after the occurrence of at least two warning notices or right after he

commits a major infraction. The Leader shall assess well the situation and have

a reasoning judgment before giving the employee a suspension, considering the

payment impacts of his decision (salary discount on the days off and effects on

the participation on results). By legal provision (article 474 of CLT), a Member

cannot be suspended for a period superior to 30 consecutive days.

Termination of the work agreement – it may be carried out after three

warning notices, suspension or depending on the infraction. The Member did not

fit the company’s rules and repeated the violations.

PROGRAM COMMUNICATION

The communication of the program is formalized through the conversation

between the Leader and his team regarding guiding and motivating the

Members and service providers on the compliance and performance of the 12

Golden Safety Rules.

In addition to the communication between the Leader and the Lead Employees,

the communication channels available within the company are also used, such

as web portals, integration programs, safety conversations, safety handbooks,

printed materials (adhesives, cardboards etc.) etc.

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4. RESPONSIBILITIES AND AUTHORITIES

MEMBERS AND SERVICE PROVIDERS. Carry out the activities in total compliance with the 12 Golden Safety Rules;. Follow up the performance of other Members, monitoring each other and

spreading the practice of the 12 Golden Safety Rules;. Assess and propose improvements in the application of the 12 Golden

Safety Rules as part of the continuous and dynamic improvement process of

the activities.

LEADERS. Guide and motivate service providers and Members regarding the 12 Golden

Safety Rules, leaders must be examples for their teams;. Following up the performance of his Members, providing them continuous

feedback; . Disclose to their teams the application of the administrative actions at the

work agreement description for cases of intentional violation;. Assess and apply the administrative actions, according to the nature and

gravity of the action committed in alignment with the Sustainability, P&O and

Legal areas.

SUSTAINABILITY, P&O AND LEGAL. Support the formation of the Administrative Procedure Commission team

and the Leaders in the decision making process;. Assess, together with the Leader, the causes of the event and prepare a

report;. Ensure the disciplinary action taken have been weighed, fair and impartial;. Ensure the reliability and non-disclosure condition of the whole process and

its registration.

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