The Group has activities that potentially involve a high number of injuries. We are pleased to report that in 2019, there were no lost time incidents relating to Nostrum Group employees, however contractors were responsible for eight LTIs during the year, all of which were in the Republic of Kazakhstan and only involved men. As per our health and safety procedures, all incidents were investigated, their causes identified, and corrective action plans developed. The accident severity rate, the fatality frequency rate, the rate of occupational diseases, the lost day rate, the absenteeism rate, the number of on-job accidents with fatalities that occurred in the listed company were not recorded separately from LTIs and TRIs. In addition, we sought to improve contractor safety management.

An updated contractor management framework is being developed with implementation expected to be in 2020. In 2019, Nostrum developed HSE pre-qualification criteria and HSE requirements for low and high risk activities. In 2019, four contractor audits and nine management system audits were performed, demonstrating an ongoing commitment to improved contractor management. In addition, a Contractor HSE Forum was conducted in October 2019, which allowed the management teams of contractor companies to review and discuss issues.

The main areas for improvement identified for 2020 are:

• Supervisor HSE Competence
• Contractor HSE Performance Management
• Determination and provision of resources needed for the operational HSE control
• HSE Leadership

In September 2019, a ‘Golden Rules’ safety campaign was rolled out within all Company facilities and distributed to all contractors. These Golden Rules state the main safety requirements of the Company and are based on international best practice within the Oil & Gas Industry and a review of Company incident statistics. Examples of the campaign initiatives include:

• A pop-up window appearing daily on login screens with a notification from the QHSE department
• HSE alerts emailed from QHSE Info Mailbox to all employees to communicate lessons learned following 2019 safety incidents
• Toolbox meetings conducted regularly on fieldsite to communicate safety initiatives
• Monthly QHSE reports issued to communicate HSE performance and promote accountability

There are no formal agreements with trade unions regarding health and safety issues.

An awards ceremony was conducted in September 2019 to recognise employees who raised Hazard Observation Cards in 2019. Hazard Identification Cards allow every employee to report unsafe conditions observed in the workplace, or comment upon any safe or unsafe personnel behaviour and to make suggestions on HSE improvement. All employees are encouraged to actively participate in hazard identification activity and fill the Hazard Observation Cards.

In 2019, there were no Tier 1 or Tier 2 process safety events registered at Nostrum’s production facilities. Tier 1 and 2 safety incidents are a loss of primary containment with the greatest consequence as defined by the American Petroleum Institute. It is an unplanned or uncontrolled release of any material, including non-toxic and non-flammable materials from a process that results in one or more of the consequences listed below:

• an employee, contractor or subcontractor incurs days away from work, injury and/or fatality;
• a hospital admission and/or fatality of a third party
• an officially declared community evacuation or community shelter in place including precautionary community evacuation or community shelter-in-place;
• fire or explosion damage greater than or equal to US$100,000 of direct cost.

The selection of the applicable maintenance strategy type versus the equipment criticality is identified based on the impact that equipment failure has on related risk. This will enable maintenance to be prioritised in the event of shortage of resources and will allow reporting against critical systems.

Safety Critical Elements are devices, equipment or systems that are required to ensure process conditions are maintained within safe operating limits, or the purpose of which is to prevent malfunctioning.

In 2019, Nostrum looked to improve incident investigation processes with a greater focus on leadership and collaboration between the HSE department and responsible business areas. Incident levels were revised so that incidents are now placed on a scale of 1-5, depending on severity, and responsibility to lead an investigation into the incident will be based on this number. The most serious incidents will be investigated by the CEO and COO, and those which are less severe will be handled by the field operations director or head of unit.

To increase awareness of QHSE generally, training was held by the British Institute of Occupational Health & Safety for 35 supervisors. A key course module was Incident Investigation which reinforced the importance of proper incident investigation and international QHSE practices.

• To participate in CDP 2020
• Implement a Contractor Safety Management process with a periodical tracking of contractors’ HSE performance;
• Provide a structured and consistent approach considering HSE requirements in the selection process of potential contractors;
• Organise in-house HSE training and examination process in order to improve HSE competence of NOG and contractor personnel performing safety critical activities.

Examples include:

• Lock out/tag out;
• Permit to work process;
• Working on heights;
• Confined space entry.