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ABP Health & Safety Policy

1.0 Statement of intent

1.1 ABP recognises its responsibility to its employees, and will do all that is reasonably practicable to ensure their health, safety and welfare at work.
1.2 ABP will, so far as is reasonably practicable, ensure that the health and safety of other persons is not put at risk by its undertaking.
1.3 The Directors and Managers of ABP give matters of health and safety equal importance to those of economy and productivity. Improvement in health and safety performance year after year is one of ABP’s main business objectives.
1.4 The Directors and Managers of ABP believe that injuries and ill health suffered at work can be prevented through effective management control and action.
1.5 ABP will provide health and safety information, instruction and training to its employees at all levels.
1.6 The Directors and Managers of ABP will monitor the implementation of this policy and the health and safety performance of the Company.
1.7 ABP will provide competent resource in the field of health and safety to provide guidance to Directors and Managers.
1.8 ABP seeks co-operation from all employees in matters of health and safety at work. We are all directly responsible for health and safety at work.
1.9 ABP, through its health and safety programmes, will promote off-the-job health and safety awareness amongst its employees.
1.10 ABP intends to set standards that are amongst the best in the industry. ABP recognises the important and valuable role played by staff safety representatives. Safety committees will be set up at all locations to facilitate consultation on health and safety issues.
1.11 ABP will review the Company’s Health and Safety Policy on a regular basis.
1.12 ABP will manage potential major accident hazards in accordance with legislation and best practice within the industry.

2.0 Safety organisation & resource

2.1 ABP’s safety organisation chart (Appendix I) illustrates the lines of responsibility for safety within the Company. The ultimate responsibility for safety within ABP lies with the Group Chief Executive. At the ABP Board level, the Engineering Director assumes the role of Group Health & Safety Director.
2.2 The Group Safety Manager reports directly to the Group Chief Executive and advises him on strategic safety issues. Along with the Group Safety Manager, ABP has appointed safety professionals as Heads of Safety and Safety Managers, and suitably qualified Safety Officers as required, to advise and assist line management on all aspects of safety management. Heads of Safety report directly to their respective Port Directors/Managing Director, ABP Connect. The Group Safety Manager provides functional leadership and guidance to these appointed safety professionals.
2.3 Port Directors, Port Managers, Managing Directors and General Managers are responsible for health and safety matters within their areas of control, and will ensure that resources are available to implement this policy effectively. Port Directors and Managing Directors shall take responsibility for health and safety matters within their areas, without it affecting the above-line management responsibilities.
2.4 All Directors, Managers and Supervisors have responsibility for health and safety matters relating to persons reporting directly to them.
2.5 Every employee will take care for his or her own health and safety, and for others whom their acts or omissions at work may affect.
2.6 All employees are encouraged to monitor health and safety issues at their workplaces, and report matters of concern to their line managers.

3.0 Safety-performance standards

3.1 It is the responsibility of the Directors and Managers to ensure that effective measures are in place to prevent accidents and other safety-related incidents. Safety targets will be agreed by the ABP Board every year and subsequently publicised. The Directors of ABP expect all locations to have zero reportable accidents, zero lost-time accidents and zero dangerous occurrences as their ultimate goal to achieve and maintain.
3.2 Standards required by law and ABP internal policies and procedures will be complied with at all locations. In addition, all locations are encouraged to put into place initiatives to improve safety standards.
3.3 Risk assessments of ABP activities, work areas, disused areas and buildings will be carried out at all locations in accordance with the ABP Risk Assessment Policy and Toolkit. These will be kept under review to ensure that risk to the health or safety of employees, tenants, customers and visitors are prevented or controlled through appropriate measures. Competent persons will carry out these risk assessments, or a group led by a competent person, and key findings of the assessments recorded and inspected by line managers. Employees or safety representatives, as appropriate, will be consulted when carrying out these risk assessments.
3.4 All new projects (new business, construction,repair, maintenance, purchase of new equipment, etc.) involving significant risks to health or safety shall be the subject of a documented safety review involving the relevant manager, engineer, Safety Manager/Officer and safety representative, as appropriate.
3.5 Safety training of employees will be kept under review by the Directors and the Safety Managers, and carried out in accordance with the ABP Safety Training Policy.
3.6 Various safety policies, procedures, codes and guidance notes have been devised and are issued from time to time to support the safety-management systems and assist in developing safe systems of work. It is the responsibility of all managers and supervisors to ensure that these policies, procedures, codes and guidance notes are
implemented. Any requirement for modification or revision will be notified, via the Head of Safety, to the Group Safety Manager.
3.7 At each business-unit location, there will be a health and safety committee consisting of employees and management representatives, as well as the Head of Safety and Safety Manager/Safety Officer. The manager of the business unit will normally chair the committee. In ports, this will be the Port Director or Port Manager. Guidelines for
the functions of the representatives and the committees are given in the ABP publication ‘Safety Representatives and Safety Committees’. Meetings of the committees will be minuted, and copies of the minutes will be posted on notice boards and circulated to the relevant individuals and departments.
3.8 At each location, adequate measures will be in place to deal with foreseeable emergencies. This includes the provision of first-aiders, first-aid equipment, first-aid rooms, fire-fighting equipment, fire officers or fire marshals and documented emergency plans, as appropriate to the level of risk.
3.9 Emergency plans will be kept up-to-date and reviewed formally on an annual basis. Emergency drills involving the emergency services, county and local emergency planners, as appropriate, shall be conducted at least every five years at all ABP ports.
3.10 ABP guidelines relating to occupational health, detailed in ABP Medical Examinations and Standards/Occupational Health Policy will be implemented at each location.
3.11 At each location, risk assessments will be carried out to ensure there are adequate measures in place to control and monitor exposure to noise, dust or
other harmful agents.
3.12 At each location, due publicity to safety matters shall be given by way of a safety notice board. Current data relating to accidents and incidents at the location, along with other relevant information, shall be clearly displayed on safety notice boards.

3.13 Procedures for the control of contractors (ABP Health and Safety Policy on Managing Contractors) will be consistently applied throughout ABP’s business.
3.14 ABP will ensure plant, equipment, buildings and structures owned by ABP are maintained to safe standards in line with statutory requirements and the ABP Inspection Procedures Policy and comprehensive records exist in respect of these inspections.
3.15 The terms and conditions of stevedoring licences, and any other terms regulating the conduct of third parties, will be consistent and will be applied at all ABP ports.
3.16 All ABP ports will have safety-liaison groups/committees involving all appropriate port users, which will meet on a regular basis to ensure best practice is shared. In addition, there will be regular contact with stevedores and other appropriate port users, during which health and safety issues are discussed. Points of action arising from these discussions will be recorded and followed up.
3.17 All ABP locations will apply a consistent workplace-transport policy (ABP Workplace Transport Policy and Procedure) which will be appropriately monitored and which will include: Only authorised personnel (whether employed by ABP or by third parties) should operate dock-use-only vehicles; Licensing/pass systems or an alternative system of control for dock-use-only vehicles; Appropriate standards relating to road layout including signage, walkways and segregation of pedestrians and vehicles.
3.18 ABP will require that personnel engaged in cargohandling activities in appropriate areas of its port estates hold IOSH- (Institution of Occupational Safety and Health) approved passports, or an equivalent, for working in docks.
3.19 ABP will seek confirmation from employers that non-ABP workers engaged in dock operations in ABP port estates are properly trained to the appropriate standards.
3.20 ABP will require that co-ordinators be appointed, where appropriate, to promote safer operations in common-user areas of its port estates. These co-ordinators may be staff of ABP, or of other dock operators.
3.21 ABP will adopt a consistent approach towards managing falls from height and, in particular: Safe systems of work for container-top working will be rigorously and consistently applied; Risk of falls into locks and off lock gates will be regularly assessed and monitored; Public access to restricted areas or areas where the public may be vulnerable to falls will be assessed, controlled and monitored.

4.0 Reports, audits, reviews and monitoring

4.1 At each location, safety-performance standards will be monitored by way of safety inspections, audits and reviews. In addition, accidents, dangerous occurrences and near-misses will be thoroughly investigated to ensure that effective measures are taken to prevent recurrence.
4.2 A consistent policy on the reporting of fatal, major injury and other reportable accidents and dangerous occurrences shall be applied throughout ABP (ABP Health and Safety Reporting Procedure).
4.3 ABP will monitor the health and safety performance of operators engaged in dock operations by: Recording and following up on any unsafe practices or unsafe equipment observed; Requiring operators to undergo independent health and safety audits and to follow through points for improvement arising out of these audits; Analysing reports and data on cargo-handling accidents/incidents received from the operators and encouraging operators to follow good practice.
4.4 The Group Safety Manager or his appointed representative will audit each business unit. Part-audits of selected areas will be conducted annually and full audits will be conducted at least every three years.
4.5 The Group Safety Manager will prepare monthly, bi-annual and annual safety reports on the whole of ABP for presentation to the ABP Board.
4.6 In addition to the report from the Group Safety Manager, the Port Managers/General Managers, via their Port Directors/Managing Directors (of subsidiary companies), will present annual safetyperformance reports on their respective ports/businesses to the Group Chief Executive. The Managing Directors of ABP Marine Environmental Research Ltd (ABPmer) and ABP Connect shall present such reports directly to the Engineering Director and the Group Chief Executive, respectively.

5.0 Individual responsibilities

5.1 All Employees
5.1.1 To be aware of the responsibilities of ABP under the Health and Safety at Work, Etc. Act 1974, and of personal responsibilities for health and safety (see Appendix II).
5.1.2 To be familiar with, and comply with the Company’s Health and Safety Policy, safety codes and procedures, and safe systems of work issued to them.
5.1.3 To ensure that, where personal protective equipment is specified and issued for a particular activity or area, it is used in the appropriate manner.
5.1.4 To report to their supervisor or manager any accident, dangerous occurrence or near-miss in which they were involved, or are aware of having taken place at their place of work, or any query regarding a health and safety issue or document.
5.1.5 To co-operate with management in the preparation of risk assessments and the preparation and introduction of safe systems of work, the investigation of accidents, in training programmes and the achievement of health and safety targets.
5.1.6 To make full use of health and safety committees by making suggestions for improving health and safety, and by reporting all potential hazards and risks to their supervisor or manager.
5.1.7 To use substances and operate plant and equipment in accordance with the information, training and instruction given.
5.1.8 To contribute to ABP doing everything that is reasonably practicable to safeguard the health and safety of its employees and that of others who may be affected by its activities.

5.2 All Supervisors, Foremen and other similar persons

In addition to the duties in Section 5.1 above:

5.2.1 To assist their manager with investigations into accidents, dangerous occurrences and near-misses, where required.
5.2.2 To ensure that safe systems of work relating to activities under their supervision are properly communicated and implemented.
5.2.3 To assist with the production of risk assessments and safe systems of work, and their communication to staff.
5.2.4 To encourage safe working practices, actively report matters of concern, participate in safety committees and safety campaigns, and make suggestions to
improve safety standards at their location.

5.3 All Managers

In addition to the duties in Section 5.1:

5.3.1 To ensure the implementation of the Company’s Health and Safety Policy, safety codes and procedures in areas under their control, with particular reference to the safety-performance standards detailed in Section 3.
5.3.2 To ensure that appropriate risk assessments are carried out and safe systems of work are drawn up and implemented for areas and activities under their control.
5.3.3 To ensure that the emergency plans for their areas of responsibility are prepared and kept up-to-date.
5.3.4 To seek advice and assistance on health and safety from the Head of Safety/Safety Manager/Safety Officer or from the Group Safety Manager.
5.3.5 To use their best endeavours to achieve the annual health and safety targets, and to improve health and safety performance in areas under their control.
5.3.6 To carry out formal periodic safety inspections of areas under their control on a planned basis and report to the Port Manager/General Manager, as appropriate.
5.3.7 To set measurable health and safety targets for their areas of control.
5.3.8 To promote safe working practices actively by means of campaigns and initiatives to promote a positive attitude to safety.
5.3.9 To ensure that immediate reports are made in accordance with the ABP Health and Safety Reporting Procedures in relation to areas under their control.
5.3.10 To ensure that accidents and dangerous occurrences in their areas of control are properly investigated and resulting actions or lessons learned are properly acted upon.
5.3.11 To ensure that remedial actions arising from safety inspections, audits, walkabouts, or following accidents/incidents, are completed within an agreed timescale in areas under their control.
5.3.12 To ensure that health and safety aspects of the work carried out by contractors on behalf of ABP are properly managed and that the ABP Procedures for
Contractors and Permits to Work are implemented in areas under their control.
5.3.13 To ensure that, where third parties are likely to be affected by ABP’s undertaking, as far as is reasonable, they are informed of any risks to their health or safety. In addition, as far as is reasonable, they are given the appropriate safety procedure, safety codes or safety information in writing.
5.3.14 To ensure that responsibilities under this policy which are allocated to foremen, supervisors and other similar persons under their control (beyond those outlined in Section 5.2), are drawn up, agreed with them and implemented.
5.3.15 To ensure that all capital-approval requests and new business proposals include a thorough health and safety review prior to submission.

5.4 Engineering Managers, Port Engineers, Heads of Engineering

In addition to the duties in Sections 5.1 and 5.3:

5.4.1 To ensure that safety is given proper consideration in the design, construction, repair and maintenance of all facilities and to seek advice, where necessary, from the Head of Safety/Safety Manager/Safety Officer or from the Group Safety Manager.
5.4.2 To ensure that safety reviews of all projects involving significant risks to health or safety are carried out and formally recorded.
5.4.3 To ensure thorough examinations and other periodic inspections of plant, equipment and structures are carried out by competent persons, in accordance with ABP Inspection Procedures.

5.5 Dock and Harbour Masters

In addition to the duties in Sections 5.1 and 5.3:

5.5.1 To ensure that, within their areas of control, all marine movements are in accordance with the Merchant Shipping Regulations, Guidance from the IMO and that the Dangerous Substances/Goods in Harbour Areas Regulations are complied with.
5.5.2 To ensure that the requirements of the Marine Safety Code are implemented for areas under their control.
5.5.3 To seek advice and assistance on marine-related health and safety issues from ABP’s Marine Advisor.

5.6 Property and Estates Managers

In addition to the duties in Sections 5.1 and 5.3:

5.6.1 To ensure that safety reviews of all projects involving significant risks to health and safety are carried out and formally recorded.
5.6.2 To ensure that health and safety is given proper consideration when developing and agreeing tenancy and leasing arrangements.
5.6.3 To ensure that there is clear delineation of health and safety responsibilities in multi-tenancy situations and where tenants’ operations interface with common-user areas and ABP’s operations.
5.6.4 To seek advice, where necessary, from the Head of Safety/Safety Manager/Safety Officer or from the Group Safety Manager to ensure health and safety has been appropriately addressed in relation to property issues.

5.7 Safety Managers, Safety Advisors, Safety Officers

In addition to the duties in Sections 5.1 and 5.3:

5.7.1 To advise line management on all aspects of health and safety at work and to seek advice from the Group Safety Manager.
5.7.2 To investigate dangerous occurrences and accidents at work, and recommend remedial measures to prevent recurrence.
5.7.3 To keep abreast of changes in safety legislation and codes of practice.
5.7.4 To carry out formal periodic safety audits and inspections and safety walkabouts with the managers on a planned basis and submit reports to Port Managers.
5.7.5 To liaise with the Group Safety Manager, enforcing authorities, insurance companies and other trade organisations on matters relating to health and safety at work.
5.7.6 To develop and deliver safety-training programmes to staff at all levels, or to arrange safety training with the help of their Head of Safety or the Group Safety Manager or other organisations.
5.7.7 To provide support and guidance to safety representatives and carry out periodic safety inspections with them.
5.7.8 To attend safety-committee meetings and provide advice and guidance on health and safety.
5.7.9 To work continually towards their own professional development, particularly if employed on a full-time basis.
5.7.10 To assist in the carrying out and reviewing of risk assessments and the development of safe systems of work.
5.7.11 To carry out or arrange the monitoring of exposure of personnel to harmful agents and advise line management on effective control measures.
5.7.12 To assist in carrying out safety reviews of new business and projects that present a significant risk to health and safety as mentioned in Section 3.4, thereby ensuring that good health and safety practices are designed and built into operations and projects.
5.7.13 To provide guidance and assistance to Port Managers and other managers to initiate safety campaigns, to promote safe working practices on and off the job, and to set and achieve annual health and safety-performance targets.
5.7.14 To keep accidents and incidents at their location under review in order to identify any adverse trends and advise line management accordingly.
5.7.15 As far as responsibilities of ABP towards its employees and other persons are concerned, to monitor and advise on the activities of various tenants and customers in respect of health and safety.

5.8 Heads of Safety

In addition to the duties in Sections 5.1 and 5.3:

5.8.1 In addition to carrying out the duties at their respective ports as detailed in Section 5.7, to: Advise their Director on matters of health and safety concerning their areas; Assist and guide the safety personnel in their areas on health and safety training and other relevant matters, where necessary; Co-ordinate safety programmes, such as safety campaigns and safety training, in their areas; Carry out appropriate health and safety monitoring to assist the Port Directors and other managers to fulfil their obligations under this policy.

5.9 Group Safety Manager

In addition to the duties in Sections 5.1 and 5.3:

5.9.1 To advise Directors and line managers on all aspects of health and safety at work.
5.9.2 To present monthly, bi-annual and annual reports to the Group Chief Executive on the safety performance of the Company.
5.9.3 To keep abreast of the changes in legislation and to interpret the legislation for implementation within and by the Company.
5.9.4 To investigate accidents of a serious nature as directed by the Group Chief Executive.
5.9.5 To lead and oversee the performance of the Heads of Safety, Safety Managers/Safety Officers.
5.9.6 To keep the Company’s Health and Safety Policy, safety codes and procedures under review to ensure their relevance and effectiveness.
5.9.7 To ensure that safety audits of all the ports and other operations are carried out at agreed intervals and reports submitted to the managers.
5.9.8 To ensure that effective safety-training programmes are established within ABP.
5.9.9 To represent and co-ordinate the Company’s response in matters with statutory authorities and trade organisations.
5.9.10 To prepare accident statistics for the Company and highlight trends in areas that require specific attention.
5.9.11 To attend safety-committee meetings at the ports on a periodic basis.
5.9.12 To establish and monitor the achievement of annual objectives and targets for improving ABP’s health and safety performance and to ensure that best practice is shared throughout the Company.

5.10 Port Managers, Managing Directors, General Managers, (of subsidiary companies and ABP Connect)

In addition to the duties in Sections 5.1 and 5.3:

5.10.1 To ensure that all accidents, dangerous occurrences and other safety-related incidents are properly investigated and that remedial measures are identified, implemented and monitored.
5.10.2 To present monthly and annual reports to their Port Director on the safety performance of their port or operation.
5.10.3 To ensure that, so far as is reasonably practicable, buildings, structures, equipment and the estates under their control are properly maintained so as not to create a risk to the health or safety of ABP employees or other persons.
5.10.4 To ensure that departmentalfunctional managers and others under their direct control carry out their respective duties within the requirements of this policy.
5.10.5 To chair the safety committee at their port or operation and ensure that it is properly constituted in line with the guidelines as stated in ABP’s ‘Safety Representatives and Safety Committees’ publication.
5.10.6 To ensure that all staff receive safety training on the ABP Safety Training Policy, relevant to their role. Also, to review the safety-training needs of the staff and to take appropriate measures to provide such  training.
5.10.7 To ensure that there are adequate measures in place to provide first aid and to deal with other emergencies.
5.10.8 To ensure that risk assessments of all activities and all parts of ABP’s property (whether in use or not), undertaking and equipment are carried out to satisfy the relevant statutory requirements.
5.10.9 To ensure that a monitoring system is set up to keep them informed of the adequacies or deficiencies of safe systems of work, and compliance with the Company’s policies and procedures on health and safety at work.
5.10.10 To carry out formal safety inspections, on a planned basis, of randomly-selected areas or activities with the Head of Safety/Safety Manager/Safety Officer and/or other managers.
5.10.11 To ensure that safety is a major consideration in all projects involving new business, construction and maintenance, and the purchase of new plant or equipment, and to ensure that formal, documented safety reviews take place at the appropriate time when there are significant health and safety risks.
5.10.12 To ensure that Port/Operation Emergency Plans are reviewed on an annual basis, and that emergency drills are carried out at least every five years.
5.10.13 To ensure that essential safety equipment, as required by the Docks Regulations, is provided and maintained.
5.10.14 To ensure that remedial action arising from safety inspections, audits, walkabouts, or following accidents or incidents are completed within an agreed timescale.

5.11 Port Directors and Managing Director of ABP Connect

In addition to the duties in Sections 5.1 and 5.3:

5.11.1 To ensure the implementation of the Company’s Health and Safety Policy, safety codes and procedures in areas under their control, with particular reference to the safety-performance standards detailed in Section 3.
5.11.2 To seek advice and assistance on health and safety matters concerning their areas from their appointed Head of Safety or from the Group Safety Manager.
5.11.3 To set measurable health and safety targets for managers of business units within their areas of control, and to ensure adequate resources are available to meet these targets.
5.11.4 To ensure that health and safety is always an agenda item at meetings with unit managers.
5.11.5 To present annual reports to the Group Chief Executive on the safety performance of their areas of responsibility.
5.11.6 In ports where there is no Port Manager, the Port Director shall fulfil responsibilities outlined in Section 5.10.

5.12 Group Property Director

In addition to the duties in Sections 5.1 and 5.3:

5.12.1 To establish that the Property/Estate Managers have appropriate guidance to implement the requirements of the ABP Health and Safety Policy in property matters in their areas of control.
5.12.2 To ensure that safety is given proper consideration in property-related projects and that formal safety reviews take place when there is a significant health and safety risk.
5.12.3 Where appropriate, to advise the Group Chief Executive on any property-related solutions to specific safety issues.

5.13 Engineering Director (Group Health & Safety Director)

In addition to the duties in Sections 5.1 and 5.3:

5.13.1 To assume the role of Group Health & Safety Director at ABP Board level.
5.13.2 To oversee the activities of the Group Safety Manager on a day-to-day basis.
5.13.3 To establish that the Engineering Managers have appropriate guidance to implement the requirements of the Health and Safety Policy of the Company in engineering matters under their areas of control.
5.13.4 To ensure the implementation of the Company’s Health and Safety Policy, safety codes and procedures within ABP Marine Environmental Research Ltd (ABPmer).
5.13.5 To ensure that immediate reports are made in accordance with the ABP Health and Safety Reporting Procedures in relation to ABP Marine Environmental Research Ltd (ABPmer).
5.13.6 To present an annual report to the Group Chief Executive on the safety performance of ABP Marine Environmental Research Ltd (ABPmer).
5.13.7 To ensure that safety is given proper consideration in projects of an engineering nature and that formal safety reviews take place when there is a significant health and safety risk.
5.13.8 Where appropriate, to advise the Group Chief Executive on any engineering solutions to specific safety issues.

5.14 Group Health & Safety Director (Engineering Director)

In addition to the duties in Sections 5.1, 5.3 and 5.13:

5.14.1 To ensure that the ABP Board gives matters of health and safety equal importance as it does to those of economy and productivity.
5.14.2 To ensure that the ABP Board provides adequate and competent health and safety personnel resource for the effective implementation of ABP’s Health and Safety Policy, safety codes and procedures.
5.14.3 To ensure that the health and safety implications of Board decisions are properly addressed by the Board.
5.14.4 To ensure that new business acquisitions and ventures are properly audited for health and safety prior to their launch or acquisition, or soon after.
5.14.5 To ensure that all capital-approval requests include a thorough health and safety review of the project, etc., prior to granting an approval.
5.14.6 To ensure that effective monitoring takes place within ABP on the implementation of Health and Safety Policies and Procedures.
5.14.7 To ensure that the ABP Board is kept fully informed of significant issues arising from accidents or incidents, health and safety audits, communications from the Health and Safety Executive, and proposals for the implementation of new EC and UK legislation and regulations.
5.14.8 From time to time, to carry out safety walkabouts or inspections during port visits with the relevant Director or Manager.
5.14.9 From time to time, to attend meetings of the local health and safety committees.

5.15 Group Chief Executive

In addition to the duties in Sections 5.1 and 5.3:

5.15.1 To ensure that ABP has an effective health and safety management structure.
5.15.2 To receive oral and written reports from Port Directors and Managing Directors, or their deputies, on fatal, major injury and other accidents and dangerous occurrences, and report to the ABP Holdings Board, as necessary.
5.15.3 To delegate, where appropriate, investigations of serious accidents and dangerous occurrences (or any other safety-related issues) to the Group Safety Manager.
5.15.4 To satisfy himself that key posts are filled by competent individuals and the requirements of these posts are being met.
5.15.5 To receive monthly, bi-annual and annual reports from the Group Safety Manager on the safety performance of the Company, and annual reports from Port Directors, the Managing Director of ABP Connect and the Engineering Director on the safety performance of their areas of responsibility.
5.15.6 From time to time, to review the safety performance of the Company with the Group Safety Manager and, as appropriate, with the Port Directors, the Managing Director of ABP Connect and the Engineering Director. Disciplinary action (including dismissal, where appropriate) may be taken against any employee found to be in breach of his or her personal responsibility either under safety legislation or under the Company’s Health and Safety Policy.












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