Health, Safety and Environment (HSE) Policy

Shandong Boyu Heavy Industry Technology Group Co., Ltd.

1. Preface

Shandong Boyu Heavy Industry Technology Group Co., Ltd., as a professional manufacturer of pressure vessels, heat exchangers, environmental protection equipment, energy equipment, and engineering installation services, adheres firmly to the principles of safe development, green development, and responsible development.
We incorporate comprehensive Health (H), Safety (S), and Environment (E) management requirements into all business activities.

This policy aims to establish a systematic, standardized, and sustainable HSE management framework, ensuring the safety and occupational health of all employees and partners, maximizing environmental protection, and supporting the Company’s long-term, stable development.

2. General Principles

This policy applies to all business activities of the Company, including but not limited to:

• Manufacturing of pressure vessels and heat exchangers (plate rolling, welding, NDT, hydrostatic testing, coating, etc.)

• Equipment delivery, onsite installation, commissioning, and operation support

• Overseas engineering and construction projects

• Outsourced fabrication and supply-chain activities

• Warehousing, logistics, packaging, loading and unloading operations

• After-sales service, maintenance, and technical support

• All employees, contractors, suppliers, and visitors participating in the above activities

3. HSE Philosophy

The Company upholds the following principles:

1) Safety First

Safety is the fundamental bottom line of our operation. No business objective shall be achieved at the expense of safety.

2) Prevention-Oriented

We emphasize risk prevention, hazard control, and continuous improvement by conducting systematic hazard identification and environmental impact assessments.

3) Participation of All Personnel

Every employee is the primary person responsible for their own safety and health. Management bears ultimate accountability.

4) Environmental Protection

We strive for clean production, compliant emissions, and efficient resource utilization.

5) Compliance-Based

We fully comply with national laws, local regulations, industry codes, customer requirements, and international standards (ASME, ISO, NB, API, etc.).

4. Corporate Commitments

(1) Compliance Commitment

We strictly comply with the Work Safety Law, Occupational Disease Prevention Law, Environmental Protection Law, Solid Waste Pollution Prevention Law, and other applicable national and local regulations, as well as industry and client HSE requirements.

(2) Occupational Health Commitment

• Control occupational hazards such as noise, dust, welding fumes, high temperature, and chemicals at the source.

• Organize routine occupational health examinations and maintain employee health records.

• Improve ventilation, dust removal, noise reduction, and filtration systems to reduce exposure levels.

(3) Safety Production Commitment

• Implement strict permits and approvals for hot work, working at heights, lifting operations, confined spaces, electrical work, hydrostatic testing, etc.

• Ensure all special equipment (cranes, forklifts, boilers, pressure vessels, etc.) is legally registered, inspected, and operated by certified personnel.

• Maintain full-process control over key procedures such as welding, NDT, and pressure testing.

(4) Environmental Protection Commitment

• Establish compliance systems for VOCs, dust, wastewater, waste gas, and noise emissions.

• Manage hazardous waste through classification, labeling, storage, transfer, and documentation.

• Develop carbon-reduction plans and continuously improve energy efficiency.

(5) Emergency Management Commitment

• Establish an emergency management organization and define responsibilities.

• Develop emergency response plans for fires, leaks, electric shock, poisoning, mechanical injury, lifting accidents, etc.

• Conduct regular emergency drills to ensure a rapid and coordinated response.

(6) Contractor Management Commitment

• Conduct HSE qualification reviews for contractors before entering the facility (licenses, personnel certificates, equipment compliance).

• Provide HSE training and assessments for all subcontracted personnel; unqualified personnel are prohibited from working.

• Supervise contractor activities and remove violators from site.

5. HSE Management System

The Company has established an HSE management system consisting of the following core modules:

1) Organization and Responsibilities

An HSE Management Committee is established under senior leadership. The Safety & Environmental Protection Department is responsible for system implementation and assigns duties to departments, workshops, and project teams.

2) Hazard Identification and Risk Assessment (HIRA)

Regular hazard identification (HI) and risk assessment (RA) are conducted, with strict controls for high-risk operations (lifting, hot work, confined spaces, etc.).

3) Operational Control

• Standard Operating Procedures (SOPs)

• Lockout/Tagout (LOTO), mechanical guarding, isolation, and emergency shutdown

• Inspection of tools and equipment, forklift management, pressure testing procedures

• Chemical management and Safety Data Sheets (SDS)

• Safety barricades, signage, and color coding systems

4) Training and Competence Development

• Three-level safety training for all personnel

• Certification for special operations

• Safety and emergency training for overseas project personnel

• Training for new equipment and processes

5) Inspections, Audits, and Performance Management

• Weekly safety inspections

• Monthly hazard identification and rectification

• Investigation of accidents and near-miss incidents

• Internal and external HSE audits

6) Emergency Preparedness and Response

• Deployment of emergency equipment (fire extinguishers, eyewash stations, first-aid kits, etc.)

• Special emergency response plans

• Records and evaluations of emergency drills

6. Responsibilities of Employees and Management

(1) Management Responsibilities

• Allocate resources required for HSE management

• Set annual HSE objectives and performance indicators

• Lead the closed-loop management of hazard rectification

• Communicate and implement HSE policies and requirements

(2) Employee Responsibilities

All employees shall:

• Comply with all safety procedures

• Wear PPE correctly

• Identify and report unsafe conditions immediately

• Refrain from unsafe actions or instructions

• Participate in required HSE training

(3) Contractor Responsibilities

• Complete HSE qualification reviews prior to entry

• Assign certified personnel for relevant operations

• Comply with all Company project HSE requirements

7. Environmental Protection Measures

1) Green Production

Adopt energy-saving technologies and equipment to improve resource efficiency.

2) Emission Control

Ensure compliant treatment and discharge of:

• VOC emissions

• Welding fumes

• Noise

• Wastewater

• Solid waste and hazardous waste

3) Hazardous Waste Management

• Classification and packaging

• Recordkeeping and traceability

• Legal transfer to qualified disposal entities

• Strict prohibition of mixing, leakage, or illegal incineration

4) Clean Energy and Carbon Reduction (where applicable)

Implement energy-saving projects such as LED lighting, coating process optimization, and logistics route optimization.

8. HSE Performance Objectives

• Zero major injuries or fatalities

• Zero occupational disease cases

• Zero environmental pollution incidents

• 100% certification for special operation personnel

• 100% compliance with PPE requirements

• 100% closure rate of hazard rectification

• 100% coverage of HSE training

9. Monitoring and Continuous Improvement

The Company ensures continuous improvement through:

• Monthly HSE performance meetings

• KPI assessments and rewards/penalties

• Annual evaluation of suppliers and contractors

• Accident investigation and root cause analysis (RCA)

• Annual management review

10. Execution and Effective Date

This Policy is approved and issued by senior management and becomes effective on the date of publication.
The Company reserves the right to update this Policy as needed to ensure compliance with the latest regulations, industry standards, and business development requirements.

Conclusion

Shandong Boyu Heavy Industry Technology Group Co., Ltd. solemnly commits to implementing the highest standards of Health, Safety, and Environment management—protecting the lives of employees, ensuring the safety of customers and partners, and safeguarding the natural environment—while promoting sustainable, green, and high-quality development.