This VPC Supplier Policy sets out Supplier’s obligations in relation to health, safety and wellbeing
(HSW) and is split into four parts:
Part A: general requirements;
Part B: specific requirements for High Risk Activities and Product supply;
Part C: incident reporting;
Part D: consequences of non-compliance

The following words and expressions have the following meanings in this VPC Supplier Policy:
“Applicable Laws” shall have the meaning attributed to it in the relevant Elite Canada
Procurement Agreement;
“Absolute Rules” means rules requiring the observation of the following rules at all
times:
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
1) always wearing seat belts when travelling in or operating vehicles;
2) Always using suitable PPE, a safety harness and fall protection
equipment when working at height.
3) never carrying out electrical work on electrical equipment, circuits
and gear without appropriate qualifications and compliance to
regulations;
4) never working under the influence of substances (alcohol or drugs)
which are illegal or in excess of legal levels or where this impairs
ability to perform tasks;
5) never using a hand held phone whilst driving and only making calls
by pulling over or using hands free devices, when it is safe to do so;
Elite Canada Health, Safety & Wellbeing V3.0
“Flash Incident” means any fatality, major incident or other high potential incident
(where loss or injury could have occurred) which will or could result in
adverse consequences for Elite Canada within 24hours following such
an incident including:
1) multiple fractures or fracture of the skull, spine or pelvis;
2) amputation of hand or foot, fingers or toes;
3) loss of sight or penetrating injury to an eye;
4) chemical/biological exposure requiring medical treatment;
5) any other life threatening injury;
6) major events impacting health/safety e.g. fire, explosion,
structural collapse, collapse of lifting or construction plant;
7) fall from height of above 3 meters; and
8) a significant incident involving a public interface;
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
“High Risk Activities” means any activities involving the following:
1) working in confined spaces;
2) overhead work/ lifting operations;
3) ground/ civil/ construction work;
4) product/ equipment safety;
5) radio frequency;
6) electrical work;
7) working at height;
8) driving (where it is an integral part of the job);
9) field installation activities relating to hardware or
infrastructure;
10) network build, operate and transfer scenarios (or component
activities);
11) manufacturing and distribution processes involving material
health and safety risks;
12) such other scenarios as Elite Canada may identify (acting
reasonably and in agreement with Supplier);
“HSW” means health, safety and wellbeing;
“PPE” means personal protective equipment;
“Red Card” means an incident type that is a major incident resulting in actual loss
(i.e. fatality, disabling injury, property damage or business
interruption);
“Yellow Card” means an incident type that is a high potential incident which could result in a loss
(i.e. injury, property damage or business interruption).
All references to “Supplier” or ”Supplier personnel” shall mean Supplier’s own employees and also
all its sub-contractors and other persons under its influence or control. Supplier shall procure
compliance by such persons.
All references to “Elite Canada” include the relevant contracting entity and all other Elite Canada
Group Companies that benefit from the goods and services being provided.

General
Supplier shall:
1.1. make proper provision for HSW for its employees, visitors, contractors and any subcontractors
working on its behalf;
1.2. comply with Applicable Laws relating to HSW;
1.3. comply with all additional and relevant standards and regulations relating to HSW;
1.4. obtain any necessary permits, licences or insurances needed;
1.5. operate an appropriate internal HSW management system;
1.6. obtain certification to OHSAS 18001 for relevant High Risk Activities from a recognised external
certification body related to the specific country, market, region or project (or alternative
equivalent certification approved for this purpose by Elite Canada in writing);
1.7. provide appropriate evidence of the competence of Supplier and Supplier personnel when
requested by Elite Canada;
1.8. Ensure that Supplier personnel have access to appropriate levels of expert HSW advice;
1.9. appoint a senior sponsor for HSW management, who shall have responsibility for HSW at all
times;
1.10. ensure roles and responsibilities with respect to the delivery of health, safety and wellbeing are
clearly defined throughout Supplier organisation;
1.11. Ensure equipment is designed, manufactured, installed, constructed, tested and certified in
accordance with Applicable Law and industry standards;
1.12. Continually monitor and review HSW performance and compliance with this VPC Supplier
Policy through programmes of inspections, testing and audits;
1.13. Regularly submit HSW performance data to Elite Canada, attend meetings and participate in
audits as reasonably required by Elite Canada;
1.14. ensure that appropriate systems and processes are in place (and adequately resourced) to
identify and address HSW risks associated with the Elite Canada Procurement Agreement;
1.15. have in place mechanisms to ensure that Supplier and Supplier personnel comply with this VPC
Supplier Policy and any Elite Canada local market HSW requirements communicated from time
to time; and
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
1.16. Have in place mechanisms to ensure the management of risks associated with specific hazards
associated with its obligations under the relevant Elite Canada Procurement Agreement.

Sub-contractors
Supplier shall have and maintain robust mechanisms to manage sub-contractors including:
2.1. Systems and processes for assessing HSW capability of sub-contractors;
2.2. Communication of Elite Canada’s HSW requirements and contractual arrangements to flow
down Elite Canada’s requirements to sub-contractors (with appropriate contractual
performance management mechanisms);
2.3. Systems for regular monitoring and review of HSW performance; and
2.4. Prohibitions on further sub-contracting of any High Risk Activities by Supplier’s sub-contractor
without the express permission of Elite Canada, and upon Elite Canada request Supplier shall
report all parties undertaking High Risk Activity for Supplier.

Training and Competence
Supplier shall have and maintain a robust HSW training regime for Supplier personnel to ensure
that Supplier and Supplier personnel are trained to deliver their assigned tasks in a safe manner
including:
3.1. Appropriate training for all tasks (in an appropriate language and delivered via appropriate
means for the target audience);
3.2. Mechanisms to ensure that High Risk Activities are only completed by trained, competent and
qualified Supplier personnel; and
3.3. Maintenance of appropriate training records available for inspection by Elite Canada at any
time.

Performance Reporting and KPIs
Where Supplier is undertaking any High Risk Activities, Supplier shall report on the following
metrics on request from Elite Canada, both generally in relation to their entire operations and
specifically for Elite Canada related activities:
4.1. Number of HSW incidents rate (No of incidents per 100,000 hours worked);
4.2. Number of serious incidents (No of incidents per 100,000 hours worked);
4.3. Number of lost time incidents per 100,000 hours worked;
4.4. Number of product failures and percentage of actions successfully completed;
4.5. Number of site inspections / audits undertaken and percentage of actions successfully
completed;
4.6. Number of breaches of on-site HSW controls detected;
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
4.7. number of statutory interventions; and
4.8. such other metrics as Elite Canada may reasonably require.

HSW Plan for High Risk Activities
5.1. Supplier shall have and maintain an HSW plan for all High Risk Activities before commencement
of work (where carrying out such High Risk Activities), setting out measures to manage the
accompanying risks. Supplier shall manage the risks in accordance with the HSW plan. Supplier
shall provide a copy of the HSW plan to Elite Canada as soon as it is ready.
5.2. The HSW plan must include:
5.2.1. Scope of work;
5.2.2. Key contacts for HSW including qualifications and responsibilities;
5.2.3. Risk assessments, method statements and safe systems of work specifically tailored to
the circumstances;
5.2.4. HSW training matrix for Supplier personnel;
5.2.5. Procedures for emergencies, monitoring, auditing, inspection, certification, incident
reporting, investigation, selection and management of subcontractors, selection use and
control of high risk products, plant/ equipment and substances; 5.2.6. measures to prevent
accidents causing personal injury or death; and
5.2.7. Relevant requirements of Applicable Laws and compliance plans.

Driving and Vehicle Safety
Supplier shall have and maintain appropriate measures to manage the risks associated with driving
and shall ensure:
6.1. Compliance with Applicable Laws and industry standards;
6.2. Selection of appropriate vehicles for the intended use;
6.3. Use of vehicles for intended purpose;
6.4. Pre-use inspection of all vehicles;
6.5. Maintenance of vehicles in line with manufacturer recommendations;
6.6. Maintenance of appropriate servicing and maintenance records;
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
6.7. Fitting of vehicles with appropriate levels of safety equipment, in particular seat belts for all
seats;
6.8. Carrying of passengers does not exceed manufacturer specifications for the vehicle, with no
carriage of excess or unauthorised passengers;
6.9. Prohibition of the carrying of passengers in the back of pick-up trucks;
6.10. Safe carrying of loads and equipment, with loads being secure and not exceeding manufacturer
specifications for the vehicle;
6.11. Fitting of hands-free car kits to all vehicles (where safe and legal to do so) and prohibition of
the use of hand held mobile phones whilst driving;
6.12. Fitting of a speed monitoring device to all vehicles used for “occupational driving” (where a role
requires driving as an integral part of the job);
6.13. towing only by vehicles that are fit for purpose and suitable for the size of trailer or equipment
being towed, with all trailers, towed equipment and mechanisms for securing towed
equipment meeting Applicable Laws and industry standards;
6.14. the putting in place of a schedule of work, geographical areas of responsibility and duration of
time on the road where a job role involves a significant amount of driving, with this being
reviewed regularly;
6.15. Occupational driving is only done by persons with the necessary competencies to perform such
role;
6.16. Drivers are appropriately assessed, licensed, trained, and medically fit to operate vehicles;
6.17. Appropriate levels of training are delivered to all drivers determined by the risk posed by their
role, and such records are maintained for evidence purposes;
6.18. drivers are qualified to drive in the country and region they are driving in and hold the
appropriate grade of licence(s), and to maintain such records for evidence purposes;
6.19. Implementation of a strict programme to monitor and manage the performance and behaviour
of drivers (including but not limited to the use of seats belts by all persons in the vehicle);
6.20. A standard set of driver requirements exist, communicating clear expectations and delivering
proper defensive driving techniques through training;
6.21. control of use of drugs and alcohol in relation to driving;
6.22. Driving at safe speeds taking into account the road conditions; and
6.23. use of industry-approved safety helmets by drivers and passengers of motorcycles, quads and
similar types of vehicle.

Working at Height
7.1. Supplier shall assess, manage and where possible eliminate the risks associated with work at
height, wherever possible, by designing out the need for such activities.
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
7.2. Supplier shall ensure that:
7.2.1. All sites are designed and constructed with suitable fall prevention measures (e.g.
towers are fitted with a Elite Canada approved fall arrests system, guard rails, restraint
points): ladder cages are not considered an appropriate fall prevention method and
must not be installed on vertical ladders;
7.2.2. it sets minimum standards for the competence and fitness for all persons who carry
out work at height on Elite Canada related work and that only those persons who have
been trained in working at height are engaged in that activity;
7.2.3. Those engaged in working at height activities remain attached to the structure at all
times;
7.2.4. Working at height activities are not conducted alone;
7.2.5. Provisions are made to protect the public from falling objects and restrict
unauthorised access;
7.2.6. It establishes arrangements for the issue, use and storage of PPE and access
equipment;
7.2.7. PPE used for working at height is appropriate for fall arrest, and must without
exception be a full body harness;
7.2.8. Procedures are in place for emergencies occurring at height, e.g. tower rescues,
incident reporting procedures; and
7.2.9. all equipment used for access, including ladders, steps, mobile elevated work
platforms (MEWPs) are appropriate and inspected prior to use and are only used by
appropriately trained people.

Electrical Work
8.1. Supplier shall have and maintain a risk management process and safe systems of work for
electrical tasks.
8.2. Supplier shall ensure that:
8.2.1. No live electrical work is undertaken, which has the potential to cause electrical injury;
8.2.2. Persons working on electrical equipment are trained, competent and qualified;
8.2.3. Electrical equipment is fit for intended purpose/environment;
8.2.4. Portable electrical equipment is inspected at regular intervals;
8.2.5. Electrical equipment in wet and/or highly conductive metal areas is low voltage,
shielded or protected by a circuit breaker;
8.2.6. Electrical equipment with potential to cause electrical injury is isolated from all
sources of power and locked off using a formal lock out/tag out system;
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
8.2.7. Excavation works use drawings, cable detection tools, and safe digging practices to
minimise the risk from underground electrical services; and
8.2.8. When working near overhead power lines, controls are implemented (e.g. to de￾energise, for cable insulation) if the risk assessment indicates that contact or flash over
may occur. This includes assessing vehicle and crane access, if appropriate.

Radio Frequency (RF) Safety
9.1.1. Supplier shall fully implement the following provisions, together with any relevant
Elite Canada local market policy or standard.
9.1.2. Supplier shall have and maintain documented procedures for site selection, design,
installation, commissioning, operation, maintenance and decommissioning phases.
These procedures should be in accordance with local (national) regulations as well as
recognised industry standards.
9.2. Supplier documented procedures shall cover the following controls:
9.2.1. Design specifications and systems of work being in operation to manage the risks in
accordance with local legal and recognised industry standards requirements for the
general public and workers;
9.2.2. An Electromagnetic Fields (EMF) risk assessment/design constraints which should be
reviewed in the event of a material change to the Radio Base Station.
9.3. Supplier shall ensure:
9.3.1. Work is carried out by trained, competent and qualified persons, with training of staff
to include an understanding of potential health risks, and risk controls (e.g.
isolation/power down procedures, use of monitoring devices), and dealing with
potential over-exposures;
9.3.2. that anyone who has an implanted or body worn electronic medical device
undergoes a special risk assessment before being permitted to enter into controlled
areas where the RF field level is potentially higher than ICNIRP Guidelines;
9.3.3. in the event of any purported interference events (e.g. products located in or on
hospital premises where life-critical electronic medical devices operate), Supplier shall
ensure that necessary procedures are in place to allow shutdown and/or power
limitation of Radio Base Stations and shall comply with relevant national guidelines
and notify Elite Canada of any such instances;
9.3.4. all relevant Supplier personnel take adequate measures to work safely in the presence
of RF Fields, including utilisation of standard safe work procedures, and compliance
with supervision, instruction & training;
9.3.5. there is clear signage and demarcation considering any Elite Canada personnel,
general public and Supplier personnel and effective access controls for access to
restricted areas;
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
9.3.6. no over exposure for any work on or near antennas and implement specific safe
working procedures addressing potential health risks and having risk controls,
obtaining any necessary approvals needed;
9.3.7. site shut down or power down or other appropriate procedures shall be implemented
to control work within relevant exclusion zones; site landlords shall be provided
sufficient information to ensure that they can fulfill their obligations to preserve
the safety of third parties;
9.3.8. appropriate guidance shall be available to the general public and workers in
accordance with national regulatory or internationally recognised guidelines;
9.3.9. Design specifications and systems of work are in operation to manage the risks in
accordance with local legal requirements and other relevant standards, for any Elite
Canada personnel, general public and Supplier personnel;
9.3.10. Maintenance of appropriate records to demonstrate compliance with the above and
clear accountability for data.
9.4. Supplier shall ensure that there is a method of auditing and verifying that the required
approvals, processes and documentation, set out in this VPC Supplier Policy, are up to date
and that Radio Base Stations and Terminal Equipment are compliant with this VPC Supplier
Policy with the following elements:
9.4.1. a system to report and investigate any suspected non-compliance incidents (e.g.
alleged over-exposure to RF); consider the health of any individual(s) concerned;
and ensure safety management systems are working;
9.4.2. compliance with RF exposure limits and risk management is incorporated for all
equipment provided;
9.4.3. records are kept, subject to any applicable data protection legislation, of: (i) Elite
Canada or Supplier personnel who are potentially exposed to RF field levels above
ICNIRP Guidelines (e.g. anyone who maintain antennas); and (ii) any complaints to
Supplier from individuals alleging they have suffered personal health effects caused
by Radio Base Stations or Terminal Equipment.

Product / Equipment Safety
Supplier shall:
10.1. Ensure potential HSW risks associated with terminals, plant, equipment and substances used or
procured on behalf of Elite Canada are assessed;
10.2. Only purchase products sourced from those manufacturers/ suppliers of goods or services that
demonstrate robust quality assurance processes and ensure the delivery/maintenance of safe
products;
10.3. Only purchase, make and release products that comply with safe standards of design using an
established process for certifying compliance with relevant safety requirements;
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
10.4. have and maintain controls for the safe use, handling, transportation, maintenance and storage
of products;
10.5. ensure all plant and equipment is suitable for its intended use, maintained in line with
manufacturer recommendations, inspected / examined before use and only used by those
trained, competent and qualified to operate it;
10.6. have incident investigation methods that are documented and include processes to deal with
product defects or failures;
10.7. provide any necessary safety procedures;
10.8. Ensure that product safety requirements are documented and include procedures for product
recall;
10.9. Document and retain all documentation pertaining to product safety (such records must be
provided to Elite Canada on request and retained for as long as is necessary);
10.10. Have a process as appropriate for the design, production, verification and approval of user
documentation to ensure that all necessary Health & Safety information, marks and warnings
are current and included;
10.11. ensure that the correct product marks/certifications are obtained and displayed relevant
to the application in which the product is destined. Such marks/certifications must be
displayed as required on the product, packaging and any associated documentation.
Where product certifications/declarations are the responsibility of other parties (e.g.
manufacturers/ suppliers of goods or services) such certification/declarations shall be
obtained by Supplier and form part of the development records;
10.12. Monitor product performance in terms of product safety related failures or reported incidents
until phase out of the product;
10.13. Take action to investigate, report, correct, and prevent in the event of a product related
safety incident occurring;
10.14. Notify Elite Canada in the event of a serious risk requiring a product recall or withdrawal from
the field;
10.15. have a process for product safety related investigations, advisory notices and recall;
10.16. have suitable information and instructions relating to the installation, use, maintenance,
storage and disposal of products are obtained and communicated to end users; and
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
10.17. Provide communication of all necessary instructions to the end user for safe and correct
operation in compliance with Applicable Laws and regulations. Such areas shall include (but not
be limited to);
10.17.1. Aviation or aircraft environment;
10.17.2. Flammable liquids or substances;
10.17.3. Operating with any medical conditions (e.g. Implanted medical devices); and
10.17.4. electro-explosive devices.

Ground / Civil Works
Supplier shall ensure that:
11.1. When conducting ground / civil works it has a mechanism for identifying buried services;
11.2. It assesses ground conditions prior to conducting any excavations, and takes steps to prevent
incidents e.g. collapse, flooding, contamination; and
11.3. It places barriers and warning signs around open excavation to warn and protect those in the
vicinity of the risk.

Overhead work/Lifting operations
Supplier shall ensure that:
12.1. All lifting activities are planned and undertaken using suitable equipment and trained,
competent and qualified persons (for high risk lifts suitable engineering certification must
be obtained); and
12.2. Scaffolding (mobile and fixed) is structurally sound and erected in accordance with safe work
practices and by suitably trained, competent and qualified persons (with high risk
installation being inspected and certified by an appropriately qualified person prior to
use).

Confined Spaces
Supplier shall ensure that:
13.1. It has and maintains a mechanism for identifying confined spaces and assessing and managing
the associated risks;
13.2. Only those persons that have received appropriate training work in confined spaces;
13.3. Where necessary there is the capability and process for testing and monitoring of air
quality;
Elite Canada Trading & Contracting WLL | م.م.ذ والمقاوالت العامة للتجارة كندا أليت P.O.Box 14676, C R:73423, Doha, Qatar, Phone: +974 7799 8819
H.O Elite Canada Trading & Contracting, 9868 33 Ave, Edmonton, AB, Canada Ph. +1 (780)4378800
13.4. Appropriate breathing apparatus and ventilation equipment is used and records kept of such
use; and
13.5. It has and maintains clear emergency and rescue procedures.