NON CONFORMITIES CORRECTIVE AND PREVENTIVE ACTIONS

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1 Page: 1 of 7 NON CONFORMITIES CORRECTIVE AND ISSUE STATUS Issue Date: Issued for Use Revision Date: - Revision No.: First Issue Action Position Issued By: Reviewed By: Reviewed By: Approved By: QESH Document Controller Company QESH Management Representative HR and Operations Department Director Chief Executive Officer

2 Page: 2 of 7 1. Scope of the Procedure This Procedure describes the recording, monitoring and handling of Material, Product System Non-Conformities as well as non-conformities arising from non-complying services or products related to subcontractors or suppliers activities. The Procedure also refers to the corresponding corrective actions following a Non- Conformity and preventive actions applied to potential nonconformities and areas which would otherwise benefit from improvement. 2. Field of application of the Procedure and responsibilities This Procedure is applied throughout the Branch. Responsible for its application are: The CEO; The COO: Chief Financial Controller; HR and Operations Centre Department Director ; Commercial Director; Business Development Manager; Company Representative for Quality, Environmental, Health and Safety (QESH) Management System; Head of Information Technology; Head of Procurement; Plant and Equipment Manager; Design Office Manager; Tendering Manager; Country Managers; Country Representatives for Quality, Environmental, Health and Safety (QESH) Management System; Senior Project Managers; Administration Department Managers; Financial Controllers; Procurement Department Managers; Quantity Surveying Managers; Computer Department Managers; Insurance Department Manager; Workshops Manager; Project Managers; Construction Managers; Site Engineers; Land surveyors;

3 Page: 3 of 7 The Laboratory Engineers; The Site QESH Representatives; The Site HSE Officers; The Quality Engineers. 3. Description of the Procedure 3.1. Definitions Non-Conformity is the non-fulfilment of a specified requirement, need or expectation that is stated, generally implied or obligatory. In the case of project related work any deviation from contract requirements defined on the contract drawings, specifications, contract programme, etc. must be considered as a Non-Conformity The Non-Conformity Report (NCR) is completed to list, monitor and follow-up Non-Conformities Corrective actions are the actions taken to eliminate the cause of a detected Non-Conformity or other undesirable situation and are recorded in the NCR Preventive actions are the actions taken to eliminate the cause of potential Non-Conformities or other potentially undesirable situations and are recorded in the NCR Handling of a Non-Conformity A flow chart depicting the above mentioned procedure is shown in Appendix A. Anyone of the Branch s employees that detects a Non-Conformity has to report it to the relevant Project Manager or Department Head. All Non-Conformities are recorded in the Non-Conformity Report (NCR) (Form F- P.820/1). In this form the Non-Conformity is described by the person that detected it and his Department Head/Project Manager (the issuer) approves the NCR before this is issued to the person responsible (responsible person) for the work or area where the Non Conformity is detected. This NCR must carry a unique consequential number that is to be recorded by the issuer on form F-P.820/2. The NCR is sent to the responsible person, along with any relevant data (the responsible person may also be a person outside of the Company, such as a supplier or a subcontractor). A copy of the NCR is given to the Country QESH Management Representative at all its stages. NCRs shall be used by the QESH M.R. during preparation of supplier and subcontractor assessments, as feedback for

4 Page: 4 of 7 calculating of key performance Indicators (ref. P.840) which shall be presented during system review (P.830). The responsible person or his delegate records the NCR in form F-P.820/2 and investigates the cause of NCR and defines the corrective preventive actions to be taken as well as the due time and individual responsible for implementation. The responsible person proceeds to all necessary actions, which are recorded in the NCR and after such actions have been completed the results of these actions are also recorded in the NCR and then sent to the issuer. The issuer of the NCR verifies that proper actions have been implemented and confirms their effectiveness prior to closing the NCR. In the case that the results are not satisfactory the NCR is closed and a new one is raised to record follow up date. The Country QESH Management Representative is informed of all Non-Conformities Reports and holds the general responsibility of monitoring the actions to follow, for all NCR s issued by the use of form F-P.820/2. The QESH Country Management Representative issues at monthly intervals the updated copies of completed forms F-P.820/2 for all relevant projects and departments to the Company QESH Management Representative. Similarly, the Department Heads and Project Managers maintain copies of completed NCRs they issue and copies of NCRs they receive and register these on form F-P.820/2. The Department Heads and Project Managers are responsible for following up all NCRs issued or received by them and ensure that prompt corrective and/or preventive actions are implemented. The Department Heads and Project Managers must issue copies of NCRs they issue to the Country QESH Management Representative. The procedure described in 3.2 may be also used for preventive action measures even in the absence of nonconformity in cases where it is necessary to be proactive taking account of other similar problems Preventive actions not directly related to a Non-Conformity Preventive actions are also possible for improvements of the QESH System. In such cases the Procedure P.140 is applied, in particular Form F-P.140/3 Request / Suggestion / Complaint is used Disposition of non-conforming materials Non-conforming materials (that cannot be used as they are) must be adequately isolated and labelled. The labels used are the following:

5 Page: 5 of 7 - Label for Disposal of Non-Conforming Materials used to characterise materials that must not be used and to define the way of disposal (rejection, return to supplier, sale etc). 4. Forms F-P 140 Request / Suggestion / Complaint F-P 820 Non-Conformity Report F-P 820 Follow-up of NCRs 5. Records Non-Conformity Reports are maintained by the Responsible Manager for ten (10) years and they are then scrapped. 6. Revision First issue of Group Wide Procedure.

6 Page: 6 of 7 Appendix A Flowchart Responsible Forms Detection of a Non-Conformity Anyone of the Company s employees Copy issued to QESH Management Representative Issue of a Non-Conformity Report (NCR) and register The Resident Manager; The Senior Project Manager; The CountryQESH Management Representative Department Heads; The Project Managers; The Construction Managers; Engineers; F-P.820/2 Corrective preventive actions to be implemented The Recipient of NCR Actions implemented and recording of results The assigned person Copy issued to QESH Management Representative Issue of a new NCR F-P.820/2 NO YES Is the verification satisfactory?

7 Page: 7 of 7 NCR close out Distribute Closed NCR (QESH Management Representative and Responsible Person)

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