QHSE Management System 30.03.2021

Overview of Quality, Health,
Safety and Environmental

(QHSE) Management at TAP
AG
October 2020
Trans Adriatic Pipeline AG

Lindenstrasse 2, 6340 Baar, Switzerland
www.tap-ag.com
Copyright Reserved: This document may not be copied, shown to or placed at the disposal of third parties Page 1 of 24
without prior consent of TAP AG.
Table of Contents
1. Introduction ................................................................................................................................................. 3
1.1 Purpose ................................................................................................................................................. 4
1.2 Abbreviations and Definitions ............................................................................................................... 4
2. Integrated QHSE Management System ...................................................................................................... 6
2.1 Introduction ........................................................................................................................................... 6
2.2 Scope .................................................................................................................................................... 7
2.3 Leadership and commitment ................................................................................................................. 8
2.4 Management System Processes and document structure ................................................................... 8
2.4.1 Process Map .................................................................................................................................. 8
2.4.2 Documentation Structure ............................................................................................................... 9
2.5 QHSE Policies ..................................................................................................................................... 12
2.6 Planning .............................................................................................................................................. 13
2.6.1 Risk Management and opportunities ........................................................................................... 13
2.6.2 QHSE Plans and Programs ......................................................................................................... 14
2.6.3 QHSE Communication and QHSE Culture .................................................................................. 14
2.7 Implementing ....................................................................................................................................... 16
2.7.1 QHSE Compliance and Legal requirements ................................................................................ 17
2.7.2 Competence and Training ............................................................................................................ 17
2.7.3 QHSE Management in contractors .............................................................................................. 17
2.7.4 Management of Change............................................................................................................... 18
2.7.5 Behaviour Based Safety (BBS) .................................................................................................... 18
2.7.6 HSE Incident reporting and investigation ..................................................................................... 19
2.7.7 Lessons Learned .......................................................................................................................... 19
2.7.8 Permit to Work System ................................................................................................................ 19
2.7.9 Environmental, Social and Cultural Heritage Management ......................................................... 20
2.8 Checking ............................................................................................................................................. 20
2.8.1 Monitoring, Measurement, Analysis, Evaluation and Reporting .................................................. 20
2.8.2 Internal QHSE Audits ................................................................................................................... 20
2.9 Improving ............................................................................................................................................ 21
2.9.1 Organisational Knowledge ........................................................................................................... 21
2.9.2 Management of Non Conformances ............................................................................................ 21
2.9.3 Management Review ................................................................................................................... 21
2.10 TAP AG 7 Principles of Quality ......................................................................................................... 22
2.11 Emergency Preparedness and Response ........................................................................................ 22
2.11.1 Alert Management ...................................................................................................................... 22
2.11.2 Notification ................................................................................................................................. 24
2.11.3 Training and Preparedness ........................................................................................................ 24
1. Introduction
The Trans Adriatic Pipeline (TAP AG) is designed to transport natural gas from the Shah Deniz II
development in Azerbaijan to the European market.
The TAP AG pipeline has the following main economic and strategic benefits:
• Diversification of gas transportation routes
• Reducing the risk of over-reliance on a single energy source and improved security and diversity of
energy supply.
• Access to gas produced in the Caspian Region
The TAP AG pipeline route is illustrated in Figure 1 and described below.
Figure 1 – TAP AG Pipeline Route
Starting at the border of Greece and Turkey, where it connects with the Trans Anatolian Pipeline (TANAP),
TAP AG crosses Northern Greece, Albania and the Adriatic Sea to southern Italy, where connects to the
Italian gas transportation grid. The TAP AG project represents the final stage in the development of the
Southern Gas Corridor, traversing 6 countries and 3,500 km.
The initial capacity of TAP AG is 10 billion cubic metres (bcm) of gas per year with a potential overall capacity
of 20 bcm following the installation of necessary additional equipment and infrastructure (e.g. additional
compressor stations).
TAP AG has developed an integrated Quality, Health, Safety, Environmental Management System (hereafter
QHSE MS) and tools to ensure that the organisation complies with the relevant legislation and regulations
in the field of health and safety and the environment.
1.1 Purpose
The purpose of this document is to provide an overview of how QHSE is managed at Trans Adriatic Pipeline
(hereafter TAP AG).
This document covers operations and maintenance and provides an overview of the QHSE-related
management system.
1.2 Abbreviations and Definitions

BOD Board of Directors
CSR Corporate and Social Responsibility
BBS TAP AG Behaviour Based Safety Procedure
BS OSHAS 18001 Occupational Health and Safety Management Systems – Requirements
/ISO 45001
Coms Communication
CMT Crisis Management Team
CTA Common Terms Agreement
EMAS Eco-Management and Audit Scheme
ER Emergency Response
ESCH Environmental, Social and Cultural Heritage
ESMM Environmental and Social Management Manual
ETS Emissions Trading System
FEED Front End Engineering Design
FERA Fire and Explosion Risk Analysis
HAZID Hazard Identification
HAZOP Hazard and Operability Studies
HSE Health Safety Environment
HSELV Health and Safety Leadership Visits
Interested party Person or organisation that can affect, be affected by, or perceive itself to be
affected by a decision or activity
IMT Incident Management Team
IOGP International Association of Oil & Gas Producers
ISO 9001:2015 Quality Management System - Requirements
ISO 14001:2015 Environmental Management Systems – Requirements with Guidance for Use
ITT Invitation to Tender
KPI Key Performance Indicator
LT Leadership Team
MOC Management of Change
MS Management System
NC Non Conformance
Ops Operations
Pims DC Electronic Document Management System Document Control Module
PO Planned Observation
PRT Pipeline Receiving Terminal
PTW Permit to Work
QHSE MS Quality, Health, Safety and Environmental Management System
QRA Quantitative Risk Analysis Onshore Pipeline
TAP AG Trans Adriatic Pipeline AG
2. Integrated QHSE Management System
2.1 Introduction
TAP AG has designed its integrated QHSE Management System (see 2.4.2 documentation structure)
following international QHSE standards. QHSE MS fulfils our shareholders’, stakeholders’ and lenders’
expectations regarding the quality of our services, the safety of all interested parties and environmental
protection.
TAP AG’s QHSE MS is certified against the international standards:
– ISO 9001:2015 for Quality Management System

– OHSAS 18001:2007 for Safety Management System
– ISO 14001:2015 for Environmental Management System
TAP AG will proceed with the upgrade of OHSAS 18001 to the new national ISO 45001:2018 standard,
while it also intends to register with EMAS for the Italian section.
The QHSE MS is based on the Plan-Do-Check-Act model of systematic management, as per the following
figure.
Figure 2_Plan Do Check Act Model at TAP AG
The key objectives of TAP AG’s integrated QHSE MS are to:

• minimise the likelihood of overlapping responsibilities
• avoid duplication of effort and create objectives and plans that do not compete against or contradict
each other
• better allocate available resources
• apply harmonised methods and processes and reduce documentation
• meet applicable ISO standards’ and shareholders’ and stakeholders’ requirements.
2.2 Scope
TAP AG QHSE MS is applicable to the following owned and operated facilities in Greece, Albania and Italy:
– Pipeline right of way (550 km) from the border between Greece and Turkey in Kipoi up to the
border between Greece and Albania, including compressor station at Kipoi and 23 block valve
stations
– Pipeline right of way (215 km) from Qendër, Bilisht in Korçë to 17 km north-west of Fier,
approximately 400 m inland from the shoreline, the compressor station near Fier, the metering
station near Bilisht and 9 block valve stations
– Pipeline right of way (105 km) pipeline traversing the Adriatic Sea to the Italian coast, the micro-
tunnel site near the town of San Foca (Melendugno – Lecce), the pipeline right of way (8.2 km),
Pipeline Receiving Terminal (PRT) and back-up control centre in Brindisi
– TAP AG Headquarters in Switzerland and TAP AG pipeline host countries (offices and facilities)
The QHSE Management System is intended to apply to TAP AG and O&M contractors undertaking work
within TAP AG operational facilities listed above.
2.3 Leadership and commitment

TAP AG Leadership Team (LT) demonstrates QHSE leadership and commitment with respect to employees,
contractors, communities and customers by ensuring that:
– Applicable statutory and regulatory QHSE requirements are determined, understood and consistently
met;
– The risks and opportunities that can affect gas transportation and the ability to enhance customer
satisfaction are determined and addressed.
The TAP AG management through the QHSE Function, ensures that this management system is
established, maintained and continually improved including the processes required and their interactions.
To support the implementation of the QHSE policies and management system, QHSE function includes
among its roles:
– Encouraging strong QHSE leadership in TAP AG
– Promoting robust QHSE management throughout TAP AG by providing the Functions with
management tools in order to ensure they can properly exercise their “line management”
responsibility for QHSE
– Remaining true to the TAP AG value of Responsibility – acting safely and caring for the future
– Fulfilling an assurance function – monitoring QHSE performance and directing improvements in
order to achieve exemplary QHSE performance.
2.4 Management System Processes and document structure

2.4.1 Process Map
TAP AG has developed the QHSE Management Process Map accessible to all TAP AG employees via
intranet, as a tool to:
– show the sequence and interaction of our processes. TAP AG employee through this map can
understand the processes, meaning they understand what we are doing and how we are doing it
– while also providing access to the associated and last updated documents (policies, manuals,
procedures) that define controls over these processes.
are the processes that
are related with decision making
activities
are the processes that are

related with the provision of our
services
Supporting are the processes

that indirectly contribute to the
value added of our final services
Figure 3_TAP AG Process Map
Process owners ensure that their specific process is implemented, monitored and continuously improved.
2.4.2 Documentation Structure

A hierarchical documentation structure applies for documentation at TAP AG as follows:
Figure 4_Documentation Hierarchy
The documentation supports the delivery of our processes including:
– Policies & Strategies: TAP AG Policies provide a framework for deploying our objectives in the subject,
relevant to the policy.
– Manuals: Provide high level controls associated with the subject regarding what has to be done, how it
is to be achieved and who is responsible for each element of the manual.
– Management System Procedures (at two levels): Provide the requirements/parameters/controls in
specific topics in support of the Management System, so deploying our Manual’s principles in detail.
– Work Instructions: Provide detailed instruction on how to carry out work associated with specific work
activities in support of delivering the objectives of process.
– Other assorted document types required by one or more of TAP AG’s processes.
All system and Process related documents are accessed via the intranet and the master documents
managed in Pims DC (TAP AG Enterprise Document Management System).
The following illustration shows how the Master Documentation of the QHSE MS is structured, in order the
above objective to be achieved. Furthermore, the QHSE documentation on TAP AG Process Map has been
designed following the below structure.
Source documents
Legend
Input
Documents to Level 1 Poli ci es Level 2 Manuals
the QHSE
ESIAs National International / Management
TAP Policies EU Legislation Permits
Legislation Lender Standards System Level 3.1 General Level 3.2
Procedures Procedures
Level 5 Method
Project Level 4 Work
Statements,
Documents Instructions
Commitments Plans
Register
Integrated QHSE Management System

QHSE Policies QHSE Policies
• QHSE Policy
• Lone Worker
QHSE Management • Drug & Alcohol
System Manual
• TAP Safe Driving
Country Env ironmental and TAP Operati ons

HSE Social Management Env ironmental
Manuals Manual Standards Manual
Planning Implementing Checking Improving

TAP Context Analysis QHSE Integrated Managem ent Of Key
– Risk, Opportunity QHSE Management
Operational Control Performance
and Actions Report Review Procedure
Procedures Indicators Procedure
QHSE Plans And

Programs Procedure QHSE Safety
TAP Lessons Learned
Operational Control QHSE Auditing
Procedure
Procedures
QHSE -
Communication
Procedure QHSE Environmental Non-conformity
Operational Control Management
QHSE Committee Procedures Procedure
and Network
Meeting
Operational Control QHSE Documentation
Integrated QHSE Health and Safety Environmental
Level 3.1 General Level 3.1 General Level 3.1 General

Procedures Procedures Procedures
• QHSE Training Procedure • Confined Spaces • Grievance Management

• QHSE Management In Procurement • Electrical Works • Identification And Assessment of TAP
Process • Journey Management Environmental Aspects And Impacts
• • Noise Control
• Corporate Management Of Change Lifting Operations
• Permit to Work • Offsets Management
Procedure
• Radiological Works • Operational Control and follow up of
• QHSE Incident Reporting And
Investigation Procedure • Safety and Consultation Zones Environmental Aspects
• Self Supported Cranes • Pollution prevention
• Alert Management •
• Use of Scaffolding Waste Control
• HSE Hazard, Impact and Risk Assessment •
• Working at Height Spills Control And Discharge Management
• QHSE Moments
• Interventions On Safety Valve Procedure
• Safety Data Sheet Control • Works With Risk Of Fire And Explosion • Atmospheric Emissions Management
• Special Operations Control
• TAP Behavior Based Safety
• TAP Traveler Procedure
• Technical Risk Matrix And Tolerance
Criteria
Level 3.2 Specific Level 3.2 Specific

Level 3.2 Integrated QHSE Operational QHSE Operational
QHSE Operational Control Procedures Control Procedures
Control Procedures
• Cultural Heritage Management (Greece)
• Cultural Heritage Management (Albania)
• HSE Legal Compliance • Cultural Heritage Management (Italy)
• QHSE Minimum standards for Contractors • Livelihood Restoration (Greece)
• Management System Documentation • Personal Protective Equipment (PPE) • Livelihood Restoration (Albania)
• Use of Unmanned Vehicles (Drones) •
• Livelihood Restoration (Italy)
• Permit To Work Role Assessment • Office Waste Management (Baar)
• Norm monitoring • Office Waste Management (Greece)
• Office Waste Management (Albania)
• Office Waste Management (Italy)
• Reporting and Calculation of NOx SOx and
CO Emissions
• Emissions Management Under European
Union Emissions Trading System (ETS)
Procedure
• Greenhouse Gas Emissions Monitoring &
Level 5 Level 5 Method Reporting Procedure
Docs Statements
Project Documents
• Emergency Response Plans • Air Quality Monitoring
• HSE Risk Assessments (Job Role and • CEMS Systems Reading And Discharge
Facilities) From Stack
• Scenario Specific Response Guidelines • Ground Water Sampling • Environmental and Social Impact
• Light Monitoring Assessments
• Noise Monitoring • Environmental Monitoring Documents
• Waste Water Sampling
Figure 5_ Presentation of QHSE Management System Documentation
2.5 QHSE Policies
The TAP AG has developed the following policies related to health,
safety and environment issues:
• QHSE Policy
• Drug and Alcohol Policy
• Driving Policy
• Lone Worker Policy
• CSR Policy
QHSE Policy sets out the key commitments of TAP AG Top
Management regarding QHSE matters and provides a framework for
the setting of QHSE objectives. The QHSE Policy is aligned with the
TAP AG’s purpose and our strategic direction. Our QHSE Policy has
been developed with consideration to our Environmental Aspects and
Impacts together with the risks associated with the provision of gas
transportation.
The QHSE Policies are available to interested parties and other via:
− The company internet website (to external interested parties).

− The company intranet site (to internal interested parties).
− Any other suitable means (such as but not limited to Induction and TAP AG HSE app).
TAP AG requires all contractors to conform to the TAP AG policies, which are embedded in all major
contracts.
The leadership team may periodically review and update the existing QHSE policies to reflect the current
TAP AG vision and values; and to ensure compliance with all relevant project standards.
2.6 Planning
2.6.1 Risk Management and opportunities
TAP AG has established a number of risk management procedures providing the methodology to be used
for the various types of risk related to TAP AG. Risks shall be escalated, as appropriate, and considered at
each relevant division of the organisation as shown below.
Figure 6_Hierarchy of Responsibility for Risk Management
Records of risk assessments are maintained in different reports and at different level such as the QRAs,
HAZID, HAZOPS, Facility Risk Assessment, Job Position Risk Assessment, environmental aspects and
impacts, in Country Specific Risk Registers, Business Risk Matrix and the Risk Management Module of Pims.
Identification of the main hazards was important in the early stages of a design, in order to allow design
decisions to be made so as to reduce the risk. Hazards identification and risk assessment involves a series
of steps:
– Identification of Hazard;
– Assessment of the risk;
– Elimination or reduction of the risk (where it is deemed to be necessary).
The following risk analysis was carried out during the FEED (Front End Engineering Design) Phase and
confirm through detailed Design Phase:
– Hazard Identification (HAZID);

– Hazard and Operability Studies (HAZOP);
– Fire and Explosion Risk Analysis (FERA);
– Quantitative Risk Analysis (QRA);
– Semiquantitative risk analysis (SQRA).
– Layers of protection analysis (LOPA);
The results of the risk analysis, together with regulatory requirements, company’s governing documents and
operator safety objectives, form the basis for a safe facility design and layout development as well as the
development of the annual plans and programs, facility response plans and scenario response guidelines.
Priority has been given to the use of preventive measures and inherently safer design principles to reduce
occupational health and safety risks. During design of the infrastructure the barrier principle applies. The
intention with the barrier principle is that if one barrier fails there shall be other barrier(-s) (barriers and/or
systems) that will prevent the event to escalate into a hazard situation.
General business risk is evaluated at a strategic level in the Leadership Team meetings with a full description
included in regular reporting to the Board. These risks cover all disciplines (legal, operation, commercial,
financial, schedule, QHSE, etc) and are further analysed and managed within the departments and
disciplines.
Planning to address risks and opportunities related to the QHSE MS are carried out under the authority of
the QHSE Committee, based on the analysis of business environment (context) and the requirements of
interested parties.
2.6.2 QHSE Plans and Programs
A Corporate triennial QHSE Strategic plan is developed to ensure TAP AG’s QHSE commitments with long
term strategic objectives to enable the Company to respond to its QHSE challenges, risks and opportunities.
This plan provides direction to TAP AG Leadership whilst considering relevant stakeholders, shareholders,
and other external drivers.
Annual Corporate QHSE Plans and Programs set out how the QHSE Strategic Plan shall be delivered and
detail the Key Performance Indicators (KPI) with specific actions, roles and responsibilities and action plans
to meet the strategic QHSE objectives.
A QHSE Committee is established as a monitoring and decision-making body and to ensure industry good
practice and standards are adopted for QHSE. The committee is responsible for the approval of the QHSE
Activity Plan and Programs and is informed and consulted on the development of policies and procedures.
2.6.3 QHSE Communication and QHSE Culture

Annually TAP AG approves under QHSE Committee a Coms and wellbeing Program with different
campaigns covering topical QHSE subjects. This program may also include campaigns to communities/
municipalities to share with them TAP AG good practices and increase QHSE perception among them.
The management system objective is to implement a two-way mechanism for the communication of QHSE
issues, concerns, information, direction, guidance, queries, etc. throughout the TAP AG organisation via the
Line Management of the organisation:
• “Top-down" from the Leadership Team (LT) to Site Teams
• “Bottom-up" from the Site Teams to the Leadership Team (LT)
Coms. Function ensures that external and internal communication is managed including (but may not be
limited to):
– Public relations and external profiling
– Corporate communications strategies and plans that impact TAP AG’s national or international
reputation
– Media Relations
– Branding of TAP AG internally and externally
– Communications coordination across the communications function
– Plans for participation in conferences and seminars
– Website, Intranet and social media
To facilitate communication and consultation within TAP AG and with contractors, TAP AG has established
a QHSE Executive forum of representatives from TAP AG (Leadership team, Ops. Director and TAP AG
QHSE), and main O&M contractors with the goal of sharing industry best practices, establishing consistent
wide QHSE guidelines and identifying where improvements in QHSE management can be made.
Regarding communities, from the beginning of the pipeline construction, TAP AG has engaged with local
communities to provide them with safety best practices such as safe driving, use of PPEs, children on sites,
etc, with the objective to change the mentality on safety and championed a safety culture to all host
countries.
Another example is “Call before you dig”. Non-authorised works performed in Trans Adriatic Pipeline’s
restricted ownership zone or near pipeline facilities may compromise the safety of pipeline operations.
To ensure safety for all at restricted ownership zone, TAP AG has launched the “Call before you dig”
campaign at host countries to request for land and local residents a prompt report before they dig or begin
activities in TAP’s restricted ownership zone, which is defined as a 4-metre area on either side of the pipeline
(4 + 4, 8m in total).
The telephone line is called "General Enquiries and Grievance line". Call staff shall provide all necessary
information and instructions/guidelines to anyone wishing to embark on activities in the proximity of the
pipeline. Call Centre staff shall provide general information available in TAP public domain. All specific
requests shall be recorded and forwarded to relevant departments.
Please visit our website for more information.
Golden rules for safety
To promote effective and proactive HSE culture, in addition to site risk assessments, TAP AG focuses the
attention on the following activities and risks that commonly lead to serious injuries and fatalities, by assigning
each one a standard known as a Golden Rule for Safety.
These rules summarise the minimum standard expected when completing these activities and managing
these risks:
– Permit to Work
– Ground Disturbance
– Confined Space Entry
– Working at Heights
– Energy Isolation
– Lifting Operations
– Driving Safely
– Hot Work
The TAP AG Golden Rules of Safety are applicable to all TAP AG managed (and managed on behalf of TAP
AG) locations and activities.
2.7 Implementing
In the implementation phase, TAP AG has developed a set of QHSE procedures to facilitate the
implementation of different plans and programs for the safe execution of activities and respect of
environment. These procedures are divided into three main categories;
• Integrated: those procedures applicable to Quality, Environment and Health and Safety issues such
as incident reporting and investigation, HSE legal requirements, contractors’ control, change
management, training and Behaviour Based Safety observations.
• H&S operational control: specific procedures related to health and safety that will require their
implementation according to the activity being executed. To remark Permit to Work (PTW), PPE
control, working at height, electrical works, confined space, lifting operations, works with risk of fire
and explosion.
• Environment and social operational control: in this case refers to specific procedures to protect
environment and communities. These include among others, emissions management under ETS,
noise control, waste management, pollution prevention, spills and discharge control, fugitive
emissions, carbon management, grievance, cultural heritage, etc.
In the next sections a detailed description is provided for some of these more relevant procedures.
2.7.1 QHSE Compliance and Legal requirements
TAP AG QHSE Function have identified the HSE legal requirements applicable to TAP AG’s activities and
facilities that includes:
- At European level: directives, decisions and regulations published in the Official Journal of the
European Community, to the extent applicable
- At the national level: applicable laws, decrees, regulations etc.
Regulatory HSE compliance is managed in accordance with TAP AG HSE Legal Compliance Procedure
through the use of electronic compliance database. The electronic database is updated periodically (varying
depending on the country) to ensure it remains reliable and current.
2.7.2 Competence and Training

TAP AG provides general awareness training to all employees and consultants regarding key QHSE issues
as part of the induction training for new starts. A QHSE induction for all staff and certain contractors also
includes QHSE information and this is supplemented with worksite specific QHSE training.
TAP AG has established a portfolio of web-based QHSE training courses, both adapted from existing
materials in the oil and gas industry and as custom-made courses specific to TAP AG’s QHSE standards
and procedures. A number of these courses are mandatory for all employees and completion is linked to the
personnel assessment process. Mandatory training is described on the Annual Training Program.
For the Operations staff, TAP AG developed the Training And Competency Assurance Strategy, as well as
the training plan (matrix) based on the on job role, location, risk exposure and tasks that the staff will have
to perform during the operational phase.
To make sure that the staff is trained and competent to perform the relevant tasks, TAP AG has drafted the
“Operations Training And Competence Assurance Procedure”.
Example of some QHSE training provided to the Operations staff in the different locations is:
• QHSE Procedure training: Operational Controls training, Environmental training, TAP AG Golden
Rules and Management System, Permit to Work, etc.
• HSE skills training: defensive and off-road driving, first aid, fire fighting, gas testing, working at height,
etc.
• Emergency Response: IMT (Incident Management Team), Emergency Response Plan training and
exercises in the different countries, etc.
• Other specific technical training related to safety elements of the asset.
2.7.3 QHSE Management in contractors

QHSE performance in contractors is key for safety execution and environmental control of our activities. For
this reason, QHSE is present from procurement phase including, where required, specific QHSE
requirements in pre-qualification and tender documents for suppling of goods and services.
Suppliers/Contractors wishing to be considered for TAP AG contracts are subject to suitable levels of QHSE
evaluation in order to ensure that they have adequate QHSE management arrangements and performance
to meet TAP AG’s expectations, depending on the work that they are potentially undertaking on behalf of
TAP AG.
This shall be in regard to:
– Pre-qualification for work that may or may not be required at the point when the new
supplier/contractor is engaged.
– Invitation to Tender (ITT) when there is a required and known scope of work that is to be
undertaken.
Once contract is awarded, TAP AG request its contractors to comply with relevant TAP AG’s QHSE
Standards and Guidelines in addition to any applicable Laws and regulations in country.
TAP AG may require contractors to develop an HSE plan/Bridging document that shall address the HSE
risks associated with the work or services to be developed in our TAP AG facilities and define the actions to
be taken to control those risks to an acceptable level. Contractor’s HSE plan shall also contain the list all
Personnel engaged in the performance of the work including training records, competency and Fit to Work
certificates. HSE plan also refers to environmental management from contractors.
The Contractor shall also be requested to ensure that each subcontractor shall provide all QHSE obligations
specified in this point.
Commencement of the work shall be subject to the QHSE’s receipt and approval of all required HSE
documentation. Once approved, contractor shall have a “green light” that shall allow to work in TAP AG
premises.
2.7.4 Management of Change

Management of Change (MOC) is one of TAP AG’s key business processes; integral to the safe and efficient
operation of the company across all countries, facilities and sites. Furthermore, the controlled and rigorous
management of changes, has been proven to be ‘good for business’ and ultimately Company reputation.
Management of Change procedure defines a rigorous, controlled, step-by-step process to identify, assess,
communicate and manage change within TAP AG.
2.7.5 Behaviour Based Safety (BBS)
Research1 evidence suggests that organisations should concentrate 80% or more of their HSE culture
improvement efforts on behavioural factors (i.e. managerial HSE related behaviours) to prevent process
safety and serious incidents.
TAP AG uses BBS forms like HSE Visit, HSE Leadership Visit, Planned Observation, Unsafe act / condition
in order to intervene against unsafe conditions and demonstrate positive HSE behaviours.
• HSE Visits: HSE visits are performed regularly by site management or personnel with specific QHSE
roles (e.g. fire wardens, first aiders) and the guidelines of the TAP AG Behaviour Based Safety (BBS)
Procedure are applied.
• Leadership Visits (LV): Leadership visits are undertaken by management as management’s

behaviour and attitude are critical to the success of the HSELV. HSELV will help improve HSE
standards and the HSE culture of the organisation. HSE leaders don’t influence others through
power, status or authority; they demonstrate positive HSE behaviours that inspire others to do the
same.
• Planned Observation (PO): Planned observation involves observing HSE behaviour at the site /
other location; intervening with an individual(s) when unsafe behaviour is perceived; then having a
conversation with the individual(s) to understand the observation; and when required, having an
1 Dr D Cooper CFIOSH C.Psychol, ‘Navigating the Safety Culture Construct: A Review of the Evidence’
(2016)
agreement with the individual(s) performing the unsafe act, to make a commitment to change their
behaviour.
This shall be a scheduled action conducted in all cases by personnel that are familiarised and trained
on this tool. It is recommended also that people performing the PO shall also have the knowledge
and competence of the task being performed.
This intervention may also be used to congratulate individual(s) on their positive HSE performance.
Integrating PO into daily tasks contributes to creating effective HSE leadership at all levels and
empowers individuals to ‘stop the job’ if they feel its unsafe through Observation and Intervention.
When delivered by non-HSE personnel a PO is much more powerful coming from them and
increasing conversations about HSE creates a positive culture.
• Unsafe Act / Condition Observation: TAP AG personnel shall intervene when they see an unsafe
condition (or unsafe act). This is how TAP AG demonstrates its’ HSE approach that if something
unsafe is observed (i.e. unsafe condition or unsafe act) the observer has an obligation to do
something to make the situation safe i.e. if you see it, you own it – don’t walk by and where this is
not possible, identifying the person responsible and arranging with them to make safe.
2.7.6 HSE Incident reporting and investigation
TAP AG requires that all HSE incidents (including near misses, accidents, spill or releases of material to the
environment, or social incidents such as damage to cultural heritage or third-party property or infrastructure)
are reported and investigated so necessary actions are taken timely and measures are put in place to avoid
future occurrences.
TAP AG follows the International Association of Oil & Gas Producers (IOGP) rules and definitions for HSE
incidents.
Regarding the Lenders, under Common Terms Agreement (CTA) TAP AG is required to notify lenders of
QHSE incidents that fall within lender reporting criteria. TAP AG is also required to develop and implement
a remedial action plan where a QHSE incident results in a non-compliance with environmental and social
requirements outlined within the CTA.
TAP AG has implemented a procedure establishing responsibilities for incident reporting, management and
resolution and the process to be used across TAP AG to investigate incidents.
2.7.7 Lessons Learned

After incident investigation and depending on the category of the indecent a
lesson learned form will be completed and distributed containing the key
learnings from the incident and recommendations to prevent recurrence of
like-in-kind events.
2.7.8 Permit to Work System

The Permit to Work system is key for controlling the work to ensure that it is conducted safely. It is a formal
process used to control the work in TAP AG’s facilities and the means of communication and co-ordination
between the different parties involved in an activity.
TAP AG Permit to Work procedure is applied to regulate the operations and control of activities carried out
at TAP AG’s assets providing direction for personnel involved in the process of preparing, issuing, monitoring
and controlling as well as the responsibilities associated.
Correct use of the Permit to Work Procedure during planning, risk assessment, isolation of energy sources
and work execution will ensure that the risks to personnel, the environment and assets are reduced to as
low as reasonably practicable.
2.7.9 Environmental, Social and Cultural Heritage Management

To ensure management and monitoring of environmental, social and cultural heritage issues, TAP AG has
developed an Environmental and Social Management Manual (ESMM) that provides an overview of the
Environmental, Social and Cultural Heritage (ESCH) standards applicable to TAP AG’s operations, detailing
how operational ESCH risks are managed to conform with applicable TAP AG performance standards, key
roles and responsibilities associated with ESCH management and defines TAP AG internal and external
ESCH reporting requirements.
The ESMM also details the ESCH compliance oversight and assurance framework designed as a
mechanism to verify that the work planned and performed is conducted according to TAP AG’s ESCH
performance standards on issues such as carbon management, waste control, pollution prevention and air
emission monitoring. The framework is based on a range of tools and processes adopted by TAP AG to
manage, monitor, measure and report ESCH performance and avoid and mitigate impacts.
2.8 Checking
2.8.1 Monitoring, Measurement, Analysis, Evaluation and Reporting
The main thrust of monitoring and measuring shall be to determine the level of achievement of TAP AG’s
objectives (KPIs), plans, programs and the effectiveness of the QHSE MS. Information and data associated
with the performance of processes and effectiveness of the QHSE MS are annually analysed and evaluated.
Annual action plan(s) are developed and followed up by process owners as a focus for the setting of KPIs
(based on the above). These KPIs are collated into functional scorecards that are associated with functions
that support the delivery of gas.
Results and actions from the analysis and evaluation will be retained as records as will management review
records.
2.8.2 Internal QHSE Audits

TAP AG’s QHSE Function shall ensure that internal audits of the QHSE MS are carried out at planned
intervals and in compliance with the approved internal QHSE Audit Program. The purpose of these audits is
to provide information regarding whether practices at TAP AG comply with the requirements defined in the
company’s QHSE MS and the requirements of ISO 9001:2015, ISO 14001:2015 and ISO 45000:2018 and
that the system is effectively implemented across the company.
The criteria for audits and scope of audits is defined for each audit. Auditors are selected, and audits
conducted with consideration to objectivity and impartiality.
– Results of audits are reported to both the auditee and managers.

– Where required correction and corrective action shall be taken.
– Records of audits (audit reports and associated actions) shall be retained.
2.9 Improving
2.9.1 Organisational Knowledge
TAP AG shall provide the basis for managing the knowledge necessary for the operation of our processes
and conformity of our service (transportation of gas); management of knowledge may consider (but not be
limited to):
– Lessons learned from Quality, Health, Safety and Environmental events, as per TAP AG Lessons
Learned Procedure.
– Sharing of stored documented knowledge (explicit knowledge) such as management system and
process documents, reports, training material etc.
2.9.2 Management of Non Conformances

TAP AG manages non-conformances when they occur including those that arise from complaints:
– Acting to control and correct the non-conformity.
– Dealing with and containing consequences (such as any other issues of a similar nature, or any potential
for similar events).
Non-conformances are reviewed and evaluated and where required, corrective actions implemented to
eliminate the cause of a nonconformity and to prevent recurrence.
2.9.3 Management Review

The Leadership Team has established the QHSE Committee to periodically review the overall effectiveness
of the QHSE MS across all organisation of TAP AG (Headquarters and Host Countries).
The purpose of the Management Review is three-fold:
– To provide management with a summary of QHSE performance over the year particularly in regard
to:
– Suitability.
– Adequacy.
– Effectiveness.
– Alignment with TAP AG’s strategic direction.
– Identify where improvements can be made, and
– Summarise the significant QHSE risks and their proposed mitigation, in the following period.
The last two points are used to develop the QHSE Activity Plan and the QHSE Departmental targets for the
following year.
2.10 TAP AG 7 Principles of Quality
TAP QHSE management system has been developed in accordance with ISO 9001:2015 requirements. This
standard is based upon the Seven Quality Principles, which TAP has adopted and promotes through
induction:
Figure 7_ 7 Principles of Quality at TAP AG
These principles are in line with the definitions provided in the following ISO quality standards:
• ISO 9000:2015 “Quality management systems Fundamentals and vocabulary”;
• ISO 9004:2018 “Quality management – Quality of an organization – Guidance to achieve sustained
success”.
2.11 Emergency Preparedness and Response

2.11.1 Alert Management
TAP has developed an Alert Management Procedure that describes the Alert Management Process in TAP
providing direction for personnel involved as part of an integrated Operation and Maintenance system, and
includes the following:
– Instructions to be followed to perform Alert Management activities.

– Assignment of responsibilities for Alert Management activities.
Under the concept of Alert TAP considers (a) “Events” as an abnormal situation of the transmission system
but is not classified as an emergency, thus does not require the activation of the site Emergency Response
Plan and (b) “Emergencies” which consist of a sudden, unexpected, or impending situation that causes, or
has the immediate potential to cause, injury, loss of life, damage to assets or the environment, damage to
reputation or interference with the normal business.
According to the level of Emergency (Tier 1, (Site level), Tier 2 (Country level) or Tier 3 (Crisis)) shall require
the activation of the appropriate Crisis and Emergency Response Plan which describes in detail the
notification and reporting lines, roles and responsibilities and specific resources put in place to manage an
emergency.
The following figure illustrates how TAP AG has organised their emergency teams (tiers) along with the main
tasks of each Tier.
Team Purpose Lead Location Main tasks

Provide business level response focusing
onstrategic and business continuity issues
Liaison with Shareholders, other
Crisis Management stakeholders, media, next-of-kin (NOK)
Team Strategic LT member Baar Liaison with Contractor
Tier 3 headquarters/strategic emergency response
centres
Provide internal expertise as part of CMT
(e.g. legal, insurance, procurement)
Provide overall coordination of the response

in-country
Incident Country Liaison with government agencies / local

Management Team Asset where communities
Tactical
Manager incident Liaison with contractor emergency/incident
Tier 2 happens team in-country
Communications link with Level 3 CMT and
Level 1 ERT
Primary response at the emergency scene

Emergency TAP At
Make scene safe and prepare for
Response Team Response incident
Operational
Team location investigation.
Tier 1 Leader / field Call-out and liaise with emergency services
Communication link with the Level 2 IMT
Figure 8_TAP Crisis and Emergency Response Organisation
To succeed throughout all levels of the TAP AG Crisis and Emergency Response organisation, this strategy
is implemented by having;
• defined roles and responsibilities for all Crisis and Emergency Response teams;
• defined interfaces and communications between all teams at TAP AG Headquarters (HQ), Country
Offices (CO), Ops. sites and contractor organisations; and
• regularly trained duty managers and team members.
TAP AG Crisis and Emergency Response Principles
TAP AG’s four Crisis and Emergency Response principles are:
1. Principle of responsibility; what lies within the organisation’s responsibility in normal day-to-day
business is also its responsibility in a crisis. This means that all levels of the organisation shall plan for
pursuance and problem solving in an emergency.
2. Principle of parity; the emergency preparedness organisation should resemble the normal business
organisation as much as possible.
3. Principle of subsidiary; all crises shall be handled at the lowest possible level to achieve a satisfactory
response.
4. Principle of cooperation; the company has a responsibility to ensure the best possible cooperation with
relevant stakeholders.
TAP AG Crisis and Emergency Response Policy
During any crisis or emergency involving TAP AG assets or personnel, our over-riding priorities are to
PROTECT the following (in this order of priority):
1. People
2. Environment
3. Asset
4. Reputation
The ER Strategy is supported by different ER Plans which define detailed requirements, notification and
reporting lines, roles and responsibilities of the various members of the Teams and specific resources put in
place at TAP AG HQ and in the host countries and sites. These plans are routinely tested during exercises
and training initiatives in TAP AG HQ and in the host countries. The aforementioned plans are support with
an Alert Management Procedure.
2.11.2 Notification
TAP AG has local TAP AG Emergency Numbers active in Greece, Italy and Albania and these are publicized
throughout the organization and across the right of way in the marker posts and in our facilities. These
numbers are supported by a 24/7 Dispatching center to ensure this call is always answered.
TAP AG has also a Response Team 24/7 on each country trained to activate the response organisation
through mobilisation of the response team and if needed the country IMTs or the Baar HQ CMT and in all
cases prudent overreaction is requested i.e. if in doubt - inform.
2.11.3 Training and Preparedness

To ensure the preparedness of the TAP AG Crisis and Emergency Response organisation annual training is
scheduled and is intended to be delivered by external Crisis Management training organisations and/or
internally by the QHSE function.
For the exercise, an identified incident risk shall be used to develop a scenario. Two levels of the Crisis and
Emergency Response organization shall participate in the exercise, and the Teams will respond to scripted
injects on a timed basis. The exercise may include external agencies and organisations to add realism to
the exercise.

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Overview of Quality, Health,

Safety and Environmental

Trans Adriatic Pipeline AG

• Diversification of gas transportation routes

• Access to gas produced in the Caspian Region

The TAP AG pipeline route is illustrated in Figure 1 and described below.

Figure 1 – TAP AG Pipeline Route

1.2 Abbreviations and Definitions

TAP AG’s QHSE MS is certified against the international standards:

– ISO 9001:2015 for Quality Management System

The key objectives of TAP AG’s integrated QHSE MS are to:

2.3 Leadership and commitment

2.4 Management System Processes and document structure

are the processes that are

Supporting are the processes

Figure 3_TAP AG Process Map

2.4.2 Documentation Structure

Figure 4_Documentation Hierarchy

The documentation supports the delivery of our processes including:

Integrated QHSE Management System

Country Env ironmental and TAP Operati ons

Planning Implementing Checking Improving

QHSE Plans And

​Operational Control QHSE Documentation

Integrated QHSE Health and Safety Environmental

Level 3.1 General Level 3.1 General Level 3.1 General

• QHSE Training Procedure • Confined Spaces • Grievance Management

Level 3.2 Specific Level 3.2 Specific

Figure 5_ Presentation of QHSE Management System Documentation

− The company internet website (to external interested parties).

Figure 6_Hierarchy of Responsibility for Risk Management

– Hazard Identification (HAZID);

2.6.2 QHSE Plans and Programs

2.6.3 QHSE Communication and QHSE Culture

Please visit our website for more information.

– Confined Space Entry

2.7.2 Competence and Training

2.7.3 QHSE Management in contractors

This shall be in regard to:

2.7.4 Management of Change

2.7.5 Behaviour Based Safety (BBS)

• Leadership Visits (LV): Leadership visits are undertaken by management as management’s

2.7.6 HSE Incident reporting and investigation

2.7.7 Lessons Learned

2.7.8 Permit to Work System

2.7.9 Environmental, Social and Cultural Heritage Management

2.8.2 Internal QHSE Audits

– Results of audits are reported to both the auditee and managers.

2.9.2 Management of Non Conformances

2.9.3 Management Review

Figure 7_ 7 Principles of Quality at TAP AG

2.11 Emergency Preparedness and Response

– Instructions to be followed to perform Alert Management activities.

Team Purpose Lead Location Main tasks

Provide overall coordination of the response

Incident Country Liaison with government agencies / local

Primary response at the emergency scene

Figure 8_TAP Crisis and Emergency Response Organisation

TAP AG’s four Crisis and Emergency Response principles are:

Operational Control QHSE Documentation