Rev: 8 Rev.

Date: 01-07-2012

Brookes Pharma (Private) Limited

For Suppliers / Contractors / Sub-Contractors / Interested Parties / Stake Holders

HSE & SA-8000 Communication Folder

List of Contents

S.No. 1. 2. a. b. 3. a. b. c. d. e. f. g. h. i. j. k. l. 4. 5. 6. 7. QHSE & SA Policy

Contents

HSE Requirements for Suppliers/ Contractors / Sub-Contractors What are High risk jobs: These require PTW Risk Assessment for high-risk jobs SA Policies and Procedures
Recruitment & Selection/Hiring Employees Orientation Remuneration Policy Discrimination Working Hours Overtime Weekly and Gazetted Holiday Policy and Procedure for Remediation of Child Labor & Young Worker Forced & Compulsory Labour Health & Safety Disciplinary Practices Access to Verification

Joint Works Council Training Facilities provided to Employees Management Review Results

Rev: 8 Rev. Date: 01-07-2012

Brookes Pharma (Private) Limited

The Q.H.S.E. & S.A. Policy
Brookes has a strong commitment to produce pharmaceutical products of the highest quality while operating in a safe, environment-friendly and socially responsible and accountable manner. To fulfill the above commitment, the organization; Follows the pharmaceutical industry standards of quality by using appropriate systems of production, storage, distribution, quality control and quality assurance. Prevents incidents (injuries, ill-health & accidents) by managing health, safety and environmental risks involved in all the various operations. Promotes environmental awareness among its employees and affiliated parties and adopts efficient techniques to prevent environmental pollution. Complies with the applicable national and international laws, standards and requirements of environment, health, safety and social accountability and safeguards the interest of all the stakeholders by acting in a socially responsible manner. Makes continual efforts to enhance quality, environment, health & safety systems by improving customer satisfaction, preventing errors, team work and human resource development.

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Brookes Pharma (Private) Limited

2 . HSE Requirements for Suppliers/Contractors/Sub-Contractors
The requirement related to product and services that can have any impact on the HSE. This requirement includes but not limited to: Handling/packaging/identification requirements. Requirements of transporting carrier/storage. Information about the product composition/MSDS. Compliance of Brookes procedure for performing the activity. Usage of protective gears. Training requirements. Handling and disposal of waste etc.

Brookes ensures that all Suppliers / Contractors / Sub-Contractors selected for any Material / Service / Contract provision are able to meet HSE requirements. This includes the following, Read, understand and implement Permission to Work (PTW) requirements associated with all high risk jobs listed on PTW. Follow all HSE requirements specified by Brookes. Monitor and ensure all contractor staff follows all HSE requirements including use of PPEs. Report any violation of HSE, accident or incident to contract coordinator immediately.

a.

What are the High Risk Jobs; These require PTW. The High Risk Jobs are but not limited to: a) b) c) d) e) f) g) h) i) Construction Maintenance of pipelines, vessels, boilers, etc. Waste Disposal Handling and transportation of Hazardous Materials such as chemicals, gases, lubricants, fuels, and oil etc. High Voltage electrical work Working in Confined Spaces Laying, replacement and maintenance of pipelines or air-conditioning ducts. Working at height Working in areas/equipment whose environments require microbiological or sanitation control.

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Brookes Pharma (Private) Limited

The Requisitioner department identifies HSE requirements in the bidding/ tender documents along with the following details (as applicable), that contractor have to perform. b. Working Procedures HSE Risk assessment of the job. Requirements of transporting carrier, machinery/equipment and tools. Handling/Packaging/Identification requirements. Information about the product composition/MSDS. Compliance of HSE procedure for performing the activity. Usage of protective gears PPEs. Competence/training requirements of workers. Handling and Disposal of Waste etc. The need to take PTW, where required. Emergency procedures. Accident/incident reporting Legal requirements

For any of the high-risk jobs, Brookes may ask the supplier/contractor to carry out a risk assessment before awarding a contract. At a minimum risk assessment must include: Potential exposure to worksite hazards and their risks Nature of work-materials to be utilized Potential consequences of incidents Operation control to mitigate the risk

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Brookes Pharma (Private) Limited

SA- 8000 Policies and Procedures
1. Purpose
The purpose of this Manual is to describe the SA-8000 policies applicable to Brookes Pharma (Private) Limited and to communicate the same to stakeholders for the better execution of the organizational processes.

2. Scope
This Manual covers all applicable requirements related to Social Accountability Management System of Brookes Pharma (Private) Limited.

3. Policies
3.1 Recruitment & Selection / Hiring
Brookes welcomes the talent of people from diverse backgrounds to provide the expertise, dedication, and imagination to propel toward a prosperous future. It looks for individuals with daring spirits and inquisitive minds who seek a broad range of opportunities for personal and professional growth, and whose efforts are realized in the improved health of people. Brookes is an exciting organization, which offers a variety of career opportunities. Its recruitment process aims to achieve the highest level of candidates care by listening to their interests and treating them like a valued customer. Brookes is committed to recruit and select the best human capital through internal or external hiring. Its hiring needs depend upon the business plan and specific request of line managers. The specific request is received through a specified format naming Human Resources Requisition Form which is filled in by the sectional/departmental head and then forwarded to H.R Department for searching out the best candidate. The H.R Department analyzes the job need and if found genuine then forward it to Vice President for approval that leads to the initiation of proper recruitment process. If the vacancy is assessed to be filled in by the internal candidate then company searches out the candidate by looking into the talent inventories followed by further proceedings. However, for the external hiring company follows the method of (i) advertisement in news papers (ii) using online recruitment partner (iii) search out the candidate through H.R. Data Bank (iv) through labor contractor (v) and sometimes get the services of Head Hunters.

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Brookes Pharma (Private) Limited

After creating a pool of desired candidates through one of the above cited methods, the candidates are shortlisted in view of the job specification followed by interviews and other selection process.

3.2 Employees Orientation

All the newcomers are oriented right after their joining with the company and its rules, regulations, policies, people and organization structure etc.

3.3 Remuneration
Every employee is paid a monthly gross salary as per his/her pay scale which is not less than the prevailing minimum wages along-with some additional payment on account of conveyance allowance for those who are either not provided with the company transport facility or those who are eligible but have willingly opted for conveyance allowance rather than company transport. Brookes is strictly adhered to not deduct any employees salary for disciplinary purpose. Brookes does not focus on hiring labor only through contractor to avoid fulfillment of obligations rather it gives precedence direct employment over through contractor. Brookes ensures that workers working under the contracting agreement are receiving the same minimum salary as the people directly employed by company. Brookes also ensures that the employees irrespective of their employment category are enrolled in Social Security, Life Insurance, E.O.B.I. etc.

3.4 Discrimination
Brookes is committed to avoid discrimination in remuneration, recruitment & selection, training & development, promotion, termination or retirement based on race, cast, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation or age. Brookes does not interfere with the exercise of personnels rights to observe tenets or practices, or to meet needs relating to race, national or social origin, religion, disability, gender, sexual orientation, family responsibilities, union membership, political opinions, or any other condition that could give rise to discrimination. Brookes does not allow any behavior that is threatening, abusive, exploitative, or sexually coercive, including gestures, language, and physical contact, in the workplace and, where applicable. Brookes does not subject personnel to pregnancy or virginity tests under any circumstances.

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Brookes Pharma (Private) Limited

3.5 Working Hours
No employee works more than 48 working hours per week as per the following distribution.

Normal Timings:
Monday Through Thursday Friday Saturday & Sunday 8:00 to 5:30 p.m. 8:00 to 6:00 p.m. Off-Days

Shift:
Monday Through Saturday 7:00 a.m. to 3:00 p.m. 3:00 p.m. to 11:00 p.m. 11:00 p.m. to 7:00 a.m. 7:00 a.m. to 4:30 p.m.

Monday Through Friday

3.6 Overtime
No employee is allowed to stay for overtime for more than 12 hours per week and 48 hours per month.

3.7 Weekly and Gazetted Holidays:

Employees are at least entitled to have one off-day in a week but generally two off-days in a week (Saturday & Sunday) are given to those who work in a general shift. Employees are also entitled for all the gazetted holidays announced by the Government of Pakistan.

3.8 Policy and Procedure for Remediation of Child Labor & Young Worker:

Policy:
Brookes Pharma (Private) Limited will neither employ/engage in child labour (specified as < 15 years of age) nor employ young workers (specified as >=15 and <18 years of age) in any aspect of its regular or contracted work. If ever a case is detected even if it relates to an incident that occurred in the past, Brookes Pharma (Private) Limited will take complete remediation and support measures as under:

1.

Procedure:

All personnel are required to immediately bring to the notice of Head of HR, information regarding any individual (child or young worker defined above) found employed, now or at any time in past.

Rev: 8 Rev. Date: 01-07-2012

Brookes Pharma (Private) Limited

2. If Child or Young Worker found to be working then Brookes will take the following actions: a) Ask them to discontinue work immediately. b) Provide adequate support to enable such children to attend and remain in school until no longer a child. c) Pay for their tuition related expenses, such as uniforms, books, and a stipend to replace essential lost income. d) In addition to providing school fees and/or contracting with a local group (if no free public education is available), the company should either; (i) offer to hire the parents, guardians, elder siblings or members of the extended family of the children OR (ii) pay a stipend to replace lost income. e) Inform interested parties who are experts on childrens welfare such as local government and /or NGOs. f) If no schools exist in that area, the company will work with local community and government to resolve this issue.

However, after attaining the age of 15 years for children and 18 years for young workers, there will be no liability on part of the company with regard to child or young worker payments / rehabilitation.

3.9 Forced and Compulsory Labor

Brookes does not engage in or support the use of forced or compulsory labor as defined in ILO Convention 29, nor shall personnel be required to pay deposits or lodge identification papers with the company upon commencing employment. Neither Brookes nor any entity supplying labor to the company withholds any part of any personnels salary, benefits, property, or documents in order to force such personnel to continue working for the company. All the personnel at Brookes have the right to leave the workplace premises after completing the standard workday, and are free to terminate their employment provided that they give reasonable notice to the company. Neither Brookes nor any entity supplying labor to the company engages in or support trafficking in human beings.

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Brookes Pharma (Private) Limited

3.10 Health And Safety
The Brookes is committed to; Provide a safe and healthy workplace environment and take effective steps to prevent potential accidents and injury to workers health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the workplace environment, and bearing in mind the prevailing knowledge of the industry and of any specific hazards. Provide to personnel on a regular basis effective health and safety instructions, including on-site instruction and, where needed, job specific instructions. Such instructions are repeated for new and reassigned personnel and in cases where accidents have occurred. Brookes maintains written records of all accidents that occur in the workplace and in company-controlled residences and property. Provide at its expense appropriate personal protective equipment to personnel. In the event of a work related injury the company provides first aid and assists the worker in obtaining follow-up medical treatment. Undertake to assess all the risks to new and expectant mothers arising out of their work activity and to ensure that all reasonable steps are taken to remove or reduce any risks to their health and safety. Provide for use by all personnel, access to clean toilet facilities, access to potable water, and, where applicable, sanitary facilities for food storage. To ensure that any dormitory facilities provided for personnel are clean, safe, and meet the basic needs of the personnel. All personnel have the right to remove themselves from imminent serious danger without seeking permission from the company.

3.11

Disciplinary Practices
Brookes treats all personnel with dignity and respect. It does not engage in or tolerate the use of corporal punishment, mental or physical coercion, or verbal abuse of personnel. No harsh or inhumane treatment is allowed.

3.12

Access to Verification
Brookes shall ensure access to its premises and to reasonable information required by the auditor in case of announced and unannounced audits of the company for the purpose of certifying its compliance with the requirements of this standard.

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Brookes Pharma (Private) Limited

Joint Works Council
Brookes has established a Joint Works Council with an aim to provide a platform where workers suggestions for improvements, grievances handling etc. can be discussed to maintain strong relationships between Workers and Management in order to provide better communication and representation. The council comprises of both male and female employees. Management Representatives comprise of two representatives as under: 1. Syeda Saba Swaleh 2. Syed Sajid Hassan Zaidi Senior Manager Packaging Senior Manager Commercial

Two workers representatives are currently members of this Joint Works Council. Their names are as under: 1. Salman Ahmed 2. Shama Parveen The Convener of the Council: Moghis Jalal Senior Manager Human Resources Maintenance Technician Line Incharge (Representative of male workers) (Representative of female workers)

The council meets and discusses issues after every six months. However, where there occurs any emergency meeting can be held earlier and at short notice. A part from this arrangement, management provides open door policy to meet and facilitate employees at any time during working hours.

Training
Employees are given trainings about the SA-8000, Health and Safety. A part from this, other on job trainings are also imparted. To make them aware and updated on the important policies, procedures, guidelines, precautions etc., regular feedback sessions, house notices and e-mail messages are sent out.

Facilities
Brookes provides various facilities to its employees which include, free meals, uniforms with washing, hygienic toilets, company provided transport facility for female workers, additional conveyance allowance for male workers, interest free loans etc.

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Rev: 8 Rev. Date: 01-07-2012

Brookes Pharma (Private) Limited

Management Review Results
Report for the period:- July 2011 to June, 2012 Agenda Status EDTOs Decision and Remarks

3.9 Status of Social Accountability Management System

3.9.0. Human Resource Management Process 3.9.1 Training, Awareness & Competence: 3.9.2 Freedom of Association and Right to Collective Bargaining: 3.9.3 Forced & Compulsory Labour
Trainings are being conducted as per training plan and evaluated accordingly. The joints works council meeting was last conducted on 11-06-12. The use of forced and compulsory labor is not at all supported. No discrimination is observed for hiring, paying remuneration, training, promotion, termination or retirement, gender etc. Mental or physical coercion and verbal abuses are neither observed nor supported. Employee generally works for 48 hours in a week at Brookes. However, in order to meet the market demand overtime is done which usually happens to be within 48 hours in a month. Excellent execution and documentation

All points had been discussed properly.

In full compliance

3.9.4 Discrimination

In full compliance

3.9.5 Disciplinary Practices

In full compliance

3.9.6 Working Hours

We strictly comply weekly hours and overtime limit.

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Rev: 8 Rev. Date: 01-07-2012

Brookes Pharma (Private) Limited

3.9.7 Remuneration
Minimum wages are paid over and above the legal requirement and is sufficient to meet the basic needs of personnel which include some discretionary income as well. Child labour is not engaged and supported at Brookes. Audits are being done as per the plan. Suppliers commitment of social accountability is available with Supply Chain. It is covered under QHAS18000 and is discussed in the MR meeting of QHSE. Interested parties are communicated SA-8000 policies and procedures for which communication folder has been made. Whenever there occurs any change in the document, it is communicated to them. However, Management Review results are communicated to them except confidential data. We would welcome dialogues with any stakeholder with respect to the compliance of SA-8000 standard. In place

OK

3.9.8 Child Labour

We comply fully

3.9.9 Control of Suppliers/Subcontractors and Sub-Suppliers

OK

3.9.10 Health & Safety

Fine

3.9.11 Outside Communication and Stakeholder Engagement

Our systems are working well for SA8000 policies communication.

3.9.12 SA-8000 Worker Representative

OK

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Rev: 8 Rev. Date: 01-07-2012

Brookes Pharma (Private) Limited

3.9.13 Access for Verification
In case of announced and unannounced audits of the company for the purpose of certifying its compliance with the requirements of SA-8000 standard, we provide access to our premises and to reasonable information required by the auditor. OK

Prepared By: SA- Management Representative

Approved By: Executive Director Technical Operations

Sign & date: ________________

Sign & date: ________________

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