Policy for Working with Contracting Organisations

Purpose of the Policy: We seek to maintain long-term and successful relationships with our contracting organisations, as they are an integral part of our operational activities. The Policy for Working with Contracting Organisations is based on the principles of integrity, cooperation and sustainability.

Partnership and cooperation: We seek to build partnership relationships with our contracting organisations based on fair business practices. We value their professionalism and expertise and recognise their important contribution to our success. We are prepared to work with our contractors on the basis of mutual respect and mutual benefit.

Transparency in relationships: We adhere to high standards of transparency in our relationships with contracting organisations. We undertake to provide clear information about our requirements, expectations and terms of cooperation. We also expect our contractors to provide accurate information about their capabilities and resources.

Proper management: We adhere to strict quality and safety standards in our operations. We expect our contracting organisations to have appropriate and comparable management systems that enable joint activities in accordance with the same standards of service quality, risk management, security, occupational safety and health, environmental protection and corporate social responsibility applied by Asia Trans KZ.

Professional development and training: We pay particular attention to the professional development and training of employees in our contracting organisations. Regular contractor training programmes, including those conducted with our participation, help improve knowledge and skills and reduce the risk of harm to health, property, the environment and society.

Sustainability and responsibility: We follow the principles of sustainable development and responsibility in our activities. We expect our contracting organisations to follow the same principles, taking into account their impact on the environment and society. We are prepared to jointly develop and implement sustainable practices in our projects.

Confidentiality and data protection: We undertake to ensure the confidentiality and protection of data relating to our contracting organisations. We comply with applicable data-protection laws and standards and expect the same from our partners.

Performance assessment: We regularly assess the effectiveness of this Policy and make adjustments where necessary to improve its operation and achieve its objectives.

Interested parties: We take into account the views and requirements of interested parties regarding this Policy and seek to meet their expectations by building strong relationships and trust.

The person responsible for implementation of this Policy is the person responsible for the OD function.

Review and update: This Policy is reviewed regularly and updated as necessary, taking into account changes in legislation and the Company’s needs.

Procedure for Selecting and Assessing Contracting Organisations

For the purpose of selection, approval and subsequent monitoring, the Company classifies engaged transport organisations according to the nature of their integration into the Company’s management system. The Company’s primary operating model is non-integrated subcontracted transport organisations, which independently manage their drivers, vehicles and operations but are required to comply with the requirements established by the Company and the Customer. Fully integrated subcontractors or drivers are treated as a separate category only where they are actually integrated into the Company’s management system. The unplanned engagement of a carrier for a one-off transport operation is permitted only in exceptional cases and subject to compliance with the established minimum approval requirements.

The unplanned engagement of a one-off carrier is permitted only where objectively necessary and does not release that carrier from complying with the minimum requirements of the Company and the Customer. Before assigning an order, the Company shall document, verify and communicate to the spot carrier at least the requirements relating to applicable legislation and necessary permits, transmission of transport and customs documents through the chain of contractors, emergency response and emergency contacts, compliance with Customer site requirements, and the terms and restrictions of further subcontracting.

All subcontracted transport organisations approved to perform orders shall be identified in the Approved Contractor Register, stating the type of service provided, contractor category, approval status and date of the next assessment.

Contractor selection

1.1. Where a contracting organisation is required to carry out work related to road transport, responsible Asia Trans KZ employees of the OD function shall assess potential contractors for compliance with the Company’s standards and requirements.

1.2. Contractor selection shall take into account the contractor’s experience, qualifications and industry reputation.

1.3. A written contract with the contractor shall clearly specify the terms of cooperation and requirements relating to service quality, risk management, security, occupational safety and health, environmental protection and corporate social responsibility.

1.4. A written contract, contract annex, application or other document establishing the terms of cooperation with a subcontracted transport organisation shall define the applicable Company and Customer requirements concerning legal compliance, occupational safety and health, security, service quality, environmental protection, driver training, route planning and safe parking, transmission of transport and customs documents through the contractor chain, emergency response, vehicle technical condition, compliance with loading and unloading site requirements, registration and reporting of non-conformities, accidents, incidents and near misses, confidentiality of operational and commercial data, and provision of information for the calculation of transport greenhouse-gas emissions.

1.5. The written agreement shall separately define whether further subcontracting of the transport operation is permitted or prohibited. If sub-subcontracting is permitted, the contractor shall obtain prior approval in cases established by the Company or Customer and ensure that all applicable requirements concerning safety, quality, security, documentation and reporting are passed on to the sub-subcontractor.

Assessment of contractor management systems

2.1. Before road transport operations are assigned to a contractor, its management systems for service quality, risk management, security, occupational safety and health, environmental protection and corporate social responsibility shall be assessed.

2.2. The assessment shall be carried out by responsible Asia Trans KZ employees or independent experts in accordance with requirements equal to or at least comparable with those applied by Asia Trans KZ.

2.3. Where necessary, the contractor shall be provided with recommendations and resources to improve its management systems and overall operations to an appropriate level.

2.4. Before entering into a contract and approving a contractor to carry out transport operations, the Company shall perform a documented preliminary assessment of compliance with applicable legal requirements, SQAS requirements, Customer requirements and the Company’s internal requirements. The result shall be documented with a conclusion on approval, conditional approval subject to corrective actions, or refusal of approval.

2.5. Depending on applicability, the assessment shall verify legal capacity and permit documents; insurance; compliance with ADR requirements and the availability of a DGSA where necessary; compliance with driver working and rest time requirements; alcohol and drug policy; BBS requirements; route planning and safe parking locations; emergency response and availability of an emergency number; vehicle maintenance and mandatory inspections; driver qualification and training; compliance with Customer site requirements; procedures for recording accidents, incidents, near misses and other non-conformities; security and confidentiality requirements; and the availability of data required by the Company to calculate greenhouse-gas emissions from transport operations.

2.6. The Company establishes minimum requirements for drivers engaged by non-integrated subcontracted transport organisations and provides the contractor with Driver Guidelines or requirements, or verifies that the contractor has equivalent documented instructions covering the applicable requirements of the Company and Customers.

2.7. The contractor shall ensure that such requirements are communicated to drivers assigned to perform the Company’s orders. The Company retains documented evidence that the requirements have been provided to the contractor and, where necessary, verifies the existence of records confirming driver familiarisation and training.

Conditions for performance assessment

3.1. A written process shall clearly define the conditions and frequency of contractor performance assessment.

3.2. The assessment may include audits, standards-compliance checks, analysis of reporting and customer feedback.

3.3. Where deficiencies or non-conformities are identified, the contractor shall be provided with recommendations and deadlines for resolving the issues.

Consideration of Customer restrictions

4.1. The written process shall take into account any specific requirements and restrictions established by Asia Trans KZ customers.

4.2. Contractors shall be informed of such requirements and are required to comply with them in all aspects of their activities.

4.3. Before assigning an order to a subcontracted transport organisation, the Company identifies applicable special Customer requirements and restrictions, including chemical-company requirements concerning safety, security, quality, drivers, vehicles, routes, loading and unloading sites, documents and reporting. These requirements shall, to the applicable extent, be included in the contract, application or transport order, or otherwise documented and communicated to the contractor before transport begins.

4.4. The Company retains documented confirmation that significant Customer requirements have been communicated to the contractor and considers their fulfilment during subsequent assessment of the contractor’s performance.

Monitoring and management

5.1. Asia Trans KZ undertakes to continuously monitor and manage contractor activities in order to ensure compliance with the standards, requirements and expectations of the Company and its customers.

5.2. In the event of non-conformity or unsatisfactory results, appropriate corrective actions shall be taken, including consideration of terminating cooperation.

5.3. The Company carries out documented monitoring of all active subcontracted transport organisations. Compliance with key requirements is verified before entering into a contract and subsequently at least once a year, taking into account risk level, the volume of transport operations performed and previous assessment results. More frequent monitoring may be established for contractors with increased risk, repeated non-conformities or unsatisfactory results.

5.4. Monitoring takes into account SQAS or alternative assessment results, accidents, incidents and near misses, Customer complaints and claims, breaches of legal and site requirements, service quality and timeliness, completion of corrective actions and other agreed indicators. The monitoring results shall include a conclusion on the contractor’s future status and, where necessary, an improvement programme with responsible persons and deadlines.

5.5. The Company maintains regular dialogue with contractors regarding assessment results and monitors the effectiveness of agreed corrective and improvement actions. Documented evidence of assessments, monitoring, correspondence, meetings and closure of actions is retained in accordance with the established procedure.

5.6. In all matters not established by this Procedure, the Guidelines on Subcontracting of Chemical Road Transport shall apply: 2005 CEFIC, ECTA, EPCA Guidelines on Subcontracting of Chemical Road Transport.