Responsible Care Implementation The Sipchem Story

Purpose & Values Purpose: Sipchem aims to be a responsible, innovative and globally recognized petrochemical company providing competitive and quality products to satisfy our customers, motivate our employees and meet Shareholders' expectations. Values: Adhere to highest ethical standards, embracing integrity, trust and taking responsibility for Sipchem's actions. Strive for operation excellence in delivering products and services. Embrace innovation and adapt to changing conditions. Care for the well being of Sipchem's employees, community and environment.

Sipchem Responsible Care and Quality Policy

Sipchem December 2001 25 employees Grass Roots Plants Grass Roots Company No policies, No standards, No procedures…. just a vision We Started with a blank Sheet of Paper, Industry Standards and Experienced Leaders 3

Responsible Care Journey 2003 Systems Needed for a Safe Startup PSSR Permit to Work Emergency Response MOC 2004 High Priority Systems implemented Commissioned Methanol Plant ahead of schedule No Process Safety Incident No Safety Incident 2005 PSM Vision Achieve World Class PSM Performance through: Operational Discipline Line Management Responsibility Employee Participation Use the OSHA PSM Standard as guide In house development Build & Reinforce on existing systems 2006 Quality and Environmental Vision Integrate Quality and Environmental initiatives. Achieving; Continual improvements International Standard Recognition thru ISO 9001 and 14001 certification 4

Sipchem Management Systems in 2010 Before Integration & Transformation Security Procedures Process Safety Management (Included “Employee Health & Safety”) Quality and Environmental Management System Linkage between the three Silos not well defined No formal procedures/system for; Distribution Product Stewardship Community Awareness & Emergency Response outside the fence 5

Documentation Structure Defined the Document Hierarchy Established guidelines for Sipchem PSM Management System Standards Written in the end state Included Element KPI’s Established review & Approval Process 6

Process Safety Management Quality and Environmental Management System Integration and Transformation Security Procedures Process Safety Management Quality and Environmental Management System Security Procedures Process Safety Management Quality and Environmental Management System 7

Responsible Care and Quality Management System Policy Statement Sipchem Management System in 2011 After Integration & Transformation Responsible Care and Quality Management System Policy Statement Security Responsible Care and Quality Management System “Roadmap” PSM Employee Health & Safety QEMS Employee Health & Safety Product Stewardship QEMS PSM CAER Distribution CAER Security Distribution Product Stewardship 8

Documentation Structure Strategic Goals Objectives & Policies Management System Standards Technical Standards Functional Standards Departmental Work Processes, Departmental Functional Procedures Work Instructions Records Level 1 Level 2 Level 3 Level 4 Figure 1 Guide Lines Corporate Work Processes, Corporate Functional Procedures Defined the Document Hierarchy Established guidelines for Sipchem Responsible Care and Quality Management System Standards Written in the end state Established review & Approval Process 9

How did we do it? Where did we start? Commitment by CEO Appointment of Responsible Care Manager and full time Responsible Care Coordinator Appointment of Executive to GPCA Responsible Care Committee Capital funding made available “World Renowned” consultants utilized 10

Management of Change Process Implemented: Executive Sponsors and Subject Matter Experts (SMEs) identified for Codes and GAP analysis completed EH&S Committee redesign ----Over 100 employees directly involved Selection and use of SME Consultants to help close specific GAPS New Committees formed to address Gaps Integration Process Launched with focus on RC&QM Roadmap Development with New Standards / Procedures Build on Deputy Management Representative (DMR) organization created for QEMS Training Communication, Communication, Communication 11

Management System Structure Roadmap and Scope of Document Changes Management System Structure New Revised Minor / Major Impacts General Minor No or little Policy 1 Major All Employees Aspects and Impacts Responsible Care and Affiliate DMRs Legal and other requirements Objectives and Targets N/A Roles and Responsibilities 2 Responsible Care, Distribution and DMRs Training Communications Responsible Care Documentation DMRs and Management Control of Documents Operational Control 6 Procurement, Distribution and Responsible Care Emergency Response Monitoring and Measurement Compliance Evaluation No or Little Nonconformance’s Record Management Responsible Care and Affiliate DMRs Internal Audit Management Review Management, Responsible Care and Affiliate DMRs 14 12 12

Audit Strategy Developed Implemented an Integrated Internal Audit Process Auditor Training PSM Auditor QEMS Auditor RC14001 Auditor Bundled certifications with single registrar Minimum 5 years experience required for RC14001 Lead Auditor 13

New Responsible Care and Quality Management Documents Policy Statement Responsible Care and Quality Policy Statement Standards Development and Control of Management System Documents Responsible Care and Quality Roles and Responsibilities Product Stewardship Commercial Partner Standard (Procurement) 14

New Responsible Care and Quality Management Documents Nine Distribution Safety Standards  Sipchem Distribution Safety Management System Distribution Safety Roles and Responsibilities Distribution Risk Management Complying with Distribution Safety Regulations Securing Chemicals in the Distribution Chain Chemical Handling in the Distribution Chain Selection and Management of Distribution Service Providers Preparation and Response to Distribution Incidents Managing Chemical Deliveries and Customer Provided Transportation 15

General Orientation and Specific Training Executive Team Orientation – 30 minute overview/refresher plus reading materials General Orientation included in Corporate Safety meeting materials – Mandatory for all Departments and Employees ….Approximately 1 hour “Inside the Fence Line” Specific training - 12 revised standards and 4 new Standards – Mandatory for DMRs and Managers …..1/2 day. Distribution Safety Specific training - 9 new standards – Mandatory for Distribution functions, Marketing, Procurement, Responsible Care, Security, Training and Public Relations / Communications 16

Areas Improved in 2012 Awareness of Aspects & Impacts Management ownership and support Affiliates and departments participation Monitoring and reporting Monitoring and Measurement Standard Employee reporting Stakeholders communications Distribution, Product Stewardship and Care Codes System improvement such as SAP-EHS & Stature 17

Focus Areas for 2013 Cascading of objectives/targets and action planning by functional areas Audit program improvements including RCA and corrective action planning Monitoring and measurements – Inspection, test, and PM programs for Safety and PSM equipment Compliance with procedures Emphasis on accountability for RC&Q Management from Executives down to employees Use of leading indicators such as CAMEL 18

Thank You