LSR_FAQ_EN (word document, 72 kB)

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FREQUENTLY ASKED QUESTIONS
GENERAL
1. Why are the Life Saving Rules necessary?
More than 15 MOL Group employees and contractors have suffered fatal injuries in accidents related
to work in the past 5 years. In many cases failure to comply with a safety rule was a significant factor.
The Life Saving Rules define clear and simple “DOs” and “DON’Ts” covering activities with the highest
potential to get severely or fatally injured. It is essential to make sure that these basic rules are
followed and workers are protected. We are determined to save lives.
2. Are the Life Saving Rules the ultimate solution to reach zero injuries?
They are expected to make a significant difference; this is also supported by the experience of our
peers who have already introduced a similar program. The Life Saving Rules are not a magic solution
though; in the end safety depends on us all.
3. Where did these 10 rules come from and why have they been selected?
The Rules are not new. They focus on the activities that carry the greatest potential threat of serious
injury or death to our staff and contractors when safety rules are not observed. They are being
enforced to ensure that everyone who works at MOL Group operations follows them and gets home
safely.
4. Does this mean that MOL Group is dissatisfied with the safety performance of the recent
years, despite the improving performance indicators?
The performance trend over the last few years shows improvement in injury frequency and most of
our employees consistently comply with safety rules. The number of fatalities and serious injuries on
the other hand has been alarmingly high, so there is room to improve compliance. That’s why it is
time to take action to stop risk-taking. We don’t want any work-related deaths or injuries.
5. Does this mean other safety rules are not as important?
All our safety rules are important. We want to see compliance with all rules, not just the Life Saving
Rules.
6. Am I expected to report rule-breaking?
Always intervene where there is unsafe working. This applies to your colleagues and contractor
employees. We want a safe working environment for everyone. If you observe rule-breaking, you
should first intervene if it is safe for you to do so. Yours may be the last opportunity to stop a rulebreak becoming an injury or fatality. If the unsafe act remains or if the violation puts other persons
also in direct danger, report immediately to the person in charge of the work activity or your direct
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supervisor. We expect everyone to intervene and encourage reporting rule-breaking so that we can
improve the safety of our operations.
7. Who do I report a breach to?
You can report the breach to the person in charge of the work activity or your direct supervisor. You
can also go to a manager higher up as well.
Please add here local information how supervisors, shift leaders, managers can report.
8. How will Life Saving Rule violations be investigated?
To ensure fairness each Life Saving Rule violation will be investigated. We will use existing
investigation procedures used at site/ BU / OpCo level.
9. What about new employees and contractors?
The Life Saving Rules are part of our induction for all new staff and contractors and must be covered
before starting work. Application of disciplinary actions is covered by employment contracts for both
own staff and contractors.
10. How will you know the Life Saving Rules have been successful?
We expect to see fewer work-related deaths and serious injuries.
11. Who can I provide feedback to about the Life Saving Rules?
You can provide feedback to your line manager, local HR helpdesk, or local SD & HSE team.
Please add here local information on feedback possibilities.
DISCIPLINARY ACTIONS
12. If I break a Life Saving Rule, will I be dismissed?
Each incident will be investigated thoroughly. Failure to comply with any Life Saving Rule will result in
disciplinary action, up to and including termination of employment for MOL Group employees or, for
employees of contractors or sub-contractors, removal from site and disqualification from future
work.
If the employee is aware of the rule and intentionally did not comply with that rule, the maximum
appropriate disciplinary action, in accordance with local law will be applied. In addition, if a
supervisor/shift leader/person in charge tolerates the conditions for rule breaking or fails to follow
through if a rule is broken, maximum appropriate disciplinary action will apply to them as well.
Please add here local disciplinary action rules.
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13. Will this be a tool to dismiss staff or release contractors?
The goal is as simple as the name says: to keep everyone safe by ensuring everyone follows the Life
Saving Rules. Our goal is not to dismiss people. As the Life Saving Rules focus on activities with the
greatest potential for killing or seriously injuring people, if there are intentional violations of the rules
in high risk operations we will apply the principle that “who decides to break the rules, decides not to
work for MOL Group”. And if a contractor is aware of the rules but does not comply, we do not want
that contractor back on MOL Group premises or working for any MOL Group company. MOL Group
however cannot ask or require a contractor company to take disciplinary action.
14. Isn’t dismissing someone too strict for breaking a Life Saving Rule?
All our safety rules exist to protect people. We’d rather take disciplinary action than allow people to
intentionally take high risks that could result in them hurting or killing themselves or others.
15. What does maximum appropriate disciplinary action mean?
Following thorough investigation, disciplinary action will depend on the risk taken, other relevant
considerations, as the intention of the rule violator and of course local laws, but the intent is to
apply the sanction that is appropriate to each situation.
Please add here local disciplinary action rules.
16. Is the disciplinary action the same for violations that did and did not result in an accident?
Yes. Disciplinary action applies to violations, even if they do not actually cause an accident.
17. Who takes the decision on the disciplinary action?
The decision on disciplinary action will be taken only after an investigation is conducted. Typically the
manager having the employer rights, supported by HR and SD & HSE will decide on the appropriate
disciplinary action. The decision to dismiss can only be taken by the management of the company
that employees the individual.
18. Can countries decide on what “maximum disciplinary action” means?
Different countries have different legal frameworks, which MOL Group will comply with. The
management of the OpCo will ensure consistent application of the Life Saving Rule principle within
the local legal framework across the Businesses operating in the country.
19. Within a given country, will disciplinary action always be the same no matter what the
violation?
Each incident will be investigated individually. There will be an assessment of the circumstances
including the risks. Disciplinary action must be proportionate to the violation. The disciplinary actions
may therefore differ depending on the risk and other circumstances.
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20. I am a supervisor/shift leader/person in charge. If one of my team members breaks a Life
Saving Rule, what will be the consequence for me?
Supervisors/shift leaders have a key role to make the Life Saving Rules work, especially in terms of
employee engagement and ensuring compliance. If you tolerate the conditions for rule breaking or
fail to follow through if a rule is broken, the disciplinary action (in accordance with local law) will also
apply to you.
21. I am an employee/contractor. If I see a Life Saving Rule being violated but do not report it
what’s the consequence for me?
An environment that tolerates the breaking of safety rules is not acceptable. We want to create a
proactive reporting culture where we address unsafe acts and conditions proactively. It is understood
however, that reporting about direct colleagues cannot be expected under all conditions. The
minimum expectation towards you is to always intervene when there is unsafe working. If the unsafe
act remains or if the violation puts other persons also in direct danger, than you need to report
immediately. Failing to do so will be investigated individually.
22. Will there be a group-level guideline specifying what the appropriate disciplinary action is
for each example of non-compliance?
No. The Life Saving Rules need to be implemented within the context of local legislative frameworks,
and it is the role of the local SD & HSE, together with HR and other relevant functions.
23. Are social events or commuting to and from work included in the Life Saving Rules?
No. Social events and commuting to or from your normal place of work are generally out of scope.
However, driving under the influence of alcohol after a social event, or breaking traffic regulations
may themselves be violations of local law. Employees are still expected to comply with all local laws.
IMPLEMENTATION
24. I sometimes feel to be under pressure to save time and finish the task as soon as possible.
How do I deal with this?
It is advised to discuss this with your direct manager or one level above. Time pressures or meeting
planned targets are no reason to break the rules.
25. Can we add rules at OpCo or Business level?
The Life Saving Rules themselves (wording or icons) cannot be changed. However, BUs and OpCos
can and will have additional safety rules besides the Life Saving Rules.
26. What will happen to existing rules?
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Rules that apply to areas that are not covered by the Life Saving Rules and which are specific to
Business or local operations and activities will remain.
27. Are the Life Saving Rules relevant for the office environment?
Compliance with the Life Saving Rules is mandatory for all MOL Group employees and contractors
while performing tasks for MOL Group. Of course most rules will have more relevance in some
setting than others.
Office workers may be exposed to industrial operations due to building maintenance or window
cleaning activities being conducted in or around their office environment. The workers involved in
carrying out such activities are subject to the Life Saving Rules and if an office worker witnesses a
violation of a Life Saving Rule they are expected to intervene. If MOL Group employees or contractors
(whether office workers or not) visit work sites or are involved in other industrial activities, all Rules
apply to them as well.
28. One of the Rules says that we are not allowed to consume alcohol or drugs while working.
Does this include consumption before work or during lunch?
Yes. Consumption of alcohol or drugs before work or during lunch could reduce your ability to do
your job safely. Employees and contractors are not allowed to work or drive while under the
influence of drugs or alcohol.
29. How about social drinking and commuting?
Social activities and activities carried out in your personal time outside of working hours are out of
scope. Local law will apply in such cases.
30. What happens if the customer consumes alcohol at a business meeting – are we
responsible for reminding them about the Life Saving Rules?
The Life Saving Rules do not apply to our customers. If you feel that your customers may be in an
unsafe situation as a result of their alcohol consumption you should intervene. But there is no duty to
do so. Intervene and request them to stop in a respectful but firm manner.
31. Are the Life Saving Rules relevant for contractors, as they often have their own set of
rules?
While conducting business for MOL Group, compliance with the Life Saving Rules is mandatory for all
contractors. Prior to doing work for MOL Group all contractors must be verifiably informed about the
Rules.
32. Do the Life Saving Rules apply to Joint Ventures?
The Life Saving Rules apply to MOL Group controlled Joint Ventures only.
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33. How do you recommend I communicate to my staff about this?
Make sure that every one of your staff receives training on the Life Saving Rules and document the
attendance. Where practical (e.g. non-office employees), this training shall be done face-to-face. It
shall be also verified that contractors working at your area of responsibility have received the
training prior to work.
34. Why are we launching this 1 November 2013?
This is to allow sufficient time to implement the Life Saving Rules consistently across all OpCos,
Business Units and sites in each country, as application of disciplinary actions will start on 1 January
2014. It will also ensure sufficient time for staff and contractor engagement.
35. Shouldn’t we be concerned that the Life Saving Rules will have a negative impact on
productivity?
It is not expected since none of the rules is new. It is expected that employees are going to become
more conscious of the safety aspects of their jobs. Our first priority is the safety of our people.
PROCESSES
36. What is the process followed in the case of a rule violation?
This will follow the current standard disciplinary process in each country or OpCo, which will be
applied consistently to all Business Units and sites in that country or OpCo.
Please add here local investigation & consequence workflow information.
37. What does “appropriate” consequence mean?
”Appropriate” is dependent on the outcomes of the investigation and local legislative framework. For
violations in high-risk operations and in case of intentional violation, we operate on the general
principle that “who decides to break the rules, decides not to work for MOL Group”. HR and other
relevant functions will always be consulted in these cases prior to final decision on the
consequences.
38. How will it be ensures that the investigations are fairly carried out and not biased against
the employee?
Investigations should take place as per the current investigation process with any HSE incident. The
process ensures fairness and transparency.
39. How shall be recorded the attendance of staff and contractor Life Saving Rules training?
The regular HSE training diary shall be used for own staff and the contractor training diary for
contractors (e.g. as part of the induction).
version: 3/9/2013
Please add here local training measures if necessary.
version: 3/9/2013
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