IMS MANUAL REV. 012

Date: JUNE 13, 2012 Form IM -001

INTEGRATED MANAGEMENT SYSTEMS MANUAL

Prepared by: (Shamail Haider - VP HSEQ) __________________________________

Reviewed by: (Rashid Jamil - DMR) __________________________________

Approved by: (Tariq S. Quddusi – MR) __________________________________

Head Office: Dawlance Center, 7/4, Civil Line, Dr. Ziauddin Ahmed Road, Karachi, Pakistan.

Factories: URIL (Unit # 1): D-14, S.I.T.E., Hali Road, Hyderabad,DPL-I (Unit # 2): S-476, National Highway, Landhi, Karachi,DPL-II (Unit # 3): D-89, Deh Khanto, Bin Qasim Town, National Highway, Landhi, Karachi.

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FOREWORD

This manual describes the Health, Safety, Environmental and Quality management systems requirements and the programs of Dawlance Group of Companies (DGC) to ensure that customers’ Health, Safety, Environmental and Quality management systems requirements are recognized, properly implemented, effectively controlled and adequately maintained. The manual also identifies the use of formal written procedures for the effective control of product quality, pollution-free and safe environment.

The DGC Health, Safety, Environmental and Quality management systems are based on the requirements outlined in standard of the International Organization for Standardization ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007. It includes provision for the prompt detection of discrepancies and for timely and effective corrective and preventive actions.

The requirements of Health, Safety, Environmental and Quality management systems as mentioned in the Integrated Management Systems Manual (IMSM) are applicable to all products, services, departments and functions of DGC Factories. The implementation of the requirements and procedures is mandatory for all concerned.

TARIQ S. QUDDUSIMANAGEMENT REPRESENTATIVEDawlance Group of Companies

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REV. 01AMENDMENT RECORD

Date Description of Change Page Revision Approval

18-01-12 INITIAL RELEASE 01 of 18 00

13-06-12 CC # IM-12001 01 of 20 01

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REV. 01Contents

1. INTRODUCTION................................................................................................................................. 6

2. COMPANY PROFILE ......................................................................................................................... 6

2.1 CORE VALUES .............................................................................................................................. 6

3. PURPOSE AND SCOPE:..................................................................................................................... 7

3.1 EXCLUSION................................................................................................................................... 7

4. DOCUMENTATION............................................................................................................................ 7

4.1 CONTROL OF DOCUMENTS...................................................................................................... 8

4.2 CONTROL OF RECORDS ............................................................................................................. 9

5. MANAGEMENT RESPONSIBILITY ............................................................................................... 9

5.1 MANAGEMENT COMMITMENT................................................................................................ 9

5.2 MANAGEMENT REVIEW ............................................................................................................ 9

5.3 CUSTOMER FOCUS.................................................................................................................... 10

5.4 POLICIES...................................................................................................................................... 10

5.5 PLANNING OF INTEGRATED MANAGEMENT SYSTEM ..................................................... 11

5.5.1 HSEQ OBJECTIVES.............................................................................................................11

5.5.2 ENVIRONMENTAL ASPECTS ...........................................................................................11

5.5.3 HAZARD IDENTIFICATION, RISK ASSESSMENT AND...............................................12

DETERMINING CONTROLS .................................................................................................

5.5.4 LEGAL AND OTHER REQUIREMENTS...........................................................................12

5.6 RESPONSIBILITIES AND AUTHORITIES: ............................................................................. 12

5.7 COMMUNICATION..................................................................................................................... 14

5.7.1 INTERNAL COMMUNICATION .......................................................................................14

5.7.2 EXTERNAL COMMUNICATION ......................................................................................14

6. RESOURCE MANAGEMENT ......................................................................................................... 15

6.1 PROVISION OF RESOURCES .................................................................................................... 15

6.2 HUMAN RESOURCES ................................................................................................................ 15

6.3 TRAINING AND DEVELOPMENT ............................................................................................ 15

6.4 INFRASTRUCTURE .................................................................................................................... 15

6.5 WORK ENVIRONMENT............................................................................................................. 16

7. PRODUCT REALIZATION / IMPLEMENTATION AND OPERATION ................................ 16

7.1 CUSTOMER-RELATED PROCESSES ............................................................................................ 16

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REV. 017.1.1 DETERMINATION OF REQUIREMENTS RELATED TO THE ....................................16

PRODUCT...............................................................................................................................

7.1.2 REVIEW OF REQUIREMENTS RELATED TO THE PRODUCT ..................................16

7.2 DESIGN AND DEVELOPMENT................................................................................................. 17

7.3 PURCHASING AND VERIFICATION OF PRODUCT.............................................................. 17

7.4 PRODUCTION AND SERVICE PROVISION ............................................................................ 17

7.4.1 CONTROL OF PRODUCTION ..........................................................................................17

7.4.2 VALIDATION OF PROCESSES FOR PRODUCTION ....................................................17

7.4.3 SERVICE PROVISION....................................................................................................... 18

7.5 PRESERVATION OF PRODUCT ...............................................................................................18

7.6 IDENTIFICATION AND TREATABILITY OF PRODUCT ...................................................... 18

7.7 CONTROL OF MONITORING AND MEASURING EQUIPMENT.......................................... 19

7.8 OPERATIONAL CONTROL........................................................................................................ 19

7.8.1 EMERGENCY PREPAREDNESS & RESPONSE............................................................19

7.8.2 INCIDENT INVESTIGATION AND REPORTING .........................................................19

8. MEASUREMENT, ANALYSIS & IMPROVEMENT .................................................................... 20

8.1 MONITORING AND MEASUREMENT OF PROCESSES AND............................................. 20

PRODUCT QUALITY .....................................................................................................................

8.2 MONITORING AND MEASUREMENT OF ENVIRONMENTAL.......................................... 20

ASPECTS .........................................................................................................................................

8.3 MONITORING AND MEASUREMENT OF HAZARDS ......................................................... 20

8.4 EVALUATION OF COMPLIANCE ........................................................................................... 20

8.3 INTERNAL AUDIT ...................................................................................................................... 20

8.4 NON-CONFORMANCES AND CONTROL OF NON- .............................................................. 21

CONFORMING PRODUCT .............................................................................................................

8.5 CORRECTIVE AND PREVENTIVE ACTIONS ......................................................................... 21

8.6 CONTINUAL IMPROVEMENT.................................................................................................. 21

Annex – 01: Organization charts of: DPL-1, DPL-2, URIL, Head Office & HSEQAnnex – 02: DGC policiesAnnex – 03: Authorization letter

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REV. 011. INTRODUCTION

It is the intent of Dawlance Group of Companies (hereinafter referred to as “DGC”) to establish an Integrated Management System (IMS) which meets the requirements of ISO 9001, ISO 14001 and OHSAS 18001.

This manual provides an overview of the Integrated Management System; its purpose is as follows:

To explain the scope of the IMS. To outline the company policies and procedures, and human resources available

for implementation. To describe the structure of organization, the structure of the IMS and the

interaction of the processes involved in the IMS. To provide all employees with a clear understanding of the management system

and the importance of adhering to the policies and procedures of the company.

2. COMPANY PROFILE

Established in 1980 Dawlance is one of the most innovative and reliable producers of Home appliances in Pakistan. DGC strives to deliver the highest value to its customers. DGC is currently involved in Designing, manufacturing, marketing and providing after sales services for the following products.

Refrigerators Chest Freezers Split Air-Conditioners Microwave Ovens Washing Machines

Various manufacturing, Sales and Service facilities are strategically located across entire Pakistan to cater customer requirements.

2.1 CORE VALUES

The core values are the principles we hold to, live by, interact and deliver as a part of Dawlance team. Following are our Core values:

Respect Team Work Creativity Openness and Candor Communication Transparency

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3. PURPOSE AND SCOPE:

The purpose of this manual is to describe DGC’s integrated Occupational Health & Safety, Environment and Quality management systems, hereinafter referred to as OHSAS , EMS,QMS. This Manual defines how the activities are conducted within factories of DGC and it provides the needed documentation and procedures to fulfill the requirements of the three standards, Quality Management System (ISO 9001:2008), Environmental Management System (ISO 14001:2004), and Occupational Health and Safety Assessment Series (OHSAS 18001:2007). The requirements of Health, Safety, Environmental and Quality management systems as mentioned in the Integrated Management Systems Manual (IMSM) are applicable to all products, services, departments and functions of DGC Factories

3.1 EXCLUSION

Clause 7.5.4 of Customer property is excluded from the scope Dawlance group of companies

4. DOCUMENTATION

DGC has established, maintained, and implemented an IMS documentation system based on the requirements of ISO 9001, ISO 14001, and OHSAS 18001. The document coversthe requirements in the three stated standards that are in common. Documents are classified as per following pyramid.

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DGC has established procedures to effectively control and manage activities in all Departments and sections in the factories. The documents have distinctive codes for identification. These procedures serve the purpose of fulfilling the requirements of ISO 9001, 14001 and OHSAS 18001 and to be coherent with the defined policies. The proper implementation of these procedures guarantees the quality of executed work and eliminates deficiencies in the integrated management system. The set of issued procedures for the health, safety, and environment satisfy the standard’s requirements to assess the risks associated with the company activities and their environmental impact.

4.1 CONTROL OF DOCUMENTS

Documents are reviewed and approved as per hierarchy defined in procedure (DGC-IMS/DC-001). All the controlled numbers are allotted only from CDC CTD as defined in procedure (DGC-IMS/DC-002). Any change (whenever required) in data/document must be authorized by HSEQ and relevant function head as defined in above mentioned procedure. DGC also determine s and controls documents of external origin.

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SOP

WI, ITI, PRODUCT / PROCESS STANDARDS

FORMS & FORMATS

LEVEL-2

LEVEL-3

LEVEL-4

LEVEL-1

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4.2 CONTROL OF RECORDS

All records, which are documents that state results achieved or provide evidence of activities performed, are kept and maintained for the specified period of time as defined in list of HSEQ records.All the IMS records that need to be maintained along with their retention times and storage areas are defined in relevant procedures in accordance with the specified requirements. For details refer system procedures for Control of Records (DGC-IMS QR-001, QR-002).

A formal system for the disposal of records has been established. IMS records may be maintained in the form of hard copies or electronic media. An index of all IMS records is maintained. All records are filed in appropriate manner for easy access and retrieval.

5. MANAGEMENT RESPONSIBILITY

5.1 MANAGEMENT COMMITMENT

DGC always strives to deliver the highest value to its customers and stakeholders. Management is committed towards the adherence to stringent product /process standard in order to meet Customer needs and requirements.The company is committed in developing, maintaining and continually improving the processes and systems, to keep Dawlance retaining and improving its top position in market.

Our activities are planned and performed in order to meet the needs and expectations of our customers by consistency in our operations. Our aim is “to make Dawlance a global brand by practicing RELIABILITY and make Pakistan proud of us”.

The management of DGC is also committed in providing a safe and environmental friendly place of work for employees and contractors, through the implementation of IMS standard as well as statutory, regulatory and legal requirements that continuously improve the application and performance of the IMS standard at DGC.

5.2 MANAGEMENT REVIEW

Organization has established and maintains procedure for reviewing the integrated management system by top management in order to ensure its continuing suitability, adequacy, effectiveness and continual improvement. Management reviews are arranged

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REV. 01periodically by HSEQ Department and it ensures that necessary information is collected to support management to carry out an effective evaluation. System procedure for Management Review of Quality & Environmental Management Systems (DGC-IMS/MR-002) outlines the details of Management Review.

5.3 CUSTOMER FOCUS

DGC’s management, at appropriate levels, determines appropriate customer needs and requirements through market research and surveys, and converts them into the form of defined requirements with the goal of achieving customer satisfaction and confidence. Obligations related to product, including regulatory, statuary and legal requirements are properly considered while determining customer needs and expectations.

5.4 POLICIES

Following are our Policy statements.

QUALITY POLICY

We strive to be perceived by our customers as a RELIABLE organization providing

high quality products and services. We are also committed to meeting customer

demands and exceeding it by continuously raising the bar .We are working to build

a company that is regarded by its employees as one they are proud to work for and

grow with.

ENVIRONMENTAL POLICY

We are committed to minimize impact on the environment through pollution

prevention, reduction in consumption of natural resource, control emissions, and

reduction and recycling of waste .The company manages its product and processes

that are not harmful to our surroundings and community by complying to all

applicable legal and regulatory requirements.

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REV. 01 HEALTH & SAFETY POLICY

Health and Safety of our employees, community and of all stake holders are of

prime importance to us. We are committed to creating and sustaining a safe

work environment by eliminating hazards and reducing risks. We accomplish

this by providing resources and trainings, to implement and support this

commitment.

5.5 PLANNING OF INTEGRATED MANAGEMENT SYSTEM

5.5.1 HSEQ OBJECTIVES

For the sake of improving and meeting the requirements of the company policies with respect to Health, Safety, Environment and Quality management systems, all head of departments (HOD’s) shall establish Departmental HSEQ objectives. At Dawlance the objectives are set, shared, monitored and evaluated in the form of;

Key Performance Indicators (KPI) Dash boards Obeya Morning Meeting Improvement projects such as KAIZENS. EMT Councils Any other departmental objectives

For details refer system procedure of Measurement, Analysis and Improvement (DGC-IMS/ MI-001)

5.5.2 ENVIRONMENTAL ASPECTS

Organization has established and maintains procedures to identify in detail various types of environmental aspects, to analyze them and determine levels of those that have or can have significant impacts on environment. All such information is kept updated.Significant environmental aspects associated with the operating activities in the organization are categorized such as

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REV. 01 Air emissions which include contaminants such as particulate matters, oxides of

nitrogen, carbon monoxides and smoke. Water discharges includes effluents which enter inland or sea water. Solid wastes are those which are deposited in landfills. Noise level. Recycling of scraped parts / material.

5.5.3 HAZARD IDENTIFICATION, RISK ASSESSMENT AND DETERMINING CONTROLS

Organization will determine activities of processes that have or could have hazardous impact to human health and safety and also and has developed the scale for measuring severity of these Hazards .Organization keeps all information about hazards and their impacts. For this purpose procedure Hazard identification & risk assessment procedure (DGC-HSE/HI-001) can be referred. Organization will ensure that results of these assessments are considered when determining the controls.

5.5.4 LEGAL AND OTHER REQUIREMENTS

Organization has established and maintains a procedure to identify legal and other requirements of integrated management system. In this regard system procedure of Identification of Legal and Other Requirements (DGC-HSE/LR-001) is referred. DGC Management has access, arranges and adheres to all sorts of legislative, legal and other requirements to which the organization subscribes or may subscribe such as

Process standards Product & service standards Industry codes of practices General environmental laws, licenses and permits Agreements with public authorities Non-regulatory standards & guidelines

5.6 RESPONSIBILITIES AND AUTHORITIES:

5.6.1 MANAGEMENT REPRESENTATIVE:

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REV. 01Director Manufacturing who is also Management Representative (MR) is overall custodian of implementation of integrated management system. MR reports directly to Managing Director (M.D).He also informs top management on the performance of HSEQ management systems for reviews and feedbacks in order to continually improve these systems. Head of quality who is also Deputy Management Representative (DMR) will officiate in the absence of MR. He will be responsible to:

Ensure that the requirements of the Integrated Management System are fully implemented and maintained.

Ensure that the company complies with all applicable laws and regulations. Provide adequate resources including Human Resources, Infrastructure and a healthy

work environment

5.6.2 HSE COUNCIL:

HSE council comprising of Director Mfg, GM (HR) and GM (Admin) is responsible to

Determine overall objectives of HSE.

Determine and approve appropriate certifications related to HSE.

Determine and approve required HSE policies and procedures, particularly in respect of inter-departmental cooperation and team work.

Determine and approve the required facilities to carry out HSE activities effectively.

5.6.3 HSEQ HEAD

HSEQ head is responsible for documentation and monitoring the compliance of integrated management system and also monitors the execution of the policies within the framework of ISO 9001/14001 & OHSAS18001 and any future certifications.

5.6.4 FACTORY MANAGER & HEAD OF DEPARTMENTS:

It is the responsibility of Factory Managers and respective head of Departments (HOD’s) to define the responsibilities of their team and assure all members understand their roles and the company policies, and ensure compliance to integrated management system requirement.

5.6.5 ALL EMPLOYEES

All employees at DGC, management and non management, permanent & temporary contract or subcontractor employees are responsible for:

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REV. 01 Planning and performing their work in accordance with the Company policies and procedures as laid down in the Integrated Management System.

Carrying out their work in a manner that will not put at risk their personal health and safety, their colleagues, company assets and will not harm the environment.

Proposing changes, where opportunities for improving performance, Failure reductions, or increased efficiency and reducing risks are identified.

Promptly reporting accidents, incidents, near misses and unsafe act and situation and any other hazardous situations they observe.

5.7 COMMUNICATION

5.7.1 INTERNAL COMMUNICATION

Internal communications shall be implemented to ensure that personnel at each relevant level are aware of the following:

The importance of conformance to IMS policies, procedures. The potential consequences of system non-conformance. Individual roles and responsibilities in achieving conformance with procedures,

including emergency preparedness and response

Internal communications may be accomplished by the use of:

Appropriate awareness and training sessions in line with job function Use of Notice boards for posting relevant information Electronic mail Forums such as OBEYA, Morning meetings and Councils.

5.7.2 EXTERNAL COMMUNICATION

Correspondences received by external partners such as customers and suppliers shall be responded by the appropriate manager or head of department. Records of those shall be kept for references.

For details system procedure of internal & external Communication(DGC-IMS/CM-001) is referred.

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REV. 016. RESOURCE MANAGEMENT

6.1 PROVISION OF RESOURCES

Management, in the light of management reviews and other controls, ensures to provide adequate resources essential for implementing and maintaining the integrated management systems and continually improve their effectiveness and enhance them.

6.2 HUMAN RESOURCES

Management has established procedure and assigned responsibilities defined in the integrated management systems to Human Resource Department for ensuring that personnel are competent on the basis of appropriate education, training, skills and experience.

6.3 TRAINING AND DEVELOPMENT

The management is aware that the success of management systems relies on the understanding and awareness of its employees. The management is responsible for ensuring that appropriate training is provided to and attended by their staff in order to carry out their assigned duties. A documented system procedure is in place to plan, execute, evaluate and improve the training process in order for this organization to sustain required growth and maintaining competitive edge in market. We are committed to develop and train our workforce in following areas;a) HSEQb) Job related skill development (such as RIAP)c) Improving knowledge base of our employees by introducing modern concepts and

techniques both from internal and external resources.d) Mentor program for new engineers.e) Industrial visits.

6.4 INFRASTRUCTURE

Management regularly reviews, determine and updates the requirements for infrastructure on as and when required basis, and make arrangements through different departments of organization. Requirements of infrastructure may include the followings:

(a) Buildings, work space and associated facilities.(b) Process equipment, both hardware and software.(c) Supporting services such as transport or communication or information services.

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6.5 WORK ENVIRONMENT

Management ensures that a healthy, safe and conducive work environment is maintained for factory personnel in each department. Company has determined and manages the work environment needed to achieve conformity to quality product requirements byproviding all the required resources. Management also ensures that accidents of any type are reported, immediate first aid is provided and reported accidents are thoroughly investigated and required corrective and preventive actions are implemented in all departments. 7S will be implemented by effective Housekeeping in all areas. A list of all those items requiring special storage condition like temperature control is also maintained by Store Department.

7. PRODUCT REALIZATION / IMPLEMENTATION AND OPERATION

DGC has established Quality Plan to ensure quality in at various production stages. The approved Inspection & Test and Instructions (ITI) fully describe the methods of inspection and testing.

7.1 CUSTOMER-RELATED PROCESSES

7.1.1 DETERMINATION OF REQUIREMENTS RELATED TO THE PRODUCT DGC has established and maintains documented procedures outlining the activities

associated with customer contracts and the necessary coordination between the relevant departments. These are detailed in relevant system procedure of Customer-Related Processes.

7.1.2 REVIEW OF REQUIREMENTS RELATED TO THE PRODUCT

All queries received from prospective customer (or Marketing Department) are reviewed to ensure that the requirements are understood and all necessary information is available prior to developing the quotations and their submission to the customer.

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7.2 DESIGN AND DEVELOPMENT

All design and development activities at DGC are controlled by the established and maintained procedures. For details refer relevant Design system procedures.

7.3 PURCHASING AND VERIFICATION OF PRODUCT

DGC maintains documented procedure to ensure that all purchased products conform to specified requirements of Health, Safety, Environment and Quality.For details refer relevant system procedures of Purchasing and Monitoring and Measurement.

7.4 PRODUCTION AND SERVICE PROVISION

7.4.1 CONTROL OF PRODUCTION

DGC ensures that processes which directly effect quality are carried out under controlled conditions and in accordance with written work instructions / approved samples / illustrations / measuring equipment. The product information is defined in relevant drawings/(BOM) Bill of material.

7.4.2 VALIDATION OF PROCESSES FOR PRODUCTION

Special processes are performed by qualified personnel using approved written procedures, MPCC and controlled equipment. The following processes are identified asthe special processes at present:

Powder Spray Coating Foaming

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REV. 01Special working environments such as humidity and temperature control, are established and maintained where required. Records of results for processes, equipment and qualification / training of personnel are kept current and available for verification.

7.4.3 SERVICE PROVISION

DGC provides after sales services for customers in case of complaints by customers regarding mal-functioning of product. For details refer procedures of Servicing.

7.5 PRESERVATION OF PRODUCT

DGC maintains documented procedures for handling, storage, packaging, preservation and delivery of products in order to protect it from deterioration and unauthorized use. For details refer relevant system procedures (DGC-HP-001 - HP-005)

7.6 IDENTIFICATION AND TREATABILITY OF PRODUCT

DGC has implemented and operates a system to trace materials, components and assemblies to their specific sources and to identify the associated test certificates as defined in the relevant procedures. Where traceability is required by the contract, codes of practice or regulations, items are identified and traceable to a specified point of origin. Such traceability is maintained throughout the design, manufacturing and operational life of the product.

Finished product is assigned unique identification code in order to establish the traceability of finished goods. Identification of parts and product status accomplished by using sticker, tags or stamps, for details refer system procedures of Inspection & Product Identification and Traceability.

Travelogue / Bar coding system is used to control the product quality at each stage of production and assembly.

All products which have passed through concession (production deviation permit). The status sticker ensures the continuity of status identification for traceability throughout production & service.

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7.7 CONTROL OF MONITORING AND MEASURING EQUIPMENT

DGC has established & maintains documented procedure for control, calibration & maintenance of inspection and test equipment, used to demonstrate the conformance of product to the specifications. For details relevant system procedures may be referred.

7.8 OPERATIONAL CONTROL

Operational control procedure are established and implemented to control and manage the associated health, safety risks and environmental hazards.

These operational control procedures are prepared based on the risk assessment done at the time this manual is developed. Different procedure shall be added to the management system for any future changes in high risk activities. Alternatively, existing procedures could be amended /updated as necessary to reflect those newly developed hazards.

7.8.1 EMERGENCY PREPAREDNESS & RESPONSE

A detail procedure (DGC-HSE/ER-001) is developed and implemented on how to respond and behave in an emergency situation. All the necessary information (i.e. emergency phone numbers, fire extinguishers location, assembly point location …etc.) are readily available and posted at appropriate locations throughout the DGC including head office and Service centers.

7.8.2 INCIDENT INVESTIGATION AND REPORTING

All incidents/accidents/unsafe acts are reported as per procedure (DGC-HSE/IR-001)and monitored. The data compiled and analyzed periodically in order to further improve the system. DGC policy on incident, accident, near miss and unsafe acts reporting is to adopt a positive attitude toward the reports in order to encourage the employees in reporting these events with purpose of the improvement, ensuring healthy, risk/hazard/accident free environment for our employees and also for learning from our mistakes.

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REV. 018. MEASUREMENT, ANALYSIS & IMPROVEMENT

8.1 MONITORING AND MEASUREMENT OF PROCESSES AND PRODUCT QUALITY

DGC applies suitable methods for the measurement and monitoring of processes and product quality. These methods demonstrate the ability of processes and product characteristics. For detail refer Quality Plan and system procedures of Measuring and Monitoring (DGC-IT-001 – IT-005)

8.2 MONITORING AND MEASUREMENT OF ENVIRONMENTAL ASPECTS

A documented system is implemented (DGC-HSE/EA-001) to identify the environmental aspects of different processes carried out at DGC, and their subsequent effects on environment. DGC is also committed to abide by all legal and regulatory requirements to minimize and control environmental impacts from its product/processes.

8.3 MONITORING AND MEASUREMENT OF HAZARDS

A documented system is implemented (DGC-HSE/HI-001) to identify Hazards, assessing risks based on risk criteria and propose counter measures across DGC. HIRA activities are conducted periodically and hazards are identified on maps which are placed throughout the facility for better understanding.

8.4 EVALUATION OF COMPLIANCE

Consistent with its commitment to compliance DGC has established, Implemented and maintained a procedure for periodically evaluating compliance with applicable legal requirements and standards. All records of the results are shared, analyzed and evaluated for improvement purposes.

Evaluation of compliance with applicable legal and other requirements has been mentioned in relevant system procedures DGC-HSE/EC-001.

8.3 INTERNAL AUDIT

DGC has established procedures for audits and implements them through HSEQ Department which evaluates objectively the adequacy of the procedures and instructions as referenced in DGC’s integrated management systems. For details refer relevant system procedure of Internal Audits (DGC-IMS/IQ-001).

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REV. 018.4 NON-CONFORMANCES AND CONTROL OF NON- CONFORMING PRODUCT

Organization has established and maintains procedure to define responsibility and authority for handling and investigating non-conformances. Procedure has also been described to take appropriate actions to overcome or mitigate any resulting impact on Health, Safety, Environment, and Quality to eliminate the root causes of subject non-conformance. For more details refer system procedure of Control of Systems Nonconformance.

8.5 CORRECTIVE AND PREVENTIVE ACTIONS

In case of non-conformance with the planned results, corrective and preventive actions are taken to ensure conformity of product. All actions taken to correct deficiencies are verified by the follow-up audits. For details refer relevant system procedure (DGC-IMS/CA-001).

8.6 CONTINUAL IMPROVEMENT

DGC strives for continual improvement of Integrated Management Systems through the implementation of IMS policy, HSEQ objectives, audit results, analysis of data, corrective and preventive actions and management reviews.