Role Purpose

• To protect the Group from fatalities, regulatory shutdowns, and material environmental incidents by driving a risk based, enforceable, and cost conscious EHS system across all companies through a structured Shared Services model.
• The role is accountable for visibility of risk, escalation of exposure, and enforcement of minimum standards, while day-to-day site execution is delegated to EHS coordinators.

Group Risk Control & Non-Negotiables

• Define and enforce Group EHS Minimum Standards (Non-Negotiables) covering:
• Fire protection systems
• Chemical/solvent handling
• Machinery safety & lockout
• Contractor high-risk work
• Effluent treatment & discharge (ETPs)
• Emissions control
• Waste management
• Maintain a live Group Critical Risk Register (Top Risks per site)
• Immediately escalate any condition that can lead to:
• NEMA shutdown / EDL suspension
• Fatality or life-threatening exposure
• Major fire or explosion

Shared Services Delivery Model

• Operate as a Group function supporting but not replacing site/company level accountability

Define:

• What EHS owns (standards, audits, escalation)
• What sites own (execution, compliance, daily control)
• Conduct quarterly structured reviews with each CEO
• Maintain formal escalation pathway to the Board for unresolved risks
• Define clear roles, responsibilities, and performance expectations for each officer aligned to Group priorities
• Ensure EHS Officers:
• Drive day-to-day compliance, inspections, and monitoring at site level
• Implement Group standards and non-negotiables
• Maintain accurate reporting and documentation

Conduct:

• Weekly operational check-ins (risk updates, incidents, priorities)
• Monthly performance reviews (KPIs, gaps, accountability)

Build capability through:

• Coaching, technical guidance, and standardization of practices across sites
• Enforce accountability by:
• Escalating non-performance or repeated failures to the leadership
• Ensure consistency across sites-no independent or conflicting EHS practices

EHS Team Leadership & Performance Management

Lead and manage a team of EHS Officers across all Group companies under a Shared Services structure;

Environmental Risk Management

Establish strict control over:

• Effluent treatment plants (ETPs)
• Waste handling and disposal
• Air emissions and chemical storage
• Ensure:
• No untreated discharge to environment
• All EDL conditions are tracked and complied with
• Implement early warning triggers (before regulatory breach occurs)

Fire Safety

• Standardize and enforce:
• Fire detection and suppression systems
• Flammable solvent storage and handling
• Emergency preparedness and drills
• Identify high-risk production processes (lamination, printing, generators, boilers)
• Ensure minimum fire risk controls are always active

Incident & Crisis Leadership

• Lead response for:
• Fatalities / serious injuries
• Environmental incidents
• Fires and major operational events
• Ensure:
• Immediate reporting to leadership
• Proper root cause investigations
• Regulatory engagement is controlled and consistent

Compliance Strategy

• Maintain a Group Compliance Dashboard
• Prioritize:
• High-risk legal exposures first
• Licenses (EDL, fire, statutory inspections)
• Ensure:
• No surprise regulatory actions due to lack of visibility
• Engage regulators proactively where risk exists

Contractor & Project Risk Governance

• Enforce minimum contractor safety requirements
• Ensure all high-risk work has:
• Permit-to-work systems
• Risk assessments and supervision
• Integrate EHS into:
• Procurement approvals
• Project execution

Safety Culture Transformation- Focus on Leadership Accountability

• Drive shift from:
• EHS department responsibility Leadership accountability
• Focus on:
• Supervisor and plant manager behavior
• Enforcement of rules, not awareness only
• Implement simple, visible safety campaigns tied to real risks

EHS Systems, Reporting & Visibility

• Implement simple, functional systems:
• Incident reporting (QR / digital)
• Risk and compliance tracking
• Provide:
• Monthly Group risk dashboard
• Quarterly Board-level risk summary
• Standardize reporting across all companies

Budget & Resource Prioritization

• Develop risk-based EHS budget
• Prioritize:
• Controls that prevent shutdowns and fatalities
• Recommend low-cost, high-impact solutions

Board & Leadership Advisory

• Report only what matters:
• Top risks
• Regulatory exposure
• Major incidents
• Required decisions
• Provide clear recommendations, not just status

KEY PERFORMANCE INDICATORS

Critical Risk Control

• 100% of sites with identified Top 5–10 risks
• 100% of critical risks escalated within 24 hrs
• 80% of critical risks with interim or permanent controls

Environmental Protection

• Zero uncontrolled discharge incidents
• 100% visibility of ETP performance status across sites
• All EDL risks flagged before breach

Regulatory Exposure

• Zero unplanned license expiries
• Zero regulatory shutdowns due to lack of escalation
• 70% closure of high-risk compliance gaps

Incident Management

• 100% reporting of serious incidents within 24 hrs
• 80% closure of high-risk corrective actions
• Reduction in:
• LTIs
• Environmental incidents
• Fire incidents

Leadership Accountability

• 100% quarterly reviews completed per company
• Documented CEO ownership of actions
• Escalations tracked to closure

Contractor & Operational Safety

• 90% of high-risk contractor activities conducted under valid permit-to-work (PTW)
• 90% of contractor works with approved risk assessments / method statements
• 90% compliance with critical controls (PPE, supervision, isolation, fire controls)

Safety Culture

• Increase in hazard/near-miss reporting
• Reduction in repeat violations
• Visible enforcement of non-negotiable rules

Reporting & Visibility

• Monthly ESG score card reports issued on time (100%)
• Group dashboard fully updated
• All sites reporting in standard format

EHS Team Performance & Accountability

• 100% of EHS Officers with defined KPIs and monthly performance reviews
• 80% of assigned actions by EHS Officers closed within timelines
• Consistent reporting quality and accuracy across all sites
• No site operating without active EHS oversight