Environmental and Sustainability Policy

Vision:

To be recognized as one of the leading enterprises in our industry on Sustainability and Environmental Stewardship.

Policy:

Sustainable Development is a top Company priority, deriving from our Governing Objective and Values and aiming to combine business goals and long term economic performance with respect for people, society and the environment.

As a materials producer, what we do impacts, but can also benefit, the environment. We are committed to strategies and actions that mitigate and reduce our operational impact on the environment (do less harm), identify and pursue win-win opportunities for both economy and ecology and actively contribute to worthwhile local, national and international initiatives (do more good).

We aim to:

  1. Comply at a minimum with local, state and federal regulations and legislation.
  2. Continuously improve our environmental performance, reviewing and monitoring, at top management level, the effectiveness of our programs and actions.
  3. Take practical measures to protect the biodiversity and natural surroundings at our facilities.
  4. Develop, implement and monitor programs to use energy and natural resources more efficiently and to reduce our emissions and waste.
  5. Reduce the waste produced by activities, promote recycling and reuse the byproducts of our own and other industries.
  6. Procure, where practical, sustainable input materials and allocate resources to develop and market sustainable products.
  7. Promote environmentally responsible attitudes and behavior in all our employees and encourage suppliers, customers and other business partners to adopt similar practices.
  8. Contribute to the wellbeing of the local communities, communicating openly and sincerely with them and pursuing good neighbor relations.
  9. Support and participate in local, national and international initiatives and organizations designed to promote sustainability by sharing knowledge, best practices and joint actions.


Separation Technologies LLC

Guidelines and Processes

The following guidelines and processes aim to move us towards achieving these policies. We understand that many of these are already in-place or have begun.

Guideline 1: Regulatory/Legal Compliance

A. Working with company legal, engineering, government affairs and external advisors our local, regional or BU environmental managers will stay informed of applicable laws and regulations that affect their existing facilities. This includes maintaining current all applicable permits.

B. Management at each location will rely on environmental managers to maintain a general knowledge of applicable and proposed laws and regulations. Key relevant provisions will be communicated to local employees.

C. Proposed new properties or facilities at existing or new sites, built or acquired, will be reviewed by environmental managers during due diligence, planning, engineering, and/or construction. This includes all applicable permit applications and studies.

D. Any events that constitute an actual or potential violation will be investigated by environmental managers and reported to local and senior management. The Business Unit and Corporate environmental managers will decide what levels in management should be informed, depending on incident.

E. Any inquiries or facility inspections by government authorities, or their representatives, will involve the applicable environmental manager(s), who will be promptly informed of any such request or visit.

F. All work of any third parties with which the Company has contracted to perform services, and all tenants on Separation Technologies property will conform to these guidelines and processes.

G. The above guidelines and processes shall not preclude the Company from pursing due regulatory or legal processes to change or reverse laws, regulations or decisions that it deems incorrect or inappropriate.

Guideline 2: Continuous Improvement and Monitoring

A. Separation Technologies shall monitor its environmental performance with the goal of continuous improvement. Performance will be reported to top management to review the effectiveness of programs and actions and to make recommendations on environmental performance, procedures, and objectives.

B. Performance and management systems will be reviewed and monitored by environmental managers and reported to local and senior management, with recommended actions. Frequencies will be established based on size of operation and the potential impact to the environment.

C. Facilities or operations with on-going periodic inspections for various environmental permits or programs will follow designated procedures and will report the results to the appropriate environmental personnel.

D. Any review findings that constitute an actual or potential violation or reporting obligations will be reported to local and senior management, and Corporate legal counsel. The Business Unit and Corporate environmental managers will decide what levels in management should be informed, depending on incident.

Guideline 3: Biodiversity and Natural Surroundings

A. Practical measures shall be taken to protect biodiversity and natural surroundings. Regulatory or permitting actions may direct these actions; however, voluntary opportunities shall also be considered.

B. For locations where government mandated environmental impact studies are not required, educate environmental managers through available community and public resources on local environmental sensitivities.

C. Where material environmental sensitivities do exist, environmental managers to work with local operations management to better understand how facility operations or planned changes impact these and determine practical options to avoid-minimize-mitigate.

D. Encourage employees to explore opportunities to enhance or restore biodiversity or natural surroundings as part of voluntary projects or in conjunction with other activities, such as quarry reclamation.

Guideline 4: Energy and Natural Resources

A. Promote the efficient use of energy and natural resources by monitoring use and implementing cost-effective programs to increase efficiency, increase substitute materials, and reduce emissions and waste.

B. Participate in the following monitoring programs:

1. Electrical and energy use monitoring at all facilities.

2. Mobile equipment operations monitoring for oil and fuel use, and idling time.

3. Greenhouse Gas (GHG) management program at cement plants:

1. World Business Council on Sustainable Development/Cement Sustainability Initiative (WBCSD/CSI) protocol

2. EPA Mandatory GHG Reporting Rule (40 CFR Part 98).

4. Environmental Performance Indicators (EPIs) and Key Performance Indicators (KPIs) pursuant to the requirements of Group Engineering and Technology (GET).

© 2008 Separation Technologies LLC. All rights reserved. ProAsh is a registered trademark of Separation Technologies LLC.
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