Human Resources SHELL IN CANADA ALCOHOL AND DRUG POLICY

Human Resources SHELL IN CANADA ALCOHOL AND DRUG POLICY January 2015

OVERVIEW Objective and Principles The objective of Shell in Canada s Alcohol and Drug Policy is to provide a framework for dealing with alcohol and drug related concerns in the workplace based upon the following principles: n Shell strives to eliminate or minimize health and safety risks associated with its business activities. n The misuse of alcohol, or prescribed or over the counter medications and the use of illegal or other drugs (e.g. synthetic marijuana) jeopardize job safety and performance, the well being of employees and the public, the environment, and Shell s corporate reputation. n As appropriate measures are necessary to ensure the safe and sustainable conduct of Shell business, the use of alcohol and illegal or other drugs and the misuse of medications by Shell employees in the workplace are strictly prohibited and subject to disciplinary action up to and including dismissal for cause. n Shell recognizes that education, deterrence, and early intervention may help prevent alcohol and drug problems and dependencies in Shell employees or assist them with rehabilitation. Employees are encouraged to seek assistance from Shell Occupational Health respecting any drug or alcohol related problem or dependency. This policy applies to all employees working for Shell in all work circumstances. Standards and Prohibitions Shell employees must perform their work duties without limitation due to the use or after effects of alcohol, illegal or other drugs, or medications (see section on Fitness for Duty). In addition, the following are strictly prohibited: n to use alcohol, illegal or other drugs or misuse medications while on duty (for employees in Safety Sensitive Positions this prohibition covers meals and other breaks); n If in a Safety Sensitive Position, to report to work or be found, while on duty, to have a detectable blood or breath equivalent, alcohol content of 40 milligrams per 100 millilitres (0.04%) or greater; n to possess, distribute, or offer for sale alcohol, illegal or other drugs, or drug paraphernalia or to illegally possess, distribute, or offer for sale medications on Shell premises (including camps), in Shell assigned vehicles, or on premises where Shell work is being performed; n to use alcohol or illegal or other drugs following a work related incident, before completion of post incident tests or receiving notification that tests will not be required; n to fail to submit to tests required pursuant to this policy; or n to interfere or attempt to interfere with the integrity of any alcohol or drug test samples. Consequences of Non-Compliance Employees failing to comply with any of the above standards or prohibitions may be subject to: n referral to Shell Occupational Health for assessment; and n disciplinary measures up to and including dismissal for cause. 2 Alcohol and Drug Policy

FITNESS FOR DUTY Standards All Shell employees must be Fit for Duty during the time they are at work. To establish Fitness for Duty, a medical and/or other professional determination is made of the physical and psychological capability of an employee to safely and acceptably perform assigned duties without limitations ( Fitness for Duty ). This determination is made considering job demands and potential job exposures. Certification To establish their fitness to perform Safety Sensitive duties prior to beginning work in a Safety Sensitive Position, employees will be required to complete a medical assessment and to test for alcohol and specified drugs as part of a Certification process ( Certification ). Procedures In any work situation where a Shell in Canada employee is suspected of being under the influence of alcohol, illegal or other drugs, or the performance disabling effects of medications, the employee may be required to undergo a Fitness for Duty assessment, which may include testing for alcohol and specified drugs. If, during the Fitness for Duty assessment, the employee is found to be unfit for duty, or if an assessment cannot be performed, the employee will be provided with transportation appropriate in the circumstances. Consequences of Non-Compliance The employee may be temporarily suspended with pay and be removed from the worksite pending one or more of the following: n receipt of an evaluation from an appropriate professional as to whether the employee has a drug or alcohol problem; n the approval of site management, after considering the job functions to be performed, the safety of the work environment, and any appropriate conditions governing the employee s return to work; or n a determination of whether a breach of this policy has occurred and, if so, the appropriate disciplinary action to be taken. SAFETY SENSITIVE POSITIONS Scope Identified Safety Sensitive Positions will include: n any position having a direct role in operations or construction where impaired performance could reasonably be expected to result in an incident having significant negative effects upon the health and/or safety of Shell employees, contractors, customers, or the public, or a significant negative impact to the environment; n positions without direct involvement at the operational level but in which decisions, failures to act, or inappropriate action could reasonably be expected to result in an incident having significant negative effects upon the health and/or safety of Shell employees, contractors, customers, or the public, or a significant negative impact to the environment; and n the temporary performance of any of the above roles. Alcohol and Drug Policy 3

SAFETY SENSITIVE POSITIONS continued Identification Safety Sensitive Positions will be identified by each Shell business unit from time to time and will include, but may not be limited to, positions involving: n the operation, maintenance, or control of equipment for the production, processing, or transportation of hydrocarbons, chemicals, hydrocarbon by-products, or any other hazardous material; n the operation of or performance of maintenance upon aircraft; n the supervision of drilling or service rig activities; n the operation of heavy equipment; n direct operational responsibilities for emergency incident response that could reasonably be expected to affect the safety of operations; and n direct responsibilities for field operations. Certification Certification includes completing a medical assessment to verify fitness to perform Safety Sensitive duties and testing for alcohol and specified drugs. Prior to beginning work in a Safety Sensitive Position, employees will be required to fulfill Certification requirements. ALCOHOL AND DRUG TESTING Certification Testing for alcohol and specified drugs is required as part of the Certification process for employees beginning work in a Safety Sensitive Position. Reasonable Cause Testing for alcohol and specified drugs will be performed when there are reasonable grounds to believe that the conduct of an employee while on duty in a Safety Sensitive Position is indicative of the use or after effects of alcohol or drugs, or the misuse of medications. The decision to test may be made by a supervisor (if possible, with the concurrence of a second supervisor or manager) based upon specific observations about an employee recorded on Shell s Reasonable Cause A&D Testing Checklist, which could include, but are not limited to, the following: n observed use of drugs or alcohol; n the smell of alcohol; n slurred speech patterns; n tremors or unsteadiness in walking/standing; n repeated errors or other unexplained changes in job performance, behaviours (e.g., absenteeism/lateness); n disoriented behaviour or drowsiness; n erratic or unusual behavior; n unsafe or careless conduct; n possession of alcohol or drugs on Shell premises. In addition, testing for alcohol and specified drugs may be required of employees in non-safety Sensitive Positions at the discretion of Shell Occupational Health if the employee has been referred to Occupational Health on the reasonable belief that the work performance of the employee is indicative of the use or after effects of alcohol or drugs, or the misuse of medications. 4 Alcohol and Drug Policy

ALCOHOL AND DRUG TESTING continued Post Incident Testing for alcohol and specified drugs will be performed as part of an internal investigation for all employees whose acts, omissions, or decisions could have been a contributing factor in the cause of any work related incident having actual consequences with a severity rating of 3, 4 or 5 on the Shell Risk Assessment Matrix ( RAM ), with respect to people, assets, environment, or reputation 1. At Shell management discretion, as part of an internal investigation, alcohol and drug testing may be required of employees whose acts, omissions, or decisions could have been a contributing factor in the cause of any other work related incident. Post incident testing should not be performed when there is clear evidence that employee error could not have been a contributing factor in causing a work related incident (e.g. structural failure from inherent defects). Reintegration and Return to Duty Unannounced alcohol and drug testing may be performed as part of a support program for any employee and will be a condition for employees in Safety Sensitive Positions following rehabilitative treatment, a breach of this policy, or recommendation by a Substance Abuse Professional. After care programs will be developed on a case-by-case basis by Shell Occupational Health. Procedures The following procedures will apply in all circumstances where testing is required: n employees who are required to take an alcohol or drug test must sign forms consenting to testing, verifying samples and authorizing the communication of the test results to health professional designated by Shell, Shell Occupational Health, and Shell management. n reasonable cause and post incident testing must be completed as soon as reasonably practicable once the determination has been made to test. In remote locations a collection service must be contacted as soon as possible to arrange for prompt testing. n the grounds upon which a decision to test is based must be documented (Reasonable Cause Checklist/ Post Incident Checklist) by a manager or supervisor prior to submitting the request for testing. n If a required alcohol test cannot be conducted within 8 hours of the initial request or a required drug test cannot be conducted within 32 hours of the initial request, the employee must be referred by the supervisor to Shell Occupational Health for an assessment of Fitness for Duty and the supervisor must provide their manager with written reasons as to why the tests could not be conducted. 1 The RAM can be found on Shell Online, Health, Safety, Security, Environment & Social Performance, Control Framework, Communications Toolkit, Risk Assessment Matrix Alcohol and Drug Policy 5

SEARCHES Standard Shell may conduct an unannounced search and/or seizure if there are reasonable grounds to believe that alcohol, illegal or other drugs, or drug paraphernalia may be present on premises where Shell work is being conducted in Shell camps or in Shell assigned vehicles. In addition, Shell conducts unannounced searches with canine assistance at construction project sites and certain operating locations, as part of a practice communicated at the site. Any attempt by an employee to impede or prevent a search and seizure of alcohol, illegal or other drugs, or drug paraphernalia will be considered a breach of this policy and may result in disciplinary action up to and including dismissal for cause. IMPAIRED DRIVING Charges and Suspensions Any employee charged with an impaired driving related offence while operating a vehicle on Shell business or driving a Shell assigned vehicle must immediately report the charge to their supervisor. In addition, any employee whose operator s licence is suspended or who is charged with an impaired driving related offence as a result of roadside testing must immediately report such suspension and/or charge to their supervisor if within the period of suspension they are required to drive on Shell business, operate mobile equipment in their work duties for Shell, or drive a Shell assigned vehicle. The supervisor will contact Shell Occupational Health for the determination of whether a Fitness for Duty assessment should be arranged. Interim Measures Provided that the employee retains a valid operator s licence, and considering the circumstances and any assessment performed by Shell Occupational Health, a determination will be made as to whether the employee is in need of an assistance program and whether the employee should be allowed to continue to operate mobile equipment or Shell assigned vehicles pending the outcome of the charge. Any safety concerns may result in work restrictions being issued for the employee. Convictions and Suspensions Any employee convicted of impaired driving or related offence must immediately report to their supervisor, the conviction, and any imposed suspension or limitations affecting their operator s licence, if their work duties for Shell require a valid operator s licence or the conviction resulted from a charge which occurred while operating a vehicle on Shell business or while driving a vehicle assigned by Shell. Accommodation If reasonable and possible, employees who have had their operator s licence suspended, but require a valid operator s licence to perform their job duties, may be temporarily accommodated in an alternative position until their operator s licence is restored. Any such accommodation should not be considered absolute or indefinite. If driving is an essential part of the employee s work duties and an alternative placement is not feasible, the employment contract may be treated as terminated. Failure to Report Failure to immediately report an impaired driving or related charge, conviction, or suspension or resulting effect upon the employee s operator s licence may result in discipline up to and including dismissal for cause. 6 Alcohol and Drug Policy

CONTRACTOR OBLIGATIONS Standard A contractor s preparation for managing risks with respect to the use by workers of drugs, alcohol, or medications that could affect the performance of the contracted work must be addressed by the Shell contract owner, prior to Shell retaining the services of the contractor. Requirements RESPONSIBILITIES At a minimum, Shell contractors performing work equivalent to that performed in Safety Sensitive Positions must have rules to prohibit, and procedures to deal with, the use (and after effects) of alcohol and illegal and other drugs and the misuse (and potential disabling effects) of medications by their employees and sub-contractors while on duty. In addition, contractors providing workers to perform Safety Sensitive duties must have policies and procedures in force for reasonable cause and post incident testing. Additional measures may be required of contractors in certain circumstances. All contractor obligations in this respect must be clearly set out in the written agreement between the contractor and Shell. Shell s Role Shell will provide appropriate assistance to employees with alcohol and/or drug problems through Shell Occupational Health and Shell s Employee Assistance Program ( EAP ) in a manner that places priority on confidentiality, fairness, and respect for the individual. Shell Occupational Health will: n create an awareness of the problems and safety risks associated with alcohol and drug use and the performance disabling effects of medications by making available appropriate educational materials and information for EAP access; and n provide training and guidance to managers and supervisors in recognizing and dealing with alcohol or drug related performance problems. Employee Responsibilities The responsibility of each Shell employee is to: n be personally responsible for compliance with this policy and for their personal safety in this respect; n assume ownership of any alcohol or drug problem by seeking professional assistance and making full use of the counseling and treatment services made available by Shell or through Shell s arrangements with outside providers; n cooperate fully during investigations of work related incidents; n comply with any treatment and aftercare program aimed at fitness to work, improving job performance, eliminating safety risks, or reintegration into the Shell workforce; n notify their supervisor if aware that another Shell employee s use of alcohol or illegal or other drugs or misuse of medications presents a safety or security risk; n use prescribed and over-the-counter medications responsibly and manage potential impairment during work hours due to the legitimate use of medications; n if in a Safety Sensitive Position, obtain advice from a physician or pharmacist as to whether any prescribed medication will affect their ability to safely perform their job duties, and report any concerns to their supervisor or Shell Occupational Health to assist with decisions regarding modification of duties or temporary re-assignment; Alcohol and Drug Policy 7

RESPONSIBILITIES continued n require that responsibilities be assigned to another Shell employee if under the influence of alcohol or drugs or the performance disabling effects of medications when asked to report for duty in a Safety Sensitive Position; and n report to their supervisor any impaired driving or related charge, conviction, or suspension of operator s licence in accordance with the requirements of this policy. Supervisor and Manager Responsibilities The responsibility of each Shell supervisor and manager is to: n ensure that this policy is communicated to Shell employees who report to them and the principles of this policy are addressed with contractors working within their area of responsibility; n identify and monitor employee behaviour and performance problems that may be linked to the use of alcohol or drugs or the misuse of medications and notify Shell Occupational Health when there is a drug or alcohol related personnel concern or if aware of an employee s limited ability to perform their duties due to the use of medications; n ensure that an employee is removed from the workplace and that Shell Occupational Health is contacted to arrange a Fitness for Duty assessment if there are concerns about the employee s immediate ability to safely perform assigned duties without limitations due to the use or after-effects of alcohol, drugs, or medications; n ensure investigations of work related incidents including post incident alcohol and drug testing as required by this policy is conducted within the appropriate timelines; n ensure that testing for alcohol and/or drugs is performed when there are reasonable grounds to believe that the conduct of any employee while on duty (including meals and other breaks) in a Safety Sensitive Position is indicative of the use or after effects of alcohol or drugs; n assist Shell Occupational Health with the periodic verification of an employee s compliance with a reintegration or return to work program; n ensure that Safety Sensitive Positions are identified within the business unit for which they are responsible and that Certification for employees occupying, or beginning work in Safety Sensitive Positions has been performed in accordance with the requirements of this policy; n ensure that sufficient contact information respecting facilities that can perform drug and alcohol testing and Fitness for Duty assessments is readily available at field locations within their area of responsibility; and n notify Shell s security department if they reasonably suspect the presence of unauthorized alcohol, illegal or other drugs, or drug paraphernalia on premises where Shell work is being conducted, or in Shell camps or Shell assigned vehicles. Consequences of Non-Compliance Failure to comply with any of the above listed responsibilities by an employee, supervisor, or manager may result in disciplinary action up to and including dismissal for cause. 2015/01 8 Alcohol and Drug Policy