Life-Saving Rules – Frequently Asked Questions

Version 3, 23/04/09

GENERAL

Why are Life-Saving Rules necessary?

More than 350 Shell employees and contractors have been killed worldwide in work-related incidents between
2000 and 2008. In many cases failure to comply with a safety rule was a significant factor. Our12 Life-Saving
Rules set out clear and simple “dos and don’ts” covering activities with the highest potential safety risk. It is
essential to make sure that the Rules are followed and people are protected. We are determined to save lives.

Do you see Life-Saving Rules as a quick fix to achieve Goal Zero?

Based on experience from several parts of Shell, we expect them to make a significant difference. They are not
a magic solution but they support our continuing Goal Zero journey.

Where did these 12 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 people when safety rules are not observed. They are being enforced to ensure that everyone who
works on Shell business follows them – and gets home safely.

What happens to the Golden Rules?

They will remain as they set out the general safety-related behaviour we expect of our people – we comply
with the law, standards and procedures; we intervene in unsafe or non-compliant actions; and we respect our
neighbours. Our Life-Saving Rules support our Golden Rules and focus attention on 12 high-risk activities.

Has Goal Zero failed?

No. The Life-Saving Rules are one part of how we continue to create the safety culture needed to avoid work-
related fatalities and serious injuries. The Life-Saving Rules help enable Goal Zero.

Does this mean that Shell has decided its safety culture is not good enough?
The performance trend over the last few years shows improvements in both fatality and serious injury rates,
and most of our people consistently comply with safety rules. But there is room to improve compliance so we’re
taking action to stop risk-taking. We don’t want any work-related deaths or injuries.

Does this mean other safety rules are not as important?

All our safety rules are important in achieving our commitment of no harm to people. We want to see
compliance with all rules, not just the Life-Saving Rules.

Am I expected to report rule-breaking?

Always intervene where there is unsafe working. This applies to your co-workers and peers. 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 rule-break becoming an injury or fatality. If the unsafe
act persists or if the violation jeopardises people’s lives, escalate immediately to the person in charge of the
work activity or your direct supervisor. We expect and encourage people to report rule-breaking so that we
can improve the safety of our operations. We do not want to instill a culture that inhibits people from
intervening.

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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 should
feel free to go to a manager higher up as well.

How will breaches be investigated?

To ensure fairness, we will continue to use existing investigation policies and procedures used at site/ Business
level.

How will you stop the strict enforcement of Life-Saving Rules driving incident reporting underground?
If you choose to stop reporting non-compliances you are choosing to make your workplace a more hazardous
place for yourself, your colleagues and your friends. In addition, we will continue to positively reinforce our
reporting culture.

Given the current tough economic conditions, how will Shell deal with pressure on safety compliance?
Our safety rules are there to be followed. Ignoring or breaking rules is unacceptable behaviour. The Rules will
actively help safety compliance, because people will always be supported when they insist on following the
Rules.

What about new employees and contractors?

The Life-Saving Rules form part of our induction/orientation process for all new staff and contractors and must
be covered before people start work.

How will you know the Life-Saving Rules have been successful?
We will see fewer work-related deaths and serious injuries.

Who can I provide feedback to about the Life-Saving Rules?

You can provide feedback to your line manager, local Human Resources Manager, or local HSSE team.

DISCIPLINARY ACTION

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 Shell employees or, for employees
of contractors or sub-contractors, removal from site and disqualification from future Shell work.
If the employee is aware of the rule or required procedure through training, experience or communication,
and did not comply with that rule or procedure, the maximum appropriate disciplinary action (in
accordance with local law) will be applied. In addition, if a supervisor tolerates the conditions for rule
breaking or fails to follow through if a Rule is broken, maximum appropriate disciplinary action (in
accordance with local law) will apply to the supervisor as well. For violations in high-risk operations the
general principle is that “if you choose to break the Rules, you choose not to work for Shell”.

Are you looking to dismiss staff/release contractors?

We’re looking to keep everyone safe by ensuring everyone follows the Life-Saving Rules. If an employee is
aware of the Rules but does not comply, we will apply maximum appropriate disciplinary action. As Life-
Saving Rules focus on activities with the greatest potential for killing or seriously injuring people, if there are
violations of the Rules in high-risk operations we will apply the principle that “if you choose to break the Rules,
you choose not to work for Shell”. And if a contractor is aware of the Rules but does not comply, we do not
want that contractor back on Shell premises or working for any Shell company. Shell cannot ask or require a
contractor company to take disciplinary action.

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Isn’t firing someone a bit extreme for breaking a Life-Saving Rule?
All our safety rules exist to protect people. We are investing a lot of effort in making sure people know the
rules. The logic is that we’d rather take disciplinary action than allow people to take risks that could result in
them hurting or killing themselves or others.

What does maximum appropriate disciplinary action mean?

Following thorough investigation, disciplinary action will depend on the risk taken, other relevant
considerations and local employment laws, but the intent is to apply the maximum sanction that is appropriate
to each situation. We have a review process to ensure disciplinary action is handled consistently.

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.

Who takes the decision on disciplinary action?

The decision on disciplinary action will be taken only after a thorough investigation is conducted by the
Business, with support from HR and HSSE in the Business, in accordance with the established disciplinary
process in the country. Typically the most senior manager representing that Business in the country,
supported by HR and HSSE, will decide on the appropriate disciplinary action. Where necessary, that
manager may elect to escalate this to the VP level depending on the nature of the violation. The decision to
dismiss can only be taken by the management of the company that employees the individual.

Can countries decide on what “maximum disciplinary action” means?

For violations in high-risk operations, the general principle is that “if you choose to break the Rules, you
choose not to work for Shell”. Failure to comply will result in disciplinary action, up to and including
termination of employment for Shell employees or, for employees of contractors or sub-contractors,
removal from site and disqualification from future Shell work. However, different countries have different
legal frameworks, which Shell will comply with. This general principle will therefore need to be
“operationalised” within the local legal framework. The Country Coordination Team chaired by the
Country Chair and supported by Country HR and Legal will ensure consistent application of the principle
within the local legal framework across the Businesses operating in the country.

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. For violations in high-risk operations, maximum
appropriate disciplinary action will be applied up to and including dismissal (in case of Shell employees),
in accordance with local law, or, for employees of contractors or sub-contractors, removal from site and
disqualification from future Shell work. We operate from the principle that ”if you choose not to comply,
you choose not to work for Shell”.

I am a supervisor. If one of my team members breaks a Life-Saving Rule, what’s the consequence for
me?
Supervisors have a key role to play in reinforcing the Life-Saving Rules in terms of employee engagement
and ensuring compliance. You need to initiate an investigation if you see a Rule being broken or know
that a Rule has been broken. If you, as a supervisor, tolerate the conditions for Rule breaking or fail to
follow through if a Rule is broken, maximum appropriate disciplinary action (in accordance with local law)
will also apply to you.

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I am an employee/contractor working on Shell business. If I see a Life-Saving Rule being broken but do
not report it what’s the consequence for me?
We want people to report all safety violations. An environment that tolerates the breaking of safety rules is
not acceptable. We will look into and deal with each situation on a case-by-case basis following a fair
and thorough investigation. We want to create a proactive reporting culture where we address unsafe acts
and situations pro-actively; we do not want to create a culture where reporting goes underground.

Will there be a set of global guidelines 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 Life-Saving Rules HR Focal Point, together with Legal and HSSE, to advise the Country
Coordination Team on what this translates into for your country.

Will there be global guidance on what constitutes a social setting or business commuting?
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 and
regulations when on Shell business. Note that the “no drugs and alcohol” rule is also covered in our Code
of Conduct.

Is it really “one strike out” or can the Businesses decide what the disciplinary outcome should be?
We do not, and you should NOT, use the terminology "one strike out" which doesn’t reflect our approach
accurately. For violations in high-risk operations the general principle is “if you choose not to follow the
Rules, you choose not to work for Shell”. It is up to HR and the Country Coordination Teams to determine
how that principle applies within the local legal context – we will always obey local laws. Hence we talk
about "maximum appropriate disciplinary action".

IMPLEMENTATION

I sometimes get pressured to “cut corners” for the sake of saving time and keeping to my targets. How
do I deal with this?
Please discuss this with your supervisor, or, if you do not feel comfortable doing that, report it to the next
level up or anonymously to the Shell Global Helpline. Time pressures or meeting planned targets are no
reason to break the Rules. Safety always comes first.

Can we add Rules at local or Business level?

The Life-Saving Rules themselves (wording or icons) cannot be changed. However, Businesses and sites
can and will have additional safety rules besides the Life-Saving Rules.

What will happen to existing country or Business rules?

All rules which duplicate the Life-Saving Rules (e.g. the Manufacturing Cardinal Rules) will be retired.
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, may be retained.

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Are the Life-Saving Rules relevant for the office environment?
Compliance with the Life-Saving Rules is mandatory for all Shell employees and contractors while
conducting Shell business. Of course, certain Rules will have more relevance in some setting than others.
Rules 9 to 12 are applicable for all Shell employees and contractors (whether office workers or not) when
traveling on Shell business.

Office workers may be exposed to industrial operations (Rules 1-9) 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. Moreover, if Shell 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.

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. You must inform your supervisor or the person in charge if you are taking medicine that may
have an effect on your performance.

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. You should always be responsible for your own safety at all times.

Do the Life Saving Rules apply when using a taxi for business and the taxi driver is either using a
mobile phone or exceeding the speed limits?
Life-Saving Rules apply to company-approved taxi services. Where possible, please use these services. In
countries where seat belts are not always available in the taxi, every effort should be made to pre-book a
car fitted with seat belts, especially if the driving conditions are high risk. Employees should raise and
discuss the risks and concerns with their line manager.

What about leased cars and company mobile phones?

Life-Saving Rules apply to all business activities. Social activities and those activities carried outside of the
business context and work are generally out of scope. However, local law will apply in such cases.

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.

Are the Life-Saving Rules relevant for Contractors – they often have their own set of rules.
While conducting business for Shell, compliance with the Life-Saving Rules is mandatory for all
contractors. Prior to doing work for Shell, a contractor must be verifiably briefed about the Rules.

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Do the Life-Saving Rules apply to all Joint Ventures?
The Life-Saving Rules apply to all Shell-controlled Joint Ventures (JVs) . For non-controlled JVs, we will
need to engage through the proper governance channels. Each Business VP will ensure that the relevant
Shell shareholder representatives tables the Life-Saving Rules with the relevant JV Management Board,
with the aim to try and influence and convince them of the importance of these Rules. Unless the JV
management decides to adopt them, the Life-Saving Rules will not apply in those JV sites.

How do you recommend I communicate to my staff about this?

Make sure that every one of your staff receives a briefing on the Life-Saving Rules, and document the
attendance at that briefing. In settings where Insight Browser is available, attendance at a briefing may be
recorded in Insight Browser. Where practical, this briefing should be done face-to-face. Repeat your
message regularly to ensure it stays fresh in the minds of your staff. Stay on message and use only
approved briefing and communications materials.

Can we get training for line managers on having “hard conversations”?

Holding “difficult” conversations and ensuring disciplinary action in case of non-compliance is not new for
the majority of line managers. Where line managers have a specific concern, they should approach their
own managers or local HR manager to obtain additional coaching and feedback on how to carry out
these conversations. They can also seek additional support from their own line managers or local HR if
they feel they have specific learning needs in this respect.

Who will be responsible to input the Life-Saving Rules into the new-employee or new transfers on-
boarding programme at site?
The local site (office, work site or work location) HSSE and the line manager must ensure that engagement
on the Life-Saving Rules is incorporated into the new employee onboarding programme at site.

Why are we launching this July 1, 2009?

This is to allow sufficient time to implement the Life-Saving Rules consistently across all Businesses and
work sites in each country. It will also ensure sufficient time for staff and contractor engagement.

The Rules may make staff more conservative. Are we ready for the impact on productivity?
There may be a temporary impact on productivity as staff and contractors learn about the Rules and how
they apply to their tasks. This can be a good thing as people become more conscious of the safety aspects
of their jobs. They also re-evaluate the risks and once they fully understand them, they are able to work
safely and efficiently to complete their tasks. Any initial drop in productivity must be balanced against a
sustained improvement in safety performance and behaviour. Our first priority is the safety of our people.

Does the implementation of Life-Saving Rules change the current HSSE Competence Framework?
No. The 12 Life-Saving Rules are basic safety rules that are already in place throughout Shell so their
implementation does not affect the HSSE Competences which we have in place. Staff should continue to
use this existing HSSE Competence Framework to assess and develop their own HSSE competences on the
job.

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PROCESSES

What is the process followed in the case of a non-compliance?

This will follow the current standard disciplinary process in each country, which will be applied consistently
to all Businesses and sites in that country. Consult your local HR adviser if you are unclear how the
disciplinary process works

What does “appropriate” consequence mean?

”Appropriate” is dependent on the outcomes of the investigation, risk level, and local legislative
framework. For violations in high-risk operations we operate on the general principle that “if you choose
to break the Rules, you choose not to work for Shell”. Country HR must be consulted to ensure that the
recommended disciplinary action is aligned with the current country disciplinary process, and is consistent
with similar recommendations within the country in other Businesses.

How do we ensure that the investigations are fairly carried out and not biased against the employee?
Investigations should take place as per the current investigation process. The process should ensure
fairness and transparency.

How do we go about recording the attendance of my staff and contractors who have attended the Life-
Saving Rules briefing/training?
In settings where Insight Browser is available, attendance at a briefing may be recorded in Insight
Browser. If Insight Browser is not available, each supervisor must keep an auditable log of a signed copy
of an attendance sheet of all employees who have attended the briefing session in order to show that all
employees have received an induction by June 30.

Contracting companies must verifiably brief their own staff. A signed copy of an attendance sheet must be
kept in the custody of local site (office, work site, or work location) management at the site to ensure that it
is available to demonstrate which staff have been briefed. Details of this process need to be decided by
the Country Coordination Team as part of the Country Implementation Plan.

If supervisors are not located at the same site as their staff (e.g. it is a virtual team), supervisors can either
brief their team virtually or ask that the virtual team members attend local site briefing conducted by
country teams, and obtain a record of attendance from the country teams after the event.

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