Driving is the greatest risk faced by our employees. To minimize this risk and ensure that APETCO standards for driving qualification and practices are followed, this driving policy applies to all APETCO controlled organizations. It provides the foundation for building a driver improvement program that will lead to Best Practices in driving safety.

The following shall be implemented in all APETCO controlled locations. In addition, a corporate Journey Management and Driving Safety Standard and local Journey Management Plans shall document details of specific requirements.

Driver Training and Qualification

Only approved personnel and contractors are allowed to drive vehicles on behalf of APETCO, including company – owned or leased vehicles, vehicles rented for business purposes and when claiming kilometer/mileage allowance. Approval is guaranteed to drivers who have taken defensive driving training every three years and commentary driver training annually. These training programs must be documented.

Seat Belts

All Company -owned or leased vehicles shall be equipped with seat belts for all occupants. As a condition of Employment, all employees and consultants must wear seat belts properly at all times when driving a company vehicle or driving any vehicle on company business or on Company property, and they must ensure that all occupants wear their seat belts properly.

Journey Management

All locations shall have in place an active journey management program that complies with the applicable standard. Each location’s journey management program shall address all local driving conditions and identified risks.

Substance Abuse

Driving a vehicle while under the influence of alcohol or any drugs or narcotics is strictly prohibited and subject to disciplinary action including termination as stated in APETCO Alcohol and Drugs Policy.

In-Vehicle Monitoring Systems and Program

An approved driver improvement monitor shall be installed in all vehicles designed for road use that are owned or leased by APETCO. All locations shall have in place a program for reviewing driver monitor data monthly and using this data to continually improve driver skills. Management shall be actively involved in the implementation and maintenance of this program.

Driver Improvement Monitors

An approved driver improvement monitor shall be installed in all vehicles designed for road use that are owned, leased or subcontracted by APETCO. All locations shall adopt a program for regularly reviewing the data gathered by the monitors and using that data to continually improve driver skills. Management must be actively involved in the implementation of this program.

Electronic Communication Devices (ECDs) Including Mobile Phones

Personnel operating company vehicles, or personal vehicles on company business or operating any vehicle on company property, shall not use ECDs while driving, even if the device or vehicle is equipped with a hands-free system. Devices can be left on during a trip to alert the driver of any incoming calls, voicemails, emails or text messages. The driver must safely leave the road and bring the vehicle to a complete and safe stop before initiating or answering a call, or responding to a voicemail, email or text message. Only in emergency situations are personnel authorized to use ECDs while driving. Only to communicate briefly with emergency personnel or someone with the ability to immediately mitigate a risk

Contractors

The requirements for Driver Training and Qualification and Seat Belt use shall be applied to all contractors that transport APETCO employees or consultants, excluding spot hire personnel transport such as public taxis. These requirements also apply, whenever practicable, to all contactors that transport APETCO Dangerous Goods. The application of other requirements in this policy to transport contractors shall be defined in local Journey Management Plans.

Disciplinary Action

Any violations of this Policy may subject the employee to disciplinary action.

Mamdouh Mahdouz

Chairman, APETCO