HEALTH, SAFETY, AND ENVIRONMENTAL (HSE) POLICY

1. Commitment
At Phoenix Metals, we are dedicated to conducting all operations in a way that prioritizes the health, safety, and well-being of our employees, contractors, and the wider community. We are equally committed to minimizing our environmental footprint and safeguarding the integrity of our assets, company property, and the property of third parties. Proactive and responsible HSE management is integral to our mission and key to our business success.

2. Compliance and Accountability
Phoenix Metals strictly adheres to all applicable laws, regulations, and agreements with governmental and business partners. Compliance is a fundamental condition of employment and is the shared responsibility of every individual within the organization. All employees and contractors are expected to align with our policies, practices, and the law to uphold the highest standards of HSE performance.

3. Objectives and Planning
To achieve our HSE goals, we maintain a robust HSE Management System. Each year, we set measurable, ambitious targets to drive continuous improvement in our HSE program.

4. Implementation and Responsibilities
We actively promote a culture of safety and environmental responsibility by:
Developing and maintaining clear HSE standards, procedures, and programs.
Conducting thorough risk assessments to ensure all activities are performed in a safe and environmentally sound manner.
Empowering employees and contractors to integrate HSE considerations into their daily tasks.
Mandating that no task proceeds without a clear understanding of its safety and environmental implications.

We also encourage all personnel to identify, report, and address substandard conditions or incidents. Investigations will be conducted to determine root causes, with findings shared across the organization to prevent recurrence. Emergency response plans will be regularly tested and supported by comprehensive training and drills.

5. Monitoring and Continuous Feedback
Regular inspections, audits, and performance evaluations ensure compliance with and effectiveness of our HSE Management System. 

6. Management Review
The HSE policy and management system undergo an annual review by senior management to ensure their relevance and effectiveness. Necessary adjustments are made to align with evolving standards, industry advancements, and organizational objectives.

7. Continuous Improvement and Leadership
Phoenix Metals is committed to continuous improvement in health, safety, environmental, and energy performance. By setting new individual and company-wide targets annually, we foster a culture of growth and innovation. 

Signed: 		Stijn van Zelst		Managing Director

Rotterdam, 1 January 2025