DUTY OF CARE DOCUMENTS

for ACE UK’s beverage carton

bring banks

1 BRING BANK COLLECTION DOCUMENTS

3 2 CARTON

PROCESSING DOCUMENTS

POLYAL DOCUMENTS

1.1 - ACE UK WASTE BROKER’S LICENCE

1.2 - PRINTWASTE RISK ASSESSMENT

1.3 - EXAMPLE WASTE TRANSFER NOTE

1.4 - PRINTWASTE WASTE CARRIER’S LICENCE

2.1 – PRINTWASTE ENVIRONMENTAL PERMIT

2.2 – RUSSELL RICHARDSON WML EXEMPTION

2.3 – RAJ WASTE CARRIER’S LICENCE

2.4 – SONOCO ALCORE WASTE CARRIER’S LICENCE

2.5 – SONOCO ALCORE ENVIRONMENTAL PERMIT

3.1 – DOWNTON WASTE CARRIER’S LICENCE

3.2 – DOWNTON WASTE MANAGEMENT EXEMPTION

3.3 – CONTROLS OF GREEN LIST WASTE

3.4 – GREEN LIST INSPECTION APPLICATION FORM

3.6 – EXAMPLE ANNEX VII FORM

3.7 – IMPORT LICENCE

3.8 – BUSINESS LICENCE

3.5 – OATLEY WASTE BROKER'S LICENCE

1 BRING BANK COLLECTION DOCUMENTS

1.1 – ACE UK WASTE BROKER’S LICENCE

ACE UK owns and operates the carton recycling bring bank scheme within your Local Authority area. We provide the bins, collection contractors, sorting, baling and reprocessing facilities. All carton material collected through this network of bring banks is sent to our carton recycling facility in Halifax, West Yorkshire for reprocessing.

1.2 – PRINTWASTE RISK ASSESSMENT

Printwaste is the contractor responsible for emptying the carton bring banks throughout most of England and Wales. Due to the specific collection method used the banks are emptied through a suction system rather than a lifting mechanism.

1.3 – PRINTWASTE EXAMPLE WASTE TRANSFER NOTE

This is given as an example only as you will have already received a Waste Transfer Note specific to your organisation. The Waste Transfer Notes are renewed annually.

1.4 – PRINTWASTE WASTE CARRIER’S LICENCE

Printwaste are contracted to collect the material from the bring banks in your area and therefore require an up to date Waste Carrier’s Licence.

1.1

Risk Assessment for the collection of beverage cartons and plastic bottles from bring banks

Task to be assessed: Bring bank collections Date assessed: 30/10/2014 Assessed by: Jeffrey Dean, Health and Safety Manager, Printwaste Recycling and Shredding

Associated risks Hazard

Who

will

be

affe

cted

Prob

abili

ty

Seve

rity

Envi

ronm

enta

l im

pact

Actions in place

Risk

sco

re

Further actions

Date

com

plet

ed

Objects fall ing from height

E 2 2 N/A Hard hat available for all drivers and operators. 4 None at present

Flying objects E 2 2 N/A Safety goggles available for all drivers and operators.

4 None at present

Moving vehicle coll isions

E 2 3 N/A Flashing beacons fitted to all vehicles, Drivers are instructed to make themselves known before entering the working area. Drivers and operators are instructed on safe working on public highways and customer premises.

6 None at present

Manual handling D 1 2 N/A Manual handling training is given to all Printwaste staff.

2 None at present

Cuts and Bruising D 2 1 N/A All drivers are made aware of the potential dangers within their training for RCV operations. P.P.E provided.

2 None at present

Slips Trips and Falls D 2 2 N/A Area to be checked for obstacles. Correct footwear to be worn. Ground conditions are to be inspected, monitored and made safe as far as is reasonably practicable.

4 None at present

Noise E 4 1 N/A Ear protection provided. Staff notified of noise level. Operation is under first action level.

4 Monitor noise levels regularly.

Crushing S 2 3 N/A Guards fitted to all moving parts with interlock switches, Trained personnel only authorised to operate. No persons are allowed to climb into the hopper or rear of the vehicle. Reversing cameras fitted to all vehicles.

6 None at present

Vehicle tipping over

E 2 2 Local All drivers are to ensure vehicle is level and stable before tipping.

4 None at present

Spil lage E 2 3 Local A full spillage procedure is in place. Staff are trained in the use of the spil l kits.

6

General Health and safety

E 2 2 N/A All Drivers are given a copy of the Health and Safety Policy and, in respect of Printwaste site management, a copy of the Site Rules.

4 None at pre sent

PW Commercial CO LTD T/A PRINTWASTE RECYCLING & SHREDDINGForm RA27 Vers ion 1 Registered in England and Wales No. 02994299

1.2

Legend for Associated risks table

Probability legend 1

Unlikely 2

Possible 3

Very Possible 4

Definitely

Severity Legend 1

Very Minor 1 2

Minor 3

Major 4

Fatal

Personnel affected E

Everybody S

Shop floor staff GP

General Public D

Driver

Additional information

• All drivers and operators will be given full on-site training before operating this vehicle. • No drivers will be allowed on site without Hi Visibil ity vest or jacket and safety boots. • Climbing into the back of tipping vehicles bodies is strictly forbidden.

Review date: 31st October 2015 Reviewer: Jeffrey Dean

PW Commercial CO LTD T/A PRINTWASTE RECYCLING & SHREDDINGForm RA27 Vers ion 1 Registered in England and Wales No. 02994299

Duty of Care Controlled Waste Transfer Note

Section A – Description of the waste

Please describe the type of waste below: (e.g. ‘composite packaging’ (EWC code 15-01-05)) Composite packaging (beverage cartons)

Please give the six figure European Waste Catalogue Code (EWC code) for the waste below: EWC code 1 5 0 1 0 5

Estimated quantity of waste: < 500 tonnes per annum

Section B – Waste producer

Name: SIC code: 84110 – General public administration activities Address: Postcode: Telephone: Email:

I confirm that I have fulfilled my duty to apply the waste hierarchy as required by regulation 12 of the Waste (England and Wales) Regulations 2011 – Print name: Signed:

Section C – Person or company collecting the waste

Name: Don Robins Address: Printwaste Recycling & Shredding, Commerce House, Tewkesbury Road, Cheltenham Postcode: GL51 9AN Telephone: 01242 588600 Email: sales@printwaste.co.uk

Name/signature of authorised signatory : Name: Don Robins Signature:

Registered Waste Carrier’s Licence number: CB/HP3413YL

Section D – Destination of waste (potential places of transfer)

Address 1: Printwaste Recycling & Shredding, Unit 5&6, The Aerodrome, Stoke Orchard, Cheltenham, GL52 7RS Transfer date: 1st November 2014 – 31st October 2015

or Address 2: Russell Richardson and Sons Limited, Clay Street, Sheffield, S9 2PE Transfer date: 1st November 2014 – 31st October 2015

Broker who arranged transfer (if applicable): Name: Broker’s Licence Number: ACE UK CB/YE5155VQ

Address: ACE UK, Suite G2, The Hub, 5 Royal Court, Gadbrook Park, Northwich, Cheshire, CW9 7UT

PW Commercial CO LTD T/A PRINTWASTE RECYCLING & SHREDDING Registered in England and Wales No. 02994299

1.3

1.4

2 CARTON PROCESSING DOCUMENTS

2.1 – PRINTWASTE ENVIRONMENTAL PERMIT

Printwaste take the majority of the cartons collected through bring banks to their baling station in Cheltenham. Here they are sorted (if there is contamination that could not be sorted at the point of collection) and/or baled ready to be transported to the carton recycling facility in Halifax, West Yorkshire.

2.2 – RUSSELL RICHARDSON WASTE MANAGEMENT LICENCE EXEMPTION

Russell Richardson has a baling hub in Sheffield which Printwaste uses to unload cartons at when they are operating in the North of England (this is dependent on the weekly round sheets).

2.3 – RAJ WASTE CARRIER’S LICENCE

RAJ collects the 25 tonne loads from the two baling hubs and brings them to the carton recycling facility.

2.4 – SONOCO ALCORE WASTE CARRIER’S LICENCE

Occasionally Sonoco Alcore will collect a load from one of the two hubs and bring the 25 tonne load back to their mill where the carton recycling facility is.

2.5 – SONOCO ALCORE ENVIRONMENTAL PERMIT

Although ACE UK owns the carton recycling facility it is housed at Sonoco Alcore’s coreboard mill in Halifax, West Yorkshire and operated by them.

2.1

2135_EPS_PermRendered_E

Schedule of exempt waste operations

Relevant objectives

The following schedule lists the exemption(s) that you have registered.

However you should be aware that this/these registration(s) is/are only validwhere you:

- comply with the conditions of the exemption(s) that you have registered(these conditions can be seen at http://www.environment-agency.gov.uk/exemptions) and,

- carry out the activity without endangering human health or harming theenvironment and, in particular:(a) without risk to water, air, soil, plants or animals;(b) without causing a nuisance through noise or odours; and(c) without adversely affecting the countryside or places of special interest.

If you fail to comply with the conditions of the exemptions, endanger humanhealth or the environment your registration and this schedule has no standingin law and you may face enforcement action.

Details of exempt waste operations

Name ofEstablishment orUndertaking:

RUSSELL RICHARDSON & SONS LTD

Trading name (if any): Russell Richardson & Sons Ltd

Address: WarehouseClay Street,Sheffield,South Yorkshire,England,S9 2PE

2.2

2135_EPS_PermRendered_E

Exemption Ref No: UH0213AW

Address where theoperation can becarried out:

WarehouseClay Street,Sheffield,South Yorkshire,England,S9 2PE

NGR: SK3802989065

Paragraph Number & Description:

2 Operations

2.1 Permitted activities

2.1.1 T4 - Preparatory treatments (baling, sorting,shredding etc) (Non-agricultural Waste only)

2.1.2 S2 - Storage of Waste in a Secure Place (Non-agricultural Waste only)

Date of issue: 13/12/2012

Please note: If at any time you stop carrying out any of these exempt wasteoperation (s) and you wish to de-register you can inform us of this by enteringthe paragraph number of the exemption you wish to de-register in the spacebelow and returning a signed copy of this schedule to us. When we receivethe schedule we will de-register the exemption, remove it from the publicregister and provide you with confirmation that your exemption has been de-registered.

Alternatively you can send a letter, signed by the exemption holder, detailingthe reference number of the exemption you wish to de-register, the paragraphnumber and the location. Please post your letter or copy schedule to theaddress provided below:-

2135_EPS_PermRendered_E

Environment AgencyNational Customer Contact Centre99 Parkway AvenueParkway Business ParkSheffieldS9 4WF

I wish to de-register the exemptions below

Signature (of exemption holder)

2.3

2.4

2.5

3.1 – DOWNTON WASTE CARRIER’S LICENCE

The baled polyAl is/has been transported by Downton to their depot in Runcorn.

3.2 – DOWNTON WASTE MANAGEMENT LICENCE

3.3 – CONTROLS OF GREEN LIST WASTE

3.4 – GREEN LIST INSPECTION APPLICATION FORM

Processing polyAl

The carton recycling facility in Halifax separates the fibre from the polyAl (polymer and aluminium laminate which makes up two of the three materials used to manufacture cartons).

We are currently deciding which UK based technology we want to use to recycle our polyAl in the long-term and a solution will be developed in 2015. Until now (November 2014) we have stored the polyAl in the hope that an existing UK processor could provide an interim recycling solution. After much work no existing viable UK recycling option for the polyAl has been identified.

We are approaching the deadline that we can legally store waste (12 months) and so we have had to secure an overseas recycling option for the polyAl. It is our preference to send the polyAl to a high quality recycler overseas in the short-term ather than dispose of it (landfill or EfW).

POLYAL PROCESSING3

PolyAl is a Green LIst waste and is being exported under code B3010 - Polyethylene to China. It has to be exported with an Annex VII form and adhere to local import controls. The polyAl has been inspected and is deemed suitable to be exported to Xiamen in China to be reprocessed by a company called Xiamen LH Environment Protection Industry Development Co, Ltd (www.lh-ep.com).

3.5 – OATELY RESOURCES LTD WASTE BROKER'S LICENCE

3.6 – EXAMPLE ANNEX VII FORM

Oatley Resources Ltd is the broker responsible for exporting teh polyAl from Runcorn to Xiamen LH.

3.7 – IMPORT LICENCE

3.8 – BUSINESS LICENCE

Xiamen LH Environment Protection Industry Development Co. Ltd. will delaminate the polyethylene for the aluminium and recycle both elements.

THE WASTE (ENGLAND AND WALES) REGULATIONS aOLLt

The EnviionmentAgency certify that the following information is entered ln the registerwhich they maintain under regulation 28 of the Waste (England and Wales) Regulations

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3.1

2135_EPS_PermRendered_E

Schedule of exempt waste operations

Relevant objectives

The following schedule lists the exemption(s) that you have registered.

However you should be aware that this/these registration(s) is/are only validwhere you:

- comply with the conditions of the exemption(s) that you have registered(these conditions can be seen at http://www.environment-agency.gov.uk/exemptions) and,

- carry out the activity without endangering human health or harming theenvironment and, in particular:(a) without risk to water, air, soil, plants or animals;(b) without causing a nuisance through noise or odours; and(c) without adversely affecting the countryside or places of specialinterest.

If you fail to comply with the conditions of the exemptions, endanger humanhealth or the environment your registration and this schedule has no standingin law and you may face enforcement action.

Details of exempt waste operations

Name ofEstablishment orUndertaking:

C M Downton (Haulage Contractors) Ltd.

Trading name (if any):

Address: Brook Farm,Moreton Valence,GLOUCESTER,GL2 7ND

3.2

2135_EPS_PermRendered_E

Exemption Ref No: AE5343SR

Address where theoperation can becarried out:

Unit 2 Premier PointAston Lane South,Preston Brook,Runcorn,England,WA7 3BE

NGR: SJ5607079934

Paragraph Number & Description:

2 Operations

2.1 Permitted activities

2.1.1 S2 - Storage of Waste in a Secure Place (Non-agricultural Waste only)

Date of issue: 30/05/2014

Please note: If at any time you stop carrying out any of these exempt wasteoperation (s) and you wish to de-register you can inform us of this by enteringthe paragraph number of the exemption you wish to de-register in the spacebelow and returning a signed copy of this schedule to us. When we receivethe schedule we will de-register the exemption, remove it from the publicregister and provide you with confirmation that your exemption has been de-registered.

Alternatively you can send a letter, signed by the exemption holder, detailingthe reference number of the exemption you wish to de-register, the paragraphnumber and the location. Please post your letter or copy schedule to theaddress provided below:-

Environment Agency

2135_EPS_PermRendered_E

National Customer Contact Centre99 Parkway AvenueParkway Business ParkSheffieldS9 4WF

I wish to de-register the exemptions below

Signature (of exemption holder)

Version 12b (March 2011)

Controls on Exports of Green List Waste to non-OECD Countries – an Update.

The current regulation (1418/2007/EC) providing control measures for the export of green list waste came into force on 29 November 2007. This regulation was amended in July 2008 by the regulation EC 740/2008, in October 2009 by EC 967/2009 and in September 2010 by EC 837/2010 .

Responses have been received for Algeria, Andorra3, Argentina, Bangladesh, Belarus, Botswana, Bosnia and Herzegovina1, Brazil, Chile, China3, Chinese Taipei, Costa Rica, Croatia3, Cuba, Egypt, Georgia, Guyana, Hong Kong2, India3, Indonesia2, Iran1, Israel, Ivory Coast (Cote d’Ivoire)1, Kenya, Kyrgyzstan, LebanoLiberia

n,

and Vietnam.

3 Macau, Malawi, Mali, Malaysia1, Moldova1, Montenegro2, Morocco, Nepal2, Oman, Pakistan, Paraguay, Peru, Philippines, Russian Federation1, Serbia2, Seychelles, Singapore2, South Africa, Sri Lanka, Thailand, Togo1, Tunisia, Ukraine1,2

To assist exporters of green list waste, we have produced a summary table setting out the controls required for the export of key waste streams to the main export destinations. The table also highlights changes in the type of control specified. Where a response has not been received from a country of destination notification controls will apply. Information on the requirements of other countries of destination or for other waste streams can be obtained from the International Waste Shipments team (Tel: 01925 542265).

Key:

P Prohibited

N Written notification and consent

G Green list controls using the Annex VII form

L Green list controls using the Annex VII form & local import controls must be observed. Changes in amendment EC 740/2008

Changes in amendment EC 967/2009

Changes in amendment EC 837/2010

1 Changes in amendment EC 740/2008

2 Changes in amendment EC 967/2009

3 Changes in amendment EC 837/2010

3.3

Version 12b (March 2011)

Waste code

Waste type Bangladesh Brazil China Chinese Taipei

Egypt Ghana Hong Kong

Iran

Response Yes Yes Yes Yes Yes No Yes Yes Iron & steel L N L L L N L N Aluminium L G L L L N L N

B1010

Copper P G L L L N L N GC010 Electrical

assemblies P N L P P N L P

GC020 Electronic scrap P N P/L2 P P N L P B1050 Non-ferrous P N & L L N N N L N B1090 Batteries P P P N P N P N B1115 Cable P P L N P N L P B2020 Glass P G P N P N L P

PET P G L L P N G N Polyethylene L G L L P N G N PVC (GH013) P G L L P N L P Polyurethane P G L N P N G N

B3010

Polypropylene P G L L P N G N B3020 Paper L3 G L L P4/N N L P B3030 Textiles P P5/NL P/L6 N N N L P7/N B3050 Wood P G L L N N L N B3140 Tyres P P P N N N L N

2 Waste wire and motor scrap only 3 Unbleached paper or paperboard, or corrugated paper, other paper and paperboard made mainly of bleached chemical pulp only 4 Unsorted paper scrap only 5 Worn clothing and other worn textile articles 6 Wool waste, cotton waste, synthetic and artificial fibres 7 Cork waste: crushed, granulated or ground cork.

3.4

3.5

ANNEX VIIINFORMATION ACCOMPANYING SHIPMENTS OF WASTE

AS REFERRED TO IN ARTICLE 3(2) AND (4)Consignment information (1)

1. Person who arranges the shipmentName: Oatley Resources LtdBroker Registration: CB/AE5390ZBTrading Address: 14 Dunscar Fold, Egerton, BoltonBL7 9EHContact Person: Paul BarnesTel.: +44 7971 942638 Fax:E-mail: paul.barnes@oatleyresources.co.uk

2. Importer/consigneeName: Xiamen LH Environment Protection IndustryDevelopment Co Ltd16 3rd Road XinfengTorch Hi Tech Industrial Development ZoneXiamen ChinaContact Person: c/o Michel BurnerTel: +33 1.71.29.12.62 Fax: +33 1.71.29.10.99

3. Actual quantity: Tonnes (Mg): m3: 4. Actual date of shipment: 15 November 2014

5.(a) First carrier (2)Name: Maerskc/o Kerry LogisticsAddress: 210-222 Hagley RoadWest, Oldbury, West Midlands,B68 0NPContact Person: Sarah ReadingTel.: +44 121 420 6970Fax: +44 121 429 6999E-mail:sarah.reading@kerrylogistics.comMeans of transport: R/SDate of transfer:Signature:

5.(b) Second carrierName:

Address:

Contact person:Tel.:Fax:E-mail:Means of transport:Date of transfer:Signature:

5.(c) Third carrierName:

Address:

Contact person:Tel.:Fax:E-mail:Means of transport:Date of transfer:Signature:

6. Waste generator (3)Original producer(s), new producer(s) or collector:Name: Alliance for Beverage Cartons and theEnvironment LtdAddress: Suite G2, The Hub, 5 Royal Court, GadbrookPark, Northwich, CW9 7UTContact person: Fay DashperTel.: 01606 530320 Fax:E-mail: fay.dashper@ace-uk.co.uk

8. Recovery operation (or if appropriate disposaloperation in the case of waste referred to in Article 3(4)):R-code/D-code: R3

9. Usual description of the waste:Plastic Scrap Poly-Al material from beverage cartonprocessing

7. Recovery facility LaboratoryName: Xiamen LH Env Prot Ind Devpt Co LtdAddress: No 16 3rd Road Xinfeng, Torch Hi TechIndustrial Development Zone, Xiamen, CHinaContact person: See Section 2 for detailsTel.: +86 592 651 8559 Fax:E-mail:

10. Waste identification (fill in relevant codes):(i) Basel Annex IX: B3010 (as per Nigel Homer EA)(ii) OECD (if different from (i)):(iii) EC list of wastes: 200139(iv) National code:

11. Countries/states concerned:Export/dispatch Transit Import/destination

Felixstowe (GB) Xiamen (CN)12. Declaration of the person who arranges the shipment: I certify that the above information is completeand correct to my best knowledge. I also certify that effective written contractual obligations have been enteredinto with the consignee (not required in the case of waste referred to in Article 3(4)):

Name: Paul Barnes Date: 07 November 2014 Signature:13. Signature upon receipt of the waste by the consignee:Name: Date: Signature:TO BE COMPLETED BY THE RECOVERY FACILITY OR BY THE LABORATORY:14. Shipment received at recovery facility or laboratory Quantity received: Tonnes(Mg): m³:Name: Date: Signature:

(1) Information accompanying shipments of green listed waste and destined for recovery or waste destinedfor laboratory analysis pursuant to Regulation (EC) No 1013/2006. For completing this document, seealso the corresponding specific instructions as contained in Annex IC of Regulation (EC) No1013/2006.(2) If more than three carriers, attach information as required in blocks 5 (a), (b), (c).(3) When the person who arranges the shipment is not the producer or collector, information about theproducer or collector shall be provided.

Reference No: 1451-Container No Seal No No of bales

3.6

3.7

3.8

Business License

Registration Number: 350205200010369

Name of Enterprise: Xiamen LH Environment Protection Industry Development Co., Ltd

Character of Business: Legal Person Business Subject <Limited Liability Corporation（invested or held by

natural person）>

Address: No.16 of the third Road of Xinfeng, Torch Hi-tech Industrial Development Zone, Xiamen

Legal Representative: Wang Hua

Registered Capital: 37,500,000 RMB

Foundation Date: December 18, 2000

Business Term: From December 18, 2000 to December 17, 2027

Scope of Operation:

For the business subject’s scope of operation, business premise, investor information, annual report, and supervision information, please visit Xiamen Business Subject Registration and Credit Information Notification Platform (website: http://www.xiamencredit.gov.cn/). Items to be operated in the scope of operation that involves licensing shall obtain permission from relative departments before being operated.

Registered with:

June 16, 2014

3.8