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Page 1: LNG services Norconsult

LNG services

Norconsult

Assignment no.: Document no.: Version:

Page 2: LNG services Norconsult

Assignment no.: Document no.: Version: 01

Swedegas Tender

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Client:

Client’s Contact Person:

Consultant: Norconsult AS, Vestfjordgaten 4, NO-1338 Sandvika

Assignment Manager:

Technical Advisor:

Other Key Personnel:

01 20150106 Issued for IDC hhe tb sce

Version Date Description Prepared by Checked by Approved by

This document has been prepared by Norconsult AS as a part of the assignment identified in the document. Intellectual property

rights to this document belongs to Norconsult AS. This document may only be used for the purpose stated in the contract

between Norconsult AS and the client, and may not be copied or made available by other means or to a greater extent than the

intended purpose requires.

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Contents

Introduction 4

Norconsult LNG competence 5

LNG process overview 5

LNG terminals 7

Flat bottom tanks, atmospheric tanks 8

Pressurized tanks 9

Multi discipline engineering 10

Risk Management, HSE and technical safety 12

Floating LNG 13

Project execution 15

Norconsult AS general information 17

General 17

Location 17

Management system 17

Quality policy 20

Health, Safety and environmental internal control 21

Health, Safety and protection of the environment 22

Health, Safety and environmental internal control policy 23

Code of ethics 24

List figures: Figure 1, Main process block diagram, pre-treatment, liquefaction, storage and import/export ............................... 5

Figure 2, Typical LNG loading block diagram .......................................................................................................... 7

Figure 3, Typical LNG off-loading and export, truck and vessel .............................................................................. 8

Figure 4, Norconsult double compartment LNG storage tank, 30 000 m3 tall design ............................................... 9

Figure 5, Norconsult double compartment LNG storage tank, 30 000 m3 low design .............................................. 9

Figure 6, Pressurised LNG bullet tanks with vapour system ................................................................................... 9

Figure 7, Pressurised LNG bullet tanks with vapour system ................................................................................. 10

Figure 8, Small scale LNG terminal with import/export facilities ............................................................................ 10

Figure 9, Static and dynamic process simulations. Graphs shows boil of gas at tank filling .................................. 12

Figure 10, LNG liquefaction plant with 30 000m3 storage tank with LNG export facilities by truck and vessel ..... 13

Figure 11, FLNG unit with export facilities of LNG, LPG and condensate ............................................................. 14

Figure 12, Typical process block diagram FLNG with export facilities ................................................................... 14

Figure 13, Norconsult general LNG/gas engineering services .............................................................................. 15

Figure 14, Typical work package/contract breakdown of LNG terminal ................................................................. 16

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Introduction

Norconsult has during the last 20 years executed a large number of LNG projects including

liquefaction, storage, export terminals and regasification. Norconsult has been working in all execution

phases of projects from early phase studies to construction follow up and plant handover to Client.

All experiences gained during the project execution phases and in depth knowledge of different

liquefaction technologies are carefully processed and added into Norconsult LNG project experience

database.

Norconsult provides multi discipline services within the following fields of engineering and project

follow up:

LNG Regasification terminals

Ship loading/ unloading

Boil-off compression

Vapour handling

LNG vaporisation

LNG storage and export

LNG liquefaction plants

Gas metering

Condensate removal

Mercury removal

Acid gas removal

Dehydration

Liquefaction

Refrigeration

LNG storage and loading

Site layout and utilities

LNG export terminals

Primary and secondary pumping

LNG storage and export

Ship loading and jetty

LNG peak shaving plants

Gas metering

Acid gas removal

Dehydration

Liquefaction

Storage and export?

Boil off and gas recovery

Gas vaporisation

Truck loading and unloading

Fire protection

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Norconsult LNG competence

LNG process overview

Production of Liquefied Natural Gas (LNG) requires the application of a broad range of technologies

and design expertise. The block flow diagram identifies the main processes and utility facilities that are

required to produce LNG. The diagram also include LNG storage and necessary terminal facility for

LNG import and export.

Figure 1, Main process block diagram, pre-treatment, liquefaction, storage and import/export

Feed gas to the plant can be taken from a gathering system or gas pipeline. This gas may contain

liquid hydrocarbons, which will be removed in the inlet reception/separator systems. It is necessary

also to remove CO2, H2S, water and mercury if the feed gas contain such elements as this will cause

damage to downstream process equipment.

The clean and dry gas is sent to the liquefaction process where the LNG is produced. The liquefaction

system is the heart of the processing plant. Norconsult has developed advanced process simulation

tools to make the client able to select the optimum liquefaction process and technology based on the

plant limitations and volume flow.

The LNG from liquefaction process is stored in large tanks at near atmospheric pressure, or in

pressurized bullet tanks if found optimum based on Client’s needs. Vapour from the storage and LNG

boil off is used for plant fuel or for export to other consumers of gas, alternatively fed back into the

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liquefaction system. Norconsult has extensive experience with the LNG storage and export systems

for both the liquefaction plants and in LNG terminals

In addition to the main process units, the liquefaction facility requires many key utility systems. These

systems must be properly integrated into the overall process scheme for the project to be successful.

Norconsult has extensive experience in design and construction of gas processing facilities, which

include all of the necessary utility and product handling systems.

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LNG terminals

LNG terminals involve the application of cryogenic engineering expertise including high cost

components. In addition to our terminal experience many of the liquefaction plants involve the storage

and export of LNG product including LNG vaporization and gas supply to local gas grid and industry.

A typical terminal set-up is presented in the figure below. The LNG is unloaded from LNG tankers at a

high rate, typically 1,000 – 12,000 m3/hr. This allows unloading to occur in about 12 hours. The LNG

is sent directly to storage, usually involving multiple pressurised tanks or to a larger flat bottom

atmospheric pressure tank. During unloading process, a large quantity of vapour is generated. Vapour

is returned to the tanker for replacement of LNG, and the surplus vapour is compressed in the boil-off

system for use as fuel or re-liquefied and returned as a LNG product in the tanks.

At gas export facilities the LNG is pumped to export pressure by submerged motor LNG pumps. The

LNG will be vaporized back to natural gas at the export pressure. The vaporization system can be

based on several different technologies conditioned the necessary capacity and environmental

conditions. The vaporisation process can be based on systems with fired equipment, seawater or air

vaporizers as well as intermediate fluid (propane) systems.

Figure 2, Typical LNG loading block diagram

Norconsult has experience from several terminals projects including import and export facilities. The

LNG terminals involve the same know-how in cryogenic systems that applies to liquefaction units. Our

experience in terminal designs covers all major systems and a variety of types of equipment, which

may be employed.

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Figure 3, Typical LNG off-loading and export, truck and vessel

Flat bottom tanks, atmospheric tanks

Norconsult has since 2009 been involved in the development of downstream LNG distribution hub’s

and terminals. The larger terminals has normally a storage unit based on a flat bottom atmospheric

LNG tank in the range of 10 000 m3 to 50 000 m3.

Norconsult has gained valuable experience in design of atmospheric full containment LNG storage

tanks with a cryogenic nickel steel inner tank and concrete outer tank with insulation in between. The

design is competitive both regarding cost and construction period, and will fulfil the standards EN 1473

and EN 14620. The design life specified is 50 years.

The LNG tank design meets the requirements given by the authority with respect to construction

standards, environmental actions also including earthquake and is designed to withstand fire and

impact from flying objects.

LNG tanks based on the full containment principals are favourable regarding risk and safety. The

safety distance reduces significantly compared to other types. The LNG plant covers less area as well

as the neighbour areas are less influence regarding restriction related to future use.

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Figure 4, Norconsult double compartment LNG storage tank, 30 000 m3 tall design

From a design point of view it is important that the tank is not evaluated as a separate item, but part of

a complete system. All individual equipment and components are part of an integrated complete

system with internal dependencies.

Norconsult has it’s own design of such tanks approved by third party like DNV-GL and DEKRA.

Norconsult services cover all phases of a project cycle from the earliest pre-investment evaluations

and feasibility studies, through planning and design, tendering and construction supervision, to project

implementation, operations and maintenance. Our company can provide the Client with multidiscipline

engineering resources that are required to deal with all aspects for development of new LNG

loading/unloading terminals including storage tank solutions.

In addition to services within tank design and engineering, Norconsult can offer engineering of

pipelines, jetties, civil process design, procurement, HSE, emergency preparedness, safety and

automation systems, instrument and telecommunication, authority handling, construction management

and owner’s engineer.

Figure 5, Norconsult double compartment LNG storage tank, 30 000 m3 low design

Pressurized tanks

Satellite terminals based on Pressurized LNG tanks

Figure 6, Pressurised LNG bullet tanks with vapour system

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For the downstream distribution, Norconsult has been involved in a number of terminals ranging from

80 m3 to 6 500 m3 storage capacity of LNG. The terminals are designed according to the standard EN

14645, and based on pressurized vacuum insulated tanks. The most of the pressurised tank terminals

have regasification based on ambient air heat exchangers. In addition to regasification, the terminals

very often have export facilities through truck loading facilities and bunkering facilities for vessels.

Norconsult has executed project management and technical management as owners engineer for a

number of these projects. This also includes the authority permitting process.

Figure 7, Pressurised LNG bullet tanks with vapour system

Multi discipline engineering

Norconsult provides full range of multi discipline engineering resources within the field gas processes

and matters related to LNG. We are using state of the art process simulation tools in order to design

and verify the process design. We are further using full-computerised 3D layout systems, allowing us

to optimise the plant layout with respect to equipment location, pipe and cable routing. Norconsult has

high focus on health, safety and environmental aspects of the plant design together with good

solutions within technical safety. This is crucial for documenting and getting all the necessary

approvals from national authorities before final investment decision is made and for final start-up

approval.

Early phase services

● Evaluation of LNG as energy source

● Investment analysis

● Concept evaluations and development

● Plant or terminal capacity assessments

● Process simulations of plant/terminal

● Site evaluation

● Hazard and risk identification

● Initial environmental assessment

● Requirements and GAP analysis

● Development of policies, goals and

acceptance criteria for HSE and quality

performance

● Advisory services related to hazardous materials, major accidents and emergency

preparedness

Figure 8, Small scale LNG terminal with import/export facilities

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● Technology qualification studies based on international recognised standards

Detail design

● Philosophies for design, operation & maintenance

● Design documents for all disciplines

● System descriptions, process and main utility systems

● Process simulation static and dynamic

● Sizing of process equipment and piping

● Fabrication drawings

● Civil

● Instrumentation and automation

● Electro

● Layout and safety

● Infrastructure and interface management

● Assistance in application processes HSE authorities

● Development and implementation of management systems (HSE, quality)

Construction Services

● Supplier and fabrication follow-up

● Construction management

● Site supervision

● HSE management and follow-up

● Mechanical Completion

● Commissioning

● Final documentation

Design in Europe is based on the following international norms and standards

● EN 1473 - Installation and Equipment for liquefied natural gas Design onshore installations

● EN 13645 - Installation and equipment for LNG , Design of onshore installations with storage

capacity between 5 t and 200 t

● EN 13458 - Cryogenic vessels

● NS-EN ISO28460_2010 Installation and equipment for liquefied natural gas -- Ship-to-shore

interface and port operations

● ATEX directive -on equipment and protective systems intended for use in potentially explosive

atmospheres (ATEX)

● Seveso III directive - control of major-accident hazards involving dangerous substances

● National laws and other regulations (B&E, NFPA, CSA, LNGA2010-MSB)

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Figure 9, Static and dynamic process simulations. Graphs shows boil of gas at tank filling

Risk Management, HSE and technical safety

Designing safe and reliable technical solutions for our clients has been Norconsult’s highest priority

goal. As the society we live in is in constant change and is growing ever more complex, global and

open. As a result, society’s vulnerability is also increasing. This means that risk assessments,

preventive measures and emergency response are becoming increasingly important elements for all

players – from public authorities to private businesses.

Norconsult has been involved for a long time in work to create a safe and well-functioning society.

With respect to LNG these aspects is crucial as consequence of LNG spill or gas leak could be

damaging and have large consequences for the workers on the plant, the plant itself and it’s

surroundings. If not properly designed fire or large gas leaks could occur.

Norconsult provide consultancy and engineering services/advices within:

Risk Management

● Working environment assessments

● Emergency preparedness

● HSE management systems

● Quality Management Systems

● Risk Management, including risk quantitative and qualitative risk analysis

● Technical safety

● Monitoring

HSE and Risk Management in development phases

Process simulations

25

● Aspen One Engineering

Includes

• Process modeling analysis and design tools integrated in Hysys

• Optimization of process designs

• Equipment sizing for layout and weight estimates

• Flare System Analyzer, including PSVsizing

• Depressurisation modelling

• Dynamic simulation for support of design and operational challenges

• Natural gas acid gas cleaning templates for rigorous design

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● Development of policies, goals and acceptance criteria for HSE and quality performance.

● Hazard identification and risk assessments.

● Risk Analysis

● Development and implementation of management systems (HSE, quality).

● Design reviews and layout reviews

● Assistance in application processes towards HSE authorities.

● HSE management and follow-up in projects.

HSE in Construction and Commissioning

● HSE management and follow-up in construction projects.

● Hazard identification and risk assessments at site

● Risk Analysis

● Inspections and audits

● Accident/incident investigation.

● Advisory services related to hazardous materials, major accidents and emergency

preparedness.

Figure 10, LNG liquefaction plant with 30 000m3 storage tank with LNG export facilities by truck and vessel

Floating LNG

Norconsult has during the last 8 years participated in 4 large floating LNG (FLNG) projects including

floating gas pre-treatment, LNG liquefaction, offshore storage of condensate, LPG and LNG, and

offshore terminals for export and import of the same products.

The applicable codes and standards for floating terminals/plants are different for the land based

facilities. The marine codes and standards must be adhered to. There is also different certifying bodies

involved in the third party evaluation of the design and construction. Typical certifying body is DNV-

GL, Lloyds and American Bureau of Shipping (ABS).

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Figure 11, FLNG unit with export facilities of LNG, LPG and condensate

During these projects, Norconsult gained valuable experiences reflecting the special considerations

necessary for the design and equipment selection when the foundations is moving in 3 directions with

variable frequency and magnitude. The design included further the complicated operation analysis of

such installation, as it shall be able to operate as a ship, as a production unit and as an export

terminal. All different modes of operation should be certified against different codes and standards.

The Norconsult contract was an Owners Engineer (OE) contract where Norconsult had the technical

coordination responsibility within the Clients organisation versus different engineering contractors of

hull, topside processes and technology owner of different technologies.

Figure 12, Typical process block diagram FLNG with export facilities

Inlet GasFacilities

DehydrationGas

TreatingLPG

Extraction

SolventRegen

Regen

GasReception/Compression

Liquefaction

LNG

Off-loading

Utilities

LNGStorage

CO2,H2S

H2O

LPG/C5+Storage

C3/C4's Condensate

Dry Gas

LPG/Cond.Off-loading

To Ships

To Ships

Feed Gas Pre-

Treatment

LNG Liquefaction

Utilities

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Project execution

Norconsult is an independent, multi-discipline engineering company giving services to all types of

engineering projects in all phases of a project life. This experience has given Norconsult an unique

position and experience for project execution follow up as partner to our Clients team. We have

experience in playing a separate or defined role in the follow up team during the construction period

and we have good experience in participating as partner in integrated follow up team headed by the

Client (Owner).

As Norconsult has no economical or financial interests in any other companies, we will act as 100%

independent consultant to our Clients, always recommending the optimum solution for the task/project

under the governing conditions.

Norconsult service will concentrate at optimum engineering solutions in the early phases and prepare

all necessary documentation to utilise the market competition to achieve the best price for

construction, mechanical completion, start-up and handover of the facilities. After having placed the

turnkey contract or placed several specialised contracts the Norconsult service will change character,

join the Clients team for contractor follow team, and establish a project task force.

Our services can be summarised in the below slide:

Figure 13, Norconsult general LNG/gas engineering services

In order to control the project with respect to contract strategy, work break down packages and time

line it is important to have a well proven management system. Some LNG projects have experience

significant budget overrun and project delay in start up. Norconsult is therefore focusing on the

importance of a maturing the project in the early phases and that the concept is matured before final

investment decision is made. Below is a schematic presentation of a high level contractual strategy

and project budget cost spread over time:

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Figure 14, Typical work package/contract breakdown of LNG terminal

C Customer Terminals

Project interated team

Amount

Site preparations

Amount

LNG Storage tank (bullet type)

Amount

LNG Tank process systems

Amount

Gasification plant

Amount

Import and export piping

Amount

Vessel loading/unloading facilities

(If applicable) Amount

Truck and rail unloading/Loading

facilities

Safety and Automation Systems

Telecom

Fire fighting Systems

Amount

Civil

Structural and Architectural

Systems

Waste Water Treatment Plant

Sewage Treatment Plant?

HVAC

Amount

10GRAND TOTAL

Customer Terminals

WP F0

WP F9

WP F9

WP G7 WP H7

WP G9 WP H9

WP G9 WP H9

WP F4

WP F5

WP E6

WP C7 WP D7 WP F7

WP C5 WP D5

9

Amount

8

WP G6 WP H6

7 WP A7

6 WP A6 WP C6 WP D6

WP G5 WP H5

3

4 WP A4 WP C4 WP D4

WP A3 WP C3 WP D3 WP G3 WP H3

WP G4 WP H4

5 WP A5

COST BREAKDOWN STRUCTURE

Work PackageA

Project General

C

EPC

management,

engineering and

services

D

Equipment cost

and

manufacturing

F

Civil construction

G

System and

equipment

installation

H

Mechanical completion,

commissioning, tests

and hand over

I

Total

B

External

assistance and

studies

FEED contractors

EPC contract site preparations

EPCIC LNG terminal contractor

0 WP A0 WP B0 WP C0 WP D0

WP B7

WP B8

WP B9

WP A8

WP A9

WP C8

WP C9

WP D8

WP D9

2 WP A2 WP C2 WP D2

1 WP A1 WP C1

Contractor identificationProject inergrated team

WP G0 WP H0

WP B1

WP B2

WP B3

WP B4

WP B5

WP B6

WP G2 WP H2

WP F1

WP F2

WP F3

WP D1

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Norconsult AS general information

General

Norconsult is an interdisciplinary engineering and design consultancy, providing services to clients in

the public and private sectors worldwide. The company is the leading Norwegian consultancy, a

considerable European player, and has leveraged its substantial international presence and

experience in projects on all continents.

Norconsult takes an active part in building society, and its interdisciplinary experience provides a solid

foundation to participate in developing tomorrow's infrastructure. The company employs engineers,

economists, social scientists, architects, landscape architects, environmental, information and

communication technology professionals as well as experts in a broad range of specialty fields.

The company's services are organized within the following nine business areas: Buildings, Energy,

Environment, Industry, Oil and Gas, Planning, Risk Management, Transport and Water. Norconsult

always seeks to improve the clients' business and secure their investments. The company covers all

phases of a project cycle from the earliest pre-investment and feasibility studies, through planning and

design, tendering and construction supervision, to project implementation, operations and

maintenance.

The company's social responsibilities in the markets it operates, as well as the respect for local laws

and regulations are key business success factors. Norconsult's corporate values are based upon good

business practice, honesty and respect for other people, and the company's statutes and operations

comply with the general requirements, codes of ethics and quality assurance policies of the

International Federation of Consulting Engineers (FIDIC).

The group's turnover was NOK 3 843 million in 2014, with an operating profit of NOK 147 million.

Norconsult has approximately 2 900 employees and is owned by the employees.

Norconsult AS has an engineering team directly involved into offshore activities, mainly in the North

Sea, as well as involvement in LNG liquefaction plants and storage and regasification terminals.

Location

The work will be executed by personnel located in Stockholm, Gothenburg in Sweden and Sandvika,

outside Oslo, Norway.

Management system

Norconsult has a management system according to NS-EN ISO 9001, current revision. The system is

documented in our Company Handbook. The system takes care of all kinds of requirements, whether

governmental, contractual or self-imposed.

The most important elements of the management system related to each assignment are the

following:

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a) Requirement Review

Requirements to work performance and results, as well as risks and interfaces, are reviewed

during the bid process, in more detail during the project start-up process and again during every

change handling process.

b) Planning

During the bid process necessary actions and activities and governing documents are identified

and plans made, based on the requirement review. During assignment start-up the plans are

reviewed, based on the detailed requirement review, and governing documents for the project are

updated, adapted or prepared as necessary. During each change handling process, the plans are

reviewed again, and revised if necessary.

c) Implementation

All current governing documents for the assignment, whether new, adapted, updated or existing

and implemented, are made available to and reviewed by assignment personnel during

assignment start-up.

d) Follow-up

The day-to-day follow-up of requirements to work performance and results is done by the leading

personnel assigned the responsibility for the work, through planned inspections, reviews and

reports.

e) Handling of Changes

Every change proposal is treated in a process resembling the assignment start-up: Review of

changes in requirements and their consequences, decision to implement the change proposal,

revision of governing documents according to the change and practical implementation of the

change.

f) Handling of nonconformities

Any nonconformity discovered starts a process with two types of actions: To remove the

nonconformity and to prevent the nonconformity occurring again.

The most important elements of the quality system at company level are the following:

g) Permanent governing documents

Laws, regulations, standards and other permanent governing documents for our operations are

identified and recorded in a common company database, and monitored by assigned personnel.

Changes are published on the relevant discipline net portal and implemented in the management

system as needed.

h) Training

All new employees undergoes a standardised initial training covering the management system and

further initial training adapted to their competence regarding relevant markets, disciplines and

services. The company has a comprehensive set of internal and external courses for employee

development.

i) Professional management and development

All disciplines offered are organised in internal discipline networks. Each discipline network has a

coordinator, a portal on our intranet and meetings for updating and development within the

discipline. Every operational consultant is a member of one or more networks, depending on the

services they perform.

j) Monitoring of the system

The management system is monitored through internal and external quality audits. The company

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performs company internal quality audits according to a yearly audit plan. Internal and external

quality audits within a project are performed according to the project plans.

k) Management review

The top management team performs a yearly review of the system, where data and experience

from the preceding year forms a basis for an evaluation of system status and prioritizing of actions

(system development, training, monitoring) for the coming year.

l) System maintenance

The management system is maintained and updated by a management system department

reporting directly to the president and CEO. Changes are published on our intranet.

Comprehensive changes are implemented through information campaigns and other training as

needed.

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Quality policy

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Health, Safety and environmental internal control

Norconsult has a Health, Safety and Environmental Internal Control System (HSE IC System) fulfilling

the requirements of the Norwegian "Regulation concerning Systematic Health, Environmental and

Safety Activities at Enterprises" ("Internal Control Regulation"). The HSE IC System is an integrated

part of our Quality System. The Quality System is documented in our Company Handbook.

The most important elements of the HSE IC System are the following:

a) Organisation

The responsibility for fulfilling all relevant requirements in governmental laws, regulations and

decisions is an integrated part of the management responsibility of every manager, both within the

basic organisation and the different project organisations.

There are two specialised functions with special responsibility for supervision of the working

environment:

- The Working Environment Committee

- The Personnel Safety Representatives

The Quality System Manager supervises the HSE IC System as part of the Quality System.

b) Review of requirements and risks

General requirements to the company in governmental laws, regulations and decisions and

general health, safety and environmental risks has been identified and necessary preventive

actions implemented. Special, additional requirements and risks due to each project are identified

during start-up of the project and additional preventive actions implemented when necessary.

c) Health and safety when working in our own offices

Factors that may affect health and safety, such as the design and state of the building, fire

protection, electrical systems, sound, light, heating, ventilation and air conditioning, cleaning,

working space ergonomics, working habits and psychosocial factors are monitored.

d) Health and safety when working outside our own offices

Factors that may affect health and safety when our employees visit or work at construction sites or

the premises of other companies are considered to be the same as for the people working there

full time. The company has general rules and advice for commonly visited types of sites and

common protective equipment available. Each employee identifies the risks and rules that are

relevant for each site they will visit and takes measures accordingly.

e) Environmental issues

The normal activities of the company does not have special adverse effects on the environment.

f) Company health service

The company has arrangements for health service. Sick leave and injuries are monitored.

g) Information

Every new employee follows an information and training programme.

All employees have access to information on the operation of the company.

h) Supervision of the HSE IC System

The HSE IC System is supervised by the manager of each organisational unit, by the Safety

Delegates and the Working Environment Committee, and, as part of the Quality System, by the

Quality System Manager.

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Health, Safety and protection of the environment

Norconsult AS statement regarding Health, Safety and protection of the environment:

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Health, Safety and environmental internal control policy

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Code of ethics

The Code of Ethics /attachment 1/ is a governing document, and part of Norconsult’s management

system. It defines the ethical standards upon which we shall act.

This Code of Ethics does not provide detailed guidance on any specific situation, or give instructions

on how to comply with local legal requirements in the many different countries in which Norconsult

operates. It provides a framework of conduct to be followed when representing Norconsult, and as

such influences how to think about what we should and should not do. Managers on all levels at

Norconsult are responsible for familiarising their employees with the Code of Ethics, and implementing

and ensuring compliance with it.

Employees shall comply with all applicable laws and regulations. If there are differences between such

laws and regulations and the standards set out in this Code of Ethics, the most stringent standard

shall be applied.