Communicate Procedure

Purpose

To describe the process for;

• Internal communication among the various levels of the organization

• Participation and consultation in QEHS matters

• Receiving, documenting, and responding to QEHS related communications from external interested parties

Responsibility and Authority

The QEHS Management Representative shall have the responsibility and authority to ensure conformance to the activities described in this procedure.

Procedure

INTERNAL COMMUNICATION

1. With regard to its QEHS management system, significant environmental impacts and health and safety risks, EH&S information, the effectiveness of the management system and the importance of meeting customer and legal requirements, SkyVine ITAD shall use a variety of methods for internal communication between the various levels and functions of SkyVine ITAD, including verbally, written and by email. See Internal Communication Table below.

2. The QEHS Management Rep communicates the QEHS policy and details of the QEHS management system, (including important environmental aspects, health and safety risks and meeting customer and legal requirements) through employee training, bulletin board postings, safety meetings and postings throughout the facilities.

3. The QEHS Management Rep communicates QEHS performance, including the effectiveness and recommendations for improvement to top management through management review meetings.

4. The QEHS Management Rep communicates corrective or preventive actions from internal or external audits through management review meetings.

5. Employees communicate preventive and corrective actions or QEHS concerns by filling out the CAPA Report or via communication at Safety meetings. Safety meetings are also the forum for employee participation and consultation regarding QEHS matters.

6. Specific instructions to manage individual customer complaints are addressed in the SkyVine ITAD 8.0.1-P Operational Control – Quality Procedure.

Internal Communication Table

What When with Whom How

QEHS Policy, EH&S Aspects and New Hire Training, Employees Verbal – Training

Hazards, Compliance Obligations, Refresher Training

Roles and Responsibilities, QEHS

Objectives and Targets,

Emergency Preparedness,

Incident Investigations, QEHS

performance

Audit Results Management Review Top Management Verbal

Meetings

Incident Investigations, Corrective Management Review Meetings Top Management Verbal

Actions and Improvement

Opportunities

EXTERNAL COMMUNICATION

1. SkyVine ITAD shall externally communicate information relevant to the QEHS management system according to the External Communication table below.

2. SkyVine ITAD shall document and respond to relevant QEHS communication from external interested parties. Regulatory compliance issues and other relevant communication, including but not limited to, environmental groups and neighbors shall be recorded on the External Communication Log or via emails and/or communication at sales meetings. Customer audits and tours of the SkyVine ITAD’s facility shall be recorded on the Visitor and Contractor Sign In Log.

3. Specific instructions to manage individual customer complaints are addressed in the SkyVine ITAD 8.0.1-P Operational Control – Quality Procedure.

External Communication Table

What When with Whom How

QEHS Policy At Sign-In External Providers, Contractors, Visitors Visitor and Contractor EHS Requirements

QEHS Policy and scope statement Always Interested Parties Website

Compliance Obligations At Sign-In External Providers, Contractors, Visitors Visitor and Contractor EHS Requirements

Regulatory Reports As required, See Regulator Written

List of Legal and Other

Requirements

Emergency As needed Emergency Responders Verbal

PARTICIPATION AND CONSULTATION

1. Employees are involved in the development and review of policies and procedures relating to QEHS performance through participation in training, job hazards analysis, incident investigation, safety meetings and input to corrective and preventive actions.

2. Employees are consulted where there are any changes that may affect the environment, quality requirements or health and safety risks through job hazards review and training.

3. Employees are informed of their participation arrangements and who is their QEHS Management Representative during new hire orientation.

4. SkyVine ITAD communicates QEHS hazards and other requirements to contractors through the Visitor and Contractor EHS Requirements. The SkyVine ITAD employee whom the contractor is reporting to shall be responsible for consulting with contractors when there are changes that affect their health and safety risks and Visitor and Contractor EHS Requirements will be updated as necessary.

5. SkyVine ITAD requires all visitors to the facility to be accompanied by a SkyVine ITAD employee. SkyVine ITAD communicates QEHS hazards and other requirements to visitors through the Visitor and Contractor EHS Requirements and through appropriate verbal communication

Related and Supporting Documents

10.2.2-F CAPA Report

10.2.3-F CAPA Log

7.4.3.1-F External Communication Log

7.2.5-F Visitor and Contractor EHS Requirements

7.2.4-F Visitor and Contractor Sign-In Log

8.0.1-P Operational Control – Quality Procedure

Document Revision History

Rev. Description of Change Approved Date Approved By

0 New 01/04/2022 C.Vo

7.4.1.1-P Communication Procedure - Rev.0

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