Purpose

To describe the process for identification of applicable compliance obligations to which SkyVine ITAD subscribes related to its product requirements, environmental, health and safety aspects, and to determine how these requirements apply to SkyVine ITAD’s environmental, quality, health and safety aspects and hazards.

To ensure that SkyVine ITAD only exports equipment and components containing focus materials to countries that legally accept them.

Responsibility and Authority

The QEH&S Management Rep is responsible for maintaining an updated list or having access to applicable compliance obligations including, regulations, rules, permits, and other requirements to which the organization subscribes.

Procedure

1. The QEH&S Management Rep is responsible for tracking and ensuring that all quality, environmental, health and safety and data security compliance obligations that are applicable to the SkyVine ITAD facility have been identified and for evaluating their potential impact on the company’s operations.

2. The QEH&S Management Rep shall document applicable quality, environmental, health and safety legal requirements and other requirements that apply to the company’s processes on the Compliance Obligations Summary List.

3. The QEH&S Management Rep shall employ several techniques to track, identify, and evaluate applicable legal and other requirements including:

   1. websites of the EPA, EPA TX, Tarrant County,

   2. information from trade associations,

   3. the internet and email lists

   4. outside consultants,

   5. direct communication with federal, regional, state, and local agencies,

   6. networking with industry peers,

   7. industry trade show,

   8. industry publications,

   9. participation in professional organizations

   10. training courses on environmental, health and safety laws.

4. SkyVine ITAD shall also ensure that “other” quality, environmental, health and safety and data security compliance obligations to which the company subscribes are listed on the Compliance Obligations Requirements Summary List, such as New Customer Profile, customer contracts, professional associations and certifications.

5. The QEH&S Management Rep shall keep the Compliance Obligations Summary List up to date.

6. SkyVine ITAD communicates relevant information compliance obligations to persons working under the control of the organization and other interested parties according to Communication Procedure.

Compliance Plan

7. SkyVine ITAD utilizes the EHS Compliance Calendar to identify and implement the steps necessary to comply with each requirement and record the implementation of these steps.

8. SkyVine ITAD shall periodically evaluate its compliance with the requirements according to the Evaluation of Compliance Procedure, which includes taking corrective action to address any issues of non-conformity.

9. Compliance obligations shall be reviewed for adequacy at least once a year during Management Review meetings.

10. The QEHS Management Rep shall identify and document (on the Import Export Requirements Summary List) the legality – under the laws of the importing countries – of all international shipments of equipment, components or materials containing FMs that have passed through the organization’s facility or control. The QEHS Management Rep shall identify all the countries that are receiving or transferring such shipments, obtain documentation demonstrating that each non-OECD country legally accepts such shipments, and only make such shipments to countries for which it has such documentation.

The documentation shall be in English and consist of original documentation from the importing or exporting country’s Competent Authority or a copy of a law or court ruling, that demonstrates the import country legally accepts such imports, and the export country legally allows such exports.

Related and Supporting Documents

6.1.4.2-F Compliance Obligations Summary List

6.1.4.3-F Import Export Requirements Summary List

6.1.4.4-F EHS Compliance Calendar

6.1.4.5-F New Customer Profile

7.4.1.1-P Communication Procedure

9.1.3.1-P Evaluation of Compliance Procedure

Document Revision History

Rev. Description of Change Approved Date Approved By

0 New 12-28-21 C. Vo

6.1.4.1-P Compliance Obligations Identification Procedure - Rev.0

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