Occupational Health and Safety Policy

This Occupational Health and Safety Policy was last updated on 21 October 2026.

1. Purpose

This Occupational Health and Safety Policy sets out how Green Earth Group N.V. (the "Company") protects the health, safety and well-being of its employees, contractors and visitors and of the communities in which it operates.

The policy states the Company's commitment to managing health and safety risks and to complying with all applicable laws, regulations and industry standards. It also sets out the responsibilities of managers and employees for a safe and healthy working environment. Its aim is a culture of safety and responsibility, lower workplace risks and continuous improvement in health and safety performance.

Environmental matters are covered by the Environmental Policy.

2. Scope

This policy applies to the Company and its group companies in every location where they operate. It applies to all employees and to contractors and other workers who carry out work on the Company's behalf.

3. Our commitment

The Company's long-term success depends on the safety of its workers, of visitors to its operations and of the public. A safe and healthy workplace is a fundamental right of every person and a business necessity. Every employee has the right to work in an environment that is free from harm.

The Company takes responsibility for maintaining a safe and productive workplace in every part of its operations. It does what it can to minimise the risk of accidents, injury and exposure to health hazards for all employees and contractors, through a proactive approach to identifying, assessing and managing risks.

4. Risk management

Every job carries risks. The Company runs a risk management programme to identify, assess and manage hazards in the workplace. The programme includes:

  • regular risk assessments;
  • investigation of incidents; and
  • continuous improvement initiatives.

Risk inventory and evaluation (RI&E)

In the Netherlands, the Company keeps a written risk inventory and evaluation (risico-inventarisatie en -evaluatie, RI&E), as article 5 of the Working Conditions Act (Arbeidsomstandighedenwet) requires. The RI&E covers all work and workplaces, including office work, travel and field visits, and psychosocial workload. It comes with an action plan (plan van aanpak) that states the measures to be taken, who is responsible and by when.

Where the law requires it, the RI&E is checked (getoetst) by a certified expert or a certified occupational health and safety service. The RI&E and the action plan are updated when work, workplaces or risks change materially, and the progress of the action plan is reviewed at least once a year. Employees can read the RI&E and the action plan.

5. Prevention and expert support

  • Prevention officer. The Company appoints at least one prevention officer (preventiemedewerker) who helps to draw up and carry out the RI&E and the action plan and advises on health and safety measures (article 13 of the Working Conditions Act).
  • Occupational health service and company doctor. The Company has a contract with a certified occupational health service (arbodienst) or a company doctor (bedrijfsarts), in line with article 14 of the Working Conditions Act. Through it, employees have access to a company doctor, including for an open consultation without involving their manager, and to periodic occupational health examinations where appropriate.

6. Training and competence

The Company gives employees the training and resources they need to do their work safely and competently. The training requirements in the Company's policies and standards apply as a baseline in every location, together with applicable legal requirements. Training includes:

  • a health and safety induction for new employees;
  • periodic refresher training for all employees and for other workers who carry out work on the Company's behalf;
  • ongoing training and development; and
  • regular competency assessments.

7. Emergency preparedness

The Company maintains emergency response plans for potential emergencies, including natural disasters, accidents and other incidents that may affect its employees, its facilities or the environment. The plans are reviewed and tested regularly to make sure they are effective.

In the Netherlands, the Company appoints and trains enough company emergency response officers (bedrijfshulpverleners, BHV) to provide first aid, fight a fire in its early stages and lead an evacuation, in line with article 15 of the Working Conditions Act and the risks identified in the RI&E. Field teams outside the Netherlands have trained first-aiders, first-aid kits and an emergency contact and evacuation plan for each project area.

8. Accidents and incidents

  • Every accident, injury, occupational illness and near miss is reported to the line manager without delay and recorded.
  • In the Netherlands, an occupational accident that leads to death, permanent injury or admission to hospital is reported immediately to the Netherlands Labour Authority (Nederlandse Arbeidsinspectie, formerly Inspectie SZW), as article 9 of the Working Conditions Act requires. The Company keeps a register of reported accidents and of accidents that led to more than three working days of absence.
  • Outside the Netherlands, accidents are reported to the competent authority as local law requires.
  • Serious incidents are investigated to find the cause, and the measures taken are recorded and fed back into the RI&E.

9. Sickness absence and return to work

The Company has a sickness absence and return-to-work (reintegration) process. In the Netherlands it follows the Gatekeeper Improvement Act (Wet verbetering poortwachter): an employee reports sick in the agreed way, the company doctor advises, and the Company and the employee draw up and follow a plan of action for return to work, with regular evaluation. Medical information is shared only with the company doctor and is handled as confidential personal data.

10. Psychosocial workload, harassment and undesirable behaviour

The Company protects employees against psychosocial workload (psychosociale arbeidsbelasting), including work pressure, aggression and violence, harassment, sexual harassment, discrimination and bullying, as article 3, paragraph 2, of the Working Conditions Act requires. It does so by:

  • including these risks in the RI&E and the action plan;
  • setting rules of conduct in the Code of Conduct and acting on every report of undesirable behaviour;
  • making a confidential adviser (vertrouwenspersoon) available, to whom employees can turn in confidence for advice and support; and
  • informing employees about these risks, the measures and where they can go for help.

11. Operations outside the Netherlands

Green Earth's subsidiaries and project teams in Uganda, Kenya and other countries of operation comply with the occupational health and safety laws of the country in which they work, including registration, reporting, insurance and inspection requirements. This policy applies there as a minimum standard. Where local law is stricter, local law applies. Where this policy is stricter, this policy applies. Contractors and implementation partners who work on Green Earth's projects are required to meet the same standards.

12. Compliance with laws and standards

The Company complies with all applicable laws, regulations and industry standards on occupational health and safety.

In addition to legal requirements, the Company aligns its approach with internationally recognised standards for occupational health and safety management systems, such as ISO 45001. It does so to improve employee safety, reduce workplace risks and create safer working conditions in every location.

13. Road and transport safety

The Company gives high priority to safety on the road and in the transport of its products. Its safety processes emphasise situational awareness and attention to detail. The Company also takes part in community outreach and in organisations that work to improve infrastructure and operating practices, in order to improve the safety of its employees and road safety in the communities where it operates.

14. Communication and engagement

Effective communication and engagement are essential to a safe and healthy workplace. The Company encourages open and transparent communication between employees and management. It engages with its stakeholders to promote awareness of health and safety and good practice.

15. Continuous improvement

The Company works to improve its health and safety performance continuously through regular reviews, assessments and audits. It learns from experience and shares good practice with its stakeholders to support continuous improvement across its industry.

16. Roles and responsibilities

  • The Board. The management board of the Company (the "Board") oversees this policy; the Chief Executive Officer approves it on the Board's behalf. The HSE and Sustainability Committee reviews the Company's health and safety policies and performance, as set out in the Terms of Reference Health, Safety and Environment (HSE) and Sustainability Committee.
  • Managers. Managers set health and safety objectives, provide resources and support, and make sure that all employees understand their roles and responsibilities.
  • Employees and contractors. Employees and contractors work safely in line with their training and help to maintain a safe and healthy workplace.
  • Prevention officer. The prevention officer supports the RI&E and the action plan and advises on measures.
  • Country Directors. Each Country Director makes sure that the venture complies with local health and safety law and with this policy.
  • Head of Legal. The Head of Legal owns this policy and keeps it up to date.

17. Reporting concerns

Employees are encouraged to report any potential breach of this policy, and any health and safety concern, to their line manager or the prevention officer. Employees can also turn to the confidential adviser. Concerns can also be raised through the channels set out in the Whistleblower and Non-Retaliation Policy, which is available to all staff. A report about the Chief Executive Officer goes to the chair of the Board. Contractors, visitors and members of the public can raise a concern by email to contact@green.earth or through the contact form at https://www.green.earth/contact.

18. Approval and review

This policy is approved by the Chief Executive Officer on behalf of the Board. The Head of Legal owns the policy and reviews it at least every two years.

History: first issued on 9 January 2018 by the Company, then named DGB Group N.V.; revised on 24 May 2023 and approved at the 2023 Annual General Meeting.