EP7.002.014 NEV-TGD-701-01.00-Environ & Social Compliance Assurance STD (Within 711)
EP7.002.014 NEV-TGD-701-01.00-Environ & Social Compliance Assurance STD (Within 711)
Document approval
The Environmental and Social Compliance Assurance Standard details both the Assurance
Program that will be used by NEOM to assess Contractors’ environmental performance and
adherence to regulatory, contractual and project requirements , which are also known as
Compliance Obligations; and also the means by which shortfalls in meeting compliance
obligations are recorded and managed.
The Environmental and Social Compliance Assurance Standard defines how NEOM inspects
and audits Contractors for compliance. The outcomes of the Inspection and Audit Program may
result in further engagement by NEOM with the Contractor, and/or enforcement action.
NEOM’s enforcement powers are progressive in nature and designed to facilitate interaction
and cooperation with the Contractor in the first instance and to proactively encourage
compliance.
2. Purpose
The overall purpose of the Inspection and Audit Program detailed in this standard is to measure
compliance with applicable requirements and to identify w here shortfalls in meeting Compliance
Obligations exist. This is achieved through acquiring objective evidence, that each Contractor
is complying with applicable Compliance Obligations.
Performance Management processes have been developed to address Inspec tion and Audit
compliance shortfalls.
3. Scope
The Environmental and Social Compliance Assurance Standard considers the Plan-Do-Check-
Act (PDCA) cycle to differentiate between audits and inspections. At a high level, inspections
are a “do” and audits are a “check”. In general terms, inspections are physical examinations of
construction sites and work locations, systems and parts of systems and hardware, for the
purposes of assessing the integrity, and/or operation of these systems. Where physical controls
are lacking or ineffective in mitigating environmental risks and impacts, the measures and
mechanisms detailed in the Environmental and Social Performance Management Procedure
shall be used to return Contractors to compliance.
Audits are based on examination of records, reports and other documented evidence produced
or generated by Contractor relating to, for example, environmental performance, the
Environmental and Social Management System, environment performance and monitoring
reports. Where compliance obligation shortfalls are identified, the Environmental Non -
Conformance Procedure shall be used to return Contractors to compliance.
4. Structure
The document is structured into four parts according to the environmental and social assurance
compliance mechanisms applicable for NEOM:
ENVIRONMENTAL PROCEDURE
CONSTRUCTION ENVIRONMENTAL INSPECTION
PROCEDURE
1. INTRODUCTION ...................................................................................................................... 6
2. PURPOSE ................................................................................................................................ 6
3. SCOPE ..................................................................................................................................... 6
4. ROLES AND RESPONSIBILITIES .......................................................................................... 6
5. PROCEDURE........................................................................................................................... 7
5.1. Inspection Documents .............................................................................................................. 7
5.1.1. Construction Environmental Inspection Schedule .................................................................... 7
5.1.2. NEOM Construction Environmental Inspection Checklist ........................................................ 7
5.1.3. NEOM Construction Environmental Inspection Report ............................................................ 7
5.2. Phases of Construction Environmental Inspection Process .................................................... 8
5.2.1 Phase 1 – Pre-inspection ......................................................................................................... 8
5.2.2 Phase 2 - Day of the Inspection ............................................................................................... 8
5.2.3 Phase 3 – Post – Inspection ..................................................................................................... 9
5.2.3.1 Environmental Inspection Checklist ....................................................................................... 10
5.2.3.2 Distribution of Environmental Inspection Checklist ................................................................ 10
5.2.3.3 Environmental Inspection Report ........................................................................................... 10
6. RELATED DOCUMENTS ...................................................................................................... 13
7. APPENDICES ........................................................................................................................ 13
APPENDIX A. GUIDELINE FOR CARRYING OUT ENVIRONMENTAL INSPECTIONS ................... 14
APPENDIX B. GUIDELINE FOR COMPLETING THE ENVIRONMENTAL INSPECTION
CHECKLIST ........................................................................................................................... 16
APPENDIX C. GUIDELINE FOR COMPLETING THE ENVIRONMENTAL INSPECTION REPORT 18
APPENDIX D.TEXT FOR DISTRIBUTION OF INSPECTION REPORT DOCUMENTS VIA
EMAIL .................................................................................................................................... 22
APPENDIX E. TEXT FOR DISTRIBUTION OF INSPECTION REPORT DOCUMENTS VIA ACONEX
................................................................................................................................................ 23
APPENDIX F. NEOM CONSTRUCTION ENVIRONMENTAL INSPECTION CHECKLIST TEMPLATE
................................................................................................................................................ 24
APPENDIX G. NEOM CONSTRUCTION ENVIRONMENTAL INSPECTION REPORT TEMPLATE. 26
APPENDIX H. CONSTRUCTION ENVIRONMENTAL INSPECTIONS SCHEDULE TEMPLATE ..... 30
Environmental inspections are an important proactive tool for ensuring that contractors working in
NEOM comply with NEOM’s Environmental requirements and the requirements of the Contractors
Environmental and Social Management Plan (ESMP). Inspections provide an opportunity to assess the
environmental performance of contractors working in NEOM and, by extension, the compliance
performance of NEOM itself. This procedure outlines the NEOM Construction Environmental inspection
program.
2. Purpose
The purpose of this procedure is to provide guidance to Employer in the execution of the Construction
Environmental Inspection Program. The Construction Environmental Inspection Program has been
developed to:
3. Scope
This procedure describes the process by which Construction Environmental Inspections are conducted.
This procedure is applicable to all contractors involved in construction activities at all NEOM locations.
1. Employer
a. Employer shall ensure that all necessary resources are provided in the execution of the
requirements of the Construction Environmental Inspection Program.
b. Employer is responsible for the execution of the construction environmental inspection
process.
c. Employer is responsible for ensuring that the required members of the inspection party are
invited to the scheduled Construction Environmental Inspection.
d. Employer is responsible for ensuring that the Environmental Inspection Checklist and the
Environmental Inspection Report is compiled accurately, comprehensively and within the
agreed timeframes.
e. Employer is responsible for leading the inspection party and ensuring that the environmental
inspection is conducted to the level of detail required to obtain a comprehensive assessment
of the environmental performance of a contractor site.
2. Contractors
a. Contractors shall fully facilitate the Construction Environmental Inspection Program, providing
access to all areas, applicable documentation and facilities to which access is reasonably
expected and required to obtain a comprehensive overview of site environmental risks.
b. Contractors shall provide adequate means of transportation to the inspection party, where
required, when access to site on foot is not reasonably practicable, based on spatial or
climatologically conditions.
5. Procedure
1. Prior to the commencement of each Gregorian calendar month, EMPLOYER will compile a
Monthly Construction Environmental Inspection Schedule.
2. NEOM Construction Environmental Inspections shall be conducted on a weekly basis or at
a frequency established by NEV.
3. The schedule shall, prior to distribution, be shared with NEV for review and approval.
4. Following approval, EMPLOYER shall distribute the approved Monthly Construction
Environmental Inspection schedule to relevant project Contractors and to NEV.
There are 3 phases associated with each NEOM Construction Environmental Inspection:
• Pre-Inspection Phase
• Inspection Phase
• Post-inspection Phase
Figure 2 – Repeat the observation, but linked to a different instructed corrective action
6. Related Documents
7. Appendices
1 NEOM Construction Environmental Inspections are one of the most effective tools available to
NEOM for managing project risks, measuring contractor performance, and changing project
behaviours.
2 How persons conduct environmental inspections is both a direct reflection on those persons as
Environmental Professionals and on the importance of environment performance held by NEOM.
The approach to conducting and managing inspection sends direct signals to the Contractor.
Should wrong signals be sent, the Contractor will not respond to the inspection process in the
desired way. If, however, the right signals are sent, we condition the Contractor to understand
that environmental risk management is a serious topic that requires serious effort and
commitment.
3 The right inspection signals include:
• Being professional – be on time; be authoritative; lead the inspection; hold firm on NEOM’s
environmental value; accept nothing less than excellence;
• Being thorough – identify all issues; examine the issues in detail;
• Being fair – Recognise and praise genuine effort;
• Aim for perfection – by failing to push the Contractors to higher levels of performance, we will
fail to achieve ‘world-class’ standards; by not insisting on perfection, we are complicit in
accepting mediocre standards; Contractor and/or Regional limitations shall not be accepted
as excuses for inaction or poor performance.
4 NEOM believe in managing all environmental risks, and by doing so prevent the conditions which
facilitate the occurrence of extensive and/or cumulative risks. In managing all environmental risks,
we are engaging in a program of transformative change intended to change established mindsets
and methods by conditioning Contractors to consider environmental outcomes in the execution of
their works.
5 When identifying issues and assigning corrective actions, the focus should be on system fixes,
not point fixes. Look deeply into the issues on site and encourage implementation of holistic
solutions (system fixes) to site problems.
Start of Inspection
1. Opening Comments to the inspection party
a. Mention previous compliance score, previous closure rate and previous critical issues
b. Ensure that all inspection party members have copies of the report on their person
c. Commence the site inspection
Figure 1
2 Contract Name & Number (A, Figure 1) - input Contract Name / Contract Number.
3 Contractor Name (B, Figure 1) - input the name of the Contractor executing the project.
4 Date of Inspection (C, Figure 1) - input the date that the inspection was completed on. The date
format shall by DD Month (full month name) YYYY.
5 Accompanied by (D, Figure 1) - input the names and companies of the inspection party members
who were present during the inspection.
6 Report By: (E, Figure 1) – input the full name of the person completing the checklist, with first
name, followed by family name.
2. Consider compliance factors and considerations, by applying the following thought process:
Figure 4
Step 2
1. During the site inspection, EMPLOYER will use a hard copy of the Environmental Inspection
Report (that was generated as a result of the previous inspection) to mark which items have been
closed and which items are deemed not completed.
2. Delete all the rows on the report with the status ‘Closed’.
3. Update, if necessary, the status column of all the remaining observations on the report to one of
the two following statuses:
a. Not Complete – where the required action detailed on the report has not been completed
to the satisfaction of the inspection party. Input ‘Not Completed’ in the status column and
infill the cell with colour red
Figure 5
Figure 6
Step 5
1. Go to ‘Environmental Compliance Score’ graph.
2. Update the graph as indicated in Figure 7.
3. Go to ‘Follow-Up Status – Closure Rate (%)’ graph.
4. Update the graph as indicated in Figure 7.
Step 6
1. Go to the final page of the report.
2. In the table titled ‘Report Generated By’ input the following details:
a. Name of the person having completed the report;
b. Company employing the person who has completed the report;
c. Signature of the person who completed the report;
d. Date that the report was completed.
Please find attached a copy of the report following an Environmental Inspection undertaken by the
PMC on the project name on the DD MM YYYY.
1. Environmental Inspection Report – outlines the non-compliances noted during the inspection,
along with supporting photographs and required corrective actions which must be
implemented; and
2. Environmental Inspection Checklist – outlines the criteria used during the inspection, and the
total compliance score for the project site.
Contractor’s Name shall ensure that all environmental issues detailed in the inspection report are
addressed within the specified timeframe.
Should you require any further information regarding this subject, please feel free to contact NEOM
Environment.
Dear Sir,
Please find attached a copy of the report following an Environmental Inspection undertaken by the
PMC on the project name on the DD MM YYYY.
1. Environmental Inspection Report – outlines the non-compliances noted during the inspection,
along with supporting photographs and required corrective actions which must be
implemented; and
2. Environmental Inspection Checklist – outlines the criteria used during the inspection, and the
total compliance score for the project site.
Should you require any further information regarding this subject, please feel free to contact NEOM
Environment.
Accompanied by:
Rev09
SECTION 2 - ENVIRONMENTAL ASSURANCE CHECK ITEMS
1 Air Emissions Score 8 Fuel and Chemical Management Score
1.1 Are emissions from generators/vehicles/equipment clear and free from dark vapours? 8.1 Bulk Fuel Storage
1.2 Is unnecessary operation of engines while equipment/vehicles are stationary prevented? 8.1.1 Are site fabricated bulk fuel storage tanks prohibited on site?
1.3 Do the movements of vehicles/equipment on site adhere to the site speed limit? 8.1.2 Do bulk fuel storage tanks reside within concrete bunds which are free of damage/defects?
1.4 Are vehicle routes kept sufficiently damp with water for the volumes of vehicular movements? 8.1.3 Has a bunded refuelling apron been installed, within which fuel transfers take place?
1.5 Is airborne dust around loading / unloading areas and activities prevented? 8.1.4 Is a spill kit, adequate for stored volumes, available at the bulk fuel storage area?
1.6 Are stockpiles actively managed (covered/dampened) to prevent airborne dust? 8.1.5 Is fuel dispensed from the bulk fuel storage tanks using an automatic refuelling nozzle?
Score Per Section 0 8.1.6 Are fuel hoses used for fuel transfers intact and free from damage?
2 Nuisance Control Score 8.2 HAZMAT Chemical Storage
2.1 Are nuisance noise levels, which effect sensitive receptors, prevented on site? 8.2.1 Are all containers in the HAZMAT chemical store placed within secondary containment?
2.2 Are all generators encased in integrated acoustic housing, which doors remain closed? 8.2.2 Is a chemical spill kit available at the HAZMAT chemical store?
2.3 Is the site free of presence of vermin/pests (rats, flies, cats, dogs)? 8.2.3 Are MSDS's available for ALL chemicals in storage?
2.4 Are materials which attract vermin (food waste, accumulated water) adequately controlled? 8.2.4 Is an updated chemical inventory available and displayed within the HAZMAT chemical store?
2.5 Are nuisance odours prevented on site? 8.2.5 Are ALL containers stacked less than 1.5m in height?
2.6 Is track-out of sediment onto publicly used roads prevented? 8.2.6 Is the HAZMAT chemical store free of volatile organic compounds (VOC's)?
2.7 Are wheel wash facilities/rumble grids provided on site to eliminate track-out? 8.3 Work-front Storage of Chemical and Hydrocarbon Containers
Score Per Section 0 8.3.1 Do all chemical/hydrocarbon containers at point of use reside within spill trays?
3 Resources / Materials Score 8.3.2 Are all chemical/hydrocarbon stored in their original, clearly labelled containers?
3.1 Are construction materials protected from damage/deterioration? 8.3.3 Are leaking/defective chemical/hydrocarbon containers promptly removed off site?
3.2 Are powdered materials stored/managed in a manner which prevents wastage? 8.3.4 Are manufactured funnels available and used for chemical / fuel transfers?
3.3 Are energy conservation practices promoted and observed on site? Score Per Section 0
3.4 Is the mixing of mortar/cement on bare ground prevented? 9 Spill Management Score
3.5 Is plastic sheeting used at concrete transfer points? 9.1 Are chemical/hydrocarbon spills to bare ground prevented?
3.6 Is excess concrete beneficially reused on site, to avoid it becoming waste? 9.2 Are soils contaminated by chemical/hydrocarbon spills immediately cleaned?
3.7 Is concrete wash-out on site prevented? 9.3 Is chemical/hydrocarbon transfer equipment and methodology acceptable?
Score Per Section 0 9.4 Is secondary containment (spill trays/concrete bunds) of adequate size and free of spills?
4 Waste Management Score 9.5 Do all spill kits have a spill kit checklist available, completed monthly?
4.1 Is the site free of litter? 9.6 Are details of emergency spill response teams displayed at all spill sensitive locations?
4.2 Is all waste on site containerised at all times? 9.7 Are spill warning signs/awareness material displayed at all spill sensitive locations?
4.3 Are bins/waste containers suitable for the types of waste being generated at work locations? Score Per Section 0
4.4 Are all bins clearly labelled, with lids that remain closed? 10 Welfare / Laydown Score
4.5 Is overfilling of bins/waste containers prevented? 10.1 Generator
4.6 Is a dedicated central waste storage location (CWSL) provided for the site? 10.1.1 Do all site generators reside within concrete bunds?
4.7 Is the dedicated CWSL clearly identified with suitable signage? 10.1.2 Is the generators concrete bund in good condition/free of holes?
4.8 Are there a sufficient number of skips provided at the CWSL? 10.1.3 Are spill kits available at all generator locations on site?
4.9 Is all waste at the CWSL stored in skips and prevented from being stored on the ground? 10.1.4 Do the spill kits at generator locations have adequate contents?
4.10 Is the CWSL sited a sufficient distance from sensitive receptors? 10.2 Toilet Facilities
4.11 Is waste segregated into the correct dedicated skips/containers at the CWSL? 10.2.1 Are the toilet facilities on site free of leaks?
4.12 Are skips/containers which contain light-weight material covered with a net? 10.2.2 Is the wastewater storage tank linked to the toilet facilities tank in good condition?
4.13 Is overfilling of skips/containers prevented? 10.2.3 Does the wastewater storage tank have a securely fitting lid attached?
Hazardous Waste 10.2.4 Are spills and unplanned releases of wastewater prevented?
4.14 Is a HAZWASTE Storage Facility (HWSF) provided? 10.3 Mess hall
4.15 Are stored quantities of hazardous waste suitable for the capacity of the HWSF? 10.3.1 Does the mess hall have food waste bins with lids that close?
4.16 Is general waste bins/skips/containers free of chemical/contaminated/hazardous waste? 10.3.2 Is the mess hall cleaned to prevent the attraction of vermin and pests?
4.17 Are liquid hazardous wastes stored in closed top/lidded containers? 10.3.3 Is pest control at the mess hall available and effective?
4.18 Are all liquid hazardous waste containers provided with secondary containment/spill trays? 10.4 Awareness Material
4.19 Are contaminated soils resulting from spills stored in the HWSF? 10.4.1 Is there a dedicated environmental notice board at locations where works congregate?
Score Per Section 0 10.4.2 Are environmental awareness material displayed on the environmental noticeboard?
5 Earthworks & Soil Score Score Per Section 0
5.1 Are site and earthworks boundaries clearly marked/identified and being adhered to? 11 Ecology / Conservation Score
5.2 Are stockpiles sited in location(s) which do not pose risks to sensitive receptors? 11.1 Terrestrial Conservation
5.3 Are soil erosion measures in place at required location(s) and effective? 11.1.1 Are protected nests/burrows/fauna habitats fenced off?
Score Per Section 0 11.1.2 Are exclusion zones around nests/burrows/fauna habitats installed and observed?
6 Water Resources and Dewatering Score 11.1.3 Are terrestrial fauna fatalities prevented?
6.1 Is water waste generated as a result of defective equipment / systems, prevented? 11.1.4 Is appropriate signage erected at protected nests/burrows/fauna habitats?
6.2 Is water waste generated as a result of unwanted behaviours by workers, prevented? 11.1.5 Are protected plants/vegetation/flora habitats fenced off?
6.3 Is wastewater piped to and stored in storage tanks prior to disposal? 11.1.6 Are exclusion zones around plants/vegetation/flora habitats installed and observed?
6.4 Are wastewater storage tanks sited within concrete secondary containment? 11.1.7 Are heritage/high value ecological sites protected and exclusion zones observed?
6.5 Is pools/accumulation of stagnant water on site prevented? 11.2 Marine Conservation
6.6 Are water resources adequately protected from pollution risks? 11.2.1 Is nearshore/floating/benthic marine litter prevented?
6.7 Are hazardous/chemical materials stored min 50 metres away from water bodies? 11.2.2 Are marine fauna fatalities prevented?
Dewatering 11.2.3 Are marine environments unaffected by project activities?
6.8 Do all dewatering wells have well casings installed? 11.2.4 Are coastal systems unaffected by project activities?
6.9 Do all dewatering booster pumps sit within a spill tray? 11.2.5 Are pollution risks to the marine adequately controlled by distance/barriers?
6.1 Is dewatering equipment free from defects/operating efficiently? 11.2.6 Are vessel/equipment movement risks in the marine environment adequately controlled?
6.11 Are dewatering hose clamps/connections free of damage, well maintained and free of leaks? Score Per Section 0
6.12 Are all dewatering hoses clearly identified with a unique labelling system? 12 Landform/Topography Preservation Score
6.13 Is localized flooding/unplanned release of water prevented? 12.1 Are landform and topograpy modifications outside approved work boundaries prevented?
6.14 Are sediment tanks free of silt and of adequate capacity for throughput volumes of water? 12.2 Is material extraction, infilling and stockpiling restricted to approved locations?
6.15 Are sediment lagoons effective in removing suspended sediment from the water? 12.3 Is blasting activities restricted to approved locations?
Score Per Section 0 12.4 Is blasting activities controlled to minimise impacts from fly rock and projectiles?
7 Vehicle and Equipment Management Score Score Per Section 0
7.1 Are site temporary roads demarcated, graded/stabilised and used for all movements? SUMMARY:
7.2 Is Vehicle / Equipment on site in a good state of repair and suitable for the tasks? 1 Air Emissions 0%
7.3 Are spill trays clean & free of litter/sediment? 2 Nuisance Control 0%
7.4 Are all vehicles and equipment free of hydrocarbon leaks? 3 Resources / Materials 0%
7.5 Are hydraulic hoses free of damage/excessive wear and tear? 4 Waste Management 0%
7.6 Is maintenance conducted in a bunded maintenance workshop with impervious flooring? 5 Earthworks & Soil 0%
Score Per Section 0 6 Water Resource and Dewatering 0%
7 Vehicle and Equipment Management 0%
8 Fuel and Chemical Management 0%
9 Spill Management 0%
10 Welfare / Laydown 0%
11 Ecology / Conservation 0%
12 Landform/Topography Preservation 0%
Final Score 0%
INSPECTION OVERVIEW
Report Number: Date:
Contractor: Start Time:
Project Title: Duration:
Report by (name): Report by (company):
Project Stakeholder Name & Company
Name:
Attendance
NEOM
PMC Name:
Contractor Env Manager Name:
Contractor (Others) Name:
Critical
Summary of Critical Environmental Issues Observed
Issue #
1
Rank in order of
criticality
24%
32%
68%
76%
Status
Inser
t
• Record all actual and potential environmental issues observed during the inspection • Describe the action that is required to address the non-compliant condition observed • Insert a representative photo of the non-compliant condition
sequ
• Observations should appear on the report in the chronological order in which they were observed on site • Actions should be specific – avoid inputting multiple actions against a single observation observed.
entia
• Observations may require multiple actions to address the non-compliant condition. In such cases, repeat the • Where an action has been completed to the satisfaction of the inspection lead, strike- • In the photo, capture where environmental impact has
l
observation, but with a different ‘Action Required’ to rectify the observed condition through to indicate that the action has been closed occurred where applicable
num
ber
Inspection Observations
Area 1
DD Month YYYY
Not Completed
Corrective actions required to
Low
1. Observation details / description rectify the non-compliant
observation
Current Observation
04 February 2020
Absence of wood dust collection during Provide plastic sheeting, etc. to
Low
2. table saw operations collect wood dust
Current Observation
04 February 2020
Chemical container at point of use Ensure all chemical containers (at
Low
3. without containment / drip tray point of use) have drip trays
28 January 2020
Corrective actions required to
Medium
Closed
4. Observation details / description rectify the non-compliant
observation
28 January 2020
5. Food waste litter near to food waste skip unattended to prevent dogs and
vermin, remove waste litter
Area 2
6.
Report Generated
Signature Report Date:
by:
Note:
• The ‘Closure Rate’ is a measure of Contractors ability to successfully address previously identified observations and conditions.
• The Closure Rate is calculated as follows:
o Total number of observations made during the previous inspection = A
o Total number of observations made during the previous inspection not observed during the current inspection = B
o Total number of observations successfully completed = C
o Total number of observations which have not been completed as observed during the current inspection = D
o (A - B) = E
o C / E x 100 = Closure Rate (Closed)
o D / E x 100 = Closure Rate (Not Completed)
• Previous observations on the report which have been assigned a “Closed Status” are highlighted as such and will be deleted from the next report for the
same location. This allows for all location specific observations to be tracked to closure.
ENVIRONMENTAL PROCEDURE
1. INTRODUCTION .....................................................................................................................33
2. PURPOSE ...............................................................................................................................33
3. SCOPE ....................................................................................................................................33
4. ROLES AND RESPONSIBILITIES .........................................................................................33
5. PROCEDURE..........................................................................................................................33
5.1. NEOM Approach to Environmental Performance Management ............................................ 34
5.2. Performance Management Measures and Models ................................................................ 34
5.2.1. Targeted Performance Model ................................................................................................. 34
5.2.2. Escalation Performance Model .............................................................................................. 34
5.3. Performance Measurement Procedure .................................................................................. 35
5.4. Performance Management Mechanism ................................................................................. 35
5.4.1. Improvement Notice (IN) ........................................................................................................ 35
5.4.2. Prohibition Notice (PN) ........................................................................................................... 36
5.4.3. Stop Work Notice (SWN) ........................................................................................................ 36
RELATED DOCUMENTS .......................................................................................................37
APPENDICES .........................................................................................................................38
APPENDIX A. TARGETED MODEL SUMMARY..................................................................................38
APPENDIX B. ESCALATION MODEL SUMMARY ..............................................................................39
APPENDIX C. PERFORMANCE MANAGEMENT FLOWCHART .......................................................40
APPENDIX D. ENVIRONMENTAL IMPROVEMENT NOTICE .............................................................41
APPENDIX E. ENVIRONMENTAL PERFORMANCE MANAGEMENT REGISTER ............................43
APPENDIX F. ENVIRONMENTAL PROHIBITION NOTICE .................................................................45
This Environmental and Social Performance Management Procedure has been developed to manage
Contractor environmental performance and to change norms of construction industry environmental
stewardship by encouraging changes in behaviour and attitude towards environmental compliance.
Contractor performance deficiencies present risk to desired environmental outcomes and to NEOM’s
environmental vision and values.
2. Purpose
This procedure describes the process by which EMPLOYER manages Contractor’s environmental and
social performance. This process allows performance deficiencies to be identified and addressed in a
structured manner.
3. Scope
3. EMPLOYER
a. Administration and implementation of the Environmental Performance Management
System
5. Procedure
1. The environmental performance of the Contractor is monitored and reported by the Proponent and
their Representatives.
2. Performance is assessed against the Contractor’s environmental compliance obligations as well
as legal compliance.
3. The following section describe the six elements that are used by the EMPLOYER to monitor
Contractors’ Environmental Performance:
Measurement of Contractors
What is assessed Performance Metric
Performance
Daily Site Inspections Site conditions / work activities Observational Data
1. To manage the performance of Contractors, the proponent may issue the following mechanism(s):
a. Improvement Notices (INs);
b. Prohibition Notices (PNs);
c. Stop Work Notices (SWNs);
Targeted Model
1. An IN will be triggered when Metrics and KPIs emanating from Weekly Inspections, EMS Audits are
deemed to trigger the need for an IN, or when environmental monitoring data indicates that
environmental standards (NEOM Standards or KSA Environmental standards) are exceeded.
2. EMPLOYER or NEV shall issue an IN using NEOM Environment Improvement Notice template
(NEOM-NEV-TGD-701_FRM03).
3. The IN shall be formally communicated to the EMPLOYER and the Contractor Project Manager.
4. EMPLOYER shall log the IN in a Central Performance Management Register.
5. The Contractor must implement the corrective actions stipulated in the IN within the timeframe
stated.
Escalation Model
7. An Improvement Notice is the first step in the Escalation process. Should the contractor fail to
implement the actions stipulated in the IN within the timeframe, the issue shall be escalated by
transferring it into a higher-level mechanism (Prohibition Notice).
Targeted Model
1. A PN will be directly triggered when a site observation of a specific activity or imminence of harm
than that of an IN, is identified. A PN may also directly triggered when Metrics and KPIs emanating
from Weekly Inspections, EMS Audits relating to a specific activity are deemed to trigger the need
for a PN, or when environmental monitoring data indicates that environmental standards are
exceeded by a particular activity.
2. The issuance of a PN will be authorized by the EMPLOYER. EMPLOYER or NEV shall issue the
PN using NEOM Environment Prohibition Notice template (NEOM-NEV-TGD-701_FRM05).
3. The PN shall be communicated to the same group as for an IN along with the NEOM Sector Chief
Executive Officer and Contractor Project Director.
4. The Contractor must immediately stop the prohibited activity and implement actions stipulated in
the PN, or by means of changing his approach to reduce the risks and imminence of harm to the
environment to an agreed acceptable level set out in a Remedial Plan, as agreed with NEOM, within
the timeframe stated in the PN.
5. EMPLOYER shall log the PN in a Central Performance Management Register.
6. EMPLOYER shall review efficacy of corrective actions implemented by Contractor and if deemed
suitable shall update the Central Performance Management Register to reflect closure of PN.
Escalation Model
7. A Prohibition Notice (PN) is issued when an Improvement Notice is not adhered to and observed
non-compliances or environmental limit exceedances are continuing beyond the timeframe stated
in the IN. Should the contractor fail to implement the actions stipulated in the PN within the
timeframe, the issue shall be escalated by transferring it into a higher-level mechanism (Stop Work
Notice).
1. A Stop Work Notice (SWN) mandates either that all works on the Project must cease temporarily
until NEOM is satisfied that the issue has been resolved, or that all works deemed to be causing a
particular unacceptable level of risk or imminence of harm to the environment must cease.
2. The Contractor must immediately stop the works as per the SWN and develop and submit an
Investigation Report and Remedial Plan for approval by NEV before implementing the activities
detailed therein. The Report and Plan should ensure the risks and imminence of harm to the
Escalation Model
4. A SWN is issued when a Prohibition Notice is not adhered to and observed non-compliances or
environmental limit exceedances are continuing. Should the contractor fail to implement the actions
stipulated in the SWN within the timeframe, the issue shall be escalated by transferring it into a
higher-level mechanism.
6. Related Documents
PART C – Actions and Timeframe Required for Improvement Notice Closure (Completed by NEOM Environment)
Actions to be implemented for the Improvement Notice to be closed: Timeframe for Completion
24 hours ☐
48 hours ☐
72 hours ☐
7 calendar days ☐
NOTE: If the actions in PART C are not effective or not completed on time, the issue will be escalated as per NEOM’s Performance
Management Procedure, up to and including a Stop Work Notice.
PART D – Required Contractor Submission (Completed by NEOM Environment)
After implementing the actions detailed in Part C within the specified timeframes, Contractor shall, with 48 hours, respond in writing to
this Improvement Notice describing the actions taken with supporting evidence of implementation (photos, documents, reports, etc). If
timely and effective implementation occurs with submission of supporting documents within 48 hours, NEOM will complete PART F of this
form and re-issue it to the Contractor, closing the improvement Notice.
PART E – Improvement Notice Issuance (NEOM) PART F – Improvement Notice Closure (NEOM)
Name Name
Position Position
Signature Signature
Stamp Stamp
Environmental Outcome required for the Prohibition Notice to be closed Timeframe for Completion
48 hours ☐
72 hours ☐
96 hours ☐
7 calendar days ☐
NOTE: If the Rectification Plan in PART C is not sufficient or is not implemented effectively or in time, the issue will be escalated as per NEOM’s
Performance Management Procedure, up to and including a Stop Work Notice.
PART E – Prohibition Notice Issuance (NEOM) PART F – Prohibition Notice Closure (NEOM)
Name Name
Position Position
Signature Signature
Stamp Stamp
ENVIRONMENTAL PROCEDURE
1. INTRODUCTION .................................................................................................................... 33
2. PURPOSE .............................................................................................................................. 33
3. SCOPE ................................................................................................................................... 33
4. ROLES AND RESPONSIBILITIES ........................................................................................ 33
5. PROCEDURE......................................................................................................................... 33
5.1 NEOM Approach to Environmental Performance Management ............................................34
5.2. Performance Management Measures and Models ................................................................34
5.3. Performance Measurement Procedure ..................................................................................35
5.4. Performance Management Mechanism .................................................................................35
6. RELATED DOCUMENTS ...................................................................................................... 37
7. APPENDICES ........................................................................................................................ 38
5.1. Environmental and Social Management System (EMS) Audits Procedure ...........................50
5.1.1. PHASE 1 – PRE-AUDIT ........................................................................................................ 50
5.1.2. PHASE 2 - DAY OF THE AUDIT ........................................................................................... 51
5.1.3. PHASE 3 - POST-AUDIT ....................................................................................................... 52
5.2. Compliance Obligation Audit Procedure ................................................................................52
5.2.1. PHASE 1 – PRE-AUDIT ........................................................................................................ 52
5.2.2. PHASE 2 - DAY OF THE AUDIT ........................................................................................... 53
5.2.3. PHASE 3 – POST AUDIT ...................................................................................................... 53
APPENDIX A. NEOM CONSTRUCTION ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)
AUDIT GUIDELINES.............................................................................................................. 55
APPENDIX B. GUIDELINE FOR COMPLETING EMS AUDIT CHECKLIST .................................. 56
APPENDIX C. GUIDELINES FOR APPLICATION OF EMS AUDIT CHECKLIST SCORES ......... 57
APPENDIX D. NEOM ENVIRONMENT AND SOCIAL MANAGEMENT SYSTEM (EMS) AUDIT
CHECKLIST ........................................................................................................................... 58
APPENDIX E. NEOM CONSTRUCTION ENVIRONMENTAL AUDIT REPORT ............................. 62
EMPLOYER conduct audits of Contractors to check their documents and records to determine
compliance against standards and regulations. During the audit, procedures and management systems
documents and records of environmental relevance are examined to ensure that robust processes are
in place.
2. Purpose
This procedure has been developed to describe the process by the EMPLOYER conducts scheduled
Environmental Audits of Contractors at NEOM.
3. Scope
This procedure relates to all Environmental and Social Management System (EMS) Audits and
Compliance Obligation Audits conducted by and on behalf of NEOM Proponents.
1. EMPLOYER
a. EMPLOYER to request in writing that Proponent nominate a Lead Auditor.
b. EMPLOYER, in consultation with Proponent, to set the Audit Schedule and send to
Contractor as per the requirements in section 6 below.
2. Contractor
a. Facilitate and host the audit team by ensuring the appropriate facilities are provided within
which to conduct the audit.
b. Ensure that all documentation and source information is available and provided to the audit
team on request.
3. The full description of Audit roles and responsibilities are given throughout sections 5 Procedure
and 6 Related Documents.
5.1.1.Phase 1 – Pre-Audit
In advance of the audit, the following actions shall be followed:
1. An EMS audit schedule shall be maintained for the project. EMPLOYER shall be responsible for
generating and maintaining the audit schedule. The EMS audit schedule shall, prior to distribution,
be shared with NEV for review and approval. EMPLOYER shall distribute the approved Monthly
Construction Environmental Audit schedule to relevant project Contractors, NEOM Proponent and
NEV.
2. The following principles shall be applied when compiling the Audit Schedule:
a. The first EMS of any Contractor’s project shall be conducted not later than 100 days after
contract award
b. From the date of the first formal EMS audit of a Contractor’s project, Audits will be
conducted thereafter on a six-monthly basis.
3. EMPLOYER shall send an EMS Audit Outlook Calendar invitation to the EMS Audit Party Members.
The scheduled date of the EMS Audit shall correlate to the date specified on the Monthly
Construction EMS Audit Schedule, which is prepared by EMPLOYER. Contractors shall be given a
minimum of 2 weeks advanced notification of a scheduled audit. A copy of the EMS Audit Checklist
should be attached to the calendar invitation.
4. The date of the EMS Audit on the calendar invitation should correspond to the date provided on the
Monthly Construction EMS Audit Schedule.
5. Calendar invitations shall be distributed at least 2 weeks in advance of the audit date.
6. The EMS Audit Party Members which shall be invited shall include:
a. Contractor Environmental Manager
b. EMPLOYER Environmental Manager (or designate) assigned to that particular Contractor
Site
c. NEV personnel assigned to the Contractor site
d. Proponent assigned to that particular Contractor Site.
7. Audits shall commence at the scheduled time, unless otherwise agreed in advance by all Audit
party members. Any changes to the scheduled time must be communicated at least 24 hours in
advance to all audit party members.
8. Contractor Environmental Manager, as the auditee, is responsible for ensuring access is available
to all documents and records detailed on the EMS Audit Checklist and requested by the Auditors.
Contractor Environmental Manager EMPLOYER shall therefore ensure that, in advance of the
audit, all documents, records and files are presented to the audit party in an orderly and systematic
manner.
1. On completion of the Construction EMS Audit Report, the EMPLOYER shall save the document
using the file name format – ‘Construction Environmental Management System Audit Report -
Project Name-YYMMDD’ (Project Name should be amended to reflect the project site which the
EMS Audit checklist relates to. YYMMDD should be amended to reflect the date, using the specified
format – for example, 4th July 2019, would be represented as 190704)
2. The NEOM Construction Environmental Audit Report is a summary of Audit findings.
3. Audit findings can be categorised as following:
a. Category 1 – Non-conformance - Breaches of legislation, significant deviation from client /
project requirements, and non-compliances which pose significant operational /
reputational risk to the client / contractor.
b. Category 2 – Improvement Opportunity - Suggestions for improvements to process /
documents / records based international best practice.
c. For each Category 1 non-conformance reported, the Contractor must raise a Non-
Conformance Report (NCR) to manage the change process required to achieve
compliance with NEOM requirements.
4. The EMS Audit Report contains data that can be analysed to identify and highlight actual and/or
emergent trends of non-compliance. NEV reserve the right to request EMPLOYER provide this
data, in a format defined by Proponent, within reasonable timeframes.
5. EMPLOYER shall ensure that the EMS Audit report is compiled, reviewed, finalized, and emailed
to Proponent personnel before COB of the third calendar day following the Audit.
6. Proponent personnel assigned to that construction site will review the document and, where
necessary, provide comments in a report, which must be addressed by the EMPLOYER prior to
distribution of the report. EMPLOYER shall co-ordinate closely until the report is to a standard
where is can be submitted to the Contractor.
7. EMPLOYER shall email the Construction Environmental Management System Audit Documents –
EMS Audit Report and Checklist – to the Contractor. EMPLOYER shall co-ordinate with Document
Control personnel to ensure that Inspection Report Documents are uploaded onto Aconex and
submitted to relevant parties as per project requirements.
8. Contractor shall submit a close out action plan to EMPLOYER with 7 days of receipt of the audit
report. The close out action plan shall provide proposed corrective actions for each Non-
conformance along with proposed dates for implementation of the corrective action.
9. Contractor shall ensure, that for each Category 1 Non-Conformance reported, raise a Contractor
NCR (Non-Conformance Report). The Contractors NCR is a mechanism for contractor change
management.
10. The Contractor shall address the non-compliances from the Audit as per the proposed close out
action plan. The contractor shall provide EMPLOYER with the close out evidence once all corrective
actions have been implemented.
11. EMPLOYER shall review the close out evidence to verify and validate that all audit findings have
been closed.
5.2.1.Phase 1 – Pre-Audit
1. The contractor shall develop a compliance obligation register for the project site based on the
Environmental Permit/Accord Compliance obligations.
2. Contractor shall provide a copy of the project Compliance Obligation register to EMPLOYER for
review and approval.
1. Ethical conduct
a. Auditors shall demonstrate their professionalism, employing confidentiality and discretion
in their duties. They also shall demonstrate integrity in their work and to develop trust with
auditees.
2. Fair presentation
a. The auditor shall report truthfully and accurately. This will include the elaboration of
difficulties encountered during the audit.
3. Due professional care
a. The auditors shall demonstrate care in their work. This should reflect the trust placed in
them by the auditee.
4. Independence
a. Auditors shall be entirely objective and ensure that only audit evidence influences the audit
findings.
5. Evidence-based approach
a. Audit evidence must be verifiable and deliver reliable and reproducible audit conclusions.
Auditor Guidelines
1. Part 1 is the “Header”. The Header contains information relating to the date of the Audit, the
Contractor site being audited, date of audit, those who were part of the audit and the name of the
person completing the checklist.
2. Part 2 is the “Audit Check Items”. This section consists of a total of 10 question topics.
A. The checklist consists of a series of questions, against which the EMS shall be assessed. The
checklist is a summary of the requirements specified in NEOM EMS Template.
B. See Appendix C for guidance on how to score the questions, 0, 5 or 10
C. Items on the checklist which are not relevant should be marked as NA. Please note – Do not place
N/A, N-A or N.A. on the checklist – only NA will be suitable and allow the formula to calculate
correctly.
D. The majority of ‘cells’ on the checklist are ‘locked’. The only cells which are not locked are those
within which the scores for each individual question are entered. The content of locked cells cannot
and should not be changed.
E. Each section of the checklist (there are 10 sections in total) will automatically total.
F. Having inputted all of the scores to applicable questions and inputted all the ‘NA’ to non-applicable
questions, a ‘Final Score’ is automatically computed on page 1 of the checklist.
G. The ‘Summary Table’ on the checklist automatically calculates the percentage score of each
individual section and the ‘Final Score’
H. Refer to Appendix D for the EMS Audit Checklist.
AUDIT OVERVIEW
Report Number Date
Contractor Start Time
Project Title Duration
Report by (name): Report by (company):
Project Stakeholder Name
Attendance
NEOM Name:
PMC Name:
Contractor Env Manager Name:
Contractor (Others) Name:
# Topic % 10
1 Previous EMS Audit Follow up
9
2 EMS Manual
8
3 Environmental Documents
4 Training 7
5 Resources 6
6.1 Waste Management
5
6.2 Resource Consumption
6.3 Maintenance Records 4
7.1 Environmental Inspections 3
7.2 Dust Monitoring
2
7.3 Noise Monitoring
8 Evaluation 1
Environmental Incidents / 0
9 Investigations 31-05-2016
10 Emergency Preparedness
CAT1 CAT2
Total
1. AUDITOR AIDE-MEMOIRE
Opening Meeting (should cover the below items (taking no longer than 10 • Close-out Meeting (should cover the below items (taking no longer than 10
minutes)): minutes)):
DEFINITIONS
CAT-1 - Non-Conformance
Breaches of legislation, significant deviation from client / project requirements, and non-compliances which pose significant operational /
reputational risk to the client / contractor.
CAT-2 – Improvement Opportunity.
Suggestions for improvements to process / documents / records based international best practice or on the auditor’s experience.
• In the table below, detail non-conformances / opportunities for improvement observed during the audit
• Add additional rows as required
• For each CAT-1 non-conformance identified, the contractor must provide a detailed Non-Conformance Action Report (Template in Section 6)
• In the table below, add additional row as required.
• Previous EMS Audit Findings should remain on the table below. Most recent EMS Audit Findings should be listed at the top of the table.
• Please list all CAT-1 findings (Non-Conformances), followed by CAT-2 findings (Improvement Opportunity)
Date of Audit CAT-1 or
(dd.mm.yy) Checklist # CAT-2 Describe Non-conformance / Improvement Opportunity
Signature Block
Signed by Contractor Environmental Manager Date Signed by Contractor Project Manager Date
ENVIRONMENTAL PROCEDURE
1. INTRODUCTION .................................................................................................................... 49
2. PURPOSE .............................................................................................................................. 49
3. SCOPE ................................................................................................................................... 49
4. ROLES AND RESPONSIBILITIES ........................................................................................ 49
5. PROCEDURE......................................................................................................................... 50
6. RELATED DOCUMENTS ...................................................................................................... 54
7. APPENDICES ........................................................................................................................ 55
1. INTRODUCTION .................................................................................................................... 70
2. PURPOSE .............................................................................................................................. 70
3. SCOPE ................................................................................................................................... 70
4. ROLES AND RESPONSIBILITIES ........................................................................................ 70
5. PROCEDURE......................................................................................................................... 70
5.1. Identifying and reporting of the environmental non-conformance ..........................................70
5.2. Step 1 – EMPLOYER Issue a Non-conformance Report .......................................................71
5.3. Step 2 – Contractors describes corrective action they will implement ...................................71
5.4. Step 3 – EMPLOYER review the proposed corrective actions ..............................................71
5.5. Step 4 – Contractor implements the proposed corrective actions Environmental Manager ..71
5.6. Step 5 – Reviewing the effectiveness of the corrective actions and close-out ......................72
6. RELATED DOCUMENTS ...................................................................................................... 72
7. APPENDICES ........................................................................................................................ 73
APPENDIX A. NEOM ENVIRONMENT NON-CONFORMANCE REPORT..................................... 73
The NEOM Environment non-conformance process is primarily applied where deviations are found to
have occurred in relation to Contractor’s fulfilment of Employers Requirements or where management
systems failures have occurred. It is also used where implementation of a change management
process is required to return Contractors management practices to compliance.
2. Purpose
The purpose of this procedure is to define the process by the EMPLOYER identifies, report and record
environmental non‐conformances. The procedure also describes the process by which appropriate
corrective actions are taken to rectify identified non-conformances, while preventing their reoccurrence
in the future.
3. Scope
The NEOM Environment non-conformance process is applicable to all NEOM projects and to NEOM
Sectors, Consultants and Contractors.
5. Procedure
1. Where a non-conformance has been identified, EMPLOYER shall initially advise the relevant
Contractor and shall issue a Non-conformance Report (NCR) (NEOM-NEV-TGD-701_FRM07 –
Appendix A) to the Contractor.
2. The following information about the non-compliances shall be recorded within the NCR Form:
a. Description of the non-conformance,
b. The event that gave rise to the issuance of the NCR – audit; observation; etc,
c. Supporting documentation related to the non-conformance.
3. EMPLOYER shall log the NCR in the Performance Management Register.
1. On receipt of the NCR, the Contractor will complete section 2 of the NCR form.
2. The Contractor will develop and document a Change Management Action Plan (CMAP) which
describes the following:
a. What corrective actions will be taken by the contractor to address the non-conformance,
b. Who will be responsible for the corrective actions,
c. By when the corrective actions will be completed.
d. Contractors shall be aware that multiple corrective actions may be required to address the
non-conformance.
3. Contractor should consider the details provided in Section 2 of the NCR form the basis of a change
management action plan (CMAP), the implementation of which will deliver the required change to
address the non-conformance.
1. Upon receiving the returned NCR form with the proposed corrective action(s) detailed, EMPLOYER
shall review it to confirm and verify that:
a. It addresses all the identified problems of the non-conformance;
b. The time frames are suitable and acceptable; and
c. All the required tasks/actions are assigned to the correct person.
2. Once EMPLOYER is satisfied with the proposed corrective action, an approval shall be provided to
the Contractor to start with implementation process to address the identified non-conformance.
5.6. Step 5 – Reviewing the effectiveness of the corrective actions and close-out
1. EMPLOYER and NEV shall undertake a review to verify and assess the effectiveness of the
corrective action implemented by the Contractor after a pre-determined period of time.
2. On the successful closure of the non‐conformance, the Non‐Conformance Report shall be signed
off by EMPLOYER and the performance management register shall be updated to reflect closure
of non-conformance.
3. If the non‐conformance persists or gaps identified after the implementation of corrective action,
Proponent shall apply performance management and/or commercial mechanisms such as applying
penalties or withholding payment to address the non-compliant condition.
6. Related Documents
Supporting
Documentation
General Comments: