Spill Reporting Requirements

Rev.1.1 December 2013

Purpose of Spill Reporting:

Hazardous materials at our facilities include large volumes of hazardous cargo, as well as oil and fuels and hazardous substances used in our operational activities including equipment, vehicle, and grounds maintenance. Spills may occur due to accidents (e.g. collisions, groundings, fires), equipment failure (e.g. pipelines, hoses, flanges), or improper operating procedures during cargo transfer or fueling, and involve crude oils, refined products or residual fuels, liquid substances, and substances in packaged form. Additionally, equipment maintenance may involve the use of potentially hazardous materials including solvents and lubricants. Our operations therefore pose a risk of accidental spills that have the potential to pollute water, soil and groundwater or affect human health. For transparency to our stakeholders and investors and management of environmental risk, APMM Group and APM Terminals require the reporting of spills. A. Spill Reporting Scope: 1. Spill reporting is required for all APM Terminals under operational scope. 2. All spills >20L and chronic leaks estimated to be greater than 20L / 24hrs should be reported using CMO, unless the spill was entirely contained within a device designed for this purpose e.g. secondary containment device (See Figure 1 for an example). 3. The total volume reported should represent the total estimated amount spilled. It should not be reduced by the amount subsequently recovered, evaporated or otherwise lost. 4. A spill is defined as an unintended / accidental releases of an environmentally harmful liquid including: - - - - - Petroleum (Oils, Fuels etc.) Chemicals (solvents etc.) Waste (e.g. Oily water) IMO Cargo Other substance with potential to harm the environment (e.g. items covered by Material Safety Data Sheet MSDS)

8. The following should be excluded from the reported data: - previously reported, spilled materials in the environment from historical losses (i.e. historical or past leakage/spills that reached the environment from tanks, pipes or other vessels, but not associated with a current release); and - hydrocarbons / chemicals in permitted discharges (e.g. wastewater effluents etc.). 9. Spills / leaks of chemicals in powder form should be reported based on an estimation of liters spilled.

Figure 1. Example of secondary containment.

B. Spill Investigation Procedure: 1. The region/facility is responsible to investigate the causes of each significant spill (defined as category 3-5 in the spill severity matrix) in line with the APMT safety incident investigation procedures, and apply appropriate remedial actions. All spills and contamination from spills should be handled in line with local regulation and industry best practice. Spills in severity categories 3-5 are automatically notified to corporate HSE. Severity Matrix Spills Category 5 4 3 2 1 Spill Quantity Spill >10,000 Litres Spill >1,000 Litres Spill >100 Litres Spill >10 Liters Spill <10 Liters Investigation procedures required

5. Reporting should include releases from operations and events including: - above-ground and below-ground facilities / equipment; - sabotage, earthquakes or other events outside operational control; and - company-owned and operated transport (including trucking that is under operational control). 6. Leakage over time, above ground or underground, is counted once at the time it is identified. 7. Where spills are to both land and water, the volume properly apportioned to each should be provided within the description of the event.

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