Facility Security Plan Awoba

Security

Facility Security Plan

Confidential

Facility Name: AWOBA FIELD

Author: James Ijoko

Local Acceptance & Sign-off Sheet

The contents of this document was prepared and accepted by:

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IGNATURE

N

AME

& T

ITLE _{James Ijoko}

C

OMPANY New Cross Exploration and Production Limited

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ATE

The contents of this document have been reviewed and accepted by:

S

IGNATURE

N

AME

& T

ITLE

C

OMPANY

D

ATE

The contents of this document have been accepted and approved by:

S

IGNATURE

N

AME

& T

ITLE

C

OMPANY

D

ATE

Table of Contents

Part 1...5

Document Management...5

1.1

Document Changes & Amendments...5

1.2

Document Distribution...5

1.3

FSP Review & Update Procedures...5

Part 2...6

Purpose of Document...6

2.1

Purpose...6

2.2

Scope of FSP...6

2.3

Reference Documents...7

Part 3...8

General Facility Information...8

3.1

Facility Information...8

Overview / Description of Facility...9

3.2.1 Facility View...10

3.2.2

Facility Location Map...10

3.3

Facility Security Structure...10

3.4

Physical Security Measures:...11

3.5

Significant Security Issues...12

Part 4...15

Threat Levels...15

4.1

Security Operating Levels...15

Part 5...18

Security Incident Response...18

5.1

Initial Security Incident Response Actions...18

5.2

Suspicious Activities...18

5.3

Initial Response To Acts Of Terrorism, Violence Or Bomb Threats...18

5.4

Security Incident Reporting Procedures...19

Facility Security Personnel...19

5.6

Roles and Responsibilities...22

5.6.1 Facility Personnel...22

5.6.2 Area Security Adviser...22

Part 6...24

Security Response Maintenance...24

6.1

Security Training...24

6.2

Security Drills and Exercises...24

Part 7...24

Security Incident Notification Requirements...24

7.1

Internal Notification References...24

7.2

External Notification References...26

Part 8...27

Facility Specific Instructions...27

SECURITY INCIDENT OR EVENT SEVERITY LEVELS...5

Incident level

Reporting...5

Written Incident Report(IR) within 30 minutes...5

SECURITY INCIDENT LEVEL CRITERIA...5

Incident Level...5

2.

Voluntary Principles on Security and Human Rights (VPSHR)...8

INDUCTION BRIEFING TO GOVERNMENT SECURITY PERSONNEL DEPLOYED TO

PROVIDE SECURITY COVER AT NEW CROSS E&P LOCATIONS...11

I certify that I have been briefed and understand the NEW CROSS guidelines on the following

topics, and my role in upholding the tenets of the guidelines...11

Part 1

Document Management

1.1

Document Changes & Amendments

This document is controlled, therefore all changes and amendments are made by the Area Security Adviser and authorised by the Security Operations Manager

The most recent changes to the document will always be recorded at the start of this table.

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1.2

Document Distribution

This FSP will be distributed to and retained by the Area Security Adviser. The document will be shared with the Operations Manager.

1.3

FSP Review & Update Procedures

The Area Security Adviser will review this FSP annually or more frequently if required by Operational or Organisational changes

Part 2

Purpose of Document

2.1

Purpose

The purpose of this FSP is to assist Facility personnel prepare for and respond quickly and safely to an actual, potential or perceived Security incident originating at or near the Facility.

A Security incident is generally defined as an incident which breaches or compromises the integrity of the Facility and which may result in personal injury, theft of property, theft of information, environmental damage, asset damage, business disruption, business reputation or economic disruption in a particular area.

The Company shall provide adequate Security for the protection of people, property, information and reputation against all identified Security threats to the Company. The FSP recognises the need for:

 Physical Security requirements, policies and procedures for both routine and emergency activities and be in compliance with all applicable laws and/or regulations

 The identification of key/critical areas and addresses the level of protection required as determined by the Facility Specific Security Risk Assessment

 A comprehensive bomb threat response programme including search procedures and responsibilities.

 Procedures for reporting Security incidents in accordance with HSSE requirements.  Procedures for Security response(s) in an emergency or crisis. Plans shall be

coordinated with the appropriate internal departments, Government agencies and industry mutual aid organisations.

 Procedures for ongoing employee and contractor Security awareness training programmes.

 Procedures for compliance with the requirement for drills and exercises to be undertaken annually or as may be required by applicable laws or regulations.

2.2

Scope of FSP

This FSP contains prioritised procedures for Facility personnel to adapt Facility operations to changing Threat Levels, as determined by the Company, and to respond to actual, potential or perceived Security Incidents or threats to the Facility, persons at the Facility or Facility operations. Examples include:

 Unauthorised access

 Bomb threats/suspicious packages  Terrorist acts

 Thefts  Vandalism  Violent Crime

Part 2

Purpose Of Document

2.3

Reference Documents

This document provides guidance on how to comply with Security Standards and related guidelines.

Part 3

General Facility Information

3.1

Facility Information

Facility Name:

AWOBA FIELD

Facility Owner Name:

NEW CROSS E&P

Physical Address:

AWOBA

Part 3

General Facility Information

Overview / Description of Facility

3.1 AREA

The Awoba field is situated in awoba, Rivers state.

3.2 FACILITY DESCRIPTION:

There is a sentry post and access control is carried out by the station wardens. There is one entry point and one emergency exit in the facility enclosed within a 2.4 Citadel fence with 0.5 razor/barbed wire top. Perimeter lighting is also feasible. The flow station has inlet and gas lift manifolds, metering skid, process area comprising of separators, pump house, saver pits and scrubber on a skid.

3.3 FACILITY CRITICAL ASSETS

o Personnel – New Cross Staff, Contractors. o Flow lines, Manifolds, and wells

3.4 PERSONNEL:

o New Cross Personnel with average POB of six per day on a normal routine work day.Forty and above during shutdown activities.

o Contractor personnel o Visitors

Part 3

General Facility Information

3.2.1 Facility View

Part 3

General Facility Information

3.3

Facility Security Structure

FACILITY SECURITY ORGANIZATION

Part 3

General Facility Information

3.4

Physical Security Measures:

 Presence of static guards around the vulnerable wells like 10 and 13.

 Perimeter lighting around the flow station.

 Citadel fencing with razor/barbed wire top.

 The facility



Part 3

General Facility Information

3.5

Significant Security Issues

3.5a. Threat Assessment.

Assessed threat at Awoba as at 22 December 2015.

LOW

MEDIUM

HIGH

EXTREME

Threat

Low

Medium

High

Extreme

Violent Crime _H7 Organized Crime _M6 Militant/Targete d Activism L3 Civil Unrest _M4 Armed Conflict _M5 Theft of Information L2 Terrorism _L3 Others n/a

3.5b. Risk Assessment

Legend:

P = Probability I = Impact ARL = Assessed Risk Level

E=Extreme H=High M=Medium L=Low U=Unlikely

SOM-Security Operations Manager ESR-External Security Relations ASA-Area Security Advisor DSS-District Security Supervisor

CRO-Community Relations Officer ERT-Emergency Response Team KMT-Kidnap Management Team, GMS –General Manager Security

S N

SECURITY

THREATS P I CONTROLS/MITIGATING MEASURES

ACTION PARTY ARL WITH COUNTER-MEASURES IMPLEMENTE D 1 Violent Crime (Armed Robbery, Piracy, Kidnapping, Carjacking, workplace violence etc) H H

Effective and adequate security

guarding (Static & Mobile Patrols). ASA/DSS

MEDIUM Provision of a hardened ‘Safe Haven’ Asset

Manager Implementation of effective Journey

management

Asset Manager Use of Security Vessels for all Marine

movement to offshore facilities and crude loading activities.

ASA/DSS Security briefings for new arrivals ASA/DSS All staff briefed on Threats and

‘Security Reaction Guidelines’ regularly.

ASA/DSS

First Aid training for staff Asset

Manager Kidnap Management Team (KMT)

available. SOM

2 Organised Crime (Asset Theft, Fraud, Bunkering)

M M Effective Access Control(ID cards for all staff and contractors

ASA/DSS MEDIUM

Loss Prevention searches of outgoing personnel and vehicles

ASA/DSS

All Company property to be clearly

marked Asset Manager

Visitors to be Escorted ASA/DSS

3 Militant Activism (IED attacks, SAF Attacks) H H

Effective and adequate security guarding (Static & Mobile Patrols). Use of Security Vessels for all Marine movement to offshore facilities and crude loading activities.

ASA/DSS ASA/DSS

MEDIUM Regular updates for GSF on emerging

threats, tactics and procedures (TTP’s) used by adversaries.

ASA/DSS Withdrawing from, or reducing

operations during high-risk periods.

Asset Manager Provision of hardened ‘Safe Haven’ Asset

Manager

Use of SIS intelligence. ASA/DSS

Staff Security Awareness alerts and briefs.

ASA/DSS Security Emergency Response Team

available

ASA/DSS Daily POB monitoring and record

keeping by Site Supv and DSS.

Asset Manager/DS S

Evacuation plan in place Asset

Manager/AS A

Conduct Security drills as dictated by SOL Asset Manager/AS A 4 Civil/ Community Unrest (Work site invasion, Blockades, Strikes etc) M M

Obtain & confirm workable MoU & LTO/FTO

CRO

LOW

Use of SIS intelligence ASA/DSS

Good Community relations’ practices and strategy.

CRO Continuous liaison with Government,

Host Communities and Security agencies

CRO/ESR Evacuating staff and none essential

personnel during crisis periods. Asset Manager Employ local labour where applicable. Asset

Manager/CR O

Prompt payment of wages/salaries of community labourers. Asset Manager 5 Armed Conflict (Inter/Intra tribal/cult fighting, JTF Operations) L H

Journey Management. Asset

Manager

LOW

Use of SIS intelligence. ASA/DSS

6 Theft of Information (Industrial Espionage, Theft of propriety information

L H ‘Clear Desk’ Policy. Asset

Manager LOW

Securing of Sensitive information. Asset Manager

Adherence to IT Policies. Asset

Manager Awareness Briefings and training ASA

for Financial

gain) Access Control as per Security Operating Levels. Asset Manager/AS A

Part 4

Threat Levels

4.1

Security Operating Levels

The Group Security Operating Levels have been developed to provide facilities and regions with consistent, action-specific criteria that are in keeping with Company business needs and standards.

Security operations at this Facility will be conducted in accordance with the Group Security Operating Levels

Responsibility for initiating changes to the facility Security Operating Levels resides with the Security Operations Manager, based on consultation with the Security Intelligence and Surveillance (SIS) unit, while approval should be done by the Corporate Security Manage. The Security Operations Manager will inform the asset of changes in the SOP and the corresponding measures that will apply as a result of the changes. Changes are typically communicated by e-mail.

Corporate Security shall be responsible for interfacing with the appropriate Government agencies to obtain intelligence and/or threat information, and for advising management of the circumstances surrounding the issue of a Threat Advisory.

The Area Security Adviser shall be responsible for initiating the appropriate measures and actions in response to changes in facility Security Operating Levels and for maintaining contact with the various Government agencies.

This Security plan is based on escalating Security Operating Levels (SOL’s) with elevated mitigations at each level. The SOL are as follows (detailed mitigations at ANNEX 1): The current SOL for AWOBA is RED

BLACK

Lockdown and Emergency Response plan implemented

Trigger: Available intelligence and recent events indicate that armed conflict is

imminent; miscreants with an established capability are actively planning to attack the company or local area within a matter of hours or days. An attack is ongoing or

expected imminently.

RED

Elevated Mitigations and Monitoring

Trigger: Available intelligence and recent events indicate that miscreants, anti-government activists, or organized and/or violent criminals have an established

capability and current intent to operate against the target or targets of this nature. It is assessed that an incident is a priority for the above groups has been planned and is likely to be mounted against the Company or within the local area imminently.

AMBER

Increased Mitigations and monitoring

Trigger: Available intelligence and recent events indicate that miscreant,

anti-government or anti-industry activists, or organized and/or violent criminals have the capability to operate within the country and that an operation is within the group’s current intent. It is assessed that an incident is likely to be a priority for the groups but there is no available information to ascertain the timing.

GREEN

Baseline Security Performance Criteria (BSPC) implemented

Trigger: Available intelligence and recent events indicate that various groups have some capability to operate within the country and that such an incident would be consistent

with the groups’ general intent; or that they have the capability, but their intent is qualified by current circumstances. It is assessed that an attack is unlikely.

4.2 Security Resources.

Security Operating Level: BLACK Force Sy

Personnel Vehicles Porta-kabin APC SECURITY SPY SSS Community Guards Community Surveillance

Security Operating Level: RED

Force Sy

Personnel Vehicles Porta-kabin APC

SECURITY

16

5

1

SPY - -SSS - -Community Guards

6

- - -Community Surveillance

20

- -

-Security Operating Level: AMBER

Force Sy

Personnel

Vehicles Porta-kabin APC

JTF SPY - -SSS - -Community Guards

- - -Community Surveillance - -

-Security Operating Level: GREEN

Force Sy

Personnel Vehicles Porta-kabin APC

JTF -SSS - -Community Guards - - -Community Surveillance - -

-Resource Distribution

Location/Force SECURITY SPY SSS Community/ Contract_Guards

Main Entry Control Point

16

4

4

2

2

2

2

-

1

Access Control

4

3

2

1

Perimeter Patrols

6

4

4

3

2

2

2

Escorts

15

5

5

5

Quick Reaction Force

15

5

5

5

5.1

Initial Security Incident Response Actions

Initial response actions are those taken by Facility Security personnel immediately upon becoming aware of a Security incident. Timely implementations of initial steps are of the utmost importance as this can positively affect the outcome.

Facility Security personnel will refer to their Facility Standard Operating Procedures documentation for guidance on the appropriate actions to take in the event of a Security incident.

It is important to note that these actions are intended only as guidelines. The appropriate response to a particular incident may vary depending on the nature and severity of the incident. Note that, without exception, personnel and public safety is the first priority.

Facility Standard Operating Procedures documentation contains specific guidance on the following Security incidents:

5.2

Suspicious Activities

There are a number of circumstances, which classify as suspicious activity and are contained within the Facility Standard Operating Procedures documentation. In all cases the procedures for dealing with such incidents are laid down within those instructions. The overriding principles to be followed are the preservation of life, the prevention of injury and the protection of property.

All suspicious activities must be reported to the Security Control Room and Area Security Adviser immediately.

5.3

Initial Response To Acts Of Terrorism, Violence Or Bomb Threats

 Take appropriate personal protective measures.  Call for medical assistance if an injury has occurred.

 Advise personnel in the area of any potential threat and consider initiating evacuation/invacuation procedures.

 Inform the Emergency Services, Police, Fire and/or Ambulance

 Advise the Facility Manager of the incident which may affect the operation of the Facility

 Consider informing Emergency Response Co-ordinator with a view to calling a crisis management team meeting

Part 5

Security Incident Response

Guidance in the event of any of the above incidents occurring can be found within the Facility Standard Operating Procedures documentation.

Certain Security incidents (i.e. injuries/fatalities, fires/explosions, spills, etc.) may result in activation of the Local Response Team. In these situations the Facility Security personnel carry out their duties under the supervision of the Incident Commander and the Operations Superintendent to be assisted by the Area Security Adviser and in accordance with the Facility Standard Operating Procedures documentation.

5.4

Security Incident Reporting Procedures

Security incidents must be entered into the Fountain reporting system within 24 hours of the incident. Critical incidents, such as criminal or violent acts, bomb threats, thefts, drug/alcohol violations, threats and civil unrest must be entered immediately and notification made to the Area Security Adviser and Security Control Room. Reference within the Facility Standard Operating Procedures documentation is made in relation to the process/procedure to be followed.

The Security Control Room will collate the information provided and disseminate both internally and externally accordingly. The nature of the incident reported will determine to whom the information will be escalated within the Company and to relevant external organisations.

Facility Security Personnel

The Area Security Adviser generally serves as the focal point for all Security related matters at the Facility. The Area Security Adviser has the following additional organisational support:

5.5.1 The District Security Supervisor (DSS)

The District Security Supervisor (DSS) oversees the day-to-day deployment and supervision of all security personnel in the Facility. These include the Spy Police as the case may be, the Nigeria Police, the Nigeria Security and Civil Defence Corps (SECURITY), the Civilian/contract guard and any other GSF, if available. He is also responsible for the day-to-day management of their logistics requirement such as Porta-cabins, vehicles etc. His duties also cover the timely collation of timesheets and daily reports to the Area Security Adviser.

5.5.2 Supernumerary Police Office-in-Charge (SPY OC) (where applicable)

N/A

5.5.3 SPY Police and Nigeria Police Personnel

N/A

5.5.4 The Contract Security Guards.

Where applicable, Contract Security Guards shall be engaged to complement the work of the GSF. The number of guards at a particular time will be based on assessed need.

It shall be the duty of the Contract Guards to open the gates for staff, visitors and contractors who have legitimate need to come into the premises.

The Guards shall maintain access Control, especially in areas where there is no GSF presence. They shall screen visitors and conduct patrol of the premises and perimeter to ensure no unauthorized entry.

5.5.5 Government Security Force (GSF)

Appropriate number of GSF personnel will be deployed to Facilities. They are to be headed by an Officer who will be directly responsible for them in terms of command and control. The main responsibility of the GSF personnel deployed to Facilities is to protect the personnel and facilities against any form of armed attack. This protection is extended to visitors and contractors living and/or working within the facilities’ perimeter fence. In doing this, the GSF personnel are expected to comply with Guidelines on the Use of Arms, and the Voluntary Principles on Security and Human Rights (VPSHR)

Other duties to be performed by the GSF include:

- Provision of Swift Operations Service (response) in the event of an emergency.

- Armed protection to the facilities and personnel against any external aggression.

- Provide armed response where needed.

- Provide escort duties for movement of designated persons.

- Taking active part in emergency response activities within and outside the Facilities

- Assisting in the procurement of Intelligence, - Apprehension of offenders.

Deployment Plan Overview

 Please refer to security resources.

5.5. 6. Nigerian Navy:

Part 5

Security Incident Response

5.6

Roles and Responsibilities

5.6.1 Facility Personnel

All NEW CROSS Staff and contracted employees have a personal responsibility for their own, their colleagues and the Company’s Security. To that end Facility personnel will:  Maintain high Security awareness and vigilance;

 Wear and visibly display Company identification cards at all times whilst on Company premises;

 Immediately report unauthorised access to the facility and restricted areas to Security;

 Immediately report introduction of prohibited weapons, incendiaries and explosives to Security;

 Immediately report unlawful acts that affect facility operations to Security;

 Provide information to the General/Facility Manager, The Area Security Adviser and law enforcement personnel in case of an incident affecting Security;

 Ensure known Security deficiencies are reported to the Area Security Adviser;  Avoid discussing facility specifics such as products handled, Security routines and

equipment with non-Company personnel;

 Safeguard Company supplied identification cards and documents and passwords;  Restrict the distribution, disclosure and availability of information contained in this

FSP to authorised personnel.

 Inform Security on organisational changes that affect contractor/visitors and full time employee (FTE) workforce with regard to authorisation and revocation of access rights.

5.6.2

Area Security Adviser.

The Area Security Adviser is assigned overall responsibility for ensuring that the FSP, procedures and programmes are implemented and maintained.

FACILITY

The Area Security Adviser may perform other duties within the Facility’s organisation, provided he or she is able to fully perform the duties and responsibilities required of the Area Security Adviser. The same person may serve as the Area Security Adviser for more than one facility.

The Area Security Adviser may assign Security duties to other facility personnel; however, he retains the accountability for these duties.

The Area Security Adviser must have general knowledge, through training or equivalent job experience in the following:

 Security organization of the Facility;

 Relevant Facility operations and conditions;

 Relevant Facility Security measures, including the meaning and the requirements of the different Threat Levels;

 Emergency preparedness, response, and contingency planning;

 Security equipment and systems, and their operational limitations; and

Part 5

Security Incident Response

The Area Security Adviser must also have knowledge of and receive training in the following, as appropriate:

 Relevant laws and codes, Group Security Standards and recommendations;

 Relevant Government legislation and regulations;

 Responsibilities and functions of local and National agencies;

 Risk assessment methodology;

 Methods of Facility Security surveys and inspections;

 Instruction techniques for Security training and education, including Security measures and procedures;

 Handling confidential sensitive Security information and Security related communications;

 Current Security threats and patterns;

 Recognizing and detecting dangerous substances and devices;

 Recognizing characteristics and behavioural patterns of persons who are likely to threaten Security;

 Techniques used to circumvent Security measures;

 Conducting and assessing Security drills and exercises,

The Area Security Adviser, for each facility for which he or she has been designated must ensure;

 That the Facility Security Risk Assessment is conducted and reviewed annually as required by Group Security Standards;

 The development and implementation of an FSP;

 That an annual self assessment is conducted and, if necessary, the FSP is updated;

 That the FSP is exercised;

 That regular Security inspections of the Facility are conducted;

 The Security awareness and vigilance of the Security personnel;

 Adequate training to personnel performing Facility Security duties;

 That occurrences which threaten the Security of the Facility are recorded and reported to the owner or operator and additional notifications as appropriate;

 The preparation, completion and submission of any reports;

 The coordination of Security services in accordance with the approved FSP;

 That Security equipment is properly operated, tested, calibrated, and maintained;

 The recording and reporting of attainment changes in Threat Levels to the owner or operator or applicable agency;

 Notification, as soon as possible, to law enforcement personnel and other emergency responders to permit a timely response to any transportation Security incident; and

Part 6

Security Response Maintenance

6.1

Security Training

The Area Security Adviser will implement and maintain the relevant training programmes at the Facility. These programmes will be specifically dependent upon the Security requirements for the individual Facility and the risks identified within the Security Risk Assessment. Detailed training records are to be retained at each Facility.

6.2

Security Drills and Exercises

Drills and Exercises are required to be undertaken at this Facility to comply with Group Security Standards. This enables the Area Security Adviser to identify any related Security deficiencies that may need to be addressed.

Annual drills and exercises will be documented to include the date, time, type of drill and/or exercise conducted, participants and duration.

Part 7

Security Incident Notification Requirements

7.1

Internal Notification References

INTERNAL NOTIFICATIONS – FACILITY SECURITY PERSONNEL

POSITION/TITLE

NAME

OFFICE

MOBILE

OTHER

Area Security Adviser Ops Superintendent District Security Supervisor

INTERNAL NOTIFICATIONS – GENERAL

POSITION/TITLE

NAME

OFFICE

MOBILE

OTHER

Sy Operations Manager, Control Room

Security Control Room

Part 7

Security Incident Notification Requirements

7.2

External Notification References

ADDITIONAL AGENCY REFERENCES

Police

EXTERNAL NOTIFICATIONS – SECURITY PERSONNEL

POSITION/TITLE

NAME

OFFICE

MOBILE

OTHER

SUPPORT RESOURCES

COMPANY

NAME

TELEPHONE

<Enter type of resource here e.g. CCTV Support>

N/A

<Enter type of resource here e.g. CCTV Support>

Part 8

Facility Specific Instructions

8.1 General Security Measures

o All Guards should undergo Initial Training which should include, but is not limited to: (1) office facility orientation, (2) duties and responsibilities, (3) access control procedures, (4) material identification and control procedures, (5) contraband/prohibited substances, (6) searches and inspections, (7) report writing, (8) evidence preservation, (9) patrolling and escort, (10) theft prevention and investigation, (11) emergency procedures, (12) basic first aid procedures, (13) Voluntary Principles on Security and Human Rights and (14) Use of Force guidelines.

8.2 Emergency Response

o A Security emergency response Team will be available as indicated in the Security Operating Level(SOL).

8.3 Patrolling

o Random Patrols of facility & Perimeter will be carried out at the frequency indicated by the SOL o Patrols will check the following:

o Integrity of the perimeter fence o Signs of unauthorized access

o Security of buildings and access points o Operation of Security lighting

8.4 Access Control

o Only staff and Contractors with a Valid Identification Card will be admitted to the Facilities.

o Visitors will have their Identification and reason for visit confirmed prior to being issued a Temporary access Badge.

o All personnel shall prominently display ID Cards while at the facility. ID Cards shall only be worn by the person to whom issued and shall not be exchanged for any purpose. o Escort of non-Company personnel shall be required in all critical, sensitive or hazardous

areas unless the individual has been cleared by the host in advance to enter such areas without escort. Visitors should be escorted whilst on Company premises; their host will be responsible for their safety and security for the duration of the visit.

o Staff should challenge any person not displaying a proper ID. o ID cards, holders and lanyards should not show the Company logo.

8.5 Search

o All personnel and vehicles entering the Facilities will be required to submit to a physical search of person and baggage.

o Frequency of searches is to be dictated by the SOL.

o Personnel refusing to be searched will not be permitted access to the Facilities.

o Searchers will use a combination of technical(Metal detection and x-ray) and physical searches

o Searches will be focused on the identification of the following: o Improvised Explosive Devices

o Weapons

o Illegal narcotic substances o Alcohol

o Any person found to be in possession of the above will not be permitted entrance to the Facilities or will have the item confiscated and held before being granted access.

8.6 Loss Prevention

o Random Search of personnel and Vehicles leaving the Facilities will be conducted in line with the SOL.

o Property Removal Authorization passes will be required before Company property can be removed from the premises.

o The authority to approve the removal of Company property from facilities shall be limited to the Facility Manager and his or her designated representatives. Such delegations shall be made in writing and updated annually.

8.7 Key Control

o A key custodian will be nominated to account for all Facility keys o All keys will be identifiable and registered.

o Recipients of keys will acknowledge receipt and turn in of keys in writing.

o Keys are not to be duplicated without written permission from the key custodian.

8.8 Firearms

o Only Government Security Forces will be permitted to carry Firearms. o All firearms are to be loaded/unloaded in recognized bays.

8.9 Communications

o All manned positions and patrols are to have a suitable means of communication to a Supervisor

o There should be provisions for a back-up communications system in the event of a major disruption to, or failure of the primary system.

8.10 Security Drills

o Security drills will be carried out and recorded as per the Security Operating level. Suggested scenario’s for drills are:

o Community invasion

o Armed attack on Project site

o Unknown Persons sighted on the Facility

o

Suspicious package

8.11 Information Security

o At the end of the working day all Company classified information should be locked away. This includes documents and information on computer media and handheld digital devices. Classified information should not be left on whiteboards, notice boards or flip charts.

o During the working day laptop computers shall be secured with locking cables and out of office hours they shall be removed from the office or locked in a secure container. o All Company classified waste shall be securely disposed of by cross-shredding or by

other secure arrangements.

o A clear desk policy should be in place.

8.12 Mailroom Activities

o Personnel assigned mailroom duties will be provided training on the recognition of and procedures for handling suspicious mail and packages. Such training will address letter and parcel Improvised Explosive Devices(IED’s) as well as hazardous substances such as Anthrax and other Biological/chemical related threats

o The mailroom will be fitted with a suitable scanner to assist in the inspection of incoming mail

8.13 Cash and High Value Items

o Burglary-resistant safes shall be used for the storage of cash, negotiable instruments or other valuables. Fire-resistant safes shall be used for the storage of documents requiring protection from fire.

o Safes weighing less than 750 lbs shall be anchored to the building structure in accordance with the manufacturer's specifications.

o Dissemination of safe combinations, and/or keys, shall be strictly limited to those who require access to the contents. Safe combinations and/or locks shall be changed upon personnel re-assignments, or when the possibility of compromise exists.

o Storage of cash or other valuables should be kept to a minimum. A procedure should be established on how long and the amount of cash or other valuables that shall be kept in the safe. In principle cash or other valuables should be kept to a minimum. The procedure will also describe who is authorised to remove contents and how custody transfer will be handled and documented when moving cash or other valuables to another location.

8.14 Exterior Security Lighting

o Manned guard posts, which operate during periods of darkness, shall be provided with protective lighting sufficient to allow for the inspection of personnel and vehicles.

o Exterior building doors shall be illuminated with lights by the use of dedicated fixtures or area lighting.

o Area lighting shall be provided for all employee, contractor, and visitor parking areas which are utilised at night.

o In the case of area lighting, the average level of horizontal luminance must exceed that of the surrounding area by between 5 lux (with no lighting in the surrounding area) and 20 lux (with adjacent lighting).

o Facility Patrols will report any Security Lighting that is not working

8.15 Car Parking

o Vehicles will only park in authorised locations as dictated by the SOL o Car parking for employees shall be demarked from visitor parking.

o Access from the office building to the car parking areas shall be highly visible, free of obstructions and well lit.

o Employees shall lock and / or secure vehicles at all times when not in use or unattended. Except in an emergency, vehicles shall not be left unsecured and unattended while the engine is running.

o Vehicle keys shall not be left in the ignition unless required by local safety policy.

8.16 Incident reporting

o All security related incidents will be reported as per Annex 6 –Incident Reporting

8.17 Community Engagements

o In line with NEW CROSS policy as regards community negotiation, only the SCD team will carry out all engagements with the stakeholder communities to cover all spectrums of representations. The SCD Team shall fulfil all NEW CROSS approved payments (homage, etc) to respective lords and thereafter secure the required FTO before mobilization. This will foster understanding and mutual trust amongst all stakeholders thereby facilitating peaceful execution of the project. This process will sustain the FTO throughout the project.

8.18 RASCI Chart

Ser Task Responsible Accountable Supports Consulted Informed

1

Production of Security

Plan ASA SOM DSS AssetManager GMS

2 Approval of Security Plan SOM SOM Asset_Manager -

-3 Implementation_{Security Plan} of ASA/DSS SOM DSS/Asset_Manager -

-4 Changes to Security_Plan ASA SOM DSS/Asset_Manager -

LOGISTICS & TRANSPORTATION 8.19 Logistics

All requests for Security Logistics support are to be directed to the Security Operations & Logistics Co-ordinator

8.20 Driving

All vehicle activities will comply with Journey Management Procedure in line with NEW CROSS guidelines that shall include:

o Drivers’ pre-journey briefing o Approved routes and speed limits

o Outlining the responsibilities of drivers in an emergency situation. o Enforcing the no night driving/sailing policy.

o Ensuring first aids boxes with approved drugs are in vehicles o Briefing on use of seat belts by all passengers

o Ensuring fire extinguishers in vehicles

o Ensuring all relevant LGA stickers are in all vehicles, etc.

8.21 Guidelines for escorts with security details

o Driving within speed limits through communities

o Briefing drivers about the local knowledge of or relevant peculiarities of each Community they transverse.

MONITORING & CHANGES

o Security plan will be reviewed annually or on any change to threat levels

o Any changes to the Security plan will be submitted in writing to the DSOM for approval. Reductions in permanent contract security guard services at facilities (i.e. organisation and staffing ) shall be subject to the MOC process. The standard does not apply to the reduction or cancellation of temporary contract guard services employed as the result of a specific incident, issue or threat.

ANNEX 1

SECURITY OPERATING LEVELS ( generic)

Sy State

Level

Definition

Action

BLACK Evacuate/lockdown/Emerge_{ncy Response} Security incident(s) occurring that are_{directly impacting NEW CROSS}

Operations or its staff.

General

Implement Facility Shut Down Plan.

Evacuate all staff if possible, remainder to Safe Haven

Emergency Response

Armed Response Team deployed-reserve brought to Immediate Notice To Move(NTM)

Travel

Security authorized moves only or as per travel SOL.

Patrolling

Continuous Patrols of facility & Perimeter

Access Control

Authorization List to be produced and only staff on the list to be granted access to Facility and Critical locations.

No Contractor’s admitted

.

All Access Gates and Building entry’s locked(keys to be held locally).

Parking

No parking within Facility. Search

100% Random search of personnel. 100%vehicles fully searched.

Loss Prevention

All stores secured, no stores to be issued/received

Communications

Full Situation Reports to be sent every 30 mins.

RED _{Elevated Security}

Security incidents resulting in loss of life occurring frequently in the area. Government Security forces engaged in Operations near to NEW CROSS Operations

This alert level may be activated on receipt of a specific threat and for a limited period of time.

General

Busines Critical staff only on site. GSF to Secure all Critical/Vital Areas

Emergency Response

Armed Security Response Team available-Immediate NTM, Reserve Team to be brought to 15mins NTM Travel

Management and Security authorization required. Mitigations will be subject to Travel SOL.

Patrolling

Patrols of facility & Perimeter (minimum of 1 round every 1 30mins).

Access Control

Use of temporary anti-intrusion obstacles – chicanes, additional barbed wire, trucks, concrete blocks

Staff

100% visual (Technical if available) check of all entries to all buildings and restricted areas

Visitors/Contractors

Written request to be submitted by contracting Company and approved by Security Management prior to issue of badges.

Visitors/Contractors to be Escorted at all times while on the Facility Main Entrance gates to be locked when not in use(key to be held locally)

Parking

No parking within 25m of buildings.

No parking of contractors vehicle within facility.

Search

50% Random search of personnel.

50%vehicles fully searched.

Loss Prevention

Manned Guarding at stores locations.

Key Control

100% accounting and Key Register to be

inspected daily

Communications

Comms check to Control Room every 4 hours Alternate comms check twice daily to Control Room

AMBER Security advised

Major security incidents occur infrequently in the area

Increased and visible security forces activity

Non-specific threats against Operations & Staff

Potential for civil unrest

Embassies issue periodic warden messages or warnings

Threats and actions against other IOC’s in area

General

Minimum Manning at Facility

Safe Haven to be identified and hardened Emergency Response

Security Response Team available - 2 mins NTM

Travel

Security Escorts to be used for persons at risk(PAR)in line with Journey Management plan.

Movement restricted to Security approved routes.

Daylight movement only(Waiver required for nighttime movement) Other Travels as per Travel SOL.

Patrolling

Random Patrols of facility & Perimeter(Minimum 1 per hour)

Access Control

Establish Forward Checkpoint at ECP

Staff

100% visual (Technical if available) check of all

entries to Facility and at entrance to identified restricted areas Visitors/Contractors

ID Confirmation & Issuance of visitors passes

Parking

Parking in identified locations only

Search

50% Random search of personnel.

100% Random search of vehicle boots. 1/25 vehicles fully searched.

Full Search personnel & vehicle search for cause.

Loss Prevention

Manned Guarding at stores locations

Key Control

100% accounting and Key Register to be inspected weekly

Firearms

Law Enforcement/ Government Security Forces Only

Communications

Radio comms check to all manned locations every hour. Twice Daily comms check to Control Room

Alternate comms check twice daily to Control Room

GREEN No restrictions

Base Line Security

Little or no violent crime

Armed aggression events are rare Security Forces are in control

General

Global Security Standards Baseline Security Performance Criteria implemented

Emergency Response

Security Response Team available-5mins Notice To Move(NTM)

Travel

Day/Night movement in line with Journey Management. As per Travel SOL.

Patrolling

Random Patrols of facility & Perimeter(Minimum 1 per 2 hours)

Access Control

Staff

100% visual check of all entries to Facility Visitors/Contractors

ID Confirmation & Issuance of visitors passes

Search

1/50 Random search of personnel.

1/50 Random search of vehicle boots. 1/100 vehicles fully searched.

Full Search personnel & vehicle search for cause.

Loss Prevention

Random Search of Vehicles departing the Facility. Property Removal Authorization controls Implemented

Key Control

100% accounting and Key Register to be inspected monthly

Firearms

No Firearms to be permitted in the Facility

Communications

Radio comms check to all manned locations every 2 hours Daily comms check to Control Room

ANNEX 2

SECURITY CONTACT DETAILS

NAME CONTACT DETAILS TEL. NO

Security Operations Manager, ASA

FACILITY CONTACT DETAIL

DESIGNATION CONTACT NUMBER

Duty Manager Medical

Security – Police Control Room Fire

Oil Spill Response Team Operations Manager Operations Superintendent Operations Team Leader Operations Room Maintenance Team Leader Maintenance General office Clinic (NURSE)

District Security Supervisor HSE Adviser

Central Production Coordination

Center (CPCC)

CRO

Senior CRC

ANNEX 3

CASUALTY MANAGEMENT PLAN

CASUALTY IDENTIFIED AND FIRST AID APPLIED

CASUALTY REPORTED TO MEDICAL

MEDICAL VERIFIES NUMBER & TYPE OF CASUALTIES CASUALTY TREATED & INCIDENT REPORTED MEDEVAC REQUIRED? ROAD OR HELICOPTER?

DUTY DOCTOR REQUESTS MEDRESCUE OPs

DUTY PILOT ASSESSES FLYING CONDITIONS FLYING CONDITIONS OK? AMBULANCE DESPATCHED WITH SECURITY ESCORT TO COLLECT CASUALTY FIRST AID CONTINUED

HELICOPTER DESPATCHED TO COLLECT CASUALTY CASUALTY RECOVERED TO IA CLINIC & TREATED DUTY PILOT RE-ASSESSES

ANNEX 4

COMMUNITY DISTURBANCE RESPONSE PLAN

COMMUNITY DISTURBANCE

REPORTED ASA/DSS INFORMED

ASA/DSS REPORTS TO COMMUNITY LIAISON OFFICER / FACILITY MANAGER

ASA/DSS ENSURES SAFETY OF STAFF

CLO PROCEEDS TO MEET WITH COMMUNITY LEADERS

YES IS COMMUNITY

RESPONSE POSITIVE?

NO

STOP WORK ON SITE

CLO REPORTS TO FACILITY MANAGER

MANAGEMENT AGREES RESOLUTION MEASURES

CLO MEETS COMMUNITY

NO ISSUE RESOLVED? YES WORKERS RETURN / RESUME WORK

ANNEX 5

IED RESPONSE FLOW CHART

BOMB THREAT RECEIVED

OR SUSPICIOUS PACKAGE/VEHICLE OBSERVED

CONFIRM

BUILDING SEARCH/ INVESTIGATION OF SUSPECT PACKAGE/VEHICLE FALSE ALARM/ UNCERTAIN CONFIRMATION/ NOTHING FOUND/ ACTIVATE MEDICAL EVACUATION PLAN NO NO DEVICE EXPLODES CAUSING CASUALTIES? FAILED SEARCH/ UNCERTAIN CONFIRMATION MANAGEMENT DECISION

HOAX/FALSE ALARM OR FAILED SEARCH

STAND DOWN AND MONITOR SITUATION DEVICE CLEARED

CONTROL

IC AUTHORIZED PERSONNEL ONLY INTO THE CORDON

CORDON

 AT SAFE DISTANCE

OUT OF LINE OF SITE

CALL

 BOMB SQUAD

 LOCAL SUPPORT FORCES

HOAX/FALSE ALARM DEVICE FOUND AND CONFIRMED OR

CANNOT BE SAFELY DISCOUNTED

CLEAR

 INCIDENT COMMANDER(IC) NOMINATED



 IDENTIFY MUSTER POINT



 SEARCH PROPOSED MUSTER AREA

EVACUATE AREA TO MUSTER POINT USING ROUTES WITHOUT LINE OF SITE TO THE DEVICE

YES

ANNEX 6 – INCIDENT REPORTING

SECURITY INCIDENT OR EVENT SEVERITY LEVELS

Incident level

Reporting

I Catastrophic Security Leadership Team (SyLt) ASP by voice

Written Incident Report(IR) within 30 minutes II Critical SyLt ASP by text - Written IR within 1hour

III Marginal SyLt ASP by email - Written IR within 2 hour

IV Negligible Written IR within 4hours

SECURITY INCIDENT LEVEL CRITERIA

Incident

Level _Event

I

 Any event involving a staff death during, or as a result.

 Any event involving multiple serious injuries.

 Theft(Cost of loss exceeds US$100,000)

 Kidnapping of Company personnel or family members.

 Attack resulting in damage to Company Facilities.

 Any event involving Small arms or explosives at Company Facility.

 Any event involving attacks on air assets.

 VPSHR violations by GSF supporting Company operations

 Any event that may receive negative International media coverage

II

 Event involving single serious injury.  Theft (Cost of loss exceeds US$50,000)

 Attacks involving damage to Facilities within 1km of Company operations.

 Events resulting in injury to members of the Communities surrounding Company Facilities.  Direct attacks on GSF positions supporting Company operations.

 Illegal Roadblocks involving hijack or burning of vehicles.  Civil disturbances directed against Company operations.



Any event that may receive negative National media coverage

III

 Attacks on GSF in the vicinity of company operations.  Theft (Cost of loss exceeds US 5,000)

 Kidnappings of foreign personnel not involved in O&G sector operations.  Kidnapping of local leaders or industry counterparts.

 Attacks involving damage to O&G industry facilities in the general area of operations.  Civil disturbances in the general area of operations.

 Attacks against GSF in the general area of operations.

 Illegal Roadblocks not resulting in kidnap or destruction of property.



Any event that may receive negative Local media coverage

IV

 Minor civil disturbances with little threat of escalation outside of Company area of operations.  VPSHR violations by GSF not supporting Company operations

 Attacks on GSF installations or personnel outside of the Company general area of operations, but supporting the O&G sector.

 Attacks on industry counterparts outside the general area of operations.  Reports of roadblocks on main routes for critical cargo.

 Minor Theft(Less than $5,000)

INCIDENT REPORTING FORMAT

ADDITIONAL INFORMATION:

Any other relevant information

WHERE:

Exact Location of the Incident

(Facility name or reference to a Facility ie approximately 2km North of

---WHAT WE ARE DOING:

Details of Response.

Additional Requirements/support needed

WHAT:

Exact Details of the Incident:

Numbers of Casualties, do not name Injured Parties

Annex 7

Guidelines on the Voluntary Principles on Security and Human Rights

The Voluntary Principles on Security and Human Rights (VPSHR) provide practical guidance to companies, on how to maintain the safety and security of their operations, with respect for the human rights and fundamental freedoms of people in surrounding communities.

The implementation of the Voluntary Principles is a cooperation effort, which should involve all three participating pillars (government, companies, and NGO’s)

The Voluntary Principles covers three (3) key areas:  Risk Assessment

 Interaction between Companies and Government Security  Interaction between Companies and Private Security Companies are obliged to:

• check available human rights records of the security forces with which they work

• ensure that the type and number of forces deployed are competent, appropriate and proportionate

• record, report and investigate any credible allegations of human rights abuses • Where force is used, it should be properly investigated and reported.

Security Forces are obliged to:

• Attempt to use non-violent means to resolve issues before using force and firearms

• issue a warning and give sufficient time for suspects to heed that warning before resorting to the use of firearms

• provide medical aid for injured persons where force is used,

BRIEFING TIPS ON INDUCTION OF NEWLY DEPLOYED GSA

PERSONNEL AT NEW CROSS E&P LOCATIONS

1.

Ethical and legal law enforcement conduct

 Law enforcement officials must at all times perform their duty under law.

 They must respect and safeguard human dignity and uphold the human rights of all persons.  They may use force only when strictly necessary and to the extent required in the

performance of their duty.

 They are forbidden to inflict, instigate or tolerate any act of torture or other cruel, inhuman or degrading treatment or punishment.

 They have the duty to safeguard the health of those in their custody and to secure medical care whenever necessary.

 Suspected unlawful and / or unethical behaviour by law enforcement officials requires prompt investigation.

Arrest

and Detention

 The absolute prohibition on torture applies equally to all arrested, detained or imprisoned persons.

 Arbitrary arrest, detention or imprisonment is prohibited.

Maintenance of Public Order

 Firing indiscriminately into a violent crowd is never a legitimate or acceptable method of dispersing it.

 Law enforcement officials must avoid the use of force or, where this is not feasible, limit its use to the minimum.

DIVISION……….

ASSET TEAM………

FIELD LOCATON………

I certify that I have been briefed and understand the New Cross guidelines and my role in

upholding the tenets of the guidelines.

Serial No.

Name Unit Date Signature

Induction Conducted by:

Name……….

Sign/Date:………