HSE Policy & HSE Management System

After an updating process necessary for the successful integration of MOL Group member companies, based on best practice and significant developments in the field, the new MOL Group HSE policy (principles and structure) was introduced in 2005 to improve HSE performance.

This policy represents the highest Group-level commitment to HSE Management and applies to all Business Units and MOL-controlled Subsidiaries as the basis for them to develop their own HSE objectives, strategies, goals and programs.

The policy is implemented gradually, by breaking down long-term goals (strategic goals and actions) into annual HSE objectives and strategies at MOL Group and lower levels to ensure that individual Unit efforts are in line with MOL Group principles.

Major HSE projects contribute substantially to the implementation of the HSE Policy. Efforts made to comply with the Major Industrial Accidents Prevention Act, within the Seveso project, help mitigate risk and reduce the consequences of accidents. MOL’s Safe Workplaces Project develops manager and employee attitudes and skills in relation to safety issues. These projects reflect our determination to improve overall safe working conditions for everyone, and to reduce HSE risks arising from our technology, operations and products to acceptable levels.

The key objective of the HSE-INFO system is to establish an efficient data management process that permits effective decision-making, improvements in HSE cost control and communication, and the achievement of successful HSE-related task fulfillment in an integrated manner. In addition, the system underpins more accurate, open, and regular communication and reporting to external stakeholders, reflecting our commitment to multi-stakeholder dialogue.

Under the umbrella of the policy, we have initiated sub-policies such as the Waste Management Policy and the Road Safety Policy.
Within the framework of new regulatory system we have introduced the new MOL Group HSE Group Guideline “Health, Safety and Environment Management System” to focus on the responsibilities and accountabilities of line management with regards to turning our HSE Policy and thematic policies (Road Safety Policy) into practice. This Group Guideline is the basis for HSE management systems at all levels in MOL Group. Although HSE matters are interrelated and co-dependent, it is recognized that the skills and processes required to manage issues may vary according to the context.

This guideline provides direction and conceptual guidance for managers to embed HSE into their business by describing a consistent HSE Management System (HSE MS) for MOL Group, with a clear segregation of duties. The Guideline describes the essential minimum elements (15 elements) of an HSE function and management system. It includes a requirement for a system to be set up in such a way that it can be externally certified according to an international systems standard.

The HSE Management System contains only guideline-level requirements which should be broken down to specific processes and methodologies in order to ensure applicability at the business level. Based on the 15 elements of the Guideline we have identified 21 top-level SD&HSE processes that were described in the so-called Global Operative Regulations (GOR), summarizing the key processes, methods and division of responsibilities, which present MOL Group-level expectations towards individual member companies. The 21 GOR descriptions include, in addition to the classical HSE areas (e.g. waste management, fire protection, etc.), new regulatory areas including Product Stewardship and Process Safety Management. This is also the first time that requirements for the three basic pillars of Sustainable Development have been defined, providing new rules for the main corporate processes in order to obtain compliance with the relevant SD criteria. The most critical action taken in 2009 was training related to the aforementioned 21 HSE regulations and putting them into practice, along with continuing preparation for GOR-based Local Operative Regulations.

Road Safety Policy

A company with such a large number of different sites requires employees to travel a lot, especially by car. To reduce the risks our colleagues face on the roads we have arranged defensive driving training for employees whose work requires regular driving. All participants take part in a theoretical course based on the Safe Drive Training syllabus, and then participate in a monthly distance-learning program to keep their newly-acquired knowledge fresh. Participants also attend a practical training session, completed with a personal written evaluation.

Legal Compliance

When considering investments, applicable legal provisions mandate impact studies for the sake of environmental protection (i.e. nature conservation or protection of arable land) and we take into account the results of such assessment studies before starting any investment projects.
Depending on the type of investment, a decision has to be made as to whether an impact study analyzing the situation prior to the investment is necessary, which would include assessing the potential impact of any changes to the environment.

Among MOL Group investments, frequent mandatory environmental impact studies are carried out in the fields of exploration and production and natural gas transmission. In the lead-up to major projects, detailed environmental impact studies are prepared by independent experts. These enable us to keep the impact on our environment to a minimum and focus attention on every possible source of potential impact from the very first stage of a project. These studies are published in municipalities, and local citizens in the neighborhood of a project are informed well in advance, before and at public hearings.

Over the decade, only a few cases concerning refining and processing required mandatory environmental impact studies prior to the introduction of new technology or operations. However, we are fully prepared to conduct more and more such studies, particularly as we expand refining capacity. The law is becoming more rigid and it is proving to be more difficult to meet the requirements of more and more international treaties and the focus on air and fresh water protection or waste management. The environmental protection authorities particularly insist on the application of BAT - best available techniques. This means that, besides fulfilling the requirements related to emission limits, we must select the most developed technology available in a given country. In the area of air protection, the focus is on the reduction of CO2 emissions and on strict limits placed on sulphur-dioxide emissions. In water management special emphasis is given to the minimization of water use and to proper wastewater treatment. Recently, MOL Group carried out several energy efficiency projects at our sites to further reduce emissions and comply with legal requirements.

Thanks to some serious unit upgrade/reconstruction work in our refineries in 2008, we significantly reduced air emissions in 2009, so compared to the HUF 92.2 mn of HSE related penalties paid in 2008, MOL Group paid in 2009 only HUF 14.7 mn. This is still not acceptable, but – considering the HSE aspects of oil and gas industry – clearly shows a huge improvement in the level of compliance. From this amount there were some small environmental-protection related issues (HUF 5.9 mn) caused mainly by inadequate contractor performance, and some safety-related penalties. We did not receive any nonmonetary sanctions in 2009.

Indicator	Unit	2005	2006	2007	2008	2009
HSE penalties	mn HUF	95.9	141.0	95.4	92.23	14.68