1.0 SCOPE
As a leading news, sports and entertainment company, Fox Corporation (“FOX”) is committed to protecting the health, safety and working environment of its employees, independent contractors, clients, business partners and neighbors. This commitment is a key aim of FOX’s Environment, Health & Safety Program (“EHS Program”) and extends to all levels of the organization.
The EHS Program focuses on the implementation and ongoing maintenance of proactive, practical and feasible controls with respect to daily work activities supporting FOX’s operations. FOX employees and contractors receive health and safety training orientations and have access to multiple workplace safety programs and resources. The EHS Program works to continuously improve performance through preventive measures, correcting hazards or dangerous conditions, and employing measures to reduce the environmental impact of our activities.
2.0 Responsibilities
Specific EHS Program responsibilities are listed below.
2.1 Executive Chair and Chief Executive Officer
The ultimate responsibility and authority for establishing and maintaining a robust EHS Program rests with the Executive Chair and Chief Executive Officer.
- Issue the organization’s EHS Program, setting the example for FOX’s culture.
- Assume overall responsibility for implementing the EHS Program at all FOX facilities.
- Assess information provided during periodic EHS management reviews, and direct actions to continually improve the EHS Program and focus on reducing risk in the workplace.
2.2 Senior Management
- Provide visible guidance and operational leadership supporting implementation of the EHS Program consistent in all locations and operations.
- Assess information provided during periodic EHS management reviews and direct actions to continually improve the EHS Program and support efforts to reduce risk in the workplace.
2.3 Directors, Department Heads and Managers
Directors, Department Heads and Managers will:
- Communicate FOX’s EHS Program and its requirements to and support implementation and maintenance by applicable employees, visitors, contractors and vendors.
- Instruct individuals under their supervision to complete any required EHS-related training.
- Take part in efforts to meet EHS-related objectives and needs for units/departments.
- Incorporate EHS requirements and responsibilities into each appropriate job description and communicate requirements and expectations to applicable employees, visitors, contractors and vendors.
- Routinely assess EHS impacts of new processes and equipment and proactively support incorporation of controls.
- Take part in efforts focused on improvement of EHS programs.
- Support periodic EHS-related assessments of work areas and/or facilities.
- Investigate accidents, injuries and illnesses promptly and thoroughly in an effort to determine causes and contributing factors and take action focused on prevention of reoccurrence.
- Provide timely and relevant information to the Workers’ Compensation Department personnel necessary to satisfy the requirements for claims management.
- Identify budget requirements necessary for compliance with established EHS policies and procedures.
2.4 Supervisors
Supervisors will:
- Implement the EHS Program and other organizational safety practices and programs under their supervision or control.
- Require staff members to complete required EHS-related training.
- Collect, recommend and implement EHS Program improvements.
- Collect data needed to maintain the EHS Program.
- Implement a process focused on maintaining workplaces and equipment under their direction in a safe, well-kept manner, in compliance with FOX’s EHS Program.
- Oversee the development and implementation of procedures emphasizing safe use of hazardous physical and chemical substances.
- Investigate accidents, injuries and illnesses promptly and thoroughly in an effort to determine causes and contributing factors and take action to prevent reoccurrence.
- Provide timely information to Workers’ Compensation Department personnel necessary to satisfy the requirements for claims management.
2.5 Employees
Every FOX employee is responsible for their own safety and for complying with all company and departmental EHS policies and procedures. Each employee is responsible for:
- Complying with FOX’s EHS Program and all other relevant health and safety practices, programs and procedures.
- Completing required EHS training as directed.
- Upholding the EHS Program, including taking part in those aspects applicable to them, including, but not limited to:
- Reporting perceived or actual incidents or near misses
- Attending meetings
- Reporting perceived or actual problems
- Recommending improvement
- Informing their supervisor of any perceived or actual EHS-related hazards, emissions or deficiencies in the workplace of which they become aware
2.6 Environment, Health and Safety Department
The EHS department (“EHS Department”) is appointed by the Executive Chair and Chief Executive Officer to manage the development, implementation and ongoing administration of the EHS Program. The EHS Department will perform the following actions in support of FOX’s EHS Program:
- Advise management and employees about responsibilities regarding the EHS Program.
- Recommend and develop EHS programs, including guidelines focused on individual and organizational compliance with applicable EHS-related laws, regulations, policies, and guidelines.
- Provide guidance and technical assistance to supervisors and managers in identifying, evaluating and correcting health and safety hazards.
- Provide training and materials necessary to support safe and healthy work practices.
- Conduct analyses of occupational incidents and injuries.
- Review EHS objectives and targets on an annual basis.
- Analyze environmental impacts for trends.
- Monitor compliance with the EHS Program, including rules and regulations, organizational health and safety policies, programs, and guidelines.
- Identify areas of improvement for the EHS Program.
- Periodically review and revise the EHS Program as necessary.
3.0 Procedure
3.1 Performance and Review of Environment, Health and Safety Program
All employees are responsible for participation in and observance of FOX’s EHS Program. Directors, Department Heads, Managers, and Supervisors are responsible for (i) assuring the operations under their control are conducted in compliance with the EHS Program and all other applicable health and safety rules, regulations, policies and guidelines, with a focus on safety; (ii) training is provided prior to start of work; and (iii) necessary and appropriate steps are taken to identify and eliminate health and safety hazards. EHS performance will be regularly assessed and evaluated. The EHS Department will review this performance annually in order to foster progressive improvement.
3.2 Program Elements and Objectives
3.2.1 Impacts
The EHS Department identifies relevant environment, health and safety risks and related impacts of FOX’s operations.
3.2.2 Regulatory Requirements
FOX has established a process for identifying, accessing and communicating applicable health and safety laws, rules, regulations, and industry policies and guidelines applicable to all impacted FOX operations.
3.2.3 Objectives
Each FOX department is responsible for considering significant environmental, health and safety risks when setting their EHS objectives.
The appropriate operational managers will assist the EHS Department to improve the EHS performance and approve these objectives.
3.2.4 EHS Programs and Implementation
Each FOX department or unit is responsible for developing and implementing an EHS program, in compliance with the Fox Corporation EHS Program, that is focused on addressing safety, accident prevention, fire/life safety, ergonomics and disaster preparedness measures for employees assigned to the department or unit.
Directors, Department Heads and Managers are responsible for complying with EHS-related obligations, including departmental Emergency Action Plans and other related documents necessary to support the effectiveness of FOX’s EHS Program.
3.2.5 Monitoring and Measurement
A periodic audit system should be established at the unit or department level to identify deficiencies and maintain an effective department-level EHS program. The EHS Department will be responsible for supporting, monitoring and assessing the management and control of each unit’s or department’s EHS program. This system of EHS management and compliance assessments and other monitoring activities permit evaluation of the quality of EHS management to identify areas for improvement and plans to optimize use of resources.
The EHS Department will assist in these processes, but it will remain the responsibility of supervisors and managers to identify and comply with applicable department-level EHS program elements.
3.2.6 Training, Awareness and Competence
All employees will be provided with introductory EHS training through the EHS Department’s “EHS Management System.” In addition, the EHS Department, with input from Department Heads, will identify, plan, monitor and record training for personnel whose work may create a significant impact upon the environment or who are likely or anticipated to engage in high-risk activities.
3.2.7 Communications
FOX has developed a communications plan to ensure that relevant information regarding EHS considerations, operations. and risks are appropriately communicated to applicable internal personnel and external stakeholders. The EHS Department also has a process through which it handles internal communications and responds to relevant communications from external stakeholders.
3.2.8 Audit
The EHS Department has developed an annual audit procedure to ensure that the EHS Program is properly implemented and maintained. The results are provided to senior management.