Health and Safety

Management Approach

Our health and safety management approach had historically been decentralized, with each division/operating site applying its own expertise and experience to identify hazards and risks, implement controls, monitor performance, and assign appropriate accountabilities. Over a number of years, we have worked to establish enterprise-wide standards aligned with international best practice. We update these standards regularly as part of our commitment to continuous improvement, operational excellence and a stronger safety culture.

To clearly articulate our expectations for health and safety performance across the business, we have developed specific fatality prevention standards – such as Light Vehicles, Heavy Mobile Equipment, Working at Heights, and Confined Spaces, among others – which are at various stages of implementation across our operations. This phased approach to implementation is due to the unique challenges of each site. We also have a Significant Potential Incident Standard in place. It requires tracking and specific management actions for any workplace incident that, under slightly different circumstances, could have resulted in a fatality.

In addition to implementing standards, we conduct independent safety culture assessments at our operating sites and track a series of leading indicators designed to increase safe behaviours, improve performance and strengthen safety culture. These indicators include visible and felt leadership interactions to set the tone from the top for safe behaviours, proactive health and safety communications, workplace inspections and training. At the corporate level, we monitor health and safety performance through regular executive reviews, peer comparisons and independent assessments.

Performance

Fatalities

In 2019, Sherritt’s divisions did not experience any work-related or community fatalities.

We continue to focus on building a strong safety culture, including removing or reducing fatal risks at the sites and eliminating unsafe behaviours. Our target in 2020 continues to be achieving an inter-dependent safety culture for our employees and contractors and zero harm for our community members in the areas in which we operate.

In 2019, we continued implementation of the fatality prevention standards, which will continue during 2020, with actions such as machine safeguarding improvements, working-at-heights facility and equipment upgrades, the installation of driver and trip monitoring technology in light vehicles, and the deployment of fatigue management measures for heavy mobile equipment operators, among other priorities.

Lost Time and Recordable Incidents

During the year, we reported three lost time incidents (which are recorded when a worker misses at least one shift following a workplace incident) and 20 recordable incidents (which include incidents resulting in lost time, restricted work, medical treatment beyond first aid, loss of consciousness, or death) across the company. This increase in incidents and statistics marks a decline from our 2018 performance.

Our 2019 performance was impacted by numerous hand injuries caused by a number of factors, including inadequate hazard recognition and control, inadequate concentration on the task at hand, unauthorized work and tool usage, and inadequate supervision. In response, management executed safety stand-downs, issued safety alerts, increased the frequency of safety interactions, focused safety interactions on tools and work methods, delivered training on awareness of the “line of fire”, and refreshed hand safety programs and general safety awareness campaigns. In addition, 2018 was a year of record-low recordable incidents in the Moa Joint Venture and rates appear to have returned to more typical levels in 2019.

Our overall safety performance in 2019 continued to be peer-leading, with a lost time incident index (total number of lost time incidents per 200,000 work hours) of 0.07 (compared to 0.08 in 2018) and a total recordable incident index (total number of recordable injuries per 200,000 work hours) of 0.47 (compared to 0.23 in 2018). This comparison was made using publicly available data from the small to medium-sized natural resource companies peer set. A small portion of these peers calculate their frequency rates per one million work hours.

Significant Potential Incidents

Sherritt records significant potential incidents (SPIs) – defined as actual or near-hit incidents that, under different circumstances, could have reasonably resulted in at least one fatality – in conformance with our standard. There were nine SPIs reported in 2019, which represents a decrease from the 16 SPIs reported in 2018. The SPIs were investigated to identify the cause(s) of each incident, and actions to prevent recurrence were identified and implemented. The most common types of SPIs in 2019 continued to be related to heavy mobile equipment, slip and fall, and working at heights. As a result, we are focusing on efforts to identify and strengthen critical controls in these areas at all of our operating sites.

In previous years, a number of SPIs relating to light vehicles were recorded at OGP. In response, in 2019 all of our light and heavy fleet drivers from OGP were evaluated by a qualified instructor and underwent a defensive driving course. The course will be updated at least every three years and will be required for new fleet drivers. Upgraded driver monitoring equipment was also installed in all vehicles. OGP didn’t record any SPIs in 2019. In 2018, OGP recorded six SPIs, four of which were related to light vehicles.

Public Safety

Management Approach

As good neighbours, it is critical that we ensure our activities and business practices avoid unintended or adverse effects on the public. We follow the regulations of our operating jurisdictions, strive to meet the expectations of nearby communities and regularly engage and collaborate with local stakeholders on health and safety–related risk awareness and emergency preparedness. Through engagement, we work to understand public concerns and safety risks, evaluate steps we can take to reduce risk, help clarify misunderstandings and dispel misinformation, and, where appropriate, collaborate with communities on initiatives that make all of us safer.

To minimize the risks of a catastrophic event impacting a local community, the company embarked on a multi-year program to implement process safety management systems at all sites. These systems ensure that major hazards are identified and controlled, changes are appropriately managed, process and equipment integrity programs are in place, operating procedures are in place, and there is adequate communication and training, among many other elements. Our Cuba joint venture operations are aligning with Cuba’s Resolution 148 for major hazard installations, and the Fort Site will align with the new Canadian CSA Z767-17 process safety management standard.

Another important way we mitigate potential impacts to both communities and our business is through effective emergency preparedness and response planning. At our operating sites, we develop plans that are grounded in scenario/risk assessments to protect the public, the environment and infrastructure in the event of a significant incident. We also implement actions to limit the severity of impacts, should an incident occur.

In Canada, Sherritt is responsible for leading emergency response efforts at its sites, while in Cuba we support our joint venture partners and the government authorities who take the lead in responding to operational emergencies. Refer to this case study for more information on the Cuban approach. Whenever possible, we coordinate closely with emergency responders in both preparedness and response activities, and we regularly conduct joint training exercises.

Sherritt’s enterprise-wide Crisis Management Standard is informed by Canadian and international practices, including the Mining Association of Canada’s Towards Sustainable Mining (TSM) Crisis Management Planning Protocol and the Incident Command System’s (ICS) management approach.

Performance

Emergency Response Planning and Training

All operating sites have up-to-date emergency response plans in place and conducted some form of crisis/emergency preparedness training in 2019. The sites regularly review emergency response plans and hold training exercises annually (at a minimum) to ensure plans are up to date and response teams are prepared.

The Fort Site subscribes to the Incident Command System (ICS) management framework for emergencies and is carrying out a multi-year plan to train and conduct field exercises for the local response team. Additionally, the Fort Site partners with the Northeast Region Community Awareness Emergency Response (NRCAER, a mutual aid emergency response group) to share best practices, reinforce mutual aid provisions, and engage with the public and local industry partners to raise awareness of community safety risks.

In Cuba, multiple training exercises occurred in 2019 at the Moa Nickel Site, as well as at the OGP facilities. Disaster reduction plans are in effect for all OGP sites in Cuba. In addition, we are currently in the process of introducing the TSM protocol for Crisis Management across all divisions.

Post-Incident Community Support

Cuba, as an island nation, is prone to seasonal storm activity. Refer to this case study for more information on how Sherritt has supported local communities in Cuba during past storm events.

In September 2019, Hurricane Dorian, a Category 5 storm, made landfall on the northern Bahamas, becoming one of the most powerful hurricanes recorded in the Atlantic Ocean. Sherritt donated $5,000 to the Bahamas Red Cross to support relief efforts in the Bahamas, where the company has a marketing office.

Stakeholder Awareness and Collaboration

Our operating sites continue to engage with local communities on risk awareness and emergency response.

In the town of Moa, we completed the refurbishment of a local community health clinic in 2019, and work progressed on a second one. Refer to this case study to learn more about Sherritt’s Community Investment Program in Cuba.

The Fort Site continued participating in key multi-stakeholder forums related to crisis and emergency preparedness. Sherritt has led the collaborative development of a response program based on potential risks the site could face, along with our NRCAER partners and local law enforcement. Subsequently, the program has been adopted by our surrounding industrial neighbours.

Site Security

Management Approach

We are committed to safeguarding our people, assets, reputation and the environment while respecting the rights of the public. We have an enterprise-wide policy that outlines our principles for creating a safe and secure business, including:

• Entering into agreements with private security service providers
• Entering into agreements with public security forces
• Reporting and investigating security-related incidents
• Applying appropriate use of force
• Protecting providers of confidential information
• Apprehending and transferring suspects to public custody

Our operating sites employ full-time and contract security personnel. We believe that competence and training are the most important elements of effective security management, and we evaluate all personnel carefully before selecting them for security detail. To ensure our interactions with the public are respectful, we provide values- and expectations-based training, including security and human rights training, to our security personnel.

Sherritt’s Security and Human Rights Standard includes standardized tools for conducting site-level gap analyses. The standard is part of Sherritt’s broader Sustainability Framework Implementation Plan for designing and implementing company-wide minimum standards across sustainability-related functions, including security. In 2019, Sherritt reviewed and updated its Human Rights Policy to reflect industry-wide best practice.

The Fort Site has implemented many of the Voluntary Principles on Security and Human Rights (VPSHRs) requirements. Application in Cuba requires a more nuanced and phased approach, including familiarizing our joint venture partners and the Cuban government with the VPSHRs before determining how best to move forward. MAC member companies that rely upon private or public security forces have committed to implementing a human rights and security approach consistent with the VPSHRs and based on a determination of risk at the mining facilities they control. Furthermore, MAC members with international mining operations report on their implementation annually in MAC’s TSM Progress Report.

Management is pursuing alignment with the VPSHRs in Cuba with the Empresa de Servicios Especializados de Protección, S.A. (SEPSA). SEPSA is the state-run security service provider that provides security at joint venture operations.

Performance

Security Incidents and Human Rights

In 2019, there were 27 security incidents, compared to 23 in 2018, with the majority of these incidents relating to thefts at the Moa Nickel Site. Our operations in Cuba and Canada did not record any significant security incidents involving allegations or claims of human rights abuse in 2019.

In 2019, we reviewed relevant indices that assess conflict and security risks and confirmed that Cuba was at low risk of violent conflicts.

At the Fort Site, security officers continued to receive basic human rights training through the provincial licensing process in Alberta. The site also trained 100% of its security personnel on the Voluntary Principles, as well as private security contractors and emergency services personnel. Sherritt reaffirmed contractual agreements between the Fort Site and the security provider to ensure compliance with all corporate requirements. Sherritt’s Fort Site continues to maintain a security licence in the province of Alberta.

In 2019, the Fort Site remained compliant with the requirements of the VPSHRs and with UNICEF’s Child Rights and Security Checklist. The Fort Site has made significant advancements in implementing the VPSHRs on site since implementation began, achieving a completion score of 89%. While Canada remains a low-risk jurisdiction for human rights infractions, Sherritt believes the Fort Site has demonstrated clear value from application of the VPs in this context. Sherritt security officers continue to work with our third-party security service provider to access online courses such as Active Shooter and Raising Threat Awareness as part of the VPSHR site training requirements. Our 2019 annual report to the Voluntary Principles on Security and Human Rights is available online.

In 2018, the Fort Site was invited to work in partnership with the local Royal Canadian Mounted Police (RCMP) detachment on the development of a security management best practice document for industrial sites in the region, and this work continued in 2019. A mapping system of the site was developed to identify risk hazard areas around the site in the event that local authorities have to travel through the site during law enforcement activities.

Employee Relations

Management Approach

Our business cannot operate and thrive without a dedicated, experienced and engaged workforce. We are committed to listening to and understanding the needs and challenges of our employees; taking action to improve the workplace; and supporting employees in reaching their potential. For the purpose of this report, employee relations include employee engagement, talent development, labour rights, and workplace diversity and inclusion.

Effective and regular two-way communication with employees is the foundation of our employee relations programs. Senior managers in the Corporate office and divisions are accountable for implementing plans to address the key needs of our workforce. In previous years, Sherritt conducted an employee survey to evaluate engagement across the business. We continue to explore new approaches for gathering employee feedback on a more frequent basis and will report on our renewed approach in a future Sustainability Report.

Ensuring the right programs are in place to support employee development at all levels is crucial for Sherritt’s long-term success and succession planning. In spite of the challenging commodity price environment, we remain committed to employee training and development. We provide a range of technical, management and leadership training in Canada and Cuba. Whenever possible, we leverage opportunities to bring different groups together to build cross-organizational networks and strengthen our shared values and culture.

Our compensation programs are aligned with Our Purpose and Our Promises, fostering a company-wide culture of accountability and pay-for-performance compensation. All salaried employees are eligible for an annual performance-based short-term incentive award expressed as a percentage of their base salary.

Across our company, we have both unionized and non-unionized workforces. We recognize and encourage the right to engage in free association and collective bargaining. As with all of our relationships, we strive for productive and mutually beneficial outcomes in our discussions with employees and organized labour representatives. When labour grievances do occur, we investigate and work to reach an acceptable solution for all parties concerned. In certain cases, we may opt for third-party arbitration. Once grievances have been resolved, the management team evaluates the issues raised and determines if any process improvements should be made.

In 2019, the Fort Site rolled out an Inclusive and Respectful Workplace Training for all employees and leaders as part of Sherritt’s Workplace and Violence Prevention Plan.

We have a policy related to workplace discrimination and violence prevention applicable to all Sherritt directors, officers and employees worldwide, including the officers, directors and employees of Sherritt’s subsidiaries and affiliated companies. There are also discrete policies on human rights, business ethics and diversity that meet legal requirements and reflect best practices. We are committed to continuous improvement in these areas, with a growing focus on diversity and inclusion.

In Cuba, Sherritt and its joint ventures are required by law to hire all national workers through an employment agency. Incidents of discrimination are handled by this state employment agency. The employment agency involves Sherritt and/or its joint venture partners in discrimination cases, as appropriate. Such involvement has occurred in previous years; however, in 2019 there were no incidents that required the involvement of Sherritt and/or its joint venture partners.

Performance

Employee Engagement

Sherritt is currently exploring new approaches for gathering employee feedback on a more frequent basis. As such, no employee engagement surveys were conducted in 2019. The next engagement survey and alternative methods of gathering feedback from employees are planned to be deployed in 2020.

A key approach to employee engagement and collecting feedback is through formal leader-once-removed discussions that are regularly held with management across the company. These discussions are intended to find out how people are really doing, get feedback and insights to help managers and their teams improve, and build trust.

For the second year in a row, Sherritt joined a list of 450 companies participating in Not Myself Today, a national mental health awareness campaign. The focus of Sherritt’s 2019 campaign was resilience – and included a series of employee workshops delivered by our Employee and Family Assistance Program (EFAP) provider, Morneau Shepell. Additionally, each location held employee engagement activities to further highlight the importance of mental well-being and support.

Organized Labour, Grievances and Strike Action

At the Fort Site, unionized employees are represented by Unifor Local 530A. Sherritt and Unifor have had an effective partnership for more than 65 years without a labour interruption. In April 2016, a new three-year agreement came into effect. In 2019, the agreement was extended for a one-year period (until March 2020), and in late 2019 the union provided notice to bargain in 2020. In Cuba, all organized labour considerations are mandated by the Cuban state, and many of the systems and tools that are common in other jurisdictions, including collective bargaining, are not employed there. As such, factoring in the Fort Site, Sherritt’s employee base is approximately 42% unionized.

The Fort Site received 18 grievances in 2019 relating to labour practices, a decrease from 2018’s total of 33. Seven grievances were resolved during the calendar year, and those that were not resolved are being managed in accordance with the procedures set out in the Collective Agreement. The Fort Site follows the process described in the Collective Agreement and the Labour Relations Act of Alberta to resolve all labour relations grievances.

There were no work stoppages as a result of labour unrest in 2019.

In 2018, Sherritt’s Fort Site engaged in a research study to “improve workplace culture in Alberta science, engineering, trades and technology companies by decreasing implicit bias and stereotypical threat”, facilitated by the Canadian Centre for Women in Science, Engineering, Trades and Technology (WinSETT). This work continued through 2019, with Sherritt’s Fort Site being one of three industry partners participating in this research. The program involves the assessment of workplace culture and a review of formal policies with the intention that the results will help Sherritt with its diversity and inclusion strategy and the industry more broadly. The project is funded by the Status of Women Canada – Western Region with in-kind contributions from participating companies and not-for-profit organizations.