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Geo Fossil Fuels Tabula Rasa Energy Perdure Petroleum Health, Safety and Environmental Policy

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Geo Fossil Fuels Tabula Rasa Energy Perdure Petroleum Health, Safety and Environmental Policy Geo Fossil Fuels Tabula Rasa Energy Perdure Petroleum Health, Safety and Environmental Policy Geo Fossil Fuels Tabula Rasa Energy Perdure Petroleum HEALTH, SAFETY & ENVIRONMENTAL (HSE) POLICY Revised 9/1/19 INTRODUCTION Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum and each of its subsidiaries (collectively referred to herein as the “Company” or “Tabula Rasa Energy”), considers the health and safety of its employees to be one of the most important phases of its operation. The Company's HSE Policy is to maintain a work environment that is safe for all employees and conducive to attaining high work standards. All safety rules and guidelines are based on recognized safe practices, standards, federal, state and local laws and regulations and industry recommended practices. Every employee is responsible for compliance with the Company's safety requirements, and their full cooperation is necessary for accident prevention and loss control. The prevention of accidents is of the utmost importance. Anyone who becomes aware of a potential hazard is expected to attempt to correct the hazard, if possible, and report the hazard to their supervisor. No illegal drugs are allowed on the facilities operated or contracted to the Company. Illegal drugs include marijuana or any other substance which the possession or use is unlawful. Also, anyone who reports for work under the influence of alcoholic beverages, stimulants, depressants, hallucinogens, or other drugs which could endanger the person or others will not be permitted to work. As a further safety precaution, entry into or upon Company's sites is conditioned upon the Company's right to search the person and personal effects of the entrant for illegal drugs. These searches may be made without prior warning and may include lockers and rooms at any work area operated by the Company, if appropriate. Such prohibited items discovered through these Company searches may be taken into custody and, if appropriate, may be turned over to the proper law enforcement authorities. The Company prohibits the possession, use or distribution by employees of firearms, explosives or weapons of any kind while on Company sites (including all concealed handguns regardless of whether the employee has been issued a concealed handgun license). Violation of the policies and procedures defined herein will be cause for disciplinary action up to and including immediate discharge/termination or cancellation of contractual services. Unless otherwise specified, for purposes of this Policy: 1. The term “site” shall mean a Company office and/or field location. 2. The term “site supervisor” shall mean the senior employee for a particular activity at a Company site. 3. The term “Senior Safety Officer” shall mean the Senior Vice President of the Company or his designee. 4. MANAGEMENT RESPONSIBILITY To ensure compliance with the policies and procedures of the Company, the managers and supervisors are charged with the responsibility for assuring safe practices by all Company employees under their supervision. The managers and supervisors also have the responsibility for being familiar with the documentation and reporting requirements as outlined in Section 5, Accident/Injury Investigation and Reporting. The managers and supervisors are expected to give the same high level of personal attention to the HSE Policy that is devoted to other supervisory responsibilities. It is the managers’ and supervisors’ responsibility to see that the Company site is operated in a safe manner, to protect the employees from hazards, and safeguard against property losses from fire, storm or other perils. The managers and supervisors are the individuals that the Company will ultimately rely upon to assure an effective HSE Policy. The managers and supervisors have the responsibility of translating safety policies into a set of on-the-job practices which must then be enforced. These practices include development of safe working procedures through training and supervision of the employees. These individuals are also responsible for the prompt correction of all recognized hazardous conditions, work methods, and practices within their area. Each supervisor is responsible and accountable for their performance in this safety function as well as their performance in other work related areas. Managers and supervisors will identify and discuss any observed violations with the employee. Any recommended disciplinary action will be documented and forwarded to the Company Senior Safety Officer. The Occupational Safety and Health Act of 1970, Section 5(a) states: ”Each employer has the general duty to furnish each of their employee’s employment and a place of employment free from recognized hazards causing, or likely to cause, death or serious physical harm; and the employer has the specific duty of complying with safety and health standards promulgated under the Act." EMPLOYEE RESPONSIBILITY The employee's responsibility is to understand and comply with the principles of the HSE Policy. Each employee is expected to abide by and support all rules, standards and policies outlined in the HSE Policy. Failure to comply with these policies and procedures will lead to disciplinary action. According to the Occupational Safety and Health Act of 1970, Section 5 (b): "Each employee has the duty to comply with safety and health standards and all rules, regulations and orders issued pursuant to this Act which are applicable to their own actions and conduct." CONTRACTORS All contractors working on Company sites should have a valid Master Service Agreement (MSA) or equivalent contract with the Company. The Company shall make a copy of the Company's HSE Policy available to contractors, and will furnish details for the particular operation planned before work commences. Site specific hazards shall be identified during facility/field orientation and/or check-in. All contractors and contractors’ personnel are expected to adhere to the Company’s policies. All contractors and contractors’ personnel at Company sites should be fully trained and currently qualified for their job in accordance with safety and environmental related regulatory and industry standards. All contractors and contractors’ personnel must understand their responsibilities relative to safety and environmental issues. All contractors and contractors’ personnel are expected to comply with all Company and governmental (federal, state, and local) safety and environmental guidelines, including but not limited to OSHA. COMMUNICATION Communication between management and employees is imperative with regard to health, safety, and environmental issues. It is the Company's responsibility to communicate potential hazards of the workplace to employees and it is the employees' responsibility to communicate the occurrence of avoidable hazards and hazardous situations to management without fear of repercussion. Communication can occur in a number of both visual and verbal formats. 1. OSHA workplace posters should be displayed in prominent locations where all employees can see them. Emergency phone numbers should be posted. In areas which require the posting of warning signs, the signs should be placed where they can be easily seen by employees and contractors. 2. Each employee will have access to or a copy of the latest edition of the HSE Policy and any future amendments. In addition, the most current version of the HSE Policy, including any amendments or changes, will be available at the Company’s office locations and on the Company intranet. 3. The Company will hold safety meetings. POLICY AUDIT The Company’s HSE Policy will be evaluated on a continuous basis, and routine audits will be conducted to maintain effectiveness and conformance with the Company’s operations and changes in industry and regulatory standards. The most widely accepted way to identify hazards and potential non-compliance is to conduct safety and health inspections. The Company is responsible for the formulation of self-inspection procedures and checklists necessary to identify and correct potential hazards or unsafe practices. The HSE Policy will be administered by the Operations Department. HSE inspections will be conducted at each facility. Inspections will be performed by the Operations Department or their designee, and the results of each inspection will be documented. The Company HSE Policy will be reviewed, at least, annually for overall effectiveness. Records of these reviews will be maintained, and any necessary changes will be implemented. Any amendments or exceptions to the HSE Policy will require approval by the Senior Safety Officer. POLICY EXCEPTIONS Exceptions to the HSE Policy may be granted on an infrequent basis under extraordinary circumstances and will require, at a minimum, a joint evaluation and approval by the Senior Safety Officer and Chief Executive Officer with advice from the Company’s outside legal counsel. When an exception is granted, additional mitigating measures shall be instituted to account for: 1. public safety; 2. the safety of Company employees; 3. the safety of Contract personnel; and 4. protection of the environment. The exception request, any mitigating measures, and appropriate contracts and approvals shall be documented and maintained by the Operations Department. DISCLAIMER REGARDING HSE POLICY This HSE Policy is intended to cover all current and future potential operations of Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum. As a result, specific sections of this Policy and various manuals,
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