Our QHSE compliance rules

AFRICA DIGITAL COMMS

QUALITY, HEALTH, SAFETY AND ENVIRONMENT (QHSE) POLICY & RULES

Document title: QHSE Policy and Operational Rules
Company: AFRICA DIGITAL COMMS
Website: https://starlink.africadigital.tech
Scope: Employees, management, consultants, subcontractors, suppliers and other authorized representatives
Application: Offices, client premises, industrial and mining sites, project locations, transport activities and field operations
Document owner: General Management / Designated QHSE Representative
Review frequency: At least every two years and following significant incidents, operational changes or regulatory updates.

1. OUR QHSE COMMITMENT

AFRICA DIGITAL COMMS is committed to delivering reliable, high-quality services while protecting people, preserving the environment, safeguarding property and maintaining the trust of our clients and partners.

Our operations span digital communication, audiovisual production, photography, video production, livestreaming, IT infrastructure, CCTV and security systems, equipment installation, maintenance and other related technical services. We recognize that these activities may expose our personnel, clients, subcontractors and members of the public to occupational, environmental and operational risks.

We therefore commit to:

• Preventing occupational injuries, work-related illnesses and avoidable incidents.
• Delivering services that meet agreed specifications, contractual requirements and applicable quality standards.
• Identifying hazards, assessing risks and implementing appropriate preventive measures before work begins.
• Complying with applicable laws, regulations, client requirements and authorized site procedures.
• Preventing pollution, minimizing waste and promoting the responsible use of energy, water, materials and equipment.
• Providing appropriate training, supervision, tools and personal protective equipment.
• Encouraging transparent reporting, employee participation and continuous improvement.
• Maintaining professional integrity, confidentiality and accountability in all business relationships.

Our principle is simple: no deadline, contract value or operational objective takes precedence over the safety of people, legal compliance or the prevention of serious environmental harm.

2. SCOPE AND APPLICATION

This policy applies to:

• Management, permanent and temporary employees.
• Consultants, freelancers and technical personnel.
• Subcontractors, suppliers and service providers working under our responsibility.
• Authorized visitors participating in our activities.
• All operations conducted in offices, studios, workshops, client premises, industrial facilities, mining sites, construction areas and public locations.

Where client or site requirements are stricter than our internal rules, the stricter applicable requirements shall be followed, provided they are consistent with applicable law.

All personnel must receive the relevant safety instructions before commencing assigned work.

3. LEADERSHIP, RESPONSIBILITIES AND ACCOUNTABILITY

3.1 General Management

General Management shall:

• Approve and communicate the QHSE policy.
• Provide reasonable resources for safe and effective operations.
• Ensure that responsibilities are assigned and understood.
• Support incident investigations and corrective actions.
• Review QHSE performance and promote continual improvement.
• Ensure that commercial commitments do not encourage unsafe work or regulatory non-compliance.

3.2 Project Managers and Supervisors

Project managers and supervisors shall:

• Assess operational risks before work begins.
• Verify that personnel are competent and authorized for their tasks.
• Confirm that required permits, PPE, tools and emergency arrangements are available.
• Conduct or organize toolbox talks and pre-task briefings.
• Monitor compliance with company and client procedures.
• Stop work when an unsafe condition or uncontrolled risk is identified.
• Report incidents, near-misses, hazards and non-conformities promptly.

3.3 Employees and Contractors

Every person working under AFRICA DIGITAL COMMS shall:

• Follow QHSE instructions and approved work procedures.
• Use PPE and equipment correctly.
• Avoid actions that endanger themselves or others.
• Report hazards, incidents, damaged equipment and unsafe conditions.
• Participate in required training and safety briefings.
• Exercise stop-work authority when there is a reasonable concern about imminent danger.
• Cooperate with inspections, investigations and corrective actions.

3.4 QHSE Representative

Where designated, the QHSE representative shall coordinate risk assessments, inspections, training records, incident reporting, corrective-action tracking and periodic performance reviews.

QHSE responsibilities remain shared across the organization; appointing a representative does not remove management or individual accountability.

4. RISK ASSESSMENT AND SAFE SYSTEMS OF WORK

No high-risk task may begin until its hazards have been assessed and appropriate controls implemented.

Before each project or activity, the responsible supervisor shall determine whether the following are required:

• Task-specific risk assessment or Job Safety Analysis (JSA).
• Method statement or documented safe work procedure.
• Permit to work issued by the authorized site authority.
• Toolbox talk and personnel competency verification.
• Equipment inspection and electrical safety checks.
• Emergency and rescue arrangements.
• Coordination with client representatives and other contractors.

Risk controls shall prioritize eliminating hazards, substituting safer methods, applying engineering controls, establishing administrative controls and using PPE as the final layer of protection.

Risk assessments must be reviewed when work conditions, equipment, personnel, location or scope change, or when new hazards are identified.

If a task cannot be performed safely, it must not proceed until the risk is controlled.

5. PERSONAL PROTECTIVE EQUIPMENT (PPE)

Personnel shall use PPE appropriate to the hazards and the client’s requirements.

Depending on the activity and site, PPE may include:

• Safety helmet.
• High-visibility vest or reflective clothing.
• Safety footwear with suitable toe protection and soles.
• Protective gloves.
• Safety glasses or face protection.
• Hearing protection.
• Suitable respiratory protection.
• Flame-resistant or other specialized protective clothing.
• Certified fall-protection equipment and harnesses.
• Additional PPE required by a risk assessment or site authority.

All PPE must be suitable for its intended use, inspected before use, maintained properly and replaced when damaged or no longer protective.

Personnel shall receive instructions on correct fitting, use, limitations and care.

No required PPE, no authorization to commence the affected task.

6. SITE ACCESS, IDENTIFICATION AND SECURITY

All personnel shall:

• Carry valid identification and display the company ID or client-issued access badge as required.
• Complete mandatory inductions before entering controlled work areas.
• Respect restricted zones, access-control procedures and security instructions.
• Obtain authorization before photographing, filming or recording within controlled facilities.
• Comply with client rules concerning mobile phones, cameras, data storage and communications equipment.
• Never lend access badges or enter a site using another person’s credentials.
• Report lost identification, suspicious activity, unauthorized access or security breaches immediately.

Access to sensitive areas, including control rooms, electrical rooms and security infrastructure, is permitted only to authorized personnel.

7. WORKING AT HEIGHT

Activities involving roofs, elevated platforms, ladders, scaffolding, poles, towers or elevated camera installations require a task-specific assessment.

The following rules apply:

• Avoid working at height whenever a safer ground-level method is reasonably practicable.
• Use appropriate, inspected and secured access equipment.
• Use collective fall protection where practicable.
• Use suitable fall-arrest or restraint systems when required by the risk assessment.
• Verify anchor points and compatibility of fall-protection equipment.
• Establish exclusion zones to protect people below.
• Secure tools and materials against falling.
• Suspend work during unsafe weather or visibility conditions.
• Prepare a rescue plan before work requiring fall-arrest equipment begins.

Only trained and authorized personnel may undertake specialized work at height.

Ladders shall not be used as a substitute for suitable work platforms where the task, duration or conditions make them unsafe.

8. ELECTRICAL SAFETY AND TECHNICAL INSTALLATIONS

This section applies to CCTV systems, NVRs, monitors, networking equipment, lighting, audiovisual systems, power supplies, UPS units, cabling and related installations.

Personnel shall:

• Inspect electrical tools, cables, plugs and equipment before use.
• Use correctly rated equipment and suitable protection against electrical hazards.
• Keep electrical equipment protected from water, excessive heat and physical damage.
• Avoid overloaded sockets, improvised connections and exposed conductors.
• Isolate electrical energy before maintenance whenever required.
• Apply lockout/tagout (LOTO) procedures where applicable and authorized.
• Verify isolation before working on equipment that could become energized.
• Use only authorized and competent personnel for electrical work.
• Maintain cable management to prevent trips, damage and accidental disconnection.
• Test and commission installations according to approved procedures.

Never handle exposed live conductors or attempt electrical repairs without the necessary competence, authorization and protective measures.

9. TOOLS, MACHINERY AND EQUIPMENT

All tools, lifting equipment, access equipment and technical devices shall be suitable for the intended task.

Before use:

• Conduct the required pre-use inspection.
• Confirm that guards, safety devices and protective features are functional.
• Verify that operators are trained and authorized.
• Remove defective equipment from service and clearly identify it as unsafe.
• Follow manufacturer instructions and applicable site procedures.
• Maintain inspection, maintenance and calibration records where applicable.

Equipment shall not be modified, bypassed or used outside its approved operating limits without proper authorization and technical assessment.

10. VEHICLE AND ROAD SAFETY

Personnel driving company vehicles, hired vehicles or client-authorized vehicles shall:

• Hold the appropriate valid driving authorization.
• Conduct pre-trip vehicle inspections.
• Wear seatbelts and require all occupants to do the same.
• Respect speed limits, traffic regulations and site traffic-management plans.
• Avoid driving while fatigued, impaired or distracted.
• Never use a handheld phone while driving.
• Secure tools, cameras, equipment and transported materials.
• Verify that loads are within vehicle capacity and properly restrained.
• Report vehicle defects, collisions, damage and near-misses promptly.

Journeys to remote or high-risk locations should be planned according to the route, weather, road conditions, communications coverage and emergency arrangements.

11. WORKING IN MINING, INDUSTRIAL AND CONSTRUCTION SITES

When working at mining operations, industrial facilities or construction sites, all personnel must comply with the client’s induction, permit-to-work, traffic, emergency, environmental and security requirements.

Additional controls may include:

• Site-specific PPE and access authorization.
• Radio communication and designated reporting channels.
• Exclusion zones around mobile equipment and lifting operations.
• Mandatory escort requirements.
• Restrictions on photography, filming and electronic devices.
• Hazardous-area restrictions and designated pedestrian routes.
• Site-specific emergency response procedures.
• Compliance with the instructions of authorized client personnel.

Personnel must never enter an operating zone, approach moving machinery or interfere with production equipment without authorization.

Client requirements do not replace our obligation to identify and report unsafe conditions.

12. AUDIOVISUAL, PHOTOGRAPHY AND LIVESTREAMING SAFETY

For filming, photography, event coverage and livestreaming, the project team shall:

• Inspect cameras, tripods, stabilizers, lighting equipment and cables before use.
• Secure tripods, stands and lighting rigs against tipping or collapse.
• Route cables safely and use appropriate cable covers.
• Position equipment without obstructing emergency exits, walkways or fire equipment.
• Confirm the stability of elevated camera positions and platforms.
• Assess crowd density, electrical loads, weather and environmental conditions.
• Obtain required filming authorizations and respect restricted areas.
• Use additional controls for outdoor broadcasts, night shoots and operations near vehicles or machinery.

Drones may only be operated by appropriately authorized personnel and in accordance with applicable aviation requirements, site rules and required permissions.

No production schedule or live broadcast requirement justifies exposing personnel or the public to an uncontrolled hazard.

13. OCCUPATIONAL HEALTH AND FITNESS FOR DUTY

AFRICA DIGITAL COMMS expects all personnel to report fit for the work they are assigned to perform.

Personnel shall:

• Avoid working under the influence of alcohol, illegal drugs or substances that impair safe performance.
• Disclose relevant fitness-for-duty limitations through appropriate confidential channels.
• Observe adequate rest breaks and report fatigue that could compromise safety.
• Use suitable manual-handling techniques and mechanical assistance when necessary.
• Maintain appropriate workstation ergonomics during office and computer-based work.
• Follow applicable occupational health precautions and site medical requirements.
• Respect the dignity, privacy and confidentiality of colleagues.

No person shall be required to continue a task when fatigue, illness or another impairment creates an unacceptable safety risk.

Medical information shall be handled confidentially and only by authorized persons.

14. ALCOHOL, DRUGS AND PROHIBITED CONDUCT

Working while impaired by alcohol or drugs is prohibited.

Personnel shall not bring, consume or distribute prohibited substances at work or on client premises.

Any restriction concerning alcohol consumption before work shall follow applicable law, client rules and the company’s formally approved fitness-for-duty requirements. A fixed 24-hour period shall not be treated as proof that an individual is fit for duty.

Violence, threats, harassment, bullying, horseplay, deliberate interference with safety devices and other dangerous conduct are prohibited.

Violations shall be handled through fair and appropriate disciplinary procedures, subject to applicable law and contractual obligations.

15. FIRE PREVENTION AND EMERGENCY RESPONSE

Personnel shall:

• Identify emergency exits, assembly points and alarm procedures during site induction.
• Keep escape routes and fire equipment unobstructed.
• Store combustible materials safely.
• Use electrical equipment in accordance with its rating and approved procedures.
• Report smoke, fire hazards, overheating equipment and damaged power supplies.
• Use fire extinguishers only when trained, when it is safe to do so and when an escape route remains available.
• Evacuate promptly when instructed or when conditions make continued occupancy unsafe.
• Account for personnel at designated assembly points.

Each project shall identify the applicable emergency contacts, communication channels and first-aid arrangements. For serious emergencies, personnel must prioritize life safety, alert the appropriate emergency service or site response team and avoid actions beyond their training.

16. FIRST AID, INCIDENT REPORTING AND INVESTIGATION

All injuries, occupational illnesses, near-misses, unsafe conditions, property damage, environmental incidents and security-related incidents shall be reported promptly.

The initial response shall prioritize:

1. Protecting people from further harm.
2. Contacting the appropriate emergency or medical response team.
3. Securing the area where safe to do so.
4. Informing the supervisor and relevant client representative.
5. Preserving relevant evidence without compromising safety.
6. Recording the event through the designated reporting process.

AFRICA DIGITAL COMMS shall investigate incidents proportionately to their actual or potential severity, identify underlying causes and define corrective and preventive actions. Actions shall have responsible owners and target dates, and their effectiveness shall be verified.

Serious incidents shall be escalated immediately and notified to relevant authorities when required by law. Personnel shall not be penalized for raising a genuine safety concern or reporting a near-miss in good faith. Deliberate misconduct, concealment or falsification may be addressed separately.

17. ENVIRONMENTAL PROTECTION AND WASTE MANAGEMENT

AFRICA DIGITAL COMMS is committed to minimizing the environmental impact of its activities.

All personnel shall:

• Prevent avoidable spills, leaks and releases.
• Dispose of waste through appropriate designated channels.
• Separate recyclable, general and hazardous waste where applicable.
• Manage electronic waste, batteries, damaged cables and electrical components responsibly.
• Avoid unnecessary printing, energy consumption and material wastage.
• Prevent pollution of soil, drains and watercourses.
• Use chemicals, fuels and cleaning products according to their safety instructions.
• Protect vegetation, wildlife and surrounding communities where relevant.
• Report spills, uncontrolled releases and environmental damage promptly.

Hazardous materials and waste shall be handled only by competent, authorized personnel and managed according to applicable requirements.

Open burning, uncontrolled dumping and unauthorized discharge of waste are prohibited.

18. QUALITY ASSURANCE AND SERVICE DELIVERY

Quality is an essential component of our QHSE commitment.

We shall:

• Confirm client requirements, deliverables, technical specifications and acceptance criteria before execution.
• Use competent personnel and appropriate equipment.
• Follow approved work plans, technical procedures and manufacturer recommendations.
• Conduct inspections, functional tests and quality checks at appropriate stages.
• Record commissioning results, defects and outstanding actions.
• Obtain required client acceptance before formally closing work.
• Correct identified non-conformities and document agreed corrective actions.
• Protect client property and prevent avoidable damage.
• Maintain traceable project documentation, including reports, test records and handover documents where applicable.

No deliverable shall be knowingly represented as complete, compliant or tested when required verification remains outstanding. Any change to the agreed scope, technical specification or acceptance criteria shall be documented and approved by the appropriate parties.

19. SUBCONTRACTOR AND SUPPLIER MANAGEMENT

Subcontractors and suppliers shall be selected and managed according to the nature, complexity and risk of the services they provide.

Where relevant, AFRICA DIGITAL COMMS shall:

• Verify technical competence, experience and required authorizations.
• Communicate applicable QHSE requirements before work begins.
• Confirm insurance, permits, certifications and other contractual documents where required.
• Assess the suitability of supplied products, materials and equipment.
• Monitor performance and compliance during project execution.
• Require reporting of incidents, defects and non-conformities.
• Apply corrective actions and proportionate contractual measures where necessary.

Subcontractors remain responsible for their own personnel and legal obligations while cooperating with AFRICA DIGITAL COMMS and the client to manage shared risks.

20. ETHICS, INTEGRITY AND PROFESSIONAL CONDUCT

Trust is built through responsible conduct as well as safe operations.

All personnel, representatives and subcontractors shall:

• Act honestly and professionally.
• Avoid bribery, fraud, corruption and undisclosed conflicts of interest.
• Maintain accurate project, financial, technical and compliance records.
• Respect client confidentiality, intellectual property and contractual obligations.
• Protect personal information and sensitive operational data.
• Avoid unauthorized disclosure of photographs, videos, site layouts, access credentials or security-system information.
• Report suspected misconduct through appropriate management channels.

No employee or contractor may falsify inspection records, training certificates, incident reports, test results or compliance documentation.

21. INFORMATION SECURITY AND CONFIDENTIALITY

Because our work may involve digital systems, CCTV, networking infrastructure, audiovisual content and client information, information security is part of our operational responsibility.

Personnel shall:

• Use authorized accounts and approved access credentials.
• Protect passwords, devices, storage media and confidential files.
• Restrict access to information according to assigned responsibilities.
• Obtain authorization before copying, transferring or publishing client data.
• Store and transmit project files using appropriate approved methods.
• Report suspected data loss, unauthorized access or cybersecurity incidents promptly.
• Return or securely dispose of client information and equipment according to contractual instructions.

Client information shall not be used for personal purposes or publicity without the required authorization.

22. TRAINING, COMPETENCE AND COMMUNICATION

AFRICA DIGITAL COMMS shall identify the training and competency requirements relevant to its activities.

Depending on the assignment, this may include:

• General QHSE induction.
• Client-specific site induction.
• Electrical safety and isolation procedures.
• Working-at-height awareness and competency.
• Fire safety and emergency response.
• First aid where required.
• Safe driving and journey management.
• Equipment handling and technical commissioning.
• Environmental awareness and incident reporting.
• Information security and confidentiality.

Training, inductions and competency evidence shall be documented where appropriate.

Toolbox talks and pre-task briefings shall be conducted for activities presenting significant risks, and their attendance recorded where required.

23. WORK STOPPAGE AND NON-COMPLIANCE

Every employee and contractor has the authority and responsibility to raise a safety concern and request that an unsafe activity be paused.

Work shall stop when, for example:

• A serious or imminent danger is identified.
• Required permits or authorizations are missing.
• Critical PPE or protective equipment is unavailable or defective.
• Personnel lack the necessary competence.
• Environmental controls are inadequate.
• Weather, visibility or site conditions become unsafe.
• An incident or unexpected change invalidates the existing risk assessment.

Work may resume only after the hazard has been assessed, appropriate controls have been implemented and the authorized responsible person has approved the restart.

Good-faith reporting of safety concerns shall be encouraged and protected from retaliation.

24. INSPECTIONS, AUDITS AND CONTINUAL IMPROVEMENT

AFRICA DIGITAL COMMS shall use proportionate monitoring and review processes to assess QHSE performance.

These may include:

• Workplace and equipment inspections.
• Project-specific compliance checks.
• Review of incidents, near-misses and non-conformities.
• Verification of training and authorization records.
• Corrective-action tracking.
• Client feedback and project close-out reviews.
• Periodic management reviews and improvement planning.

Performance indicators may include:

• Number of recordable incidents and lost-time injuries.
• Near-misses and hazards reported.
• Percentage of corrective actions closed by their due dates.
• Completion of required inductions and training.
• Completion of planned inspections.
• Environmental incidents and waste-management compliance.
• Quality defects, rework and client acceptance outcomes.

Targets and reporting frequencies shall be defined according to the organization’s operational scale, risk profile and contractual obligations. Performance data shall be accurate, appropriately documented and reviewed for opportunities to improve.

25. DOCUMENT CONTROL AND RECORD KEEPING

Relevant QHSE documentation shall be maintained, protected against unauthorized alteration and made available to authorized stakeholders when appropriate.

Records may include:

• Approved policies and procedures.
• Risk assessments and method statements.
• Induction and training records.
• PPE and equipment inspection records.
• Permits to work, where applicable.
• Incident reports and investigations.
• Environmental records.
• Quality inspections, test results and commissioning reports.
• Corrective-action registers and project handover documents.

Records shall be retained for the applicable legal, contractual and company-defined periods.

Only current, approved versions of controlled procedures shall be used for operational activities.

26. IMPLEMENTATION, ENFORCEMENT AND REVIEW

Compliance with this policy is mandatory for all personnel and contractors within its scope.

Depending on the severity of a breach, applicable law and contractual terms, corrective measures may include additional training, work suspension, removal from a site, formal disciplinary action or termination of a contract.

AFRICA DIGITAL COMMS shall review this policy at least annually and whenever significant changes in legislation, operations, risk exposure or client requirements make a review necessary.

This policy shall be communicated to employees, relevant contractors and other interested parties. Additional procedures, forms and project-specific controls may be issued to support its implementation.

27. MANAGEMENT DECLARATION

AFRICA DIGITAL COMMS recognizes that operational excellence depends on protecting people, delivering consistent quality, respecting the environment and maintaining the confidence of clients and partners.

Management commits to providing leadership, encouraging accountability, addressing identified risks and improving QHSE performance through practical, measurable and documented actions.

Every person working with us has a role in maintaining these standards.

OUR COMMITMENT: QUALITY IN EVERY DELIVERABLE. SAFETY IN EVERY OPERATION. RESPONSIBILITY IN EVERY ACTION.

Approved by: General Management, AFRICA DIGITAL COMMS
Name: MARTIN KANKU
Position: Managing Director / General Manager
Signature:  MK
Effective date: November, 2025
Next review date: November, 2027