Policy:
Viking has an overarching policy defining environmental, health, and safety objectives that provides a framework for the Company’s management and operational activities. Viking, after conducting a thorough gap analysis on its policies, will add to this policy a commitment to implement IFC’s Performance Standards in its operations (or more stringent national standards if they exist) and to promote the Performance Standards and good international industry practice (GIIP) with clients. The policy will signal to both employees and clients the importance that Viking places on managing social, environmental, health, and safety risks in the countries where it works under sometimes challenging circumstances.
Assessment:
The Company will, as part of its effort to achieve outcomes consistent with IFC’s Performance Standards, develop a four stage formal risk assessment procedure to review and screen projects for bidding, manage client performance risks during operations, and identify, based on experience, which clients will help it meet the aspirations laid out in its policy statement. The steps will be the following:
Viking will use commercially reasonable endeavors to carry out a due diligence on the projects where it intends to bid. The due diligence will identify potential risks and impacts from the project as a whole, and will determine the likelihood that the project in all of its aspects and impacts will conform to the Company’s environmental and social standards, including the IFC Performance Standards, the World Bank Group EHS Guidelines, and GIIP. It will only accept those contracts where it believes that the project can meet these international standards.
Viking will have a formal checklist for site acceptance, which will be part of its contract with the client. The checklist will identify those features of a site that will ensure that Viking can carry out its activities without creating risks and impacts outside the site. These features may include access road designed to minimize ongoing impact on local communities, appropriate site drainage and pit design, and fencing to prevent unauthorized access. Viking will not accept sites unless they have met the requirements set out in the checklist.
During the course of carrying out a contract, should Viking identify situations in which a particular project will not meet Company standards because of actions or activities of the client, Viking will use commercially reasonable efforts to communicate with the client about the situation and recommend that the client take corrective actions based on international good practice, including the Performance Standards.
At least annually, Viking senior management, with the possible participation of IFC, will review all recent and ongoing projects and identify those clients who are contributing to Viking meeting its own Company standards and whose actions reduce the social and environmental risks around projects in which Viking is invo
lved. Viking will seek to expand its business with these clients. Where particular clients have acted in a way that has put projects at greater social and environmental risk, Viking will seek to discuss with these companies how these risks and impacts might be better managed. However, should communications with these latter clients indicate an unwillingness to improve their risk management and lessen their impacts and where there is evidence of serious non compliance with PS standards and provisions, Viking will not seek further business with them.
Viking is not undertaking environmental and social impact assessments (“ESIAs”) of the projects it bids for, since its role is limited to providing oilfield services, and it is the client company’s responsibility to prepare the environmental and social documents, obtain environmental permits, and obtain permission to enter the land required to carry out the services. Furthermore, the Company generally doesn’t prepare the site and its ability to mitigate the impacts from its activities is limited to the area designated by the contracting company. The Company will typically have to contractually adhere to the environmental, health and safety (HSE) management plan and specific environmental management system (EMS) requirements prepared by the E&P company to which Viking provides services. The management plan and system should be based on the ESA carried out by the client company. At the same time Viking will have its own EHS management plan and management system. To mitigate the risks inherent in this business model in that the two systems may not mesh, Viking will, as part of its screening of potential projects according to the steps laid out above, identify any potential conflicts or gaps and work with the client to develop bridging documents or other project-specific mechanisms for removing the risks. For example, Viking will use commercially reasonable efforts to obtain assurance that land acquisition, renting or leasing agreements, and compensation for lost crops and associated assets/structures, at sites where the Company is seeking a contract has been carried out in accordance with the objectives of IFC’s PS5. Viking will also seek assurance and use commercially reasonable efforts, including publicly available sources, to acquire the relevant documentation from the E&P clients on impacts and risks associated with impacts on biodiversity (PS 6) and cultural heritage (PS 8).
Management:
The four steps described above will be built into Viking’s management system. Viking is developing an integrated management system, VIKING SMART, that identifies issues and outlines preventive and/or mitigation measures, not just on social, environmental, health and safety issues, but across all of Viking’s operations. Under SMART, some corporate manuals (e.g., HSE, Quality and Business Development), which are comprehensive in their procedures, standards, and forms, have been developed, while others
(e.g., Human Resources, Supply Chain and Logistic, Internal Affairs), along with procedures and the standard outline in the Quality Manual framework, are still under development. Most department-specific operating manuals for the Company’s three main activities (geophysical/seismic, drilling, and well completion) are currently being developed. The HSE manual will include a chance finds procedure for physical cultural heritage. The integrated nature of Viking Smart will allow the company to evaluate risks and issues across a number of areas of its operations, where in other company’s management systems these different areas can be much more compartmentalized and separated.
The Company maintains a good in-country presence, particularly in Turkey, where Viking is headquartered, and is focused on maintaining a strong HSE program while improving on its environmental and social performance.
Organizational Capacity:
Management has a good mix of major company background and smaller specialized oil field services company experience. Department directors have strong technical knowledge and good understanding of the sector market.
Viking has qualified HSE personnel and is currently assessing its management team to fill some vacancies and ensure that each regional area of operations is sufficiently covered. Viking will establish a Global HSE manager to oversee its operations. In line with this approach, Viking will assess its current and projected operations to determine if additional middle level personnel may be needed to ensure the HSE and social procedures and standards are fully implemented at the field level.
Given that the Viking SMART system has not yet been fully completed, integration of the existing training program for all staff will need to be developed and implemented. The training should be appropriate for the level of responsibility and operational area. This training will include an introduction to the Performance Standards and the relevant WBG EHS Guidelines. Additionally, project specific training may be needed where the EHS management plan and system of the E&P company may differ from Viking’s own system. A specific training program will be implemented for the seasonal seismic workers (for a discussion of these workers, see below in PS 2).
Stakeholder Engagement and Grievance Procedure:
Viking, through its operations, has limited engagement with affected stakeholders. The Company has an informal process, particularly for seismic operations where access to land is required, to deal with affected stakeholders. When undertaking seismic work, the Company can avoid land owners who do not want their land to be affected. This informal process on seismic work will be developed into a formal procedure, which could become one of the services that Viking provides to geotechnical clients. As part of SMART, Viking will formalize a grievance mechanism and, where relevant, develop effective procedures to receive, log, and,
where it does have responsibility, resolve grievances from affected communities by qualified personnel. The process will ensure that all grievances that have been received that are the responsibility of the contracting company are formally passed on to that company. In addition, Viking will also develop and implement community engagement procedures in accordance with PS1 provisions, including mechanisms for receiving and responding to community interests and information request, on an ongoing basis.
Monitoring and Evaluation:
Viking, as part of SMART, has developed a systematic approach for monitoring its activities including regular inspections of equipment and operations, HSE reports and key performance indicators, and data analysis that lead to procedural changes to correct issues and prevent HSE incidents. Furthermore, Viking will use reasonable endeavors to collect relevant site specific HSE data as recorded by the E&P client as part of their regular monitoring and evaluation activities. These data may be used in the annual review of client risks.
Emergency response:
Viking has developed an emergency response manual for its drilling operations taking into account the particular environment of its operations (e.g., Kurdistan/northern Iraq). The manual addresses levels and types of emergencies, specific response structures and responsibilities, and notification procedures. Emergency training and regular drills are part of Viking SMART system.
