TCCQS Ev. 3Global Audit Program

EOSH Due Diligence Module

This module serves as a guide to the auditor in completing the TCCQS Evolution 3 Environmental Compliance assessment during an environmental audit. The auditor will determine whether or not the organization is complying with the specifications and requirements of The Coca-Cola Company by completing this audit module.

Plant: / Date:
Auditor(s):

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1) Questionnaire:

Yes / No
  1. Does the operation conduct EOSH due diligence assessments for all real estate before completing certain transactions?
  2. Does Due Diligence assessment follow the Company’s requirements for EOSH Due Diligence?
  3. Has the operation established a Corrective Action Plan to address each EOSH issue and risk ?

1.Does the operation conducts EOSH due diligence assessments for all real estate before completing certain transactions?1

2.Does Due Diligence assessment follow the Company’s requirements for EOSH Due Diligence?...... 2

3.Has the operation established a Corrective Action Plan to address each EOSH issue and risk ?...... 2

2) Reference Standards List:

EOSH Due DiligenceRequirements

TCCQS updates are captured till August March 31June 30v310, 20062007

Note: these requirements are not applicable for Toll Fillers

3) Specifications and Requirements Summary:

Specifications / Requirements
1 /

Does the operation conducts EOSH due diligence assessments for all real estate before completing certain transactions?

The “OSH” portion of an assessment is not required for transactions involving only undeveloped land ( such as “green fields” )
Exceptions to item 4:(a) property is used solely to store raw or finished goods and no known environmental issues exist on or near the site; and (b) leases of residential or office facilities, unless lease terms warrant such an assessment
EOSH due diligence may be required for transactions that do not necessarily involve purchase or sale of real estatedepending on the deal. Resolve the level of EOSH due diligence required for transactions beyond those listed by consulting with the due diligence team, the Company’s Environment & Water Resources Department and Legal Division /
  • Conduct EOSH due diligence for all real estate in question before completing the following transactions
1)Acquiring any real property
2)Selling real property
3)Leasing property for manufacturing, R & D or maintenance purposes
4)Leasing property for other purposes. ( e.g. warehouse / distr. ) for one year or longer
  • Assessment to be conducted by qualified, experienced professionals :
Phase 1: qualified associates or outside consultants
Phase 2: qualified outside consultants only
  • Written report for all EOSH due diligence assessments to be retained permanently
/ E + S
2 /

Does Due Diligence assessment follow the Company’s requirements for EOSH Due Diligence?

EOSH due diligence assessments typically have one to three phases .Most due diligence assessments involve only a phase I. Whether the assessment should proceed to a phase 2 or 3 will depend on the specific facts and circumstances involved. See full document for applicability of Phase 2 & 3 /
  • Assessments consist at least of a Phase 1 evaluation
  • Phase one evaluation is consistent with the latest version of ASTM E 1527-05 and 1528-05 or other equivalent internationally recognized standards
  • Any Phase 1 assessment must include the following parts as a minimum
Review plant or property records and permits pertaining to EOSH issues
Interview key personnel and other key people
Assessment of the property and surroundings
Review of government records pertaining to the EOSH permits, compliance and performance of the facility
Review of historical records
Evaluation of wetlands and endangered species
Evaluation of compliance with applicable EOSH legal requirements
Evaluation of the facility’s or operation’s water supply to include
-Access to water ( legal right and permit )
-Availability of water
-Quality of the source water
-Social and community issues ( e.g. impact of current or forecasted water withdrawals on local water supplies…)
- Identification and evaluation of any NGO or community activism in the local area
-Evaluation of the presence and condition of the OSH controls employed at those facilities and/or operations
-Summary of actual and potential EOSH risks and issues
-Estimate of the financial impact of identified EOSH risks and issues
  • Report must be completed under a Company’s associate’s direction or its divisions, subsidiaries, agents or affiliates.
  • Phase 2 assessments required whenever Phase 1 results show the property may be environmentally contaminated
/
E + S
E + S
E only

S
E only
3 /

Has the operation established a Corrective Action Plan to address each EOSH issue and risk ?

/
  • Operation has a corrective action plan ( CAP ) which addresses all the EOSH findings identified during the EOSH due diligence
  • For each recommendation made in the CAP a responsible person is designated and an estimated completion date provided
  • Money is budgeted in the operations business plan to implement the CAP
  • Implementation of the CAP is followed up on a regularly basis
/ E+S

4) Comments & Remarks:

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Document nr.: GAP-COM-eKO-DDr-EE&MEEUCONFIDENTIALRevision date:030/101/1002/20087/2006

Edition nr.: 10.35Page 1 of 2Revised by:RSUTK

Reviewed by: RSU